Pr. CIT v. Abhisar Buildwell (P.) Ltd.

2 SCC 433Reported decision2024#1298 most cited

What is Pr. CIT v. Abhisar Buildwell (P.) Ltd. authority for?

The jurisdiction of the Assessing Officer under Sections 153A and 153C, in respect of completed or unabated assessments following a search or requisition, is confined to making additions only on the basis of incriminating material found during the search that correlates to the relevant assessment years.

87

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2013 to 2026.

Also referred to as

Pr. CIT v. Abhisar Buildwell · Section 153A · Section 153C · search assessment · completed assessments · unabated assessments · incriminating material · correlation of material · AO jurisdiction · Section 132 · reassessment

Issues it is cited on

Judgments citing Pr. CIT v. Abhisar Buildwell (P.) Ltd.

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

ITA 2570/CHNY/2025[2011-12]Status: DisposedITAT Chennai09 Mar 2026AY 2011-12

Bench: This Tribunal. 2. Since, The Facts Are The Identical Across All The Appeals / For All The Assessment Years, Except For The Nature Of The Additions / Disallowances Varying In Few Of The Assessment Year(S) Before This Tribunal In The Present Batch Of 6 Appeals, The Appeal Arising From The A.Y. 2012-13 Is Being Taken Up As The Lead Case With The Consent Of The Both The Ld. Ar As Well As The Departmental Representatives. 3. The Brief Fact Of The Present Case Is That The Assessee, Shri Thanushkodi Narayanan, Is The Managing Director Of M/S.Annai Builders Real Estates Pvt Ltd. The Assessee Filed His Original Return Of Income For The A.Y. 2012-13 On 27.09.2012 In Declaring A Total Income Of Rs.24,87,430/-. 4. A Search & Seizure Operation Was Carried Out In Terms Of Section 132 Of The Act On 04.10.2017 In The Residential Premises Of The Assessee & Also In The Premises Of M/S.Annai Builders Real Estates Pvt. Ltd. In Which The Assessee Is The Managing Director. 5. Thereafter, A Notice U/S.153A Of The Act For The A.Y.2012-13 Was Issued On 25.09.2018 To The Assessee By The Assessing Officer (In Short “Ao”) & In Response To The Same, The Assessee Had Filed E-Return Of Income For The A.Y. 2012-13 On 17.08.2019 In Declaring Total Income Of Rs.14,53,440/-. :-3-:

Section 132Section 142Section 142(1)Section 143(2)Section 153A

…s of this Court relied upon by the Appellate Tribunal in the orders impugned before us, we have been referred to a judgment of the Supreme Court in Pr. CIT, Central-3 v. Abhisar Buildwell Pvt. Ltd. [2023] 149 taxmann.com 399/293 Taxman 141/ 454 ITR 212/(2024) 2 SCC 433], which deals with the manner in which an assessment under Section 153A for a block period must be made pursuant to a search under Section 132 of the I.T. Act or a requisition under Section 132A of the I.T. Act. In particular, the said decision :-21-: ITA Nos: 2569, 2570, 2571, 2573 to 2577/Chny/2025 notices the amendments that were brought into th…

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Pr. CIT v. Abhisar Buildwell (P.) Ltd. (2 SCC 433) — Cited in 87 Judgments | BharatTax