CIT (Central) v. Kabul Chawla

2015 SCC OnLine DEL 11555Reported decision2015#513 most cited

What is CIT (Central) v. Kabul Chawla authority for?

No addition can be made in respect of a completed assessment in the absence of incriminating material, especially when considering the object and purpose of Section 153-A.

186

judgments rely on this decision, according to BharatTax’s citation analysis of 366,418 Indian tax judgments — from 2016 to 2026.

Also referred to as

Kabul Chawla · CIT v. Kabul Chawla · 2015 SCC OnLine DEL 11555 · Section 153A · completed assessment · incriminating material · block assessment · assessment procedure

Sections most often in play

Section 143(3)Section 153CSection 153ASection 132Section 147Section 148Section 151Section 149
Read the full judgment

Issues it is cited on

section 153atosection 153b(1)(a)abatement of assessmentsection 153c proceedingssection 113section 153b(1)section 158bdsection 153c(1)panchnamablock periodbest judgment assessmentsection 153b

Judgments citing CIT (Central) v. Kabul Chawla

Dy. Commissioner of Income Tax, Central Circle-3, New Delhi, Delhi vs. Bhushan Dua, Delhi

ITA 279/DEL/2024[2017-18]Status: DisposedITAT Delhi25 Sept 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

…d therefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon'ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrimina…

Dy. Commissioner of Income Tax, Central Circle - 3, New Delhi, Delhi vs. Super Cassettes Industries Pvt. Ltd., Delhi

ITA 273/DEL/2024[2018-19]Status: DisposedITAT Delhi25 Sept 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

…d therefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon'ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrimina…

Dy. Commissioner of Income Tax, Central Circle - 3, Delhi vs. Super Cassettes Industries Pvt. Ltd., Delhi

ITA 272/DEL/2024[2017-18]Status: DisposedITAT Delhi25 Sept 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

Super Cassettes Industries Private Limited, Delhi vs. DCIT Central Circle 03, Delhi

ITA 271/DEL/2024[2019-20]Status: DisposedITAT Delhi25 Sept 2025AY 2019-20

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

Deputy Commissioner of Income Tax, Central Circle-03, New Delhi, Delhi vs. Luv Ranjan, Ghaziabad

ITA 1845/DEL/2024[2019-20]Status: DisposedITAT Delhi25 Sept 2025AY 2019-20

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

…therefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon'ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrimina…

Deputy Commissioner of Income Tax, Central Circle 3, New Delhi, Delhi vs. Bhushan Dua, Delhi

ITA 2951/DEL/2023[2016-17]Status: DisposedITAT Delhi25 Sept 2025AY 2016-17

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

Deputy Commissioner of Income Tax, Central Circle 3, New Delhi, Delhi vs. Bhushan Dua, Delhi

ITA 2950/DEL/2023[2015-16]Status: DisposedITAT Delhi25 Sept 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

Deputy Commissioner of Income Tax, Central Circle 3, New Delhi, Delhi vs. Super Cassettes Industries Pvt. Ltd., Delhi

ITA 2756/DEL/2023[2016-17]Status: DisposedITAT Delhi25 Sept 2025AY 2016-17

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

Super Cassettes Industries Pvt Ltd, Delhi vs. DCIT Central Circle-3, Delhi

ITA 2714/DEL/2023[2016-17]Status: DisposedITAT Delhi25 Sept 2025AY 2016-17

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

Super Cassettes Industries Pvt Ltd, New Delhi vs. DCIT Central Circle-3, Delhi

ITA 2713/DEL/2023[2015-16]Status: DisposedITAT Delhi25 Sept 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

Deputy Commissioner of Income Tax, Central Circle 3, Delhi vs. Super Cassettes Industries Private Limited, Delhi

ITA 2512/DEL/2023[2014-15]Status: DisposedITAT Delhi25 Sept 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

Deputy Commissioner of Income Tax, Central Circle 3, Delhi vs. Super Cassettes Industries Private Limited, Delhi

ITA 2511/DEL/2023[2013-14]Status: DisposedITAT Delhi25 Sept 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

Deputy Commissioner of Income Tax, Central Circle-3, Delhi vs. Bhushan Dua, New Delhi

ITA 2510/DEL/2023[2013-14]Status: DisposedITAT Delhi25 Sept 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

Deputy Commissioner of Income Tax, Central Circle 3, Delhi vs. Bhushan Dua, New Delhi

ITA 2509/DEL/2023[2014-15]Status: DisposedITAT Delhi25 Sept 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

The Pr Commissioner of Income Tax vs. M/S Atria Wind (Kadambur) Pvt Ltd

ITA/103/2025HC Karnataka03 Sept 2025

Bench: CHIEF JUSTICE,C M JOSHI

Section 132Section 143(3)Section 153ASection 2Section 260Section 260ASection 47

…- 1 - HC-KAR NC: 2025:KHC:34452-DB ITA No. 103 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 3RD DAY OF SEPTEMBER, 2025 PRESENT THE HON'BLE MR. VIBHU BAKHRU, CHIEF JUSTICE AND THE HON'BLE MR. JUSTICE C M JOSHI INCOME TAX APPEAL NO. 103 OF 2025 BETWEEN: 1. THE PR. COMMISSIONER OF INCOME TAX CENTRAL, 3RD FLOOR, C.R. BUILDING, QUEENS ROAD, BENGALURU-560 001. 2. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(4), 3RD FLOOR, C.R BUILDING, QUEENS ROAD, BENGALURU-560 001. …APPELLANTS (BY SRI. Y V RAVIRAJ,ADVOCATE) AND: 1. M/S ATRI…

Deputy Commissioner, Delhi vs. Ravindra Singh, Greater Noida

In the result, the Appeals of the Revenue in I

ITA 2459/DEL/2023[2014-15]Status: DisposedITAT Delhi28 Aug 2025AY 2014-15

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

Section 132Section 153ASection 156Section 69Section 69A

…der, it is seen that the additions is not based on any incriminating material found during the course of search on the appellant. The appellant has placed reliance on the ratio of the decision of Hon'ble Delhi High Court in the case of Pr.CIT Vs. Kabul Chawla 61 Taxmann.com 421, 15. This decision of Hon'ble Delhi High Court came up for consideration of the Hon'ble Supreme Court in the case of Pr.CIT Vs. AbhisarBuildwell Pvt. Ltd. in Civil Appeal No. 6580 of 2021 and other connected appeals. The apex court vide its order dated 24.04.2022 has upheld the above referred order of Delhi High Court by holding as under:…

Deputy Commissioner, Delhi vs. Ravindra Singh, Greater Noida

In the result, the Appeals of the Revenue in I

ITA 2458/DEL/2023[2013-14]Status: DisposedITAT Delhi28 Aug 2025AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

Section 132Section 153ASection 156Section 69Section 69A

…der, it is seen that the additions is not based on any incriminating material found during the course of search on the appellant. The appellant has placed reliance on the ratio of the decision of Hon'ble Delhi High Court in the case of Pr.CIT Vs. Kabul Chawla 61 Taxmann.com 421, 15. This decision of Hon'ble Delhi High Court came up for consideration of the Hon'ble Supreme Court in the case of Pr.CIT Vs. AbhisarBuildwell Pvt. Ltd. in Civil Appeal No. 6580 of 2021 and other connected appeals. The apex court vide its order dated 24.04.2022 has upheld the above referred order of Delhi High Court by holding as under:…

Deputy Commissioner, Delhi vs. Ravindra Singh, Greater Noida

In the result, the Appeals of the Revenue in I

ITA 2457/DEL/2023[2012-13]Status: DisposedITAT Delhi28 Aug 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

Section 132Section 153ASection 156Section 69Section 69A

…der, it is seen that the additions is not based on any incriminating material found during the course of search on the appellant. The appellant has placed reliance on the ratio of the decision of Hon'ble Delhi High Court in the case of Pr.CIT Vs. Kabul Chawla 61 Taxmann.com 421, 15. This decision of Hon'ble Delhi High Court came up for consideration of the Hon'ble Supreme Court in the case of Pr.CIT Vs. AbhisarBuildwell Pvt. Ltd. in Civil Appeal No. 6580 of 2021 and other connected appeals. The apex court vide its order dated 24.04.2022 has upheld the above referred order of Delhi High Court by holding as under:…

Shri Abhishek Soin, Ludhiana vs. DCIT, CC-II, Ludhiana

The appeals are partly allowed

ITA 322/CHANDI/2019[2011-12]Status: DisposedITAT Chandigarh29 Jul 2025AY 2011-12

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

For Appellant: Shri Aditya Kumar, CAFor Respondent: Shri Manav Bansal, CIT DR
Section 10(38)Section 132Section 139(1)Section 143(1)Section 143(3)Section 153ASection 153DSection 263

…s of this order is based upon the construction of the position of law that in a search assessment, any issue can be examined rather unearthed or not during the course of search. When judgement of the Hon'ble Delhi High Court in the case of CIT Vs Kabul Chawla 388 ITR 571 was brought to his notice , then he ignored that judgement only on the basis that appeal is being filed before the Supreme Court against this. He relied upon the judgement of Hon'ble Karnataka High Court in the case of Canara Housing Development Corporation Vs DCIT. After judgement of Hon'ble Supreme Court in the case of Abhisar Buildwell, situat…

Shri Abhishek Soin, Ludhiana vs. DCIT, CC-II, Ludhiana

The appeals are partly allowed

ITA 321/CHANDI/2019[2010-11]Status: DisposedITAT Chandigarh29 Jul 2025AY 2010-11

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

For Appellant: Shri Aditya Kumar, CAFor Respondent: Shri Manav Bansal, CIT DR
Section 10(38)Section 132Section 139(1)Section 143(1)Section 143(3)Section 153ASection 153DSection 263

…s of this order is based upon the construction of the position of law that in a search assessment, any issue can be examined rather unearthed or not during the course of search. When judgement of the Hon'ble Delhi High Court in the case of CIT Vs Kabul Chawla 388 ITR 571 was brought to his notice , then he ignored that judgement only on the basis that appeal is being filed before the Supreme Court against this. He relied upon the judgement of Hon'ble Karnataka High Court in the case of Canara Housing Development Corporation Vs DCIT. After judgement of Hon'ble Supreme Court in the case of Abhisar Buildwell, situat…