CIT v. IBC Knowledge Park (P.) Ltd.

385 ITR 346High Court2016#198 most cited

What is CIT v. IBC Knowledge Park (P.) Ltd. authority for?

A statement made by an assessee under Section 131 during search proceedings, without any corroborating incriminating material found during the search, cannot solely constitute incriminating evidence for making additions in assessments under Section 153A or 153C.

371

judgments rely on this decision, according to BharatTax’s citation analysis of 367,518 Indian tax judgments — from 2016 to 2026.

Also referred to as

CIT v. IBC Knowledge Park · IBC Knowledge Park · 385 ITR 346 · section 153A · section 153C · section 131 statement · incriminating material · search assessment · additions without evidence · completed assessments · undisclosed income

Also reported as

69 Taxmann.com 108287 CTR 261

Sections most often in play

Section 153ASection 143(3)Section 132Section 132(4)Section 153CSection 131Section 132ASection 69
Read the full judgment

Issues it is cited on

section 158bdsection 153a proceedingssection 158b(b)section 158bb(1)section 158bbsection 153(a)jdasection 153c(1)documents seizedsection 158bsection 158section 153a(1)

Judgments citing CIT v. IBC Knowledge Park (P.) Ltd.

Assistant Commissioner of Income Tax Central Circle-2(3), Bangalore vs. Sri C T Ravi, Chikkamangalur

In the result, Revenue’s appeals for Assessment Years 2008-09 to 2012-13 are dismissed as indicated above

ITA 284/BANG/2018[2010-11]Status: DisposedITAT Bangalore05 Jul 2019AY 2010-11

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

For Appellant: Shri. V. Chandrashekhar, AdvocateFor Respondent: Shri. R. N. Siddappaji, Addl. CIT
Section 132Section 143(3)Section 153CSection 2Section 292C

…alia, raised legal grounds assailing the impugned orders of the CIT(A). The learned DR for Revenue vehemently contended that the CIT(A) has seriously erred in relying the decision of the Hon’ble Karnataka High Court in the case of IBC Knowledge Park (P) Ltd., 385 ITR 346 (Kar). The learned DR, in submissions, put forth the following arguments / propositions. According to the learned DR, firstly, the assessee did not raise the issue of assumption of jurisdiction under section 153C of the Act during the course of assessment proceedings and she is therefore precluded from objecting to the same in appellate proceedin…

Assistant Commissioner of Income Tax Central Circle-2(3), Bangalore vs. Sri C T Ravi, Chikkamangalur

In the result, Revenue’s appeals for Assessment Years 2008-09 to 2012-13 are dismissed as indicated above

ITA 283/BANG/2018[2009-10]Status: DisposedITAT Bangalore05 Jul 2019AY 2009-10

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

For Appellant: Shri. V. Chandrashekhar, AdvocateFor Respondent: Shri. R. N. Siddappaji, Addl. CIT
Section 132Section 143(3)Section 153CSection 2Section 292C

…alia, raised legal grounds assailing the impugned orders of the CIT(A). The learned DR for Revenue vehemently contended that the CIT(A) has seriously erred in relying the decision of the Hon’ble Karnataka High Court in the case of IBC Knowledge Park (P) Ltd., 385 ITR 346 (Kar). The learned DR, in submissions, put forth the following arguments / propositions. According to the learned DR, firstly, the assessee did not raise the issue of assumption of jurisdiction under section 153C of the Act during the course of assessment proceedings and she is therefore precluded from objecting to the same in appellate proceedin…

Assistant Commissioner of Income Tax Central Circle-2(3), Bangalore vs. Sri C T Ravi, Chikkamangalur

In the result, Revenue’s appeals for Assessment Years 2008-09 to 2012-13 are dismissed as indicated above

ITA 282/BANG/2018[2008-09]Status: DisposedITAT Bangalore05 Jul 2019AY 2008-09

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

For Appellant: Shri. V. Chandrashekhar, AdvocateFor Respondent: Shri. R. N. Siddappaji, Addl. CIT
Section 132Section 143(3)Section 153CSection 2Section 292C

…alia, raised legal grounds assailing the impugned orders of the CIT(A). The learned DR for Revenue vehemently contended that the CIT(A) has seriously erred in relying the decision of the Hon’ble Karnataka High Court in the case of IBC Knowledge Park (P) Ltd., 385 ITR 346 (Kar). The learned DR, in submissions, put forth the following arguments / propositions. According to the learned DR, firstly, the assessee did not raise the issue of assumption of jurisdiction under section 153C of the Act during the course of assessment proceedings and she is therefore precluded from objecting to the same in appellate proceedin…

Assistant Commissioner of Income Tax Central Circle-2(3), Bangalore vs. Smt.Pallavi Ravi, Chikkamangalur

In the result, Revenue’s appeals for Assessment Years 2008-09 to 2012-13 are dismissed as indicated above

ITA 274/BANG/2018[2012-13]Status: DisposedITAT Bangalore05 Jul 2019AY 2012-13

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

For Appellant: Shri. V. Chandrashekhar, AdvocateFor Respondent: Shri. R. N. Siddappaji, Addl. CIT
Section 132Section 143(3)Section 153CSection 2Section 292C

…alia, raised legal grounds assailing the impugned orders of the CIT(A). The learned DR for Revenue vehemently contended that the CIT(A) has seriously erred in relying the decision of the Hon’ble Karnataka High Court in the case of IBC Knowledge Park (P) Ltd., 385 ITR 346 (Kar). The learned DR, in submissions, put forth the following arguments / propositions. According to the learned DR, firstly, the assessee did not raise the issue of assumption of jurisdiction under section 153C of the Act during the course of assessment proceedings and she is therefore precluded from objecting to the same in appellate proceedin…

Assistant Commissioner of Income Tax Central Circle-2(3), Bangalore vs. Smt.Pallavi Ravi, Chikkamangalur

In the result, Revenue’s appeals for Assessment Years 2008-09 to 2012-13 are dismissed as indicated above

ITA 273/BANG/2018[2011-12]Status: DisposedITAT Bangalore05 Jul 2019AY 2011-12

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

For Appellant: Shri. V. Chandrashekhar, AdvocateFor Respondent: Shri. R. N. Siddappaji, Addl. CIT
Section 132Section 143(3)Section 153CSection 2Section 292C

…alia, raised legal grounds assailing the impugned orders of the CIT(A). The learned DR for Revenue vehemently contended that the CIT(A) has seriously erred in relying the decision of the Hon’ble Karnataka High Court in the case of IBC Knowledge Park (P) Ltd., 385 ITR 346 (Kar). The learned DR, in submissions, put forth the following arguments / propositions. According to the learned DR, firstly, the assessee did not raise the issue of assumption of jurisdiction under section 153C of the Act during the course of assessment proceedings and she is therefore precluded from objecting to the same in appellate proceedin…

Assistant Commissioner of Income Tax Central Circle-2(3), Bangalore vs. Smt.Pallavi Ravi, Chikkamangalur

In the result, Revenue’s appeals for Assessment Years 2008-09 to 2012-13 are dismissed as indicated above

ITA 272/BANG/2018[2008-09]Status: DisposedITAT Bangalore05 Jul 2019AY 2008-09

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

For Appellant: Shri. V. Chandrashekhar, AdvocateFor Respondent: Shri. R. N. Siddappaji, Addl. CIT
Section 132Section 143(3)Section 153CSection 2Section 292C

…alia, raised legal grounds assailing the impugned orders of the CIT(A). The learned DR for Revenue vehemently contended that the CIT(A) has seriously erred in relying the decision of the Hon’ble Karnataka High Court in the case of IBC Knowledge Park (P) Ltd., 385 ITR 346 (Kar). The learned DR, in submissions, put forth the following arguments / propositions. According to the learned DR, firstly, the assessee did not raise the issue of assumption of jurisdiction under section 153C of the Act during the course of assessment proceedings and she is therefore precluded from objecting to the same in appellate proceedin…

ACIT, New Delhi vs. Shri Charanjit Singh Sarna, New Delhi

The appeals of the Revenue are dismissed

ITA 3944/DEL/2015[2009-10]Status: DisposedITAT Delhi03 Jun 2019AY 2009-10

Bench: Shri G. D. Agrawal & Ms Suchitra Kamble

Section 132ASection 153ASection 41(1)Section 68

…TR 526 • Pr. CIT v. RSA Digi Prints in ITA Nos. 469, 471, 504 and 505 of 2017 dated 06.09.2017 Gujarat High Court. • Pr. CIT v. Salasar Stock Broking Ltd. in ITA No. 254 of 2016 dated 24.08.2016 Calcutta High Court • CIT v. IBC Knowledge Park Pvt. Ltd. [2016] 385 ITR 346 • CIT v. Continental Warehousing Corporation Ltd. [2015] 374 ITR 645 7. The Ld. AR further submitted that before the CIT(A) the assessee has duly raised legal grounds and grounds on merits of the case. Though, the CIT(A) has allowed the appeal of the assessee on the merits of the case, however, the legal ground and arguments raised by the assess…

ACIT, New Delhi vs. Shri Charanjit Singh Sarna, New Delhi

The appeals of the Revenue are dismissed

ITA 3943/DEL/2015[2008-09]Status: DisposedITAT Delhi03 Jun 2019AY 2008-09

Bench: Shri G. D. Agrawal & Ms Suchitra Kamble

Section 132ASection 153ASection 41(1)Section 68

…TR 526 • Pr. CIT v. RSA Digi Prints in ITA Nos. 469, 471, 504 and 505 of 2017 dated 06.09.2017 Gujarat High Court. • Pr. CIT v. Salasar Stock Broking Ltd. in ITA No. 254 of 2016 dated 24.08.2016 Calcutta High Court • CIT v. IBC Knowledge Park Pvt. Ltd. [2016] 385 ITR 346 • CIT v. Continental Warehousing Corporation Ltd. [2015] 374 ITR 645 7. The Ld. AR further submitted that before the CIT(A) the assessee has duly raised legal grounds and grounds on merits of the case. Though, the CIT(A) has allowed the appeal of the assessee on the merits of the case, however, the legal ground and arguments raised by the assess…

Deputy Commissioner of Income Tax, Central Circle, Kota vs. M/S. Agrasen Agro Industries Private Limited, Kota

ITA 1205/JPR/2018[2011-12]Status: DisposedITAT Jaipur27 Mar 2019AY 2011-12
Section 143(3)Section 153Section 153ASection 68

…ujarat High Court in Principal Commissioner of Income Tax v. Saumya Construction Pvt. Ltd. (2016) 387 ITR 529 (Guj); (Copy at Case Law PB 181-193 in case of M/s Kota Dall Mill) (viii) Hon’ble Karnataka High Court in CIT v. IBC Knowledge Park Pvt. Ltd. (2016) 385 ITR 346 (Kar) (Copy at Case Law PB 160- 180) (ix) Kolkata High Court in Pr. CIT-2 v. Salasar Stock Broking Ltd. 2016-TIOL-2099-HC-KOL-IT (Copy at Case Law PB 213-214 in case of M/s Kota Dall Mill) (x) Hon’ble Bombay High Court in CIT v. Gurinder Singh Bawa (2016) 386 ITR 483 (Bom). (Copy at Case Law PB 207-209 in case of M/s Kota Dall Mill) (xi) Hon’b…

Deputy Commissioner of Income Tax, Central Circle, Kota vs. M/S. Agrasen Agro Industries Private Limited, Kota

ITA 1188/JPR/2018[2010-11]Status: DisposedITAT Jaipur27 Mar 2019AY 2010-11
Section 143(3)Section 153Section 153ASection 68

…ujarat High Court in Principal Commissioner of Income Tax v. Saumya Construction Pvt. Ltd. (2016) 387 ITR 529 (Guj); (Copy at Case Law PB 181-193 in case of M/s Kota Dall Mill) (viii) Hon’ble Karnataka High Court in CIT v. IBC Knowledge Park Pvt. Ltd. (2016) 385 ITR 346 (Kar) (Copy at Case Law PB 160- 180) (ix) Kolkata High Court in Pr. CIT-2 v. Salasar Stock Broking Ltd. 2016-TIOL-2099-HC-KOL-IT (Copy at Case Law PB 213-214 in case of M/s Kota Dall Mill) (x) Hon’ble Bombay High Court in CIT v. Gurinder Singh Bawa (2016) 386 ITR 483 (Bom). (Copy at Case Law PB 207-209 in case of M/s Kota Dall Mill) (xi) Hon’b…

M/S. Agrasen Agro Industries Private Limited, Kota vs. Deputy Commissioner of Income Tax, Central Circle, Kota

ITA 1053/JPR/2018[2010-11]Status: DisposedITAT Jaipur27 Mar 2019AY 2010-11
Section 143(3)Section 153Section 153ASection 68

…ujarat High Court in Principal Commissioner of Income Tax v. Saumya Construction Pvt. Ltd. (2016) 387 ITR 529 (Guj); (Copy at Case Law PB 181-193 in case of M/s Kota Dall Mill) (viii) Hon’ble Karnataka High Court in CIT v. IBC Knowledge Park Pvt. Ltd. (2016) 385 ITR 346 (Kar) (Copy at Case Law PB 160- 180) (ix) Kolkata High Court in Pr. CIT-2 v. Salasar Stock Broking Ltd. 2016-TIOL-2099-HC-KOL-IT (Copy at Case Law PB 213-214 in case of M/s Kota Dall Mill) (x) Hon’ble Bombay High Court in CIT v. Gurinder Singh Bawa (2016) 386 ITR 483 (Bom). (Copy at Case Law PB 207-209 in case of M/s Kota Dall Mill) (xi) Hon’b…

DCIT, CC-4(1), Kolkata vs. M/S Maan Steel & Power Ltd., Kolkata

In the result this appeal of the revenue is dismissed

ITA 1192/KOL/2017[2011-12]Status: DisposedITAT Kolkata06 Feb 2019AY 2011-12

Bench: Sri J. Sudhakar Reddy & Sri A. T. Varkey)

Section 132Section 153ASection 250

…dgment of the Hon'ble Delhi High Court has been followed in several judgments not only by the Hon'ble Delhi High Court but also by other Hon'ble High Court like, Pr. CIT vs. Somaya Construction Pvt. Ltd. 387 ITR 529 (Guj), CIT vs. IBC Knowledge Park Pvt. Ltd. 385 ITR 346 (Kar) and CIT vs.Gurinder Singh Bawa reported in 386 ITR 483. In the latest judgment the Hon'ble Delhi High Court in Pr. CIT vs. Meeta Gutgutia, their Lordships reiterated the same principle after discussing and analyzing catena of decisions including that of Anil Kumar Bhatia (supra) and Dayawanti Gupta. The Hon'ble HighCourt observed and held a…

Deputy Commissioner of Income Tax, Circle-1(2)(1), Bangalore vs. Shri Sachin Kamath, Bangalore

In the result, the Revenue’s appeals bearing ITA Nos

ITA 1784/BANG/2017[2011-12]Status: DisposedITAT Bangalore31 Jan 2019AY 2011-12

Bench: Shri Chandra Poojari & Shri Pavan Kumar Gadale

For Appellant: Shri S.Srinivasan, CAFor Respondent: Dr.Pradeep Kumar,P.V., Addl.CIT(DR)
Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147Section 148

…en submissions and relied on the decision of the Hon’ble Calcutta High Court in the case of Rawatmal Harakchand vs. CIT (129 ITR 346) (Cal) and the decision of the Hon’ble jurisdictional High Court in the case of CIT vs. IBC Knowledge Park (P) Ltd., (2016) 287 CTR 261(Kar) and particular attention was drawn to para.50 of the judgment and submitted that proceedings u/s 153C shall prevail. The learned AR also relied on the decision of the co-ordinate bench in ITO vs. Arun Kumar Kapoor (2011) 58 DTR(AT) 201(ITAT, Amritsar). 16. Contra, the learned DR submitted that the AO has rightly passed order u/s 143(3) r.…

Deputy Commissioner of Income Tax Circle-1(2)(1), Bangalore vs. Shri Sachin Kamath, Bangalore

In the result, the Revenue’s appeals bearing ITA Nos

ITA 1783/BANG/2017[2009-10]Status: DisposedITAT Bangalore31 Jan 2019AY 2009-10

Bench: Shri Chandra Poojari & Shri Pavan Kumar Gadale

For Appellant: Shri S.Srinivasan, CAFor Respondent: Dr.Pradeep Kumar,P.V., Addl.CIT(DR)
Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147Section 148

…en submissions and relied on the decision of the Hon’ble Calcutta High Court in the case of Rawatmal Harakchand vs. CIT (129 ITR 346) (Cal) and the decision of the Hon’ble jurisdictional High Court in the case of CIT vs. IBC Knowledge Park (P) Ltd., (2016) 287 CTR 261(Kar) and particular attention was drawn to para.50 of the judgment and submitted that proceedings u/s 153C shall prevail. The learned AR also relied on the decision of the co-ordinate bench in ITO vs. Arun Kumar Kapoor (2011) 58 DTR(AT) 201(ITAT, Amritsar). 16. Contra, the learned DR submitted that the AO has rightly passed order u/s 143(3) r.…

Deputy Commissioner of Income Tax, Circle-1(2)(1), Bangalore vs. Shri Sachin Kamath, Bangalore

In the result, the Revenue’s appeals bearing ITA Nos

ITA 1782/BANG/2017[2008-09]Status: DisposedITAT Bangalore31 Jan 2019AY 2008-09

Bench: Shri Chandra Poojari & Shri Pavan Kumar Gadale

For Appellant: Shri S.Srinivasan, CAFor Respondent: Dr.Pradeep Kumar,P.V., Addl.CIT(DR)
Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147Section 148

…en submissions and relied on the decision of the Hon’ble Calcutta High Court in the case of Rawatmal Harakchand vs. CIT (129 ITR 346) (Cal) and the decision of the Hon’ble jurisdictional High Court in the case of CIT vs. IBC Knowledge Park (P) Ltd., (2016) 287 CTR 261(Kar) and particular attention was drawn to para.50 of the judgment and submitted that proceedings u/s 153C shall prevail. The learned AR also relied on the decision of the co-ordinate bench in ITO vs. Arun Kumar Kapoor (2011) 58 DTR(AT) 201(ITAT, Amritsar). 16. Contra, the learned DR submitted that the AO has rightly passed order u/s 143(3) r.…

Deputy Commissioner of Income Tax, Circle-1(2)(1), Bangalore vs. Shri Sachin Kamath, Bangalore

In the result, the Revenue’s appeals bearing ITA Nos

ITA 1781/BANG/2017[2007-08]Status: DisposedITAT Bangalore31 Jan 2019AY 2007-08

Bench: Shri Chandra Poojari & Shri Pavan Kumar Gadale

For Appellant: Shri S.Srinivasan, CAFor Respondent: Dr.Pradeep Kumar,P.V., Addl.CIT(DR)
Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147Section 148

…en submissions and relied on the decision of the Hon’ble Calcutta High Court in the case of Rawatmal Harakchand vs. CIT (129 ITR 346) (Cal) and the decision of the Hon’ble jurisdictional High Court in the case of CIT vs. IBC Knowledge Park (P) Ltd., (2016) 287 CTR 261(Kar) and particular attention was drawn to para.50 of the judgment and submitted that proceedings u/s 153C shall prevail. The learned AR also relied on the decision of the co-ordinate bench in ITO vs. Arun Kumar Kapoor (2011) 58 DTR(AT) 201(ITAT, Amritsar). 16. Contra, the learned DR submitted that the AO has rightly passed order u/s 143(3) r.…

Deputy Commissioner of Income Tax Circle-1(2)(1), Bangalore vs. Shri Sachin Kamath, Bangalore

In the result, the Revenue’s appeals bearing ITA Nos

ITA 1780/BANG/2017[2006-07]Status: DisposedITAT Bangalore31 Jan 2019AY 2006-07

Bench: Shri Chandra Poojari & Shri Pavan Kumar Gadale

For Appellant: Shri S.Srinivasan, CAFor Respondent: Dr.Pradeep Kumar,P.V., Addl.CIT(DR)
Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147Section 148

…en submissions and relied on the decision of the Hon’ble Calcutta High Court in the case of Rawatmal Harakchand vs. CIT (129 ITR 346) (Cal) and the decision of the Hon’ble jurisdictional High Court in the case of CIT vs. IBC Knowledge Park (P) Ltd., (2016) 287 CTR 261(Kar) and particular attention was drawn to para.50 of the judgment and submitted that proceedings u/s 153C shall prevail. The learned AR also relied on the decision of the co-ordinate bench in ITO vs. Arun Kumar Kapoor (2011) 58 DTR(AT) 201(ITAT, Amritsar). 16. Contra, the learned DR submitted that the AO has rightly passed order u/s 143(3) r.…

Sri Rajesh Kumar, Bangalore vs. ACIT, Bangalore

In the result, the appeal filed by the assessee is dismissed

ITA 195/BANG/2010[2005-06]Status: DisposedITAT Bangalore11 Jan 2019AY 2005-06

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadaleassessment Year : 2005-06

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri K.V. Aravind, Standing Counsel
Section 153Section 153ASection 153CSection 2(22)(e)Section 234A

…o be decided after considering these paras of synopsis. He also pointed out that as per these paras of synopsis reliance has been placed on the judgment of Hon'ble Karnataka High Court rendered in the case of CIT Vs. IBC Knowledge Park [P] Ltd. as reported in 385 ITR 346. In addition to this, reliance has been placed on two judgments of Hon’ble Delhi High Court rendered in the case of CIT Vs. Kabul Chawla as reported in 380 ITR 573 and in the case of PCIT Vs. Ms. Lata Jain as reported in 384 ITR 543. As against this, ld. DR of revenue supported the order of CIT (A) and he also submitted that these judgments cited…

ACIT, New Delhi vs. Smt Urmila Chandulal Patel, New Delhi

Accordingly all the appeals of the revenue with respect to all these assesses are dismissed

ITA 1459/DEL/2015[2010-11]Status: DisposedITAT Delhi31 Dec 2018AY 2010-11

Bench: Shri Prashant Maharishi & Shri K.N.Charyacit, Vs. Rohan Patel, Central Circle-06, New Delhi 10, Executive Club Road, Chandanholla Mehrauli, New Delhi Pan: Asjpp8428L (Appellant) (Respondent) Acit, Vs. Himanshu Patel, Central Circle-06, New Delhi 10, Executive Club Road, Chandanholla Mehrauli, New Delhi Pan: Actpp8270C (Appellant) (Respondent) Acit, Vs. Praduman Patel, Central Circle-06, New Delhi 10, Executive Club Road, Chandanholla Mehrauli, New Delhi Pan: Ajhpp2206P (Appellant) (Respondent) Acit, Vs. Krish Patel, Central Circle-06, New Delhi 10, Executive Club Road, Chandanholla Mehrauli, New Delhi Pan: Aqvpp2875R (Appellant) (Respondent) Acit, Vs. Urmila Chandulal Patel, Central Circle-06, New Delhi 10, Executive Club Road, Chandanholla Mehrauli, New Delhi Pan: Aeipp1395R

For Appellant: Shri Raj Gupta, CAFor Respondent: Smt Sulekha Verma, CIT DR
Section 132Section 142Section 153Section 153C

…o documents found during search were incriminating in nature and prima facie represents undisclosed income o In the absence of above categorical findings in satisfaction note. 153C proceedings cannot be initiated CASE LAWS CIT Vs. IBC Knowledge Park (P) Ltd. 385 ITR 346 (Kar.) ―We answer the substantial question of law no.2 by holding that the tribunal was not correct in holding that the assessment under section 153C was valid despite there being no satisfaction recorded to the effect that the document found during the search on 1 7 June 2008 were incriminating in nature and prima facie represented undisclosed i…

ACIT, New Delhi vs. Krish Patel, New Delhi

Accordingly all the appeals of the revenue with respect to all these assesses are dismissed

ITA 1458/DEL/2015[2010-11]Status: DisposedITAT Delhi31 Dec 2018AY 2010-11

Bench: Shri Prashant Maharishi & Shri K.N.Charyacit, Vs. Rohan Patel, Central Circle-06, New Delhi 10, Executive Club Road, Chandanholla Mehrauli, New Delhi Pan: Asjpp8428L (Appellant) (Respondent) Acit, Vs. Himanshu Patel, Central Circle-06, New Delhi 10, Executive Club Road, Chandanholla Mehrauli, New Delhi Pan: Actpp8270C (Appellant) (Respondent) Acit, Vs. Praduman Patel, Central Circle-06, New Delhi 10, Executive Club Road, Chandanholla Mehrauli, New Delhi Pan: Ajhpp2206P (Appellant) (Respondent) Acit, Vs. Krish Patel, Central Circle-06, New Delhi 10, Executive Club Road, Chandanholla Mehrauli, New Delhi Pan: Aqvpp2875R (Appellant) (Respondent) Acit, Vs. Urmila Chandulal Patel, Central Circle-06, New Delhi 10, Executive Club Road, Chandanholla Mehrauli, New Delhi Pan: Aeipp1395R

For Appellant: Shri Raj Gupta, CAFor Respondent: Smt Sulekha Verma, CIT DR
Section 132Section 142Section 153Section 153C

…o documents found during search were incriminating in nature and prima facie represents undisclosed income o In the absence of above categorical findings in satisfaction note. 153C proceedings cannot be initiated CASE LAWS CIT Vs. IBC Knowledge Park (P) Ltd. 385 ITR 346 (Kar.) ―We answer the substantial question of law no.2 by holding that the tribunal was not correct in holding that the assessment under section 153C was valid despite there being no satisfaction recorded to the effect that the document found during the search on 1 7 June 2008 were incriminating in nature and prima facie represented undisclosed i…