DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, RANCHI, RANCHI vs. VIJAY KUMAR SAHU INFRASTRUCTURE PRIVATE LIMITED, RANCHI

ITA 258/RAN/2025Status: DisposedITAT Ranchi29 July 2026AY 2020-2125 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 153C was invalid because the assessee's AO did not record independent satisfaction. Following High Court precedents, the Tribunal quashed the notice and the consequential assessment.

What were the facts?

The assessee challenged proceedings initiated under Section 153C, arguing that the Assessing Officer (AO) of the searched person lacked independent satisfaction and that the assessee's AO also failed to record any satisfaction. Documents were seized during a search on a third party, leading to the initiation of 153C proceedings against the assessee.

What were the issues?

Whether proceedings under Section 153C are valid without independent satisfaction recorded by the assessee's Assessing Officer. Whether the satisfaction note of the searched person's AO is sufficient for initiating proceedings against the assessee.

Which sections of the Income-tax Act were involved?

Section 153C,Section 69C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: SHRI GEORGE MATHAN & SHRI RATNESH NANDAN SAHAY

For Appellant: Shri Devesh Poddar, A.R
For Respondent: Shri H. Robindro Singh, CIT-DR
Hearing: 29/07/2026Pronounced: 29/07/2026

PER: BENCH

1.

ITA No. 201/Ran/2025 is an appeal filed by the assessee and ITA No. 258/Ran/2025 is an appeal filed by the revenue against the order passed by the ld. CIT(A), Patna-3, Patna dated 17/04/2025 for the A.Y. 2020-21. 2. Shri Devesh Poddar, ld AR appeared for the assessee and H. Robindro Singh, ld. CIT-DR appeared for the revenue.

ITA No. 201 & 258/Ran/2025

3.

It was su

The order continues below.

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