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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

Deputy Commissioner of Income Tax, Central Ciecle-2, Coimbatore vs. V Sathyamoorthy Co, Erode

ITA 1547/CHNY/2024[2020-21]Status: DisposedITAT Chennai17 Oct 2024AY 2020-21
For Respondent: Shri S. Sridhar (Advocate)- Ld.AR
Section 143(3)Section 153A

Appeals) - 20, Chennai failed to appreciate that the search assessment completed by making the disputed addition(s) in the absence of valid incriminating seized material relatable to such addition(s) should be reckoned as nullity in raw and further ought to have appreciated that the judicial trend in this regard ... Appeals) - 20, Chennai failed to appreciate that the excel sheet relied upon by the Assessing Officer should not be construed as 'incriminating seized material' and further ought to have appreciated that the contents of the seized material had no evidentiary value in the absence of any corroborative evidence

V Sathyamoorthy&Co, Erode vs. DCIT, Central Circle -2, Coimbatore

The appeal stands partly allowed

ITA 1025/CHNY/2024[2021-22]Status: DisposedITAT Chennai17 Oct 2024AY 2021-22

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.1025/Chny/2024 (िनधा*रण वष* / Assessment Year: 2021-22) M/S. V. Sathyamoorthy & Co. Dcit बनाम/ 41, Patel Road, Central Circle-2 Vs. Near Blood Bank, Erode-638 001. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacfv-0222-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" की ओर से/ Assessee By : Shri S. Sridhar (Advocate)- Ld.Ar " थ" की ओर से/Revenue By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr

For Appellant: Shri S. Sridhar (Advocate)- Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR
Section 143(3)

Appeals) - 20, Chennai failed to appreciate that the search assessment completed by making the disputed addition(s) in the absence of valid incriminating seized material relatable to such addition(s) should be reckoned as nullity in law and further ought to have appreciated that the judicial trend in this regard ... Appeals) - 20, Chennai failed to appreciate that the excel sheet relied upon by the Assessing Officer should not be construed as 'incriminating seized material' and further ought to have appreciated that the contents of the seized material had no evidentiary value in the absence of any corroborative evidence

V Sathyamoorthy&Co, Erode vs. DCIT, Central Circle -, Coimbatore

ITA 1024/CHNY/2024[2020-21]Status: DisposedITAT Chennai17 Oct 2024AY 2020-21

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं. / Ita No.1024/Chny/2024 (िनधा*रण वष* / Assessment Year: 2020-21) M/S. V. Sathyamoorthy & Co. Dcit बनाम/ 41, Patel Road, Central Circle-2 Vs. Near Blood Bank, Erode-638 001. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacfv-0222-D (अपीलाथ"/Appellant) : (" थ" / Respondent) & 2. आयकरअपील सं./ Ita No.1547/Chny/2024 (िनधा*रण वष* / Assessment Year: 2020-21) Dcit M/S. V. Sathyamoorthy & Co., बनाम/ Central Circle-2 41, Patel Road, Near Blood Bank, Vs. Coimbatore. Erode-638 001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacfv-0222-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" की ओर से/ Assessee By : Shri S. Sridhar (Advocate)- Ld.Ar " थ" की ओर से/Revenue By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 29-07-2024 घोषणाकीतारीख /Date Of Pronouncement : 17-10-2024 आदेश / O R D E R

For Appellant: Shri S. Sridhar (Advocate)- Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR
Section 143(3)Section 153A

Appeals) - 20, Chennai failed to appreciate that the search assessment completed by making the disputed addition(s) in the absence of valid incriminating seized material relatable to such addition(s) should be reckoned as nullity in raw and further ought to have appreciated that the judicial trend in this regard ... Appeals) - 20, Chennai failed to appreciate that the excel sheet relied upon by the Assessing Officer should not be construed as 'incriminating seized material' and further ought to have appreciated that the contents of the seized material had no evidentiary value in the absence of any corroborative evidence

Rohit Ladiwala, Jaipur vs. DCIT, Central Circle-1, Jaipur

ITA 339/JPR/2024[2015-16]Status: DisposedITAT Jaipur17 Oct 2024AY 2015-16
For Appellant: Sh. Vinod Kumar Gupta, CAFor Respondent: MS. Alka Gautam, CIT(V.H)
Section 132(1)Section 139Section 143(2)Section 143(3)Section 153ASection 68Section 69

donors. The assessee has furnished only the copy of gift deed and id proof of the donors. The same was already available in the seized material. Thus, a show cause letter dated 26.12.2019 was issued to the assessee. The assessee has not furnished any reply to the show cause

Rajesh Motiram Panjuani, Mumbai vs. Central Circle 6(2), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 3134/MUM/2024[2016-17]Status: DisposedITAT Mumbai17 Oct 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Rajesh Motiram Panjuani, Acit Central Circle-6(2), 17 Jay Ambe, 154 Garodia Nagar, Air India Building, Churchgate, Vs. Ghatkopar (East), Mumbai-400020. Mumbai-400077. Pan No. Aahpp 6752 F Appellant Respondent

For Appellant: Mr. R.R. Makwana, Sr. DRFor Respondent: Mr. Bharat Kanabar
Section 131Section 132Section 133

order has . The Assessing Officer in the assessment order has . The Assessing Officer in the assessment order has reproduced the relevant extract of the seized material. For ready reproduced the relevant extract of the seized material. For ready reproduced the relevant extract of the seized material. For ready reference same ... meters and rate per square meter with dates tax. Details of square meters and rate per square meter with dates are mentioned in the seized material. It also contain are mentioned in the seized material. It also contains details of s details of cheque cheque cheque payments payments payments made

Ganesh Das Taneja, Najibabad vs. Deputy Commissioner of Income Tax, Central Circle, Moradabad

In the result, Appeals of the Assessee in ITA No

ITA 2621/DEL/2023[AY 2011-12]Status: DisposedITAT Delhi17 Oct 2024

Bench: Sh. Pradip Kumar Kedia & Shri Yogesh Kumar U.S.I.T.A. No. 2621/Del/2023 (A.Y 2011-12) Ganesh Das Taneja, Deputy Commissioner Ajmal Khan Road, Of Income Tax Vs. Najibabad, Central Circle, Income Uttar Pradesh, 246763, Tax Office, Civil Lines Moradabad, Uttar Pan No. Aawpt0826H Pradesh (Appellant) (Respondent) I.T.A. No. 2613/Del/2023 (A.Y 2012-13) Ganesh Das Taneja, Deputy Commissioner Ajmal Khan Road, Of Income Tax Vs. Najibabad, Central Circle, Income Uttar Pradesh, 246763, Tax Office, Civil Lines Moradabad, Pan No. Aawpt0826H Uttar Pradesh (Appellant) (Respondent)

For Appellant: Sh. Ganesh Das Taneja, Self and Sh. Vidit Taneja, CA
Section 143(3)Section 153CSection 69

case from AY 2008-09 to AY 2011-12 and in the case of the appellant the alleged income escaping assessment as per the seized material as well as that of the observation of the Assessing officer is only Rs. 48,00,000/- which is less than ... cited on this issue. 5. The Ld. CIT has erred in dismissing the ground that aforesaid additions u/s 69 merely on the basis of seized material found from the residence of third party Viral Patel and his statement, without providing the appellant an opportunity of cross- examination and in absence

Ganesh Das Taneja, Najibabad vs. Deputy Commissioner of Income Tax, Central Circle, Moradabad

In the result, Appeals of the Assessee in ITA No

ITA 2613/DEL/2023[2012-13]Status: DisposedITAT Delhi17 Oct 2024AY 2012-13

Bench: Sh. Pradip Kumar Kedia & Shri Yogesh Kumar U.S.I.T.A. No. 2621/Del/2023 (A.Y 2011-12) Ganesh Das Taneja, Deputy Commissioner Ajmal Khan Road, Of Income Tax Vs. Najibabad, Central Circle, Income Uttar Pradesh, 246763, Tax Office, Civil Lines Moradabad, Uttar Pan No. Aawpt0826H Pradesh (Appellant) (Respondent) I.T.A. No. 2613/Del/2023 (A.Y 2012-13) Ganesh Das Taneja, Deputy Commissioner Ajmal Khan Road, Of Income Tax Vs. Najibabad, Central Circle, Income Uttar Pradesh, 246763, Tax Office, Civil Lines Moradabad, Pan No. Aawpt0826H Uttar Pradesh (Appellant) (Respondent)

For Appellant: Sh. Ganesh Das Taneja, Self and Sh. Vidit Taneja, CA
Section 143(3)Section 153CSection 69

case from AY 2008-09 to AY 2011-12 and in the case of the appellant the alleged income escaping assessment as per the seized material as well as that of the observation of the Assessing officer is only Rs. 48,00,000/- which is less than ... cited on this issue. 5. The Ld. CIT has erred in dismissing the ground that aforesaid additions u/s 69 merely on the basis of seized material found from the residence of third party Viral Patel and his statement, without providing the appellant an opportunity of cross- examination and in absence

Ganadhipati Construction Private Ltd, Patna vs. PCIT, Central, Patna

In the result, all the appeals of the assessee bearing

ITA 360/PAT/2024[2021-22]Status: DisposedITAT Patna16 Oct 2024AY 2021-22

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133(6)Section 142(1)Section 143(3)Section 153CSection 263

used in section 263 is applicable to the Appellant’s case. (6) For that the Ld. Pr.CIT has erred in raising issues on the seized material in the SCN which does not pertained/ belonging to the appellant’s company. Assessment Years: 2017-2018to 2021-2022 Gandhipati Construction Private Limited ... that the Ld. Pr.CIT has erred in passing the assessment order without raising queries or making enquiries and verification vis-a-vis the seized material. (20) For that the Ld. Pr.CIT has erred in holding that regular books of accounts were neither found during the course of search action

Ganadhipati Construction Private Limited, Patna vs. PCIT, Central, Patna

In the result, all the appeals of the assessee bearing

ITA 359/PAT/2024[2020-21]Status: DisposedITAT Patna16 Oct 2024AY 2020-21

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133(6)Section 142(1)Section 143(3)Section 153CSection 263

used in section 263 is applicable to the Appellant’s case. (6) For that the Ld. Pr.CIT has erred in raising issues on the seized material in the SCN which does not pertained/ belonging to the appellant’s company. Assessment Years: 2017-2018to 2021-2022 Gandhipati Construction Private Limited ... that the Ld. Pr.CIT has erred in passing the assessment order without raising queries or making enquiries and verification vis-a-vis the seized material. (20) For that the Ld. Pr.CIT has erred in holding that regular books of accounts were neither found during the course of search action

Ganadhipati Construction Private Limited, Patna vs. PCIT, Central, Patna

In the result, all the appeals of the assessee bearing

ITA 358/PAT/2024[2019-20]Status: DisposedITAT Patna16 Oct 2024AY 2019-20

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133(6)Section 142(1)Section 143(3)Section 153CSection 263

used in section 263 is applicable to the Appellant’s case. (6) For that the Ld. Pr.CIT has erred in raising issues on the seized material in the SCN which does not pertained/ belonging to the appellant’s company. Assessment Years: 2017-2018to 2021-2022 Gandhipati Construction Private Limited ... that the Ld. Pr.CIT has erred in passing the assessment order without raising queries or making enquiries and verification vis-a-vis the seized material. (20) For that the Ld. Pr.CIT has erred in holding that regular books of accounts were neither found during the course of search action

Ganadhipati Construction Pvt Ltd, Patna vs. PCIT, Central, Patna

In the result, all the appeals of the assessee bearing

ITA 357/PAT/2024[2018-19]Status: DisposedITAT Patna16 Oct 2024AY 2018-19

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133(6)Section 142(1)Section 143(3)Section 153CSection 263

used in section 263 is applicable to the Appellant’s case. (6) For that the Ld. Pr.CIT has erred in raising issues on the seized material in the SCN which does not pertained/ belonging to the appellant’s company. Assessment Years: 2017-2018to 2021-2022 Gandhipati Construction Private Limited ... that the Ld. Pr.CIT has erred in passing the assessment order without raising queries or making enquiries and verification vis-a-vis the seized material. (20) For that the Ld. Pr.CIT has erred in holding that regular books of accounts were neither found during the course of search action

Ganadhipati Construction Private Limited, Patna vs. PCIT, Central, Patna

In the result, all the appeals of the assessee bearing

ITA 356/PAT/2024[2017-18]Status: DisposedITAT Patna16 Oct 2024AY 2017-18

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 133(6)Section 142(1)Section 143(3)Section 153CSection 263

used in section 263 is applicable to the Appellant’s case. (6) For that the Ld. Pr.CIT has erred in raising issues on the seized material in the SCN which does not pertained/ belonging to the appellant’s company. Assessment Years: 2017-2018to 2021-2022 Gandhipati Construction Private Limited ... that the Ld. Pr.CIT has erred in passing the assessment order without raising queries or making enquiries and verification vis-a-vis the seized material. (20) For that the Ld. Pr.CIT has erred in holding that regular books of accounts were neither found during the course of search action

Sadhwani Wood Product Private Ltd, Kota vs. Principal Commissioner of Income Tax, (Central) Jaipur, Jaipur

In the result, both the appeal of the assessee are allowed

ITA 398/JPR/2024[2019-2020]Status: DisposedITAT Jaipur16 Oct 2024AY 2019-2020
For Appellant: Sh. Sidharth Ranka, Adv. &For Respondent: Sh. Arvind Kumar, CIT
Section 115BSection 143(3)Section 253(5)Section 263Section 5Section 69A

page 163 to184, the assessee has accepted out of books sales to the tune of Rs. 22,40,32,276/- based on the seized material. Since, the same was not declared in the return of income, the then AO has made an addition ... with the prior approval of the Joint Commissioner. Before us, the Id. Counsel for the assessee stated that for the search assessment cases whatever seized material are found 28 ITA Nos. 922 & 398/JP/2024 Sadhwani Wood Products Private Ltd. vs. PCIT belonging/pertaining to the assessee, a copy of complete

ITO, Ward-1, Dhule vs. Mitul Jagdishchandra Shah, Nandurbar

ITA 1433/PUN/2023[2015-16]Status: DisposedITAT Pune15 Oct 2024AY 2015-16

Bench: Shri

For Appellant: Shri R. ShahFor Respondent: Shri Keyur Patel, CIT-DR And
Section 143(1)Section 143(3)Section 148Section 151

Income-tax 124 Taxman 392 (Gujarat), the Hon'ble High Court of Gujarat has hetd 13. it is settied legal position that the seized material fas to be read and accepled as a whole and it is not permissible to pick and choose or make further estimates therefrom unless ... learned lower authorities have made addition of Rs.9,55,65,676/- in assessee’s hands based on the relevant entries made in the seized material coupled with his post-survey sec.131 statement(s). Mr. Shah claims at the same time that the assessee’s multiple post-survey statement

Income Tax Officer, Ward-1, Dhule vs. Mitul Jagdishchandra Shah, Nandurbar

ITA 1432/PUN/2023[2010-11]Status: DisposedITAT Pune15 Oct 2024AY 2010-11

Bench: Shri

For Appellant: Shri R. ShahFor Respondent: Shri Keyur Patel, CIT-DR And
Section 143(1)Section 143(3)Section 148Section 151

Income-tax 124 Taxman 392 (Gujarat), the Hon'ble High Court of Gujarat has hetd 13. it is settied legal position that the seized material fas to be read and accepled as a whole and it is not permissible to pick and choose or make further estimates therefrom unless ... learned lower authorities have made addition of Rs.9,55,65,676/- in assessee’s hands based on the relevant entries made in the seized material coupled with his post-survey sec.131 statement(s). Mr. Shah claims at the same time that the assessee’s multiple post-survey statement

Mitul Jagdishchandra Shah, Surat vs. Assistant Commissioner of Income-Tax, Circle - Dhule, Dhule

ITA 1339/PUN/2023[2015-16]Status: DisposedITAT Pune15 Oct 2024AY 2015-16

Bench: Shri

For Appellant: Shri R. ShahFor Respondent: Shri Keyur Patel, CIT-DR And
Section 143(1)Section 143(3)Section 148Section 151

Income-tax 124 Taxman 392 (Gujarat), the Hon'ble High Court of Gujarat has hetd 13. it is settied legal position that the seized material fas to be read and accepled as a whole and it is not permissible to pick and choose or make further estimates therefrom unless ... learned lower authorities have made addition of Rs.9,55,65,676/- in assessee’s hands based on the relevant entries made in the seized material coupled with his post-survey sec.131 statement(s). Mr. Shah claims at the same time that the assessee’s multiple post-survey statement

Mitul Jagdishchandra Shah, Surat vs. Assistant Commissioner of Income-Tax, Circle, Dhule

ITA 1338/PUN/2023[2010-11]Status: DisposedITAT Pune15 Oct 2024AY 2010-11

Bench: Shri

For Appellant: Shri R. ShahFor Respondent: Shri Keyur Patel, CIT-DR And
Section 143(1)Section 143(3)Section 148Section 151

Income-tax 124 Taxman 392 (Gujarat), the Hon'ble High Court of Gujarat has hetd 13. it is settied legal position that the seized material fas to be read and accepled as a whole and it is not permissible to pick and choose or make further estimates therefrom unless ... learned lower authorities have made addition of Rs.9,55,65,676/- in assessee’s hands based on the relevant entries made in the seized material coupled with his post-survey sec.131 statement(s). Mr. Shah claims at the same time that the assessee’s multiple post-survey statement

St.Joseph'S Educational Trust, Chennai vs. PCIT Central Chennai - 1, Chennai

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

ITA 1620/CHNY/2024[2020-21]Status: DisposedITAT Chennai15 Oct 2024AY 2020-21

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Shri Nilay Baran Som, IRS, CIT
Section 11Section 115BSection 12ASection 142(1)Section 153ASection 153DSection 263

sheet as 'cash' were offered to tax "anonymous donations" and paid taxes thereon under section 115BBC of the Act. The seized material Ann/JCE/ANJ/ED/S-1 does not mention that the alleged receipts are capitation fees. The assessees have also offered to tax those receipts in the form of DD, which were already ... aggregate of income: During the course of search in the case of the assessee trust on 07.11.2019, it was noticed from the seized material Ann/JCE/ANJ/ED/S-1 that the assessee had collected capitation fees by way of cash which was not accounted in the books of account. The trustee of the assessee

St.Joseph'S Institute of Science and Technology Trust, Chennai vs. PCIT Central Chennai - 1, Chennai

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

ITA 1619/CHNY/2024[2020-21]Status: DisposedITAT Chennai15 Oct 2024AY 2020-21

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Shri Nilay Baran Som, IRS, CIT
Section 11Section 115BSection 12ASection 142(1)Section 153ASection 153DSection 263

sheet as 'cash' were offered to tax "anonymous donations" and paid taxes thereon under section 115BBC of the Act. The seized material Ann/JCE/ANJ/ED/S-1 does not mention that the alleged receipts are capitation fees. The assessees have also offered to tax those receipts in the form of DD, which were already ... aggregate of income: During the course of search in the case of the assessee trust on 07.11.2019, it was noticed from the seized material Ann/JCE/ANJ/ED/S-1 that the assessee had collected capitation fees by way of cash which was not accounted in the books of account. The trustee of the assessee

St.Joseph'S Institute of Science and Technology Trust, Chennai vs. PCIT Central Chennai - 1, Chennai

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

ITA 1618/CHNY/2024[2018-19]Status: DisposedITAT Chennai15 Oct 2024AY 2018-19
Section 11Section 115BSection 12ASection 142(1)Section 153ASection 153DSection 263

mentioned in the excel sheet as 'cash' were offered to tax "anonymous donations" and paid taxes thereon under section 115BBC of the Act. The seized material Ann/JCE/ANJ/ED/S-1 does not mention that the alleged receipts are capitation fees. The assessees have also offered to tax those receipts in the form ... aggregate of income: During the course of search in the case of the assessee trust on 07.11.2019, it was noticed from the seized material Ann/JCE/ANJ/ED/S-1 that the assessee had collected capitation fees by way of cash which was not accounted in the books of account. The trustee of the assessee