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“seized material”

Search & SeizureSection 153ASection 153A12,214 judgments

The decision most relied on for seized material is Pr. CIT v. Abhisar Buildwell (P.) Ltd. (149 Taxmann.com 399), cited in 2,379 judgments on BharatTax.

Leading authorities on seized material

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

No income can be quantified or disallowance made under Section 153A of the Income-tax Act unless it is justified on the basis of material seized during the course of the search.

CIT v. Calcutta Knitwears
362 ITR 673 · 2014 · Supreme Court
528
citing judgments

For initiating proceedings under Section 153C, the Assessing Officer of the searched person must record a satisfaction that seized material pertains to a third party, and the Assessing Officer of that third party must also record satisfaction that the material has a nexus to undisclosed income.

ACIT v. Serajuddin & Co.
163 Taxmann.com 118 · 2024 · Supreme Court
500
citing judgments

Strict adherence to approval protocols under Section 153D, including those in the Departmental Manual of Office Procedure, is essential for search assessments. An assessment is invalid if the approving authority fails to apply its mind or consider all relevant seized material before granting approval.

CIT v. Murli Agro Products Ltd.
49 Taxmann.com 172 · 2014 · High Court
331
citing judgments

In assessments under Section 153A, additions for unabated assessment years are permissible only if based on seized or incriminating material discovered during the search.

ARN Infrastructure India Ltd. v. Asstt. CIT
394 ITR 569 · 2017 · High Court
282
citing judgments

For initiating proceedings under Section 153C, seized documents must be incriminating and specifically relate to the assessment years for which assessments are reopened. A document relevant only for one year cannot be used to reopen other assessment years without being incriminating for those years.

CIT v. Ashwani Gupta
322 ITR 396 · 2010 · High Court
262
citing judgments

Proceedings become fatal if principles of natural justice are violated, such as when seized material is not provided to the assessee or cross-examination of a person whose statement the Assessing Officer relies upon is denied.

CIT v. Jasjit Singh
155 Taxmann.com 155 · 2023 · Supreme Court
235
citing judgments

For assessments under Section 153C concerning a non-searched person, the relevant date for calculating the block of assessment years is the date on which the jurisdictional Assessing Officer of that person assumes possession of the seized material, not the date of the original search. This date determines the look-back period for reopening assessments under Section 153A read with 153C.

Saksham Commodities Ltd. v. Income Tax Officer
161 Taxmann.com 485 · 2024 · High Court
196
citing judgments

Recording satisfaction under Section 153C for initiating proceedings against a third person is not a mechanical exercise; it requires a finding that seized material has a direct bearing on the third person's income, and improper satisfaction vitiates the assessment. Abatement under the second proviso to Section 153A is an inevitable consequence of a search, irrespective of the Assessing Officer's opinion on the material's impact.

Judgments citing seized material

Bhagawati M Jain, Dombivali vs. Ward 3(1), Kalyan

In the result, appeal of the assessee is allowed

ITA 2408/MUM/2025[2018-2019]Status: DisposedITAT Mumbai10 Mar 2026AY 2018-2019

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2018-19 Bhagawati M Jain Income Tax Officer C-22, Bhanu Chs, Ward 3(1), Bhanu Nagar, Dombivali East, 2Nd Floor, Rani Mansion, Vs. Kalyan - 421201 Kalyan-Murbad Rd, Maharashtra Kalyan-Dombivali, Maharashtra, 421301 (Pan: Aatpj1123G) (Appellant) (Respondent) Present For: Assessee : Shri Viraj Mehta, Ca Revenue : Shri Aditya Rai, Sr. Dr Date Of Hearing : 22.12.2025 Date Of Pronouncement : 10.03.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2024-25/1073449956(1), Dated 19.02.2025, Passed Against The Assessment Order By Assessing Officer, National Faceless Assessment Centre, Delhi, U/S. 147 R.W.S.144B Of The Income- Tax Act (Hereinafter Referred To As The “Act”), Dated 26.02.2024, For Assessment Year 2018-19. 2. Grounds Taken By Assessee Are Reproduced As Under:

For Appellant: Shri Viraj Mehta, CAFor Respondent: Shri Aditya Rai, Sr. DR
Section 132Section 139(1)Section 147Section 148Section 148ASection 151Section 153CSection 69B

case of M/s. Bhagawati Developers and its group concerns on 15.10.2018. In the course of this search action and based upon the seized material and submissions made therein, it was noted that assessee had purchased a shop from one of the concerns of the said builder and made payment ... group concerns whose statement was recorded under oath during the search and survey action. By placing reliance on the said statement and seized material found during the course of search of the builder, ld. Assessing Officer 4 Bhagawati M Jain AY 2018-19 came to a conclusion that assessee

Accurate Buildcon, Rajkot vs. DCIT, CC-1, Rajkot

ITA 770/RJT/2024[2022-23]Status: DisposedITAT Rajkot09 Mar 2026AY 2022-23

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

assessee and ld DR for the Revenue and evidences on record. We note that assessing officer did not reach on right conclusion, based on seized material and the profit estimation sustained by the learned CIT(A), on “on money”, is on very higher side, and we note that both ... profit element embedded therein can be taxed; however, the rate of profit estimation depends on the facts of each case. We have examined the seized material and past records and noted that the past profit margin as per audited books of accounts and as per seized material is 7% (average

Accurate Buildcon, Rajkot vs. DCIT, CC-1, Rajkot

ITA 769/RJT/2024[2021-22]Status: DisposedITAT Rajkot09 Mar 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

assessee and ld DR for the Revenue and evidences on record. We note that assessing officer did not reach on right conclusion, based on seized material and the profit estimation sustained by the learned CIT(A), on “on money”, is on very higher side, and we note that both ... profit element embedded therein can be taxed; however, the rate of profit estimation depends on the facts of each case. We have examined the seized material and past records and noted that the past profit margin as per audited books of accounts and as per seized material is 7% (average

Accurate Buildcon, Rajkot vs. DCIT, CC-1, Rajkot

ITA 768/RJT/2024[2020-21]Status: DisposedITAT Rajkot09 Mar 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

assessee and ld DR for the Revenue and evidences on record. We note that assessing officer did not reach on right conclusion, based on seized material and the profit estimation sustained by the learned CIT(A), on “on money”, is on very higher side, and we note that both ... profit element embedded therein can be taxed; however, the rate of profit estimation depends on the facts of each case. We have examined the seized material and past records and noted that the past profit margin as per audited books of accounts and as per seized material is 7% (average

Accurate Buildcon, Rajkot vs. DCIT, CC-1, Rajkot

ITA 767/RJT/2024[2019-20]Status: DisposedITAT Rajkot09 Mar 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

assessee and ld DR for the Revenue and evidences on record. We note that assessing officer did not reach on right conclusion, based on seized material and the profit estimation sustained by the learned CIT(A), on “on money”, is on very higher side, and we note that both ... profit element embedded therein can be taxed; however, the rate of profit estimation depends on the facts of each case. We have examined the seized material and past records and noted that the past profit margin as per audited books of accounts and as per seized material is 7% (average

Accurate Buildcon, Rajkot vs. DCIT, CC-1, Rajkot

ITA 766/RJT/2024[2017-18]Status: DisposedITAT Rajkot09 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

assessee and ld DR for the Revenue and evidences on record. We note that assessing officer did not reach on right conclusion, based on seized material and the profit estimation sustained by the learned CIT(A), on “on money”, is on very higher side, and we note that both ... profit element embedded therein can be taxed; however, the rate of profit estimation depends on the facts of each case. We have examined the seized material and past records and noted that the past profit margin as per audited books of accounts and as per seized material is 7% (average

DCIT, Central Circle 1, Rajkot vs. Shri Jagjivan Ranchhodbhai Sakhiya, Rajkot

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

ITA 744/RJT/2024[2020-21]Status: DisposedITAT Rajkot09 Mar 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 142(1)Section 143(2)Section 147Section 148Section 151Section 69C

assessee within the meaning of section 69C r.w.s. 115BBE of the Act. 5. The transactions pertaining to the assessee have been gathered from the seized material during the search operation, a notice under section 148 of the Act has been issued on 25-08-2022 to the assessee after following ... objections raised by the assessee against initiation of proceedings u/s 148 of the Act have been disposed of and the images of original seized material pertaining to the assessee have been supplied and discussed in the notices issued u/s 142(1) of the Act from time to time. 6. That

DCIT, Central Circle 1, Rajkot vs. Jagjivan Ranchhodbhai Sakhiya, Rajkot

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

ITA 743/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 142(1)Section 143(2)Section 147Section 148Section 151Section 69C

assessee within the meaning of section 69C r.w.s. 115BBE of the Act. 5. The transactions pertaining to the assessee have been gathered from the seized material during the search operation, a notice under section 148 of the Act has been issued on 25-08-2022 to the assessee after following ... objections raised by the assessee against initiation of proceedings u/s 148 of the Act have been disposed of and the images of original seized material pertaining to the assessee have been supplied and discussed in the notices issued u/s 142(1) of the Act from time to time. 6. That

DCIT, Central Circle 1, Rajkot vs. Buildcon Associates, Rajkot

ITA 691/RJT/2024[2019-20]Status: DisposedITAT Rajkot09 Mar 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

I.T.A Nos. 506 to 508, 674 to 675 & 691/Rjt/2024 Buildcon Associates aforementioned transactions pertaining to the assessee have been gathered from the seized material during the search operation, therefore, a notice under section 148 of the Act has been issued on 23-03-2022, to the assessee after following ... seeking primary as well as further details from the assessee for carrying out the assessment. In view of natural justice, the images of original seized material pertaining to the assessee have been supplied and discussed in the notices issued u/s 142(1) of the Act. 6. The assessing officer observed

DCIT, Central Circle 1, Rajkot vs. Krishna Developers, Rajkot

ITA 688/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 143(3)Section 147Section 250

Business Park”. 5. During the assessment proceedings, details regarding unaccounted part of the aforementioned transactions, pertaining to the assessee have been gathered from the seized material during the search operation, therefore, a notice under section 148 of the Act has been issued on 25/08/2022, to the assessee after following ... seeking primary as well as further details from the assessee for carrying out the assessment. In view of natural justice, the images of original seized material pertaining to the assessee have been supplied and discussed in the notices issued u/s 142(1) of the Act. 6. The assessing officer noticed

DCIT, Central Circle 1, Rajkot vs. Buildcon Associates, Rajkot

ITA 675/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

I.T.A Nos. 506 to 508, 674 to 675 & 691/Rjt/2024 Buildcon Associates aforementioned transactions pertaining to the assessee have been gathered from the seized material during the search operation, therefore, a notice under section 148 of the Act has been issued on 23-03-2022, to the assessee after following ... seeking primary as well as further details from the assessee for carrying out the assessment. In view of natural justice, the images of original seized material pertaining to the assessee have been supplied and discussed in the notices issued u/s 142(1) of the Act. 6. The assessing officer observed

DCIT, Central Circle -1, Rajkot vs. Buildcon Associates, Rajkot

ITA 674/RJT/2024[2015-16]Status: DisposedITAT Rajkot09 Mar 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

I.T.A Nos. 506 to 508, 674 to 675 & 691/Rjt/2024 Buildcon Associates aforementioned transactions pertaining to the assessee have been gathered from the seized material during the search operation, therefore, a notice under section 148 of the Act has been issued on 23-03-2022, to the assessee after following ... seeking primary as well as further details from the assessee for carrying out the assessment. In view of natural justice, the images of original seized material pertaining to the assessee have been supplied and discussed in the notices issued u/s 142(1) of the Act. 6. The assessing officer observed

Krishna Developers, Rajkot vs. Deputy Commissioner of Income Tax, Central 1, Rajkot

ITA 544/RJT/2024[2019-20]Status: DisposedITAT Rajkot09 Mar 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 143(3)Section 147Section 250

Business Park”. 5. During the assessment proceedings, details regarding unaccounted part of the aforementioned transactions, pertaining to the assessee have been gathered from the seized material during the search operation, therefore, a notice under section 148 of the Act has been issued on 25/08/2022, to the assessee after following ... seeking primary as well as further details from the assessee for carrying out the assessment. In view of natural justice, the images of original seized material pertaining to the assessee have been supplied and discussed in the notices issued u/s 142(1) of the Act. 6. The assessing officer noticed

Krishna Developers, Rajkot vs. The Deputy Commissioner of Income Tax, Central-1, Rajkot

ITA 543/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 143(3)Section 147Section 250

Business Park”. 5. During the assessment proceedings, details regarding unaccounted part of the aforementioned transactions, pertaining to the assessee have been gathered from the seized material during the search operation, therefore, a notice under section 148 of the Act has been issued on 25/08/2022, to the assessee after following ... seeking primary as well as further details from the assessee for carrying out the assessment. In view of natural justice, the images of original seized material pertaining to the assessee have been supplied and discussed in the notices issued u/s 142(1) of the Act. 6. The assessing officer noticed

Buildcon Associates, Rajkot vs. Deputy Commissioner of Income Tax, Central - 1, Rajkot

ITA 508/RJT/2024[2020-21]Status: DisposedITAT Rajkot09 Mar 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

I.T.A Nos. 506 to 508, 674 to 675 & 691/Rjt/2024 Buildcon Associates aforementioned transactions pertaining to the assessee have been gathered from the seized material during the search operation, therefore, a notice under section 148 of the Act has been issued on 23-03-2022, to the assessee after following ... seeking primary as well as further details from the assessee for carrying out the assessment. In view of natural justice, the images of original seized material pertaining to the assessee have been supplied and discussed in the notices issued u/s 142(1) of the Act. 6. The assessing officer observed

Buildcon Associates, Rajkot vs. Deputy Commissioner of Income Tax, Central - 1, Rajkot

ITA 507/RJT/2024[2019-20]Status: DisposedITAT Rajkot09 Mar 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

I.T.A Nos. 506 to 508, 674 to 675 & 691/Rjt/2024 Buildcon Associates aforementioned transactions pertaining to the assessee have been gathered from the seized material during the search operation, therefore, a notice under section 148 of the Act has been issued on 23-03-2022, to the assessee after following ... seeking primary as well as further details from the assessee for carrying out the assessment. In view of natural justice, the images of original seized material pertaining to the assessee have been supplied and discussed in the notices issued u/s 142(1) of the Act. 6. The assessing officer observed

Buildcon Associates, Rajkot vs. Deputy Commissioner of Income Tax, Central -1, Rajkot

ITA 506/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

I.T.A Nos. 506 to 508, 674 to 675 & 691/Rjt/2024 Buildcon Associates aforementioned transactions pertaining to the assessee have been gathered from the seized material during the search operation, therefore, a notice under section 148 of the Act has been issued on 23-03-2022, to the assessee after following ... seeking primary as well as further details from the assessee for carrying out the assessment. In view of natural justice, the images of original seized material pertaining to the assessee have been supplied and discussed in the notices issued u/s 142(1) of the Act. 6. The assessing officer observed

Arvind Kumar Aggarwal, Ambala vs. DCIT, Central Circle-2, Chandigarh, Central Circle Chandigarh

ITA 445/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh09 Mar 2026AY 2016-17

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.343/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) & 2. आयकर अपील सं. / Ita No.344/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) & 3. आयकर अपील सं. / Ita No.345/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2014-15) & 4. आयकर अपील सं. / Ita No.445/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2016-17) & 5. आयकर अपील सं. / Ita No.346/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) Shri Arvind Kumar Aggarwal Dcit (Central-2) बनाम/ C/O Sh. Rajiv Goel & Associates Cr Building, Sector 17 179, Bank Road Chandigarh – 160017 Vs. Ambala Cantt. (Haryana) -133001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Abfpa-8832-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Rajiv Goel & Sh. Dhruv Goel (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Meenkashi Vohra (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 10-12-2025 घोषणाकीतारीख /Date Of Pronouncement : 09-03-2026

For Appellant: Sh. Rajiv Goel & Sh. Dhruv Goel (CA) – Ld. ARsFor Respondent: Smt. Meenkashi Vohra (CIT) - Ld. DR (Virtual)
Section 132Section 139(1)Section 143(3)Section 153ASection 153A(1)(b)Section 153DSection 69

Micky Ji. However, during post-search in statement u/s 131, the assessee retracted his statements and stated that the pages of the seized material was only estimation of land development projects prepared by him which was planned to be developed near MDSD College Road in Ambala city and Ghale Road

Rohit Aggarwal, Ambala vs. DCIT, Central Circle-2, Chandigarh, Central Circle

The appeal stands partly allowed

ITA 428/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh09 Mar 2026AY 2016-17

Bench: SHRI LALIET KUMAR (Judicial Member), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Sh. Rajiv Goel & Sh. Dhruv Goel (CA) – Ld. ARsFor Respondent: Smt. Meenkashi Vohra (CIT) - Ld. DR (Virtual)
Section 131Section 153A(1)(b)

Project-1 whereas entries at Pages Nos. 26 to 31 are with respect to Project-2. During assessment proceeding, the assessee stated that the seized material was merely estimation of land development projects. It was pointed out that there was no plotting on land on the entire stretch of both ... stressed the need for exercising caution and for bringing on record relevant, reliable and cogent evidence to corroborate the entries found noted in the seized material. The court, thus, concluded that loose sheets / papers are not admissible as evidence. Further, even if same are held to be admissible, additions could

Rohit Aggarwal, Ambala vs. DCIT, Central Circle-2, Chandigarh, Central Circle Chandigarh

The appeal stands partly allowed

ITA 427/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh09 Mar 2026AY 2015-16

Bench: SHRI LALIET KUMAR (Judicial Member), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Sh. Rajiv Goel & Sh. Dhruv Goel (CA) – Ld. ARsFor Respondent: Smt. Meenkashi Vohra (CIT) - Ld. DR (Virtual)
Section 131Section 153A(1)(b)

Project-1 whereas entries at Pages Nos. 26 to 31 are with respect to Project-2. During assessment proceeding, the assessee stated that the seized material was merely estimation of land development projects. It was pointed out that there was no plotting on land on the entire stretch of both ... stressed the need for exercising caution and for bringing on record relevant, reliable and cogent evidence to corroborate the entries found noted in the seized material. The court, thus, concluded that loose sheets / papers are not admissible as evidence. Further, even if same are held to be admissible, additions could