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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

M/S. Tatva Renewable Power Pvt. Ltd., Hyderabad vs. ACIT, Central Circle-1(2), Chennai

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

ITA 1771/CHNY/2025[2016-17]Status: DisposedITAT Chennai14 Nov 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1769/Chny/2025 िनधा"रण वष"/Assessment Year: 2014-15 M/S. Ojas Plantations Private Limited, Vs. The Assistant Commissioner Of No. 51, Park View Street, Near Gandhi Income Tax/Dc, Road, Alwarthirunagar, Tiruvallur, Central Circle 1(2), Chennai 600 087. Chennai. [Pan:Aabco1853F] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1770/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Pippala Leaf Developers Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aahcp2411J] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1771/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Tatva Renewable Power Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aaect8340D] (अपीलाथ"/Appellant) (""थ"/Respondent)

Section 132Section 153A

during the course of search. He refers to assessment order and submits there was no search in the case of the assessee and no incriminating material was referred in the assessment order. He argued vehemently that the assessment under section 153A of the Act made in the hands ... assessee without there being search and incriminating material found or seized in the case of the assessee, is not justified. He 7 I.T.A. Nos.1769 to 1772 & 1793/Chny/25 refers to the decision of the Hon’ble High Court of Gujarat in the case of CIT v. Ramesh D. Patel reported

M/S. Pippala Leaf Developers Pvt. Ltd., Hyderabad vs. ACIT, Central Circle-1(2), Chennai

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

ITA 1770/CHNY/2025[2016-17]Status: DisposedITAT Chennai14 Nov 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1769/Chny/2025 िनधा"रण वष"/Assessment Year: 2014-15 M/S. Ojas Plantations Private Limited, Vs. The Assistant Commissioner Of No. 51, Park View Street, Near Gandhi Income Tax/Dc, Road, Alwarthirunagar, Tiruvallur, Central Circle 1(2), Chennai 600 087. Chennai. [Pan:Aabco1853F] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1770/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Pippala Leaf Developers Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aahcp2411J] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1771/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Tatva Renewable Power Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aaect8340D] (अपीलाथ"/Appellant) (""थ"/Respondent)

Section 132Section 153A

during the course of search. He refers to assessment order and submits there was no search in the case of the assessee and no incriminating material was referred in the assessment order. He argued vehemently that the assessment under section 153A of the Act made in the hands ... assessee without there being search and incriminating material found or seized in the case of the assessee, is not justified. He 7 I.T.A. Nos.1769 to 1772 & 1793/Chny/25 refers to the decision of the Hon’ble High Court of Gujarat in the case of CIT v. Ramesh D. Patel reported

M/S. Ojas Plantations Pvt. Ltd., Chennai vs. ACIT, Central Circle-1(2), Chennai

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

ITA 1769/CHNY/2025[2014-15]Status: DisposedITAT Chennai14 Nov 2025AY 2014-15

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1769/Chny/2025 िनधा"रण वष"/Assessment Year: 2014-15 M/S. Ojas Plantations Private Limited, Vs. The Assistant Commissioner Of No. 51, Park View Street, Near Gandhi Income Tax/Dc, Road, Alwarthirunagar, Tiruvallur, Central Circle 1(2), Chennai 600 087. Chennai. [Pan:Aabco1853F] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1770/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Pippala Leaf Developers Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aahcp2411J] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1771/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Tatva Renewable Power Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aaect8340D] (अपीलाथ"/Appellant) (""थ"/Respondent)

Section 132Section 153A

during the course of search. He refers to assessment order and submits there was no search in the case of the assessee and no incriminating material was referred in the assessment order. He argued vehemently that the assessment under section 153A of the Act made in the hands ... assessee without there being search and incriminating material found or seized in the case of the assessee, is not justified. He 7 I.T.A. Nos.1769 to 1772 & 1793/Chny/25 refers to the decision of the Hon’ble High Court of Gujarat in the case of CIT v. Ramesh D. Patel reported

Srs Panchratan Diamonds Pvt Ltd, Delhi vs. DCIT Central Circle-7, New Delhi

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

ITA 219/DEL/2023[2016-17]Status: DisposedITAT Delhi14 Nov 2025AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Arijit Chakraborty, AdvFor Respondent: Shri Mahesh Kumar, CIT (DR)
Section 132Section 143(2)Section 153ASection 153C

This too appears to suggest that while the notice could be composite and based on a common satisfaction note which encapsulates the incriminating material pertaining to the AYs' in question, it is only returns which must and mandatorily be filed separately. 25. Regard must be had to the indubitable fact ... initiation of action and which would enable us to evaluate whether an opinion has been validly formed. As long as it rests on incriminating material which pertains to the AYs' in question, the same would qualify the requirement of Section 153C. We deem it apposite to observe that while

Srs Panchratan Diamonds Pvt Ltd., New Delhi vs. DCIT Central Circle-7, New Delhi

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

ITA 218/DEL/2023[2015-16]Status: DisposedITAT Delhi14 Nov 2025AY 2015-16

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Arijit Chakraborty, AdvFor Respondent: Shri Mahesh Kumar, CIT (DR)
Section 132Section 143(2)Section 153ASection 153C

This too appears to suggest that while the notice could be composite and based on a common satisfaction note which encapsulates the incriminating material pertaining to the AYs' in question, it is only returns which must and mandatorily be filed separately. 25. Regard must be had to the indubitable fact ... initiation of action and which would enable us to evaluate whether an opinion has been validly formed. As long as it rests on incriminating material which pertains to the AYs' in question, the same would qualify the requirement of Section 153C. We deem it apposite to observe that while

Sanjeev Sharma, New Delh vs. ACIT, Central Circle-16, New Delhi

The appeals of the assessee are allowed

ITA 2046/DEL/2022[2013-14]Status: DisposedITAT Delhi14 Nov 2025AY 2013-14

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year:2013-14]

Section 132Section 153ASection 153CSection 69Section 69A

when the case of the assessee is covered under the provision of section 153 of the Act and if reliance is placed on the incriminating material found during the course of search of third-party, then provision of section 153C of the Act would be applicable and have

Sanjeev Sharma, New Delhi vs. ACIT Central Circale-16, New Delhi

The appeals of the assessee are allowed

ITA 1979/DEL/2022[2017-18]Status: DisposedITAT Delhi14 Nov 2025AY 2017-18

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year:2013-14]

Section 132Section 153ASection 153CSection 69Section 69A

when the case of the assessee is covered under the provision of section 153 of the Act and if reliance is placed on the incriminating material found during the course of search of third-party, then provision of section 153C of the Act would be applicable and have

Sanjeev Sharma, New Delhi vs. ACIT, Central Circle-16, New Delhi

The appeals of the assessee are allowed

ITA 1978/DEL/2022[2016-17]Status: DisposedITAT Delhi14 Nov 2025AY 2016-17

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year:2013-14]

Section 132Section 153ASection 153CSection 69Section 69A

when the case of the assessee is covered under the provision of section 153 of the Act and if reliance is placed on the incriminating material found during the course of search of third-party, then provision of section 153C of the Act would be applicable and have

Sanjeev Sharma, New Delhi vs. ACIT Central Circle-16, New Delhi

The appeals of the assessee are allowed

ITA 1977/DEL/2022[2015-16]Status: DisposedITAT Delhi14 Nov 2025AY 2015-16

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year:2013-14]

Section 132Section 153ASection 153CSection 69Section 69A

when the case of the assessee is covered under the provision of section 153 of the Act and if reliance is placed on the incriminating material found during the course of search of third-party, then provision of section 153C of the Act would be applicable and have

Sanjeev Sharma, New Delhi vs. ACIT Central Circle-16, New Delhi

The appeals of the assessee are allowed

ITA 1976/DEL/2022[2014-15]Status: DisposedITAT Delhi14 Nov 2025AY 2014-15

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year:2013-14]

Section 132Section 153ASection 153CSection 69Section 69A

when the case of the assessee is covered under the provision of section 153 of the Act and if reliance is placed on the incriminating material found during the course of search of third-party, then provision of section 153C of the Act would be applicable and have

Rohit Jain, Tonk vs. Income Tax Officer, Ward, Tonk

In the result, the appeals of the assessee are allowed

ITA 760/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Nov 2025AY 2015-16
For Appellant: Shri Jaideep Malik, AdvocateFor Respondent: Mrs. Alka Gauta, CIT-DR
Section 153CSection 69C

addition of Rs.6,95,634/- on account of the alleged un-explained expenditure u/s 69C in the purchase of Truck in absence of any incriminating material if any found and seized during the course of search proceedings no valid addition could be made u/s 153C of the act in absence ... incriminating material as held consistently by the judicial authorities. Thus, the addition so made is factually and legally incorrect and thus the same deserve to be deleted. 3. On the facts and in the circumstances of the case, Id. AO has legally and factually erred in treating the instruments

Rohit Jain, Tonk vs. Income Tax Officer - Ward, Tonk

In the result, the appeals of the assessee are allowed

ITA 759/JPR/2025[2012-13]Status: DisposedITAT Jaipur13 Nov 2025AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Jaideep Malik, AdvocateFor Respondent: Mrs. Alka Gauta, CIT-DR
Section 153CSection 69C

account of the alleged un-explained expenditure u/s 69C in the purchase of Truck in absence of any incriminating material if any found and seized during the course of search proceedings no valid addition could be made u/s 153C of the act in absence of any incriminating material as held ... legally and factually erred in treating the instruments of the property dealings as found and seized during the course of search operations as incriminating material. In fact the instruments so found were duly accounted for and reflected in the books of appellant and were not incriminating material as incorrectly observed

Mohit Jain, Tonk vs. Income Tax Officer, Tonk

In the result, the appeals of the assessee are allowed

ITA 758/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Nov 2025AY 2015-16
For Appellant: Shri Jaideep Malik, AdvocateFor Respondent: Mrs. Alka Gauta, CIT-DR
Section 153CSection 69C

addition of Rs.6,95,634/- on account of the alleged un-explained expenditure u/s 69C in the purchase of Truck in absence of any incriminating material if any found and seized during the course of search proceedings no valid addition could be made u/s 153C of the act in absence ... incriminating material as held consistently by the judicial authorities. Thus, the addition so made is factually and legally incorrect and thus the same deserve to be deleted. 3. On the facts and in the circumstances of the case, Id. AO has legally and factually erred in treating the instruments

Mohit Jain, Tonk vs. Income Tax Officer, Tonk

In the result, the appeals of the assessee are allowed

ITA 757/JPR/2025[2013-14]Status: DisposedITAT Jaipur13 Nov 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Jaideep Malik, AdvocateFor Respondent: Mrs. Alka Gauta, CIT-DR
Section 153CSection 69C

account of the alleged un-explained expenditure u/s 69C in the purchase of Truck in absence of any incriminating material if any found and seized during the course of search proceedings no valid addition could be made u/s 153C of the act in absence of any incriminating material as held ... legally and factually erred in treating the instruments of the property dealings as found and seized during the course of search operations as incriminating material. In fact the instruments so found were duly accounted for and reflected in the books of appellant and were not incriminating material as incorrectly observed

Shubham Jain, Tonk, Rajasthan vs. Income Tax Officer, Ward - Tonk, Maha Devali, Tonk

In the result, the appeals of the assessee are allowed

ITA 756/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Nov 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Jaideep Malik, AdvocateFor Respondent: Mrs. Alka Gauta, CIT-DR
Section 153CSection 69C

account of the alleged un-explained expenditure u/s 69C in the purchase of Truck in absence of any incriminating material if any found and seized during the course of search proceedings no valid addition could be made u/s 153C of the act in absence of any incriminating material as held ... legally and factually erred in treating the instruments of the property dealings as found and seized during the course of search operations as incriminating material. In fact the instruments so found were duly accounted for and reflected in the books of appellant and were not incriminating material as incorrectly observed

Samandeep Kaur, Irs, Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Trimurti Homes Pvt. Ltd., Ludhiana

Appeals stand dismissed

ITA 1035/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh13 Nov 2025AY 2019-20

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No. 1034/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2018-19) & 2. आयकर अपील सं./ Ita No. 1035/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2019-20) Dcit-Central Circle-1 M/S Trimurti Homes Pvt. Ltd. बनाम/ Ludhiana – 141001 Hb-1199, Phase-1, Urban Estate Vs. Dugri, Ludhiana-141002 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aadct-6759-P (अपीलाथ"/Appellant) : (""थ" / Respondent) & 3. Co. No. 29/Chandi/2025 [In Ita No. 1034/Chandi/2024] (िनधा"रण वष" / Assessment Year: 2018-19) & 4. Co. No. 30/Chandi/2025 [In Ita No. 1035/Chandi/2024] (िनधा"रण वष" / Assessment Year: 2019-20) M/S Trimurti Homes Pvt. Ltd. Dcit-Central Circle-1 बनाम/ Hb-1199, Phase-1, Urban Estate Ludhiana-141001 Vs. Dugri, Ludhiana-141002 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aadct-6759-P (Cross-Objector) (Respondent) : Revenue By : Smt. Kusum Bansal (Cit) – Ld. Dr (Virtual) Assessee By : Shri Ashwani Kumar (Ca) A/W Shri Aditya Kumar (Ca) & Ms. Deepali Aggarwal (Ca) - Ld. Ars सुनवाईकीतारीख/Date Of Hearing : 15-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 13/11/2025

For Appellant: Shri Ashwani Kumar (CA) a/w Shri Aditya KumarFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR (Virtual)
Section 132Section 132(4)Section 142(1)Section 143(2)Section 147Section 148

reasons to believe’ since there was no document to substantiate the impugned addition in the hands of the assessee. Another argument was that no incriminating material was found either from the premises of the assessee or from the premises of the third-party which would indicate exchange of higher sale ... findings and Adjudication 4. It emerges that the assessee was searched along with various other entities. It is undisputed fact that no incriminating material or document, whatsoever, has been found from the possession / premises of the assessee which would indicate exchange of higher sale consideration between the assessee and HBPL

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Trimurti Homes Pvt. Ltd., Ludhiana

Appeals stand dismissed

ITA 1034/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh13 Nov 2025AY 2018-19

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No. 1034/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2018-19) & 2. आयकर अपील सं./ Ita No. 1035/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2019-20) Dcit-Central Circle-1 M/S Trimurti Homes Pvt. Ltd. बनाम/ Ludhiana – 141001 Hb-1199, Phase-1, Urban Estate Vs. Dugri, Ludhiana-141002 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aadct-6759-P (अपीलाथ"/Appellant) : (""थ" / Respondent) & 3. Co. No. 29/Chandi/2025 [In Ita No. 1034/Chandi/2024] (िनधा"रण वष" / Assessment Year: 2018-19) & 4. Co. No. 30/Chandi/2025 [In Ita No. 1035/Chandi/2024] (िनधा"रण वष" / Assessment Year: 2019-20) M/S Trimurti Homes Pvt. Ltd. Dcit-Central Circle-1 बनाम/ Hb-1199, Phase-1, Urban Estate Ludhiana-141001 Vs. Dugri, Ludhiana-141002 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aadct-6759-P (Cross-Objector) (Respondent) : Revenue By : Smt. Kusum Bansal (Cit) – Ld. Dr (Virtual) Assessee By : Shri Ashwani Kumar (Ca) A/W Shri Aditya Kumar (Ca) & Ms. Deepali Aggarwal (Ca) - Ld. Ars सुनवाईकीतारीख/Date Of Hearing : 15-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 13/11/2025

For Appellant: Shri Ashwani Kumar (CA) a/w Shri Aditya KumarFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR (Virtual)
Section 132Section 132(4)Section 142(1)Section 143(2)Section 147Section 148

reasons to believe’ since there was no document to substantiate the impugned addition in the hands of the assessee. Another argument was that no incriminating material was found either from the premises of the assessee or from the premises of the third-party which would indicate exchange of higher sale ... findings and Adjudication 4. It emerges that the assessee was searched along with various other entities. It is undisputed fact that no incriminating material or document, whatsoever, has been found from the possession / premises of the assessee which would indicate exchange of higher sale consideration between the assessee and HBPL

Ujjal Sinha, Kolkata vs. DCIT, Central Circle 4(1), Kolkata

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

ITA 1935/KOL/2025[2012-2013]Status: DisposedITAT Kolkata13 Nov 2025AY 2012-2013

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1931, 1932, 1934 & 1935/Kol/2025 Assessment Years: 2008-09, 2009-10, 2012-13 & 2012-13 Ujjal Sinha……………….……..……………………….……….……….……Appellant 57/3, Ballygunge Circular Road, Ballygunge S.O, Kol- 700019.. [Pan: Aeips4499F] Vs. Dcit, Central Circle-4(1), Kolkata….……..……………….....……...…..…..Respondent Appearances By: Shri S. K. Tulsiyan, Advocate & Lata Goyal, Ca, Appeared On Behalf Of The Appellant. Shri Sanat Kr. Raha, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 28, 2025 Date Of Pronouncing The Order : November 13, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Dated 05.08.25, 05.08.25, 04.08.25 & 04.08.25 Of The National Faceless Appeal Centre [Hereinafter Referred To As The “Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”] Confirming Penalty U/S 271(1)(C) Of The Act Levied By The Assessing Officer. Since The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order.

Section 139(1)Section 143(2)Section 153ASection 24Section 250Section 271(1)(c)Section 274

income of Rs.11,20,550/-. Thereafter, a search and seizure operation was conducted on 24.01.2012 in the residential premises of the assessee wherein no incriminating material was found and/or seized. Consequent upon such search and seizure action, notice u/s. 153A of the Act dated 01/10/2013 was issued and in response

Ujjal Sinha, Kolkata vs. DCIT, Central Circle 4(1), Kolkata

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

ITA 1934/KOL/2025[2012-2013]Status: DisposedITAT Kolkata13 Nov 2025AY 2012-2013

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1931, 1932, 1934 & 1935/Kol/2025 Assessment Years: 2008-09, 2009-10, 2012-13 & 2012-13 Ujjal Sinha……………….……..……………………….……….……….……Appellant 57/3, Ballygunge Circular Road, Ballygunge S.O, Kol- 700019.. [Pan: Aeips4499F] Vs. Dcit, Central Circle-4(1), Kolkata….……..……………….....……...…..…..Respondent Appearances By: Shri S. K. Tulsiyan, Advocate & Lata Goyal, Ca, Appeared On Behalf Of The Appellant. Shri Sanat Kr. Raha, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 28, 2025 Date Of Pronouncing The Order : November 13, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Dated 05.08.25, 05.08.25, 04.08.25 & 04.08.25 Of The National Faceless Appeal Centre [Hereinafter Referred To As The “Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”] Confirming Penalty U/S 271(1)(C) Of The Act Levied By The Assessing Officer. Since The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order.

Section 139(1)Section 143(2)Section 153ASection 24Section 250Section 271(1)(c)Section 274

income of Rs.11,20,550/-. Thereafter, a search and seizure operation was conducted on 24.01.2012 in the residential premises of the assessee wherein no incriminating material was found and/or seized. Consequent upon such search and seizure action, notice u/s. 153A of the Act dated 01/10/2013 was issued and in response

Ujjal Sinha, Kolkata vs. DCIT, Central Circle 4(1), Kolkata

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

ITA 1933/KOL/2025[2011-2012]Status: DisposedITAT Kolkata13 Nov 2025AY 2011-2012

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2011-12 Ujjal Sinha……..…………………..………………….……….……….……Appellant 57/3, Ballygunge Circular Road, Ballygunge S.O, Kolkata 19. [Pan: Aeips4499F] Vs. Dcit, Central Circle-4(1), Kolkata……………………….....……...…..…..Respondent Appearances By: Shri S. K. Tulsiyan, Advocate & Lata Goyal, Ca, Appeared On Behalf Of The Appellant. Shri Sanat Kr. Raha, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 28, 2025 Date Of Pronouncing The Order : November 13, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 05.08.2025 Of The Cit (Appeals)-27, Kolkata [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2011–12. 2. Brief Facts Of The Case Are That The Assessee Had Filed His Return Of Income U/S.139(1) Of The Act For The A.Y. 2011-12 On 11/02/2012 Declaring A Total Income Of Rs.19,12,432/-. In The Instant Case, A Search & Seizure Operation Was Conducted On 24.01.2012 In The Residential Premises Of The Assessee Wherein No Incriminating Material Was Found. Thereafter. The Assessment Was Completed U/S 153A/143(3) Of The Act On 31/03/2014 Assessing The Total Income At Rs.92,12,430/- Wherein The Following Two Additions To The Total Income Were Made:

Section 139(1)Section 153ASection 24Section 250Section 271(1)(c)

instant case, a search and seizure operation was conducted on 24.01.2012 in the residential premises of the assessee wherein no incriminating material was found. Thereafter. the assessment was completed u/s 153A/143(3) of the Act on 31/03/2014 assessing the total income at Rs.92,12,430/- wherein the following two additions