SANCHAR NEST SAHAKARI AWAS SAMITI LIMITED,GHAZIABAD vs. DCIT /ACIT CENTRAL CIRCLE, GHAZIABAD

ITA 1868/DEL/2026Status: DisposedITAT Delhi05 August 2026AY 2014-158 pages
AI SummaryAllowed

What were the facts?

A search was conducted on the Alankit Group, and subsequently, seized material and a satisfaction note were handed over to the Assessing Officer (AO) for initiating proceedings under Section 153C. The AO made additions to the assessee's income for AYs 2014-15, 2015-16, and 2016-17, which were upheld by the CIT(A).

What did the Tribunal hold?

The Tribunal held that the proceedings under Section 153C were not permissible as the date of handing over of the seized material to the AO occurred after April 1, 2021, making the notice invalid as per Section 153C(3). Consequently, the assessment orders were quashed.

What were the issues?

The primary issue was the validity of the notice issued under Section 153C, specifically whether it was issued in accordance with the amended provisions of Section 153C(3) concerning the date of search initiation for non-searched persons.

Which sections of the Income-tax Act were involved?

Section 153C,Section 153C(3),Section 68,Section 115BBE,Section 69C

AI-generated summary — verify with the full judgment below

ITA Nos.1868 to 1870/DEL/2026 SANCHAR NEST SAHAKARI AWAS SAMITI LIMITED IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “A” NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER Assessment Year: 2014-15 SANCHAR NEST SAHAKARI AWAS SAMITI Vs. DCIT/ACIT, LIMITED, Central Circle, ITO, 206-207, Ansal Satyam, RDC, Raj Nagar, CGO Complex-1, Hapur Ghaziabad, Uttar Pradesh 201001. Chungi, Ghaziabad, Uttar PAN No. AAGAS0241Q Pradesh 201001. Appellant Respondent Assessment Year: 2015-16 SANCHAR NEST SAHAKARI AWAS SAMITI Vs. DCIT/ACIT, LIMITED, Central Circle, ITO, 206-207, Ansal Satyam, RDC, Raj Nagar, CGO Complex-1, Hapur Ghaziabad, Uttar Pradesh 201001. Chungi, Ghaziabad, Uttar PAN No. AAGAS0241Q Pradesh 201001. Appellant Respondent & Assessment Year: 2016-17 SANCHAR NEST SAHAKARI AWAS SAMITI Vs. DCIT/ACIT, LIMITED, Central Circle, ITO, 206-207, Ansal Satyam, RDC, Raj Nagar, CGO Complex-1, Hapur Ghaziabad, Uttar Pradesh 201001. Chungi, Ghaziabad, Uttar PAN No. AAGAS0241Q Pradesh 201001. Appellant Respondent Assessee by Shri Akhilesh Kumar, AR & Shri Govind Agarwal, Adv.

Revenue by Shri Jitender Singh, CIT DR Date of hearing: 16.07.2026 Pronouncem

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