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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

Srinivasa Reddy Yeturu, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1898/HYD/2025[2022-23]Status: DisposedITAT Hyderabad18 Feb 2026AY 2022-23

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1898/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2022-23) Shri Srinivasa Reddy Yeturu, Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aalpy0486H Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, C.A राज" व "ारा/Revenue By: Shri Ashuthosh Pradhan, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 10/12/2025 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee, Which Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), 11, Hyderabad, Dated 01/10/2025, For The A.Y 2022-23. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, C.AFor Respondent: Shri Ashuthosh Pradhan, Sr. AR
Section 132Section 143(2)Section 153Section 69ASection 80DSection 80E

having the jurisdiction over the assessee shall be excluded. In the present case, as per the letter of the A.O, the seized material in the group was received by the A.O on 22/08/2023 and if we consider clause (xii) of Exp.(1) to section 153 of the Act, the period ... clause (xii) of section 153 of the Act. The search in the present case was on 4/1/2023 and the A.O received the seized material on 22/08/2023. The above period taken by the A.O of the searched person falls in two financial years i.e. from 4/1/2023 to 31/3/2023 falls in financial

Exel Rubber Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1895/HYD/2025[2022-23]Status: DisposedITAT Hyderabad18 Feb 2026AY 2022-23

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1895/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2022-23) M/S. Exel Rubber (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaace4495J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 20/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad Dated 09/10/2025 For The A.Y 2022-23. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 143(2)Section 153Section 250

having the jurisdiction over the assessee shall be excluded. In the present case, as per the letter of the A.O, the seized material in the group was received by the A.O on 22/08/2023 and if we consider clause (xii) of Exp.(1) to section 153 of the Act, the period ... clause (xii) of section 153 of the Act. The search in the present case was on 4/1/2023 and the A.O received the seized material on 22/08/2023. The above period taken by the A.O of the searched person falls in two financial years i.e. from 4/1/2023 to 31/3/2023 falls in financial

Exel Rubber Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 1894/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1894/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2014-15) M/S. Exel Rubber (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaace4495J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 20/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11 Hyderabad, Dated 11/10/2025 For The A.Y 2014-15. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 143(2)Section 143(3)Section 147Section 148Section 149(1)Section 69A

Exel Rubber Private Ltd 9. The learned Counsel for the assessee has pointed out that since the seized material was found from the possession of the other person than the assessee, then the Assessing Officer was required to take approval from the Pr. CIT as per clause (iv) of Explanation ... beyond 3 years from the end of the A.Ys and the Assessing Officer has failed to satisfy the mandatory conditions that the seized material and other documents/evidence in the possession of the Assessing Officer revealed the income escaped the assessment represented by an asset or entries in the books

Ace Tyres Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1893/HYD/2025[2022-23]Status: DisposedITAT Hyderabad18 Feb 2026AY 2022-23

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1893/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2022-23) M/S. Ace Tyres (P) Ltd Vs. Dy.Cit Hyderabad Central Circle (1)2 Pan:Aadca2210N Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 20/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per. Manjunatha, G. A.M. This Appeal Is Filed By The Assessee Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Dated 16/10/2025 For The A.Y 2022-23. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT
Section 143(2)Section 148Section 153

having the jurisdiction over the assessee shall be excluded. In the present case, as per the letter of the A.O, the seized material in the group was received by the A.O on 22/08/2023 and if we consider clause (xii) of Exp.(1) to section 153 of the Act, the period ... clause (xii) of section 153 of the Act. The search in the present case was on 4/1/2023 and the A.O received the seized material on 22/08/2023. The above period taken by the A.O of the searched person falls in two financial years i.e. from 4/1/2023 to 31/3/2023 falls in financial

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee allowed

ITA 1885/HYD/2025[2022-23]Status: DisposedITAT Hyderabad18 Feb 2026AY 2022-23

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1885/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2022-23) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Dated 31/10/2025 For The A.Y 2022-23. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT
Section 143(2)Section 153

having the jurisdiction over the assessee shall be excluded. In the present case, as per the letter of the A.O, the seized material in the group was received by the A.O on 22/08/2023 and if we consider clause (xii) of Exp.(1) to section 153 of the Act, the period ... clause (xii) of section 153 of the Act. The search in the present case was on 4/1/2023 and the A.O received the seized material on 22/08/2023. The above period taken by the A.O of the searched person falls in two financial years i.e. from 4/1/2023 to 31/3/2023 falls in financial

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1884/HYD/2025[2021-22]Status: DisposedITAT Hyderabad18 Feb 2026AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 132(4)Section 143(1)Section 143(3)Section 148

which notice under section 148 of the Act is issued. In the present case, the A.O without demonstrating as to how the seized material found during the course of search suggest income escaped the assessment for the relevant Asst. Years has simply issued notice under section ... DELL Laptop and copied to the Pen Driver before taking printout during the course of search. Since the A.O has relied upon the seized material found during the course of search in the case of Shri Ramesh Kumar Sanaka, Sr. Accounts Manager, for framing the assessment of the assessee

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1876/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 132(4)Section 143(1)Section 143(3)Section 148

which notice under section 148 of the Act is issued. In the present case, the A.O without demonstrating as to how the seized material found during the course of search suggest income escaped the assessment for the relevant Asst. Years has simply issued notice under section ... DELL Laptop and copied to the Pen Driver before taking printout during the course of search. Since the A.O has relied upon the seized material found during the course of search in the case of Shri Ramesh Kumar Sanaka, Sr. Accounts Manager, for framing the assessment of the assessee

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1874/HYD/2025[2018-19]Status: DisposedITAT Hyderabad18 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-
Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

authority as provided in section 151(ii) of the I.T. Act. 9. The learned Counsel for the assessee has pointed out that since the seized material was found from the possession of the other person than the assessee, then the Assessing Officer was required to take approval from ... beyond 3 years from the end of the A.Ys and the Assessing Officer has failed to satisfy the mandatory conditions that the seized material and other documents/evidence in the possession of the Assessing Officer revealed the income escaped the assessment represented by an asset or entries in 10 ITA.Nos

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1872/HYD/2025[2016-17]Status: DisposedITAT Hyderabad18 Feb 2026AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-
Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

authority as provided in section 151(ii) of the I.T. Act. 9. The learned Counsel for the assessee has pointed out that since the seized material was found from the possession of the other person than the assessee, then the Assessing Officer was required to take approval from ... beyond 3 years from the end of the A.Ys and the Assessing Officer has failed to satisfy the mandatory conditions that the seized material and other documents/evidence in the possession of the Assessing Officer revealed the income escaped the assessment represented by an asset or entries in 10 ITA.Nos

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1870/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-
Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

authority as provided in section 151(ii) of the I.T. Act. 9. The learned Counsel for the assessee has pointed out that since the seized material was found from the possession of the other person than the assessee, then the Assessing Officer was required to take approval from ... beyond 3 years from the end of the A.Ys and the Assessing Officer has failed to satisfy the mandatory conditions that the seized material and other documents/evidence in the possession of the Assessing Officer revealed the income escaped the assessment represented by an asset or entries in 10 ITA.Nos

Exel Rubber Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1566/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.आ. अपी.सं / Ita Nos.1566 & 1571/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2020-21 & 2021-22) M/S. Exel Rubber Private Ltd Vs. Hyderabad Dy.Cit Central Circle 1 (2) Hyderabad Pan:Aaace4495J (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V. Prasad, Ca राजस्व द्वारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख / Date Of Hearing: 20/01/2026 घोषणा की तारीख / Pronouncement: 18/02/2026 Per Manjunatha, G. A.M. आदेश/Order These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 14/07/2025 For The A.Ys 2020-21, 2021-22 & 2022-23 Respectively. Since Common Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 132(4)Section 143(3)Section 148

which notice under section 148 of the Act is issued. In the present case, the A.O without demonstrating as to how the seized material found during the course of search suggest income escaped the assessment for the relevant Asst. Years has simply issued notice under section ... DELL Laptop and copied to the Pen Driver before taking printout during the course of search. Since the A.O has relied upon the seized material found during the course of search in the case of Shri Ramesh Kumar Sanaka, Sr. Accounts Manager, for framing the assessment of the assessee