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“incriminating material”

Search & SeizureSection 153ASection 153A8,981 judgments

The decision most relied on for incriminating material is CIT v. Kabul Chawla (380 ITR 573), cited in 3,235 judgments on BharatTax.

Leading authorities on incriminating material

CIT v. Kabul Chawla
380 ITR 573 · 2016 · High Court
3,235
citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

Pr. CIT v. Abhisar Buildwell (P.) Ltd.
149 Taxmann.com 399 · 2023 · Supreme Court
2,379
citing judgments

An assessment under section 153A is without jurisdiction if there is an absence of incriminating material for an unabated assessment year.

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.

Pr. CIT v. Meeta Gutgutia
395 ITR 526 · 2017 · High Court
1,226
citing judgments

In search assessments under Section 153A, additions to income are permissible only if incriminating material is found during the search; in the absence of such material, completed assessments cannot be disturbed. A statement recorded under Section 132(4) and later retracted may not, on its own, constitute sufficient incriminating evidence for making additions.

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.

PCIT v. Best Infrastructure (India) (P.) Ltd.
397 ITR 82 · 2017 · High Court
786
citing judgments

A statement recorded under Section 132(4) of the Income Tax Act, 1961, does not by itself constitute incriminating material for making additions to income.

CIT v. RRJ Securities Ltd.
380 ITR 612 · 2016 · High Court
689
citing judgments

Completed assessments can be interfered with under Section 153A or 153C only on the basis of incriminating material unearthed during the search, necessitating a direct correlation between the discovered material and the power to assess or reopen concluded assessments.

Pr. CIT v. Saumya Constructions (P.)Ltd.
387 ITR 529 · 2016 · High Court
670
citing judgments

Assessments under Section 153A cannot be sustained without any incriminating material found during the search that substantiates the additions. This principle applies even to completed assessments where no additional income is disclosed.

Judgments citing incriminating material

Bhagwanti Lalitkumar Jain, Mumbai vs. ACIT, Central Circle 4(2), Mumbai

In the result, the appeal filed by the assessee is hereby allowed

ITA 8655/MUM/2025[2019-20]Status: DisposedITAT Mumbai25 Feb 2026AY 2019-20

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Arun Kanti Datta, CIT-DR
Section 115BSection 132Section 143(2)Section 147Section 153CSection 250Section 69

facts and circumstances of the case and in law, the Ld. CIT(A) failed to appreciate that the AO has not referred to any incriminating material in the satisfaction note issued to the Appellant; 4. The Ld. CIT(A) erred in confirming the assessment order by not appreciating that ... failed to appreciate that the addition is based solely on the uncorroborated statement of third party/parties and there is no tangible and incriminating material on record. The addition confirmed is bad-in-law and based on surmises, conjectures and unreliable evidences and liable to be deleted

Rajesh Sarda, Nagpur vs. Assistant Commissioner of Income Tax, Central Circle-2(2), Nagpur

In the result, the addition of undisclosed income under section 68 is deleted

ITA 44/NAG/2022[2015-16]Status: DisposedITAT Nagpur24 Feb 2026AY 2015-16

Bench: Shri Pawan Singh & Shri Khettra Mohan Roy(Physical Hearing) Rajesh Sarda, Acit, Central Circle – 2(2), Nagpur 14, Daga Lay–Out, Ambazari Road, Vs Aayakar Bhawan, Civil Lines, Nagpur – 440033. Maharashtra – 440001. [Pan: Ahaps4925M] Appellant / Assessee Respondent / Revenue Assessee By Shri K.P. Dewani, Advocate Revenue By Shri Pankaj Kumar, Cit–Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 24.02.2026 Order Under Section 254(1) Of Income Tax Act

Section 10(38)Section 132Section 153ASection 234ASection 254(1)Section 68Section 69C

part of total investment held by assessee, with other different shares. The allotment of shares from various companies are accepted. Nothing incriminating material was found during the search nor any adverse evidence was Rajesh Sarda (AY2015-16) ITA 44/Nag/2022 brought in the assessment proceeding. The merger of Kailash Auto Finance

Ammati Venkatachalapathisetty Satish Kumar, Chintamani vs. Income Tax Officer, Ward-1, Chikkaballapur

ITA 2041/BANG/2025[2018-19]Status: DisposedITAT Bangalore24 Feb 2026AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 133(6)Section 133ASection 147Section 250Section 44A

learned AR, this entire exercise was based only on estimation and presumption without any supporting evidence. 33.1 It was further contended that no incriminating material was found during the survey to show unaccounted sales or purchases. The addition was made merely relying on the statement recorded, without any corroborative evidence

Ammati Venkatachalapathisetty Satish Kumar, Chintamani vs. Income Tax Officer, Ward-1, Chikkaballapur

ITA 2040/BANG/2025[2017-18]Status: DisposedITAT Bangalore24 Feb 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Sheettal, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 133(6)Section 133ASection 147Section 250Section 44A

learned AR, this entire exercise was based only on estimation and presumption without any supporting evidence. 33.1 It was further contended that no incriminating material was found during the survey to show unaccounted sales or purchases. The addition was made merely relying on the statement recorded, without any corroborative evidence

Ammati Venkatachalapathisetty Satish Kumar, Chintamani vs. Income Tax Officer, Ward-1, Chikkaballapur

ITA 2039/BANG/2025[2015-16]Status: DisposedITAT Bangalore24 Feb 2026AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Respondent: 03.02.2026
Section 133(6)Section 133ASection 147Section 250Section 44A

learned AR, this entire exercise was based only on estimation and presumption without any supporting evidence. 33.1 It was further contended that no incriminating material was found during the survey to show unaccounted sales or purchases. The addition was made merely relying on the statement recorded, without any corroborative evidence

Dinesh Jawaraji Parihar, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 4(2), Mumbai

In the result, the appeal filed by the assessee is hereby allowed

ITA 5634/MUM/2025[2019-20]Status: DisposedITAT Mumbai24 Feb 2026AY 2019-20

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Umashankar Prasad, CIT-DR
Section 132Section 143(2)Section 153CSection 250Section 69

case of the appellant and in law Ld. CIT(A) -52, Mumbai has erred in ignoring that fact that there is no incriminating material unearthed by Assessing Officer in case of the appellant u/s. 153C of the Act. 3) That on the facts and in the circumstances of the case ... builder/promoter. The Ld. AR challenged the Ld. AO’s jurisdiction for invoking section 153C of the Act in the absence of any incriminating material pertaining to the assessee. The Ld. AR also argued on the other grounds such as opportunity of cross examination was not given to the assessee

Dinesh Jawaraji Parihar, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 4(2), Mumbai

In the result, the appeal filed by the assessee is hereby allowed

ITA 5633/MUM/2025[2018-19]Status: DisposedITAT Mumbai24 Feb 2026AY 2018-19

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Umashankar Prasad, CIT-DR
Section 132Section 143(2)Section 153CSection 250Section 69

case of the appellant and in law Ld. CIT(A) -52, Mumbai has erred in ignoring that fact that there is no incriminating material unearthed by Assessing Officer in case of the appellant u/s. 153C of the Act. 3) That on the facts and in the circumstances of the case ... builder/promoter. The Ld. AR challenged the Ld. AO’s jurisdiction for invoking section 153C of the Act in the absence of any incriminating material pertaining to the assessee. The Ld. AR also argued on the other grounds such as opportunity of cross examination was not given to the assessee

Dinesh Jawaraji Parihar, Mumbai vs. Assistant Commissioner of Income Tax Central Circle -4(2), Mumbai

ITA 5629/MUM/2025[2017-18]Status: DisposedITAT Mumbai24 Feb 2026AY 2017-18

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Ms. Rutuja Pawar, ARFor Respondent: Shri Umashankar Prasad, CIT-DR
Section 132Section 143(2)Section 153CSection 250Section 69

case of the appellant and in law Ld. CIT(A) -52, Mumbai has erred in ignoring that fact that there is no incriminating material unearthed by Assessing Officer in case of the appellant u/s. 153C of the Act. 3) That on the facts and in the circumstances of the case ... builder/promoter. The Ld. AR challenged the Ld. AO's jurisdiction for invoking section 153C of the Act in the absence of any incriminating material pertaining to the assessee. The Ld. AR also argued on the other grounds such as opportunity of cross examination was not given to the assessee

Kamalkumar Ramkumar Agrawal, Ahmedabad vs. The Dy.CIT, Circle-2(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1975/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad23 Feb 2026AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shah, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 132Section 147Section 148Section 153CSection 69

same search action in the Navratna Group and based on similar Excel-sheet data, the Tribunal held that in the absence of any specific incriminating material directly evidencing payment of on-money by the assessee, no adverse inference could be drawn. The Tribunal, after detailed examination, allowed the appeal ... period under consideration. Therefore, in view of the present facts, placed before us, we are of the considered view that there is no adverse incriminating material in possession of the Department specifically mentioning payment of Rs. 55,00,000/- as cash on-money payment towards purchase of immovable property. Accordingly

Sejal Paresh Chopra, Mumbai Maharahstra vs. Central Circle 4(2) ACIT Assistant Commissioner of Income Tax, Mumbai Maharashtra

In the result, the appeal filed by the assessee is hereby allowed

ITA 7062/MUM/2025[2020-21]Status: DisposedITAT Mumbai23 Feb 2026AY 2020-21

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Vimal Punmiya, ARFor Respondent: Shri Vivek Perampurna, CIT-DR
Section 132Section 142(1)Section 250Section 69

Appellate Tribunal. 2. That the AO and CIT(A) grossly erred in holding that the pen drive data seized from the third party constitutes incriminating material against the appellant without bringing any corroborative evidence or establishing any direct nexus between the appellant and such data. Addition u/s 69 cannot ... builder/promoter. The Ld. AR challenged the Ld. AO’s jurisdiction for invoking section 153C of the Act in the absence of any incriminating material pertaining to the assessee. The Ld. AR also argued on the other grounds such as opportunity of cross examination was not given to the assessee

Sejal Paresh Chopra, Mumbai Maharashtra vs. Central Circle 4(2) ACIT Assistant Commissioner of Income Tax, Mumbai Maharashtra

In the result, the appeal filed by the assessee is hereby allowed

ITA 7061/MUM/2025[2019-20]Status: DisposedITAT Mumbai23 Feb 2026AY 2019-20

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Vimal Punmiya, ARFor Respondent: Shri Vivek Perampurna, CIT-DR
Section 132Section 142(1)Section 250Section 69

Appellate Tribunal. 2. That the AO and CIT(A) grossly erred in holding that the pen drive data seized from the third party constitutes incriminating material against the appellant without bringing any corroborative evidence or establishing any direct nexus between the appellant and such data. Addition u/s 69 cannot ... builder/promoter. The Ld. AR challenged the Ld. AO’s jurisdiction for invoking section 153C of the Act in the absence of any incriminating material pertaining to the assessee. The Ld. AR also argued on the other grounds such as opportunity of cross examination was not given to the assessee

Chenaram Habtaji Parihar, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 4(2), Mumbai

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

ITA 5632/MUM/2025[2019-20]Status: DisposedITAT Mumbai23 Feb 2026AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2017-18 & Assessment Year: 2018-19 & Assessment Year: 2019-20 Chenaramhabtaji Parihar Vs. Assistant Commissioner Of Income Tax Circle-4(2) Room No.1918, 19Th Floor, Air 203, 2Nd Floor, Tirangabldg, B Wing, Kamathipura, 2Nd Lane, India Building, Nariman Point, Mumbai-400021 Mumbai-400008

Section 132Section 153CSection 69

case of the appellant and in law Ld. CIT(A) -52, Mumbai has erred in ignoring that fact that there is no incriminating material unearthed by Assessing Officer in case of the appellant u/s. 153C of the Act. 3) That on the facts and in the circumstances of the case ... necessary.” 3. The Ld. Authorised Representative submitted that, the impugned additions are wholly unsustainable in law and on facts. It was contended that no incriminating material belonging to the assessee was found during the course of search and the entire addition rests merely on the statement of Shri Imran Ansari

Chenaram Habtaji Parihar, Mumbai vs. Assistant Commissioner of Income Tax Central Circle -4(2), Mumbai

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

ITA 5631/MUM/2025[2018-19]Status: DisposedITAT Mumbai23 Feb 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2017-18 & Assessment Year: 2018-19 & Assessment Year: 2019-20 Chenaramhabtaji Parihar Vs. Assistant Commissioner Of Income Tax Circle-4(2) Room No.1918, 19Th Floor, Air 203, 2Nd Floor, Tirangabldg, B Wing, Kamathipura, 2Nd Lane, India Building, Nariman Point, Mumbai-400021 Mumbai-400008

Section 132Section 153CSection 69

case of the appellant and in law Ld. CIT(A) -52, Mumbai has erred in ignoring that fact that there is no incriminating material unearthed by Assessing Officer in case of the appellant u/s. 153C of the Act. 3) That on the facts and in the circumstances of the case ... necessary.” 3. The Ld. Authorised Representative submitted that, the impugned additions are wholly unsustainable in law and on facts. It was contended that no incriminating material belonging to the assessee was found during the course of search and the entire addition rests merely on the statement of Shri Imran Ansari

Chenaram Habtaji Parihar, Mumbai vs. Assistant Commissioner of Income Tax Central Circle -4(2), Mumbai

ITA 5630/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Feb 2026AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

Section 132Section 153CSection 69

case of the appellant and in law Ld. CIT(A) -52, Mumbai has erred in ignoring that fact that there is no incriminating material unearthed by Assessing Officer in case of the appellant u/s. 153C of the Act. 3) That on the facts and in the circumstances of the case ... necessary.” 3. The Ld. Authorised Representative submitted that, the impugned additions are wholly unsustainable in law and on facts. It was contended that no incriminating material belonging to the assessee was found during the course of search and the entire addition rests merely on the statement of Shri Imran Ansari

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

produce any material which would irrefutably evidence that the assessee had made the aforementioned payment, but had also neither confronted the so called incriminating material nor afforded the assessee an opportunity to cross examine the person based on whose statement adverse inferences were being sought to be drawn ... case. The Ld. AR submitted that as the AO had failed to produce any incriminating material which would irrefutably relate the assessee to the incriminating material/document found in the course of the search conducted on the aforementioned party, therefore, 6 Satyanarayana Reddy Cheruku there is no basis for making

Sama Narasimha Reddy and Sama Saraswathi Reddy Gardens, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1335/HYD/2025[2014-15]Status: DisposedITAT Hyderabad20 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

provisions of section 148(2) of the Act. 5. The Learned CIT(A) ought to have considered that the AO, without having any incriminating material to suggest that income has escaped assessment was found during the course of survey, has issued notice u/s 148 and that to without recording reasons

Sama Narasimha Reddy and Sama Saraswathi Reddy Gardens, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1334/HYD/2025[2013-14]Status: DisposedITAT Hyderabad20 Feb 2026AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

provisions of section 148(2) of the Act. 5. The Learned CIT(A) ought to have considered that the AO, without having any incriminating material to suggest that income has escaped assessment was found during the course of survey, has issued notice u/s 148 and that to without recording reasons

Sama Narasimha Reddy and Sama Saraswathi Reddy Gardens, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1333/HYD/2025[2012-13]Status: DisposedITAT Hyderabad20 Feb 2026AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

provisions of section 148(2) of the Act. 5. The Learned CIT(A) ought to have considered that the AO, without having any incriminating material to suggest that income has escaped assessment was found during the course of survey, has issued notice u/s 148 and that to without recording reasons

Sama Narasimha Reddy and Sama Saraswathi Reddy Gardens, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1332/HYD/2025[2011-12]Status: DisposedITAT Hyderabad20 Feb 2026AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

provisions of section 148(2) of the Act. 5. The Learned CIT(A) ought to have considered that the AO, without having any incriminating material to suggest that income has escaped assessment was found during the course of survey, has issued notice u/s 148 and that to without recording reasons

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

submitted by producing the ledger account of Mr. Vasudev in his books. 5. The Ld.CIT(A) erred in holding that the seized paper constitutes incriminating material as it contains unaccounted cash transactions along with admitted banking transactions whereas the seized paper nowhere mentioned that cash loan of Rs.2 crores ... indicate the date or year of the alleged cash transaction with Mr. Vasudev and Page 3 of 19 consequently, it does not constitute incriminating material for the AY in question. The AO erred in making this addition in the assessment completed u/s.153C for the assessment year in question which