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 366,416 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

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

The appeal stands dismissed

ITA 1265/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17

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…

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

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

ITA 1264/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17

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…

Chitra Narendra Parmar, Pune vs. ACIT, Central Circle 2(1), Pune

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

ITA 1262/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17

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…

Assistant Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Kasthoori Raja Dhanush, Chennai

In the result, all the appeals of the Revenue and Cross-Objections

ITA 3192/CHNY/2024[2020-21]Status: DisposedITAT Chennai30 Jun 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3188 To 3192/Chny/2024 निर्धारणवर्ष/Assessment Years: 2015-16, 2016-17, 2017-18, 2019-20 & 2020-21 & Cross-Objection Nos.22 To 26/Chny/2025 निर्धारणवर्ष/Assessment Years: 2015-16, 2016-17, 2017-18, 2019-20 & 2020-21 The Acit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement V. : : : : Kasthoori Raja Dhanush, Old No.16/5, New No.33/5, Rajamannar Street, Thyagaraya Nagar, Chennai-600 017. [Pan: Actpv 0618 E] (प्रत्यर्थी/Respondent/Cross- Objector) Mrs. Sheila Parthasarthy, Cit Mr. N. Arjun Raj, Advocate 28.04.2025 30.06.2025 आदेश / Order Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals) 19, Chennai (Hereinafter Referred To As `Ld.Cit(A) `) All Dated 17.10.2024 For The

Section 132Section 153ASection 15ASection 271D

…ted 30.8.2022 was valid in as much as it contained sufficient reference to the incriminating material found in the course of search. For this, the Ld. CIT, DR relied on the decision of Hon'ble Delhi High Court in the case of Indian National Congress vs. DCIT (463 ITR 431). The Ld. CIT, DR further submitted that, the proceedings u/s 153C have been validly initiated for the preceding six assessment years viz., AYs 2014-15 to AY 2020-21, by taking the reference date of search to be 05-02-2020, in light of the amendment brought in Section 153C by Finance Act, 2017. The Ld. CIT, DR referred to CBDT Circular No. 24/201…

Assistant Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Kasthoori Raja Dhanush, Chennai

In the result, all the appeals of the Revenue and In the result, all the appeals of the Revenue and Cross

ITA 3190/CHNY/2024[2017-18]Status: DisposedITAT Chennai30 Jun 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Mrs. Sheila Parthasarthy, CIT
Section 132Section 15A

…urse of search. For this, the Ld. CIT, DR relied on the found in the course of search. For this, the Ld. CIT, DR relied on the decision of Hon’ble Delhi Hi decision of Hon’ble Delhi High Court in the case of Indian National Indian National Congress vs. DCIT (463 ITR 431). The Ld. CIT, DR further submitted . The Ld. CIT, DR further submitted Congress vs. DCIT (463 ITR 431) that, the proceedings u/s 153C have been validly initiated for the that, the proceedings u/s 153C have been validly initiated for the that, the proceedings u/s 153C have been validly initiated for the preceding six assessment years preceding s…

Assistant Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Kasthoori Raja Dhanush, Chennai

In the result, all the appeals of the Revenue and In the result, all the appeals of the Revenue and Cross

ITA 3189/CHNY/2024[2016-17]Status: DisposedITAT Chennai30 Jun 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Mrs. Sheila Parthasarthy, CIT
Section 132Section 15A

…urse of search. For this, the Ld. CIT, DR relied on the found in the course of search. For this, the Ld. CIT, DR relied on the decision of Hon’ble Delhi Hi decision of Hon’ble Delhi High Court in the case of Indian National Indian National Congress vs. DCIT (463 ITR 431). The Ld. CIT, DR further submitted . The Ld. CIT, DR further submitted Congress vs. DCIT (463 ITR 431) that, the proceedings u/s 153C have been validly initiated for the that, the proceedings u/s 153C have been validly initiated for the that, the proceedings u/s 153C have been validly initiated for the preceding six assessment years preceding s…

Assistant Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Kasthoori Raja Dhanush, Chennai

In the result, all the appeals of the Revenue and In the result, all the appeals of the Revenue and Cross

ITA 3188/CHNY/2024[2015-16]Status: DisposedITAT Chennai30 Jun 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Mrs. Sheila Parthasarthy, CIT
Section 132Section 15A

…urse of search. For this, the Ld. CIT, DR relied on the found in the course of search. For this, the Ld. CIT, DR relied on the decision of Hon’ble Delhi Hi decision of Hon’ble Delhi High Court in the case of Indian National Indian National Congress vs. DCIT (463 ITR 431). The Ld. CIT, DR further submitted . The Ld. CIT, DR further submitted Congress vs. DCIT (463 ITR 431) that, the proceedings u/s 153C have been validly initiated for the that, the proceedings u/s 153C have been validly initiated for the that, the proceedings u/s 153C have been validly initiated for the preceding six assessment years preceding s…

Harish Kumar Agrawal, Uttar Pradesh vs. Deputy Commissioner of Income Tax, Central Circle -3, New Delhi

Appeal is allowed in above terms

ITA 5652/DEL/2024[2020-21]Status: DisposedITAT Delhi03 Jun 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2020-21 Vs. Dcit, Sh. Harish Kumar Agrawal, 1080, Arya Nagar, Gali No. 3, Central Circle-3, Kosi Kalan, New Delhi Uttar Pradesh Pan: Aawpa1906F (Appellant) (Respondent) Assessee By Sh. M.M. Agrawal, Ca Department By Ms. Suman Malik, Cit(Dr)

Section 153ASection 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘B’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Assessment Year: 2020-21 Vs. DCIT, Sh. Harish Kumar Agrawal, 1080, Arya Nagar, Gali No. 3, Central Circle-3, Kosi Kalan, New Delhi Uttar Pradesh PAN: AAWPA1906F (Appellant) (Respondent) Assessee by Sh. M.M. Agrawal, CA Department by Ms. Suman Malik, CIT(DR) Date of hearing 03.06.2025 Date of pronouncement 03.06.2025 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2020-21, arises against the Commissioner of Income Tax (Appeals)…

DCIT., Central Circle-1(3), Hyderabad vs. Sudhakar Reddy Nalla, Hyderabad

ITA 776/HYD/2024[2016-17]Status: DisposedITAT Hyderabad01 Apr 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: : Smt. M. Narmada, CIT-DR &
Section 132Section 153CSection 69ASection 69C

…sions of section 153C of the Act for recording CSN for more than one year. In support of her contention, the Ld. DR invited our attention to para nos.22 to 25 of the decision of Hon'ble Delhi High Court in the case of Indian National Congresss Vs. DCIT (2024) 463 ITR 431 (Del) wherein the Hon'ble Court has held that, there is no bar in the statute qua recording of CSN. The only condition which has been specified under the statute is the satisfaction of the Ld. AO that the seized material has an impact on the total income for the relevant assessment year. The Ld. DR also invited our attention to page no.54 of the…

DCIT., Central Circle-1(3), Hyderabad vs. Sudhakar Reddy Nalla, Hyderabad

ITA 1194/HYD/2024[2019-20]Status: DisposedITAT Hyderabad01 Apr 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: : Smt. M. Narmada, CIT-DR &
Section 132Section 153CSection 69ASection 69C

…sions of section 153C of the Act for recording CSN for more than one year. In support of her contention, the Ld. DR invited our attention to para nos.22 to 25 of the decision of Hon'ble Delhi High Court in the case of Indian National Congresss Vs. DCIT (2024) 463 ITR 431 (Del) wherein the Hon'ble Court has held that, there is no bar in the statute qua recording of CSN. The only condition which has been specified under the statute is the satisfaction of the Ld. AO that the seized material has an impact on the total income for the relevant assessment year. The Ld. DR also invited our attention to page no.54 of the…

Sudhakar Reddy Nalla, Hyderabad vs. DCIT., Central Circle-1(3), Hyderabad

ITA 1098/HYD/2024[2016-17]Status: DisposedITAT Hyderabad01 Apr 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: : Smt. M. Narmada, CIT-DR &
Section 132Section 153CSection 69ASection 69C

…sions of section 153C of the Act for recording CSN for more than one year. In support of her contention, the Ld. DR invited our attention to para nos.22 to 25 of the decision of Hon'ble Delhi High Court in the case of Indian National Congresss Vs. DCIT (2024) 463 ITR 431 (Del) wherein the Hon'ble Court has held that, there is no bar in the statute qua recording of CSN. The only condition which has been specified under the statute is the satisfaction of the Ld. AO that the seized material has an impact on the total income for the relevant assessment year. The Ld. DR also invited our attention to page no.54 of the…

Mr. Abhishek Chhabra, New Delhi vs. ITO, New Delhi

Appeal is allowed in above terms

ITA 5652/DEL/2013[2009-10]Status: DisposedITAT Delhi19 Mar 2025AY 2009-10

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2020-21 Vs. Dcit, Sh. Harish Kumar Agrawal, 1080, Arya Nagar, Gali No. 3, Central Circle-3, Kosi Kalan, New Delhi Uttar Pradesh Pan: Aawpa1906F (Appellant) (Respondent) Assessee By Sh. M.M. Agrawal, Ca Department By Ms. Suman Malik, Cit(Dr)

Section 153ASection 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘B’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Assessment Year: 2020-21 Vs. DCIT, Sh. Harish Kumar Agrawal, 1080, Arya Nagar, Gali No. 3, Central Circle-3, Kosi Kalan, New Delhi Uttar Pradesh PAN: AAWPA1906F (Appellant) (Respondent) Assessee by Sh. M.M. Agrawal, CA Department by Ms. Suman Malik, CIT(DR) Date of hearing 03.06.2025 Date of pronouncement 03.06.2025 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2020-21, arises against the Commissioner of Income Tax (Appeals)…

ACIT, Central Circle- 30, New Delhi vs. Kuber Securities, New Delhi

ITA 4213/DEL/2018[2013-14]Status: DisposedITAT Delhi03 Mar 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…

ITO, Ward- 6(4), New Delhi vs. Creative Techno Solutions Pvt. Ltd., New Delhi

ITA 4265/DEL/2017[2012-13]Status: DisposedITAT Delhi27 Feb 2025AY 2012-13

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…

Partistha Commercial Centre Private Limited, Delhi vs. Commissioner of Income Tax (Appeals), Delhi

ITA 4264/DEL/2024[2016-17]Status: DisposedITAT Delhi23 Jan 2025AY 2016-17

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…

DCIT, Ghaziabad vs. M/S. Devidayal Aluminium Industries Pvt. Ltd., Ghaziabad

ITA 4297/DEL/2016[2013-14]Status: DisposedITAT Delhi08 Jan 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…

Renu Singh, Delhi vs. Assistant Commissioner of Income Tax, Central Circle-3, Delhi

In the result, the appeal of the assessee is allowed

ITA 2806/DEL/2024[2019-20]Status: DisposedITAT Delhi25 Nov 2024AY 2019-20

Bench: Shri Pradip Kumar Kedia & Shri Pradip Kumar Kedia & Shri Pradip Kumar Kedia & Shri Vimal Kumarshri Vimal Kumar

Section 1Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL N THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI “F” BENCH: NEW DELHI BEFORE SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER & SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER & SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER & SHRI VIMAL KUMAR, JUDICIAL MEMBER SHRI VIMAL KUMAR, JUDICIAL MEMBER ITA No [Assessment Year : Assessment Year : 2019-20] Renu Singh vs ACIT Pranshu Pranshu Goel, Goel, C Chartered Central Circle-3 3 Accountant 5A/3A 5A/3A Delhi Ansari Raod Darya Ganj Ansari Raod Darya Ganj New Delhi-110002 110002 PAN-CHVPS2282J CHVPS2282J APPELLANT RESPONDENT ITA No [Assessment Year :…

DCIT, CC-2(4), Chennai vs. V.Baskaran, Chennai

In the result, the appeal filed by the assessee in IT(SS)A No

ITA 604/CHNY/2021[2017-18]Status: DisposedITAT Chennai20 Sept 2024AY 2017-18

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri A.P. Srinivas, Sr. Standing Counsel
Section 132Section 142(1)Section 143(3)Section 144Section 158B

…ome of the assessee.That the law requires only prima facie satisfaction only has been corroborated by the courts of law Reliance is made on the IT(SS)A No.3/Chny/2017 & ruling of the Hon'ble Delhi High Court in the case of Indian National Congress reported in 463 ITR 431(Del) where it has been 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 requirement of section 153C of the Act.It is further subm…

Amol Awasthi, New Delhi vs. DCIT, Central Circle-I, New Delhi

In the result, appeals are allowed, as indicated

ITA 1348/DEL/2024[2018-19]Status: DisposedITAT Delhi13 Sept 2024AY 2018-19

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D” DELHI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT AND SHRI M BALAGANESH, ACCOUNTANT MEMBER ITA Nos.1342, 1343, 1344, 1345, 1346, 1347 & 1348/DEL/2024 Assessment Years: 2011-12, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 & 2018-19 Amol Awasthi, Vs. DCIT, Central Circle-I C/o Vinod Kumar Bindal & New Delhi Co. Chartered Accountants Shiv Sushil Bhawan D-219, Vivek Vihar, Phase-I New Delhi TAN/PAN: AACPA8416E (Appellant) (Respondent) Assessee by: Shri Vinod Kumar Bindal, AR Ms. Rinky Sharma, ITP Respondent by: Shri Vijay B Vasanta, CIT-DR Date of hearing: 03 07 202…

Amol Awasthi, New Delhi vs. DCIT, Central Circle-1, New Delhi

In the result, appeals are allowed, as indicated

ITA 1347/DEL/2024[2016-17]Status: DisposedITAT Delhi13 Sept 2024AY 2016-17

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D” DELHI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT AND SHRI M BALAGANESH, ACCOUNTANT MEMBER ITA Nos.1342, 1343, 1344, 1345, 1346, 1347 & 1348/DEL/2024 Assessment Years: 2011-12, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 & 2018-19 Amol Awasthi, Vs. DCIT, Central Circle-I C/o Vinod Kumar Bindal & New Delhi Co. Chartered Accountants Shiv Sushil Bhawan D-219, Vivek Vihar, Phase-I New Delhi TAN/PAN: AACPA8416E (Appellant) (Respondent) Assessee by: Shri Vinod Kumar Bindal, AR Ms. Rinky Sharma, ITP Respondent by: Shri Vijay B Vasanta, CIT-DR Date of hearing: 03 07 202…