KASIREDDY RANADHEER REDDY,BANGALORE vs. ACIT, CENTRAL CIRCLE-2(1), BENGALURU

ITA 883/BANG/2025Status: DisposedITAT Bangalore02 February 2026AY 2011-12Bench: 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 'dumb document' without corroborative evidence cannot be the sole basis for an addition. Furthermore, the assessment was invalid as it was framed under Section 143(3) instead of the mandatory Section 153C when seized material from a third-party search was involved.

What were the facts?

During a search at a third party's premises, documents related to the assessee's alleged undisclosed income from money lending were found. The Assessing Officer made additions based on these documents, which the assessee claimed were not theirs and pertained to earlier years.

What were the issues?

Whether additions can be made solely on the basis of a 'dumb document' found during a search, and whether assessment proceedings were correctly initiated under Section 153C when material was seized from a third party.

Which sections of the Income-tax Act were involved?

Section 132,Section 69,Section 132(4A),Section 292C,Section 153C,Section 143(3)

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Income Tax Appellate Tribunal, ‘A’ BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI SOUNDARARAJAN K

For Appellant: Shri Shivprasad Reddy, AR &, Shri B.S Balachandran, Advocate
For Respondent: Shri N Balusamy, JCIT (DR)
Hearing: 17.12.2025Pronounced: 02.02.2026

PER WASEEM AHMED, ACCOUNTANT MEMBER:

These 6 appeals, filed by the assessee against the separate order of the learned Commissioner of Income Tax (Appeal) (hereafter- learned CIT(A)) under the provision of section 259 of the Income Tax Act, 1961 (hereafter- the Act), were heard together.

First, we take up ITA No. 882/Bang/2025 pertaining to AY 2010-11

ITA No.882 to 887/Bang/2025 2. The assessee in the memo of appeal raised multiple grounds numbered 1 to 7 and sub-grounds thereunder, which we, for the sake of brevity, are n

The order continues below.

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