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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

Assistant Commissioner of Income Tax, Central Circle-25, New Delhi, Delhi vs. Avtar Singh Kochar, Haryana

ITA 4438/DEL/2025[2019-20]Status: DisposedITAT Delhi09 Jan 2026AY 2019-20

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. MayankPatawari, AdvFor Respondent: Sh. AlashOjha, Adv
Section 143(3)Section 153D

Copies of the final assessment orders should be forwarded to this office immediately after passing the orders. Proposal for retention of seized material should also be forwarded to this office within time as per IT Act, 1961. Before passing the final order, in case, there is requirement of protecting

Jsp Projects (P) Ltd, Delhi vs. DCIT, Central Circle-13, Delhi/South Delhi

In the result, the appeal of the assessee is allowed

ITA 3594/DEL/2025[2014-2015]Status: DisposedITAT Delhi09 Jan 2026AY 2014-2015

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2014-15] M/S Jsp Projects Private Dcit, Central Circle-13, 2Nd Floor, Income Tax Building, Limited, C/O- Ca Vaibhav Goel, 75, Vs E-2 Ara Centre, Jhandewalan Navyug Market, First Floor, Extension, Delhi-110055 Ghaziabad(Up) Uttar Pradesh-201001 Pan-Aadcj0677L Appellant Respondent Assessee By Shri Ved Jain, Adv. Ms. Uma Upadhyay, Ca & Shri Aditya Garg, Adv. Revenue By Ms. Amisha S. Gupta, Cit-Dr Date Of Hearing 15.10.2025 Date Of Pronouncement 09.01.2026 Order Per Amitabh Shukla, Am

Section 127(2)Section 153CSection 63Section 65BSection 68

order under section 153C(supra) clearly shows that no incriminating documents was specifically seized as belonging to the assessee. It was argued that the seized material reproduced in the books of accounts. 5. In support of her contentions, the ld. Counsel placed reliance upon the decision of Hon’ble Apex ... related to the evidence found, it does not mean that the assessment "can be arbitrary or made without any relevance or nexus with the seized material. Obviously, an assessment has to be made under this section only on the basis of the seized material." 8. Per Contra, ld. DR placed

Avtar Singh Kochar, Rohtak vs. DCIT, Central Circle-25, Delhi

ITA 2909/DEL/2025[2019-20]Status: DisposedITAT Delhi09 Jan 2026AY 2019-20

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. MayankPatawari, AdvFor Respondent: Sh. AlashOjha, Adv
Section 143(3)Section 153D

Copies of the final assessment orders should be forwarded to this office immediately after passing the orders. Proposal for retention of seized material should also be forwarded to this office within time as per IT Act, 1961. Before passing the final order, in case, there is requirement of protecting

Assistant Commissioner of Income Tax, Central Circle-25 New Delhi, Delhi vs. Faridabad Presswell Pvt Ltd, Delhi

In the result, the appeal of the

ITA 2801/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.2801/Del/2024 िनधा"रणवष"/Assessment Year: 2015-16 बनाम Assistant Commissioner Of Faridabad Presswell Pvt. Ltd. Income Tax, Vs. 24, Ashoka Chamber, 5B, Central Circle-25, Room No.317, Rajindra Park, Pusa Road, 3Rd Floor, E-2, Ara Centre, New Delhi. Jhandewalan Extension, Pan No. Aaacfs815B Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 250

Apparently, the assessee had purchased 312214 sq. mts. Of land, which was registered in the month of January and February, 2015 1 from the seized material, an inference was drawn that some part of the consideration (Rs. 8 crores) for the said transaction was made in cash and not disclosed ... order. 5.6 Regarding the second additional ground under Rule 27, pertaining to the assessment being done without any live nexus with seized material, would need to be discussed. The second ground (supra) pertains to a challenging of the fact that the impugned addition has been made on a basis other

Emm. Kay Electricals, Jalandhar vs. Assistant Commissioner of Income Tax, Jalandhar

In the result the appeal of the assessee is allowed for statistical purpose

ITA 208/ASR/2019[2011-12]Status: DisposedITAT Amritsar08 Jan 2026AY 2011-12

Bench: Shri Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Sandeep Vijh, CA
Section 132(1)Section 143(3)Section 153CSection 234ASection 250(6)Section 69A

other person) , in the files of the other person, is adequate compliance, as long as it demonstrates that the AO was satisfied that seized materials pertains to the other person and in support he relied on the Hon’ble Apex court in the case of Supermalls Pvt Ltd v PCIT

Dipaliben M. Shah, Vadodara vs. The Dy.CIT, Central Circle-2, Vadodara

In the result, the appeals bearing IT(SS)A No

ITA 537/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad08 Jan 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumarit(Ss)A No. 103 & 104/Ahd/2023 (Assessment Year: 2009-10 & 2010-11) Vs. Dipaliben M. Shah, Deputy Commissioner Of E/33, Krishnalila Society, Income-Tax, Near Bankers Hosptial, Central Circle-2, Harni Warasia Ring Road, Baroda Vadodara-390006 [Pan : Ajrps 7522 B]

For Appellant: Shri Manish J. Shah, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 132Section 139(1)Section 153ASection 250

Officer made additions of Rs.1,24,000/- and Rs.1,25,000/- treating the same as unaccounted income of the assessee on the basis of seized material, noting that the amounts represented cash received on new admissions. 10. The Ld. CIT(A), though accepting this factual position, proceeded to treat ... taxmann.com 818. Respectfully following the said decision, Ground Nos. 1 &2 raised by the assessee are dismissed. Ground No. 3 15. The seized material reflected purchase of the properties at Village Hanumanpura for Rs.51,00,000/-. The assessee has offered this amount before the Settlement Commission. These facts

Income Tax Officer, Pune vs. Sagar Construction Company, Pune

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

ITA 1812/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Suhas Bora and Riya OswalFor Respondent: Shri S. Sadananda Singh, JCIT
Section 142(1)Section 143(1)Section 147Section 148Section 269SSection 37Section 68

Counsel for the assessee at the outset submitted that the basis of reopening was the information obtained and the notings in the seized material from a search u/s 132 of the Act in the case of Sri Sachin Nahar. Referring to para 6 12 CO No.43/PUN/2025 page 4 of assessment ... that it is the settled proposition of law that section 153C of the Act is a complete code for cases of ‘other persons’ where seized material belongs 13 CO No.43/PUN/2025 to them and therefore, resort to section 147 in such cases is not in accordance with law. He submitted that

Narender Nath, Delhi vs. DCIT Central Circle-2, Delhi

Appeal is allowed

ITA 4990/DEL/2025[2021-2022]Status: DisposedITAT Delhi08 Jan 2026AY 2021-2022

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 4990/Del/2025 : Asstt. Year : 2021-22 Narender Nath, Vs Dcit, C/O Sandeep Goel, Adv. Central Circle-2, F-26/124, Sector-7, Rohini, New Delhi-110055 Delhi-110085 (Appellant) (Respondent) Pan No. Aacpn0022D Assessee By : Sh. Prikshit Aggarwal, Ca & Sh. Mukul Gupta, Adv. Revenue By : Ms. Amish S. Gupt, Cit-Dr Date Of Hearing: 08.01.2026 Date Of Pronouncement: 08.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2021-22, Arises Against The Cit(A)-23, Delhi’S Din & Order No. Itba/Apl/S/250/2025–26/1078979102(1) Dated 28.07.2025, In Proceedings U/S 153C R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”)

For Appellant: Sh. Prikshit Aggarwal, CA &For Respondent: Ms. Amish S. Gupt, CIT-DR
Section 153CSection 153C(1)(a)

Faced with this situation, the Revenue could once again not dispute that section 153C(1)(a) stipulates the category of the seized material as “any money, bullion, jewellery.....” 3 Narender Nath which could be held as belonging to a third person and such documents etc. could only be treated

Assistant Commissioner of Income Tax, Central Circle-2, Ludhiana vs. Ritu Dhingra, Shakti Vihar, Haibowal Kalan, Ludhiana

In the result, the appeal of the Assessee and cross appeal of the Department are allowed for statistical purposes

ITA 862/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh07 Jan 2026AY 2019-20

Bench: him:- (a) That the assessment order dated 31.03.2023 passed u/s 143(3) r.w.s.153C is bad in law in as much no incriminating material was found suggesting any escapement of income at premises of Sh. Avtar Singh Kochhar. (b) That the assessment order passed is non-est and bad in law in as much the proceedings have not been conducted in the manner prescribed by the Department instructions from time to time which are mandatory for compliance by the Learned Authorities particularly with respect

For Appellant: Shri Ashwani Kumar, C.A and Ms. Deepali Aggarwal, C.AFor Respondent: Shri Rajat Kumar Kureel, CIT, DR
Section 131Section 132Section 143(3)Section 144Section 153CSection 153C(3)Section 153DSection 250Section 251(1)(a)

remittances routed through M/s Dhanya General Trading FZE and M/s Tirupati Diam FZE. According to the Assessing Officer, the transaction details appearing in the seized material matched with the assessee’s export invoices and bank credits. Since the assessee failed to satisfactorily explain the nature and source of the credits

Ritu Dhingra, Ludhiana vs. Deputy Commissioner of Income Tax, Central Circle-2, Ludhiana

In the result, the appeal of the Assessee and cross appeal of the Department are allowed for statistical purposes

ITA 645/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh07 Jan 2026AY 2019-20

Bench: him:-

For Appellant: Shri Ashwani Kumar, C.A and Ms. Deepali Aggarwal, C.AFor Respondent: Shri Rajat Kumar Kureel, CIT, DR
Section 131Section 132Section 143(3)Section 144Section 153CSection 153C(3)Section 153DSection 250Section 251(1)(a)

remittances routed through M/s Dhanya General Trading FZE and M/s Tirupati Diam FZE. According to the Assessing Officer, the transaction details appearing in the seized material matched with the assessee’s export invoices and bank credits. Since the assessee failed to satisfactorily explain the nature and source of the credits

Bharat Kumar Bansal, Hyderabad vs. ACIT., Central Circle-2(1), Hyderabad

ITA 1006/HYD/2025[2019-20]Status: DisposedITAT Hyderabad07 Jan 2026AY 2019-20
For Appellant: Shri A Srinivas, CAFor Respondent: Shri S. Arun Kumar, Sr. DR
Section 153C

nand seized from the premises of the searched person. The Learned\nAssessing Officer (\"Ld. AO\") recorded a satisfaction note dated\n12.10.2022, stating that the seized material belonged to the\nassessee. On the basis of the said satisfaction note, notices under\nsection 153C of the Act were issued to the assessee ... satisfaction note for multiple assessment\n\nyears from AY 2013-14 to AY 2019-20. The Ld. AR further invited\nour attention to the seized material relied upon by the Revenue,\nnamely an \"agreement of sale\" dated 28.08.2018, placed at page\nnos. 2 to 6 of the paper book

Bharat Kumar Bansal, Hyderabad vs. ACIT., Central Circle-2(1), Hyderabad

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

ITA 1005/HYD/2025[2018-19]Status: DisposedITAT Hyderabad07 Jan 2026AY 2018-19

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1000 To 1006/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2013-14 To 2019-20) Shri Bharat Kumar Bansal Vs. Assistant Commissioner Hyderabad Of Income Tax Pan:Abfpb6416P Central Circle 2(1) Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A Srinivas, Ca राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 17/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026 आदेश/Order Per Bench: These Seven Appeals Are Filed By Shri Bharat Kumar Bansal (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) All Dated 07.03.2025 For The A.Ys. 2013- 14 To 2019-20. Since Common & Identical Issues Are Raised By The Assessee In All These Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find There Is A Delay Of 06 Days In Filing Of All These Appeals Before This Tribunal. The Assessee Has Page 1 Of 9

For Appellant: Shri A Srinivas, CAFor Respondent: : Shri S. Arun Kumar, Sr. DR
Section 153C

seized from the premises of the searched person. The Learned Assessing Officer (“Ld. AO”) recorded a satisfaction note dated 12.10.2022, stating that the seized material belonged to the assessee. On the basis of the said satisfaction note, notices under section 153C of the Act were issued to the assessee ... Bharat Kumar Bansal years from AY 2013-14 to AY 2019-20. The Ld. AR further invited our attention to the seized material relied upon by the Revenue, namely an “agreement of sale” dated 28.08.2018, placed at page nos. 2 to 6 of the paper book, and submitted that

Bharat Kumar Bansal, Hyderabad vs. ACIT., Central Circle-2(1), Hyderabad

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

ITA 1004/HYD/2025[2017-18]Status: DisposedITAT Hyderabad07 Jan 2026AY 2017-18

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1000 To 1006/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2013-14 To 2019-20) Shri Bharat Kumar Bansal Vs. Assistant Commissioner Hyderabad Of Income Tax Pan:Abfpb6416P Central Circle 2(1) Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A Srinivas, Ca राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 17/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026 आदेश/Order Per Bench: These Seven Appeals Are Filed By Shri Bharat Kumar Bansal (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) All Dated 07.03.2025 For The A.Ys. 2013- 14 To 2019-20. Since Common & Identical Issues Are Raised By The Assessee In All These Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find There Is A Delay Of 06 Days In Filing Of All These Appeals Before This Tribunal. The Assessee Has Page 1 Of 9

For Appellant: Shri A Srinivas, CAFor Respondent: : Shri S. Arun Kumar, Sr. DR
Section 153C

seized from the premises of the searched person. The Learned Assessing Officer (“Ld. AO”) recorded a satisfaction note dated 12.10.2022, stating that the seized material belonged to the assessee. On the basis of the said satisfaction note, notices under section 153C of the Act were issued to the assessee ... Bharat Kumar Bansal years from AY 2013-14 to AY 2019-20. The Ld. AR further invited our attention to the seized material relied upon by the Revenue, namely an “agreement of sale” dated 28.08.2018, placed at page nos. 2 to 6 of the paper book, and submitted that

Bharat Kumar Bansal, Hyderabad vs. ACIT, Central Circle-2(1), Hyderabad

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

ITA 1003/HYD/2025[2016-17]Status: DisposedITAT Hyderabad07 Jan 2026AY 2016-17

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1000 To 1006/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2013-14 To 2019-20) Shri Bharat Kumar Bansal Vs. Assistant Commissioner Hyderabad Of Income Tax Pan:Abfpb6416P Central Circle 2(1) Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A Srinivas, Ca राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 17/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026 आदेश/Order Per Bench: These Seven Appeals Are Filed By Shri Bharat Kumar Bansal (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) All Dated 07.03.2025 For The A.Ys. 2013- 14 To 2019-20. Since Common & Identical Issues Are Raised By The Assessee In All These Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find There Is A Delay Of 06 Days In Filing Of All These Appeals Before This Tribunal. The Assessee Has Page 1 Of 9

For Appellant: Shri A Srinivas, CAFor Respondent: : Shri S. Arun Kumar, Sr. DR
Section 153C

seized from the premises of the searched person. The Learned Assessing Officer (“Ld. AO”) recorded a satisfaction note dated 12.10.2022, stating that the seized material belonged to the assessee. On the basis of the said satisfaction note, notices under section 153C of the Act were issued to the assessee ... Bharat Kumar Bansal years from AY 2013-14 to AY 2019-20. The Ld. AR further invited our attention to the seized material relied upon by the Revenue, namely an “agreement of sale” dated 28.08.2018, placed at page nos. 2 to 6 of the paper book, and submitted that

Bharat Kumar Bansal, Hyderabad vs. ACIT, Central Circle-2(1), Hyderabad

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

ITA 1002/HYD/2025[2015-16]Status: DisposedITAT Hyderabad07 Jan 2026AY 2015-16

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1000 To 1006/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2013-14 To 2019-20) Shri Bharat Kumar Bansal Vs. Assistant Commissioner Hyderabad Of Income Tax Pan:Abfpb6416P Central Circle 2(1) Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A Srinivas, Ca राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 17/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026 आदेश/Order Per Bench: These Seven Appeals Are Filed By Shri Bharat Kumar Bansal (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) All Dated 07.03.2025 For The A.Ys. 2013- 14 To 2019-20. Since Common & Identical Issues Are Raised By The Assessee In All These Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find There Is A Delay Of 06 Days In Filing Of All These Appeals Before This Tribunal. The Assessee Has Page 1 Of 9

For Appellant: Shri A Srinivas, CAFor Respondent: : Shri S. Arun Kumar, Sr. DR
Section 153C

seized from the premises of the searched person. The Learned Assessing Officer (“Ld. AO”) recorded a satisfaction note dated 12.10.2022, stating that the seized material belonged to the assessee. On the basis of the said satisfaction note, notices under section 153C of the Act were issued to the assessee ... Bharat Kumar Bansal years from AY 2013-14 to AY 2019-20. The Ld. AR further invited our attention to the seized material relied upon by the Revenue, namely an “agreement of sale” dated 28.08.2018, placed at page nos. 2 to 6 of the paper book, and submitted that

Bharat Kumar Bansal, Hyderabad vs. ACIT., Central Circle -2(1), Hyderabad

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

ITA 1001/HYD/2025[2014-15]Status: DisposedITAT Hyderabad07 Jan 2026AY 2014-15

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.1000 To 1006/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2013-14 To 2019-20) Shri Bharat Kumar Bansal Vs. Hyderabad Pan:Abfpb6416P (Appellant) Assistant Commissioner Of Income Tax Central Circle 2(1) Hyderabad (Respondent) निर्धारिती द्वारा /Assessee By: Shri A Srinivas, Ca राजस्व द्वारा / Revenue By:: | Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख /Date Of Hearing: 17/12/2025 घोषणा की तारीख / Pronouncement: | 07/01/2026 आदेश/Order Per Bench: These Seven Appeals Are Filed By Shri Bharat Kumar Bansal (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) All Dated 07.03.2025 For The A.Ys. 2013- 14 To 2019-20. Since Common & Identical Issues Are Raised By The Assessee In All These Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find There Is A Delay Of 06 Days In Filing Of All These Appeals Before This Tribunal. The Assessee Has Filed Separate Petitions For Condonation Of Delay Along With Copies Of The Affidavits Explaining The Reasons For Such Delay & Praying For Condonation Of The Same. After Considering The Reasons Stated By The Assessee & Upon Hearing The Submissions Of The Learned Departmental Representative (“Ld. Dr”), We Are Satisfied That The Delay Was Due To Reasonable Cause. Accordingly, The Delay Of 06 Days In Filing Of All These Appeals Are Condoned & The Appeals Are Admitted For Adjudication On Merits. 3. Identical Grounds Have Been Raised By The Assessee In

For Appellant: Shri A Srinivas, CA
Section 153C

seized from the premises of the searched person. The Learned Assessing Officer (“Ld. AO”) recorded a satisfaction note dated 12.10.2022, stating that the seized material belonged to the assessee. On the basis of the said satisfaction note, notices under section 153C of the Act were issued to the assessee ... consolidated satisfaction note for multiple assessment years from AY 2013-14 to AY 2019-20. The Ld. AR further invited our attention to the seized material relied upon by the Revenue, namely an “agreement of sale” dated 28.08.2018, placed at page nos. 2 to 6 of the paper book

Bharat Kumar Bansal, Hyderabad vs. ACIT, Central Circle-2(1), Hyderabad

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

ITA 1000/HYD/2025[2013-14]Status: DisposedITAT Hyderabad07 Jan 2026AY 2013-14

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1000 To 1006/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2013-14 To 2019-20) Shri Bharat Kumar Bansal Vs. Assistant Commissioner Hyderabad Of Income Tax Pan:Abfpb6416P Central Circle 2(1) Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A Srinivas, Ca राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 17/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026 आदेश/Order Per Bench: These Seven Appeals Are Filed By Shri Bharat Kumar Bansal (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) All Dated 07.03.2025 For The A.Ys. 2013- 14 To 2019-20. Since Common & Identical Issues Are Raised By The Assessee In All These Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find There Is A Delay Of 06 Days In Filing Of All These Appeals Before This Tribunal. The Assessee Has Page 1 Of 9

For Appellant: Shri A Srinivas, CAFor Respondent: : Shri S. Arun Kumar, Sr. DR
Section 153C

seized from the premises of the searched person. The Learned Assessing Officer (“Ld. AO”) recorded a satisfaction note dated 12.10.2022, stating that the seized material belonged to the assessee. On the basis of the said satisfaction note, notices under section 153C of the Act were issued to the assessee ... Bharat Kumar Bansal years from AY 2013-14 to AY 2019-20. The Ld. AR further invited our attention to the seized material relied upon by the Revenue, namely an “agreement of sale” dated 28.08.2018, placed at page nos. 2 to 6 of the paper book, and submitted that

Sundarasamy Rep. by Kokila, Tiruppur vs. ACIT, Central Circle-3, Coimbatore

In the result, all the appeals of the assessee are allowed

ITA 2207/CHNY/2025[2021-22]Status: DisposedITAT Chennai07 Jan 2026AY 2021-22

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

For Appellant: Mr. S.Sridhar, Advocate (Erode)For Respondent: Ms.E.Pavuna Sundari, CIT
Section 132Section 132(4)Section 139(1)Section 153CSection 250

that the assessee had engaged in a loan transaction with Shri G. N. Anbuchezian, a prominent financier in the Tamil Nadu film industry. The seized material further revealed cash dealings between the assessee and Shri G. N. Anbuchezian, which were directly relevant to the computation of the assessee’s total ... Section 153C were initiated. Accordingly, notices under Section 153C were issued to the assessee on 08.09.2022. 9. In this case, the handing over of seized materials to the Jurisdictional Assessing Officer (JAO) of the assessee was on 08.09.2022. In such case, the said date has to be construed

Sundarasamy Rep. by Kokila, Tiruppur vs. ACIT, Central Circle-3, Coimbatore

In the result, all the appeals of the assessee are allowed

ITA 2206/CHNY/2025[2018-19]Status: DisposedITAT Chennai07 Jan 2026AY 2018-19

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

For Appellant: Mr. S.Sridhar, Advocate (Erode)For Respondent: Ms.E.Pavuna Sundari, CIT
Section 132Section 132(4)Section 139(1)Section 153CSection 250

that the assessee had engaged in a loan transaction with Shri G. N. Anbuchezian, a prominent financier in the Tamil Nadu film industry. The seized material further revealed cash dealings between the assessee and Shri G. N. Anbuchezian, which were directly relevant to the computation of the assessee’s total ... Section 153C were initiated. Accordingly, notices under Section 153C were issued to the assessee on 08.09.2022. 9. In this case, the handing over of seized materials to the Jurisdictional Assessing Officer (JAO) of the assessee was on 08.09.2022. In such case, the said date has to be construed

Sundarasamy Kohila, Tiruppur vs. ACIT, Central Circle-3, Coimbatore

In the result, all the appeals of the assessee are allowed

ITA 2204/CHNY/2025[2019-20]Status: DisposedITAT Chennai07 Jan 2026AY 2019-20

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

For Appellant: Mr. S.Sridhar, Advocate (Erode)For Respondent: Ms.E.Pavuna Sundari, CIT
Section 132Section 132(4)Section 139(1)Section 153CSection 250

that the assessee had engaged in a loan transaction with Shri G. N. Anbuchezian, a prominent financier in the Tamil Nadu film industry. The seized material further revealed cash dealings between the assessee and Shri G. N. Anbuchezian, which were directly relevant to the computation of the assessee’s total ... Section 153C were initiated. Accordingly, notices under Section 153C were issued to the assessee on 08.09.2022. 9. In this case, the handing over of seized materials to the Jurisdictional Assessing Officer (JAO) of the assessee was on 08.09.2022. In such case, the said date has to be construed