Saraya Industries Ltd. v. Union of India

306 ITR 189High Court2008#2086 most cited

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

For proceedings under section 153C to be initiated, the seized documents, books of account, or valuable articles must be of such a nature that they can persuade the Assessing Officer to reopen even closed assessments, indicating incriminating material related to undisclosed income.

55

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2015 to 2025.

Also referred to as

Saraya Industries Ltd. v. Union of India · 306 ITR 189 · section 153C · search and seizure · incriminating material · undisclosed income · reopening assessments

Sections most often in play

Section 143(3)Section 153CSection 153ASection 147Section 148Section 151Section 149Section 139
Read the full judgment

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

Alka Agarwal, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4267/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…

Alka Agarwal, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4266/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…

Alka Agarwal, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4265/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…

Alka Agarwal, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4264/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…

Sakshi Agarwal, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4223/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…

Sakshi Agarwal, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4221/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…

Sakshi Agarwal, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4220/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…

Sakshi Agarwal, New Delhi vs. DCIT, Central Circle- 28, New Delhi

ITA 4219/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…

Sakshi Agarwal, New Delhi vs. DCIT, Central Circle-28, Delhi

ITA 4218/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…

Sakshi Agarwal, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4217/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…

Sakshi Agarwal, New Delhi vs. DCIT Central Circle-28, New Delhi

ITA 4216/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 Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4215/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 Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4214/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 Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4213/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 Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4212/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 Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4211/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 Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4210/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 Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4209/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 Forex India Limited, New Delhi vs. DCIT, Central Circle-28, New Delhi

ITA 4208/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…

Chandra Vidya Investment & Finance Pvt. Ltd., New Delhi vs. Deputy Commissioner of Income Tax, Central Circle -28, Delhi, New Delhi

ITA 4023/DEL/2025[2017-18]Status: DisposedITAT Delhi20 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal, Accountnat Member

Section 153Section 153ASection 153C

…(1) that the Assessing Officer should also be satisfied that such valuable articles or books of account 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…