DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. RAJAMANI GOBINATH, DINDIGUL

ITA 1542/CHNY/2025Status: DisposedITAT Chennai23 January 20267 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal noted that a coordinate bench had already quashed proceedings against Shri N R Viswanathan under Section 153C, holding that the seized material did not pertain to him and the AO's satisfaction was invalid. Following this precedent, the Tribunal held that the material seized could not be said to belong or relate to the assessee, and thus the assessment orders were rightly quashed by the CIT(A).

What were the facts?

A search action on a third party, Shri CP Anbunathan, revealed account books with notings potentially related to coal commission received by the assessee on behalf of Shri N R Viswanathan. The Assessing Officer (AO) initiated proceedings under Section 153C based on this, treating the income protectively. No incriminating material was found on the assessee's premises.

What were the issues?

Whether the protective assessment and subsequent proceedings under Section 153C against the assessee were valid, given the lack of direct incriminating material and the prior quashing of similar proceedings against a related party.

Which sections of the Income-tax Act were involved?

Section 250,Section 132,Section 132(4),Section 153A,Section 153C,Section 139(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & SHRI S.R.RAGHUNATHA

Hearing: 29.10.2025Pronounced: 23.01.2026

PER BENCH: These appeals preferred by the Revenue and the cross objections of the assessee arise from the orders passed by the Learned Commissioner of Income Tax (Appeals)-18 (hereinafter referred to as ‘Ld.CIT(A)‘), Chennai, dated 29.03.2025 for Assessment Years (hereinafter referred to as ‘AY‘) 2014-

The order continues below.

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