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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

Professional Automotives Private Limited, Jammu vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 815/JPR/2025[2019-20]Status: DisposedITAT Jaipur23 Jul 2025AY 2019-20
For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

voucher was alleged as bogus by Id.AO nor any contrary evidence was brought on record either by making independent enquiry or out of seized material and unverified observations made by the Investigation team were simply relied upon, thus the disallowances so confirmed, deserves to be deleted ... Rajendra Singh.Immediately after conclusion of the search proceedings, the assessee company through its director applied for the copies of said statements along with other seized material which were supplied to them. On receipt of the copies of statements and after in-depth and minute examination thereof, it was observed that

Professional Automotives Private Limited, Jammu vs. Assisstant Commissioner of Income Tax Central Circle-1, Jaipur

In the result the appeal of the assessee in ITA no

ITA 814/JPR/2025[2018-19]Status: DisposedITAT Jaipur23 Jul 2025AY 2018-19
For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

voucher was alleged as bogus by Id.AO nor any contrary evidence was brought on record either by making independent enquiry or out of seized material and unverified observations made by the Investigation team were simply relied upon, thus the disallowances so confirmed, deserves to be deleted ... Rajendra Singh.Immediately after conclusion of the search proceedings, the assessee company through its director applied for the copies of said statements along with other seized material which were supplied to them. On receipt of the copies of statements and after in-depth and minute examination thereof, it was observed that

Professional Automotives Private Limited, Jammu vs. Assistant Commissioner of Income Tax, Central Circle-1, Jaipur

ITA 813/JPR/2025[2017-18]Status: DisposedITAT Jaipur23 Jul 2025AY 2017-18
For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 132(4)Section 143(3)Section 37(1)

voucher was alleged as bogus by ld.AO nor any contrary evidence was brought on record either by making independent enquiry or out of seized material and unverified observations made by the Investigation team were simply relied upon, thus the disallowances so confirmed, deserves to be deleted. 3. On the facts ... Rajendra Singh.Immediately after conclusion of the search proceedings, the assessee company through its director applied for the copies of said statements along with other seized material which were supplied to them. On receipt of the copies of statements and after in-depth and minute examination thereof, it was observed that

Professional Automotives Private Limited, Jammu vs. Assistant Commissioner of Income Tax, Central Circle-1, Jaipur

In the result the appeal of the assessee in ITA no

ITA 812/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

voucher was alleged as bogus by ld.AO nor any contrary evidence was brought on record either by making independent enquiry or out of seized material and unverified observations made by the Investigation team were simply relied upon, thus the disallowances so confirmed, deserves to be deleted. Professional Automotives Private Limited ... Rajendra Singh.Immediately after conclusion of the search proceedings, the assessee company through its director applied for the copies of said statements along with other seized material which were supplied to them. On receipt of the copies of statements and after in-depth and minute examination thereof, it was observed that

Professional Automotives Private Limited, Jammu vs. Assisstant Commissioner of Income Tax, Central Circle-1, Jaipur

In the result the appeal of the assessee in ITA no

ITA 811/JPR/2025[2015-16]Status: DisposedITAT Jaipur23 Jul 2025AY 2015-16
For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

voucher was alleged as bogus by Id.AO nor any contrary evidence was brought on record either by making independent enquiry or out of seized material and unverified observations made by the Investigation team were simply relied upon, thus the disallowances so confirmed, deserves to be deleted ... Rajendra Singh.Immediately after conclusion of the search proceedings, the assessee company through its director applied for the copies of said statements along with other seized material which were supplied to them. On receipt of the copies of statements and after in-depth and minute examination thereof, it was observed that

Professional Automotives Private Limited, Jammu vs. Assistant Commissioner of Income Tax, Centre Circle -1, Jaipur

ITA 810/JPR/2025[2014-15]Status: DisposedITAT Jaipur23 Jul 2025AY 2014-15
For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

voucher was alleged as bogus by ld.AO nor any contrary evidence was brought on record either by making independent enquiry or out of seized material and unverified observations made by the Investigation team were simply relied upon, thus the disallowances so confirmed, deserves to be deleted. 3. On the facts ... Rajendra Singh.Immediately after conclusion of the search proceedings, the assessee company through its director applied for the copies of said statements along with other seized material which were supplied to them. On receipt of the copies of statements and after in-depth and minute examination thereof, it was observed that

Professional Automotives Private Limited, Jammu vs. Assistant Commissioner of Income Tax, Central Circle -1, Jaipur

ITA 809/JPR/2025[2013-14]Status: DisposedITAT Jaipur23 Jul 2025AY 2013-14
For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

voucher was alleged as bogus by ld.AO nor any contrary evidence was brought on record either by making independent enquiry or out of seized material and unverified observations made by the Investigation team were simply relied upon, thus the disallowances so confirmed, deserves to be deleted. 3. On the facts ... Rajendra Singh.Immediately after conclusion of the search proceedings, the assessee company through its director applied for the copies of said statements along with other seized material which were supplied to them. On receipt of the copies of statements and after in-depth and minute examination thereof, it was observed that

M/S Banna Lal Jat Constructions Pvt. Ltd., Bhilwara vs. DCIT, Central Circle, Ajmer

Appeal is partly allowed by reducing the penalty to the

ITA 1569/JPR/2024[2015-16]Status: DisposedITAT Jaipur23 Jul 2025AY 2015-16

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 132Section 250Section 271ASection 274

Contractor was Rs.1,06,76,391/- (PB 77) and that of assessee was Rs.4,21,691/- (PB 78). Both these documents are part of seized material as is evident from the signature of authorized officer. (c) The inventory of cash found at Rs.1,21,43,210/- and that seized

Shri Satish Soin, Ludhiana vs. ACIT, CC-II, Ludhiana

In the result, appeal of the assessee is allowed

ITA 303/CHANDI/2019[2012-13]Status: DisposedITAT Chandigarh23 Jul 2025AY 2012-13

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 303/Chd/2019 "नधा"रण वष" / Assessment Year : 2012-13 Shri Satish Soin, बनाम The Acit, House No.31, Garden Enclave, Central Circle-2, Vs South City-Ii, Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Advps6254N अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Ashwani Kumar & Ms. Muskan Garg, Cas राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr तार"ख/Date Of Hearing : 26.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 23.07.2025 Hybrid Hearing आदेश/Order Per Rajpal Yadav, Vp

For Appellant: Shri Ashwani Kumar &For Respondent: Smt. Kusum Bansal, CIT DR
Section 10(38)Section 132Section 143(3)Section 153ASection 153DSection 263

Canara Housing Development Corporation Vs DCIT, Central Circle, Bangalore. On the strength of this judgement, he was of the view that apart from seized material, any other issue could also be examined in an assessment required to be framed under Section 153A of the Income Tax Act. The judgement ... Abhisar Buildwell Pvt. Ltd. 149 taxman.com 399, the additions in an assessment under Section 153A was to be made on the basis of seized material found during the course of search. No such material was either found during the course of search nor any material was transmitted

Kathir Kaman Jewels Pvt. Ltd., Chennai vs. DCIT, Central Circle -3(1), Chennai

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 20/CHNY/2025[2016-17]Status: DisposedITAT Chennai23 Jul 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.17, 18, 19 & 20/Chny/2025 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2015-16 & 2016-17 Kathir Kaman Jewels Pvt. Ltd., Vs. The Deputy Commissioner Of New No. 40 (Old No. 23), Sarojini Income Tax, Street, T. Nagar, Chennai 600 017. Central Circle 3(1) Chennai. [Pan:Aacck4534C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Banusekar, Advocate & Shri H. Yeshwanth Kumar, Advocate ""थ" की ओर से/Respondent By : Shri C.N. Bipin, Cit सुनवाई की तारीख/ Date Of Hearing : 24.06.2025 घोषणा की तारीख /Date Of Pronouncement : 23.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 17.10.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals) – 20, Chennai For The Assessment Years 2011-12, 2012-13, 2015-16 & 2016-17. 2. Since Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed To 2

For Appellant: Shri T. Banusekar, Advocate &For Respondent: Shri C.N. Bipin, CIT
Section 132Section 132(4)Section 139Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153C

Considering the satisfaction note recorded by the Assessing Officer of Shri B. Ayyappan, based on the seized material, the Jurisdictional Assessing Officer of the assessee issued notice under section 153C of the Act dated 04.10.2018 to the assessee. In response to the said notice, the assessee filed its return ... purchases as determined by the search team during the course of search and seizure operation conducted in the case of Shri Ayyappan. From the seized materials, after extracting data from the hard disk, the Assessing Officer noted unaccounted data of old gold purchases and sales which were maintained

Kathir Kaman Jewels Pvt. Ltd., Chennai vs. DCIT, Central Circle-3(1), Chennai

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 19/CHNY/2025[2015-16]Status: DisposedITAT Chennai23 Jul 2025AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.17, 18, 19 & 20/Chny/2025 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2015-16 & 2016-17 Kathir Kaman Jewels Pvt. Ltd., Vs. The Deputy Commissioner Of New No. 40 (Old No. 23), Sarojini Income Tax, Street, T. Nagar, Chennai 600 017. Central Circle 3(1) Chennai. [Pan:Aacck4534C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Banusekar, Advocate & Shri H. Yeshwanth Kumar, Advocate ""थ" की ओर से/Respondent By : Shri C.N. Bipin, Cit सुनवाई की तारीख/ Date Of Hearing : 24.06.2025 घोषणा की तारीख /Date Of Pronouncement : 23.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 17.10.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals) – 20, Chennai For The Assessment Years 2011-12, 2012-13, 2015-16 & 2016-17. 2. Since Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed To 2

For Appellant: Shri T. Banusekar, Advocate &For Respondent: Shri C.N. Bipin, CIT
Section 132Section 132(4)Section 139Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153C

Considering the satisfaction note recorded by the Assessing Officer of Shri B. Ayyappan, based on the seized material, the Jurisdictional Assessing Officer of the assessee issued notice under section 153C of the Act dated 04.10.2018 to the assessee. In response to the said notice, the assessee filed its return ... purchases as determined by the search team during the course of search and seizure operation conducted in the case of Shri Ayyappan. From the seized materials, after extracting data from the hard disk, the Assessing Officer noted unaccounted data of old gold purchases and sales which were maintained

Kathir Kaman Jewels Pvt. Ltd., Chennai vs. DCIT, Central Circle-3(1), Chennai

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 18/CHNY/2025[2012-13]Status: DisposedITAT Chennai23 Jul 2025AY 2012-13

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.17, 18, 19 & 20/Chny/2025 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2015-16 & 2016-17 Kathir Kaman Jewels Pvt. Ltd., Vs. The Deputy Commissioner Of New No. 40 (Old No. 23), Sarojini Income Tax, Street, T. Nagar, Chennai 600 017. Central Circle 3(1) Chennai. [Pan:Aacck4534C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Banusekar, Advocate & Shri H. Yeshwanth Kumar, Advocate ""थ" की ओर से/Respondent By : Shri C.N. Bipin, Cit सुनवाई की तारीख/ Date Of Hearing : 24.06.2025 घोषणा की तारीख /Date Of Pronouncement : 23.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 17.10.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals) – 20, Chennai For The Assessment Years 2011-12, 2012-13, 2015-16 & 2016-17. 2. Since Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed To 2

For Appellant: Shri T. Banusekar, Advocate &For Respondent: Shri C.N. Bipin, CIT
Section 132Section 132(4)Section 139Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153C

Considering the satisfaction note recorded by the Assessing Officer of Shri B. Ayyappan, based on the seized material, the Jurisdictional Assessing Officer of the assessee issued notice under section 153C of the Act dated 04.10.2018 to the assessee. In response to the said notice, the assessee filed its return ... purchases as determined by the search team during the course of search and seizure operation conducted in the case of Shri Ayyappan. From the seized materials, after extracting data from the hard disk, the Assessing Officer noted unaccounted data of old gold purchases and sales which were maintained

Kathir Kaman Jewels Pvt. Ltd., Chennai vs. DCIT, Central Circle-3(1), Chennai

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 17/CHNY/2025[2011-12]Status: DisposedITAT Chennai23 Jul 2025AY 2011-12

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.17, 18, 19 & 20/Chny/2025 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2015-16 & 2016-17 Kathir Kaman Jewels Pvt. Ltd., Vs. The Deputy Commissioner Of New No. 40 (Old No. 23), Sarojini Income Tax, Street, T. Nagar, Chennai 600 017. Central Circle 3(1) Chennai. [Pan:Aacck4534C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Banusekar, Advocate & Shri H. Yeshwanth Kumar, Advocate ""थ" की ओर से/Respondent By : Shri C.N. Bipin, Cit सुनवाई की तारीख/ Date Of Hearing : 24.06.2025 घोषणा की तारीख /Date Of Pronouncement : 23.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 17.10.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals) – 20, Chennai For The Assessment Years 2011-12, 2012-13, 2015-16 & 2016-17. 2. Since Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed To 2

For Appellant: Shri T. Banusekar, Advocate &For Respondent: Shri C.N. Bipin, CIT
Section 132Section 132(4)Section 139Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153C

Considering the satisfaction note recorded by the Assessing Officer of Shri B. Ayyappan, based on the seized material, the Jurisdictional Assessing Officer of the assessee issued notice under section 153C of the Act dated 04.10.2018 to the assessee. In response to the said notice, the assessee filed its return ... purchases as determined by the search team during the course of search and seizure operation conducted in the case of Shri Ayyappan. From the seized materials, after extracting data from the hard disk, the Assessing Officer noted unaccounted data of old gold purchases and sales which were maintained

Jitendra Kumar, Faridabad vs. DCIT, Central Circle-1, Faridabad

In the result, the appeal of the assessee is allowed

ITA 62/DEL/2025[2020-21]Status: DisposedITAT Delhi23 Jul 2025AY 2020-21

Bench: Shri Yogesh Kumar Us & Shri Manish Agarwal

Section 132Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153DSection 250Section 69

perusal of the approval, it could be seen that Addl. CIT while granting the approval has not stated whether he has gone through the seized material, assessment records including the replies filed by the assessee with reference to the additions/ disallowance proposed in the drafts assessment order. Rather the Addl ... approval letter it is stated whether any discussions were carried between the AO and the Addl. CIT or he has gone through the seized material. As per ld. AR, the Addl. CIT has not verified the material, nor any reference was made in the approval letter about the material supplied

Jitendra Kumar, Faridabad vs. DCIT, Central Circle-1, Faridabad

In the result, the appeal of the assessee is allowed

ITA 61/DEL/2025[2018-19]Status: DisposedITAT Delhi23 Jul 2025AY 2018-19

Bench: Shri Yogesh Kumar Us & Shri Manish Agarwal

Section 132Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153DSection 250Section 69

perusal of the approval, it could be seen that Addl. CIT while granting the approval has not stated whether he has gone through the seized material, assessment records including the replies filed by the assessee with reference to the additions/ disallowance proposed in the drafts assessment order. Rather the Addl ... approval letter it is stated whether any discussions were carried between the AO and the Addl. CIT or he has gone through the seized material. As per ld. AR, the Addl. CIT has not verified the material, nor any reference was made in the approval letter about the material supplied

Jitendra Kumar, Faridabad vs. DCIT Central Circle-1, Faridabad

In the result, the appeal of the assessee is allowed

ITA 60/DEL/2025[2017-18]Status: DisposedITAT Delhi23 Jul 2025AY 2017-18

Bench: Shri Yogesh Kumar Us & Shri Manish Agarwal

Section 132Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153DSection 250Section 69

perusal of the approval, it could be seen that Addl. CIT while granting the approval has not stated whether he has gone through the seized material, assessment records including the replies filed by the assessee with reference to the additions/ disallowance proposed in the drafts assessment order. Rather the Addl ... approval letter it is stated whether any discussions were carried between the AO and the Addl. CIT or he has gone through the seized material. As per ld. AR, the Addl. CIT has not verified the material, nor any reference was made in the approval letter about the material supplied

Jitendra Kumar, Faridabad vs. DCIT, Central Circle-1, Faridabad

In the result, the appeal of the assessee is allowed

ITA 59/DEL/2025[2016-17]Status: DisposedITAT Delhi23 Jul 2025AY 2016-17

Bench: Shri Yogesh Kumar Us & Shri Manish Agarwal

Section 132Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153DSection 250Section 69

perusal of the approval, it could be seen that Addl. CIT while granting the approval has not stated whether he has gone through the seized material, assessment records including the replies filed by the assessee with reference to the additions/ disallowance proposed in the drafts assessment order. Rather the Addl ... approval letter it is stated whether any discussions were carried between the AO and the Addl. CIT or he has gone through the seized material. As per ld. AR, the Addl. CIT has not verified the material, nor any reference was made in the approval letter about the material supplied

Jitendra Kumar, Faridabad vs. DCIT, Central Circle-1, Faridabad

In the result, the appeal of the assessee is allowed

ITA 58/DEL/2025[2015-16]Status: DisposedITAT Delhi23 Jul 2025AY 2015-16

Bench: Shri Yogesh Kumar Us & Shri Manish Agarwal

Section 132Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153DSection 250Section 69

perusal of the approval, it could be seen that Addl. CIT while granting the approval has not stated whether he has gone through the seized material, assessment records including the replies filed by the assessee with reference to the additions/ disallowance proposed in the drafts assessment order. Rather the Addl ... approval letter it is stated whether any discussions were carried between the AO and the Addl. CIT or he has gone through the seized material. As per ld. AR, the Addl. CIT has not verified the material, nor any reference was made in the approval letter about the material supplied

Jitendra Kumar, Faridabad vs. DCIT, Central Circle-1, Faridabad

In the result, the appeal of the assessee is allowed

ITA 57/DEL/2025[2014-15]Status: DisposedITAT Delhi23 Jul 2025AY 2014-15

Bench: Shri Yogesh Kumar Us & Shri Manish Agarwal

Section 132Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153DSection 250Section 69

perusal of the approval, it could be seen that Addl. CIT while granting the approval has not stated whether he has gone through the seized material, assessment records including the replies filed by the assessee with reference to the additions/ disallowance proposed in the drafts assessment order. Rather the Addl ... approval letter it is stated whether any discussions were carried between the AO and the Addl. CIT or he has gone through the seized material. As per ld. AR, the Addl. CIT has not verified the material, nor any reference was made in the approval letter about the material supplied

Jitendra Kumar, Faridabad vs. DCIT, Central Circle-1, Faridabad

In the result, the appeal of the assessee is allowed

ITA 56/DEL/2025[2013-14]Status: DisposedITAT Delhi23 Jul 2025AY 2013-14

Bench: Shri Yogesh Kumar Us & Shri Manish Agarwal

Section 132Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153DSection 250Section 69

perusal of the approval, it could be seen that Addl. CIT while granting the approval has not stated whether he has gone through the seized material, assessment records including the replies filed by the assessee with reference to the additions/ disallowance proposed in the drafts assessment order. Rather the Addl ... approval letter it is stated whether any discussions were carried between the AO and the Addl. CIT or he has gone through the seized material. As per ld. AR, the Addl. CIT has not verified the material, nor any reference was made in the approval letter about the material supplied