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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

Assistant Commissioner of Income Tax, Central Circle-1, Rajahmundry vs. Hasini Infra Consrtuctions& Developers, Kakinada

In the result, both the Revenue’s appeals are dismissed

ITA 24/VIZ/2023[2018-19]Status: DisposedITAT Visakhapatnam04 May 2023AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. Nos.9, 10 & 11/Viz/2023 ("नधा"रणवष"/ Assessment Year: 2017-18, 2018-19 & 2019-20) Hasini Infra Constructions & Vs. The Asst. Commissioner Of Developers, Income Tax, D.No.2-27-23, Gokul Street, Central Circle-1, Kakinada. Rajahmundry. Pan: Aaifh 0895 E (अपीलाथ"/ Appellant) (""यथ"/ Respondent) आयकरअपीलसं./ I.T.A. Nos. 24 & 25/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2018-19 & 2019-20) The Asst. Commissioner Of Vs. Hasini Infra Constructions Income Tax & Developers, Central Circle-1, D.No.2-27-23, Gokul Street, Rajahmundry. Kakinada. Pan: Aaifh 0895 E (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Assessee By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Revenue By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 132Section 142(1)Section 143(2)Section 143(3)Section 153A

seizure operation U/s. 132 of the Act was conducted on 28/03/2019 in the case of the assessee-firm at its registered premises wherein certain incriminating material was found and seized. Subsequently, the case was centralized by the order of the Ld. Principal Commissioner of Income Tax-2, Visakhapatnam vide order ... ought to have appreciated that the Assessing Officer has made the addition without proper jurisdiction since the addition made on the basis of incriminating material found in the third party premises but not in the premises of the appellant. 3. The Ld. CIT(A) ought to have considered that

Navya Hasini and Harshitha Constructions and Developers, Bhimavaram vs. Assistant Commissioner of Income Tax, Central Circle-1, Rajahmundry

In the result, appeal of the assessee is allowed

ITA 14/VIZ/2023[2019-20]Status: DisposedITAT Visakhapatnam04 May 2023AY 2019-20

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri M.V. Prasad, CAFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 142(1)Section 143(2)Section 153A

based on the documents seized from the premises of the Managing Partner Mr. Ch. Murali. The Ld. AR pleaded that no incriminating material was found in the premises of the assessee during the search in the premises of the assessee and hence the making of additions based on the material ... plain reading of the above section it is intended by the Legislature that section 153C can be invoked by the Revenue and can utilize incriminating material found in the search of any other person different to the assessee. In the instant case, such incriminating material was found in the premises

Navya Hasini and Harshitha Constructions and Developers, Bhimavaram vs. Assistant Commissioner of Income Tax, Central Circle-1, Rajahmundry

In the result, appeal of the assessee is allowed

ITA 13/VIZ/2023[2018-19]Status: DisposedITAT Visakhapatnam04 May 2023AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri M.V. Prasad, CAFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 142(1)Section 143(2)Section 153A

based on the documents seized from the premises of the Managing Partner Mr. Ch. Murali. The Ld. AR pleaded that no incriminating material was found in the premises of the assessee during the search in the premises of the assessee and hence the making of additions based on the material ... plain reading of the above section it is intended by the Legislature that section 153C can be invoked by the Revenue and can utilize incriminating material found in the search of any other person different to the assessee. In the instant case, such incriminating material was found in the premises

Navya Hasini and Harshitha Constructions and Developers, Bhimavaram vs. Assistant Commissioner of Income Tax, Central Circle-1, Rajahmundry

In the result, appeal of the assessee is allowed

ITA 12/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam04 May 2023AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri M.V. Prasad, CAFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 142(1)Section 143(2)Section 153A

based on the documents seized from the premises of the Managing Partner Mr. Ch. Murali. The Ld. AR pleaded that no incriminating material was found in the premises of the assessee during the search in the premises of the assessee and hence the making of additions based on the material ... plain reading of the above section it is intended by the Legislature that section 153C can be invoked by the Revenue and can utilize incriminating material found in the search of any other person different to the assessee. In the instant case, such incriminating material was found in the premises

Hasini Infra Constructions and Developers, Kakinada vs. Assistant Commissioner of Income Tax, Central Circle-1, Rajahmundry

In the result, both the Revenue’s appeals are dismissed

ITA 11/VIZ/2023[2019-20]Status: DisposedITAT Visakhapatnam04 May 2023AY 2019-20

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. Nos.9, 10 & 11/Viz/2023 ("नधा"रणवष"/ Assessment Year: 2017-18, 2018-19 & 2019-20) Hasini Infra Constructions & Vs. The Asst. Commissioner Of Developers, Income Tax, D.No.2-27-23, Gokul Street, Central Circle-1, Kakinada. Rajahmundry. Pan: Aaifh 0895 E (अपीलाथ"/ Appellant) (""यथ"/ Respondent) आयकरअपीलसं./ I.T.A. Nos. 24 & 25/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2018-19 & 2019-20) The Asst. Commissioner Of Vs. Hasini Infra Constructions Income Tax & Developers, Central Circle-1, D.No.2-27-23, Gokul Street, Rajahmundry. Kakinada. Pan: Aaifh 0895 E (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Assessee By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Revenue By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 132Section 142(1)Section 143(2)Section 143(3)Section 153A

seizure operation U/s. 132 of the Act was conducted on 28/03/2019 in the case of the assessee-firm at its registered premises wherein certain incriminating material was found and seized. Subsequently, the case was centralized by the order of the Ld. Principal Commissioner of Income Tax-2, Visakhapatnam vide order ... ought to have appreciated that the Assessing Officer has made the addition without proper jurisdiction since the addition made on the basis of incriminating material found in the third party premises but not in the premises of the appellant. 3. The Ld. CIT(A) ought to have considered that

Hasini Infra Constructions and Developers, Kakinada vs. Assistant Commissioner of Income Tax, Central Circle-1, Rajahmundry

In the result, both the Revenue’s appeals are dismissed

ITA 10/VIZ/2023[2018-19]Status: DisposedITAT Visakhapatnam04 May 2023AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. Nos.9, 10 & 11/Viz/2023 ("नधा"रणवष"/ Assessment Year: 2017-18, 2018-19 & 2019-20) Hasini Infra Constructions & Vs. The Asst. Commissioner Of Developers, Income Tax, D.No.2-27-23, Gokul Street, Central Circle-1, Kakinada. Rajahmundry. Pan: Aaifh 0895 E (अपीलाथ"/ Appellant) (""यथ"/ Respondent) आयकरअपीलसं./ I.T.A. Nos. 24 & 25/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2018-19 & 2019-20) The Asst. Commissioner Of Vs. Hasini Infra Constructions Income Tax & Developers, Central Circle-1, D.No.2-27-23, Gokul Street, Rajahmundry. Kakinada. Pan: Aaifh 0895 E (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Assessee By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Revenue By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 132Section 142(1)Section 143(2)Section 143(3)Section 153A

seizure operation U/s. 132 of the Act was conducted on 28/03/2019 in the case of the assessee-firm at its registered premises wherein certain incriminating material was found and seized. Subsequently, the case was centralized by the order of the Ld. Principal Commissioner of Income Tax-2, Visakhapatnam vide order ... ought to have appreciated that the Assessing Officer has made the addition without proper jurisdiction since the addition made on the basis of incriminating material found in the third party premises but not in the premises of the appellant. 3. The Ld. CIT(A) ought to have considered that

Late Sh. Vijay Kumar Johari (Through L/H Smt. Hema Johari, Sh. Vaibhav Johari & Sh. Varun Johari), 63, Om Nivas, Masjid Wali Gali, 22 Godam, Jaipur vs. ACIT, Circle-2, Jaipur

In the result, appeal of the assessee is allowed

ITA 241/JPR/2022[2017-18]Status: DisposedITAT Jaipur04 May 2023AY 2017-18

Bench: HON’BLE SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Ms Monisha Choudhary (Addl.CIT)
Section 115BSection 133ASection 143(1)Section 69

that the revenue authorities have not disputed the fact that the assessee’s only source of income is from Dal &Basen Mill. No other incriminating material or document was found during the course of survey which could indicate that the assessee has any other source of income. It can thus ... that the revenue authorities have not disputed the fact that the assessee’s only source of income is from Dal &Basen Mill. No other incriminating material or document was found during the course of survey which could indicate that the assessee has 15 Late Shri Vijay Kumar Johari, Jaipur

Nirmal Uppal, Faridabad vs. DCIT, Central Circle-7, New Delhi

Appeal is allowed

ITA 1955/DEL/2022[2016-17]Status: HeardITAT Delhi03 May 2023AY 2016-17

Bench: Sh. N.K.Billaiya & Sh.Anubhav Sharmaita No. 1954/Del/2022, A.Y. 2016-17 Ita No. 1955/Del/2022, A.Y. 2016-17 Smt. Nirmal Uppal Vs. Dcit, House No. 25, Sector-28, Central Circle-7 Faridabad New Delhi Pan : Aaqpu3784P

Section 132(4)Section 153Section 271Section 271(1)(c)Section 68Section 69C

facts in brief are that the search and seizure operation was conducted in the Jindal Bullion Ltd. (JBL) Group on 05.01.2017 and from the incriminating material recovered in the form of data it was allegedly found that it is systematically engaged in cash transactions with a number of entities

Nirmal Uppal, Faridabad vs. DCIT, Central Circle-7, New Delhi

Appeal is allowed

ITA 1954/DEL/2022[2016-17]Status: HeardITAT Delhi03 May 2023AY 2016-17

Bench: Sh. N.K.Billaiya & Sh.Anubhav Sharmaita No. 1954/Del/2022, A.Y. 2016-17 Ita No. 1955/Del/2022, A.Y. 2016-17 Smt. Nirmal Uppal Vs. Dcit, House No. 25, Sector-28, Central Circle-7 Faridabad New Delhi Pan : Aaqpu3784P

Section 132(4)Section 153Section 271Section 271(1)(c)Section 68Section 69C

facts in brief are that the search and seizure operation was conducted in the Jindal Bullion Ltd. (JBL) Group on 05.01.2017 and from the incriminating material recovered in the form of data it was allegedly found that it is systematically engaged in cash transactions with a number of entities

DCIT Central Circle- 8, New Delhi vs. Vatika Limited, Gurgaon

ITA 623/DEL/2020[2017-18]Status: DisposedITAT Delhi03 May 2023AY 2017-18

Bench: Sh. N.K.Billaiya & Sh.Anubhav Sharmaita No. 623/Del/2020, A.Y. 2017-18 Dcit Vs. M/S. Vatika Limited 4Th Floor, Central Circle-8 New Delhi Vatika Triangle, M.G.Road, Sushant Lok-I, Block-A, Gurgaon, Haryana-122002 Pan : Aabcv5647G

Section 132(4)Section 142(1)Section 143(2)Section 143(3)

facts in deleting the addition of Rs. 34,76,00,000/- even though the same had been made on the basis of incriminating material discovered during the search at the assessee’s premises. 2. The appellant craves leave to add, alter or amend any/ all of the grounds of appeal ... record. 4. Ld. DR supported the findings of Ld. AO and submitted that Ld. AO had rightly taken into consideration the statements and incriminating material. It was submitted that addition is on account of undisclosed profits and retrun of higher revenue is of no consequence. 5. On behalf

Three C Universal Developers Pvt. Ltd., New Delhi vs. ACIT, Central Circle- 6, New Delhi

In the result, all the four appeals of the assessee for AYs 2010-11,

ITA 7582/DEL/2018[2014-15]Status: DisposedITAT Delhi01 May 2023AY 2014-15

Bench: Dr. Brr Kumar & Ms. Astha Chandra

For Appellant: NoneFor Respondent: Shri H.K. Chaudhary, CIT-DR
Section 132Section 142(1)Section 153ASection 234A

r.w.s. 143(3) of I.T. Act since the assessment for the year under consideration stood competed prior to the date of search and no incriminating material relating to alleged bogus purchases was found during such search. 2. That the Ld. CIT(A) has erred both in law and on facts ... alleged bogus purchases of Rs. 12,94,34,506/- (wrongly taken as Rs. 12,94,75,010/- by CIT(A) because no incriminating material concerning such addition was found during the course of search and further no assessment for such year was pending on the date of search. 3. That

Three C Universal Developers Pvt. Ltd., New Delhi vs. ACIT, Central Circle- 6, New Delhi

In the result, all the four appeals of the assessee for AYs 2010-11,

ITA 7581/DEL/2018[2013-14]Status: DisposedITAT Delhi01 May 2023AY 2013-14

Bench: Dr. Brr Kumar & Ms. Astha Chandra

For Appellant: NoneFor Respondent: Shri H.K. Chaudhary, CIT-DR
Section 132Section 142(1)Section 153ASection 234A

r.w.s. 143(3) of I.T. Act since the assessment for the year under consideration stood competed prior to the date of search and no incriminating material relating to alleged bogus purchases was found during such search. 2. That the Ld. CIT(A) has erred both in law and on facts ... alleged bogus purchases of Rs. 12,94,34,506/- (wrongly taken as Rs. 12,94,75,010/- by CIT(A) because no incriminating material concerning such addition was found during the course of search and further no assessment for such year was pending on the date of search. 3. That

Three C Universal Developers Pvt. Ltd., New Delhi vs. ACIT, Central Circle- 6, New Delhi

In the result, all the four appeals of the assessee for AYs 2010-11,

ITA 7580/DEL/2018[2011-12]Status: DisposedITAT Delhi01 May 2023AY 2011-12

Bench: Dr. Brr Kumar & Ms. Astha Chandra

For Appellant: NoneFor Respondent: Shri H.K. Chaudhary, CIT-DR
Section 132Section 142(1)Section 153ASection 234A

r.w.s. 143(3) of I.T. Act since the assessment for the year under consideration stood competed prior to the date of search and no incriminating material relating to alleged bogus purchases was found during such search. 2. That the Ld. CIT(A) has erred both in law and on facts ... alleged bogus purchases of Rs. 12,94,34,506/- (wrongly taken as Rs. 12,94,75,010/- by CIT(A) because no incriminating material concerning such addition was found during the course of search and further no assessment for such year was pending on the date of search. 3. That

Three C Universal Developers Pvt. Ltd., New Delhi vs. ACIT, Central Circle- 6, New Delhi

In the result, all the four appeals of the assessee for AYs 2010-11,

ITA 7579/DEL/2018[2010-11]Status: DisposedITAT Delhi01 May 2023AY 2010-11

Bench: Dr. Brr Kumar & Ms. Astha Chandra

For Appellant: NoneFor Respondent: Shri H.K. Chaudhary, CIT-DR
Section 132Section 142(1)Section 153ASection 234A

r.w.s. 143(3) of I.T. Act since the assessment for the year under consideration stood competed prior to the date of search and no incriminating material relating to alleged bogus purchases was found during such search. 2. That the Ld. CIT(A) has erred both in law and on facts ... alleged bogus purchases of Rs. 12,94,34,506/- (wrongly taken as Rs. 12,94,75,010/- by CIT(A) because no incriminating material concerning such addition was found during the course of search and further no assessment for such year was pending on the date of search. 3. That

ACIT Central Circle-2(1), Mumbai vs. M/S. G Nine Modular Pvt. Ltd., Mumbai

In the result, all the four appeals of the Revenue are In the result, all the four appeals of the Revenue are In the result, all the four appeals of the Revenue are dismissed

ITA 3214/MUM/2022[2017-18]Status: DisposedITAT Mumbai28 Apr 2023AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale ()

For Appellant: Mr. Naresh Jain, ARFor Respondent: Dr. Kishor Dhule, CIT-DR

Mumbai is right in holding that in holding that no incriminating material was found to sustain addition. no incriminating material was found to sustain addition. no incriminating material was found to sustain addition. 2. Whether on the facts and circumstances of the case and Whether on the facts and circumstances ... made in the made in the assessment assessment order onl order only y on on the ground the ground that no that no incriminating material was found to sustain the addition incriminating material was found to sustain the addition incriminating material was found to sustain the addition without without appreciating

ACIT Central Circle-2(1), Mumbai vs. M/S. G Nine Modular Pvt. Ltd., Mumbai

In the result, all the four appeals of the Revenue are In the result, all the four appeals of the Revenue are In the result, all the four appeals of the Revenue are dismissed

ITA 3213/MUM/2022[2016-17]Status: DisposedITAT Mumbai28 Apr 2023AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale ()

For Appellant: Mr. Naresh Jain, ARFor Respondent: Dr. Kishor Dhule, CIT-DR

Mumbai is right in holding that in holding that no incriminating material was found to sustain addition. no incriminating material was found to sustain addition. no incriminating material was found to sustain addition. 2. Whether on the facts and circumstances of the case and Whether on the facts and circumstances ... made in the made in the assessment assessment order onl order only y on on the ground the ground that no that no incriminating material was found to sustain the addition incriminating material was found to sustain the addition incriminating material was found to sustain the addition without without appreciating

ACIT Central Circle-2(1), Mumbai vs. M/S. G Nine Modular Pvt. Ltd., Mumbai

In the result, all the four appeals of the Revenue are In the result, all the four appeals of the Revenue are In the result, all the four appeals of the Revenue are dismissed

ITA 3212/MUM/2022[2015-16]Status: DisposedITAT Mumbai28 Apr 2023AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale ()

For Appellant: Mr. Naresh Jain, ARFor Respondent: Dr. Kishor Dhule, CIT-DR

Mumbai is right in holding that in holding that no incriminating material was found to sustain addition. no incriminating material was found to sustain addition. no incriminating material was found to sustain addition. 2. Whether on the facts and circumstances of the case and Whether on the facts and circumstances ... made in the made in the assessment assessment order onl order only y on on the ground the ground that no that no incriminating material was found to sustain the addition incriminating material was found to sustain the addition incriminating material was found to sustain the addition without without appreciating

DCIT, CC-8, New Delhi vs. Bjn Holdings Ltd. (Dissolved Company Through Its Successor Bjn Holding (I) Ltd.), Delhi

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

ITA 46/DEL/2022[2010-11]Status: DisposedITAT Delhi28 Apr 2023AY 2010-11

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Pradeep Dinodia, CAFor Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 132Section 142(1)Section 143(2)Section 143CSection 153CSection 273A

where the assessment/s for the year/s subsequent to the year of the search would have to made u/s 153C (where there would be not incriminating material) and some of the six assessment years prior to the year of the search would be left out, thereby frustrating the scheme of assessment

DCIT, CC-8, New Delhi vs. Bjn Holdings Ltd. (Dissolved Company Through Its Successor Bjn Holding (I) Ltd.), Delhi

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

ITA 45/DEL/2022[2009-10]Status: DisposedITAT Delhi28 Apr 2023AY 2009-10

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Pradeep Dinodia, CAFor Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 132Section 142(1)Section 143(2)Section 143CSection 153CSection 273A

where the assessment/s for the year/s subsequent to the year of the search would have to made u/s 153C (where there would be not incriminating material) and some of the six assessment years prior to the year of the search would be left out, thereby frustrating the scheme of assessment

DCIT, CC-8, New Delhi vs. Bjn Holdings Ltd. (Dissolved Company Through Its Successor Bjn Holding (I) Ltd.), Delhi

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

ITA 44/DEL/2022[2008-09]Status: DisposedITAT Delhi28 Apr 2023AY 2008-09

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Pradeep Dinodia, CAFor Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 132Section 142(1)Section 143(2)Section 143CSection 153CSection 273A

where the assessment/s for the year/s subsequent to the year of the search would have to made u/s 153C (where there would be not incriminating material) and some of the six assessment years prior to the year of the search would be left out, thereby frustrating the scheme of assessment