SH. MANISH DHARIWAL,KOTA vs. DCIT, CENTRAL CIRCLE, KOTA, KOTA

ITA 1772/JPR/2025Status: DisposedITAT Jaipur16 June 2026AY 2020-2113 pages
AI SummaryAllowed

What were the facts?

During a search action on a third party, information was received by the assessee's AO alleging cash payments for property purchases. This led to proceedings under Section 153C, with the AO issuing notices based on documents received after the search.

What did the Tribunal hold?

The Tribunal held that the proceedings under Section 153C were invalid because the AO received the relevant documents after the 'sunset clause' deadline of April 1, 2021. Therefore, the AO lacked jurisdiction.

What were the issues?

Whether the proceedings initiated under Section 153C are valid when the AO receives the seized documents after the statutory cut-off date specified in Section 153C(3)? Whether the addition made under Section 69 is justified based on the evidence?

Which sections of the Income-tax Act were involved?

Section 153C,Section 153C(3),Section 69

AI-generated summary — verify with the full judgment below

AY 2020-21

IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, "A" BENCH, JAIPUR BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER & & Co LLP, Chartered Central Circle, Kota, Accountants, 5th Floor, Milestone Rajasthan-324009 Building, Gandhinagar Turn, Tonk Road, Jaipur, Rajasthan-302015 PAN/GIR No: ABRPD3709M & Co LLP, Chartered Central Circle, Kota, Accountants, 5th Floor, Milestone Rajasthan-324009 Building, Gandhinagar Turn, Tonk Road, Jaipur, Rajasthan-302015 PAN/GIR No: AGTPD0046J Neetu Dhariwal, Kalani & Co LLP, Vs. DCIT, Chartered Accountants, 5th Floor, Central Circle, Kota, Milestone Building, Gandhinagar Rajasthan-324009 Turn, Tonk Road, Jaipur, Rajasthan 302015

PAN/GIR No: AHCPD0246J AY 2020-21

Appellant by : Shri P.C. Parwal, CA Respondent by : Shri Rajesh Ojha, CIT

Date of Hearing 24.03.2026 Date of Pronouncement 16.06.2026

[O R D E R]

Per Sanjay Garg, Judicial Member:

The captioned appeals have been preferred by the different but related assessees against the separate orders of even date 23.09.2025 of the Ld. Commissioner of Income Tax (Appeals) [herei

The order continues below.

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