MOHAN PAL,HALDWANI, NAINITAL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HALDWANI, ACIT-DCIT, CENTRAL CIRCLE, HALDWANI

ITA 83/DDN/2024Status: DisposedITAT Dehradun12 March 2026AY 2013-14Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)15 pages
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What did the Tribunal hold?

The Tribunal held that the satisfaction note recorded by the AO was improper as it did not explicitly state that the seized material had a "bearing on the determination of the total income of such other person". Relying on the Delhi High Court's decision in Saksham Commodities Ltd., the Tribunal quashed the assessment orders.

What were the facts?

The assessee filed appeals against assessment orders passed under Section 153C of the Income Tax Act. The primary contention was that the satisfaction note recorded by the Assessing Officer (AO) for initiating proceedings under Section 153C was invalid.

What were the issues?

Whether the satisfaction recorded by the AO for initiating proceedings under Section 153C was valid and whether it explicitly mentioned the bearing of seized material on the assessee's total income.

Which sections of the Income-tax Act were involved?

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

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Cases cited in this judgment(2)Show list

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Income Tax Appellate Tribunal, DEHRADUN “DB” BENCH: DEHRADUN

Before: SHRI YOGESH KUMAR U.S. & SHRI MANISH AGARWAL

For Appellant: Shri Kalrav Mehrotra, Adv. &, Shri Shubham Bansal, Adv
For Respondent: Ms. Poonam Sharma, CIT DR
Hearing: 11.03.2026Pronounced: 12.03.2026

PER BENCH The captioned three appeals are filed by assessee against the separate orders dated 16.04.2024, 16.04.2024 and 18.04.2024 by Ld. Commissioner of Income Tax (A), Lucknow-3 [“Ld. CIT(A)”] passed u/s 250 of the Income Tax Act, 1961 [“the Act”] arising out of assessment orders, all dated 28.12.2019 passed u/s 143(3) r.w.s. 153C of the Act pertaining to Assessment Year 2013-14 to 2015-16 respectively.

2.

Ld.AR for the assessee filed an application for admission of additional grounds of appeal and contended containing that these additional grounds of appeal are purely legal in nature and required

ITA No. 83 to 85/DDN/2024

no investigation, th

The order continues below.

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