← All Phrases

“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

Maddirala Srinivasa Rao, Hyderabad vs. ACIT., Central Circle 3(1), Hyderabad

In the result, both the appeals filed by the assessee, i

ITA 158/HYD/2025[2020-21]Status: DisposedITAT Hyderabad21 Jan 2026AY 2020-21
Section 115BSection 132Section 132ASection 143(1)Section 143(3)Section 153ASection 158

certain loose sheets, documents, printed sheets taken from the assessee’s laptop (make: Lenovo) were seized vide Annexure: A/MSR/Res/01. On an analysis of the seized material, it Srinivasa Rao Maddirala vs. ACIT was observed that the assessee was in receipt of an amount of Rs.3,31,42,000/- during ... appellant, certain loose sheets, documents, printed sheets taken from assessee's Lenovo laptop were seized vide Annex. A/MSR/RES/01 the said contents of seized material were analysed and it was noticed that appellant was in receipt of Rs. 3,31,42,000/- during different periods relevant for A.Ys

Swapna Ravikanthi, Narsapur vs. DCIT., Central Circle-2(4), Hyderabad

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

ITA 1471/HYD/2025[2019-20]Status: DisposedITAT Hyderabad21 Jan 2026AY 2019-20
Section 115BSection 132Section 153ASection 153CSection 69

During the search assessment proceedings under Section 153A of the Act, in the case of the searched person, on analysis of the seized material vide Annexure A/MSR/OFF/01, page 123, the A.O. of the searched person was satisfied that, the seized material belongs to and the information contained in the said

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. ACIT., Central Circle - 2(1), Hyderabad

ITA 1105/HYD/2025[2016-17]Status: DisposedITAT Hyderabad21 Jan 2026AY 2016-17
For Appellant: Shri Siddharth ToshnivalFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 143(1)Section 143(3)Section 153CSection 153D

153C. In ground 1A, the appellant argued that the AO of the searched person did not explicitly record satisfaction that the seized material pertains to or relates to the appellant. In Ground 1B, the appellant contended that the notice u/s 153C was issued before the satisfaction was recorded ... satisfaction note of the AO of the searched person mentions the seized material's relevance to the appellant's income for certain assessment years but failed to state that it directly pertains to the appellant. The appellant claimed that section 153C requires the satisfaction to explicitly confirm that the material

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. ACIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

ITA 1104/HYD/2025[2015-16]Status: DisposedITAT Hyderabad21 Jan 2026AY 2015-16

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

For Appellant: Shri Siddharth ToshnivalFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 153CSection 153D

153C. In ground 1A, the appellant argued that the AO of the searched person did not explicitly record satisfaction that the seized material pertains to or relates to the appellant. In Ground 1B, the appellant contended that the notice u/s 153C was issued before the satisfaction was recorded ... satisfaction note of the AO of the searched person mentions the seized material's relevance to the appellant's income for certain assessment years but failed to state that it directly pertains to the appellant. The appellant claimed that section 153C requires the satisfaction to explicitly confirm that the material

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. ACIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

ITA 1103/HYD/2025[2014-15]Status: DisposedITAT Hyderabad21 Jan 2026AY 2014-15

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

For Appellant: Shri Siddharth ToshnivalFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 153CSection 153D

153C. In ground 1A, the appellant argued that the AO of the searched person did not explicitly record satisfaction that the seized material pertains to or relates to the appellant. In Ground 1B, the appellant contended that the notice u/s 153C was issued before the satisfaction was recorded ... satisfaction note of the AO of the searched person mentions the seized material's relevance to the appellant's income for certain assessment years but failed to state that it directly pertains to the appellant. The appellant claimed that section 153C requires the satisfaction to explicitly confirm that the material

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. DCIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

ITA 1102/HYD/2025[2013-14]Status: DisposedITAT Hyderabad21 Jan 2026AY 2013-14

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

For Appellant: Shri Siddharth ToshnivalFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 153CSection 153D

153C. In ground 1A, the appellant argued that the AO of the searched person did not explicitly record satisfaction that the seized material pertains to or relates to the appellant. In Ground 1B, the appellant contended that the notice u/s 153C was issued before the satisfaction was recorded ... satisfaction note of the AO of the searched person mentions the seized material's relevance to the appellant's income for certain assessment years but failed to state that it directly pertains to the appellant. The appellant claimed that section 153C requires the satisfaction to explicitly confirm that the material

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. ACIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

ITA 1101/HYD/2025[2012-13]Status: DisposedITAT Hyderabad21 Jan 2026AY 2012-13

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

For Appellant: Shri Siddharth ToshnivalFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 153CSection 153D

153C. In ground 1A, the appellant argued that the AO of the searched person did not explicitly record satisfaction that the seized material pertains to or relates to the appellant. In Ground 1B, the appellant contended that the notice u/s 153C was issued before the satisfaction was recorded ... satisfaction note of the AO of the searched person mentions the seized material's relevance to the appellant's income for certain assessment years but failed to state that it directly pertains to the appellant. The appellant claimed that section 153C requires the satisfaction to explicitly confirm that the material

Deputy Commissioner of Income Tax, Madurai vs. Sitaram Jewellers, Madurai

In the result, both the appeals of the revenue are dismissed

ITA 915/CHNY/2025[2020-21]Status: DisposedITAT Chennai21 Jan 2026AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri.T.Vasudevan, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 131Section 132Section 69C

915/Chny/2025 accounts. On perusal of the same the AO found that few of the transactions are not matching with the seized materials. 10. Accordingly, the Assessing Officer concluded that the assessee had not disclosed the entire transaction held with the Mohanlal Jewellers Pvt Ltd and treated unaccounted transactions / expenditures ... entire addition(s) were made upon the findings unearthed during the course of search in the case of MJPL and others. In the seized materials there existed three types of transactions viz.. transactions in regular course recorded in the regular books of accounts as payment through banking channels, second

Deputy Commissioner of Income Tax, Madurai vs. Sitaram Jewellers, Madurai

In the result, both the appeals of the revenue are dismissed

ITA 913/CHNY/2025[2021-22]Status: DisposedITAT Chennai21 Jan 2026AY 2021-22

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri.T.Vasudevan, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 131Section 132Section 69C

915/Chny/2025 accounts. On perusal of the same the AO found that few of the transactions are not matching with the seized materials. 10. Accordingly, the Assessing Officer concluded that the assessee had not disclosed the entire transaction held with the Mohanlal Jewellers Pvt Ltd and treated unaccounted transactions / expenditures ... entire addition(s) were made upon the findings unearthed during the course of search in the case of MJPL and others. In the seized materials there existed three types of transactions viz.. transactions in regular course recorded in the regular books of accounts as payment through banking channels, second

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 737/CHNY/2022[2013-2014]Status: DisposedITAT Chennai21 Jan 2026AY 2013-2014

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed ... consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 736/CHNY/2022[2012-2013]Status: DisposedITAT Chennai21 Jan 2026AY 2012-2013

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed ... consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 735/CHNY/2022[2011-2012]Status: DisposedITAT Chennai21 Jan 2026AY 2011-2012

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed ... consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 734/CHNY/2022[2010-2011]Status: DisposedITAT Chennai21 Jan 2026AY 2010-2011

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed ... consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 733/CHNY/2022[2009-2010]Status: DisposedITAT Chennai21 Jan 2026AY 2009-2010

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed ... consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 732/CHNY/2022[2008-2009]Status: DisposedITAT Chennai21 Jan 2026AY 2008-2009

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed ... consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed

Mr.V.Churchil, Theni vs. CIT(A)-19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 730/CHNY/2022[2012-2013]Status: DisposedITAT Chennai21 Jan 2026AY 2012-2013

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed ... consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed

Mr.V.Churchil, Theni vs. CIT(A)-19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 729/CHNY/2022[2011-2012]Status: DisposedITAT Chennai21 Jan 2026AY 2011-2012

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed ... consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed

Mr.V.Churchil, Theni vs. CIT(A)-19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 728/CHNY/2022[2010-2011]Status: DisposedITAT Chennai21 Jan 2026AY 2010-2011

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed ... consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed

Mr.V.Churchil, Theni vs. CIT(A)-19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 727/CHNY/2022[2009-2010]Status: DisposedITAT Chennai21 Jan 2026AY 2009-2010

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed ... consider the retraction statement filed by the appellant. 5. The Ld. CIT(A) and the Ld. Assessing Officer failed to consider the diary noting (seized material) showing that average price of the plots sold were around Rs.41,000/- 6. The Ld. CIT(A) and the Ld. Assessing Officer failed

Dr. Shridhar Ra vs. Aheb Limbikai DCIT Central Circle 17, Delhivs.Ashwani Kumar Gupta (HUF), Kanpur

ITA 6108/DEL/2025[2013-14]Status: DisposedITAT Delhi21 Jan 2026AY 2013-14

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shukla

For Appellant: Sh. Sandeep Chadha, FCAFor Respondent: Ms. Amish S. Gupt, CIT-DR
Section 132Section 139Section 143(3)Section 147Section 148Section 149Section 153Section 153ASection 153CSection 181

falls beyond the period of ten assessment years from the end of the assessment year relevant to the previous year in which the seized material is received by the learned AO. Before delving into the legal grounds; it is essential to go through the facts and the legal provisions under ... that since the AY 2011-12 does not fall within the period often assessment years from the end of the assessment year in which seized material has been received by JAO. The appellant placed reliance on the decision of Apex Court in the case of Jasjit Singh