Anil Kumar Gopikishan Arawal v. CIT

418 ITR 25High Court2019#4700 most cited

What is Anil Kumar Gopikishan Arawal v. CIT authority for?

Amended provisions of Section 153C of the Income Tax Act, 1961 apply where the search and seizure occurred after the amendment came into force.

25

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2020 to 2025.

Also referred to as

Anil Kumar Gopikishan Arawal · Section 153C · Section 153A · search and seizure · amended provisions · date of search · Income Tax Act

Sections most often in play

Section 132Section 153ASection 153CSection 132(4)Section 143(3)Section 292CSection 115BBESection 132(1A)

Issues it is cited on

section 153c(1)section 153a(1)(a)block periodsatisfaction notedocuments seizedincome escaping assessmentinterest u/s 234bsearch assessmentsection 132(1)section 158section 132aregular assessment

Judgments citing Anil Kumar Gopikishan Arawal v. CIT

PRASHANT SONI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-7, DELHI

In the result, the appeal of the assessee is allowed

ITA 2612/DEL/2022[2015-16]Status: DisposedITAT Delhi30 Dec 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanprashant Soni, Vs. Dcit, Central Circle 7, M-50, First Floor, Delhi. Guru Harkishan Nagar, Sunder Vihar, New Delhi – 110 087. (Pan : Basps5961H) (Appellant) (Respondent) Assessee By : Shri Ankit Kumar, Advocate Revenue By : Shri Jitender Singh, Cit Dr Date Of Hearing : 17.11.2025 Date Of Order : 30.12.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-24, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 30.08.2022 For Assessment Year 2015-16. 2. At The Outset, Ld. Ar Of The Assessee Raised Legal Issue Relating To Assumption Of Jurisdiction Under Section 153C Of The Income-Tax Act, 1961 (For Short ‘The Act’) By Raising Ground Nos.1 & 2 Which Read As Under :- “1. On The Facts & Circumstances Of The Case, The Order Passed By The Ld. Ao & Impugned Order Passed By The Cit (A) Is Bad Both In The Eye Of Law & On Facts.

For Appellant: Shri Ankit Kumar, AdvocateFor Respondent: Shri Jitender Singh, CIT DR
Section 132Section 132(4)Section 153ASection 153BSection 153CSection 292C

…dgment of Hon’ble Supreme Court in case of CIT v. Calcutta Knitwears reported in 362 ITR 673 and a copy of the circular is placed at pages 86-87 of JPB. The ld. AR of the assessee relied on the following judgments :- 6. (i) Anil Kumar Goptal Krishan Agarwal – 418 ITR 25 (Guj.); (ii) Bharat Bhushan Jain 370 ITR 695 (Del.); (iii) Radhey Shayam Bansal 337 ITR 217 (Del.); 4 7. With regard to the satisfaction recorded by the assessing officer of searched person do not satisfy the rigor of section 153C of the Act and is therefore illegal, invalid and without jurisdiction, he submitted that in respect of seized documen…

THE ITO-2 SURENDRANAGAR(REGULAR CHARGE WARD-4(2)(1)), AHMEDABAD vs. SHRI PRANAV PRAFULCHANDRA VORA,, AHMEDABAD

In the result, appeal filed by the Revenue is dismissed

ITA 183/AHD/2021[2011-12]Status: DisposedITAT Ahmedabad15 May 2025AY 2011-12

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

For Appellant: Shri Dhinal Shah, A.RFor Respondent: Shri Ketan Gajjar, Sr. DR
Section 132Section 153ASection 153CSection 250(6)Section 69

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE: SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER AND Ms. SUCHITRA KAMBLE, JUDICIAL MEMBER आयकर अपील सं./I.T.A. No. 183/Ahd/2021 ("नधा"रण वष" / Assessment Year : 2011-12) बनाम/ The Income Tax Officer Shri Pranav Prafulchandra Ward -2, Surendranagar Vora Vs. 3, Ashapura Park, Behind Vimalnath Society, Near Gokul Park Restaurant, Surendranagar "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : ACYPV7581R (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant by : Shri Dhinal Shah, A.R. ""यथ" क" ओर से/Respondent by : Shri Ketan Gajjar, Sr. DR Date of Hearing 23/04/2025…

DCIT CENTRAL CIRCLE-01, DELHI vs. DL HEERA BHAI JEWELLERY ARCADE PVT. LTD. , DELHI

ITA 61/DEL/2022[2017-18]Status: HeardITAT Delhi26 Mar 2024AY 2017-18

Bench: SHRI SAKTIJIT DEY, VICE PRESIDENT [AS (Third Member)

Section 143Section 143(3)Section 153ASection 153CSection 154

…. Sarwar Agency (P.) Ltd. [2017] 397 ITR 400 (Del. HC) (iii) ARN Infrastructure India Ltd. v. ACIT [2017] 394 ITR 569 (Del. HC) (iv) Karina Airlines International Limited v. ACIT ITA No.203/Del/2021 (Del.Trib.) (v) Anil Kumar Gopikishan Agrawal v. ACIT [2019] 418 ITR 25 (Guj. HC) (vi) Canyon Financial Services Ltd. v. ITO [2017] 399 ITR 202 (Del. HC) (vii) PCIT v. Dreamcity Buildwell (P.) Ltd. [2019] 417 ITR 617 (Del. HC) (viii) Shri Vinod Kumar v. DCIT, ITA No.2526/Del/2017 (Del. Trib.) (ix) Shri Sanjay Thakur v. DCIT, ITA No.3559/Del/2015 (Del. Trib.) (x) Mikado Realtors P. Ltd. v. PCIT, ITA No.50/Del/2021 (Del…

DL HEERA BHAI JEWELLERY ARCADE PVT. LTD. ,DELHI vs. ACIT CENTRAL CIRCLE-1, NEW DELHI

ITA 951/DEL/2021[2017-18]Status: HeardITAT Delhi26 Mar 2024AY 2017-18

Bench: SHRI SAKTIJIT DEY, VICE PRESIDENT [AS (Third Member)

Section 143Section 143(3)Section 153ASection 153CSection 154

…. Sarwar Agency (P.) Ltd. [2017] 397 ITR 400 (Del. HC) (iii) ARN Infrastructure India Ltd. v. ACIT [2017] 394 ITR 569 (Del. HC) (iv) Karina Airlines International Limited v. ACIT ITA No.203/Del/2021 (Del.Trib.) (v) Anil Kumar Gopikishan Agrawal v. ACIT [2019] 418 ITR 25 (Guj. HC) (vi) Canyon Financial Services Ltd. v. ITO [2017] 399 ITR 202 (Del. HC) (vii) PCIT v. Dreamcity Buildwell (P.) Ltd. [2019] 417 ITR 617 (Del. HC) (viii) Shri Vinod Kumar v. DCIT, ITA No.2526/Del/2017 (Del. Trib.) (ix) Shri Sanjay Thakur v. DCIT, ITA No.3559/Del/2015 (Del. Trib.) (x) Mikado Realtors P. Ltd. v. PCIT, ITA No.50/Del/2021 (Del…

SHREE GOPAL LANDCRAFT P.LTD,NEW DELHI vs. ACIT, CENTRAL CIRCLE-13, NEW DELHI

In the result, the appeals of the assessee are allowed in the manner as indicated above

ITA 1661/DEL/2022[2016-17]Status: DisposedITAT Delhi19 Oct 2023AY 2016-17

Bench: Shri Chandra Mohan Garg & Girish Agrawal

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H K Choudhary, CIT(DR)
Section 143(3)Section 153Section 153C

…de Finance Act, 2017. Thus, as per CBDT circular mentioned above, the amended provisions would not be applicable to the present case. Taking note of the aforesaid CBDT circular, the Hon’ble Gujarat High Court, in case of Anil Kumar Gopikishan Arawal Vs. CIT, (418 ITR 25), has held that the amended provisions of section 153C of the Act would apply where search and seizure is made after the amendment……” 8. Therefore, keeping in view the facts of the case that the date of search was 23.07.2015, date of recording satisfaction by the AO of searched person was 23.03.2018 and the date of recording of satisfaction by the…

SHREE GOPAL LANDCRAFT P.LTD,NEW DELHI vs. ACIT, CENTRAL CIRCLE-13, NEW DELHI

In the result, the appeals of the assessee are allowed in the manner as indicated above

ITA 1660/DEL/2022[2015-16]Status: DisposedITAT Delhi19 Oct 2023AY 2015-16

Bench: Shri Chandra Mohan Garg & Girish Agrawal

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H K Choudhary, CIT(DR)
Section 143(3)Section 153Section 153C

…de Finance Act, 2017. Thus, as per CBDT circular mentioned above, the amended provisions would not be applicable to the present case. Taking note of the aforesaid CBDT circular, the Hon’ble Gujarat High Court, in case of Anil Kumar Gopikishan Arawal Vs. CIT, (418 ITR 25), has held that the amended provisions of section 153C of the Act would apply where search and seizure is made after the amendment……” 8. Therefore, keeping in view the facts of the case that the date of search was 23.07.2015, date of recording satisfaction by the AO of searched person was 23.03.2018 and the date of recording of satisfaction by the…

SHREE GOPAL LANDCRAFT P.LTD,NEW DELHI vs. ACIT, CENTRAL CIRCLE-13, NEW DELHI

In the result, the appeals of the assessee are allowed in the manner as indicated above

ITA 1659/DEL/2022[2013-14]Status: DisposedITAT Delhi19 Oct 2023AY 2013-14

Bench: Shri Chandra Mohan Garg & Girish Agrawal

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H K Choudhary, CIT(DR)
Section 143(3)Section 153Section 153C

…de Finance Act, 2017. Thus, as per CBDT circular mentioned above, the amended provisions would not be applicable to the present case. Taking note of the aforesaid CBDT circular, the Hon’ble Gujarat High Court, in case of Anil Kumar Gopikishan Arawal Vs. CIT, (418 ITR 25), has held that the amended provisions of section 153C of the Act would apply where search and seizure is made after the amendment……” 8. Therefore, keeping in view the facts of the case that the date of search was 23.07.2015, date of recording satisfaction by the AO of searched person was 23.03.2018 and the date of recording of satisfaction by the…

SHREE GOPAL LANDCRAFT (P) LTD.,DELHI vs. ACIT, CENTRAL CIRCLE-13, NEW DELHI

In the result, the appeals of the assessee are allowed in the manner as indicated above

ITA 1658/DEL/2022[2012-13]Status: DisposedITAT Delhi19 Oct 2023AY 2012-13

Bench: Shri Chandra Mohan Garg & Girish Agrawal

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H K Choudhary, CIT(DR)
Section 143(3)Section 153Section 153C

…de Finance Act, 2017. Thus, as per CBDT circular mentioned above, the amended provisions would not be applicable to the present case. Taking note of the aforesaid CBDT circular, the Hon’ble Gujarat High Court, in case of Anil Kumar Gopikishan Arawal Vs. CIT, (418 ITR 25), has held that the amended provisions of section 153C of the Act would apply where search and seizure is made after the amendment……” 8. Therefore, keeping in view the facts of the case that the date of search was 23.07.2015, date of recording satisfaction by the AO of searched person was 23.03.2018 and the date of recording of satisfaction by the…

SHREE GOPAL LANDCRAFT (P) LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-13, NEW DELHI

In the result, the appeals of the assessee are allowed in the manner as indicated above

ITA 1657/DEL/2022[2011-12]Status: DisposedITAT Delhi19 Oct 2023AY 2011-12

Bench: Shri Chandra Mohan Garg & Girish Agrawal

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H K Choudhary, CIT(DR)
Section 143(3)Section 153Section 153C

…de Finance Act, 2017. Thus, as per CBDT circular mentioned above, the amended provisions would not be applicable to the present case. Taking note of the aforesaid CBDT circular, the Hon’ble Gujarat High Court, in case of Anil Kumar Gopikishan Arawal Vs. CIT, (418 ITR 25), has held that the amended provisions of section 153C of the Act would apply where search and seizure is made after the amendment……” 8. Therefore, keeping in view the facts of the case that the date of search was 23.07.2015, date of recording satisfaction by the AO of searched person was 23.03.2018 and the date of recording of satisfaction by the…

ACIT, CENTRAL CIRCLE-2, NEW DELHI vs. OPAL BUILDWELL P.LTD, DELHI

Accordingly notice was issued on 18.10.2016. Thus, there is no substance in the grounds raised and the same are decided against the Revenue. The appeal of Revenue is dismissed

ITA 2899/DEL/2019[2010-11]Status: DisposedITAT Delhi30 Jun 2023AY 2010-11

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaacit, Vs. M/S. Opal Buildwell P. Ltd. Central Circle-2 (Formerly Namo Resorts Pvt. New Delhi Ltd.) 445, Kucha Baijnath, Chandni Chowk, Delhi Pan : Aabcn9757H (Appellant) (Respondent)

Section 131Section 132Section 143(1)Section 153CSection 153C(1)

…de Finance Act, 2017. Thus, as per CBDT circular mentioned above, the amended provisions would not be applicable to the present case. Taking note of the aforesaid CBDT circular, the Hon’ble Gujarat High Court, in case of Anil Kumar Gopikishan Arawal Vs. CIT, (418 ITR 25), has held that the amended provisions of section 153C of the Act would apply where search and seizure is made after the amendment. Considered in the aforesaid perspective, the apprehension of the Revenue that if the amended provisions are not applied with reference to the date of recording of satisfaction there will be different sets of assessmen…

DCIT CIRCLE-05, NEW DELHI vs. KARINA AIRLINES INTERNATIONAL LIMITED, NEW DELHI

In the result, the appeal is dismissed

ITA 714/DEL/2021[2011-12]Status: DisposedITAT Delhi11 May 2023AY 2011-12

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2011-12

Section 132Section 153ASection 153C

…de Finance Act, 2017. Thus, as per CBDT circular mentioned above, the amended provisions would not be applicable to the present case. Taking note of the aforesaid CBDT circular, the Hon’ble Gujarat High Court, in case of Anil Kumar Gopikishan Arawal Vs. CIT, (418 ITR 25), has held that the amended provisions of section 153C of the Act would apply where search and seizure is made after the amendment. Considered in the aforesaid perspective, the apprehension of the Revenue that if the 4 | P a g e AY: 2011-12 amended provisions are not applied with reference to the date of recording of satisfaction there will be di…

ACIT, CENTRAL CIRCLE-1(1), AHMEDABAD vs. M/S. ASHRITA CONSTRUCTION PVT. LTD., AHMEDABAD

In the result, the Cross Objection filed by the Assessee is allowed

ITA 2023/AHD/2018[2015-16]Status: DisposedITAT Ahmedabad09 Nov 2022AY 2015-16
For Appellant: Shri James Kurian, CIT-DRFor Respondent: Shri Tushar Hemani, Sr. Adv. &
Section 132Section 142(1)Section 143(3)Section 153ASection 153C

…Counsel brought to our attention that the search action was carried out in the third party premises namely Venus Group on 10.03.2015. It is well settled law by the Jurisdictional High Court judgment in the case of Anil Kumar Gopikishan Agrawal vs. ACIT [2019] 418 ITR 25 that in the case of search action carried out u/s. 132 of the Act prior to 01.06.2015 jurisdiction u/s. 153C of the Act can be invoked only, if the material seized during the course of search in the case of a third party ‘belongs to’ to some person other than the searched person. Here search action has been taken place on 10.03.2015 much prior 01.…

NALIN VYAS (THROUGH LEGAL HEIR BRIJESH VYAS),VIRAR vs. ITO 4 (3), THANE

In the result, all the appeals of the assessee are allowed

ITA 6397/MUM/2019[2012-13]Status: DisposedITAT Mumbai04 Aug 2022AY 2012-13
For Appellant: Shri Himanshu GandhiFor Respondent: Dr. Mahesh Akhade (DR) &
Section 132Section 153CSection 271(1)(c)

…153C (ie. before 01.06.2015) is applicable or the post- amended section 153C is applicable. We note that this issue is no longer res-integra and the Hon’ble Gujarat High Court has answered the same in its decision in Anilkumar Gopikishan Agrawal V CIT (2019) 418 ITR 25 (Guj) wherein similar issue cropped up and the Hon’ble High Court held that it is the date of search that has to be considered to be relevant date for the purpose of applying the provision of section 153C(1) of the Act by observing as under: - “The moot question that arises for consideration in the present case is as to what is relevant date from…

NALIN VYAS (THROUGH LEGAL HEIR BRIJESH VYAS),VIRAR vs. ITO 4 (3), THANE

In the result, all the appeals of the assessee are allowed

ITA 6396/MUM/2019[2012-13]Status: DisposedITAT Mumbai04 Aug 2022AY 2012-13
For Appellant: Shri Himanshu GandhiFor Respondent: Dr. Mahesh Akhade (DR) &
Section 132Section 153CSection 271(1)(c)

…153C (ie. before 01.06.2015) is applicable or the post- amended section 153C is applicable. We note that this issue is no longer res-integra and the Hon’ble Gujarat High Court has answered the same in its decision in Anilkumar Gopikishan Agrawal V CIT (2019) 418 ITR 25 (Guj) wherein similar issue cropped up and the Hon’ble High Court held that it is the date of search that has to be considered to be relevant date for the purpose of applying the provision of section 153C(1) of the Act by observing as under: - “The moot question that arises for consideration in the present case is as to what is relevant date from…

NALIN VYAS (THROUGH LEGAL HEIR BRIJESH VYAS),VIRAR vs. ITO 4 (3), THANE

In the result, all the appeals of the assessee are allowed

ITA 6395/MUM/2019[2011-12]Status: DisposedITAT Mumbai04 Aug 2022AY 2011-12
For Appellant: Shri Himanshu GandhiFor Respondent: Dr. Mahesh Akhade (DR) &
Section 132Section 153CSection 271(1)(c)

…153C (ie. before 01.06.2015) is applicable or the post- amended section 153C is applicable. We note that this issue is no longer res-integra and the Hon’ble Gujarat High Court has answered the same in its decision in Anilkumar Gopikishan Agrawal V CIT (2019) 418 ITR 25 (Guj) wherein similar issue cropped up and the Hon’ble High Court held that it is the date of search that has to be considered to be relevant date for the purpose of applying the provision of section 153C(1) of the Act by observing as under: - “The moot question that arises for consideration in the present case is as to what is relevant date from…

NALIN VYAS (THROUGH LEGAL HEIR BRIJESH VYAS),VIRAR vs. ITO 4 (3), THANE

In the result, all the appeals of the assessee are allowed

ITA 6394/MUM/2019[2011-12]Status: DisposedITAT Mumbai04 Aug 2022AY 2011-12
For Appellant: Shri Himanshu GandhiFor Respondent: Dr. Mahesh Akhade (DR) &
Section 132Section 153CSection 271(1)(c)

…153C (ie. before 01.06.2015) is applicable or the post- amended section 153C is applicable. We note that this issue is no longer res-integra and the Hon’ble Gujarat High Court has answered the same in its decision in Anilkumar Gopikishan Agrawal V CIT (2019) 418 ITR 25 (Guj) wherein similar issue cropped up and the Hon’ble High Court held that it is the date of search that has to be considered to be relevant date for the purpose of applying the provision of section 153C(1) of the Act by observing as under: - “The moot question that arises for consideration in the present case is as to what is relevant date from…

NALIN VYAS (THROUGH LEGAL HEIR BRIJESH VYAS),VIRAR vs. ITO 4 (3), THANE

In the result, all the appeals of the assessee are allowed

ITA 6393/MUM/2019[2010-11]Status: DisposedITAT Mumbai04 Aug 2022AY 2010-11
For Appellant: Shri Himanshu GandhiFor Respondent: Dr. Mahesh Akhade (DR) &
Section 132Section 153CSection 271(1)(c)

…153C (ie. before 01.06.2015) is applicable or the post- amended section 153C is applicable. We note that this issue is no longer res-integra and the Hon’ble Gujarat High Court has answered the same in its decision in Anilkumar Gopikishan Agrawal V CIT (2019) 418 ITR 25 (Guj) wherein similar issue cropped up and the Hon’ble High Court held that it is the date of search that has to be considered to be relevant date for the purpose of applying the provision of section 153C(1) of the Act by observing as under: - “The moot question that arises for consideration in the present case is as to what is relevant date from…

NALIN VYAS (THROUGH LEGAL HEIR BRIJESH VYAS),VIRAR vs. ITO 4 (3), THANE

In the result, all the appeals of the assessee are allowed

ITA 6392/MUM/2019[2010-11]Status: DisposedITAT Mumbai04 Aug 2022AY 2010-11
For Appellant: Shri Himanshu GandhiFor Respondent: Dr. Mahesh Akhade (DR) &
Section 132Section 153CSection 271(1)(c)

…153C (ie. before 01.06.2015) is applicable or the post- amended section 153C is applicable. We note that this issue is no longer res-integra and the Hon’ble Gujarat High Court has answered the same in its decision in Anilkumar Gopikishan Agrawal V CIT (2019) 418 ITR 25 (Guj) wherein similar issue cropped up and the Hon’ble High Court held that it is the date of search that has to be considered to be relevant date for the purpose of applying the provision of section 153C(1) of the Act by observing as under: - “The moot question that arises for consideration in the present case is as to what is relevant date from…

DCIT CIRCLE- 05, NEW DELHI vs. OJJUS MEDICARE PRIVATE LIMITED, NEW DELHI

In the result, the appeal of the assessee is allowed, as indicated above

ITA 955/DEL/2021[2012-13]Status: DisposedITAT Delhi29 Jul 2022AY 2012-13

Bench: Shri C.M. Garg & Shri Anadee Nath Misshraassessment Year: 2012-13 Ojjus Medicare Private Limited, Vs. Acit, No.11, Gali No.5, Block-A, Circle-05, West Karawal Nagar, New Delhi. New Delhi – 110 094. Pan: Aabch6207Q Assessment Year: 2012-13

For Appellant: Shri Ruchesh Sinha, AdvocateFor Respondent: Ms Rinku Singh, CIT-DR
Section 132Section 132ASection 143(3)Section 153Section 153ASection 153C

…as per CBDT circular mentioned above, the amended provisions would not be applicable to the present case. Taking note of the aforesaid CBDT circular, the Hon’ble Gujarat High Court, in case of Anil Kumar Gopikishan ITAs No.202 & 955/Del/2021 Arawal Vs. CIT, (418 ITR 25), has held that the amended provisions of section 153C of the Act would apply where search and seizure is made after the amendment……” 7. Therefore, keeping in view the facts of the case that the date of search was 07.04.2016, date of recording satisfaction by the AO of searched person was 29.03.2019 and the date of recording of satisfaction by th…

OJJUS MEDICARE PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE- 05, NEW DELHI

In the result, the appeal of the assessee is allowed, as indicated above

ITA 202/DEL/2021[2012-13]Status: DisposedITAT Delhi29 Jul 2022AY 2012-13

Bench: Shri C.M. Garg & Shri Anadee Nath Misshraassessment Year: 2012-13 Ojjus Medicare Private Limited, Vs. Acit, No.11, Gali No.5, Block-A, Circle-05, West Karawal Nagar, New Delhi. New Delhi – 110 094. Pan: Aabch6207Q Assessment Year: 2012-13

For Appellant: Shri Ruchesh Sinha, AdvocateFor Respondent: Ms Rinku Singh, CIT-DR
Section 132Section 132ASection 143(3)Section 153Section 153ASection 153C

…as per CBDT circular mentioned above, the amended provisions would not be applicable to the present case. Taking note of the aforesaid CBDT circular, the Hon’ble Gujarat High Court, in case of Anil Kumar Gopikishan ITAs No.202 & 955/Del/2021 Arawal Vs. CIT, (418 ITR 25), has held that the amended provisions of section 153C of the Act would apply where search and seizure is made after the amendment……” 7. Therefore, keeping in view the facts of the case that the date of search was 07.04.2016, date of recording satisfaction by the AO of searched person was 29.03.2019 and the date of recording of satisfaction by th…

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Anil Kumar Gopikishan Arawal v. CIT (418 ITR 25) — Cited in 25 Judgments | BharatTax