PAL MINERAL INDUSTRIES (P) LIMITED,HALDWANI vs. DC/ACIT, CENTRAL CIRCLE, HALDWANI, HALDWANI

ITA 106/DDN/2025Status: DisposedITAT Dehradun12 March 2026AY 2013-2014Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)15 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer's satisfaction note for initiating proceedings under Section 153C was improper because it did not explicitly state that the seized material had a bearing on the determination of the assessee's total income. This failure vitiates the assessment.

What were the facts?

The assessee filed appeals after a delay, which was condoned. The assessee also sought to raise additional grounds of appeal concerning the validity of proceedings under Section 153C.

What were the issues?

The key issue was whether the satisfaction note recorded by the Assessing Officer for initiating proceedings under Section 153C was valid, specifically regarding the requirement that seized material must have a bearing on the determination of 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 appeals are filed by assessee against the orders, both dated 29.03.2025 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 order, both dated 29.12.2019 passed u/s 143(3) r.w.s. 153C of the Act pertaining to Assessment Year 2014-15 and 2013-14 respectively.

2.

Both appeals filed delayed by 08 days for which an affidavit is filed explaining the circumstances for the delay. It is stated that the assessee and its counsel are placed at two different cities therefore,

ITA No. 105 & 106/DDN/2024

the appeal could not b

The order continues below.

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