TEJAL KAUSHIK MAISHERI,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(1), HYDERABAD

ITA 2210/HYD/2025Status: DisposedITAT Hyderabad17 June 2026AY 2019-2017 pages
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What were the facts?

During a search operation, an agreement of sale and a receipt for Rs. 50 lacs were found, indicating a cash receipt by the assessees. The property was later sold to a different entity, leading the AO to treat the Rs. 50 lacs as unexplained cash receipt under Section 69A.

What did the Tribunal hold?

The Tribunal held that the invocation of Section 153C was valid as the search was initiated before April 1, 2021, and the deeming fiction regarding the date of receipt of seized material applies only for abatement of assessment years, not for the applicability of Section 153C itself. The Tribunal also found no merit in the contention regarding mechanical approval under Section 153D.

What were the issues?

The key issues were the validity of the assessment under Section 153C due to the date of receipt of seized material and the validity of the approval granted under Section 153D. The Tribunal also considered the addition made under Section 69A.

Which sections of the Income-tax Act were involved?

Section 153C,Section 69A,Section 153D,Section 132,Section 148,Section 153A,Section 153C(1),Section 153C(3),Section 132A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad ‘B’ Bench, Hyderabad

For Appellant: Ms Uppaluri Meena, Sr-AR

Heard together (2 matters)

I.T.A. No.2210/Hyd/2025
I.T.A. No.2211/Hyd/2025

Read from the judgment's own cause title. This page is filed under one of them.

PER RAVISH SOOD, JM: The present appeals filed by the abovementioned assessees are directed against the respec

The order continues below.

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