ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, PATNA vs. PATNA IRON PVT. LTD., PATNA

ITA 373/PAT/2025Status: DisposedITAT Patna26 February 2026AY 2020-21Bench: SHRI DUVVURU RL REDDY (Vice President), SHRI RAJESH KUMAR (Accountant Member)16 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that additions based on documents seized from a third party can only be made if proceedings are initiated under Section 153C. Since proceedings were initiated under Section 153A, the assessment was deemed invalid.

What were the facts?

During a search operation, incriminating documents were found from a third party. The Assessing Officer (AO) made additions based on these documents, initiating proceedings under Section 153A. The assessee argued that proceedings should have been under Section 153C as the documents were seized from someone else.

What were the issues?

Whether additions made based on documents seized from a third party are valid when assessment proceedings were initiated under Section 153A instead of Section 153C.

Which sections of the Income-tax Act were involved?

Section 153A,Section 153C

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Cases cited in this judgment(9)Show list

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Income Tax Appellate Tribunal, “DB” BENCH, PATNA

Before: SHRI DUVVURU RL REDDY, VP & SHRI RAJESH KUMAR, AM Shri Manish Rastogi, AR

For Appellant: Shri Manish Rastogi, AR
For Respondent: Md. A.H. Chowdhary, DR
Hearing: 27.11.2025Pronounced: 26.02.2025

Per Rajesh Kumar, AM:

These appeals of two different assessee’sappeal by the Revenue are against the order of the Comm

The order continues below.

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