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“search and seizure”

Search & SeizureSection 132Section 13210,164 judgments

The decision most relied on for search and seizure is CIT v. Continental Warehousing Corporation (Nhava Sheva) Ltd. (374 ITR 645), cited in 1,823 judgments on BharatTax.

Leading authorities on search and seizure

CIT v. Continental Warehousing Corporation (Nhava Sheva) Ltd.
374 ITR 645 · 2015 · High Court
1,823
citing judgments

In Section 153A proceedings, the scope of assessment extends to abated proceedings, enabling an assessee to raise fresh legal claims that could have been made in regular assessment proceedings.

CIT v. Sinhgad Technical Education Society
397 ITR 344 · 2017 · Supreme Court
1,589
citing judgments

For assessments under Section 153C, a notice is legally unsustainable if there is no incriminating material correlated to the specific assessment years for which reassessment is sought.

All Cargo Global Logistics Ltd. v. DCIT
137 ITD 287 · 2012 · ITAT
907
citing judgments

In non-abated assessments, the Assessing Officer can make additions under section 153A based on books of accounts or documents found during a search but not produced during the original assessment, provided such material is incriminating.

Commissioner of Income Tax v. Harjeev Aggarwal
290 CTR 263 · 2016 · High Court
583
citing judgments

Assessment based solely on a statement recorded under Section 132(4) of the Income Tax Act requires the statement to be relatable to incriminating material or evidence found during the search, especially when considering Section 158BB(1) which restricts computation of undisclosed income to evidence found during search.

CIT v. Anil Kumar Bhatia
352 ITR 493 · 2013 · High Court
537
citing judgments

Section 153A can be invoked to reassess income for all years under consideration prior to a search, even if returns for those years were processed under Section 143(1)(a). The Assessing Officer has the power to reassess total income in such cases without fetters.

E.N. Gopakumar v. CIT
75 Taxmann.com 215 · 2016 · High Court
428
citing judgments

In search assessments conducted under Section 153A of the Income-tax Act, additions to the assessee's income can be made even in the absence of incriminating material found during a search operation conducted under Section 132.

DCIT v. Sunil Kumar Sharma
159 Taxmann.com 179 · 2024 · High Court
269
citing judgments

Loose sheets of paper containing jottings, not shown to be part of regularly maintained books of accounts, do not constitute incriminating material for initiating assessment under section 153C. The satisfaction note required for 153C proceedings must specify the assessment year to which the alleged incriminating material belongs.

Kishore Kumar v. Deputy Commissioner of Income
52 Taxmann.com 449 · 2014 · High Court
255
citing judgments

An unretracted admission of undisclosed income made by an assessee in a sworn statement under Section 132(4) during a search and seizure operation forms a valid basis for making additions and levying tax, especially when no books of accounts are maintained.

Judgments citing search and seizure

Bharat Harishchandra Purohit, Mumbai vs. DCIT CC4(2), Mumbai

In the result, all the appeals filed by the assessee stands allowed

ITA 5831/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Shri Pawan Singh& Shri Arun Khodpia

Section 153CSection 254(1)Section 69

concerned, the same was not found from the possession of the assessee but was found as per order of assessment, during the search and seizure conducted in the case of third party therefore, in the absence of corroborative evidence to establish that the contents of pendrive are correct and authenticated ... addition made of ` 42 lakh on account of alleged payment of on–money in cash towards purchase of a flat lies in a search and seizure operation conducted in case of Hiranandani Group and related persons. Though, in the assessment order the Assessing Officer has not discussed in detail

Asha Shivdasani, Mumbai vs. CIT(A), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 2312/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarasha Ranjit Shivdasani V/S. Assistant Commissioner Of 801, Benhur Apartments, बनाम Income Tax (Appeals), Acit 32, Narayan Debholkar Central Circle – 5(3), Road, Malabar Hills, Room No. 1906, 19Th Floor, Air Mumbai – 400 006, India Building, Nariman Point, Maharashtra Mumbai – 400021, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Bhzps0010H Appellant/अपीलाथी .. Respondent/प्रतिवादी

For Appellant: Shri Shreyas Shah,ARFor Respondent: Shri Surendra Mohan, (Sr. DR)
Section 132(1)Section 132(4)Section 143(3)Section 153ASection 69A

Facts in brief are that the assessee filed her original return of income declaring total income of Rs. 43,85,500/-. Subsequently, a search and seizure operation u/s 132(1) of the Act was conducted on 30/10/2018 in the case of the assessee.Consequent to search action, the notice u/s 153A

Zento Exim Private Limited, Ram Nagar Extension vs. ACIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5131/DEL/2025[2023-24]Status: DisposedITAT Delhi19 Jan 2026AY 2023-24

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2023-24] Zento Exim Private Limited, Acit, 1/4331, T/F, Kh No.587 Ram Vikas Bhawan, Ito, Nagar Extension, Vs New Delhi-110002 New Delhi-110032 Pan-Aljpk8665M Assessee Revenue Assessee By Shri Gaurav Jain, Adv. Shri Tarun Chanana, Adv. Revenue By Ms. Amish S Gupt, Sr. Dr Date Of Hearing 19.01.2026 Date Of Pronouncement 19.01.2026

Section 132Section 132(4)Section 143(2)Section 143(3)Section 148BSection 69A

under consideration, the assessee filed his Return of Income for A.Y. 2023-24 on 28.10.2023, declaring total income of Rs.63,59,050/-. A search and seizure operation under section 132 was initiated on M/s Montage Enterprises Pvt. Ltd. (MEPL) on 21.02.2023. The premises owned by the assessee was also covered ... during the search and seizure operation. In this light, the case of the assessee was opened for assessment u/s Page 2 of 5 143(3) of the Act after issuing notice u/s 143(2) of the Act dated 18.06.2024. As per the facts recorded

Dr. Virendra Swaroop Educational Foundation, Kanpur vs. ACIT, Central Circle, Dehradun

In the result, appeal of the assessee is allowed

ITA 211/DDN/2025[2023-24]Status: DisposedITAT Dehradun16 Jan 2026AY 2023-24

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2023-24] Dr. Virendra Swaroop Vs Acit Educational Foundation Central Circle 15/96, Civil Lines, Kanpur Dehradun Uttar Pradesh-208001 Pan-Aaajd0224D Appellant Respondent Assessee By Shri Salil Kapoor, Adv. Shri Rajiv Sahni, Ca Shri Sumit Lal Chandanim, Adv. Shri Shivam Yadav, Adv. & Ms. Ananya Kapoor, Adv. Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 11.12.2025 Date Of Pronouncement 16.01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 16.09.2025 By Ld. Pr. Commissioner Of Income Tax (Central), Kanpur [“Pcit”] Passed U/S 12(Ab)(4)(Ii) Of The Income Tax Act, 1961[“The Act”] Cancelling The Registration Granted U/S 12A Of The Act From Assessment Year 2023-24 & Onwards.

Section 11Section 12Section 127Section 12ASection 12A(1)(ac)Section 132Section 143(3)

registration granted u/s 12A of the Act from Assessment Year 2023-24 and onwards. 2. Brief facts of the case are that a search and seizure action u/s 132 of the Act was conducted on 24.11.2022 in the case of Mehta Group and connected associates, Dehradun engaged in the business ... that the second proviso of section 143(3) having come into effect from 01.04.2022 is not applicable to the assessment initiated consequent to search and seizure operations u/s 132 of the Act carried out on 19.02.2020, the ld. PCIT, Gurgaon improved his case by claiming that he had exercised

Sunil Piyush Shah, Ahmedabad vs. NFAC, Delhi Present Juris. -the ITO, Ward-5(3)(2), Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 1917/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2019-20

Bench: Ms. Suchitra Kambleassessment Year 2019-20

For Appellant: Shri Sunil Piyush Shah, A.RFor Respondent: Shri Suresh Chand Meena, Sr. D.R
Section 132Section 132(4)Section 144BSection 147Section 148ASection 244ASection 250Section 270ASection 270A(9)Section 29A

80GGC/80G of the Act in the case of Manvadhikar National Party during assessment year 2019-20. A search and seizure action u/s. 132 of the Act was conducted in various cases of political parties including Manvadhikar National Party and 2 Charitable Organizations on 02-02-2021. The statement

Tushar Vipinchandra Shukla, Ahmedabad vs. The ITO, Ward-5(3)(2), Ahmedabad

In the result, the appeal of the assessee is partly allowed for statistical purpose

ITA 1654/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2019-20

Bench: Ms. Suchitra Kambleassessment Year 2019-20

For Appellant: Shri Mehul Thakkar, A.RFor Respondent: Shri Suresh Chand Meena, Sr. D.R
Section 132(4)Section 139(1)Section 147Section 148ASection 151Section 80G

issued show cause notice u/s. 148A, notice u/s. 148 was issued and served upon the assessee on 16-04-2023 in respect search and seizure action dated 07-04-2022 conducted by the Department in respect of 23 Ahmedabad based registered un-recognised political parties. It was found that ... assessee has ignored the total holistic interpretation of the proviso more specifically proviso (a) as in the present assessee’s case there was search and seizure action conducted by the revenue in respect of 23 Ahmedabad based registered un-recognized political parties (Date of search 07-0- 2022). Thus

Vikas Jain, Noida vs. ACIT, CC-7, Delhi

ITA 8436/DEL/2025[2022-23]Status: DisposedITAT Delhi16 Jan 2026AY 2022-23

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singh

Section 143(3)Section 148

First Appellate Authority. ITA nos.- 8433 to 8436/Del/2025 4. The issues involved in the appeals are common and we find that, out of search and seizure operation, the case of the assessee was selected for scrutiny assessment in terms of the Explanation 2(iv) to Section 148 of the Income

Vikas Jain, Noida vs. ACIT, CC-7, Delhi

ITA 8435/DEL/2025[2021-22]Status: DisposedITAT Delhi16 Jan 2026AY 2021-22

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singh

Section 143(3)Section 148

First Appellate Authority. ITA nos.- 8433 to 8436/Del/2025 4. The issues involved in the appeals are common and we find that, out of search and seizure operation, the case of the assessee was selected for scrutiny assessment in terms of the Explanation 2(iv) to Section 148 of the Income

Vikas Jain, Noida vs. ACIT, CC-7, Delhi

ITA 8434/DEL/2025[2020-21]Status: DisposedITAT Delhi16 Jan 2026AY 2020-21

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singh

Section 143(3)Section 148

First Appellate Authority. ITA nos.- 8433 to 8436/Del/2025 4. The issues involved in the appeals are common and we find that, out of search and seizure operation, the case of the assessee was selected for scrutiny assessment in terms of the Explanation 2(iv) to Section 148 of the Income

Vikas Jain, Noida vs. ACIT, CC-7, Delhi

ITA 8433/DEL/2025[2019-20]Status: DisposedITAT Delhi16 Jan 2026AY 2019-20

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singh

Section 143(3)Section 148

First Appellate Authority. ITA nos.- 8433 to 8436/Del/2025 4. The issues involved in the appeals are common and we find that, out of search and seizure operation, the case of the assessee was selected for scrutiny assessment in terms of the Explanation 2(iv) to Section 148 of the Income

Onus Plantations and Agro Limited, Delhi vs. DCIT, Central Circle-6, Delhi

In the result, appeal of the assessee is allowed

ITA 5004/DEL/2025[2015-16]Status: DisposedITAT Delhi16 Jan 2026AY 2015-16

Bench: Shri Raj Kumar Chauhan & Shri Manish Agarwal

Section 127(2)(a)Section 127(3)Section 132Section 132(4)Section 139Section 153CSection 153DSection 250Section 68Section 69C

judicious manner while granting approval under section 153D of the Act. The CBDT guidelines explicitly emphasize the close coordination required in search and seizure assessments. Therefore, it is reasonable to conclude that, in accordance with prevailing administrative practices and guidelines, the approving authority has a comprehensive understanding of the issues ... shared by Investigation Wing with both the assessing officer and Addl. CIT. In fact, CBDT guideline dt. 22.12.2006 on the subject of the search and Seizure Assessments clearly outlines such close coordination. Thus, as per the prevailing Practice and Guidelines, the approving authority has good idea of issues involved

Divya Panwar, Shamli vs. DCIT, Meerut

In the result, the appeal of the assessee is allowed

ITA 4287/DEL/2025[2019-2020]Status: DisposedITAT Delhi16 Jan 2026AY 2019-2020

Bench: Ld. CIT(A) who vide impugned order dated 07.05.2025, dismissed the

Section 132Section 147Section 148Section 250Section 292CSection 69B

dated 27.03.2024 passed u/s 147 of the Act pertaining to Assessment Year 2019-20. 2. Brief facts of the case are that a search and seizure action u/s 132 was carried out in the case of Omaxe Group of cases on 14.03.2022. During the course of search, digital data

Vsg PAN Industries Private Limited, Sonepat, Haryana vs. DCIT/ACIT Cen Cir-II, Noida

In the result, the appeal of the assessee is partly allowed

ITA 3985/DEL/2025[2022-23]Status: DisposedITAT Delhi16 Jan 2026AY 2022-23

Bench: Shri Mahavir Singh & Shri Manish Agarwal

Section 143(3)Section 145Section 250

Masala and filed its return of income on 04.10.2022, declaring total income of INR Page | 1 ITA No.3985/Del/2025 16,27,86,890/-. A search and seizure action was carried out on 21.02.2023 at M/s. Montage Enterprises Pvt. Ltd. (“MEPL”) wherein it was found that assessee has made certain cash purchases

DCIT, Central Circle 28, New Delhi vs. Abhi Capital Services Ltd., New Delhi

In the result, both the captioned appeals of the Revenue in ITA

ITA 2886/DEL/2025[2012-13]Status: DisposedITAT Delhi16 Jan 2026AY 2012-13

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Varun Garg, CAFor Respondent: Ms. Pooja Swaroop, CIT-DR
Section 132Section 143(1)Section 153C

A.Ys 2011-12 and 2012-13 is a time barred assessment. The ld. counsel for the assessee pointed out that in this case, search and seizure u/s 132 of the Act was undertaken on Alankit Group on 18.10.2019 wherein some documents were found pertaining to the assessee for which satisfaction

DCIT, Central Circle 28, New Delhi vs. Abhi Capital Services Limited, Delhi

In the result, both the captioned appeals of the Revenue in ITA

ITA 2885/DEL/2025[2011-12]Status: DisposedITAT Delhi16 Jan 2026AY 2011-12

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Varun Garg, CAFor Respondent: Ms. Pooja Swaroop, CIT-DR
Section 132Section 143(1)Section 153C

A.Ys 2011-12 and 2012-13 is a time barred assessment. The ld. counsel for the assessee pointed out that in this case, search and seizure u/s 132 of the Act was undertaken on Alankit Group on 18.10.2019 wherein some documents were found pertaining to the assessee for which satisfaction

Horizon Buildmart Pvt Ltd, Gurgaon vs. ACIT, Circle-2, Faridabad

In the result, the appeal of the Assessee is partly allowed

ITA 1250/DEL/2025[2011-12]Status: DisposedITAT Delhi16 Jan 2026AY 2011-12

Bench: Shri Sudhir Kumar & Shri Manish Agarwalhorizon Buildmart Pvt. Ltd., Asst. Cit, C-131, Ground Floor, Block-C, Central Circle-Ii, Sushant Shopping Arcade, Vs. Faridabad, Sushant Lok-1, Haryana-121001. Gurgaon-122002. Pan-Aacch4582P (Appellant) (Respondent) Shri S.S. Nagar, Ca Assessee By Department By Ms. Amisha S. Gupta, Cit Dr Date Of Hearing 03/11/2025 Date Of Pronouncement 16/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon (‘Ld. Cit(A)’ In Short) Dated 27.01.2025 In Appeal No.10581/Cit(A) Ggn-3/2018-19 For Assessment Year 2011-12 Arising Out Of The Order Passed U/S 147 R.W.S 144 Of The Income Tax Act, 1961 (‘The Act’ For Short) Dated 28.12.2018. 2. Brief Facts Of The Case Are That Assessee Is Private Limited Company Engaged In The Business Of Real Estate. The Assessee Filed Its Return Of Income On 30.09.2011 Declaring A Loss Of Rs.54,833/-. The Ao Had Information That Assessee Received Loan Horizon Buildmart Pvt. Ltd. Vs. Acit

Section 143(2)Section 147Section 148Section 153C

carried out any independent enquiry or verification and simply based on the letter issued by DCIT for search and seizure action was conducted on M3M India Group, concluded that the funds received by the assessee from M/s Grand Realcon Pvt. Ltd. are not genuine. The Ld. AR further submits that ... Taxmann.com 574 has held as under: Section 153C, read with sections 147 and 148, of the Income-tax Act, 1961 - Search and seizure - Assessment of any other person (Reassessment) - Assessment year 2011- 12 - A search was conducted in respect of 'J' and 'N' and a large volume of documents were

Assistant Commissioner of Income Tax, New Delhi vs. Jalco Financial Services Private Limited, New Delhi

The appeal is dismissed

ITA 4209/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Naveenc Chandraacit, Vs. Jalco Financial Services Room No. 316A, C.R. Private Limited Building, I.P. Estate, K-7B, Ground Floor, New Delhi – 110002 Kalkaji, New Delhi – 110019 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaacj2791E Appellant .. Respondent

For Appellant: Sh. MayankPatawari, AdvFor Respondent: Sh. Om Prakash, Sr. DR
Section 143(1)Section 143(3)Section 15HSection 37Section 37(1)Section 68

further referred to an information which was received from DDIT (Inv.)- Unit 4 (1), Kolkata dated 28th June 2017 informing that a search and seizure operation was carried out in the case of Shri Vikas Kumar Agarwal, who was an entry provider. It is further stated by the AO that

ACIT, Circle-10(1), New Delhi vs. Index Securities & Research Pvt Ltd, New Delhi

In the result, the appeal filed by the Department of Revenue is dismissed

ITA 2181/DEL/2022[2016-17]Status: DisposedITAT Delhi16 Jan 2026AY 2016-17

Bench: Shri S Rifaur Rahman & Shri Vimal Kumar

Section 142(1)Section 143(2)Section 250Section 68

information received from DCIT, Central Circle, through certain communications. Though, in the said communications, the concerned authority has stated that in course of search and seizure operation conducted in case of Jagat Group, certain incriminating materials were found indicating that M/s. Vidya Shankar Investments Pvt. Ltd. and M/s. Index Securities ... further relevant to observe, in case of M/s. Vidya Shankar Investments Pvt. Ltd., relying upon the information gathered in course of search and seizure operation conducted in case of Jagat Group, assessments were completed in assessment years 200708, 2008-09 an 2009-10 making huge additions towards unexplained cash credit

Sahodhar Reddy Muddasani, Hyderabad vs. DCIT, Central Circle-1(3), Hyderabad

In the result, appeal of the assessee is allowed

ITA 1619/HYD/2025[2016-17]Status: DisposedITAT Hyderabad15 Jan 2026AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1619/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Shri Sahodhar Reddy Vs. Dy.Cit Muddasani Central Circle 1(3) Hyderabad Hyderabad Pan:Aelpm9122N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Shri C Maheshwar Reddy राज" व "ारा/Revenue By: Shri Sankar Pandi P, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 06/01/2026 घोषणा की तारीख/Pronouncement: 16/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Sahodhar Reddy Muddasani (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) Dated 24.09.2025 For The A.Y. 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: CA Shri C Maheshwar ReddyFor Respondent: Shri Sankar Pandi P, Sr. DR
Section 132Section 153ASection 2(47)Section 2(47)(v)Section 45(1)Section 53A

assessee filed his return of income for the Assessment Year 2016–17 on 16.01.2018 declaring total income of Rs.5,85,350/-. A search and seizure operation under section 132 of the Income Tax Act, 1961 (“the Act”) was conducted on 09.08.2018 in the case of the assessee along with

Chandra Prakash Jain, Uttarpradesh vs. DCIT Central Circle -20, Delhi

In the result the appeal of the assessee is hereby

ITA 5296/DEL/2025[2022-23]Status: DisposedITAT Delhi15 Jan 2026AY 2022-23

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 5296/Del/2025 : Asstt. Year : 2022-23 Sh. Chandra Prakash Jain, Vs Dcit, 308, Augusta Town Homes, Sector- Central Circle-20, 128, Jp Wishtown Noida, Maharishi New Delhi Nagar, Sultanpur, Gautam Buddha Nagar, Uttar Pradesh-201304 (Appellant) (Respondent) Pan No. Aakpj0890M Assessee By : Sh. Ved Jain, Adv., Sh. Pawan Garg, Ca & Ms. Ishika Dua, Ca Revenue By : Ms. Amish S. Gupt, Cit-Dr Date Of Hearing: 15.01.2026 Date Of Pronouncement: 15.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2022-23, Arises Against The Cit(A)-27, New Delhi’S Din & Order No. Itba/Apl/M/250/2024–25/1075064329(1) Dated 26.03.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Ved Jain, AdvFor Respondent: Ms. Amish S. Gupt, CIT-DR
Section 132Section 143(3)Section 69A

individual person, he filed his return of income for A.Y. 2022- 23 on 30.07.2022 declaring income of Rs. 43,37,120/-. 4.2 A search and seizure operation u/s 132/133A of the IT Act, 1961 was conducted on the assessee's premises on 30.09.2021. During the search operation at residence premise