PRAMOD SUBBIAHNAPALYA VENKATPATHI,BENGALURU vs. DCIT, CENTRAL CIRCLE-2(1), BANGALORE

ITA 678/BANG/2025Status: DisposedITAT Bangalore10 March 2026AY 2018-19Bench: SHRI WASEEM AHMED (Accountant Member), SHRI SOUNDARARAJAN K. (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that a separate satisfaction note is required for each Assessment Year under Section 153C of the IT Act, and a consolidated note vitiates the assessment proceedings. Relying on the judgment of the Hon'ble Jurisdictional High Court, which was affirmed by the Supreme Court, the Tribunal found the notice issued u/s. 153C to be invalid.

What were the facts?

A search and seizure operation was conducted on the assessee's premises and premises of MG Charitable Trust. The AO issued notices u/s. 153C of the Act based on a common satisfaction note for A.Ys. 2015-16 to 2020-21. The assessee did not respond to the notices, and the AO made additions based on bank statements and a sale agreement, treating Rs. 6,00,000/- as unexplained money.

What were the issues?

Whether the notice issued u/s. 153C of the Act, based on a common satisfaction note for multiple assessment years, is valid. Whether additions made without incriminating documents are sustainable.

Which sections of the Income-tax Act were involved?

Section 153C,Section 132,Section 142(1),Section 69

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Cases cited in this judgment(3)Show list

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Income Tax Appellate Tribunal, ‘B’ BENCH : BANGALORE

Before: SHRI WASEEM AHMED & SHRI SOUNDARARAJAN K.

For Appellant: Shri Vinay Simha, CA
For Respondent: Shri Subramanian, JCIT-DR

PER BENCH

These are the six appeals filed by the assessee challenging the separate orders of Ld.CIT(A)-15, Bengaluru all dated 29/01/2025 in respect of the A.Ys. 2015-16 to 2020-21. The assessee had raised separate grounds in respect of each assessment years and filed twice additional grounds which are all in the nature of the legal ground. ITA Nos. 675 to 680/Bang/2025

2.

In the additional ground filed at the first time, the assessee had raised a legal plea that the AO had erred in making additions or disallowances when there are no incriminating documents seized at th

The order continues below.

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