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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

Superways Enterpirses Private Limited, Mumbai vs. DCIT Central Circle 7(1), Mumbai

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

ITA 3145/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Feb 2026AY 2018-19

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 132Section 143(3)Section 68

search operation. In course of search and seizure operation, books of account of the assessee maintained in tally software were seized. While examining the seized materials, Assessing Officer found that though the assessee is engaged trading in Steel goods however, there was no evidence to indicate actual movement of materials/goods ... Thus, on analyzing the seized material found from assessee coupled with seized materials found from other group entities, the Assessing Officer noted that the assessee and other group entities without undertaking any genuine business activity were fabricating invoices to avail ‘Letters of Credit’ (LC) facilities from Bank by artificially inflating

Superways Enterpirses Private Limited, Mumbai vs. DCIT Central Circle 7(1), Mumbai

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

ITA 3144/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Feb 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 132Section 143(3)Section 68

search operation. In course of search and seizure operation, books of account of the assessee maintained in tally software were seized. While examining the seized materials, Assessing Officer found that though the assessee is engaged trading in Steel goods however, there was no evidence to indicate actual movement of materials/goods ... Thus, on analyzing the seized material found from assessee coupled with seized materials found from other group entities, the Assessing Officer noted that the assessee and other group entities without undertaking any genuine business activity were fabricating invoices to avail ‘Letters of Credit’ (LC) facilities from Bank by artificially inflating

Superways Enterpirses Private Limited, Mumbai vs. DCIT Central Circle 7(1), Mumbai

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

ITA 3143/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Feb 2026AY 2016-17

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 132Section 143(3)Section 68

search operation. In course of search and seizure operation, books of account of the assessee maintained in tally software were seized. While examining the seized materials, Assessing Officer found that though the assessee is engaged trading in Steel goods however, there was no evidence to indicate actual movement of materials/goods ... Thus, on analyzing the seized material found from assessee coupled with seized materials found from other group entities, the Assessing Officer noted that the assessee and other group entities without undertaking any genuine business activity were fabricating invoices to avail ‘Letters of Credit’ (LC) facilities from Bank by artificially inflating

Superways Enterpirses Private Limited Ltd, Mumbai vs. DCIT Central Circle 7(1), Mumbai

In the result, Revenue's appeals are dismissed and assessee's appeals are

ITA 3142/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Feb 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Jagadish

Section 132Section 143(3)Section 68

search operation. In course of search and seizure operation, books of account of the assessee maintained in tally software were seized. While examining the seized materials, Assessing Officer found that though the assessee is engaged trading in Steel goods however, there was no evidence to indicate actual movement of materials/goods ... Thus, on analyzing the seized material found from assessee coupled with seized materials found from other group entities, the Assessing Officer noted that the assessee and other group entities without undertaking any genuine business activity were fabricating invoices to avail ‘Letters of Credit' (LC) facilities from Bank by artificially inflating

Superways Enterpirses Private Limited, Mumbai vs. DCIT Central Circle 7(1), Mumbai

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

ITA 3140/MUM/2025[2013-14]Status: DisposedITAT Mumbai27 Feb 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 132Section 143(3)Section 68

search operation. In course of search and seizure operation, books of account of the assessee maintained in tally software were seized. While examining the seized materials, Assessing Officer found that though the assessee is engaged trading in Steel goods however, there was no evidence to indicate actual movement of materials/goods ... Thus, on analyzing the seized material found from assessee coupled with seized materials found from other group entities, the Assessing Officer noted that the assessee and other group entities without undertaking any genuine business activity were fabricating invoices to avail ‘Letters of Credit’ (LC) facilities from Bank by artificially inflating

Assistant Commissioner of Income Tax, Central Circle-2, Patna vs. Patna Iron Pvt. Ltd., Patna

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed

ITA 373/PAT/2025[2020-21]Status: DisposedITAT Patna26 Feb 2026AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

case in restricting the addition to Rs 55,12,500/- by applying the Gross profit 15% by suspiciously treating the figures recorded in the seized material as turnover amounting to Rs 3,67,50,000/, which is wrong, illegal and unjustified. 4. For that the learned CIT(A) failed ... added ₹3,46,31,230/-. The second addition was made by the ld. AO in respect of amount which was found recorded in the seized materials found from the premises of the third-party Shri Laxman Tikmani during the course of search on himof ₹3,67,50,000/-.The assessment

Sushil Kumar Kanodia, Patna vs. ACIT, Central Circle-2, Patna

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed

ITA 237/PAT/2025[2017-18]Status: DisposedITAT Patna26 Feb 2026AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

case in restricting the addition to Rs 55,12,500/- by applying the Gross profit 15% by suspiciously treating the figures recorded in the seized material as turnover amounting to Rs 3,67,50,000/, which is wrong, illegal and unjustified. 4. For that the learned CIT(A) failed ... added ₹3,46,31,230/-. The second addition was made by the ld. AO in respect of amount which was found recorded in the seized materials found from the premises of the third-party Shri Laxman Tikmani during the course of search on himof ₹3,67,50,000/-.The assessment

ITO-WD-1(2)(1), Ahmedabad vs. Avs Corporation, Ahmedabad

In the result, all the three appeals of the Revenue stand dismissed

ITA 1627/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Ms. Nupur Shah, ARFor Respondent: Shri Alpesh Parmar, CIT-DR &
Section 115BSection 143(1)Section 147Section 148Section 250Section 69A

assessee. 13. The aforesaid factual details show that the name of any project of the assessee was not specifically mentioned in the seized material from Shri Gautam Shah. It was during his lengthy statement that he mentioned in respect of some data that the same pertained to Satva Project. However ... from the purchasers whose name were recorded in the books of the assessee. No cash voucher or cash trail was found either from the seized material of the searched person or from the assessee. The Hon’ble Supreme Court in the case of “CIT vs. Odeon Builders (P.) Ltd.” reported

ITO-WD-1(2)(1), Ahmedabad vs. Avs Corporation, Ahmedabad

In the result, all the three appeals of the Revenue stand dismissed

ITA 1621/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2019-20

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Ms. Nupur Shah, ARFor Respondent: Shri Alpesh Parmar, CIT-DR &
Section 115BSection 143(1)Section 147Section 148Section 250Section 69A

assessee. 13. The aforesaid factual details show that the name of any project of the assessee was not specifically mentioned in the seized material from Shri Gautam Shah. It was during his lengthy statement that he mentioned in respect of some data that the same pertained to Satva Project. However ... from the purchasers whose name were recorded in the books of the assessee. No cash voucher or cash trail was found either from the seized material of the searched person or from the assessee. The Hon’ble Supreme Court in the case of “CIT vs. Odeon Builders (P.) Ltd.” reported

ITO-WD-1(2)(1), Ahmedabad vs. Avs Corporation, Ahmedabad

In the result, all the three appeals of the Revenue stand dismissed

ITA 1620/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2018-19

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Ms. Nupur Shah, ARFor Respondent: Shri Alpesh Parmar, CIT-DR &
Section 115BSection 143(1)Section 147Section 148Section 250Section 69A

assessee. 13. The aforesaid factual details show that the name of any project of the assessee was not specifically mentioned in the seized material from Shri Gautam Shah. It was during his lengthy statement that he mentioned in respect of some data that the same pertained to Satva Project. However ... from the purchasers whose name were recorded in the books of the assessee. No cash voucher or cash trail was found either from the seized material of the searched person or from the assessee. The Hon’ble Supreme Court in the case of “CIT vs. Odeon Builders (P.) Ltd.” reported

Jesaram Purohit, Mumbai vs. DCIT, Central Circle 4(2), Mumbai

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

ITA 8345/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Feb 2026AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law, L.d
Section 132Section 132(4)Section 153CSection 69

been claimed in the order of assessment that the assessee had paid on money, but again no such statement has been confronted, neither the seized material /documents /pendrive was confronted to the assessee nor the copy of statement of Key person was confronted. 13. Therefore, in our view, the information

Juararam Chogaji Purohit, Mumbai vs. DCIT Central Circle, Mumbai

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

ITA 8193/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Feb 2026AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law
Section 153CSection 69

been claimed in the order of assessment that the assessee had paid on money, but again no such statement has been confronted, neither the seized material /documents /pendrive was confronted to the assessee nor the copy of statement of Key person was confronted. 13. Therefore, in our view, the information

Juararam Chogaji Purohit, Mumbai vs. DCIT Central Circle 4(2), Mumbai

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

ITA 8192/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Feb 2026AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law
Section 153CSection 69

been claimed in the order of assessment that the assessee had paid on money, but again no such statement has been confronted, neither the seized material /documents /pendrive was confronted to the assessee nor the copy of statement of Key person was confronted. 13. Therefore, in our view, the information

Juararam Chogaji Purohit, Mumbai vs. DCIT Central Circle 4(2), Mumbai

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

ITA 8191/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the case in law
Section 153CSection 69

been claimed in the order of assessment that the assessee had paid on money, but again no such statement has been confronted, neither the seized material /documents /pendrive was confronted to the assessee nor the copy of statement of Key person was confronted. 13. Therefore, in our view, the information

Ummesalma Huzefa Ghadiali, Mumbai vs. DCIT-Central Circle 4(2), Mumbai

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

ITA 8187/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Feb 2026AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the Appellant's case and in law the Id. CIT
Section 132(4)Section 153C

been claimed in the order of assessment that the assessee had paid on money, but again no such statement has been confronted, neither the seized material /documents /pendrive was confronted to the assessee nor the copy of statement of Key person was confronted. 13. Therefore, in our view, the information

Ummesalma Huzefa Ghadiali, Mumbai vs. DCIT-Central Circle 4(2), Mumbai

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

ITA 8186/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Feb 2026AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. On the facts and circumstances of the Appellant's case and in law the Id. CIT
Section 132(4)Section 153C

been claimed in the order of assessment that the assessee had paid on money, but again no such statement has been confronted, neither the seized material /documents /pendrive was confronted to the assessee nor the copy of statement of Key person was confronted. 13. Therefore, in our view, the information

Jinal Akshay Jain, Mumbai vs. Deputy Commissioner of Income-Tax (DCIT), Central Circle-4(2), Mumbai

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

ITA 6737/MUM/2025[2020-21]Status: DisposedITAT Mumbai26 Feb 2026AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. This appeal is directed against the
Section 132Section 132(4)Section 143(3)Section 153CSection 250Section 69

been claimed in the order of assessment that the assessee had paid on money, but again no such statement has been confronted, neither the seized material /documents /pendrive was confronted to the assessee nor the copy of statement of Key person was confronted. 13. Therefore, in our view, the information

Jinal Akshay Jain, Mumbai vs. Deputy Commissioner of Income-Tax (DCIT), Central Circle-4(2), Mumbai

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

ITA 6736/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Feb 2026AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

For Appellant: 1. This appeal is directed against the
Section 132Section 132(4)Section 143(3)Section 153CSection 250Section 69

been claimed in the order of assessment that the assessee had paid on money, but again no such statement has been confronted, neither the seized material /documents /pendrive was confronted to the assessee nor the copy of statement of Key person was confronted. 13. Therefore, in our view, the information

Shri Saurin Shah Legal Heir of Late Ashok Damodar Shah, Ahmedabad vs. The ACIT, Circle-4(1)(1), Ahmedabad

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

ITA 1813/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2016-17

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(1)Section 147Section 69A

been explained by the Assessing Officer while proceeding against the assessee. The statements of the persons recorded during search with reference to the alleged, seized material, was not provided to the assessee and hence, the entire proceedings under Section 153C of the IT Act of 1961 stood vitiated

Msn Laboratories Private Limited, Hyderabad vs. Addl. CIT, Central Range-2, Hyderabad

In the result, the appeals filed by the assessee for the A

ITA 2172/HYD/2025[2021-22]Status: DisposedITAT Hyderabad25 Feb 2026AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2164, 2165, 2171 & 2172/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2018-19 To 2021-22) M/S. Msn Laboratories (P) Ltd Vs. Additional Cit Hyderabad Central Range-2 Pan:Aadcm6283F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 21/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate, But Identical Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad, All Dated 08/10/2025 For The A.Ys 2018-19 To 2021-22 Respectively. Since, Identical Issues Have Been Raised By The Assessee In All These Four Appeals, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 153ASection 269Section 271DSection 274

from a person from a single day in excess of Rs. 2 lakhs observed that, there is no dispute on the fact that the seized material clearly shows recording date-wise sale of spent solvents and scraps by the assessee group companies which were reflected in segment ... that neither the A.O nor the Add. CIT has made out a case of violation of section 269ST of the I.T. Act from the seized material so as to allege that the assessee had received Rs. 2 lakhs or more in respect of a single transaction which attracts provisions