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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

ACIT-CC-1(3), Mumbai vs. Bhagwati Developers, Navi Mumbai

In the result ground number 1 and 2 of the appeal for assessment year 2015 – 16 of the learned assessing officer are dismissed

ITA 1346/MUM/2024[2012-13]Status: DisposedITAT Mumbai08 Oct 2024AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shriraj Kumar Chauhan, Jm A.Y.2012-13 A.Y.2015-16 Acit-Central Circle-1(3), Bhagwati Developers, Mumbai 1306, 13Th Floor, Vs. Real Tech Park, Plot No.39/2, Sector-30A, Vashi Navi Mumbai Co No. 80/Mum/2024 A.Y. 2012-13 [Ita No. 1346/Mum/2024] Bhagwati Developers, Acit-Central Circle-1(3), 1306, 13Th Floor, Mumbai Real Tech Park, Plot No.39/2, Sector-30A, Vashi Navi Mumbai Pan Aalfb 5272C A.Y. 2012-13 Acit-Central Circle-1(3), Ms. Shanti Enterprises, Mumbai Office No. 1306, Real Tech Park, Plot No.39/2, Sector-30A Vashi Co No. 110/Mum/2024 A.Y. 2012-13 [Ita No. 1349/Mum/2024] Ms. Shanti Enterprises, Acit-Central Circle-1(3), Office No. 1306, Real Tech Mumbai Park, Plot No.39/2, Sector-30A Vashi (Appellant) (Respondent) Assessee By Shri Mani Jain & Shri Prateek Jain

Section 132Section 143Section 153ASection 69C

only when the source for the same is not explained that in the present case the source of the expenditure is in the same seized material which is already been taxed by the assessing ITA No.1346,1349 & 1490/M/2024 CO 80, 110/Mum/2024 A Y : 2012–13, 2015-16 Bhagwati Developers & others ... interim board for settlement has already accepted the chargeability of the profit at the rate of 12.25% of the gross receipt therefore when the seized material is the same and issues also related to the same search, there is no reason to take any different view. He further relied upon

Gemco International, Jaipur vs. Income Tax Officer Ward 2(1), Jaipur

In the result, the appeal filed by the assessee stands partly allowed with no order as to cost

ITA 410/JPR/2024[2012-13]Status: DisposedITAT Jaipur04 Oct 2024AY 2012-13

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Vivek Bhargava, CAFor Respondent: Shri Gautam Singh Choudhary,JCIT-DR
Section 143(3)Section 147Section 148Section 153ASection 153C

confirming the assumption of jurisdiction by the Id. AO u/s 147/148 whereas the assessment of other person other than the searched person based on seized material can be made u/s 153C read with section 153A. 2. The Id. CIT (Appeals) erred in law and on facts in confirming the issuance ... confirming the assumption of jurisdiction by the ld. AO u/s 147/148 whereas the assessment of other person other than the searched person based on seized material can be made u/s 153C read with section 153A. Order passed by ld. CIT (Appeals) 2. Assessee raised this ground of appeal as ground

M/S Inland World Logistics Pvt. Ltd., Kolkata vs. PCIT(Cen.)- Kolkata-2, Kolkata

In the result, the appeal of the assessee is allowed

ITA 935/KOL/2024[2018-19]Status: DisposedITAT Kolkata03 Oct 2024AY 2018-19

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rakesh Mishrai.T.A. No. 935/Kol/2024 Assessment Year: 2018-2019 M/S. Inland World Logistics Pvt. Limited,…Appellant P-221/2, Strand Bank Road, Burrabazar, Kolkata-700001 [Pan:Aaaci5607C] -Vs.- Principal Commissioner Of Income Tax (Central), Kolkata-2,…………………………………………..…Respondent Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Rakesh Jain, Fca, Appeared On Behalf Of The Assessee Shri Subhendu Datta, Cit (D.R.) & Smt. Monali Shaha Mukherjee, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: July 25, 2024 Date Of Pronouncing The Order: October 03, 2024 O R D E R

Section 132Section 139Section 139(1)Section 143(1)Section 143(2)Section 153ASection 263

Assessing Officer has accepted the original returned income of the assessee filed under section 139. He did not make any addition because no seized material was found. He passed the assessment order on 31.03.2022. 4. The ld. Pr. CIT assumed jurisdiction under section 263 on the ground that the assessee

DCIT, Central Circle-1, Jaipur vs. Mahaveer Kumar Jain, Jaipur

ITA 469/JPR/2024[2011]Status: DisposedITAT Jaipur03 Oct 2024
For Appellant: Shri Tanju Agarwal AdvocateFor Respondent: Shri Ajey Malik, CIT-DR
Section 69

Kalyan Hotel & Resorts, Rajendra Prasad Nagar, Jaipur, various incriminating documents as well as digital data were found and seized. On verification of seized material, it was noticed that the assessee has made huge investment in the construction of the Hotel K. Mahaveer but no such investment was declared

The Pr. Commissioner of Income Tax, CIT (A) vs. Smt. Ambika Ghorpade

The appeal is disposed of with liberty as prayed for by the learned

ITA/719/2018HC Karnataka01 Oct 2024

Bench: S.G.PANDIT,C.M. POONACHA

Section 260

does not belong to the assessee, when Sri. Bharat S. Ghorpade was the key person looking after the business of the assessee and the seized material has a nexus with the business carried on and transactions reflected in cheque have been corroborated with the books of accounts maintained ... recorded perverse finding? 2. Whether on the facts and in the circumstances of the case, the Tribunal is right in holding that the seized material found in the premises of Sri. Bharat S. Ghorpade and Sri. Karthikeya Ghropade cannot be relied on in the case of the assessee, when

The Pr. Commissioner of Income Tax, CIT (A) vs. M/S. Bmm Ispat Ltd

The appeal is disposed of with liberty as prayed for by the learned

ITA/685/2018HC Karnataka01 Oct 2024

Bench: S.G.PANDIT,C.M. POONACHA

Section 132Section 132ASection 153ASection 260

when Section 153A of the act does not contemplate assessment on the basis of the seized material?. 2. Whether on the facts and in the circumstances of the case, the Tribunal was correct in holding that in order to sustain addition/disallowances, the same should be on the basis

Vinod Sanwaldas Dhingra, Nagpur vs. Assistant Commissioner of Income Tax Central Circle-2(2), Nagpur

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

ITA 375/NAG/2023[2020-2021]Status: DisposedITAT Nagpur01 Oct 2024AY 2020-2021

Bench: Shri V. Durga Rao

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Sandeep Salonkhe
Section 132(1)Section 143(3)Section 234A

Income Tax (Appeals)-3, Nagpur erred in making addition of noting and jotting made by the Kamnani group and relied on the rough seized material from the premises of Kamnani group and without granting any opportunity to cross examine and on the basis of rough noting and jotting treated ... recorded in the books of account of the assessee, hence there is no question of transactions made in cash, which were shown in the seized materials. The Assessing Officer has not accepted the contention of the assessee and treated unaccounted cash transaction and made addition

Msn Institute of Medical Sciences Private Limited, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

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

ITA 483/HYD/2024[2015-16]Status: DisposedITAT Hyderabad01 Oct 2024AY 2015-16

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No. 483/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2015-16) Msn Institute Of Medical Vs. Asstt. C. I. T. Sciences Private Ltd Central Circle 2(4) Hyderabad Hyderabad Pan:Aajcm1030E (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Cas Shri M.V. Prasad & Shri K.S Rajendra Kumar राज" व "ारा/Revenue By:: Shri Srinath Sadanala, Dr सुनवाई की तारीख/Date Of Hearing: 05/09/2024 घोषणा की तारीख/Pronouncement: 01/10/2024

For Appellant: CAs Shri M.V. Prasad and ShriFor Respondent: : Shri Srinath Sadanala, DR
Section 132Section 69

Institute of Medical Sciences P Ltd with written affidavit and also explained the contents of the seized material. Therefore, the question of offering additional income as per the seized document does not arise. The Assessing Officer however, was not convinced with the explanation of the assessee and according

Shri. Irulandi Thevar Vetrivel, Madurai vs. ACIT, Central Cricle 2, Madurai

In the result, all the appeals of the Revenue are dismissed and the appeals of the assessee are partly allowed

ITA 240/CHNY/2024[2021-22]Status: DisposedITAT Chennai01 Oct 2024AY 2021-22

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Shri Y Sridhar, FCAFor Respondent: Shri R Clement Ramesh
Section 132Section 139Section 139(1)Section 153ASection 37Section 65B

Loss Account extracted from the seized tally software was reproduced by the AO in the impugned assessment orders. 4. Upon analysis of the above seized material i.e. the tally software, the AO was of the view that, the tally data revealed that, the assessee had understated his taxable income ... month-wise cash payments debited under the head ‘Coolie & Wages’ which was of identical amount. 6. It is noted that, the above seized material, findings, and the statements were put to the assessee for his explanation. The AO noted that, the assessee only filed the retraction statements of the employees

Shri. Irulandi Thevar Vetrivel, Madurai vs. ACIT, Central Circle 2, Madurai

In the result, all the appeals of the Revenue are dismissed and the appeals of the assessee are partly allowed

ITA 239/CHNY/2024[2020-21]Status: DisposedITAT Chennai01 Oct 2024AY 2020-21

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Shri Y Sridhar, FCAFor Respondent: Shri R Clement Ramesh
Section 132Section 139Section 139(1)Section 153ASection 37Section 65B

Loss Account extracted from the seized tally software was reproduced by the AO in the impugned assessment orders. 4. Upon analysis of the above seized material i.e. the tally software, the AO was of the view that, the tally data revealed that, the assessee had understated his taxable income ... month-wise cash payments debited under the head ‘Coolie & Wages’ which was of identical amount. 6. It is noted that, the above seized material, findings, and the statements were put to the assessee for his explanation. The AO noted that, the assessee only filed the retraction statements of the employees

Shri. Irulandi Thevar Vetrivel, Madurai vs. ACIT, Central Circle 2, Madurai

ITA 238/CHNY/2024[2019-20]Status: DisposedITAT Chennai01 Oct 2024AY 2019-20

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos. 131 To 136/Chny/2024 निर्धारण वर्ष/Assessment Years: 2016-17 To 2021-22 The Acit, Central Circle-2, Madurai. (अपीलार्थी/Appellant) V. Shri Irulandi Thevar Vetrivel, No.3/1, Ashok Nagar, 4Th Street, Palamedu Main Road, Madurai - 625 018. [Pan: Acopv 5310 J] (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos. 235 To 240/Chny/2024 निर्धारण वर्ष/Assessment Years: 2016-17 To 2021-22 Shri Irulandi Thevar Vetrivel, No.3/1, Ashok Nagar, 4Th Street, Palamedu Main Road, Madurai - 625 018. [Pan: Acopv_5310 J] (अपीलार्थी/Appellant) V. The Acit, Central Circle-2, Madurai. (प्रत्यर्थी/Respondent) Department By : Shri R Clement Ramesh Kumar, Cit-Dr Assessee By : Shri Y Sridhar, Fca सुनवाईकीतारीख/Date Of Hearing : 12.08.2024 घोषणाकीतारीख /Date Of Pronouncement : 01.10.2024

For Appellant: Shri Y Sridhar, FCAFor Respondent: Shri R Clement Ramesh
Section 132Section 139Section 139(1)Section 153ASection 37Section 65B

Loss Account extracted from the seized tally software was reproduced by the AO in the impugned assessment orders. 4. Upon analysis of the above seized material i.e. the tally software, the AO was of the view that, the tally data revealed that, the assessee had understated his taxable income ... month-wise cash payments debited under the head 'Coolie & Wages' which was of identical amount. 6. It is noted that, the above seized material, findings, and the statements were put to the assessee for his explanation. The AO noted that, the assessee only filed the retraction statements of the employees

Shri. Irulandi Thevar Vetrivel, Madurai vs. ACIT, Central, Circle 2, Madurai

ITA 237/CHNY/2024[2018-19]Status: DisposedITAT Chennai01 Oct 2024AY 2018-19

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos. 131 To 136/Chny/2024 निर्धारण वर्ष/Assessment Years: 2016-17 To 2021-22 The Acit, Central Circle-2, Madurai. (अपीलार्थी/Appellant) V. Shri Irulandi Thevar Vetrivel, No.3/1, Ashok Nagar, 4Th Street, Palamedu Main Road, Madurai - 625 018. [Pan: Acopv 5310 J] (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos. 235 To 240/Chny/2024 निर्धारण वर्ष/Assessment Years: 2016-17 To 2021-22 Shri Irulandi Thevar Vetrivel, No.3/1, Ashok Nagar, 4Th Street, Palamedu Main Road, Madurai - 625 018. [Pan: Acopv_5310 J] (अपीलार्थी/Appellant) V. The Acit, Central Circle-2, Madurai. (प्रत्यर्थी/Respondent) Department By : Shri R Clement Ramesh Kumar, Cit-Dr Assessee By : Shri Y Sridhar, Fca सुनवाईकीतारीख/Date Of Hearing : 12.08.2024 घोषणाकीतारीख /Date Of Pronouncement : 01.10.2024

For Appellant: Shri Y Sridhar, FCAFor Respondent: Shri R Clement Ramesh
Section 132Section 139Section 139(1)Section 153ASection 37Section 65B

Loss Account extracted from the seized tally software was reproduced by the AO in the impugned assessment orders. 4. Upon analysis of the above seized material i.e. the tally software, the AO was of the view that, the tally data revealed that, the assessee had understated his taxable income ... month-wise cash payments debited under the head 'Coolie & Wages' which was of identical amount. 6. It is noted that, the above seized material, findings, and the statements were put to the assessee for his explanation. The AO noted that, the assessee only filed the retraction statements of the employees

Shir. Irulandi Thevar Vetrivel, Madurai vs. ACIT, Central Circle 2, Madurai

In the result, all the appeals of the Revenue are dismissed and the appeals of the assessee are partly allowed

ITA 236/CHNY/2024[2017-18]Status: DisposedITAT Chennai01 Oct 2024AY 2017-18

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Shri Y Sridhar, FCAFor Respondent: Shri R Clement Ramesh
Section 132Section 139Section 139(1)Section 153ASection 37Section 65B

Loss Account extracted from the seized tally software was reproduced by the AO in the impugned assessment orders. 4. Upon analysis of the above seized material i.e. the tally software, the AO was of the view that, the tally data revealed that, the assessee had understated his taxable income ... month-wise cash payments debited under the head ‘Coolie & Wages’ which was of identical amount. 6. It is noted that, the above seized material, findings, and the statements were put to the assessee for his explanation. The AO noted that, the assessee only filed the retraction statements of the employees

Shri. Irulandi Thevar Vetrivel, Madurai vs. ACIT, Central Circle 2, Madurai

In the result, all the appeals of the Revenue are dismissed and the appeals of the assessee are partly allowed

ITA 235/CHNY/2024[2016-17]Status: DisposedITAT Chennai01 Oct 2024AY 2016-17

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Shri Y Sridhar, FCAFor Respondent: Shri R Clement Ramesh
Section 132Section 139Section 139(1)Section 153ASection 37Section 65B

Loss Account extracted from the seized tally software was reproduced by the AO in the impugned assessment orders. 4. Upon analysis of the above seized material i.e. the tally software, the AO was of the view that, the tally data revealed that, the assessee had understated his taxable income ... month-wise cash payments debited under the head ‘Coolie & Wages’ which was of identical amount. 6. It is noted that, the above seized material, findings, and the statements were put to the assessee for his explanation. The AO noted that, the assessee only filed the retraction statements of the employees

A.Govindaraj, Deputy Commissioner of Income Tax, Central Circle-2, Madurai, Central Range vs. Irulandi Thevar Vetrivel, Palamedu Main Road Madurai

ITA 132/CHNY/2024[2017-2018]Status: DisposedITAT Chennai01 Oct 2024AY 2017-2018

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos. 131 To 136/Chny/2024 निर्धारण वर्ष/Assessment Years: 2016-17 To 2021-22 The Acit, Central Circle-2, Madurai. (अपीलार्थी/Appellant) V. Shri Irulandi Thevar Vetrivel, No.3/1, Ashok Nagar, 4Th Street, Palamedu Main Road, Madurai - 625 018. [Pan: Acopv 5310 J] (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos. 235 To 240/Chny/2024 निर्धारण वर्ष/Assessment Years: 2016-17 To 2021-22 Shri Irulandi Thevar Vetrivel, No.3/1, Ashok Nagar, 4Th Street, Palamedu Main Road, Madurai - 625 018. [Pan: Acopv 5310 J] (अपीलार्थी/Appellant) V. The Acit, Central Circle-2, Madurai. (प्रत्यर्थी/Respondent) Department By : Shri R Clement Ramesh Kumar, Cit-Dr Assessee By : Shri Y Sridhar, Fca सुनवाईकीतारीख/Date Of Hearing : 12.08.2024 घोषणाकीतारीख /Date Of Pronouncement : 01.10.2024

For Appellant: Shri Y Sridhar, FCAFor Respondent: Shri R Clement Ramesh
Section 132Section 139Section 139(1)Section 153ASection 37Section 65B

Loss Account extracted from the seized tally software was reproduced by the AO in the impugned assessment orders. 4. Upon analysis of the above seized material i.e. the tally software, the AO was of the view that, the tally data revealed that, the assessee had understated his taxable income ... month-wise cash payments debited under the head 'Coolie & Wages' which was of identical amount. 6. It is noted that, the above seized material, findings, and the statements were put to the assessee for his explanation. The AO noted that, the assessee only filed the retraction statements of the employees

Deputy Commissioner of Income Tax, Centralcircle-2, Madurai vs. Irulandi Thevar Vetrivel, Palamedu Main Road, Madurai

ITA 131/CHNY/2024[2016-2017]Status: DisposedITAT Chennai01 Oct 2024AY 2016-2017

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos. 131 To 136/Chny/2024 निर्धारण वर्ष/Assessment Years: 2016-17 To 2021-22 The Acit, Central Circle-2, Madurai. V. Shri Irulandi Thevar Vetrivel, No.3/1, Ashok Nagar, 4Th Street, Palamedu Main Road, Madurai - 625 018. (अपीलार्थी/Appellant) [Pan: Acopv 5310 J] (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos. 235 To 240/Chny/2024 निर्धारण वर्ष/Assessment Years: 2016-17 To 2021-22 Shri Irulandi Thevar Vetrivel, No.3/1, Ashok Nagar, 4Th Street, Palamedu Main Road, Madurai - 625 018. V. The Acit, Central Circle-2, Madurai. [Pan: Acopv_5310 J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Department By Assessee By : Shri R Clement Ramesh Kumar, Cit-Dr : Shri Y Sridhar, Fca सुनवाईकीतारीख/Date Of Hearing : 12.08.2024 घोषणाकीतारीख /Date Of Pronouncement : 01.10.2024

For Appellant: Shri R Clement Ramesh
Section 132Section 139Section 139(1)Section 153ASection 37Section 65B

Loss Account extracted from the seized tally software was reproduced by the AO in the impugned assessment orders. 4. Upon analysis of the above seized material i.e. the tally software, the AO was of the view that, the tally data revealed that, the assessee had understated his taxable income ... month-wise cash payments debited under the head 'Coolie & Wages' which was of identical amount. 6. It is noted that, the above seized material, findings, and the statements were put to the assessee for his explanation. The AO noted that, the assessee only filed the retraction statements of the employees

Jagdishchandra Prahladdas Pasari, Thane vs. ITO Ward 14, Thane

In the result, appeal of the assessee is dismissed

ITA 6263/MUM/2019[1997-98]Status: DisposedITAT Mumbai01 Oct 2024AY 1997-98

Bench: Shri Anikesh Banerjee & Shri Gagan Goyal, Accountantjagdishchandra Prahaladdas Pasari 503/D, Santoor Apts., Pokhran Road No. 2, Thane West, Thane Maharashtra – 400 601 Pan No.: Aagpp0103M ...... Appellant Vs. Ito Ward 14, 6Th Floor, Aksar It Park, Road No. 16Z, Nehru Nagar, Wagle Estate, Thane (W), Maharashtra – 400 604 ..... Respondent

For Appellant: NoneFor Respondent: Ms. Rajeshwari Menon, Ld. DR
Section 143Section 143(3)Section 250Section 263Section 271Section 271(1)Section 68

also required to be taken into account. As far as the assessee is concerned, the undisputed fact is that on the basis of the seized material a cash flow statement was prepared which was supplied to the Assessing Officer. After the search, the working of the said cash flow statement ... therefore, required to be examined by the Assessing Officer, that too after due verification from the seized material. A cash flow statement which was prepared on the basis of the seized material must not be ignored. Once the assessee is in the business of finance, then the assessee is required

The Pr Commissioner of Income Tax vs. Sln Coffee Curing Works

The appeal is disposed of with liberty as prayed for by the learned

ITA/407/2023HC Karnataka30 Sept 2024

Bench: S.G.PANDIT,C.M. POONACHA

Section 260Section 69

assessee by issuing specific directions though the assessing authority had made addition of Rs.104577000 under the head business income on the basis of seized material which indicated undisclosed cash loans which were given by assessee and accrued interest income was also detailed therein? 2. Whether, on the facts ... taxable ignoring the fact that the assessee and its partners have recovered such interest payment and details of same were available in seized materials? 8. Whether on the facts and in the circumstances of the case, the Tribunal's order can be said as perverse in treating the interest

Ajit Madhukar Valsangkar, Pune vs. ACIT, Central Circle 1(3), Pune

In the result, the appeal filed by the appellant is partly allowed for statistical purposes

ITA 1412/PUN/2024[2016-17]Status: DisposedITAT Pune30 Sept 2024AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1412/Pun/2024 "नधा"रण वष" / Assessment Year : 2016-17

For Appellant: Shri Jayant G. Pendse &For Respondent: Shri Amol Khairnar
Section 132Section 142(1)Section 153CSection 250

total consideration of Rs.77.00 crores. It was found that share of the appellant, being the family member of Kulkari family, based on the seized material is Rs.12,03,125/-. Since the appellant had not disclosed the capital gains arising on the sale of said property based on the satisfaction note

Assistant Commissioner of Income Tax, Central Circle-2(2), Hyderabad vs. Sylns Agro Developers Private Limited, Hyderabad

In the result, all the six appeals filed by the Revenue

ITA 405/HYD/2023[2021-22]Status: DisposedITAT Hyderabad30 Sept 2024AY 2021-22

Bench: Shri Laliet Kumar & Shri Manjunatha, G.S.No Appeal In Ita No. Assessee Respondent A.Y 1 381/Hyd/2023 Acit Central Circle Bhoomika Agro 2020-21 2(2) Hyderabad Farms (P) Ltd Hyderabad Pan:Aafcb6665G 2 382/Hyd/2023 -Do- -Do- 2021-22 3 Co 7/Hyd/2023 Bhoomika Agro Acit Central Circle 2020-21 (Ita 381/H/23) Farms (P) Ltd 2(2) Hyderabad Hyderabad Pan:Aafcb6665G 4 Co 8/Hyd/2023 -Do- -Do- 2021-22 (Ita 382/H/23) 5 385/Hyd/2023 -Do- Sunshine Estate 2019-20 Construction India Llp, Hyderabad Pan:Adrfs0667D 6 386/Hyd/2023 -Do- -Do- 2020-21 7 387/Hyd/2023 -Do- -Do- 2022-22 8 Co3/Hyd/2023 Sunshine Estate Acit Central Circle 2019-20 (Ita 385/H/23) Construction India 2(2) Hyderabad Llp, Hyderabad Pan:Adrfs0667D 9 Co4/Hyd/2023 -Do- -Do- 2020-21 (Ita 386/H/23) 10 Co5/Hyd/2023 -Do- -Do- 2021-22 (Ita 387/H/23) 11 388/Hyd/2023 -Do- Krishi Housing (P) 2017-18 Ltd Hyderabad Pan:Aafck9740B 12 389/Hyd/2023 -Do- -Do- 2018-19 13 390/Hyd/2023 -Do- -Do- 2019-20 14 391/Hyd/2023 -Do- -Do- 2020-21 15 392/Hyd/2023 -Do- -Do- 2021-22 16 Co9/Hyd/2023 Krishi Housing (P) Acit Central Circle 2017-18 (Ita 388/H/23) Ltd Hyderabad 2(2) Hyderabad Pan:Aafck9740B

filed any confirmation from the said parties evidencing the receipt of cash. 4. Ld.CIT(A) failed to distinguish the fact that while in the seized material found in the Spectra Group there is mention of Page 3 of 37 ITA 381 of 2023 and others Bhoomika Agro Farms outward movement ... India Eco Projects (P) Ltd, agreement of sale dated 14.08.2019, and certain cash receipts were found and seized vide Annexure GAR/RES/01. On verification of seized material from pages No. 1 to 17 of the Annexure, it was noticed that an agreement of sale dated 14.08.2019 was found. The agreement