Tax v. Gopi Apartments

360 ITR 411Reported decision2014#847 most cited

What is Tax v. Gopi Apartments authority for?

For initiating assessment proceedings under Section 153C against a person other than the one searched, the Assessing Officer's satisfaction that seized assets or documents belong to such other person is deemed to be recorded on the date the AO assumes possession of those seized assets or documents in the capacity of an AO for that other person.

123

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2026.

Also referred to as

Tax v. Gopi Apartments · 360 ITR 411 · Section 153C · date of satisfaction recording · search assessment third party · Assessing Officer possession · seized documents · Section 153A proceedings · Allahabad High Court

Sections most often in play

Section 153CSection 153ASection 143(3)Section 147Section 148Section 151Section 149Section 132

Issues it is cited on

section 153atosection 153b(1)(a)abatement of assessmentsection 132(4a)(i)section 6(3)(ii)section 292c(1)(i)section 153c proceedingssection 113section 153b(1)section 158bdsection 292c(1)section 6(3)

Judgments citing Tax v. Gopi Apartments

WAANEEP SOLAR PRIVATE LIMITED,DELHI vs. CENTRAL CIRCLE 2(4), MUMBAI

ITA 4031/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Jan 2026AY 2015-16

Bench: Justice (Retd.) C. V. Bhadang & Shri Prabhash Shankar

For Appellant: Shri Rushabh Mehta, ARFor Respondent: Shri Arun Kanti Datta, (CIT-DR)
Section 132Section 143(3)Section 153CSection 292CSection 69C

…d, the assessee relied upon the following case laws:- i. DCIT vs Sunil Sharma [2024] 168 taxmann.com 77(SC) ii. CIT vs Singhad Technical Education Society (84 taxmann.com290) iii. DCIT VS Sunil Sharma [2024] 159 taxmann.com 179 (Karnataka) iv. Gopi Apartment (365 ITR 411) 7.3. In view of the above submissions, the Ld. AR submitted that since the satisfaction was not recorded properly, the assessment order for AY 2018-19 should be quashed and even on merits in view of the above submissions, the addition should be deleted. 8. The Ld. Cit-DR supported the orders of the authorities below. He relied upon the decision…

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4304/DEL/2025[2020-21]Status: DisposedITAT Delhi28 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4303/DEL/2025[2019-20]Status: DisposedITAT Delhi28 Nov 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4302/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Nov 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4301/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4300/DEL/2025[2016-17]Status: DisposedITAT Delhi28 Nov 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4299/DEL/2025[2015-16]Status: DisposedITAT Delhi28 Nov 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4298/DEL/2025[2014-15]Status: DisposedITAT Delhi28 Nov 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4297/DEL/2025[2013-14]Status: DisposedITAT Delhi28 Nov 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4280/DEL/2025[2020-21]Status: DisposedITAT Delhi28 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4279/DEL/2025[2019-20]Status: DisposedITAT Delhi28 Nov 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4278/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Nov 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4277/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4276/DEL/2025[2016-17]Status: DisposedITAT Delhi28 Nov 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4275/DEL/2025[2015-16]Status: DisposedITAT Delhi28 Nov 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4274/DEL/2025[2014-15]Status: DisposedITAT Delhi28 Nov 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4273/DEL/2025[2013-14]Status: DisposedITAT Delhi28 Nov 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

ALKA AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

ITA 4272/DEL/2025[2020-21]Status: DisposedITAT Delhi28 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

ALKA AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

ITA 4271/DEL/2025[2019-20]Status: DisposedITAT Delhi28 Nov 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

ALKA AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

ITA 4269/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Nov 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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