PCIT, Central-3 v. Abhisar Buildwell Pvt. Ltd.

150 Taxmann.com 257Supreme Court of India2023#2047 most cited

What is PCIT, Central-3 v. Abhisar Buildwell Pvt. Ltd. authority for?

In search assessments under Section 153A, additions to income for completed assessments are permissible only if based on incriminating material found during the search; additions relying on non-incriminating documents cannot be sustained.

56

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2023 to 2025.

Also referred to as

PCIT v. Abhisar Buildwell · 150 Taxmann.com 257 · Section 153A · Section 132 · scope of assessment · incriminating material · non-incriminating documents · search assessment · additions to income · completed assessments

Sections most often in play

Section 132Section 153ASection 147Section 148Section 1961Section 143(3)Section 69ASection 153C

Issues it is cited on

section 133a(3)(iii)substantive assessmentsection 153(1)(a)retraction of statementsurvey under section 133asection 153a proceedingssection 271aaabusiness connectionblock periodsection 65bdocuments seizedsection 65

Judgments citing PCIT, Central-3 v. Abhisar Buildwell Pvt. Ltd.

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 392/ASR/2024[2012-13]Status: DisposedITAT Amritsar30 Oct 2025AY 2012-13

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 391/ASR/2024[2011-12]Status: DisposedITAT Amritsar30 Oct 2025AY 2011-12

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 390/ASR/2024[2019-20]Status: DisposedITAT Amritsar30 Oct 2025AY 2019-20

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 389/ASR/2024[2018-19]Status: DisposedITAT Amritsar30 Oct 2025AY 2018-19

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 388/ASR/2024[2017-18]Status: DisposedITAT Amritsar30 Oct 2025AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 387/ASR/2024[2016-17]Status: DisposedITAT Amritsar30 Oct 2025AY 2016-17

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 386/ASR/2024[2015-16]Status: DisposedITAT Amritsar30 Oct 2025AY 2015-16

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 385/ASR/2024[2014-15]Status: DisposedITAT Amritsar30 Oct 2025AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAXQ, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 384/ASR/2024[2013-14]Status: DisposedITAT Amritsar30 Oct 2025AY 2013-14

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 383/ASR/2024[2018-19]Status: DisposedITAT Amritsar30 Oct 2025AY 2018-19

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 382/ASR/2024[2017-18]Status: DisposedITAT Amritsar30 Oct 2025AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 340/ASR/2024[2016-17]Status: DisposedITAT Amritsar30 Oct 2025AY 2016-17

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DCIT CENTRAL CIRCLE 1, JALANDHAR, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 339/ASR/2024[2015-16]Status: DisposedITAT Amritsar30 Oct 2025AY 2015-16

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DCIT CENTRAL CIRCLE 1 JALANDHAR, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 338/ASR/2024[2014-15]Status: DisposedITAT Amritsar30 Oct 2025AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 337/ASR/2024[2013-14]Status: DisposedITAT Amritsar30 Oct 2025AY 2013-14

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 266/ASR/2024[2012-13]Status: DisposedITAT Amritsar30 Oct 2025AY 2012-13

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 265/ASR/2024[2011-12]Status: DisposedITAT Amritsar30 Oct 2025AY 2011-12

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. RAJNI MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 251/ASR/2024[2019-20]Status: DisposedITAT Amritsar30 Oct 2025AY 2019-20

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. RAJNI MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 250/ASR/2024[2018-19]Status: DisposedITAT Amritsar30 Oct 2025AY 2018-19

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. RAJNI MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 249/ASR/2024[2017-18]Status: DisposedITAT Amritsar30 Oct 2025AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…income of the person. Therefore, any addition on the basic of these documents, which is not incriminating, cannot be sustained in view of the law laid down by the Hon'ble Supreme Court in the case of PCIT, Central-3 vs. Abhisar Buildwell Pvt. Ltd. reported at 150 Taxmann.com 257 (SC) (2023). 5.4.3 Thus, is observed that the addition has been made on the basis of estimation. The AO has mentioned that no document in support of income declared as business income has been provided by the appellant. Further, no incriminating document has been found during the search to indicate that loan taken from Wakeup Portfolio M…

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