UMAPATHY SRINIVASA GOWDA,BENGALURU vs. DCIT, CENTRAL CIRCLE-2(1), BENGALURU

ITA 369/BANG/2026Status: DisposedITAT Bangalore24 July 2026AY 2019-2015 pages
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What were the facts?

The assessee's assessments were completed under Section 153C following a search operation. The assessee argued that the Section 153C proceedings were invalid as the notice was issued after the insertion of Section 153C(3), which restricted its applicability. The Revenue contended that the original search date should be considered.

What did the Tribunal hold?

The Tribunal held that for an 'other person' under Section 153C, the deemed date of initiation of search, based on the receipt of seized material and recording of satisfaction, governs the applicability of Section 153C(3). Since this deemed date fell after the cut-off date of April 1, 2021, the proceedings under Section 153C were without jurisdiction.

What were the issues?

Whether proceedings under Section 153C are valid when the deemed date of initiation for an 'other person' falls after the cut-off date specified in Section 153C(3), despite the original search occurring earlier.

Which sections of the Income-tax Act were involved?

Section 153C,Section 132,Section 153C(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI SANDEEP SINGH KARHAIL

For Respondent: Shri N.S Shashidhara, CIT DR, Shri Pradeep. S, Addl. CIT

PER BENCH: -

1.

All These 7 appeals are filed by Shri Umapathy Srinivas Gowda [ the Assessee/ Appellant] relate to assessment years 2013-14 to 2019-20 and arise from assessment orders passed pursuant to search proceedings under the Income-tax Act., involving similar issues, having common arguments, therefore after adjudicating the

The order continues below.

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