DCIT CENTER. CIRCLE-AMRAVATI, NAGPUR vs. SANDEEP HARIBHAU PUNDKAR, AKOLA

ITA 364/NAG/2025Status: DisposedITAT Nagpur16 June 2026AY 2019-208 pages
AI SummaryAllowed

What were the facts?

The Revenue appealed an order of the CIT(A), while the assessee filed a cross-objection challenging the assumption of jurisdiction under Section 153C. The assessee argued that the satisfaction note was recorded after April 1, 2021, making Section 153C(3) applicable.

What did the Tribunal hold?

The Tribunal held that the date of recording the satisfaction note is crucial, and since it was recorded after April 1, 2021, Section 153C(3) of the Act applies. Consequently, the assessment order passed under Section 153C was vitiated.

What were the issues?

Whether the assessment proceedings initiated under Section 153C were valid when the satisfaction note was recorded after April 1, 2021, and whether the consolidated satisfaction note was legally sufficient.

Which sections of the Income-tax Act were involved?

Section 153C,Section 153C(3),Section 132,Section 132A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, NAGPUR BENCH :: NAGPUR

Before: SHRI ANUBHAV SHARMA & SHRI KHETTRA MOHAN ROY

For Appellant: Shri Kapil Hirani, Advocate
For Respondent: Shri Pankaj Kumar, CIT-DR
Hearing: 12.06.2026Pronounced: 16.06.2026

Heard together (2 matters)

C.O.No. 14/NAG/2026
ITA No. 364/NAG/2025

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

PER ANUBHAV SHARMA, JM:

This appeal filed by the Revenue and the Cross Objection filed by the assessee are directed against the order of Commissioner of Income Tax (Appeals)-3, Nagpur (for short, “CIT(A)”), dated 25/03/2025 passed under section 250 of the Income Tax Act, 1961 (for short, “Act”) which is emanating from the assessment order dated 29.09.2021 passed u/s. 143(3) r.w.s. 153C of the Act by the ACIT, Central Circle, Akola for the Assessment Year (AY) 2019-20. 2.

The order continues below.

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