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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

DCIT (CC) - 2 (3), Mumbai vs. Classic Marble Co. Pvt. Ltd., Mumbai

In the result, all the appeals filed by the Revenue are dismissed

ITA 1705/MUM/2024[2014-15]Status: DisposedITAT Mumbai23 Sept 2024AY 2014-15

Bench: Shri B.R. Baskaran & Shri Sunil Kumar Singh

For Appellant: Mr. Neelkanth Khandelwal, CAFor Respondent: Ms. Madhu Malati Ghosh, CIT-DR
Section 131Section 132Section 133ASection 142(1)

having data related to sales during F.Y. 2018-19 during the search proceedings. The same is annexed herewith as Annexure-17 of the seized material. Please go through the same and 20 Classic Marble Co. Pvt. Ltd., explain why the same quality of the marble has been:Saki to different ... copies of the statements recorded in the search and relied upon by him, workings of the alleged unaccounted sales party- wise and the seized material retrieved from the WhatsApp chats these were not furnished to the appellant by the A.O. No opportunity to cross examine the aforesaid witnesses

DCIT (CC) - 2(3), Mumbai vs. Classic Marble Co. Pvt. Ltd, Mumbai

In the result, all the appeals filed by the Revenue are dismissed

ITA 1701/MUM/2024[2020-21]Status: DisposedITAT Mumbai23 Sept 2024AY 2020-21

Bench: Shri B.R. Baskaran & Shri Sunil Kumar Singh

For Appellant: Mr. Neelkanth Khandelwal, CAFor Respondent: Ms. Madhu Malati Ghosh, CIT-DR
Section 131Section 132Section 133ASection 142(1)

having data related to sales during F.Y. 2018-19 during the search proceedings. The same is annexed herewith as Annexure-17 of the seized material. Please go through the same and 20 Classic Marble Co. Pvt. Ltd., explain why the same quality of the marble has been:Saki to different ... copies of the statements recorded in the search and relied upon by him, workings of the alleged unaccounted sales party- wise and the seized material retrieved from the WhatsApp chats these were not furnished to the appellant by the A.O. No opportunity to cross examine the aforesaid witnesses

The Pr Commissioner of Income Tax vs. M/S Vsl Mining Company Pvt Ltd

Appeal is dismissed as being

ITA/32/2020HC Karnataka20 Sept 2024

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

Section 10BSection 132Section 133ASection 142(1)Section 143(2)Section 260Section 260A

circumstances of the case, the Tribunal is right in law in holding that the assessing authority cannot take cognizance of the seized material in the proceedings under section 143(3) of the Act without invoking provisions of Section 153C of the Act by ignoring that there is no bar section ... under section 153C or under any other provisions of the Act to take cognizance of seized material in regular assessment?” 7. It is the contention of learned counsel Sri Y.H.Raviraj appearing along with Sri Sushal Tiwari, learned counsel for the Revenue that the Tribunal erred in holding that the Revenue

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

The appeal stands partly allowed

ITA 1021/CHNY/2024[2017-18]Status: DisposedITAT Chennai20 Sept 2024AY 2017-18

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.1021/Chny/2024 (िनधा*रण वष* / Assessment Year: 2017-18) 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)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

DCIT, CC-2(4), Chennai vs. V.Baskaran, Chennai

In the result, the appeal filed by the assessee in IT(SS)A No

ITA 604/CHNY/2021[2017-18]Status: DisposedITAT Chennai20 Sept 2024AY 2017-18

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri A.P. Srinivas, Sr. Standing Counsel
Section 132Section 142(1)Section 143(3)Section 144Section 158B

holding that the AO erred in assuming jurisdiction u/s.153C of the Act, as the satisfaction note did not contain any seized material or documents pertaining to the assessee with regard to assessment year 2017-18. For this, Revenue has raised the following Ground ... erred in holding that the assuming jurisdiction by the assessing officer u/s.153C is not correct since the satisfaction note did not contain any seized material or documents pertaining to the appellant with regard to the determination of total income for the AY 2017-18. 3. The Learned CIT(A) failed

Ace Developers, Mangaluru vs. Deputy Commissioner of Income-Tax, Central Circle-1, Mangaluru

In the result, the appeal of the assessee is hereby allowed

ITA 365/BANG/2024[2017-18]Status: DisposedITAT Bangalore20 Sept 2024AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Ms. Sheetal Borkar, AdvocateFor Respondent: Shri Subramanian S, CIT (DR)
Section 132Section 133ASection 40A(3)

seized diary actually represented the sales made by the assessee. Such onus had not been discharged by the revenue. Mere entries in the seized material were not sufficient to prove that the assessee had indulged in such a transaction. The inference of the Assessing Officer that the assessee has received

Ace Developers, Mangaluru vs. Deputy Commissioner of Income-Tax, Central Circle-1, Mangaluru

In the result, the appeal of the assessee is hereby allowed

ITA 364/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 Sept 2024AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Ms. Sheetal Borkar, AdvocateFor Respondent: Shri Subramanian S, CIT (DR)
Section 132Section 133ASection 40A(3)

seized diary actually represented the sales made by the assessee. Such onus had not been discharged by the revenue. Mere entries in the seized material were not sufficient to prove that the assessee had indulged in such a transaction. The inference of the Assessing Officer that the assessee has received

Ace Developers, Mangaluru vs. Deputy Commissioner of Income-Tax, Central Circle-1, Mangaluru

In the result, the appeal of the assessee is hereby allowed

ITA 363/BANG/2024[2015-16]Status: DisposedITAT Bangalore20 Sept 2024AY 2015-16

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Ms. Sheetal Borkar, AdvocateFor Respondent: Shri Subramanian S, CIT (DR)
Section 132Section 133ASection 40A(3)

seized diary actually represented the sales made by the assessee. Such onus had not been discharged by the revenue. Mere entries in the seized material were not sufficient to prove that the assessee had indulged in such a transaction. The inference of the Assessing Officer that the assessee has received

Ace Developers, Mangaluru vs. Deputy Commissioner of Income-Tax, Central Circle-1, Mangaluru

In the result, the appeal of the assessee is hereby allowed

ITA 362/BANG/2024[2014-15]Status: DisposedITAT Bangalore20 Sept 2024AY 2014-15

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Ms. Sheetal Borkar, AdvocateFor Respondent: Shri Subramanian S, CIT (DR)
Section 132Section 133ASection 40A(3)

seized diary actually represented the sales made by the assessee. Such onus had not been discharged by the revenue. Mere entries in the seized material were not sufficient to prove that the assessee had indulged in such a transaction. The inference of the Assessing Officer that the assessee has received

Khoday Eshwarsa and Sons Pvt Ltd (Formerly Ms Khoday Eshwarsa and Sons), Bangalore vs. DCIT- Central Circle 1(1) Bgl, Bangalore

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

ITA 1080/BANG/2024[2022-23]Status: DisposedITAT Bangalore20 Sept 2024AY 2022-23

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 153ASection 153BSection 153D

based on which the officer is making the assessment. Furthermore, the AO should frame the assessment after due application of mind after evaluating the seized materials. Thus, the superior authority has to approve the Assessment order. The object of entrusting the duty of Approval of assessment in search cases ... letter written by the AO for getting the approval from the range head, was supported along with detailed checklist indicating the statements, seized materials and submissions filed by the assessee. Thus, the additional CIT while granting approval under section 153D of the Act has examined the draft order, written submission

Khoday Eshwarsa and Sons ( Presently Khoday Eshwarsa and Sons Pvt Ltd, Bangalore vs. DCIT - Central Circle 1(1) Bangalore, Bangalore

In the result, the appeal filed by the assessee is hereby allowed for statistical purposes

ITA 1079/BANG/2024[2020-21]Status: DisposedITAT Bangalore20 Sept 2024AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Shankar A, Sr. AdvocateFor Respondent: Shri DK Mishra, CIT (DR)
Section 153ASection 153BSection 153D

No.1079 & 1080/Bang/2024 Page 5 of 14 assessment. Furthermore, the AO should frame the assessment after due application of mind after evaluating the seized materials. Thus, the superior authority has to approve the Assessment order. The object of entrusting the duty of Approval of assessment in search cases is that ... letter written by the AO for getting the approval from the range head, was supported along with detailed checklist indicating the statements, seized materials and submissions filed by the assessee. Thus, the additional CIT while granting approval under section 153D of the Act has examined the draft order, written submission

Vijaykumar Mangilalji Chordiya, Nashik vs. National Faceless Assessment Centre, Delhi

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

ITA 1075/PUN/2024[2013-14]Status: DisposedITAT Pune19 Sept 2024AY 2013-14

Bench: Shri R. K. Panda & Shri S.S. Godaraassessment Year : 2013-14

For Appellant: Shri Nikhil PathakFor Respondent: Shri Arvind Desai, Addl CIT, DR
Section 143(2)Section 147Section 148Section 151Section 2(40)

statement recorded u/s. 132(4) of the Act at his residence on 02.08.2017, Shri Sachin Nahar stated that this seized material contain details of his money lending business in Cash and the Notings therein are related to Principal amount lent by lenders & borrowed by borrowers, names of lenders & borrowers

Kk Mohandas, Kannur vs. DCIT Central Circle 2, Kozhikode

The appeal of the assessee is allowed

ITA 497/COCH/2023[2010-11]Status: DisposedITAT Cochin19 Sept 2024AY 2010-11

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadav

For Appellant: Shri. Pavav Ved, AdvFor Respondent: Shri. K. Jayaganesh, Senior AR
Section 132Section 153C

consideration and adjudication was whether the Tribunal was right in holding that it was not necessary to record a satisfaction to the effect that seized material shows undisclosed income. While deciding this issue, the High Court came to the conclusion at para 50 thereof, that "the detection of seized material

The ACIT Central-3, Indore vs. Jarnalbeer Singh Bhatia, Khandwa

ITA 228/IND/2023[2018-19]Status: DisposedITAT Indore18 Sept 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniit(Ss)A Nos.19 To 23/Ind/2023 & Ita No.226/Ind/2023 Ays : 2013-14 To 2018-19 Jarnalbeer Singh Bhatia, Dcit/Acit, बनाम/ Bhatia Transport (Central)-3, Vs. Services, Indore. Old Indore Lines, Pandhana Road, Khandwa (Pan: Aixpb4565C) (Assessee/Appellant) (Revenue/Respondent)

Section 132Section 153ASection 69

Para 7.1 to 7.14 of assessment-order. When the AO show-caused assessee to explain transactions, the assessee submitted reply mainly contending that the seized material did not belong to assessee; that the statements of assessee’s staff wherein they confirmed that the seized documents/transactions belonged to assessee were obtained ... undisclosed interest income earned from them. The appellant during assessment proceedings as well as during appellate proceedings has strongly contended that the impunged seized material 'Radiant Deluxe Account Book' inventoried as BS-1 does not belong to him or his family member or any of his business establishment. He further

Jarnalbeer Singh Bhatia, Khandwa vs. The ACIT Central-3, Indore

ITA 226/IND/2023[2018-19]Status: DisposedITAT Indore18 Sept 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniit(Ss)A Nos.19 To 23/Ind/2023 & Ita No.226/Ind/2023 Ays : 2013-14 To 2018-19 Jarnalbeer Singh Bhatia, Dcit/Acit, बनाम/ Bhatia Transport (Central)-3, Vs. Services, Indore. Old Indore Lines, Pandhana Road, Khandwa (Pan: Aixpb4565C) (Assessee/Appellant) (Revenue/Respondent)

Section 132Section 153ASection 69

Para 7.1 to 7.14 of assessment-order. When the AO show-caused assessee to explain transactions, the assessee submitted reply mainly contending that the seized material did not belong to assessee; that the statements of assessee’s staff wherein they confirmed that the seized documents/transactions belonged to assessee were obtained ... undisclosed interest income earned from them. The appellant during assessment proceedings as well as during appellate proceedings has strongly contended that the impunged seized material 'Radiant Deluxe Account Book' inventoried as BS-1 does not belong to him or his family member or any of his business establishment. He further

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

The appeals stand allowed

ITA 1020/CHNY/2024[2016-17]Status: DisposedITAT Chennai18 Sept 2024AY 2016-17

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं. / Ita No.1019/Chny/2024 (िनधा*रण वष* / Assessment Year: 2015-16) & 2. आयकरअपील सं./ Ita No.1020/Chny/2024 (िनधा*रण वष* / Assessment Year: 2016-17) 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 सुनवाईकीतारीख/Date Of Hearing : 29-07-2024 घोषणाकीतारीख /Date Of Pronouncement : 18-09-2024 आदेश / O R D E R Per Bench: 1.1 Aforesaid Appeals By Assessee For Assessment Years (Ay) 2015- 16 & 2016-17 Arises Out Of Separate Orders Of Learned First Appellate Authority. Facts As Well As Issues Are Stated To Be Substantially The Same In Both The Years. 1.2 First, We Take Up Assessee’S Appeal For Ay 2015-16 Which Arises Out Of An Order Passed By Learned Commissioner Of Income Tax

For Appellant: Shri S. Sridhar (Advocate)- Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR
Section 143(3)Section 153ASection 251

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 ... assessee opposed the addition of the same on the ground that aggregate amount for FYs 2012-13 to 2016-17 as mentioned in the seized material was Rs.214.40 Lacs whereas Ld. AO proposed addition of Rs.294.84 Lacs. It was explained that land was held in the name of two partners

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

The appeals stand allowed

ITA 1019/CHNY/2024[2015-16]Status: DisposedITAT Chennai18 Sept 2024AY 2015-16

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं. / Ita No.1019/Chny/2024 (िनधा*रण वष* / Assessment Year: 2015-16) & 2. आयकरअपील सं./ Ita No.1020/Chny/2024 (िनधा*रण वष* / Assessment Year: 2016-17) 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 सुनवाईकीतारीख/Date Of Hearing : 29-07-2024 घोषणाकीतारीख /Date Of Pronouncement : 18-09-2024 आदेश / O R D E R Per Bench: 1.1 Aforesaid Appeals By Assessee For Assessment Years (Ay) 2015- 16 & 2016-17 Arises Out Of Separate Orders Of Learned First Appellate Authority. Facts As Well As Issues Are Stated To Be Substantially The Same In Both The Years. 1.2 First, We Take Up Assessee’S Appeal For Ay 2015-16 Which Arises Out Of An Order Passed By Learned Commissioner Of Income Tax

For Appellant: Shri S. Sridhar (Advocate)- Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR
Section 143(3)Section 153ASection 251

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 ... assessee opposed the addition of the same on the ground that aggregate amount for FYs 2012-13 to 2016-17 as mentioned in the seized material was Rs.214.40 Lacs whereas Ld. AO proposed addition of Rs.294.84 Lacs. It was explained that land was held in the name of two partners

Vinodhini, Chennai vs. ACIT, Central Circle-1(2), Chennai

Appeal stand allowed

ITA 921/CHNY/2023[2018-19]Status: DisposedITAT Chennai18 Sept 2024AY 2018-19

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकर अपील सं./ Ita No.921/Chny/2023 (िनधा9रण वष9 / Assessment Year: 2018-19) Mrs. Vinodhini Acit बनाम/ Flat No.14, Door No.98, Central Circle-1(2) Harrington Road, Chetpet, Vs. Chennai. Chennai-600 031. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Bmapv-2726-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri N. Arjun Raj (Advocate)- Ld.Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit)-Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 20-06-2024 घोषणा की तारीख /Date Of Pronouncement : 18-09-2024

For Appellant: Shri N. Arjun Raj (Advocate)- Ld.ARFor Respondent: Shri Nilay Baran Som (CIT)-Ld. Sr. DR
Section 153CSection 2(14)

jurisdiction and not sustainable both on facts and in law. 15. The CIT(A) failed to appreciate that in the absence of any incriminating seized material forming part of the search records, the addition made in the form of STCG in the search assessment completed was wrong, erroneous, incorrect, invalid ... activities could have been carried out by the assessee. It has further been submitted that the addition has been made on the basis of seized material, information emanating therefrom and the sworn statement of assessee’s son. Reference has been made to the decision of Hon’ble High Court

Deputy Commissioner of Income Tax, Central Circle 1(2), Chennai vs. Bondalapati Shivaji Rao, Chennai

In the result, appeal filed by the assessee stands allowed and appeal filed by the Revenue is dismissed

ITA 1103/CHNY/2023[2019-20]Status: DisposedITAT Chennai18 Sept 2024AY 2019-20

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1044/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 V. Shri Bondalapati Shivaji Rao, The Dcit, 121, Shankar Nagar, M.G. Road, Central Circle-1(2), Pammal, Chennai-600 075. Chennai. [Pan: Aahpb 0083 D] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.1103/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 V. The Dcit, Shri Bondalapati Shivaji Rao, Central Circle-1(2), 121, Shankar Nagar, Chennai. M.G. Road, Pammal, Chennai-600 075. [Pan: Aahpb 0083 D] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri B. Ramakrishnan, FCAFor Respondent: Shri V. Nandakumar, CIT
Section 127Section 132Section 143(2)Section 143(3)Section 153C

आयकर अपीलीय अिधकरण, ‘बी’ "यायपीठ, चे"ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH: CHENNAI "ी एबी टी. वक", "ाियक

Bondalapati Shivaji Rao, Chennai vs. Assistant Commissioner of Income Tax, Central Circle - 1(2), Chennai

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

ITA 1044/CHNY/2023[AY 2019-20]Status: DisposedITAT Chennai18 Sept 2024

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1044/Chny/2023 निर्धारण वर्ष/Assessment Year: 2019-20 Shri Bondalapati Shivaji Rao, 121, Shankar Nagar, M.G. Road, Pammal, Chennai-600 075. [Pan: Aahpb 0083 D] (अपीलार्थी/Appellant) The Dcit, Central Circle-1(2), Chennai. (अपीलार्थी/Appellant) V. The Dcit, Central Circle-1(2), Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.1103/Chny/2023 निर्धारण वर्ष/Assessment Year: 2019-20 V. Shri Bondalapati Shivaji Rao, 121, Shankar Nagar, M.G. Road, Pammal, Chennai-600 075. [Pan: Aahpb 0083 D] (प्रत्यर्थी/Respondent) Assessee By : Shri B. Ramakrishnan, Fca Shri S. Dwarakesh, Ca Shri Shrenik Chordia, Ca Department By : Shri V. Nandakumar, Cit सुनवाईकीतारीख/Date Of Hearing : 08.08.2024 घोषणाकीतारीख /Date Of Pronouncement : 18.09.2024 आदेश / Order Per Aby T. Varkey, Jm: These Appeals Preferred By The Assessee & The Revenue Are Against The Order Of The Learned Commissioner Of Income Tax (Appeals)- 18, Chennai (Hereinafter In Short `The Ld.Cit(A)') Dated 26.07.2023 Passed For Assessment Year (Hereinafter In Short `Ay') 2019-20.

For Appellant: Shri B. Ramakrishnan, FCAFor Respondent: Shri V. Nandakumar, CIT
Section 127Section 132Section 143(2)Section 143(3)Section 153C

आयकर अपीलीय अधिकरण, 'बी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'B' BENCH: CHENNΑΙ श्री एबी टी. वर्की, न्यायिक