Saraya Industries Ltd. v. Union of India

306 ITR 189High Court2008#2106 most cited

What is Saraya Industries Ltd. v. Union of India authority for?

The provisions of Section 153C enable revenue authorities to initiate proceedings and investigate the contents of seized documents belonging to an 'other person', without requiring a conclusive finding that such documents definitively represent undisclosed income at the outset.

55

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2025.

Also referred to as

Saraya Industries Ltd. · Section 153C · initiation of proceedings · 'other person' assessment · seized documents · undisclosed income · requirement for conclusive finding · investigative power · Section 153A · search and seizure assessment

Sections most often in play

Section 143(3)Section 153CSection 153ASection 147Section 148Section 151Section 149Section 139

Issues it is cited on

section 153atosection 153b(1)(a)abatement of assessmentsection 153c proceedingssection 113section 153b(1)section 158bdsection 153c(1)panchnamablock periodbest judgment assessmentsection 153b

Judgments citing Saraya Industries Ltd. v. Union of India

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4304/DEL/2025[2020-21]Status: DisposedITAT Delhi28 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4303/DEL/2025[2019-20]Status: DisposedITAT Delhi28 Nov 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4302/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Nov 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4301/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4300/DEL/2025[2016-17]Status: DisposedITAT Delhi28 Nov 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4299/DEL/2025[2015-16]Status: DisposedITAT Delhi28 Nov 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4298/DEL/2025[2014-15]Status: DisposedITAT Delhi28 Nov 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

PRATISHTHA IMAGES PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4297/DEL/2025[2013-14]Status: DisposedITAT Delhi28 Nov 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4280/DEL/2025[2020-21]Status: DisposedITAT Delhi28 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4279/DEL/2025[2019-20]Status: DisposedITAT Delhi28 Nov 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4278/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Nov 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4277/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4276/DEL/2025[2016-17]Status: DisposedITAT Delhi28 Nov 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4275/DEL/2025[2015-16]Status: DisposedITAT Delhi28 Nov 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4274/DEL/2025[2014-15]Status: DisposedITAT Delhi28 Nov 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

ALANKIT FINSEC LTD,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 4273/DEL/2025[2013-14]Status: DisposedITAT Delhi28 Nov 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

ALKA AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

ITA 4272/DEL/2025[2020-21]Status: DisposedITAT Delhi28 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

ALKA AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

ITA 4271/DEL/2025[2019-20]Status: DisposedITAT Delhi28 Nov 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

ALKA AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

ITA 4269/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Nov 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

ALKA AGARWAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-28, NEW DELHI

ITA 4268/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahman, Accountnat Member

…such valuable articles or books of account or documents belonging to the other person must be shown to show to conclusively reflect or disclose any undisclosed income. xxxx xxxx xxxx 17. The judgment of this court in Saraya Industries Ltd. [2008] 216 CTR 257/306 ITR 189/171 Taxman 194 (Delhi) was relied upon by Mr. Bajpai, in support of his contention that the seizure of the document must be of such nature that even closed assessments for six years could be reopened and this requirement postulates that the provisions of section 153C can be set in motion only if there is a finding that the seized document or book…

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