ACEMONEY (INDIA) LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI

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ITA 821/DEL/2026Status: HeardITAT Delhi09 July 2026AY 2019-20203 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 failure of the Assessing Officer to explicitly state that the seized material had a bearing on the assessee's income determination is fatal to the validity of the proceedings. Therefore, the assessment under Section 153C was quashed.

What were the facts?

The Assessing Officer recorded satisfaction for proceedings under Section 153C based on a search in the Alankit group of cases. The satisfaction note did not explicitly state that the seized material had a bearing on the determination of the assessee's total taxable income.

What were the issues?

Whether the satisfaction recorded by the Assessing Officer under Section 153C is valid if it does not explicitly state that the seized material has a bearing on the determination of the assessee's total 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 KRINWANT SAHAY

Hearing: 08.07.2026Pronounced: 08.07.2026

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘H’, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER ITA No. 821/Del/2026 Assessment Year: 2019-20

Acemoney (India) Limited Vs Deputy Commissioner of WP-501D, 2nd Floor, Unit No. 203A, Income Tax, Shiv Market, Ashok Vihar, Room No. 327, ARA Centre, Delhi- 110052 Jhandewala Extention, New Delhi- 110055 (APPELLANT) (RESPONDENT) PAN No. AAOCA5278M

Assessee by: Sh. Rohit Singal, CA Revenue by : Sh. Bhopal Singh, CIT DR

Date of Hearing: 08.07.2026 Date of Pronouncement: 08.07.2026 ORDER

This assessee’s appeal for Assessment Year 2019-20 arises against the Commissioner of Income Tax(Appeals) (for short, ‘CIT(A)’), Delhi-25’s order dated 14.01.2026 passed in DIN & order No. ITBA/APL/S/250/2025-26/1084782851(1), involving proceedings u/s 153C of the Income Tax Act, 1961; hereinafter referred to as, “the Act”.

Heard both the parties at length. Case file perused.

2 2. Coming to the first and foremost legal issue arising for our apt adjudication herein, we note that the learned departmental authorities had carried out the search in question on 18.10.2019 in Alankit group of cases. And that the Assessing Officer of the said searched party recorded his section 153C of satisfaction on 24.06.2022 that the assessee was the beneficiary of accommodation entries amounting to Rs. 15,00,000/- , in the relevant previous year (Page-14 in the case records). The is no indication that he had made it clear therein that the said material had “a bearing” in determination of the assessee’s total taxable income.

3.

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.

4.

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) 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. The impugned section 153C assessment is quashed accordingly.

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

5.

This assessee’s appeal is allowed.

Order Pronounced in the Open Court on 08.07.2026.

Sd/- Sd/- (KRINWANT SAHAY) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 09.07.2026 *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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