FAYAZ MOHAMMED,HYDERABAD vs. DCIT, CENTRAL CIRCLE 2(4), HYDERABAD, HYDERABAD

ITA 1671/HYD/2025Status: DisposedITAT Hyderabad25 February 2026AY 2017-1816 pages
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What did the Tribunal hold?

The Tribunal held that the notice issued under section 153C of the Act was beyond the prescribed limitation period, making it invalid. Consequently, the assessment order passed under section 153C was quashed.

What were the facts?

A search operation was conducted on M/s. Skill Promoters, and seized material indicated information pertaining to the assessee for multiple assessment years. The Assessing Officer (AO) initiated proceedings under section 153C based on a satisfaction note and issued a notice. The AO made an addition of Rs. 2 lakhs as unexplained money for the purchase of property.

What were the issues?

Whether the notice issued under section 153C was within the prescribed time limit for initiating proceedings. Whether additions made under section 69 were justified in light of the invalidity of the section 153C proceedings.

Which sections of the Income-tax Act were involved?

Section 153C,Section 69

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ITA Nos 1671 and 1672 of 2025 Fayaz Mohammed

2.

The assessee has raised the following grounds of appeal:

Sno. Grounds of Appeal T

1.

The Order of the Ld. CIT (A) u/s 250 of the Act dt. 08.08.2025 for the AY 2017-18 is erroneous both on facts and in law to the extent the order is prejudicial to the interests of the appellant.

2.

The Ld. CIT(A) has erred in dismissing the appeal of the assessee without actually considering the submissions of the assessee and without appreciating the facts and circumstances of the case which is invalid and bad in law.

3.

The Ld. CIT(A) ought to have considered that the common satisfaction note was recorded for the assessment years 2014-15 to 2020-21, which is bad in law and therefore, the notice u/s 153C for the AY 2017-18 is invalid and the assessment completed u/s 153C deserves to be annulled.

4.

The Ld. CIT(A) ought to have appreciated that that there is no proper recording of satisfaction note in the appellant's case for invoking the provisions of section 153C of the Act and that consolidated satisfaction note recorded for different assessment years would vitiate entire assessment proceedings.

5.

The Ld. CIT(A) ought to have considered that the

The order continues below.

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