ADITI INFRABUILD AND SERVICES LTD.,DELHI vs. DCIT, CENTRAL CIRCLE-30, DELHI

ITA 5970/DEL/2024Status: DisposedITAT Delhi21 January 2026AY 2019-2016 pages
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What did the Tribunal hold?

The ITAT held that the satisfaction recorded by the AO for initiating proceedings under Section 153C must explicitly state that the seized material has a bearing on the determination of the assessee's total income. Following the jurisdictional High Court's decision in Saksham Commodities Ltd., the Tribunal found the AO's satisfaction to be invalid as it lacked this crucial element.

What were the facts?

Proceedings under Section 153C were initiated against the assessee based on Tally data seized during a search on a third party, Sanjay Jain. The Assessing Officer (AO) made additions, which were upheld by the CIT(A). The assessee appealed to the Income Tax Appellate Tribunal (ITAT).

What were the issues?

Validity of satisfaction note recorded by the AO for initiating proceedings u/s 153C, and whether seized material had a bearing on the determination of the assessee's total income.

Which sections of the Income-tax Act were involved?

Section 153C,Section 143(3),Section 132,Section 250,Section 153A,Section 37,Section 153D,Section 131,Section 132(4),Section 194

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI A BENCH: NEW DELHI

Before: SHRI RAJ KUMAR CHAUHAN & SHRI MANISH AGARWAL

For Appellant: Shri Amit Goel, CA &, Shri Pranav Yadav, Adv
For Respondent: Shri Jitender Singh, CIT DR
Hearing: 18.12.2025Pronounced: 21.01.2026

PER MANISH AGARWAL, AM : The present appeal is filed by assessee against the order dated 16.12.2023 of Ld. Commissioner of Income Tax (A)-30, New Delhi [“Ld. CIT(A)”] in Appeal No.30/10574/2018-19 passed u/s 250 of the Income Tax Act, 1961 [“the Act”] arising out of assessment order dated 29.03.2023 passed u/s 153C r.w.s. 143(3) of the Act pertaining to Assessment Year 2019-20. 2. Brief facts of the case are that a search and seizure operation u/s 132 of the Act was conducted on 26.10.2020 in the cases of Sanjay Jain & Mehta Group at various residential and business premises. During the course of sear

The order continues below.

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