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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

Vikas Dugar L/H of Late Shri Keshari Singh Dugar, Jaipur vs. PCIT (Central), Jaipur

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

ITA 387/JPR/2025[A.Y.2015-16]Status: DisposedITAT Jaipur15 Jul 2025

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

For Appellant: Shri Prakul Khurana, Adv. &For Respondent: Shri Rajesh Ojha, CIT-DR
Section 263

related to the evidence found, it does not mean that the assessment "can be arbitrary or made without any relevance or nexus with the seized material. Obviously an assessment has to be made under this Section only on the basis of seized material." v. In absence of any incriminating material

Vikas Dugar Legal Heir of Late Shri Keshari Singh Dugar, Jaipur vs. PCIT (Central), Jaipur

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

ITA 386/JPR/2025[A.Y. 2014-15]Status: DisposedITAT Jaipur15 Jul 2025

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

For Appellant: Shri Prakul Khurana, Adv. &For Respondent: Shri Rajesh Ojha, CIT-DR
Section 263

related to the evidence found, it does not mean that the assessment "can be arbitrary or made without any relevance or nexus with the seized material. Obviously an assessment has to be made under this Section only on the basis of seized material." v. In absence of any incriminating material

Amico Textiles, Solan vs. DCIT CC-1, Chandigarth

The appeal stand allowed in terms of our above order

ITA 430/CHANDI/2022[2013-14]Status: DisposedITAT Chandigarh15 Jul 2025AY 2013-14

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.430/Chandi/2022 (िनधा"रणवष" / Assessment Year: 2013-14) M/S Amico Textiles Dcit Village Bir Plassi, Ropar Road, Central Circle-1 बनाम/ Vs. Nalagarh, Solan Chandigarh Himachal Pradesh 176077 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaqfa-9823-K (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Neeraj Jain (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Manav Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 23-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 15-07-2025. आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2013-14 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 31-03-2022 In The Matter Of An Assessment Framed By Ld. Ao U/S 147 R.W.S. 153A Of The Act On 17-12- 2018. The Assessee Is Aggrieved By Confirmation Of Addition Of Rs.46.87 Lacs.

For Appellant: Sh. Neeraj Jain (CA) – Ld. ARFor Respondent: Sh. Manav Bansal (CIT) – Ld. DR
Section 139Section 147Section 148Section 149Section 151Section 153Section 153ASection 153CSection 68

possession of one of the partners which was used against the assessee to make the impugned addition. However, Ld. CIT(A) noted that the seized material belonged to the partner of the assessee-firm though it contained transactions related to the assessee. Since the document belonging to assessee ... dated 31.12.2018 i.e. after the amendment carried out in Section 153C by Finance Act, 2015. 12. We have taken cognizance of the alleged seized material (extracted supra) as well as the belief formed by the AO while recording the reasons for re-opening of the assessment. According to the Revenue

Sri. Nithin Bagamane, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalaore

ITA 372/BANG/2024[2018-19]Status: DisposedITAT Bangalore15 Jul 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 132Section 153CSection 69C

assessee as well as the company. The assessee filed their return of income pursuant to the notice issued u/s. 153C. Based on the seized materials, the AO made the additions and completed the assessment u/s.153C of the Act. The said assessment orders were challenged by the assessee before the Ld.CIT ... premises of the assessee as well as the companies in the 7th floor appears to be correct. As discussed earlier, the recovery of seized materials were all from the 7th floor premises of the Coffee Day Square building. Therefore, the department cannot now say that the alleged documents were recovered

Sri. Nithin Bagamane, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru

ITA 371/BANG/2024[2017-18]Status: DisposedITAT Bangalore15 Jul 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 132Section 153CSection 69C

assessee as well as the company. The assessee filed their return of income pursuant to the notice issued u/s. 153C. Based on the seized materials, the AO made the additions and completed the assessment u/s.153C of the Act. The said assessment orders were challenged by the assessee before the Ld.CIT ... premises of the assessee as well as the companies in the 7th floor appears to be correct. As discussed earlier, the recovery of seized materials were all from the 7th floor premises of the Coffee Day Square building. Therefore, the department cannot now say that the alleged documents were recovered

Sri. Nithin Bagamane, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

ITA 370/BANG/2024[2016-17]Status: DisposedITAT Bangalore15 Jul 2025AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 132Section 153CSection 69C

assessee as well as the company. The assessee filed their return of income pursuant to the notice issued u/s. 153C. Based on the seized materials, the AO made the additions and completed the assessment u/s. 153C of the Act. The said assessment orders were challenged by the assessee before

Sri. Nithin Bagamane, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru

ITA 369/BANG/2024[2015-16]Status: DisposedITAT Bangalore15 Jul 2025AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 132Section 153CSection 69C

assessee as well as the company. The assessee filed their return of income pursuant to the notice issued u/s. 153C. Based on the seized materials, the AO made the additions and completed the assessment u/s. 153C of the Act. The said assessment orders were challenged by the assessee before

Sri. Nithin Bagamane, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

ITA 368/BANG/2024[2014-15]Status: DisposedITAT Bangalore15 Jul 2025AY 2014-15

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 132Section 153CSection 69C

assessee as well as the company. The assessee filed their return of income pursuant to the notice issued u/s. 153C. Based on the seized materials, the AO made the additions and completed the assessment u/s. 153C of the Act. The said assessment orders were challenged by the assessee before

Sri. Nithin Bagamane, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

ITA 367/BANG/2024[2013-14]Status: DisposedITAT Bangalore15 Jul 2025AY 2013-14

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 132Section 153CSection 69C

assessee as well as the company. The assessee filed their return of income pursuant to the notice issued u/s. 153C. Based on the seized materials, the AO made the additions and completed the assessment u/s. 153C of the Act. The said assessment orders were challenged by the assessee before

Sri. Nithin Bagamane, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

ITA 366/BANG/2024[2012-13]Status: DisposedITAT Bangalore15 Jul 2025AY 2012-13

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 132Section 153CSection 69C

assessee as well as the company. The assessee filed their return of income pursuant to the notice issued u/s. 153C. Based on the seized materials, the AO made the additions and completed the assessment u/s. 153C of the Act. The said assessment orders were challenged by the assessee before

Shri Balaji India Private Limited, Gurgaon vs. Assistant Commissioner of Income Tax Central Circle 1, Faridabad

Accordingly, the present appeals, along with all pending applications, are dismissed

ITA 5752/DEL/2024[2021-22]Status: DisposedITAT Delhi15 Jul 2025AY 2021-22

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 5744/Del/2024 : Asstt. Year: 2019-20 Ita No. 5745/Del/2024 : Asstt. Year: 2020-21 Ita No. 5752/Del/2024 : Asstt. Year: 2021-22 Shri Balaji (India) Pvt. Ltd., Vs Acit, Vpo Badshahpur, Near Arya Samaj Central Circle-1, Mandir, Gurgaon-122017 Faridabad-121001 (Appellant) (Respondent) Pan No. Aaccs5328Q Assessee By: Sh. Anshul Mittal, Adv. Revenue By : Sh. Mahesh Kumar, Cit-Dr Date Of Hearing: 15.07.2025 Date Of Pronouncement: 15.07.2025 Order Per Satbeer Singh Godara: These Assessee’S Three Appeals Ita Nos. 5744, 5745 & 5752/Del/2024, For Assessment Years 2019-20, 2020-21 & 2021-22, Arise Against The Cit(A)-3, Gurgaon’S Orders Dated 21St & 22Nd October, 2024 Passed In Case Nos. 10964/2018-19, 10827/2019-20 & 10090/2020-21, In Proceedings U/S 143(3) R.W.S. 153A Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: Sh. Anshul Mittal, AdvFor Respondent: Sh. Mahesh Kumar, CIT-DR
Section 132Section 143(3)Section 148Section 153ASection 153CSection 260A

this factual backdrop that we put the Revenue to one question that since the impugned addition(s) are based on the corresponding seized material in M/s Chhoker Group having an independent search, the same would not form the corresponding basis of the impugned addition in absence of either section 153C ... section 148 proceedings against the appellant herein. It vehemently argues that given the fact that the assessee was confronted with the said seized material, we ought to uphold the impugned assessment forming subject matter of adjudication. Shri Balaji (India) Pvt. Ltd. 4. We find no merit in the Revenue

Shri Balaji India Private Limited, Gurgaon vs. Assistant Commissioner of Income Tax Central Circle 1, Faridabad

Accordingly, the present appeals, along with all pending applications, are dismissed

ITA 5745/DEL/2024[2020-21]Status: DisposedITAT Delhi15 Jul 2025AY 2020-21

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 5744/Del/2024 : Asstt. Year: 2019-20 Ita No. 5745/Del/2024 : Asstt. Year: 2020-21 Ita No. 5752/Del/2024 : Asstt. Year: 2021-22 Shri Balaji (India) Pvt. Ltd., Vs Acit, Vpo Badshahpur, Near Arya Samaj Central Circle-1, Mandir, Gurgaon-122017 Faridabad-121001 (Appellant) (Respondent) Pan No. Aaccs5328Q Assessee By: Sh. Anshul Mittal, Adv. Revenue By : Sh. Mahesh Kumar, Cit-Dr Date Of Hearing: 15.07.2025 Date Of Pronouncement: 15.07.2025 Order Per Satbeer Singh Godara: These Assessee’S Three Appeals Ita Nos. 5744, 5745 & 5752/Del/2024, For Assessment Years 2019-20, 2020-21 & 2021-22, Arise Against The Cit(A)-3, Gurgaon’S Orders Dated 21St & 22Nd October, 2024 Passed In Case Nos. 10964/2018-19, 10827/2019-20 & 10090/2020-21, In Proceedings U/S 143(3) R.W.S. 153A Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: Sh. Anshul Mittal, AdvFor Respondent: Sh. Mahesh Kumar, CIT-DR
Section 132Section 143(3)Section 148Section 153ASection 153CSection 260A

this factual backdrop that we put the Revenue to one question that since the impugned addition(s) are based on the corresponding seized material in M/s Chhoker Group having an independent search, the same would not form the corresponding basis of the impugned addition in absence of either section 153C ... section 148 proceedings against the appellant herein. It vehemently argues that given the fact that the assessee was confronted with the said seized material, we ought to uphold the impugned assessment forming subject matter of adjudication. Shri Balaji (India) Pvt. Ltd. 4. We find no merit in the Revenue

Shri Balaji India Private Limited, Gurugram vs. Assistant Commissioner of Income Tax, Faridabad

Accordingly, the present appeals, along with all pending applications, are dismissed

ITA 5744/DEL/2024[2019-20]Status: DisposedITAT Delhi15 Jul 2025AY 2019-20

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 5744/Del/2024 : Asstt. Year: 2019-20 Ita No. 5745/Del/2024 : Asstt. Year: 2020-21 Ita No. 5752/Del/2024 : Asstt. Year: 2021-22 Shri Balaji (India) Pvt. Ltd., Vs Acit, Vpo Badshahpur, Near Arya Samaj Central Circle-1, Mandir, Gurgaon-122017 Faridabad-121001 (Appellant) (Respondent) Pan No. Aaccs5328Q Assessee By: Sh. Anshul Mittal, Adv. Revenue By : Sh. Mahesh Kumar, Cit-Dr Date Of Hearing: 15.07.2025 Date Of Pronouncement: 15.07.2025 Order Per Satbeer Singh Godara: These Assessee’S Three Appeals Ita Nos. 5744, 5745 & 5752/Del/2024, For Assessment Years 2019-20, 2020-21 & 2021-22, Arise Against The Cit(A)-3, Gurgaon’S Orders Dated 21St & 22Nd October, 2024 Passed In Case Nos. 10964/2018-19, 10827/2019-20 & 10090/2020-21, In Proceedings U/S 143(3) R.W.S. 153A Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: Sh. Anshul Mittal, AdvFor Respondent: Sh. Mahesh Kumar, CIT-DR
Section 132Section 143(3)Section 148Section 153ASection 153CSection 260A

this factual backdrop that we put the Revenue to one question that since the impugned addition(s) are based on the corresponding seized material in M/s Chhoker Group having an independent search, the same would not form the corresponding basis of the impugned addition in absence of either section 153C ... section 148 proceedings against the appellant herein. It vehemently argues that given the fact that the assessee was confronted with the said seized material, we ought to uphold the impugned assessment forming subject matter of adjudication. Shri Balaji (India) Pvt. Ltd. 4. We find no merit in the Revenue

Ashok Bharti Goswami, Pune vs. ACIT, Central Circle 2(1), Pune

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

ITA 1272/PUN/2024[2018-19]Status: DisposedITAT Pune14 Jul 2025AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

also admitted by Shri Yuvraj Dhamale in his statement. Accordingly, the Dy.CIT, Central Circle 2(3), Pune who was having possession of the seized material in capacity of the Assessing Officer of Shri Yuvraj Dhamale and M/s. Wellbuild Merchants Pvt. Ltd. recorded the satisfaction that the information contained on page ... thus, the case law relied upon by the appellant (supra) is not applicable in the case of the appellant. Moreover, as discussed above, the seized material contains specific entries of cash paid by the appellant to the Yuvraj Dhamale group as on money for purchase of flat and the same

Ashish Ramesh Oswal, Pune vs. ACIT, Central Circle 2(1), Pune

ITA 1271/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

also admitted by Shri Yuvraj Dhamale in his statement. Accordingly, the Dy.CIT, Central Circle 2(3), Pune who was having possession of the seized material in capacity of the Assessing Officer of Shri Yuvraj Dhamale and M/s. Wellbuild Merchants Pvt. Ltd. recorded the satisfaction that the information contained on page ... thus, the case law relied upon by the appellant (supra) is not applicable in the case of the appellant. Moreover, as discussed above, the seized material contains specific entries of cash paid by the appellant to the Yuvraj Dhamale group as on money for purchase of flat and the same

Adish Shantilal Solanki, Pune vs. Assistant Commissioner of Income Tax, Central Circle-2(1), Pune

ITA 1270/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

Section 131Section 132Section 142(1)Section 143(1)Section 153C

also admitted by Shri Yuvraj Dhamale in his statement. Accordingly, the Dy.CIT, Central Circle 2(3), Pune who was having possession of the seized material in capacity of the Assessing Officer of Shri Yuvraj Dhamale and M/s. Wellbuild Merchants Pvt. Ltd. recorded the satisfaction that the information contained on page ... thus, the case law relied upon by the appellant (supra) is not applicable in the case of the appellant. Moreover, as discussed above, the seized material contains specific entries of cash paid by the appellant to the Yuvraj Dhamale group as on money for purchase of flat and the same

Chitra Narendra Parmar, Pune vs. Assistant Commissioner of Income Tax, Central Circle-2(1), Pune

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

ITA 1269/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

also admitted by Shri Yuvraj Dhamale in his statement. Accordingly, the Dy.CIT, Central Circle 2(3), Pune who was having possession of the seized material in capacity of the Assessing Officer of Shri Yuvraj Dhamale and M/s. Wellbuild Merchants Pvt. Ltd. recorded the satisfaction that the information contained on page ... thus, the case law relied upon by the appellant (supra) is not applicable in the case of the appellant. Moreover, as discussed above, the seized material contains specific entries of cash paid by the appellant to the Yuvraj Dhamale group as on money for purchase of flat and the same

Ramlal Bhikulal Shah, Pune vs. ACIT, Central Circle 2(1), Pune

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

ITA 1268/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

also admitted by Shri Yuvraj Dhamale in his statement. Accordingly, the Dy.CIT, Central Circle 2(3), Pune who was having possession of the seized material in capacity of the Assessing Officer of Shri Yuvraj Dhamale and M/s. Wellbuild Merchants Pvt. Ltd. recorded the satisfaction that the information contained on page ... thus, the case law relied upon by the appellant (supra) is not applicable in the case of the appellant. Moreover, as discussed above, the seized material contains specific entries of cash paid by the appellant to the Yuvraj Dhamale group as on money for purchase of flat and the same

Deepak Kantilal Jain, Pune vs. ACIT, Central Circle 2(1), Pune

The appeal stands dismissed

ITA 1267/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

Section 131Section 132Section 142(1)Section 143(1)Section 153C

also admitted by Shri Yuvraj Dhamale in his statement. Accordingly, the Dy.CIT, Central Circle 2(3), Pune who was having possession of the seized material in capacity of the Assessing Officer of Shri Yuvraj Dhamale and M/s. Wellbuild Merchants Pvt. Ltd. recorded the satisfaction that the information contained on page ... thus, the case law relied upon by the appellant (supra) is not applicable in the case of the appellant. Moreover, as discussed above, the seized material contains specific entries of cash paid by the appellant to the Yuvraj Dhamale group as on money for purchase of flat and the same

Ashish Ramesh Oswal, Pune vs. ACIT, Central Circle 2(1), Pune

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

ITA 1266/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

also admitted by Shri Yuvraj Dhamale in his statement. Accordingly, the Dy.CIT, Central Circle 2(3), Pune who was having possession of the seized material in capacity of the Assessing Officer of Shri Yuvraj Dhamale and M/s. Wellbuild Merchants Pvt. Ltd. recorded the satisfaction that the information contained on page ... thus, the case law relied upon by the appellant (supra) is not applicable in the case of the appellant. Moreover, as discussed above, the seized material contains specific entries of cash paid by the appellant to the Yuvraj Dhamale group as on money for purchase of flat and the same