Tax v. Gopi Apartments

360 ITR 411Reported decision2014#847 most cited

What is Tax v. Gopi Apartments authority for?

Where the Assessing Officer (AO) seizes documents during a search under Section 132, and these documents pertain to a person other than the one searched, the AO must record a satisfaction note. This satisfaction is a prerequisite for initiating proceedings against the other person under Section 153C.

123

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2015 to 2026.

Also referred to as

CIT v. Gopi Apartments · Section 153C · Section 132 · search and seizure · satisfaction note · seized documents · person other than searched person · assessment · income tax act

Sections most often in play

Section 153CSection 153ASection 143(3)Section 147Section 148Section 151Section 149Section 132

Issues it is cited on

section 153atosection 153b(1)(a)abatement of assessmentsection 132(4a)(i)section 6(3)(ii)section 292c(1)(i)section 153c proceedingssection 113section 153b(1)section 158bdsection 292c(1)section 6(3)

Judgments citing Tax v. Gopi Apartments

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…

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

…recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched. 19. The Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: (2014) 360 ITR 411 has expressed a similar view in the following words:- "25. A bare perusal of the provision contained in Section 153C of the I.T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1) or has be…