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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

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

ITA 2171/HYD/2025[2020-21]Status: DisposedITAT Hyderabad25 Feb 2026AY 2020-21
For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 153ASection 269Section 269OSection 269SSection 271D

lakh more in respect of a single transaction to attract levy of 271DA since the day wise amounts of sale of spent solvents the seized material are pertaining to transactions with multipl different units of the appellant company. 7) On the facts and circumstances of the case ... 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

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 2165/HYD/2025[2019-20]Status: DisposedITAT Hyderabad25 Feb 2026AY 2019-20

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

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

ITA 2164/HYD/2025[2018-19]Status: DisposedITAT Hyderabad25 Feb 2026AY 2018-19
For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 153ASection 269Section 269OSection 269SSection 271D

lakh more in respect of a single transaction to attract levy of 271DA since the day wise amounts of sale of spent solvents the seized material are pertaining to transactions with multipl different units of the appellant company. 7) On the facts and circumstances of the case ... 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

Fayaz Mohammed, Hyderabad vs. DCIT, Central Circle 2(4), Hyderabad

ITA 1672/HYD/2025[2018-19]Status: DisposedITAT Hyderabad25 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.

For Appellant: Shri P Murali Mohan Rao, САFor Respondent: Smt.V Koteshwaramma, Sr.AR
Section 132Section 147Section 148Section 153ASection 153CSection 250Section 69

invalid and without Jurisdiction as the assessment was originally reopened u/s 148 by the ITO, Ward 12(1), Hyderabad on the strength of the seized material found during the search conducted u/s 132 of the Act. 6. The Ld. CIT(A) ought to have considered that the notice u/s 153C ... 22/10/2019. During the course of assessment proceedings, in the case of the searched person, the A.O of the searched person, on analysis of seized material vide annexure No. A/SPPL/OFF/01 had satisfied that the information contained in the seized material pertains to the assessee and information contained therein, has a bearing

Fayaz Mohammed, Hyderabad vs. DCIT, Central Circle 2(4), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1671/HYD/2025[2017-18]Status: DisposedITAT Hyderabad25 Feb 2026AY 2017-18
Section 132Section 147Section 148Section 153ASection 153CSection 250Section 69

invalid and without Jurisdiction as the assessment was originally reopened u/s 148 by the ITO, Ward 12(1), Hyderabad on the strength of the seized material found during the search conducted u/s 132 of the Act. 6. The Ld. CIT(A) ought to have considered that the notice u/s 153C ... 22/10/2019. During the course of assessment proceedings, in the case of the searched person, the A.O of the searched person, on analysis of seized material vide annexure No. A/SPPL/OFF/01 had satisfied that the information contained in the seized material pertains to the assessee and information contained therein, has a bearing

Samiuddin Aslam, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, all the 4 appeals filed by the assessee are allowed

ITA 1225/HYD/2025[2019-20]Status: DisposedITAT Hyderabad25 Feb 2026AY 2019-20

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1222 To 1225/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Vs. Asstt. Commissioner Of Hyderabad Income Tax, Central Circle 2(4) Hyderabad Pan: Ckvpa7727F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 22/01/2026 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 Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 115BSection 132Section 144C(5)Section 153CSection 69Section 69A

22/10/2019. During the course of assessment proceedings of Skill Promoters (P) Ltd, the A.O of the searched person, on analysis of the seized material vide Annexure No. A/SPPL/OFF/01 was satisfied that the information contained in the seized material pertains to Shri Samiuddin Aslam and information contained therein, has a bearing ... paid consideration through legitimate banking channels only. The A.O after considering the relevant submissions of the assessee and also taking note of the seized material during the course of search, observed that, on analysis of excel sheets pertaining to the assessee, it was found that the name of the assessee

Samiuddin Aslam, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, all the 4 appeals filed by the assessee are allowed

ITA 1224/HYD/2025[2018-19]Status: DisposedITAT Hyderabad25 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1222 To 1225/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Vs. Asstt. Commissioner Of Hyderabad Income Tax, Central Circle 2(4) Hyderabad Pan: Ckvpa7727F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 22/01/2026 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 Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 115BSection 132Section 144C(5)Section 153CSection 69Section 69A

22/10/2019. During the course of assessment proceedings of Skill Promoters (P) Ltd, the A.O of the searched person, on analysis of the seized material vide Annexure No. A/SPPL/OFF/01 was satisfied that the information contained in the seized material pertains to Shri Samiuddin Aslam and information contained therein, has a bearing ... paid consideration through legitimate banking channels only. The A.O after considering the relevant submissions of the assessee and also taking note of the seized material during the course of search, observed that, on analysis of excel sheets pertaining to the assessee, it was found that the name of the assessee

Samiuddin Aslam, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

ITA 1223/HYD/2025[2017-18]Status: DisposedITAT Hyderabad25 Feb 2026AY 2017-18

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.आ.अपी.सं / Ita Nos.1222 To 1225/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Hyderabad Pan: Ckvpa7727F (Appellant) Vs. Asstt. Commissioner Of Income Tax, Central Circle 2(4) Hyderabad (Respondent) निर्धारिती द्वारा / Assessee By: राजस्व द्वारा / Revenue By: Shri P. Murali Mohan Rao, Ca Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख / Date Of Hearing: 22/01/2026 घोषणा की तारीख / Pronouncement: 25/02/2026 Per. Manjunatha, G. A.M. आदेश/Order These Four Appeals Filed By The Assessee Are Directed Against The Separate Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Respondent: Shri P. Murali Mohan Rao, CA
Section 132Section 144C(13)Section 148Section 153BSection 153CSection 69

22/10/2019. During the course of assessment proceedings of Skill Promoters (P) Ltd, the A.O of the searched person, on analysis of the seized material vide Annexure No. A/SPPL/OFF/01 was satisfied that the information contained in the seized material pertains to Shri Samiuddin Aslam and information contained therein, has a bearing ... paid consideration through legitimate banking channels only. The A.O after considering the relevant submissions of the assessee and also taking note of the seized material during the course of search, observed that, on analysis of excel sheets pertaining to the assessee, it was found that the name of the assessee

Samiuddin Aslam, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, all the 4 appeals filed by the assessee are allowed

ITA 1222/HYD/2025[2016-17]Status: DisposedITAT Hyderabad25 Feb 2026AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1222 To 1225/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Vs. Asstt. Commissioner Of Hyderabad Income Tax, Central Circle 2(4) Hyderabad Pan: Ckvpa7727F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 22/01/2026 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 Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 115BSection 132Section 144C(5)Section 153CSection 69Section 69A

22/10/2019. During the course of assessment proceedings of Skill Promoters (P) Ltd, the A.O of the searched person, on analysis of the seized material vide Annexure No. A/SPPL/OFF/01 was satisfied that the information contained in the seized material pertains to Shri Samiuddin Aslam and information contained therein, has a bearing ... paid consideration through legitimate banking channels only. The A.O after considering the relevant submissions of the assessee and also taking note of the seized material during the course of search, observed that, on analysis of excel sheets pertaining to the assessee, it was found that the name of the assessee

Bhagwanti Lalitkumar Jain, Mumbai vs. ACIT, Central Circle 4(2), Mumbai

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

ITA 8656/MUM/2025[2018-19]Status: DisposedITAT Mumbai25 Feb 2026AY 2018-19

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Arun Kanti Datta, CIT-DR
Section 115BSection 132Section 143(2)Section 147Section 153CSection 250Section 69

above mentioned grounds. 6. The Learned Authorised Representative (‘Ld. AR’ for short) for the assessee commenced his arguments stating that there was no seized material pertaining to the Ms. Bhagwanti Lalitkumar Jain assessee and the Ld. AO merely relied on the material seized from the third party which ... 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

Bhagwanti Lalitkumar Jain, Mumbai vs. ACIT, Central Circle 4(2), Mumbai

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

ITA 8655/MUM/2025[2019-20]Status: DisposedITAT Mumbai25 Feb 2026AY 2019-20

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Arun Kanti Datta, CIT-DR
Section 115BSection 132Section 143(2)Section 147Section 153CSection 250Section 69

above mentioned grounds. 6. The Learned Authorised Representative (‘Ld. AR’ for short) for the assessee commenced his arguments stating that there was no seized material pertaining to the Ms. Bhagwanti Lalitkumar Jain assessee and the Ld. AO merely relied on the material seized from the third party which ... 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

R K Infralink LLP, Rajkot vs. ACIT, CC-1, Rajkot

In the result, ground No. 3 in Revenue`s appeal in ITA No

ITA 531/RJT/2024[2022-23]Status: DisposedITAT Rajkot24 Feb 2026AY 2022-23

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

Section 143(3)Section 147Section 148Section 250

Sarvanand Sonvani. While passing the assessment order, the assessing officer has referred to incriminating evidence found during the course of search, data extracted from seized material, the assessee's reply in response to show cause notice and concluded that the assessee has 5 ITA No. 528-531 & 518-521/Rjt/2024 ... assessee group. 6. As details regarding an unaccounted part of the above mentioned transactions pertaining to the assessee, have been gathered from the seized material during the search operation. Therefore, the case of the assessee has been reopened under section 147 of the Act, after following the due procedure laid

R K Infralink LLP, Rajkot vs. ACIT, CC-1, Rajkot, Rajokt

In the result, ground No. 3 in Revenue`s appeal in ITA No

ITA 530/RJT/2024[2021-22]Status: DisposedITAT Rajkot24 Feb 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

Section 143(3)Section 147Section 148Section 250

Sarvanand Sonvani. While passing the assessment order, the assessing officer has referred to incriminating evidence found during the course of search, data extracted from seized material, the assessee's reply in response to show cause notice and concluded that the assessee has 5 ITA No. 528-531 & 518-521/Rjt/2024 ... assessee group. 6. As details regarding an unaccounted part of the above mentioned transactions pertaining to the assessee, have been gathered from the seized material during the search operation. Therefore, the case of the assessee has been reopened under section 147 of the Act, after following the due procedure laid

R K Infralink LLP, Rajkot vs. ACIT, CC-1, Rajkot

In the result, ground No. 3 in Revenue`s appeal in ITA No

ITA 529/RJT/2024[2020-21]Status: DisposedITAT Rajkot24 Feb 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

Section 143(3)Section 147Section 148Section 250

Sarvanand Sonvani. While passing the assessment order, the assessing officer has referred to incriminating evidence found during the course of search, data extracted from seized material, the assessee's reply in response to show cause notice and concluded that the assessee has 5 ITA No. 528-531 & 518-521/Rjt/2024 ... assessee group. 6. As details regarding an unaccounted part of the above mentioned transactions pertaining to the assessee, have been gathered from the seized material during the search operation. Therefore, the case of the assessee has been reopened under section 147 of the Act, after following the due procedure laid

R K Infralink LLP, Rajkot vs. ACIT, CC-1, Rajkot

In the result, ground No. 3 in Revenue`s appeal in ITA No

ITA 528/RJT/2024[2019-20]Status: DisposedITAT Rajkot24 Feb 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

Section 143(3)Section 147Section 148Section 250

Sarvanand Sonvani. While passing the assessment order, the assessing officer has referred to incriminating evidence found during the course of search, data extracted from seized material, the assessee's reply in response to show cause notice and concluded that the assessee has 5 ITA No. 528-531 & 518-521/Rjt/2024 ... assessee group. 6. As details regarding an unaccounted part of the above mentioned transactions pertaining to the assessee, have been gathered from the seized material during the search operation. Therefore, the case of the assessee has been reopened under section 147 of the Act, after following the due procedure laid

DCIT, Central Circle 1, Rajkot vs. Rk Infralink LLP, Rajkot

In the result, ground No. 3 in Revenue`s appeal in ITA No

ITA 521/RJT/2024[2022-23]Status: DisposedITAT Rajkot24 Feb 2026AY 2022-23

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

Section 143(3)Section 147Section 148Section 250

Sarvanand Sonvani. While passing the assessment order, the assessing officer has referred to incriminating evidence found during the course of search, data extracted from seized material, the assessee's reply in response to show cause notice and concluded that the assessee has 5 ITA No. 528-531 & 518-521/Rjt/2024 ... assessee group. 6. As details regarding an unaccounted part of the above mentioned transactions pertaining to the assessee, have been gathered from the seized material during the search operation. Therefore, the case of the assessee has been reopened under section 147 of the Act, after following the due procedure laid

DCIT, Central Circle 1, Rajkot vs. Rk Infralink LLP, Rajkot

In the result, ground No. 3 in Revenue`s appeal in ITA No

ITA 520/RJT/2024[2021-22]Status: DisposedITAT Rajkot24 Feb 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

Section 143(3)Section 147Section 148Section 250

Sarvanand Sonvani. While passing the assessment order, the assessing officer has referred to incriminating evidence found during the course of search, data extracted from seized material, the assessee's reply in response to show cause notice and concluded that the assessee has 5 ITA No. 528-531 & 518-521/Rjt/2024 ... assessee group. 6. As details regarding an unaccounted part of the above mentioned transactions pertaining to the assessee, have been gathered from the seized material during the search operation. Therefore, the case of the assessee has been reopened under section 147 of the Act, after following the due procedure laid

DCIT, Central Circle 1, Rajkot vs. Rk Infralink LLP, Rajkot

In the result, ground No. 3 in Revenue`s appeal in ITA No

ITA 519/RJT/2024[2020-21]Status: DisposedITAT Rajkot24 Feb 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

Section 143(3)Section 147Section 148Section 250

Sarvanand Sonvani. While passing the assessment order, the assessing officer has referred to incriminating evidence found during the course of search, data extracted from seized material, the assessee's reply in response to show cause notice and concluded that the assessee has 5 ITA No. 528-531 & 518-521/Rjt/2024 ... assessee group. 6. As details regarding an unaccounted part of the above mentioned transactions pertaining to the assessee, have been gathered from the seized material during the search operation. Therefore, the case of the assessee has been reopened under section 147 of the Act, after following the due procedure laid

DCIT, Central Circle 1, Rajkot vs. Rk Infralink LLP, Rajkot

In the result, ground No. 3 in Revenue`s appeal in ITA No

ITA 518/RJT/2024[2019-20]Status: DisposedITAT Rajkot24 Feb 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

Section 143(3)Section 147Section 148Section 250

Sarvanand Sonvani. While passing the assessment order, the assessing officer has referred to incriminating evidence found during the course of search, data extracted from seized material, the assessee's reply in response to show cause notice and concluded that the assessee has 5 ITA No. 528-531 & 518-521/Rjt/2024 ... assessee group. 6. As details regarding an unaccounted part of the above mentioned transactions pertaining to the assessee, have been gathered from the seized material during the search operation. Therefore, the case of the assessee has been reopened under section 147 of the Act, after following the due procedure laid

Dinesh Jawaraji Parihar, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 4(2), Mumbai

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

ITA 5634/MUM/2025[2019-20]Status: DisposedITAT Mumbai24 Feb 2026AY 2019-20

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Umashankar Prasad, CIT-DR
Section 132Section 143(2)Section 153CSection 250Section 69

above mentioned grounds. 6. The Learned Authorised Representative (‘Ld. AR’ for short) for the assessee commenced her arguments stating that there was no seized material pertaining to the assessee and the Ld. AO merely relied on the material seized from the third party which did not establish any nexus with ... 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