GLOBAL MEDIKIT LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE-28, DELHI

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ITA 9050/DEL/2025Status: DisposedITAT Delhi10 July 2026AY 2014-153 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer's satisfaction note did not clearly indicate that the seized material had a bearing on the determination of the assessee's taxable income. This failure is fatal to the validity of the proceedings.

What were the facts?

The assessee's appeals relate to assessment years 2013-14 and 2014-15, initiated under Section 153C of the Income Tax Act. The primary contention is that the Assessing Officer failed to record proper satisfaction before initiating these proceedings.

What were the issues?

Whether the proceedings initiated under Section 153C are valid if the Assessing Officer's satisfaction note does not explicitly state that the seized material has a bearing on the determination of taxable income.

Which sections of the Income-tax Act were involved?

Section 153C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘H’, NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI SANJAY AWASTHI

Hearing: 01.07.2026Pronounced: 10.07.2026

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘H’, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER ITA Nos. 9049 & 9050/Del/2025 Assessment Year: 2013-14 & 2014-15

Global Medikit Limited Vs Deputy Commissioner of 3, Dr. G C Narang Marg, Income Tax Shakti Nagar, Central Circle-28, Roshan Ara Road, ARA Centre, Jhandewalan Delhi- 100007 Extn. New Delhi- 110005 (APPELLANT) (RESPONDENT) PAN No. AAECA7743D

Assessee by: Sh. Amit Goyal, CA Revenue by : Sh. Bhopal Singh, CIT DR Date of Hearing: 01.07.2026 Date of Pronouncement: 10.07.2026 ORDER These assessee’s twin appeals ITA Nos. 9049 & 9050/Del/2025; for assessment years 2013-14 & 2014-15, arise against Commissioner of Income Tax (Appeals) (in short, ‘CIT(A)’), Delhi-25’s orders dated 22.12.2025, passed in DIN & Order Nos. ITBA/APL/S/250/2025- 26/1083957610(1) & ITBA/APL/S/250/2025-26/1083957463(1), involving proceedings u/s 153C of the Income Tax Act, 1961; hereinafter referred to as, ‘the Act’, respectively.

Heard both the parties at length. Case file perused.

2 2. Learned counsel representing the assessee raises its first and foremost legal ground going to the root of the matter that this is a clearcut case of non-recording of a proper satisfaction u/s 153C of the Act which renders the twin assessments herein; both framed on 25.03.2003 has non-est ones in the eyes of law.

3.

That being the case, we hereby notice from a perusal of the case record that the assessee’s learned Assessing Officer had recorded his latter round of satisfaction on 14.02.2022 followed by his notice issued initiating the proceedings on 18.02.2022 in its case. And that the said satisfaction note nowhere makes it clear that the relevant seized material at “a bearing” on determination of the assessee’s total taxable income.

4.

Learned CIT(DR) vehement states in this factual backdrop that we ought to appreciate the totality of circumstances wherein such a satisfaction note may not always state that the corresponding seized material must have “a bearing” explicitly in his latter round of satisfaction.

5.

We are afraid that Revenue’s foregoing stand hardly deserves to be accepted once case law Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi). He has already settled the issue in the assessee’s favour that such a failure on the Assessing Officer’s part is very much fatal to validity of the impugned proceedings. Ordered accordingly.

3 All other remaining pleadings between the parties stand rendered academic.

6.

This assessee’s appeal is allowed. A copy of this common order be placed in the separate case files.

Order Pronounced in the Open Court on 10.07.2026.

Sd/- Sd/- (SANJAY AWASTHI) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 10.07.2026 *Pooja Mittal, Sr. PS* Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR

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