MAMATA AJILA,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

ITA 1984/BANG/2025Status: DisposedITAT Bangalore12 August 2026AY 2017-1815 pages
AI SummaryAllowed

What were the facts?

A search action under section 132 was conducted on the assessee's premises, leading to the seizure of incriminating documents. The Assessing Officer (AO) subsequently issued notices under section 153C, making additions to the assessee's income. The assessee appealed against these additions.

What did the Tribunal hold?

The Tribunal held that a common satisfaction note for multiple assessment years vitiates the entire assessment proceedings, as per the jurisdictional High Court's decision. Additionally, the assessment for AY 2018-19 was incorrectly made under section 143(3) instead of section 153C.

What were the issues?

The primary issues were the validity of assessment proceedings initiated under section 153C due to a common satisfaction note and the AO's jurisdiction in issuing notices and making assessments.

Which sections of the Income-tax Act were involved?

Section 153C,Section 143(3),Section 132,Section 120(4)(b)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH : BANGALORE

Before: SHRI BALAKRISHNAN S & SHRI KESHAV DUBEY

For Appellant: Shri. V. Chandrashekar, Advocate
For Respondent: Shri. N. S. Shashidhara, CIT(DR)(ITAT), Bengaluru
Hearing: 11.06.2026Pronounced: 12.08.2026

Per Balakrishnan S, Accountant Member :

These appeals are filed by the assessee against the order of learned Commissioner of Income Tax – Appeals – 11, Bengaluru, vide appeal Nos. as detailed below, for the Assessment Years 2014-15 to 2018-19, arising out of the order passed under section 153C r.w.s. 143(3) r.w.s. 153D dated 24.12.2019 for the Assessment Years 2014-15 to 2017-18 and 143(3) r.w.s. 153D dated 24.12.2019 for the Assessment Year 2018-19. ITA Nos.1981 to 1985/Bang/2025 2. Since the assessee is same, and the issues are common and identical, these appea

The order continues below.

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