Saksham Commodities Ltd. v. Income Tax Officer

161 Taxmann.com 485High Court2024#479 most cited

What is Saksham Commodities Ltd. v. Income Tax Officer authority for?

Recording satisfaction under Section 153C for initiating proceedings against a third person is not a mechanical exercise; it requires a finding that seized material has a direct bearing on the third person's income, and improper satisfaction vitiates the assessment. Abatement under the second proviso to Section 153A is an inevitable consequence of a search, irrespective of the Assessing Officer's opinion on the material's impact.

196

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2024 to 2026.

Also referred to as

Saksham Commodities Ltd. · Section 153C satisfaction · Section 153A abatement · bearing on income · third party assessment · search assessment · vitiated assessment · mechanical exercise · Section 132

Also reported as

464 ITR 12024 SCC OnLine DEL 3851

Issues it is cited on

Judgments citing Saksham Commodities Ltd. v. Income Tax Officer