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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

Sanjay Rawat, Dehradun vs. ACIT Central Circle, Dehradun

In the result, appeal of the assessee is allowed

ITA 90/DDN/2024[2015-16]Status: DisposedITAT Dehradun11 Feb 2026AY 2015-16

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 271

ITA Nos.90, 95 & 104/DDN/2024 IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “SMC” BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S, JUDICIAL

Sh.Sanjay Rawat, Dehradun vs. ACIT, Circle, Dehradun

In the result, appeal of the assessee is allowed

ITA 104/DDN/2024[2013-14]Status: DisposedITAT Dehradun11 Feb 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 271

ITA Nos.90, 95 & 104/DDN/2024 IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “SMC” BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S, JUDICIAL

Smt Neha Prasanna Ghotage, Belagavi vs. Income Tax Officer, Ward - 1, Karwar

Appeals are DISMISSED

ITA 268/PAN/2025[2010-11]Status: DisposedITAT Panaji11 Feb 2026AY 2010-11

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]
Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

refuted that, pursuant to a search action u/s 132 of the Act on Mr Prasanna Ghotage (the spouse of the present appellant assessee) certain incriminating material of the assessee were found and seized. The consequential proceedings were initiated u/s 153 of the Act. In response thereto, the assessee neither filed

Smt Neha Prasanna Ghotage, Belagavi vs. Income Tax Officer, Ward - 1, Karwar

Appeals are DISMISSED

ITA 267/PAN/2025[2009-10]Status: DisposedITAT Panaji11 Feb 2026AY 2009-10

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]
Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

refuted that, pursuant to a search action u/s 132 of the Act on Mr Prasanna Ghotage (the spouse of the present appellant assessee) certain incriminating material of the assessee were found and seized. The consequential proceedings were initiated u/s 153 of the Act. In response thereto, the assessee neither filed

Smt Neha Prasanna Ghotage, Belagavi vs. Income Tax Officer, Ward - 1, Karwar

Appeals are DISMISSED

ITA 266/PAN/2025[2008-09]Status: DisposedITAT Panaji11 Feb 2026AY 2008-09

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]
Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

refuted that, pursuant to a search action u/s 132 of the Act on Mr Prasanna Ghotage (the spouse of the present appellant assessee) certain incriminating material of the assessee were found and seized. The consequential proceedings were initiated u/s 153 of the Act. In response thereto, the assessee neither filed

Smt Neha Prasanna Ghotage, Belagavi vs. Income Tax Officer, Ward - 1, Karwar

Appeals are DISMISSED

ITA 265/PAN/2025[2007-08]Status: DisposedITAT Panaji11 Feb 2026AY 2007-08

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]
Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

refuted that, pursuant to a search action u/s 132 of the Act on Mr Prasanna Ghotage (the spouse of the present appellant assessee) certain incriminating material of the assessee were found and seized. The consequential proceedings were initiated u/s 153 of the Act. In response thereto, the assessee neither filed

Smt Neha Prasanna Ghotage, Belagavi vs. Income Tax Officer, Ward - 1, Karwar

Appeals are DISMISSED

ITA 264/PAN/2025[2006-07]Status: DisposedITAT Panaji11 Feb 2026AY 2006-07

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]
Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

refuted that, pursuant to a search action u/s 132 of the Act on Mr Prasanna Ghotage (the spouse of the present appellant assessee) certain incriminating material of the assessee were found and seized. The consequential proceedings were initiated u/s 153 of the Act. In response thereto, the assessee neither filed

Smt Neha Prasanna Ghotage, Belagavi vs. Assistant Commissioner of Income Tax, Central Circle - 2, Belagavi

Appeals are DISMISSED

ITA 263/PAN/2025[2010-11]Status: DisposedITAT Panaji11 Feb 2026AY 2010-11

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]
Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

refuted that, pursuant to a search action u/s 132 of the Act on Mr Prasanna Ghotage (the spouse of the present appellant assessee) certain incriminating material of the assessee were found and seized. The consequential proceedings were initiated u/s 153 of the Act. In response thereto, the assessee neither filed

Smt Neha Prasanna Ghotage, Belagavi vs. Assistant Commissioner of Income Tax, Central Circle - 2, Belagavi

Appeals are DISMISSED

ITA 262/PAN/2025[2009-10]Status: DisposedITAT Panaji11 Feb 2026AY 2009-10

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]
Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

refuted that, pursuant to a search action u/s 132 of the Act on Mr Prasanna Ghotage (the spouse of the present appellant assessee) certain incriminating material of the assessee were found and seized. The consequential proceedings were initiated u/s 153 of the Act. In response thereto, the assessee neither filed

Smt Neha Prasanna Ghotage, Belagavi vs. Assistant Commissioner of Income Tax, Central Circle - 2, Belagavi

Appeals are DISMISSED

ITA 261/PAN/2025[2008-09]Status: DisposedITAT Panaji11 Feb 2026AY 2008-09

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]
Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

refuted that, pursuant to a search action u/s 132 of the Act on Mr Prasanna Ghotage (the spouse of the present appellant assessee) certain incriminating material of the assessee were found and seized. The consequential proceedings were initiated u/s 153 of the Act. In response thereto, the assessee neither filed

Smt Neha Prasanna Ghotage, Belagavi vs. Assistant Commissioner of Income Tax, Central Circle - 2, Belagavi

Appeals are DISMISSED

ITA 260/PAN/2025[2007-08]Status: DisposedITAT Panaji11 Feb 2026AY 2007-08

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]
Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

refuted that, pursuant to a search action u/s 132 of the Act on Mr Prasanna Ghotage (the spouse of the present appellant assessee) certain incriminating material of the assessee were found and seized. The consequential proceedings were initiated u/s 153 of the Act. In response thereto, the assessee neither filed

Smt Neha Prasanna Ghotage, Belagavi vs. Assistant Commissioner of Income Tax, Central Circle, 2, Belagavi

Appeals are DISMISSED

ITA 259/PAN/2025[2006-07]Status: DisposedITAT Panaji11 Feb 2026AY 2006-07

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]
Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

refuted that, pursuant to a search action u/s 132 of the Act on Mr Prasanna Ghotage (the spouse of the present appellant assessee) certain incriminating material of the assessee were found and seized. The consequential proceedings were initiated u/s 153 of the Act. In response thereto, the assessee neither filed

Home Construction Co, Ludhiana vs. DCIT Central Circle 1, Ludhiana

In the result, appeal of the Assessee is allowed

ITA 615/CHANDI/2025[2022-2023]Status: DisposedITAT Chandigarh11 Feb 2026AY 2022-2023

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 132Section 139(1)Section 271A

held that the statement of Shri Jagjit Singh Grewal, being vague and not related to any specific flat or transaction, does not constitute incriminating material and cannot be the sole basis for addition, as it amounts to surmise and conjecture. This view is supported by the Hon'ble Supreme Court ... Kochhar), the CIT(A) deleted the addition of Rs.33,33,334/-. The AO had extrapolated the rate from Flat A-1 without any specific incriminating material relating to Flat A-3. The CIT(A) observed that in the real estate sector, the price of each flat varies significantly

Sricharan Devineni, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

ITA 1573/HYD/2025[2022-23]Status: DisposedITAT Hyderabad11 Feb 2026AY 2022-23

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia(In आयकर अपीलसं./I.T.A. No.1559/Hyd/2025 (निर्धारणवर्ष/ Assessment Year:2023-24) Nagalakshmi Devineni, Hyderabad. Pan: Afnpd6112N Vs. Dcit, Central Circle-1(2), Hyderabad. (अपीलार्थी/ Appellant) (प्रत्यर्थी / Respondent) (In आयकर अपीलसं./I.T.A. No.1563/Hyd/2025 (निर्धारणवर्ष/ Assessment Year:2021-22) Sri Venkat Devineni, Hyderabad. Pan: Alipd6384R Vs. Dcit, Central Circle-1(2), Hyderabad. (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) (In आयकर अपीलसं./I.T.A. No.1573/Hyd/2025 (निर्धारणवर्ष/ Assessment Year:2022-23) Sricharan Devineni, Hyderabad. Pan: Bgjpd6383B Vs. Dcit, Central Circle-1(2), Hyderabad. (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाताकाप्रतिनिधित्व/ Assessee Represented By राजस्वकाप्रतिनिधित्व/ Department Represented By : Shri H. Srinivasulu, Advocate : Dr. Sachin Kumar, Sr. Ar सुनवाईसमाप्तहोनेकीतिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/ Date Of Pronouncement

Section 1Section 132

statement of the assessee's son, who is admittedly a third party in the assessee's case. It was contended that no incriminating material whatsoever was found or seized from the possession of the assessee during the course of the search. The Ld. AO has also failed to substantiate

Sri Venkat Devineni, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1563/HYD/2025[2021-22]Status: DisposedITAT Hyderabad11 Feb 2026AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia(In आयकर अपीलसं./I.T.A. No.1559/Hyd/2025 (निर्धारणवर्ष/ Assessment Year:2023-24) Nagalakshmi Devineni, Hyderabad. Pan: Afnpd6112N (अपीलार्थी/ Appellant) Vs. Dcit, Central Circle-1(2), Hyderabad. (प्रत्यर्थी / Respondent) (In आयकर अपीलसं./I.T.A. No.1563/Hyd/2025 (निर्धारणवर्ष/ Assessment Year:2021-22) Sri Venkat Devineni, Hyderabad. Pan: Alipd6384R (अपीलार्थी/ Appellant) Vs. Dcit, Central Circle-1(2), Hyderabad. (प्रत्यर्थी/ Respondent) (In आयकर अपीलसं./I.T.A. No.1573/Hyd/2025 (निर्धारणवर्ष/ Assessment Year:2022-23) Sricharan Devineni, Hyderabad. Pan: Bgjpd6383B (अपीलार्थी/ Appellant) Vs. Dcit, Central Circle-1(2), Hyderabad. (प्रत्यर्थी/ Respondent) करदाताकाप्रतिनिधित्व/ Assessee Represented By राजस्वकाप्रतिनिधित्व/ Department Represented By : Shri H. Srinivasulu, Advocate : Dr. Sachin Kumar, Sr. Ar सुनवाईसमाप्तहोनेकीतिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/ Date Of Pronouncement

Section 132

statement of the assessee's son, who is admittedly a third party in the assessee's case. It was contended that no incriminating material whatsoever was found or seized from the possession of the assessee during the course of the search. The Ld. AO has also failed to substantiate

Nagalakshmi Devineni, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee in ITA no

ITA 1559/HYD/2025[2023-24]Status: DisposedITAT Hyderabad11 Feb 2026AY 2023-24

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia(In आयकर अपीलसं./I.T.A. No.1559/Hyd/2025 ("नधा"रणवष"/ Assessment Year:2023-24) Nagalakshmi Devineni, Vs. Dcit, Hyderabad. Central Circle-1(2), Pan: Afnpd6112N Hyderabad. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) (In आयकर अपीलसं./I.T.A. No.1563/Hyd/2025 ("नधा"रणवष"/ Assessment Year:2021-22) Sri Venkat Devineni, Vs. Dcit, Hyderabad. Central Circle-1(2), Pan: Alipd6384R Hyderabad. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) (In आयकर अपीलसं./I.T.A. No.1573/Hyd/2025 ("नधा"रणवष"/ Assessment Year:2022-23) Sricharan Devineni, Vs. Dcit, Hyderabad. Central Circle-1(2), Pan: Bgjpd6383B Hyderabad. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri H. Srinivasulu, Advocate Assessee Represented By राज"वका""त"न"ध"व/ : Dr. Sachin Kumar, Sr. Ar Department Represented By

Section 132Section 132(4)

statement of the assessee’s son, who is admittedly a third party in the assessee’s case. It was contended that no incriminating material whatsoever was found or seized from the possession of the assessee during the course of the search. The Ld. AO has also failed to substantiate ... following effect : “38. Fifthly, statements recorded under Section 132 (4) of the Act of the Act do not by themselves constitute incriminating material as has been explained by this Court in Commissioner of Income Tax v. Harjeev Aggarwal (supra). Lastly, as already pointed out hereinbefore, the facts in the present

Narmala Pennechand Sarda, Mumbai vs. Income Tax Officer, Ward - 42(2)(4), Mumbai

In the result, the addition made by

ITA 7291/MUM/2025[2023-24]Status: DisposedITAT Mumbai11 Feb 2026AY 2023-24

Bench: Shri Pawan Singh& Shri Arun Khodpia(Physical Hearing)

Section 132Section 143(3)Section 254(1)Section 69

recorded that a search action under section 132 was carried out in Surana Group in Surat on 08.12.2023. In the said search action, certain incriminating material of unaccounted transaction pertaining to real estate business of Surana Group was found and seized from the residential premises of Pawankumar Rameshwarlal Lahoti ... such incriminating material, certain evidence pertains to project “IFC” that is international finance centre, which is commercial complex. As per the information available on GujRera website, it consists of one tower having 195 units. The project was developed in Vesu area of Surat. The AO also received information from DDIT

Meghji Mansukhlal Dodhia, Bhiwandi vs. DCIT-CC-3, Thane

ITA 2224/MUM/2025[2013-14]Status: DisposedITAT Mumbai11 Feb 2026AY 2013-14

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. It(Ss)A No. 2226/Mum/2025 S.A. No. 79/Mum/2025 (Assessment Year: 2012-13) Mansukhlal Meghji Dodhia House No. 104, Dodhia House, New Mavji Compound, Narpoli, Maharashtra-421 302 (Applicant) Dcit Cc-3, Thane Vs. Room No. 12, A Wing, 6Th Floor, Ashar It Park, Thane, West, Maharashtra - 400 604 Pan/Gir No. Aaspd6746L (Respondent) 2. Ita No. 2224/Mum/2025 S.A. No. 80/Mum/2025 (Assessment Year: 2013-14) 3. It(Ss)A No. 2223/Mum/2025 S.A. No. 81/Mum/2025 & 4. It(Ss)A No. 2222/Mum/2025 S.A. No. 82/Mum/2025 (Assessment Year: 2015-16) 5. It(Ss)A No. 2225/Mum/2025 S.A. No. 83/Mum/2025 (Assessment Year: 2016-17) Meghji Mansukhlal Dodhia House No. 104, Dodhia House, New Mavji Compound, Narpoli, Maharashtra-421 302 (Applicant) Dcit Cc-3, Thane Vs. Room No. 12, A Wing, 6Th Floor, Ashar It Park, Thane, West, Maharashtra - 400 604 Pan/Gir No. Aaspd6746L (Respondent) (2) It(Ss)A No. 2226, 2223, 2222 & 2225/Mum/2025 &

Section 132Section 143(3)Section 153ASection 68Section 69D

constituted “dumb documents”. It was further contended that no corroborative evidence was brought on record to establish receipt or utilization of cash and no incriminating material pertaining to certain assessment years was found during search. The assessee submitted that the additions were made merely on the basis of statements which ... account of alleged unexplained cash credit in respect of unsecured loan in the absenсе of any incriminating material unearthed during course of search carried out on the appellant and making addition solely on the basis of information received from other sources in the proceedings initiated by issue of notice

Dheeraj Chaudhary, New Delhi vs. ACIT, Central Circle-8, New Delhi

In the result, appeal of the assessee in ITA No

ITA 6217/DEL/2018[2015-16]Status: DisposedITAT Delhi11 Feb 2026AY 2015-16

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Ruchesh Sinha, AdvFor Respondent: Shri Sumer Singh Meena,CIT-DR
Section 153A

assessment u/s 153A of the Income-tax Act, 1961 [the Act, for short] [A.Y 2015-16] Shri Dheeraj Chaudhary vs ACIT since no incriminating material was found as a result of search and the additions made are without jurisdiction. 3. Briefly stated, the facts of the case are that ... said addition. Ground 7 is allowed. 14. The challenge in ground 1 to 4 to the assessment being made u/s 153A/143(3) without incriminating materials, are dismissed as the AO has validly assumed the jurisdiction u/s 153A on the basis of incriminating materials as discussed above. The ground

Shri Kamlesh Vashrambhai Ramani, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Central Circle-2, Rajkot-Gujarat

In the result, appeal filed by the assessee, (in ITA No

ITA 65/RJT/2014[2010-11]Status: DisposedITAT Rajkot10 Feb 2026AY 2010-11

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita No.451/Rjt/2013 (Assessment Years: (2008-2009) Shri Vashrambhai Ghelabhai Ramani, Vs. The Dcit, 22, Ranchodnagar Society, Kuvadava Central Circle-2, Road, Rajkot. Rajkot. "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bflpr5056N आयकर अपील सं./Ita Nos.65/Rjt/2014 (Assessment Years: (2010-11) & आयकर अपील सं./Ita Nos. 63/Rjt/2014 &407/Rjt/2014 (Assessment Year: 2011-2012) Shri Kamlesh Vashrambhai Ramani, Deputy Commissioner Of Income-Tax, Prop. Marutinandan Petroleum, 22, Vs. Central Circle-2, Ranchodnagar Society,Rajkot. Rajkot. "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahqpr2043D

For Appellant: Shri Samir Bhuptani, ARFor Respondent: Shri Sanjay Kumar, CIT- DR
Section 132Section 143(3)Section 153ASection 271A

income. The Ld.Counsel for the assessee also submitted, addition should not be made, based on the assessee’s son statement, as there was no incriminating material, in the hands of the AO to make addition. Therefore, ld. Counsel contended that remaining addition sustained by the learned