ITO v. Vikram Sujitkumar Bhatia

453 ITR 417Supreme Court of India2023#2170 most cited

What is ITO v. Vikram Sujitkumar Bhatia authority for?

For assessments under Section 153C, the six or ten assessment years for which assessments can be made are counted backward from the assessment year in which the search was initiated on the searched person, as per the proviso to Section 153C(1). This clarifies the starting point for determining the block period for a person other than the one searched.

54

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2023 to 2026.

Also referred to as

ITO v. Vikram Sujitkumar Bhatia · Section 153C · Section 153C(1) proviso · relevant assessment years · block period · search assessment · person other than searched person · starting point for 153C · six assessment years · ten assessment years · Supreme Court

Also reported as

2023 SCC OnLine SC 370

Sections most often in play

Section 153CSection 153ASection 143(3)Section 132Section 147Section 148Section 151Section 69
Read the full judgment

Issues it is cited on

books or books of accountsection 153(c)(1)section 2(12a)section 2(40)section 153(c)section 141section 92esection 153c(1)section 153b(1)(b)jewellery found during searchblock periodsection 148(2)

Judgments citing ITO v. Vikram Sujitkumar Bhatia

ACIT CIR-19(1), NEW DELHI vs. SHIPRA BANSAL, NEW DELHI

In the result, appeal of the revenue is dismissed

ITA 4474/DEL/2025[2012-13]Status: DisposedITAT Delhi27 Jan 2026AY 2012-13

Bench: SHRI ANUBHAV SHARMA, JUDICAL MEMBER, SHRI MANISH AGARWAL (Accountant Member)

Section 132Section 142(1)Section 143(2)Section 153Section 153ASection 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’: NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ACIT, Circle 19(1), Shipra Bansal, Room No.221, 2nd Floor, CR Vs. W-82, Ground Floor, Building, New Delhi-110002 Greater Kailash-I, New-Delhi-110048 PAN:AAAPS4862N (Appellant) (Respondent) Department by Ms. Pooja Swaroop, CIT DR Assessee by Dr. Rakesh Gupta & Shri Somil Aggarwal, Advs. Date of hearing 21.01.2026 Date of pronouncement 27.01.2026 O R D E R PER MANISH AGARWAL, AM: This appeal is filed by the revenue against the order of the Ld. Commissioner of In…

BABULAL MULCHAND VARMA,MUMBAI vs. ACIT CENTRAL CIRCLE-4(3), MUMBAI

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

ITA 3150/MUM/2025[2009-10]Status: DisposedITAT Mumbai22 Jan 2026AY 2009-10

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Respondent: Mr. Ajay R. Singh &
Section 143(3)Section 153CSection 69

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “B” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAHUL CHAUDHARY (JUDICIAL MEMBER) ITA No. 3150 & 3148/MUM/2025 Assessment Year: 2009-10 & 2010-11 Babulal Mulchand Varma, Asst. CIT Central Circle-4(3), 35th Floor, Flat No. 3501, Four Room No. 420, 4th floor, Vs. Season, Private Residence Sub Kautilya Bhavan, C-41 to C- Plot No. 1 H 136, Dr. Moses 43, G Block, Bandra Kurla Road, Worli Naka, Lower Parel, Complex, Bandra (East), Mumbai-400018. Mumbai-400051. PAN NO. AARPV 5138 M Appellant Respondent : Mr. Ajay R. Singh & Assessee by Mr. Akshay…

BABULAL MULCHAND VARMA,MUMBAI vs. ACIT, CENTRAL CIRCLE-4(3), MUMBAI

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

ITA 3148/MUM/2025[2010-11]Status: DisposedITAT Mumbai22 Jan 2026AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Respondent: Mr. Ajay R. Singh &
Section 143(3)Section 153CSection 69

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “B” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAHUL CHAUDHARY (JUDICIAL MEMBER) ITA No. 3150 & 3148/MUM/2025 Assessment Year: 2009-10 & 2010-11 Babulal Mulchand Varma, Asst. CIT Central Circle-4(3), 35th Floor, Flat No. 3501, Four Room No. 420, 4th floor, Vs. Season, Private Residence Sub Kautilya Bhavan, C-41 to C- Plot No. 1 H 136, Dr. Moses 43, G Block, Bandra Kurla Road, Worli Naka, Lower Parel, Complex, Bandra (East), Mumbai-400018. Mumbai-400051. PAN NO. AARPV 5138 M Appellant Respondent : Mr. Ajay R. Singh & Assessee by Mr. Akshay…

ACIT-CIRCLE-2(1)(1), AGRA vs. PUNEET AGARWAL, AGRA

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

ITA 338/AGR/2025[2015-16]Status: DisposedITAT Agra04 Dec 2025AY 2015-16

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 132(1)Section 132(4)

…gement Set, wherein, the proceedings were initiated u/s 148 on the basis of document found from ‘third party’ and it was held following the decision of Hon’ble Supreme CO Nos.04, 03 & 05/Agr/2025 Court in the case of Sh. Vikram Sujit Kumar Bhatia, reported in 453 ITR 417, wherein, it has been held that the amendment in Finance Act 2015, where the legislature has used expression ‘pertains or pertain to’ in place of ‘belongs or belongs to’ will have retrospective effect and the issuance of notice u/s 153C is mandatory and the finding on this issue has been given in that judgment in para-9, page 296 of the judgement…

ACIT-CIRCEL-2(1)(1), AGRA vs. MAYANK AGRAWAL, AGRA

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

ITA 336/AGR/2025[2015-16]Status: DisposedITAT Agra04 Dec 2025AY 2015-16

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 132(1)Section 132(4)

…gement Set, wherein, the proceedings were initiated u/s 148 on the basis of document found from ‘third party’ and it was held following the decision of Hon’ble Supreme CO Nos.04, 03 & 05/Agr/2025 Court in the case of Sh. Vikram Sujit Kumar Bhatia, reported in 453 ITR 417, wherein, it has been held that the amendment in Finance Act 2015, where the legislature has used expression ‘pertains or pertain to’ in place of ‘belongs or belongs to’ will have retrospective effect and the issuance of notice u/s 153C is mandatory and the finding on this issue has been given in that judgment in para-9, page 296 of the judgement…

VISHWAMBHAR DAYAL AGARWAL,AGRA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE2(1)(1), AGRA, AGRA

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

ITA 330/AGR/2025[2015-16]Status: DisposedITAT Agra04 Dec 2025AY 2015-16

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 132(1)Section 132(4)

…gement Set, wherein, the proceedings were initiated u/s 148 on the basis of document found from ‘third party’ and it was held following the decision of Hon’ble Supreme CO Nos.04, 03 & 05/Agr/2025 Court in the case of Sh. Vikram Sujit Kumar Bhatia, reported in 453 ITR 417, wherein, it has been held that the amendment in Finance Act 2015, where the legislature has used expression ‘pertains or pertain to’ in place of ‘belongs or belongs to’ will have retrospective effect and the issuance of notice u/s 153C is mandatory and the finding on this issue has been given in that judgment in para-9, page 296 of the judgement…

DCIT, CENTRAL CIRCLE-28, NEW DELHI, NEW DELHI vs. CHANDRA VIDYA INVESTMENT & FINANCE PVT. LTD., NEW DELHI

In the result, appeals of Revenue in ITA No

ITA 3700/DEL/2025[2013-14]Status: DisposedITAT Delhi07 Nov 2025AY 2013-14

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Monika Singh, CT-DR
Section 153Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘F’ BENCH, NEW DELHI BEFORE SHRI YOGESH KUMAR US, JUDICIAL MEMBER, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No.3697/DEL/2025 [A.Y. 2010-11] ITA No.3698/DEL/2025 [A.Y. 2011-12] ITA No. 3699/DEL/2025 [A.Y. 2012-13] ITA No. 3700/DEL/2025 [A.Y. 2013-14] The Dy. C.I.T Vs. M/s Chandra Vidya Investment & Finance Central Circle -28 Pvt Ltd., 86-A, 3rd Floor, Left Side New Delhi Panchsheel Park, New Delhi PAN: AAACC 1174 A (Applicant) (Respondent) Assessee By : None Department By : Shri Monika Singh, CT-DR Date of Hearing : 15.10.2025 Date of Pronouncement : 07.…

DCIT, CENTRAL CIRCLE -28, NEW DELHI, NEW DELHI vs. CHANDRA VIDYA INVESTMENT & FINANCE PVT. LTD., NEW DELHI

In the result, appeals of Revenue in ITA No

ITA 3699/DEL/2025[2012-13]Status: DisposedITAT Delhi07 Nov 2025AY 2012-13

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Monika Singh, CT-DR
Section 153Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘F’ BENCH, NEW DELHI BEFORE SHRI YOGESH KUMAR US, JUDICIAL MEMBER, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No.3697/DEL/2025 [A.Y. 2010-11] ITA No.3698/DEL/2025 [A.Y. 2011-12] ITA No. 3699/DEL/2025 [A.Y. 2012-13] ITA No. 3700/DEL/2025 [A.Y. 2013-14] The Dy. C.I.T Vs. M/s Chandra Vidya Investment & Finance Central Circle -28 Pvt Ltd., 86-A, 3rd Floor, Left Side New Delhi Panchsheel Park, New Delhi PAN: AAACC 1174 A (Applicant) (Respondent) Assessee By : None Department By : Shri Monika Singh, CT-DR Date of Hearing : 15.10.2025 Date of Pronouncement : 07.…

DCIT, CENTRAL CIRCLE-28, NEW DELHI, NEW DELHI vs. CHANDRA VIDYA INVESTMENT & FINANCE PVT. LTD., NEW DELHI

In the result, appeals of Revenue in ITA No

ITA 3698/DEL/2025[2011-12]Status: DisposedITAT Delhi07 Nov 2025AY 2011-12

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Monika Singh, CT-DR
Section 153Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘F’ BENCH, NEW DELHI BEFORE SHRI YOGESH KUMAR US, JUDICIAL MEMBER, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No.3697/DEL/2025 [A.Y. 2010-11] ITA No.3698/DEL/2025 [A.Y. 2011-12] ITA No. 3699/DEL/2025 [A.Y. 2012-13] ITA No. 3700/DEL/2025 [A.Y. 2013-14] The Dy. C.I.T Vs. M/s Chandra Vidya Investment & Finance Central Circle -28 Pvt Ltd., 86-A, 3rd Floor, Left Side New Delhi Panchsheel Park, New Delhi PAN: AAACC 1174 A (Applicant) (Respondent) Assessee By : None Department By : Shri Monika Singh, CT-DR Date of Hearing : 15.10.2025 Date of Pronouncement : 07.…

DCIT, CENTRAL CIRCLE-28, NEW DELHI, NEW DELHI vs. CHANDRA VIDYA INVESTMENT & FINANCE PVT. LTD., NEW DELHI

In the result, appeals of Revenue in ITA No

ITA 3697/DEL/2025[2010-11]Status: DisposedITAT Delhi07 Nov 2025AY 2010-11

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Monika Singh, CT-DR
Section 153Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘F’ BENCH, NEW DELHI BEFORE SHRI YOGESH KUMAR US, JUDICIAL MEMBER, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No.3697/DEL/2025 [A.Y. 2010-11] ITA No.3698/DEL/2025 [A.Y. 2011-12] ITA No. 3699/DEL/2025 [A.Y. 2012-13] ITA No. 3700/DEL/2025 [A.Y. 2013-14] The Dy. C.I.T Vs. M/s Chandra Vidya Investment & Finance Central Circle -28 Pvt Ltd., 86-A, 3rd Floor, Left Side New Delhi Panchsheel Park, New Delhi PAN: AAACC 1174 A (Applicant) (Respondent) Assessee By : None Department By : Shri Monika Singh, CT-DR Date of Hearing : 15.10.2025 Date of Pronouncement : 07.…

DCIT ,CENTRAL CIRCLE-28, NEW DELHI, NEW DELHI vs. M/S TRANSLINE TECHNOLOGIES PVT LTD, NEW DELHI

In the result, appeals of Revenue in ITA No

ITA 3694/DEL/2025[2012-13]Status: DisposedITAT Delhi07 Nov 2025AY 2012-13

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: M/s Chinu BhasinFor Respondent: Shri Monika Singh, CT-DR
Section 1Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘F’ BENCH, NEW DELHI BEFORE SHRI YOGESH KUMAR US, JUDICIAL MEMBER, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No.3693/DEL/2025 [A.Y. 2011-12] ITA No. 3694/DEL/2025 [A.Y. 2012-13] The Dy. C.I.T Vs. M/s Transline Technologies Ltd 23-A, 3rd Floor, Moti Nagar Central Circle -28 New Delhi West Delhi, New Delhi PAN: AABCT 3687 J CO No. 36/DEL/2025 (A/o ITA No.3693/DEL/2025 [A.Y. 2011-12]) [ CO No. 37/DEL/2025 (A/o ITA No. 3694/DEL/2025 [A.Y. 2012-13]) M/s Transline Technologies Ltd Vs. The Dy. C.I.T 23-A, 3rd Floor, Moti Nagar Central Circle -28 West Delhi, New Del…

DCIT, CENTRAL CIRCLE-28, NEW DELHI, NEW DELHI vs. M/S TRANSLINE TECHNOLOGIES LIMITED, NEW DELHI

In the result, appeals of Revenue in ITA No

ITA 3693/DEL/2025[2011-12]Status: DisposedITAT Delhi07 Nov 2025AY 2011-12

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: M/s Chinu BhasinFor Respondent: Shri Monika Singh, CT-DR
Section 1Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘F’ BENCH, NEW DELHI BEFORE SHRI YOGESH KUMAR US, JUDICIAL MEMBER, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No.3693/DEL/2025 [A.Y. 2011-12] ITA No. 3694/DEL/2025 [A.Y. 2012-13] The Dy. C.I.T Vs. M/s Transline Technologies Ltd 23-A, 3rd Floor, Moti Nagar Central Circle -28 New Delhi West Delhi, New Delhi PAN: AABCT 3687 J CO No. 36/DEL/2025 (A/o ITA No.3693/DEL/2025 [A.Y. 2011-12]) [ CO No. 37/DEL/2025 (A/o ITA No. 3694/DEL/2025 [A.Y. 2012-13]) M/s Transline Technologies Ltd Vs. The Dy. C.I.T 23-A, 3rd Floor, Moti Nagar Central Circle -28 West Delhi, New Del…

JOINT COMMISSIONER OF INCOME TAX (IN SITU) CIRCLE-I, , LUDHIANA vs. KAPIL THAPAR, LUDHIANA

In the result, appeal of the Department is dismissed and Cross

ITA 246/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh28 Oct 2025AY 2016-17

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 148Section 153CSection 69A

…accounts/documents/information unearthed during the course of search and, thus, under such circumstances, the notice u/s 153C is required to be issued. iv) The binding judgment of Hon'ble Supreme Court in the case of "Vikram Sujit Kumar Bhatia", reported in 453 ITR 417 is clearly applicable. v) It is further submitted that earlier before Finance Act 2015, the words were belong or belongs to instead of pertain or pertains to and, thus, it is submitted that the Assessing Officer ought to have followed the procedure contemplated in section 153C, which is mandatory one, since the AO has failed to follow this proced…

DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI vs. SHREE VARDHMAN DEVELOPERS PRIVATE LIMITED, NEW DELHI

In the result, appeal of Revenue in ITA No

ITA 4009/DEL/2025[2011-12]Status: DisposedITAT Delhi27 Oct 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 153Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘G’ BENCH, NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 4009/DEL/2025 [A.Y 2011-12] The Dy. C.I.T Vs. Shree Vardhman Developers Pvt New Delhi 301-311, Indraprakash Building 21, Barakhamba Road, Connaught Place, New Delhi PAN: AACCV 1495 M (Appellant) (Respondent) Assessee By : Shri Ved Jain, Adv Shri Pawan Garg, CA Ms. Ishika Dua, CA Department By : Shri Mahesh Kumar, CIT-DR Date of Hearing : 09.10.2025 Date of Pronouncement : 27.10.2025 PER NAVEEN CHANDRA, AM :- This appeal by the assessee is di…

ISHA GUPTA,PITAMPURA DELHI vs. CENTRAL CIRCLE 28, DELHI, JHANDEWALAN

The appeals are allowed and the impugned assessments are quashed

ITA 4319/DEL/2025[2014-15]Status: DisposedITAT Delhi19 Sept 2025AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Raghav Sharma &For Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 144Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: A : NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI ANUBHAV SHARMA, JUDICIAL MEMBER ITAs No.1764 & 4319/Del/2025 Assessment Years: 2013-14 & 2014-15 Isha Gupta, Vs DCIT, KU 73, Pitampura, Central Circle-28, Sri Nagar Colony, Delhi. North West Delhi, New Delhi. PAN: AAOPG4352K (Appellant) (Respondent) Assessee by : Shri Raghav Sharma & Shri Mohit Gupta, CAs; & Ms Agni Chaudhary, Advocate Revenue by : Shri Ajay Kumar Arora, Sr. DR Date of Hearing : 03.09.2025 Date of Pronouncement : 19.09.2025 ORDER PER ANUBHAV SHARMA, JM: These are appeals…

ISHA GUPTA,DELHI vs. DCIT CC 28, JHANDEWALAN

The appeals are allowed and the impugned assessments are quashed

ITA 1764/DEL/2025[2013-14]Status: DisposedITAT Delhi19 Sept 2025AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Raghav Sharma &For Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 144Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: A : NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI ANUBHAV SHARMA, JUDICIAL MEMBER ITAs No.1764 & 4319/Del/2025 Assessment Years: 2013-14 & 2014-15 Isha Gupta, Vs DCIT, KU 73, Pitampura, Central Circle-28, Sri Nagar Colony, Delhi. North West Delhi, New Delhi. PAN: AAOPG4352K (Appellant) (Respondent) Assessee by : Shri Raghav Sharma & Shri Mohit Gupta, CAs; & Ms Agni Chaudhary, Advocate Revenue by : Shri Ajay Kumar Arora, Sr. DR Date of Hearing : 03.09.2025 Date of Pronouncement : 19.09.2025 ORDER PER ANUBHAV SHARMA, JM: These are appeals…

SH. MOHIT AGARWAL,JAIPUR vs. DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR

In the result, both the appeals of the Revenue mentioned (supra) are dismissed and the appeal of the assessee is partly allowed in above terms

ITA 788/JPR/2025[2020-21]Status: DisposedITAT Jaipur15 Sept 2025AY 2020-21

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, C.A, Ld. ARFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 132Section 153ASection 153CSection 250Section 69Section 69A

…d in this regard the date of search is 22-10-2019. The language of section as on date of issuance of notice u/s. 153C shall apply as per ratio of Income-tax Officer v. Vikram Sujit kumar Bhatia [2023] 149 taxmann.com 123 (SC)/ [2023] 293 Taxman 4 (SC)/ [2023] 453 ITR 417 (SC) [06-04-2023]. No opinion is being expressed on the contention of the merits of the case including on the contention of the appellant regarding that all the additions made in the assessment order have been considered in the settlement petition filed by the father of the appellant as such issue has not been examined. Needless to say, in the a…

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. MOHIT AGARWAL, JAIPUR

In the result, both the appeals of the Revenue mentioned (supra) are dismissed and the appeal of the assessee is partly allowed in above terms

ITA 104/JPR/2025[2016]Status: DisposedITAT Jaipur15 Sept 2025

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, C.A, Ld. ARFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 132Section 153ASection 153CSection 250Section 69Section 69A

…d in this regard the date of search is 22-10-2019. The language of section as on date of issuance of notice u/s. 153C shall apply as per ratio of Income-tax Officer v. Vikram Sujit kumar Bhatia [2023] 149 taxmann.com 123 (SC)/ [2023] 293 Taxman 4 (SC)/ [2023] 453 ITR 417 (SC) [06-04-2023]. No opinion is being expressed on the contention of the merits of the case including on the contention of the appellant regarding that all the additions made in the assessment order have been considered in the settlement petition filed by the father of the appellant as such issue has not been examined. Needless to say, in the a…

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. MOHIT AGARWAL, JAIPUR

In the result, both the appeals of the Revenue mentioned (supra) are dismissed and the appeal of the assessee is partly allowed in above terms

ITA 103/JPR/2025[2014]Status: DisposedITAT Jaipur15 Sept 2025

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, C.A, Ld. ARFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 132Section 153ASection 153CSection 250Section 69Section 69A

…d in this regard the date of search is 22-10-2019. The language of section as on date of issuance of notice u/s. 153C shall apply as per ratio of Income-tax Officer v. Vikram Sujit kumar Bhatia [2023] 149 taxmann.com 123 (SC)/ [2023] 293 Taxman 4 (SC)/ [2023] 453 ITR 417 (SC) [06-04-2023]. No opinion is being expressed on the contention of the merits of the case including on the contention of the appellant regarding that all the additions made in the assessment order have been considered in the settlement petition filed by the father of the appellant as such issue has not been examined. Needless to say, in the a…

RAGHAV KUMAR DHOOT,JAIPUR vs. DCIT CENTRAL CIRCLE 1, JAIPUR

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

ITA 491/JPR/2025[2018-19]Status: DisposedITAT Jaipur06 Aug 2025AY 2018-19
For Appellant: Shri C.M. Agarwal, C.AFor Respondent: Shri Rajesh Ojha, CIT- DR
Section 143(2)Section 143(3)Section 153ASection 292BSection 68

…ame to be substituted by\nthe words \"pertains or pertain to\". In this regard the Honourable\nSupreme Court has observed and held in the case of Income-tax Officer\nv. Vikram Sujitkumar Bhatia, [2023] 149 taxmann.com 123 (SC)/[2023]\n293 Taxman 4 (SC)/[2023] 453 ITR 417 (SC) [06-04-2023] as under:-\n4.1 It is submitted by Shri Nataraj, learned ASG that the amendment in\nsection 153C was necessitated in view of the observation of the Delhi\nHigh Court in the case of Pepsico India Holdings (P.) Ltd. v. Asstt. CIT\n[2014] 50 taxmann.com 299/[2015] 228 Taxman 116 (Mag.)/2014 SCC\nOnline Del 4155 whereby the High Cou…

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