ACIT, CC-30, NEW DELHI, NEW DELHI vs. DEEPAK BUILDERS AND ENGINEERS INDIA LIMITED, DELHI

ITA 2100/DEL/2025Status: DisposedITAT Delhi01 December 2025AY 2020-216 pages
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What did the Tribunal hold?

The Tribunal found that the satisfaction note recorded by the Assessing Officer was not explicitly clear as to whether the seized material had a bearing on the determination of the total income of the assessee. Relying on a High Court decision, the Tribunal held that the recording of Section 153C satisfaction is not a mechanical exercise and an improper satisfaction vitiates the assessment.

What were the facts?

Proceedings under Section 153C r.w.s. 143(3) of the Income-tax Act were initiated against the assessee based on a search conducted on an entry operator. The Revenue argued that the satisfaction note for initiating these proceedings was validly recorded based on incriminating material found during the search.

What were the issues?

Validity of Section 153C proceedings due to improper satisfaction note by the Assessing Officer.

Which sections of the Income-tax Act were involved?

Section 153C,Section 143(3),Section 153A,Section 132,Section 131

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Income Tax Appellate Tribunal, DELHI BENCH: ‘E’ NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWAL

For Respondent: Ms. Amisha S. Gupta, CIT(DR)
Hearing: 01.12.2025Pronounced: 01.12.2025

PER SATBEER SINGH GODARA, JM These assessee’s and Revenue’s cross appeals ITA No. 875/Del/2025 and 2100/Del/2025 for assessment year 2020-21, arises against the Commissioner of Income Tax (Appeals)-30 [in short, the “CIT(A)”], Delhi’s order dated 20.12.2024 passed in case no. 30/10740/2019-20, involving proceedings under section 153C r.w.

The order continues below.

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