Indian National Congress v. DCIT

463 ITR 431High Court2024#584 most cited

What is Indian National Congress v. DCIT authority for?

A consolidated satisfaction note covering multiple assessment years is valid for initiating proceedings under section 153C, provided the seized material and the additions rest on incriminating evidence pertaining to those years.

167

judgments rely on this decision, according to BharatTax’s citation analysis of 366,421 Indian tax judgments — from 2024 to 2026.

Also referred to as

Indian National Congress v. DCIT · section 153C · consolidated satisfaction note · incriminating material · assessment years · search and seizure · block period · section 132(4)

Also reported as

160 Taxmann.com 606

Sections most often in play

Section 153CSection 132Section 143(3)Section 153ASection 115BBESection 144Section 153DSection 292C

Issues it is cited on

section 153atosection 153b(1)(a)section 158bdabatement of assessmentsection 153c proceedingssection 153b(1)section 113income tax settlement commissionsection 269stsection 144ablock periodsection 153c(1)

Judgments citing Indian National Congress v. DCIT

Alankit Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4210/DEL/2025[2015-16]Status: DisposedITAT Delhi28 Nov 2025AY 2015-16

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

…e basis of this seized material impact of each assessment year has been tabulated in detail in compliance to the provisions of Section 153C. In this regard, reliance is placed on the Decision of Hon'ble Delhi High Court Indian National Congress v. DCIT [2024] 463 ITR 431, initially ruled that a composite satisfaction note would suffice the requirements of Section 153C, provided it included details of the material gathered during a search that pertained to all the assessment years in the block. 10. Further, reliance is also placed on the decision of Hon'ble Supreme Court in case of M/S Super Malls Private Limited…

Alankit Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4209/DEL/2025[2014-15]Status: DisposedITAT Delhi28 Nov 2025AY 2014-15

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

…e basis of this seized material impact of each assessment year has been tabulated in detail in compliance to the provisions of Section 153C. In this regard, reliance is placed on the Decision of Hon'ble Delhi High Court Indian National Congress v. DCIT [2024] 463 ITR 431, initially ruled that a composite satisfaction note would suffice the requirements of Section 153C, provided it included details of the material gathered during a search that pertained to all the assessment years in the block. 10. Further, reliance is also placed on the decision of Hon'ble Supreme Court in case of M/S Super Malls Private Limited…

Alankit Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4208/DEL/2025[2013-14]Status: DisposedITAT Delhi28 Nov 2025AY 2013-14

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

…e basis of this seized material impact of each assessment year has been tabulated in detail in compliance to the provisions of Section 153C. In this regard, reliance is placed on the Decision of Hon'ble Delhi High Court Indian National Congress v. DCIT [2024] 463 ITR 431, initially ruled that a composite satisfaction note would suffice the requirements of Section 153C, provided it included details of the material gathered during a search that pertained to all the assessment years in the block. 10. Further, reliance is also placed on the decision of Hon'ble Supreme Court in case of M/S Super Malls Private Limited…

Ratna Sagar Pvt Ltd, Delhi vs. DCIT, Central Circle-4, Delhi

In the result, appeals of the Assessee are partly allowed as

ITA 170/DEL/2025[2019-20]Status: DisposedITAT Delhi21 Nov 2025AY 2019-20

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.169 & 170/Del/2025 िनधा"रणवष"/Assessment Years:2018-19 & 2019-20 बनाम Ratna Sagar Pvt. Ltd., Dcit, Gf-10, Virat Bhawan, Mukherjee Nagar, Vs. Central Circle-4, Commercial Complex, Delhi. Jhandewalan Extn., C/O M/S Raj Kumar & Associates, New Delhi. L-7A (Lgf), South Extension, Part-Ii, New Delhi. Pan No.Aaacr1294C अपीलाथ" Appellant ""यथ"/Respondent

Section 132(4)Section 153CSection 65BSection 69ASection 7

…LTD. RATNA SAGAR (P) LTD. RATNA SAGAR (P) LTD. 4. On the other hand, the Ld. DR strongly placed reliance on the orders of the authorities below. Ld. DR also placed reliance on the decision of the Hon’ble Delhi High Court in the case of Indian Youth Congress (463 ITR 431). 5. Heard rival submissions, perused the orders of the authorities below. In this case on perusal of the RTI reply dated 28.01.2025 furnished by the Assessing Officer, we observed that the AO is unable to provide a copy of satisfaction note recorded by the AO of searched person. In the case of PCIT vs. G. Laxmi Aruna the Hon’ble Karnataka…

Ratna Sagar Pvt Ltd, Delhi vs. DCIT, Central Circle-4, Delhi

In the result, appeals of the Assessee are partly allowed as

ITA 169/DEL/2025[2018-19]Status: DisposedITAT Delhi21 Nov 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.169 & 170/Del/2025 िनधा"रणवष"/Assessment Years:2018-19 & 2019-20 बनाम Ratna Sagar Pvt. Ltd., Dcit, Gf-10, Virat Bhawan, Mukherjee Nagar, Vs. Central Circle-4, Commercial Complex, Delhi. Jhandewalan Extn., C/O M/S Raj Kumar & Associates, New Delhi. L-7A (Lgf), South Extension, Part-Ii, New Delhi. Pan No.Aaacr1294C अपीलाथ" Appellant ""यथ"/Respondent

Section 132(4)Section 153CSection 65BSection 69ASection 7

…LTD. RATNA SAGAR (P) LTD. RATNA SAGAR (P) LTD. 4. On the other hand, the Ld. DR strongly placed reliance on the orders of the authorities below. Ld. DR also placed reliance on the decision of the Hon’ble Delhi High Court in the case of Indian Youth Congress (463 ITR 431). 5. Heard rival submissions, perused the orders of the authorities below. In this case on perusal of the RTI reply dated 28.01.2025 furnished by the Assessing Officer, we observed that the AO is unable to provide a copy of satisfaction note recorded by the AO of searched person. In the case of PCIT vs. G. Laxmi Aruna the Hon’ble Karnataka…

Srs Panchratan Diamonds Pvt Ltd, Delhi vs. DCIT Central Circle-7, New Delhi

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

ITA 219/DEL/2023[2016-17]Status: DisposedITAT Delhi14 Nov 2025AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Arijit Chakraborty, AdvFor Respondent: Shri Mahesh Kumar, CIT (DR)
Section 132Section 143(2)Section 153ASection 153C

…, if any, shall stand disposed of. ITA Nos. 218 & 219/Del/2023 SRS Panchratan Diamonds Pvt. Ltd The Learned DR before us vehemently relied on the decision of the 8. Hon’ble Jurisdictional High Court in the case of Indian National Congress vs DCIT reported in 463 ITR 431 (Del) dated 22-03-2024 wherein it was held as under:- 24. The provision only requires the AO to be satisfied that the material collated and handed over is likely to have an impact on the total income for the relevant AY or AYs'. While an assessment would necessarily have to be made in respect of each of the relevant AY or AYs', we find ourselves…

Srs Panchratan Diamonds Pvt Ltd., New Delhi vs. DCIT Central Circle-7, New Delhi

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

ITA 218/DEL/2023[2015-16]Status: DisposedITAT Delhi14 Nov 2025AY 2015-16

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Arijit Chakraborty, AdvFor Respondent: Shri Mahesh Kumar, CIT (DR)
Section 132Section 143(2)Section 153ASection 153C

…, if any, shall stand disposed of. ITA Nos. 218 & 219/Del/2023 SRS Panchratan Diamonds Pvt. Ltd The Learned DR before us vehemently relied on the decision of the 8. Hon’ble Jurisdictional High Court in the case of Indian National Congress vs DCIT reported in 463 ITR 431 (Del) dated 22-03-2024 wherein it was held as under:- 24. The provision only requires the AO to be satisfied that the material collated and handed over is likely to have an impact on the total income for the relevant AY or AYs'. While an assessment would necessarily have to be made in respect of each of the relevant AY or AYs', we find ourselves…

Wockhardt Limited, Aurangabad vs. The Assistant Commissioner of Income Tax Central Circle 2(1), Pune

In the result, the appeal of the assessee is partly allowed

ITA 837/PUN/2025[2016-17]Status: DisposedITAT Pune10 Nov 2025AY 2016-17

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Manthan ShahFor Respondent: Shri Amit Bobde
Section 127Section 132Section 132(4)Section 143(2)Section 153C

…ith the determination of the total income of the other person for different AYs would be legal and valid. 9.2 Referring to the decision of the Hon’ble Delhi High Court in the case of Indian National Congress (INC) Vs. Deputy Commissioner of Income Tax (2024) 463 ITR 431 (Delhi), the Ld. DR submitted as under : “4.5 The principle of substance over form in relation to satisfaction note u/s 153C has been upheld by Delhi High Court in the case of Indian National Congress(INC) Vs. Deputy Commissioner of Income Tax[2024] 463 ITR 431 (Delhi) (Annexure-4 of the PB) wherein the Hon. High Court has specifically dealt with…

Wockhardt Limited, Aurangabad vs. The Assistant Commissioner of Income Tax Central Circle 2(1), Pune

In the result, the appeal of the assessee is partly allowed

ITA 836/PUN/2025[2018-19]Status: DisposedITAT Pune10 Nov 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Manthan ShahFor Respondent: Shri Amit Bobde
Section 127Section 132Section 132(4)Section 143(2)Section 153C

…ith the determination of the total income of the other person for different AYs would be legal and valid. 9.2 Referring to the decision of the Hon’ble Delhi High Court in the case of Indian National Congress (INC) Vs. Deputy Commissioner of Income Tax (2024) 463 ITR 431 (Delhi), the Ld. DR submitted as under : “4.5 The principle of substance over form in relation to satisfaction note u/s 153C has been upheld by Delhi High Court in the case of Indian National Congress(INC) Vs. Deputy Commissioner of Income Tax[2024] 463 ITR 431 (Delhi) (Annexure-4 of the PB) wherein the Hon. High Court has specifically dealt with…

Wockhardt Limited, Aurangabad vs. The Assistant Commissioner of Income Tax Central Circle-2(1), Pune

In the result, the appeal of the assessee is partly allowed

ITA 835/PUN/2025[2017-18]Status: DisposedITAT Pune10 Nov 2025AY 2017-18

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.837, 835 & 836/Pun/2025 निर्धारण वर्ष / Assessment Years : 2016-17, 2017-18 & 2018-19 Wockhardt Limited, D-4, Midc, Chikalthana, Aurangabad-431006 Vs. Assistant Commissioner Of Income Tax, Central Circle-2(1), Pune Pan : Aaacw2472M अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Shri Manthan Shah Shri Amit Bobde 13-08-2025 10-11-2025 आदेश / Order Per Astha Chandra, Jm : The Above Three Captioned Appeals Filed By The Assessee Are Directed Against The Separate Order(S) All Dated 27.01.2025 Of The Ld. Commissioner Of Income Tax (Appeals)-12, Pune ["Cit(A)"] Pertaining To Assessment Years ("Ays") 2016-17, 2017-18 & 2018-19. Since, The Issue(S) Involved Are Identical, These Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Department byFor Respondent: Date of hearing
Section 127Section 132Section 132(4)Section 143(2)Section 153C

…with the determination of the total income of the other person for different AYs would be legal and valid. 9.2 Referring to the decision of the Hon'ble Delhi High Court in the case of Indian National Congress (INC) Vs. Deputy Commissioner of Income Tax (2024) 463 ITR 431 (Delhi), the Ld. DR submitted as under : “4.5 The principle of substance over form in relation to satisfaction note u/s 153C has been upheld by Delhi High Court in the case of Indian National Congress(INC) Vs. Deputy Commissioner of Income Tax[2024] 463 ITR 431 (Delhi) (Annexure-4 of the PB) wherein the Hon. High Court has specifically dealt with…

Stercon Energy Pvt. Ltd., Delhi vs. ACIT, Central Circle-29, Delhi

In the result, the appeal of the assessee is allowed

ITA 5798/DEL/2024[2016-17]Status: DisposedITAT Delhi17 Oct 2025AY 2016-17

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.5797/Del/2024 (ASSESSMENT YEAR 2017-18) Asst. CIT, Stercon Energy Pvt. Ltd., Central Circle-29, 215-219 Pearls Business Park, Vs. New Delhi. Saraswati Park, Delhi-110034. PAN-AAOCS7746Q (Appellant) (Respondent) Assessee by Shri Amol Sinha, Adv., & Shri Ankit Kumar, Adv. Department by Shri Dayainder Singh Sindhu, CIT(D Date of Hearing 16/10/2025 Date of Pronouncement 17/10/2025 O R D E R PER MANISH AGARWAL, AM: These three appeals are filed by the asses…

Stercon Energy Pvt. Ltd., Delhi vs. ACIT Central Circle- 29, Delhi

In the result, the appeal of the assessee is allowed

ITA 5797/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Oct 2025AY 2017-18

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.5797/Del/2024 (ASSESSMENT YEAR 2017-18) Asst. CIT, Stercon Energy Pvt. Ltd., Central Circle-29, 215-219 Pearls Business Park, Vs. New Delhi. Saraswati Park, Delhi-110034. PAN-AAOCS7746Q (Appellant) (Respondent) Assessee by Shri Amol Sinha, Adv., & Shri Ankit Kumar, Adv. Department by Shri Dayainder Singh Sindhu, CIT(D Date of Hearing 16/10/2025 Date of Pronouncement 17/10/2025 O R D E R PER MANISH AGARWAL, AM: These three appeals are filed by the asses…

Stercon Energy Pvt Ltd, Delhi vs. ACIT, Central Circle-29, Delhi

In the result, the appeal of the assessee is allowed

ITA 5796/DEL/2024[2018-19]Status: DisposedITAT Delhi17 Oct 2025AY 2018-19

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.5797/Del/2024 (ASSESSMENT YEAR 2017-18) Asst. CIT, Stercon Energy Pvt. Ltd., Central Circle-29, 215-219 Pearls Business Park, Vs. New Delhi. Saraswati Park, Delhi-110034. PAN-AAOCS7746Q (Appellant) (Respondent) Assessee by Shri Amol Sinha, Adv., & Shri Ankit Kumar, Adv. Department by Shri Dayainder Singh Sindhu, CIT(D Date of Hearing 16/10/2025 Date of Pronouncement 17/10/2025 O R D E R PER MANISH AGARWAL, AM: These three appeals are filed by the asses…

ACIT, Central Circle-2(3), Pune vs. Subhash Jivraj Jain, Pune

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

ITA 1690/PUN/2024[2017-18]Status: DisposedITAT Pune21 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2017-18

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Akhilesh Srivastva, Addl.CIT
Section 131Section 132Section 143(2)Section 153C

…n can hinder the legitimate collection of taxes. Further, there is no explicit prohibition in the statute for such common satisfaction note. 15. Referring to the decision of the Hon’ble Delhi High Court in the case of Indian National Congress vs. DCIT (2024) 463 ITR 431 (Del), he submitted that the Hon’ble High Court in the said decision has held that satisfaction note merely forms foundation for initiation of action which would enable to evaluate whether an opinion has been validly formed and as long as it rests on incriminating material, which pertains to assessment years in question, same would qualify requir…

Ashok Bharti Goswami, Pune vs. ACIT, Central Circle 2(1), Pune

In the result, all the appeals filed by the respective assessees are allowed

ITA 1272/PUN/2024[2018-19]Status: DisposedITAT Pune14 Jul 2025AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

…n can hinder the legitimate collection of taxes. Further, there is no explicit prohibition in the statute for such common satisfaction note. 49. Referring to the decision of the Hon’ble Delhi High Court in the case of Indian National Congress vs. DCIT (2024) 463 ITR 431 (Del), he submitted that the Hon’ble High Court in the said decision has held that satisfaction note merely forms foundation for initiation of action which would enable to evaluate whether an opinion has been validly formed and as long as it rests on incriminating material, which pertains to assessment years in question, same would qualify requir…

Ashish Ramesh Oswal, Pune vs. ACIT, Central Circle 2(1), Pune

ITA 1271/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

…n can hinder the legitimate collection of taxes. Further, there is no explicit prohibition in the statute for such common satisfaction note. 49. Referring to the decision of the Hon'ble Delhi High Court in the case of Indian National Congress vs. DCIT (2024) 463 ITR 431 (Del), he submitted that the Hon'ble High Court in the said decision has held that satisfaction note merely forms foundation for initiation of action which would enable to evaluate whether an opinion has been validly formed and as long as it rests on incriminating material, which pertains to assessment years in question, same would qualify requir…

Adish Shantilal Solanki, Pune vs. Assistant Commissioner of Income Tax, Central Circle-2(1), Pune

ITA 1270/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

Section 131Section 132Section 142(1)Section 143(1)Section 153C

…on can hinder the legitimate collection of taxes. Further, there is no explicit prohibition in the statute for such common satisfaction note. 49. Referring to the decision of the Hon'ble Delhi High Court in the case of Indian National Congress vs. DCIT (2024) 463 ITR 431 (Del), he submitted that the Hon'ble High Court in the said decision has held that satisfaction note merely forms foundation for initiation of action which would enable to evaluate whether an opinion has been validly formed and as long as it rests on incriminating material, which pertains to assessment years in question, same would qualify requir…

Chitra Narendra Parmar, Pune vs. Assistant Commissioner of Income Tax, Central Circle-2(1), Pune

In the result, all the appeals filed by the respective assessees are allowed

ITA 1269/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

…n can hinder the legitimate collection of taxes. Further, there is no explicit prohibition in the statute for such common satisfaction note. 49. Referring to the decision of the Hon’ble Delhi High Court in the case of Indian National Congress vs. DCIT (2024) 463 ITR 431 (Del), he submitted that the Hon’ble High Court in the said decision has held that satisfaction note merely forms foundation for initiation of action which would enable to evaluate whether an opinion has been validly formed and as long as it rests on incriminating material, which pertains to assessment years in question, same would qualify requir…

Ramlal Bhikulal Shah, Pune vs. ACIT, Central Circle 2(1), Pune

In the result, all the appeals filed by the respective assessees are allowed

ITA 1268/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

…n can hinder the legitimate collection of taxes. Further, there is no explicit prohibition in the statute for such common satisfaction note. 49. Referring to the decision of the Hon’ble Delhi High Court in the case of Indian National Congress vs. DCIT (2024) 463 ITR 431 (Del), he submitted that the Hon’ble High Court in the said decision has held that satisfaction note merely forms foundation for initiation of action which would enable to evaluate whether an opinion has been validly formed and as long as it rests on incriminating material, which pertains to assessment years in question, same would qualify requir…

Deepak Kantilal Jain, Pune vs. ACIT, Central Circle 2(1), Pune

The appeal stands dismissed

ITA 1267/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

Section 131Section 132Section 142(1)Section 143(1)Section 153C

…on can hinder the legitimate collection of taxes. Further, there is no explicit prohibition in the statute for such common satisfaction note. 49. Referring to the decision of the Hon'ble Delhi High Court in the case of Indian National Congress vs. DCIT (2024) 463 ITR 431 (Del), he submitted that the Hon'ble High Court in the said decision has held that satisfaction note merely forms foundation for initiation of action which would enable to evaluate whether an opinion has been validly formed and as long as it rests on incriminating material, which pertains to assessment years in question, same would qualify requir…