Pepsi Foods Pvt. Ltd. v. ACIT

362 ITR 373Supreme Court of India2014#11575 most cited
9

judgments rely on this decision, according to BharatTax’s citation analysis of 348,607 Indian tax judgments — from 2025 to 2025.

Sections most often in play

Section 132Section 153CSection 69ASection 69Section 131Section 142(1)Section 292CSection 68

Issues it is cited on

record datesection 158bdsection 153c(1)jdapanchnamadumb documentssection 158bcsection 292cloose paperssatisfaction notesection 292on-money

Judgments citing Pepsi Foods Pvt. Ltd. v. ACIT

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Ramasamy Rajasehar, Perambalur

In the result, appeal filed by the Revenue is dismissed and the Cross-Objection filed by the assessee is partly allowed

ITA 3336/CHNY/2024[2014-15]Status: DisposedITAT Chennai20 Nov 2025AY 2014-15

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Mr. Shiva Srinivas, C.I.T
Section 143(3)Section 69

…t be recorded distinctly for each year. A failure to do so, strikes at the root of the assessment. Moreover, the Hon’ble Delhi High Court in Pepsi Foods Pvt. Ltd. v. ACIT [(2014) 367 ITR 112 (Del)] and the Hon’ble Supreme Court in Calcutta Knitwears [(2014) 362 ITR 373 (SC)] have emphasized that the AO must demonstrate a live and direct nexus between the seized material and the relevant assessment year in respect :-16-: I.T.A. No.:3336 /Chny/2024 & C.O.No.29/Chny/2025 of the “other person,” which cannot be presumed in the absence of year-specific satisfaction. 30. In the present factual matrix, upon a caref…

M/S Good Living Shelters Pvt Ltd, Mumbai vs. Assistant Commissioner of Income Tax-12(2)(2), Mumbai

In the result all three appeals filed by the assessee are allowed

ITA 1611/MUM/2024[2009-10]Status: DisposedITAT Mumbai28 Oct 2025AY 2009-10

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Ms. Padmavathy S, Hon’Ble

For Appellant: S/Shri Subhash Chhajed & Sunil WakawalaFor Respondent: Shri Arun Kanti Datta -CIT DR
Section 132Section 143(1)Section 143(3)Section 153CSection 69A

…d that recording of such satisfaction note is sine qua non for the subsequent issuance of notices and the consequent assessment. 17. We further notice that the CBDT in Circular No. 24/2015 took note of the decision of the Supreme Court M/s Calcutta Knitwear [362 ITR 373] and has issued a circular which reads as under:- "Taking note of the above, on 31.12.2015, a Circular No. 24 of 2015 was issued by the Central Board of Direct Taxes (CBDT) which reads as under: "1. The issue of recording of satisfaction for the purposes of section 158BD/153C has been subject matter of litigation. 2. The Hon'ble Supreme Court i…

M/S Good Living Shelters Pvt Ltd, Mumbai vs. Assistant Commissioner of Income Tax-12(2)(2), Mumbai

In the result all three appeals filed by the assessee are allowed

ITA 1610/MUM/2024[2010-11]Status: DisposedITAT Mumbai28 Oct 2025AY 2010-11

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Ms. Padmavathy S, Hon’Ble

For Appellant: S/Shri Subhash Chhajed & Sunil WakawalaFor Respondent: Shri Arun Kanti Datta -CIT DR
Section 132Section 143(1)Section 143(3)Section 153CSection 69A

…d that recording of such satisfaction note is sine qua non for the subsequent issuance of notices and the consequent assessment. 17. We further notice that the CBDT in Circular No. 24/2015 took note of the decision of the Supreme Court M/s Calcutta Knitwear [362 ITR 373] and has issued a circular which reads as under:- "Taking note of the above, on 31.12.2015, a Circular No. 24 of 2015 was issued by the Central Board of Direct Taxes (CBDT) which reads as under: "1. The issue of recording of satisfaction for the purposes of section 158BD/153C has been subject matter of litigation. 2. The Hon'ble Supreme Court i…

M/S Good Livilng Shelters Pvt Ltd, Mumbai vs. Assistant Commissioner of Income Tax 12(2)(2), Mumbai

In the result all three appeals filed by the assessee are allowed

ITA 1609/MUM/2024[2008-09]Status: DisposedITAT Mumbai28 Oct 2025AY 2008-09

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Ms. Padmavathy S, Hon’Ble

For Appellant: S/Shri Subhash Chhajed & Sunil WakawalaFor Respondent: Shri Arun Kanti Datta -CIT DR
Section 132Section 143(1)Section 143(3)Section 153CSection 69A

…d that recording of such satisfaction note is sine qua non for the subsequent issuance of notices and the consequent assessment. 17. We further notice that the CBDT in Circular No. 24/2015 took note of the decision of the Supreme Court M/s Calcutta Knitwear [362 ITR 373] and has issued a circular which reads as under:- "Taking note of the above, on 31.12.2015, a Circular No. 24 of 2015 was issued by the Central Board of Direct Taxes (CBDT) which reads as under: "1. The issue of recording of satisfaction for the purposes of section 158BD/153C has been subject matter of litigation. 2. The Hon'ble Supreme Court i…

Rangamani Krishnan, Chennai vs. ACIT, Central Circle-1(2), Chennai

In the result all the five appeals filed by the assessee for the A

ITA 457/CHNY/2025[2019-20]Status: DisposedITAT Chennai17 Jul 2025AY 2019-20

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

For Appellant: Shri D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 131Section 142Section 142(1)Section 250Section 69

…must be recorded distinctly for each year. A failure to do so strikes at the root of the assessment. Moreover, the Hon’ble Delhi High Court in Pepsi Foods Pvt. Ltd. v. ACIT [(2014) 367 ITR 112 (Del)] and the Hon’ble Supreme Court in Calcutta Knitwears [(2014) 362 ITR 373 (SC)] have emphasized that the AO must demonstrate a live and direct nexus between the seized material and the relevant assessment year in respect of the “other person,” which cannot be presumed in the absence of year-specific satisfaction. 16. In the present case, the ld.AR stated that the satisfaction note relied upon by the Revenue is common…

Rangamani Krishnan, Chennai vs. ACIT, Central Circle-1(2), Chennai

In the result all the five appeals filed by the assessee for the A

ITA 456/CHNY/2025[2018-19]Status: DisposedITAT Chennai17 Jul 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

For Appellant: Shri D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 131Section 142Section 142(1)Section 250Section 69

…must be recorded distinctly for each year. A failure to do so strikes at the root of the assessment. Moreover, the Hon’ble Delhi High Court in Pepsi Foods Pvt. Ltd. v. ACIT [(2014) 367 ITR 112 (Del)] and the Hon’ble Supreme Court in Calcutta Knitwears [(2014) 362 ITR 373 (SC)] have emphasized that the AO must demonstrate a live and direct nexus between the seized material and the relevant assessment year in respect of the “other person,” which cannot be presumed in the absence of year-specific satisfaction. 16. In the present case, the ld.AR stated that the satisfaction note relied upon by the Revenue is common…

Rangamani Krishnan, Chennai vs. ACIT, Central Circle-1(2), Chennai

In the result all the five appeals filed by the assessee for the A

ITA 455/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Jul 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

For Appellant: Shri D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 131Section 142Section 142(1)Section 250Section 69

…must be recorded distinctly for each year. A failure to do so strikes at the root of the assessment. Moreover, the Hon’ble Delhi High Court in Pepsi Foods Pvt. Ltd. v. ACIT [(2014) 367 ITR 112 (Del)] and the Hon’ble Supreme Court in Calcutta Knitwears [(2014) 362 ITR 373 (SC)] have emphasized that the AO must demonstrate a live and direct nexus between the seized material and the relevant assessment year in respect of the “other person,” which cannot be presumed in the absence of year-specific satisfaction. 16. In the present case, the ld.AR stated that the satisfaction note relied upon by the Revenue is common…

Rangamani Krishnan, Chennai vs. ACIT, Central Circle-1(2), Chennai

In the result all the five appeals filed by the assessee for the A

ITA 454/CHNY/2025[2016-17]Status: DisposedITAT Chennai17 Jul 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

For Appellant: Shri D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 131Section 142Section 142(1)Section 250Section 69

…must be recorded distinctly for each year. A failure to do so strikes at the root of the assessment. Moreover, the Hon’ble Delhi High Court in Pepsi Foods Pvt. Ltd. v. ACIT [(2014) 367 ITR 112 (Del)] and the Hon’ble Supreme Court in Calcutta Knitwears [(2014) 362 ITR 373 (SC)] have emphasized that the AO must demonstrate a live and direct nexus between the seized material and the relevant assessment year in respect of the “other person,” which cannot be presumed in the absence of year-specific satisfaction. 16. In the present case, the ld.AR stated that the satisfaction note relied upon by the Revenue is common…

Rangamani Krishnan, Chennai vs. ACIT, Central Circle-1(3), Chennai

In the result all the five appeals filed by the assessee for the A

ITA 453/CHNY/2025[2015-16]Status: DisposedITAT Chennai17 Jul 2025AY 2015-16

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

For Appellant: Shri D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 131Section 142Section 142(1)Section 250Section 69

…must be recorded distinctly for each year. A failure to do so strikes at the root of the assessment. Moreover, the Hon’ble Delhi High Court in Pepsi Foods Pvt. Ltd. v. ACIT [(2014) 367 ITR 112 (Del)] and the Hon’ble Supreme Court in Calcutta Knitwears [(2014) 362 ITR 373 (SC)] have emphasized that the AO must demonstrate a live and direct nexus between the seized material and the relevant assessment year in respect of the “other person,” which cannot be presumed in the absence of year-specific satisfaction. 16. In the present case, the ld.AR stated that the satisfaction note relied upon by the Revenue is common…