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“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

Pramod Subbiahnapalya Venkatpathi, Bengaluru vs. DCIT, Central Circle-2(1), Bangalore

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

ITA 678/BANG/2025[2018-19]Status: DisposedITAT Bangalore10 Mar 2026AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR
Section 132Section 142(1)Section 153CSection 69

first time, the assessee had raised a legal plea that the AO had erred in making additions or disallowances when there are no incriminating documents seized at the time of search. 3. In the additional ground filed at the second time, the assessee had raised a legal plea that, whether ... recording of satisfaction u/s. 153C of the searched person has been recorded by the AO of the assessee. We have also perused the documents seized at the time of search which was mentioned as annexure – A to the above said notice. We have also perused the recording of reasons

Pramod Subbiahnapalya Venkatathi, Bangalore vs. DCIT, Central Circle -2(1), Bangalore

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

ITA 677/BANG/2025[2017-18]Status: DisposedITAT Bangalore10 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR
Section 132Section 142(1)Section 153CSection 69

first time, the assessee had raised a legal plea that the AO had erred in making additions or disallowances when there are no incriminating documents seized at the time of search. 3. In the additional ground filed at the second time, the assessee had raised a legal plea that, whether ... recording of satisfaction u/s. 153C of the searched person has been recorded by the AO of the assessee. We have also perused the documents seized at the time of search which was mentioned as annexure – A to the above said notice. We have also perused the recording of reasons

Pramod Subbiahnapalya Venkatathi, Bengaluru vs. DCIT, Central Circle-2(1), Bangalore

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

ITA 676/BANG/2025[2016-17]Status: DisposedITAT Bangalore10 Mar 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR
Section 132Section 142(1)Section 153CSection 69

first time, the assessee had raised a legal plea that the AO had erred in making additions or disallowances when there are no incriminating documents seized at the time of search. 3. In the additional ground filed at the second time, the assessee had raised a legal plea that, whether ... recording of satisfaction u/s. 153C of the searched person has been recorded by the AO of the assessee. We have also perused the documents seized at the time of search which was mentioned as annexure – A to the above said notice. We have also perused the recording of reasons

Pramod Subbiahnapalya Venkatpathi, Bengaluru vs. DCIT, Central Circle-2(1), Bangalore

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

ITA 675/BANG/2025[2015-16]Status: DisposedITAT Bangalore10 Mar 2026AY 2015-16

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR
Section 132Section 142(1)Section 153CSection 69

first time, the assessee had raised a legal plea that the AO had erred in making additions or disallowances when there are no incriminating documents seized at the time of search. 3. In the additional ground filed at the second time, the assessee had raised a legal plea that, whether ... recording of satisfaction u/s. 153C of the searched person has been recorded by the AO of the assessee. We have also perused the documents seized at the time of search which was mentioned as annexure – A to the above said notice. We have also perused the recording of reasons

Vimal Todi, Indore vs. Additional Commissioner of Income Tax, Indore

Appeal is allowed

ITA 188/IND/2024[2012-13]Status: DisposedITAT Indore06 Mar 2026AY 2012-13

Bench: Shri B.M. Biyani & Shri Paresh M Joshishri Vimal Todi, Additional Commissioner बनाम/ 501, Darshan Residency, Of Income-Tax, Vs. 104-105, Anand Bazar, Indore Indore

Section 132Section 254(2)Section 271DSection 275Section 275(1)(c)

order requires no interference.” (b) Ram Kishan Verma Vs. Addl. CIT (2023) 157 taxmann.com 7 (ITAT, Jaipur): In this case, on the basis of documents seized from possession of one Shri DP Sehgal during a search proceeding u/s 132(1) on 19.12.2014, the DDIT, Jaipur, found a contravention of section ... reference letter of the Asstt. CIT for levy of penalty as under :- XXX (not reproduced) This reference was made on the basis of the documents seized from the possession of Shri DP Sehgal during the course of search and seizure action under section

DCIT, CC-2(3), Kolkata vs. Dailmer Industries Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2922/KOL/2025[2022-23]Status: DisposedITAT Kolkata06 Mar 2026AY 2022-23

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 132(1)Section 132(4)Section 133(6)Section 133ASection 143(1)Section 148Section 250Section 68

recorded on 15.03.2022 and he conformed the loan transactions to be actual transactions. It was also noted by the ld. CIT (A) that the documents seized contained the list of loan transactions of Laser Power and Infra Pvt. Ltd and not the assessee company. Therefore, no adverse inference could

DCIT, CC-2(3), Kolkata vs. Dailmer Industries Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2921/KOL/2025[2020-21]Status: DisposedITAT Kolkata06 Mar 2026AY 2020-21

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 132(1)Section 132(4)Section 133(6)Section 133ASection 143(1)Section 148Section 250Section 68

recorded on 15.03.2022 and he conformed the loan transactions to be actual transactions. It was also noted by the ld. CIT (A) that the documents seized contained the list of loan transactions of Laser Power and Infra Pvt. Ltd and not the assessee company. Therefore, no adverse inference could

Bijay Kumar Garodia, Kolkata vs. DCIT, Central Circle 3(4), Kolkata

In the result, the appeal of the revenue is dismissed

ITA 2938/KOL/2025[2013-2014]Status: DisposedITAT Kolkata05 Mar 2026AY 2013-2014

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 132Section 132(1)Section 143(3)Section 250Section 271A

details of undisclosed income and also explained the manner in which he earned the undisclosed income. The AO also mentioned in para 3 the documents seized such as documents relating to cash found as well as jewellery and other asset found and seized which were not pertaining to the disclosure

Bileshivale Muddanna Govardhana Murthy, Bangalore vs. DCIT, Central Circle - 1(2), Bangalore

ITA 2193/BANG/2025[2014-15]Status: DisposedITAT Bangalore05 Mar 2026AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri R.E Balasubramanyam, CAFor Respondent: Shri Azhar Zain VP, CIT(DR)
Section 153ASection 250

confirming the addition on the transaction of agreement to sale of immovable property. 5. During the course of assessment proceedings, the AO examined various documents seized and furnished by the assessee. It was noticed that the assessee, along with his mother and brothers, was a joint owner of certain immovable

Bileshivale Muddanna Govardhana Murthy, Bengaluru vs. DCIT, Central Circle - 1(2), Bengaluru

ITA 2192/BANG/2025[2013-14]Status: DisposedITAT Bangalore05 Mar 2026AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri R.E Balasubramanyam, CAFor Respondent: Shri Azhar Zain VP, CIT(DR)
Section 153ASection 250

confirming the addition on the transaction of agreement to sale of immovable property. 5. During the course of assessment proceedings, the AO examined various documents seized and furnished by the assessee. It was noticed that the assessee, along with his mother and brothers, was a joint owner of certain immovable

Assistant Commissioner of Income Tax, Central Circle-2, Patna vs. Patna Iron Pvt. Ltd., Patna

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed

ITA 373/PAT/2025[2020-21]Status: DisposedITAT Patna26 Feb 2026AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

wrong, illegal and unjustified. 4. For that the learned CIT(A) failed to appreciate that the addition made on the basis of the documents seized from somebody else ought to have been added in the assessment proceedings commenced under section 153C of the Act, which is wrong, illegal and unjustified ... vide order passed by the under section 127 of the Act by the Pr CIT-1, Patna. Therefore, it is implied that the documents seized from the possession of Shri Lazman Tikhmani also came into the possession of the ld. AO after the transfer of jurisdiction

Patna Iron Pvt. Ltd., Patna vs. ACIT, Central Circle-2, Patna

In the result, the appeals of the assessee are allowed and appeal of

ITA 332/PAT/2025[2020-21]Status: DisposedITAT Patna26 Feb 2026AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

wrong, illegal and unjustified. 4. For that the learned CIT(A) failed to appreciate that the addition made on the basis of the documents seized from somebody else ought to have been added in the assessment proceedings commenced under section 153C of the Act, which is wrong, illegal and unjustified ... vide order passed by the under section 127 of the Act by the Pr CIT-1, Patna. Therefore, it is implied that the documents seized from the possession of Shri Lazman Tikhmani also came into the possession of the Id. AO after the transfer of jurisdiction

Sushil Kumar Kanodia, Patna vs. ACIT, Central Circle-2, Patna

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed

ITA 237/PAT/2025[2017-18]Status: DisposedITAT Patna26 Feb 2026AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

wrong, illegal and unjustified. 4. For that the learned CIT(A) failed to appreciate that the addition made on the basis of the documents seized from somebody else ought to have been added in the assessment proceedings commenced under section 153C of the Act, which is wrong, illegal and unjustified ... vide order passed by the under section 127 of the Act by the Pr CIT-1, Patna. Therefore, it is implied that the documents seized from the possession of Shri Lazman Tikhmani also came into the possession of the ld. AO after the transfer of jurisdiction

Deputy Commissioner of Income Tax, Cnetral Circle-4(3), Kolkata vs. Dilip Kumar Ghosh, Kolkata

In the result, the appeal of the Revenue and CO of the Assessee are

ITA 1606/KOL/2025[2018-19]Status: DisposedITAT Kolkata26 Feb 2026AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri Siddharth Jhajharia, ARFor Respondent: Shri Madhu Malti Ghosh, DR
Section 115BSection 153ASection 69A

issued statutory notices along with questionnaire which were replied by the assessee. The assessee submitted before the Id. AO that the documents seized during the course of search revealed that these documents contained entries recorded in the books of account of M/s Jagatbandhu Tea Estate Pvt. Ltd. of which assessee

Fayaz Mohammed, Hyderabad vs. DCIT, Central Circle 2(4), Hyderabad

ITA 1672/HYD/2025[2018-19]Status: DisposedITAT Hyderabad25 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.

For Appellant: Shri P Murali Mohan Rao, САFor Respondent: Smt.V Koteshwaramma, Sr.AR
Section 132Section 147Section 148Section 153ASection 153CSection 250Section 69

ITA Nos 1671 and 1672 of 2025 Fayaz Mohammed आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL

Fayaz Mohammed, Hyderabad vs. DCIT, Central Circle 2(4), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1671/HYD/2025[2017-18]Status: DisposedITAT Hyderabad25 Feb 2026AY 2017-18
Section 132Section 147Section 148Section 153ASection 153CSection 250Section 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

Satyanarayana Reddy Cheruku, Warangal vs. Income Tax Officer, Ward-1, Warangal

ITA 1358/HYD/2025[2010-11]Status: DisposedITAT Hyderabad20 Feb 2026AY 2010-11

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1358/Hyd/2025 (िनधा"रण वष"/Assessment Year:2010-11) Satyanarayana Reddy Vs. Income Tax Officer, Cheruku, Ward-1, Warangal. Warangal. Pan: Aaupc0479M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By: Ms. Aditi Goyal, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 03/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals)-12, Hyderabad, Dated 23/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) R.W.S 153C Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 11/12/2017 For The Assessment Year (Ay) 2010-11. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Ms. Aditi Goyal, Sr. AR
Section 143(3)Section 153CSection 69A

having been paid any amount over and above the prescribed fees of Rs.15 lakhs. The AO held a conviction that as the incriminating documents seized in the course of the search and seizure operations referred to the amount of Rs.15 lakhs (supra) that the assessee had admittedly paid towards

Thippareddy Govindareddy Malli Reddy, Bengaluru vs. DCIT, Central Circle 2(3), Bengaluru

In the result appeal of assessee is dismissed

ITA 685/BANG/2025[AY 2017-18]Status: DisposedITAT Bangalore20 Feb 2026

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian, Jt.CIT (DR)(ITAT), Bengaluru
Section 132Section 139(1)Section 143(2)Section 153Section 153CSection 69A

premises of the wife of the assessee. Further the documents were also found and seized from the premises of M/s. R.K. Cortina. The documents seized from the premises of the wife of assessee as well as from M/s. R.K. Cortina were stated to be having a bearing on the determination ... interest , he also mentioned reason how assessee wanted to settle the above cash loan and why the above amount was found in the documents seized. The assessee also explained that how the above amount of Rs 2 crores paid by the assessee in cash to Mr Vasudev would have been

Param Propertt Devloper, Ambernath vs. ACIT, Central Circle-2, Thane

ITA 3243/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarit(Ss)A/3241/Mum/2025 (A.Y. 2016-17) It(Ss)A/3242/Mum/2025 (A.Y. 2017-18) It(Ss)A/3243/Mum/2025 (A.Y. 2020-21) Param Property Developers V/S. Assistant Commissioner Of Plot No. 30, Jivandeep बनाम Income Tax, Central Circle Apartment, Station Road, Ambarnath(E), Thane 421501, Maharashtra 2,Thane, Ashar It Park, 6Th Floor, Wagale Industrial Estate, Thane- 400 604, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aalfp9248G Appellant/अपीलार्थी .. Respondent/प्रतिवादी Pride Infrastructure It(Ss)A/3309/Mum/2025 (A.Y. 2014-15) It(Ss)A/3310/Mum/2025 (A.Y. 2015-16) V/S. Assistant Commissioner Of Plot No. 34, Ketan Bhavan, बनाम Income Tax, Central Circle Suryoday Chs Ltd., Station Road, Ambarnath(E), Thane 421 501, Maharashtra 2,Thane, Ashar It Park, 6Th Floor, Wagale Industrial Estate, Thane- 400 604, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aamfp3255G Appellant/अपीलार्थी .. Respondent/प्रतिवादी Page | 2

Section 132Section 143(3)

IN THE INCOME-TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT

Dy.Commissioner of Income Tax Central Circle-1, Patna vs. Parth Ashram Edu Services Private Limited, Patna

In the result, the appeal filed by the Revenue is partly allowed for statistical purposes

ITA 444/PAT/2024[2019-20]Status: DisposedITAT Patna19 Feb 2026AY 2019-20

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 133ASection 143(1)Section 250Section 292C

IN THE INCOME TAX APPELLATE TRIBUNAL PATNA ‘DB’ BENCH AT KOLKATA [Virtual Court] Before SHRI SONJOY SARMA, JUDICIAL MEMBER & SHRI