ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-25, DELHI, DELHI vs. PRATYAKSH APPARELS PRIVATE LIMITED, DELHI
What did the Tribunal hold?
The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.
What were the facts?
The appeals involved assessments framed under Section 153C of the Income Tax Act, 1961. The core issue was the validity of these assessments due to alleged lack of incriminating material and improper satisfaction recorded by the Assessing Officer.
What were the issues?
Whether assessments framed under Section 153C are valid when the Assessing Officer's satisfaction is improper and lacks explicit mention of the seized material's bearing on total income determination.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Heard together (16 matters)
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IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER
ITA No.5378/Del/2025 along with C.O. No.205/Del/2026 Assessment Year: 2011-12 With ITA No.5379/Del/2025 along with C.O. No.206/Del/2026 Assessment Year: 2012-13 With ITA No.5380/Del/2025 along with C.O. No.207/Del/2026 Assessment Year: 2013-14 With ITA No.5381/Del/2025 along with C.O. No.208/Del/2026 Assessment Year: 2014-15 With ITA No.5382/Del/2025 along with C.O. No.209/Del/2026 Assessment Year: 2015-16 With ITA No.5383/Del/2025 along with C.O. No.210/Del/2026 Assessment Year: 2016-17 With ITA No.5384/Del/2025 along with C.O. No.211/Del/2026 Assessment Year: 2017-18 With ITA No. 6149/Del/2025 ; Assessment Year: 2015-16 With ITA No. 6927/Del/2025 ; Assessment Year: 2018-19 Central Circle-25, F-3, 1st Floor, TDI Fun New Delhi Republic Mall, Moti Nagar, New Delhi- 110 015 PAN: AAHCA5444J (Appellant) (Respondent/Cross-objector)
ITA No. 8051 to 8057/Del/2025; Assessment Years: 2013-14 to 2019-20 Vs. Pratyaksh ACIT, Apparels Private Central Circle-25, Limited New Delhi H-84, 1st Floor, Shivaji Pa
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More judgments on Section 153C
- Neepaben Sunnybhai Motwani, Rajkot vs Income Tax Officer, RajkotITA 875/RJT/2026[2021-22]Status: Disposed19 Oct 2026AY 2021-22
- Neepaben Sunnybhai Motwani, Rajkot vs The Income Tax Officer, RajkotITA 874/RJT/2026[2020-21]Status: Disposed19 Oct 2026AY 2020-21
- Venish Vinodray Lalani, Rajkot vs Income Tax Officer, MorbiITA 197/RJT/2026[2019-20]Status: Disposed19 Oct 2026AY 2019-20
- Ajay Singh, Kota vs DCIT, Central Circle, KotaITA 495/JPR/2026[2016-17]Status: Disposed13 Oct 2026AY 2016-17
- Dineshkumar Chhaganlal Manavadaria, Junagadh vs ITO Ward 1, JunagadhITA 837/RJT/2025[2020-21]Status: Disposed9 Oct 2026AY 2020-21
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