KRISH PACKAGING PVT LTD,NEW DELHI vs. DCIT CENTRAL CIRCLE, NOIDA

ITA 3942/DEL/2019Status: DisposedITAT Delhi13 March 2026AY 2011-12Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI NAVEEN CHANDRA (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the invocation of Section 153C requires the Assessing Officer (AO) to be satisfied that the recovered material has a bearing on the determination of total income for a specific Assessment Year. The Tribunal found that the satisfaction notes in this case failed to record reasons as to how the discovered material pertained to the relevant AY and impacted its total income. Therefore, the Tribunal quashed the reassessment order.

What were the facts?

The assessee preferred an appeal against the order passed by the Ld. Commissioner of Income Tax(A)-IV, Kanpur, which arose out of an assessment order passed by the DCIT under Section 143(3)/153C of the Income Tax Act, 1961 for Assessment Year 2011-12. The assessee raised an additional ground alleging that the assessment order was without jurisdiction as the proceedings under Section 153C were initiated without satisfying the statutory pre-conditions, specifically without recording a satisfaction note.

What were the issues?

Whether the proceedings initiated under Section 153C of the Income Tax Act are valid without a proper satisfaction note from the Assessing Officer regarding the bearing of recovered material on the total income of the relevant Assessment Year.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 153C,Section 69,Section 153A

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Income Tax Appellate Tribunal, “C” BENCH, DELHI

Before: SHRI ANUBHAV SHARMA & SHRI NAVEEN CHANDRA

For Appellant: Adv. Sh. Shailesh Gupta, CA, Adv. (virtual)
Hearing: 10.03.2026Pronounced: 13.3.2025

PER ANUBHAV SHARMA, JM:

This appeal is preferred by the assessee against the order dated

28.02.

2019 of the Ld. Commissioner of Income Tax(A)-IV, Kanpur

(hereinafter referred as Ld. First Appellate Authority or in short Ld. ‘FAA’)

in Appeal No : CIT(A)-IV/11778/DCIT-CC/Noida/2016-17/918 arising out

of the order dated 18.03.2016 u/s 143(3)/153C of the Income Tax Act, 1961

(hereinafter referred to as ‘the Act’) passed by the DCIT,CC, Noida for AY:

2011-12. 2. On hearing both

The order continues below.

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