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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

Jaipal Singh, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

Appeal of the assessee are disposed off

ITA 119/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Mar 2025AY 2017-18
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

assessee through an affidavit sought to retract from statement made under section 132(4) on ground that (a) when there was no evidence or incriminating material discovered at time of search no addition could have been made merely on basis of statement under section 132(4) and (b) that impugned

Jaipal Singh, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

Appeal of the assessee are disposed off

ITA 118/JPR/2024[2016-17]Status: DisposedITAT Jaipur11 Mar 2025AY 2016-17
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

assessee through an affidavit sought to retract from statement made under section 132(4) on ground that (a) when there was no evidence or incriminating material discovered at time of search no addition could have been made merely on basis of statement under section 132(4) and (b) that

Jaipal Singh, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

Appeal of the assessee are disposed off

ITA 116/JPR/2024[2014-15]Status: DisposedITAT Jaipur11 Mar 2025AY 2014-15
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

assessee through an affidavit sought to retract from statement made under section 132(4) on ground that (a) when there was no evidence or incriminating material discovered at time of search no addition could have been made merely on basis of statement under section 132(4) and (b) that

Jaipal Singh, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

Appeal of the assessee are disposed off

ITA 115/JPR/2024[2013-14]Status: DisposedITAT Jaipur11 Mar 2025AY 2013-14
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

assessee through an affidavit sought to retract from statement made under section 132(4) on ground that (a) when there was no evidence or incriminating material discovered at time of search no addition could have been made merely on basis of statement under section 132(4) and (b) that impugned

Raziulla Syed, Hyderabad vs. ITO (Int Taxn)-2, Hyderabad

In the result, appeal of the Assessee is allowed

ITA 986/HYD/2024[2017-18]Status: DisposedITAT Hyderabad11 Mar 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA P Murali Mohan RaoFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 132Section 142(1)Section 144C(5)Section 147Section 148Section 148ASection 195

proceedings u/sec.147 of the Act instead of 153C. He submitted that where there is a search u/sec.132 of the Act and found any incriminating material related to other person i.e., in the present case search was conducted in M/s. Skill Promoters Pvt. Ltd., and found loose sheets pertains ... assessee viz., Raziulla Syed. He submitted that when there was a search conducted u/sec.132 of the Act and some incriminating material was impounded or relatable to the person other than on whom search was conducted, section 153C is to be resorted to. He accordingly submitted that reopening of assessment u/sec.147

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Coimbatore

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

ITA 552/CHNY/2024[2018-19]Status: DisposedITAT Chennai11 Mar 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

Appeals) - 20, Chennai failed to appreciate that having assessed the appellant in terms of Section 153A of the Act based on the incriminating materials seized during the search in the premises of Mr. O. Arumugasamy and others in contra distinction to the search in the premises of the appellant herein ... wherein no incriminating materials were seized for the purpose of making the disputed addition(s) in the search assessment order(s), the consequential search assessment order passed should be reckoned as bad in law. 4. The CIT(Appeals) - 20, Chennai failed to appreciate that having used the disputed search materials

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Coimbatore

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

ITA 551/CHNY/2024[2017-18]Status: DisposedITAT Chennai11 Mar 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

Appeals) - 20, Chennai failed to appreciate that having assessed the appellant in terms of Section 153A of the Act based on the incriminating materials seized during the search in the premises of Mr. O. Arumugasamy and others in contra distinction to the search in the premises of the appellant herein ... wherein no incriminating materials were seized for the purpose of making the disputed addition(s) in the search assessment order(s), the consequential search assessment order passed should be reckoned as bad in law. 4. The CIT(Appeals) - 20, Chennai failed to appreciate that having used the disputed search materials

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Coimbatore

ITA 550/CHNY/2024[2016-17]Status: DisposedITAT Chennai11 Mar 2025AY 2016-17
For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

Appeals) 20, Chennai failed to appreciate that having assessed the appellant in terms of Section 153A of the Act based on the incriminating materials seized during the search in the premises of Mr. O. Arumugasamy and others in contra distinction to the search in the premises of the appellant herein ... wherein no incriminating materials were seized for the purpose of making the disputed addition(s) in the search assessment order(s), the consequential search assessment order passed should be reckoned as bad in law. 4. The CIT(Appeals) - 20, Chennai failed to appreciate that having used the disputed search materials

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Chennai

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

ITA 549/CHNY/2024[2015-16]Status: DisposedITAT Chennai11 Mar 2025AY 2015-16

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

Appeals) - 20, Chennai failed to appreciate that having assessed the appellant in terms of Section 153A of the Act based on the incriminating materials seized during the search in the premises of Mr. O. Arumugasamy and others in contra distinction to the search in the premises of the appellant herein ... wherein no incriminating materials were seized for the purpose of making the disputed addition(s) in the search assessment order(s), the consequential search assessment order passed should be reckoned as bad in law. 4. The CIT(Appeals) - 20, Chennai failed to appreciate that having used the disputed search materials

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Coimbatore

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

ITA 548/CHNY/2024[2014-15]Status: DisposedITAT Chennai11 Mar 2025AY 2014-15

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

Appeals) - 20, Chennai failed to appreciate that having assessed the appellant in terms of Section 153A of the Act based on the incriminating materials seized during the search in the premises of Mr. O. Arumugasamy and others in contra distinction to the search in the premises of the appellant herein ... wherein no incriminating materials were seized for the purpose of making the disputed addition(s) in the search assessment order(s), the consequential search assessment order passed should be reckoned as bad in law. 4. The CIT(Appeals) - 20, Chennai failed to appreciate that having used the disputed search materials

DCIT-C-6(2), Mumbai vs. Samira Habitats India Limited, Mumbai

In the result, appeals by the revenue are dismissed and cross- objections by the assessee are allowed

ITA 5713/MUM/2024[2007-08]Status: DisposedITAT Mumbai11 Mar 2025AY 2007-08

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Rakesh Joshi, A/RFor Respondent: Shri Dr. Kishor Dhule, CIT D/R
Section 132Section 144Section 153CSection 153C(1)

case of assessee. 7. We have carefully perused the assessment order. Surprisingly, the assessment order is completely silent on the date on which the incriminating material relating to the “third person” i.e., the assessee was received by the AO nor there is any mention of any satisfaction recorded in respect ... those incriminating material. As per the information gathered the notice in the case of the searched person was issued in May, 2013, therefore, it can be safely presumed that the notice in the case of the “other person” i.e., the assessee, must have been issued after the proceedings initiated

DCIT-C-6(2), Mumbai vs. Samira Habitats India Limited, Mumbai

In the result, appeals by the revenue are dismissed and cross- objections by the assessee are allowed

ITA 5712/MUM/2024[2008-09]Status: DisposedITAT Mumbai11 Mar 2025AY 2008-09

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Rakesh Joshi, A/RFor Respondent: Shri Dr. Kishor Dhule, CIT D/R
Section 132Section 144Section 153CSection 153C(1)

case of assessee. 7. We have carefully perused the assessment order. Surprisingly, the assessment order is completely silent on the date on which the incriminating material relating to the “third person” i.e., the assessee was received by the AO nor there is any mention of any satisfaction recorded in respect ... those incriminating material. As per the information gathered the notice in the case of the searched person was issued in May, 2013, therefore, it can be safely presumed that the notice in the case of the “other person” i.e., the assessee, must have been issued after the proceedings initiated

ACIT CC -6(1), Mumbai, Bkc vs. Sanjay Dagadu Deshpute, Nasik

In the result, appeal of the Revenue is dismissed

ITA 5680/MUM/2024[2021-22]Status: DisposedITAT Mumbai11 Mar 2025AY 2021-22

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri Rashmikant Modi / KetkiFor Respondent: Shri Dr. Kishor Dhule, CIT-DR
Section 132Section 132(4)Section 148Section 69C

some of the documents belonging to 3 ITA No.5680/Mum/2024 - Sanjay Dagadu Deshpute Rucha Group were kept at the premises of Shri Avish Atal the incriminating materials contained details of payment made by the PWD Engineers. One of the entry related to the assessee, it was alleged that the assessee

Raj Kumar Golecha, Pali vs. Assistant Commissioner of Income Tax, Central Circle-2, Jodhpur, Aaykar Bhawan

Appeal of the assessee is allowed

ITA 515/JODH/2023[2014-15]Status: DisposedITAT Jodhpur10 Mar 2025AY 2014-15
Section 10(38)Section 132Section 132(4)Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 250

search or requisition, namely, in relation to material disclosed during the search or requisition. If in relation to any assessment year, no incriminating material is found, no addition or disallowance can be made in relation to that assessment year in the exercise of powers under section 153A ... income determined and sought to be taxed were not from the materials seized during the time of search. Since in the instant case, no incriminating materials were seized during the time of search and therefore, no addition or disallowance can be made in an assessment under section 153A

M/S River Valley Flour Mills Pvt Ltd, Patna vs. ACIT, Central Circle-1, Patna

In the result, the appeal of the assessee is allowed

ITA 14/PAT/2025[2015-16]Status: DisposedITAT Patna10 Mar 2025AY 2015-16

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

For Appellant: Shri S.K. Tulsiyan, ARFor Respondent: Shri Ashwani Kr. Singal, DR
Section 132(1)Section 132(4)Section 142(1)Section 143(2)Section 153ASection 271A

assessment years, during the course of recording of statement u/s 132(4) of the Act, which was not backed by any incriminating material found during the course of rch. Accordingly, the assessee did not offer the same to tax in the returns of income filed for the various assessment years ... name of the assessee company was found to be incorrect by the assessee as there was no incriminating material 06. (PI Page |4 ITA No.14/PAT/2025 M/s River Valley Flour Mills Pvt. Itd; A.Y. 2015-16 found during search and no such income was ever offered or assessed. We also note

Resonance Eduventures Limited, Kota vs. ACIT DCIT, Central Circle, Kota

In the result, all the appeals of the assessee are allowed

ITA 672/JPR/2024[2018-19]Status: DisposedITAT Jaipur10 Mar 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Mahendra Gargieya, Adv. (Thr. V.C)&For Respondent: Smt. Alka Gautam, CIT-DR
Section 143(3)Section 14ASection 153DSection 234DSection 250

case by not following the law laid down by the Apex Court holding that no addition is legally permissible in absence of any incriminating material found during the course of search in the case of an unabated/completed assessment and hence, in this case, in absence of any incriminating material found ... submitted that Jt. CIT is the approving authority who, before granting approval, is required to see all search material including incriminating material, seized documents, appraisal report, enquiries made by the investigation wing and various enquiries made by the Assessing Officer during the assessment proceedings and the replies submitted

Resonance Eduventures Limited, Kota vs. ACIT DCIT, Central Circle, Kota

In the result, all the appeals of the assessee are allowed

ITA 671/JPR/2024[2017-18]Status: DisposedITAT Jaipur10 Mar 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Mahendra Gargieya, Adv. (Thr. V.C)&For Respondent: Smt. Alka Gautam, CIT-DR
Section 143(3)Section 14ASection 153DSection 234DSection 250

case by not following the law laid down by the Apex Court holding that no addition is legally permissible in absence of any incriminating material found during the course of search in the case of an unabated/completed assessment and hence, in this case, in absence of any incriminating material found ... submitted that Jt. CIT is the approving authority who, before granting approval, is required to see all search material including incriminating material, seized documents, appraisal report, enquiries made by the investigation wing and various enquiries made by the Assessing Officer during the assessment proceedings and the replies submitted

Resonance Eduventures Limited, Kota vs. ACIT DCIT, Central Circle, Kota

In the result, all the appeals of the assessee are allowed

ITA 670/JPR/2024[2016-17]Status: DisposedITAT Jaipur10 Mar 2025AY 2016-17
For Appellant: Shri Mahendra Gargieya, Adv. (Thr. V.C)&For Respondent: Smt. Alka Gautam, CIT-DR
Section 143(3)Section 14ASection 153DSection 234DSection 250

case by not following the law laid down by the Apex Court holding that no addition is legally permissible in absence of any incriminating material found during the course of search in the case of an unabated/completed assessment and hence, in this case, in absence of any incriminating material found ... submitted that Jt. CIT is the approving authority who, before granting approval, is required to see all search material including incriminating material, seized documents, appraisal report, enquiries made by the investigation wing and various enquiries made by the Assessing Officer during the assessment proceedings and the replies submitted

Resonance Eduventures Limited, Kota vs. ACIT DCIT, Central Circle, Kota

In the result, all the appeals of the assessee are allowed

ITA 669/JPR/2024[2015-16]Status: DisposedITAT Jaipur10 Mar 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Mahendra Gargieya, Adv. (Thr. V.C)&For Respondent: Smt. Alka Gautam, CIT-DR
Section 143(3)Section 14ASection 153DSection 234DSection 250

case by not following the law laid down by the Apex Court holding that no addition is legally permissible in absence of any incriminating material found during the course of search in the case of an unabated/completed assessment and hence, in this case, in absence of any incriminating material found ... submitted that Jt. CIT is the approving authority who, before granting approval, is required to see all search material including incriminating material, seized documents, appraisal report, enquiries made by the investigation wing and various enquiries made by the Assessing Officer during the assessment proceedings and the replies submitted

ACIT, Jaipur vs. Udai Buildhome Pvt Ltd, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1486/JPR/2024[2018]Status: DisposedITAT Jaipur10 Mar 2025

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, JM आयकर अपील सं. / ITA Nos.1399, 1400, 1401 & 1486/JP/2024 निर्धारण वर्ष / Assessment Years : 2014-15, 2015-16, 2017-18 & 2018-19 Asstt. Commissioner of Income Tax, Central Circle-02, Jaipur बनाम Vs. M/s Udai Buildhome Pvt. Ltd. 302, Golden Sunrise Apartment, Lajpat Marg, C- Scheme, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AABCU 5068 J अपीलार्थी / Appellant निर्धारिती की ओर से / Assessee by: प्रत्यर्थी / Respond

For Appellant: Sh. C.M. Agarwal, CAFor Respondent: Smt. Roshanta Meena, CIT
Section 143(3)Section 153C

very initiation of proceedings u/s 153C of the Income Tax Act is totally illegal, bad in law and without jurisdiction. (b) No incriminating material belonging to the assessee was found during the course of search pertaining to the A.Y.2013-14. On this issue the appellant has contended that:- In the assessment ... years which are mentioned in that provision, the same alone would not be sufficient to justify steps in that direction being taken, unless the incriminating material so found is likely to have an impact on the total income of a particular AY forming part of the six AYs' immediately preceding