← All Phrases

“documents seized”

Search & SeizureSection 132Section 1322,593 judgments

The decision most relied on for documents seized is SSP Aviation Ltd. v. Deputy Commissioner of Income Tax (346 ITR 177), cited in 308 judgments on BharatTax.

Leading authorities on documents seized

SSP Aviation Ltd. v. Deputy Commissioner of Income Tax
346 ITR 177 · 2012 · High Court
308
citing judgments

The date of initiation of search or requisition for the purpose of abatement of assessment proceedings is the date of search or requisition, or the date of receipt of seized documents by the jurisdictional Assessing Officer, whichever is later. Proceedings under section 153C can only be initiated by the Assessing Officer of the searched person after being satisfied that seized documents belong to another person.

CIT v. R. Nalini Devi ITTA 232 of 2013 (A. P)
294 ITR 49 · 2007 · Supreme Court
299
citing judgments

Additions to income cannot be made solely based on uncorroborated third-party statements, documents, or loose sheets seized during a search, and such evidence requires the assessee to be provided with an opportunity for cross-examination.

ARN Infrastructure India Ltd. v. Asstt. CIT
394 ITR 569 · 2017 · High Court
282
citing judgments

For initiating proceedings under Section 153C, seized documents must be incriminating and specifically relate to the assessment years for which assessments are reopened. A document relevant only for one year cannot be used to reopen other assessment years without being incriminating for those years.

Pepsico India Holdings (P) Ltd. v. ACIT
370 ITR 295 · 2015 · High Court
249
citing judgments

Section 153C of the Income-tax Act is invoked only when it is established that seized documents do not belong to the searched person, or if the searched person disclaims them; the satisfaction note must specifically indicate this fact.

Manish Maheshwari v. ACIT
289 ITR 341 · 2007 · Supreme Court
237
citing judgments

A block assessment proceeding under section 158BD is illegal if the procedure laid down in section 153C is not followed. The provisions of section 153C are similar to section 158BD in block assessment proceedings.

Pr. CIT v. Index Securities (P.) Ltd.
86 Taxmann.com 84 · 2017 · High Court
184
citing judgments

For a valid reassessment under Section 153C, seized documents must be incriminating and directly relevant to the assessment years being reopened. Documents that are not incriminating or do not relate to the assessment years do not satisfy the jurisdictional requirement.

CIT v. Girish Chaudhary
296 ITR 619 · 2008 · High Court
175
citing judgments

Additions to income cannot be made solely based on "dumb documents" or vague loose papers seized during a search that merely indicate rates without specific corroborative material linking them to the assessee's unaccounted transactions. The presumption under Section 292C may not apply to such documents.

CIT v. Sant Lal
118 Taxmann.com 432 · 2020 · High Court
154
citing judgments

An addition to income cannot be made solely on the basis of entries in a diary seized from a third party if the diary is not found in the assessee's premises, not in the assessee's handwriting, and the revenue fails to provide corroborative evidence linking the assessee to the diary.

Judgments citing documents seized

Shri Sanjay Haresh Mulchandani, Mumbai vs. Income Tax Officer Ward 19(3)(1), Mumbai

In the result, the assessee succeeds in the present appeal

ITA 4751/MUM/2025[2011-12]Status: DisposedITAT Mumbai30 Dec 2025AY 2011-12

Bench: Shri Narender Kumar Choudhryassessment Year: 2011-12 Shri Sanjay Haresh The Income Tax Officer, Mulchandani Ward, 19 (3) (1), 4-C Ajanta Apartments, M L Vs. Piramal Chamber, Dhanukar Marg, Peddar Road, Mumbai – 400013. Mumbai – 40026 Pan – Aadpm 3393 B (Appellant) (Respondent) Present For: Assessee By : Shri Harsh Kapadia & Nitin Khinchi, Ld. Ars Revenue By : Shri Sandeep Jumale, Ld. Sr. Dr Date Of Hearing : 20.11.2025 Date Of Pronouncement : 30.12.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 08.07.2025, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2011-12. 2. In The Instant Case, The Assessee Along With His Uncle Had Purchased A Flat In Iscon Platinum, Ahmedabad On A Consideration Of Rs. 59,30,000/- Through Cheques. Subsequently, Search Under Section 132 Of The Act Was Conducted By The Investigation Wing, In The Case Of Jp Iscon

For Appellant: Shri Harsh Kapadia & Nitin KhinchiFor Respondent: Shri Sandeep Jumale, Ld. Sr. DR
Section 132Section 143(1)Section 147Section 148Section 250

basis of which the case of the assessee was reopened, there is no handwritten note by the assessee in any of the documents seized, there is no 6 Shri Sanjay Haresh Mulchandani allotment letter in the name of the assessee to show that the assessee had advanced money for purchase

Farooqi Gulamsamdani, Hyderabad vs. DCIT., Central Circle - 1(3), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 814/HYD/2025[2019-20]Status: DisposedITAT Hyderabad24 Dec 2025AY 2019-20

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.814/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2019-20) Shri Farooqi Gulam Samdani, Dy. Commissioner Of Income Tax, Vs. Central Circle 1(3), Hyderabad. Hyderabad. Pan : Aispg5022C (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P. Murali Mohan Rao, C.A. रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr-Ar सुिवधई की तधरीख/Date Of Hearing: 11/11/2025 घोर्णध की तधरीख/Pronouncement: 24/12/2025

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Dr. Sachin Kumar, SR-AR
Section 127Section 132Section 142(1)Section 153CSection 69

where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned, belongs to a person other than a person referred to in section 153A of the Act, then the books of account or documents ... additions made by the Assessing Officer towards consideration paid in cash for purchase of property as per the agreement of sale and documents seized at the time of search and claimed that the additions made by the Assessing Officer is not made on any material found during the course

DCIT., Central Circle-1(3), Hyderabad vs. Light House Movie Makers LLP, Hyderabad

In the result, the appeal filed by the revenue is dismissed

ITA 319/HYD/2024[2020-21]Status: DisposedITAT Hyderabad24 Dec 2025AY 2020-21

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं / Ita No.297/Hyd/2024 (निर्धारण वर्ष/Assessment Year:2015-16) Vs. Dy. Commissioner Of Income Tax, Central Circle 1(3), Hyderabad. (Appellant) Shri Atchi Reddy Kovvuri, Hyderabad Pan: Adopk6018R (Respondent) आ.अपी.सं / Ita Nos.318 & 319/Hyd/2024 (निर्धारण वर्ष/Assessment Years:2019-20 & 2020-21) Vs. M/S. Light House Movie Makers Llp, Hyderabad. Dy. Commissioner Of Income Tax, Central Circle 1(3), Hyderabad. (Appellant) Pan: Aagfl8979H (Respondent) निर्धारिती द्वारा / Assessees By: राजस्व द्वारा / Revenue By: सुनवाई की तारीख /Date Of Hearing: घोषणा की तारीख / Pronouncement: Shri A. Srinivas, C.A. Smt. U Mini Chandran, Cit-Dr 18/11/2025 24/12/2025 आदेश/Order Per Manjunatha G, A.М. : These Appeals Are Filed By Revenue Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, All Dated 19.11.2024 For The

Section 132Section 139Section 142(1)Section 153C

provisions of Section 153C of the Act, the incriminating material which was seized has to pertain to the assessment year in question and the documents seized has to establish a co-relation, document wise with the AYs where the assessment was initiated by invoking section 153C. The relevant extract ... cash loans received by the assessee are evidenced by the collateral documents and acknowledged by the assessee himself which is evident from the documents seized during the course of search and therefore, the Assessing Officer made additions in the assessment towards cash loans repaid by the assessee as unexplained money

DCIT., Central Circle-1(3), Hyderabad vs. Light House Movie Makers LLP, Hyderabad

In the result, both the appeals filed by the revenue are dismissed

ITA 318/HYD/2024[2019-20]Status: DisposedITAT Hyderabad24 Dec 2025AY 2019-20

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.297/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2015-16) Dy. Commissioner Of Income Shri Atchi Reddy Kovvuri, Vs. Hyderabad Tax, Pan : Adopk6018R Central Circle 1(3), Hyderabad. (Appellant) (Respondent) आ.अपी.सं /Ita Nos.318 & 319/Hyd/2024 (निर्धारण वर्ा/Assessment Years:2019-20 & 2020-21) Dy. Commissioner Of Income M/S. Light House Movie Makers Vs. Llp, Hyderabad. Tax, Pan : Aagfl8979H Central Circle 1(3), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessees By: Shri A. Srinivas, C.A. रधजस् व द्वधरध/Revenue By: Smt. U Mini Chandran, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 18/11/2025 घोर्णध की तधरीख/Pronouncement: 24/12/2025 आदेश/Order Per Manjunatha G, A.M. : These Appeals Are Filed By Revenue Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, All Dated 19.11.2024 For The

For Respondent: Smt. U Mini Chandran, CIT-DR
Section 132Section 139Section 142(1)Section 153C

cash loans received by the assessee are evidenced by the collateral documents and acknowledged by the assessee himself which is evident from the documents seized during the course of search and therefore, the Assessing Officer made additions in the assessment towards cash loans repaid by the assessee as unexplained money