SHABNAM BHARATINDER SINGH,DELHI vs. DCIT,CENTRAL CIRCLE-32, DELHI

ITA 3141/DEL/2025Status: DisposedITAT Delhi12 December 2025AY 2018-19Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)16 pages
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What did the Tribunal hold?

The Tribunal held that the satisfaction recorded by the AO for initiating proceedings under Section 153C was invalid as it did not demonstrate that the seized material had a bearing on the determination of the assessee's total income. Consequently, the proceedings initiated under Section 153C and the consequent assessment orders were quashed.

What were the facts?

Proceedings under Section 153C were initiated against the assessee based on certain diary entries found during a search on a third party. The Assessing Officer (AO) recorded satisfaction that the documents pertained to the assessee, but failed to establish that these entries had a bearing on the assessee's total income.

What were the issues?

Whether the satisfaction recorded by the AO for initiating proceedings under Section 153C was valid, and if the seized material had a bearing on the assessee's total income.

Which sections of the Income-tax Act were involved?

Section 153C,Section 143(3)

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Cases cited in this judgment(5)Show list

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Income Tax Appellate Tribunal, DELHI “E” BENCH: NEW DELHI

Before: SHRI SUDHIR KUMAR & SHRI MANISH AGARWAL

For Appellant: Ms. Vibhooti Malhotra, Adv
For Respondent: Shri Sanjay Kumar, CIT DR
Hearing: 18.09.2025Pronounced: 12.12.2025

PER MANISH AGARWAL, AM : The captioned appeals are filed by assessee against the separate orders, both dated 17.03.2025 by Ld. Commissioner of Income Tax (A)-30, NewDelhi [“Ld. CIT(A)”] in Appeal No. 30/10352/2017-18 and in Appeal No. 30/10590/2018-19 passed u/s 250 of the Income Tax Act, 1961 [“the Act”] arising out of assessment orders, both dated 30.03.2023 passed u/s 153C r.w.s 143(3) of the Act pertaining to Assessment Years 2018-19 & 2019- 20 respectively.

2.

As both the captioned appeals filed by the assessee have similar issues which are inter-linked, inter-connected and this fact has been admitted by both the parties during the course of hearing

The order continues below.

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