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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

Vadiappan Senthilmurugan, Erode vs. ACIT, Central Circle-3, Coimbatore

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

ITA 2188/CHNY/2025[2021-22]Status: DisposedITAT Chennai07 Jan 2026AY 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

Seethadevi, Erode vs. ACIT, Central Circle-3, Coimbatore

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

ITA 2171/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

Arunraj, Erode vs. ACIT, Central Circ 3, Cbe, Coimbatore

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

ITA 2168/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

Everyeady Spinning Mills Private Limited, Triupur vs. ACIT, Central Cricle 3, Coimbatore

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

ITA 2144/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

Moorthy Ramasubramanian, Tuticorin vs. DCIT, Circle-1, Tirnelveli

In the result, the appeal of the assessee is allowed

ITA 2007/CHNY/2025[2018-19]Status: DisposedITAT Chennai07 Jan 2026AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadish

For Appellant: Shri H. Yeshwanth Kumar, AdvocateFor Respondent: Ms. R. Anitha, Addl.CIT
Section 143(1)Section 143(3)Section 144BSection 145(3)

absent in the present case. The computation of alleged unaccounted sales running into several crores is based solely on mathematical assumptions without any seized material, suppressed invoices, or evidence of unrecorded transactions. Estimation of income must have a rational nexus with facts; suspicion and conjectures cannot substitute evidence. The impugned

Deputy Commissioner of Income Tax, Delhi vs. E-Homes Infrastructure Pvt. Ltd., Delhi

In the result, the appeal of the Revenue is dismissed and Cross-

ITA 2887/DEL/2025[2021-22]Status: DisposedITAT Delhi07 Jan 2026AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshe-Homes Infrastructure Deputy Commissioner Of Pvt. Ltd. Income Tax, Vs. Room No.343, Delhi. 3Rd Floor, Ara Centre, Jhandewalan Extn., New Delhi-110001 Pan-Aabce9129Q (Appellant) (Respondent) C.O. No. 107/Del/2025 Arising Out Of Ita No.2887/Del/2025 (Assessment Year 2021-22) Deputy Commissioner Of E-Homes Infrastructure Income Tax, Pvt. Ltd. Vs. Delhi. Room No.343, 3Rd Floor, Ara Centre, Jhandewalan Extn., New Delhi-110001 Pan-Aabce9129Q (Appellant) (Respondent)

Section 132Section 143(3)Section 153CSection 28

even when this interpretation is contrary to the legislative intent since for the years after the search there can never be C.O. No.107/Del/2025 incriminating seized material and as such assessment in years cannot be made u/s 153C of the Act? 5. That the order of the CIT (A) is perverse

Income Tax Officer, Ward 16(3), C R Building, Ip Estate New Delhi vs. Mb Infrabuild Private Limited, Rohini Northwest Delhi

Appeal are hereby allowed

ITA 3358/DEL/2024[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 3358/Del/2024 : Asstt. Year : 2018-19 Income Tax Officer, Vs Mb Infrabuild Pvt. Ltd., Ward-16(3), House No. 863, Sector-13, Veer New Delhi-110002 Apartment, Rohini, New Delhi-110085 (Appellant) (Respondent) Pan No. Aahcm5701E Assessee By : Sh. Raghav Sharma, Ca, Sh. Mohit Gupta, Ca & Ms. Agni Choudhary, Adv. Revenue By : Ms. Ankush Kalra, Sr. Dr Date Of Hearing: 07.01.2026 Date Of Pronouncement: 07.01.2026 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2018-19, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024–25/106607632(1) Dated 25.06.2024, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Raghav Sharma, CAFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 132Section 147

Total 1,00,00,000/- As mentioned, the above information was based upon post-search investigation. Further AO has reproduced some of the seized materials and reply of the Sumit Jindal but AO has not connected to above entries with the reproduced documents in the final addition made ... been even bothered to either offer any cross examination for the purpose of necessary verification nor the impugned addition is based on any seized material as rightly recorded in the CIT(A)’s detailed discussion. The Revenue has further failed to support the impugned addition by any other evidence

Neetal Relan, New Delhi vs. ACIT, Central Circle-14, New Delhi

In the result, both the appeal of the assessee in ITA No

ITA 3038/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 153CSection 250

have stated that certain documents and information pertained to the assessee. Accordingly, the AO of searched person recorded his satisfaction and handed over relevant seized material to the AO of assessee. Subsequently, satisfaction was recorded by the AO of assessee on 19.11.2020 and notice u/s 153C was issued ... with the AO from time to time with reference to the issues relating to different assessment years and the nature of contents of the seized material. She thus submits that by any stretch of imagination, it cannot be inferred that Range Head was not in a position to apply

Neetal Relan, New Delhi vs. ACIT, Central Circle-14, New Delhi

In the result, both the appeal of the assessee in ITA No

ITA 3037/DEL/2023[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 153CSection 250

have stated that certain documents and information pertained to the assessee. Accordingly, the AO of searched person recorded his satisfaction and handed over relevant seized material to the AO of assessee. Subsequently, satisfaction was recorded by the AO of assessee on 19.11.2020 and notice u/s 153C was issued ... with the AO from time to time with reference to the issues relating to different assessment years and the nature of contents of the seized material. She thus submits that by any stretch of imagination, it cannot be inferred that Range Head was not in a position to apply

Arundhati Dnyandeo Kalane, Ahilyanagar vs. ITO, Ward-1, Ahilyanagar

In the result, the appeal filed by the assessee is partly allowed as per the terms indicated above

ITA 623/PUN/2025[2013-14]Status: DisposedITAT Pune06 Jan 2026AY 2013-14

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.623/Pun/2025 Assessment Year : 2013-14

For Appellant: Shri Prasad BhandariFor Respondent: Shri Bharat Andhale
Section 147Section 250Section 69

that the assessee is an individual and did not file any return of income for A.Y. 2013- 14. Based on the information about seized material found during the course of search and seizure action carried out in the case of Nandan Group and Shri Shamkant Kotkar, assessee was issued notice ... During the course of re-assessment proceedings, ld. AO 4 Arundhati Dnyandeo Kalane mentioned that on page 39 Bundle No.2 of the seized material found during the course of search at Nandan Group and based on such information appearing in such seized material he concluded that the assessee has made

Deepak Kakubhai Mehta, Mumbai vs. DCIT, Central Circle 4(1), Mumbai

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

ITA 6511/MUM/2025[2018-19]Status: DisposedITAT Mumbai06 Jan 2026AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 1Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 30Section 56

which could justify the additions made in the assessment orders. The learned counsel emphasised that the assessment orders themselves do not refer to any seized material found from the assessee. Mr Bindal the Ld. Counsel of the assessee submitted that in the statements recorded ... specific and exclusive mechanism under section 153C of the Act. 36.1. Section 153C mandates, as a condition precedent, the recording of satisfaction that the seized material belongs to or pertains to the assessee, followed by the lawful transmission of such material to the Assessing Officer having jurisdiction over the assessee

Deepak Kakubhai Mehta, Mumbai vs. DCIT, Central Circle 4(1), Mumbai

ITA 6510/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Jan 2026AY 2017-18
Section 1Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 30Section 56

which could justify the additions made in the assessment orders. The learned counsel emphasised that the assessment orders themselves do not refer to any seized material found from the assessee. Mr Bindal the Ld. Counsel of the assessee submitted that in the statements recorded ... specific and exclusive mechanism under section 153C of the Act. 36.1. Section 153C mandates, as a condition precedent, the recording of satisfaction that the seized material belongs to or pertains to the assessee, followed by the lawful transmission of such material to the Assessing Officer having jurisdiction over the assessee

Deepak Kakubhai Mehta, Mumbai vs. DCIT, Central Circle 4(1), Mumbai

ITA 6509/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Jan 2026AY 2016-17
Section 1Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 30Section 56

which could justify the additions made in the assessment orders. The learned counsel emphasised that the assessment orders themselves do not refer to any seized material found from the assessee. Mr Bindal the Ld. Counsel of the assessee submitted that in the statements recorded ... specific and exclusive mechanism under section 153C of the Act. 36.1. Section 153C mandates, as a condition precedent, the recording of satisfaction that the seized material belongs to or pertains to the assessee, followed by the lawful transmission of such material to the Assessing Officer having jurisdiction over the assessee

Deepak Kakubhai Mehta, Mumbai vs. DCIT, Central Circle 4(1), Mumbai

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

ITA 6508/MUM/2025[2015-16]Status: DisposedITAT Mumbai06 Jan 2026AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 1Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 30Section 56

which could justify the additions made in the assessment orders. The learned counsel emphasised that the assessment orders themselves do not refer to any seized material found from the assessee. Mr Bindal the Ld. Counsel of the assessee submitted that in the statements recorded ... specific and exclusive mechanism under section 153C of the Act. 36.1. Section 153C mandates, as a condition precedent, the recording of satisfaction that the seized material belongs to or pertains to the assessee, followed by the lawful transmission of such material to the Assessing Officer having jurisdiction over the assessee

Deepak Kakubhai Mehta, Mumbai vs. DCIT, Central Circle 4(1), Mumbai

ITA 6507/MUM/2025[2014-15]Status: DisposedITAT Mumbai06 Jan 2026AY 2014-15
Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 56Section 69Section 69A

which could justify the additions\nmade in the assessment orders. The learned counsel\nemphasised that the assessment orders themselves do not\nrefer to any seized material found from the assessee. Mr\nBindal the Ld. Counsel of the assessee submitted that in the\nstatements recorded ... specific and\nexclusive mechanism under section 153C of the Act.\n36.1. Section 153C mandates, as a condition precedent, the\nrecording of satisfaction that the seized material belongs to or\npertains to the assessee, followed by the lawful transmission\nof such material to the Assessing Officer having jurisdiction\nover the assessee

Deepak Kakubhai Mehta, Mumbai vs. DCIT, Central Circle 4(1), Mumbai

ITA 6506/MUM/2025[2013-14]Status: DisposedITAT Mumbai06 Jan 2026AY 2013-14
Section 1Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 4Section 56

which could justify the additions made in the assessment orders. The learned counsel emphasised that the assessment orders themselves do not refer to any seized material found from the assessee. Mr Bindal the Ld. Counsel of the assessee submitted that in the statements recorded ... specific and exclusive mechanism under section 153C of the Act. 36.1. Section 153C mandates, as a condition precedent, the recording of satisfaction that the seized material belongs to or pertains to the assessee, followed by the lawful transmission of such material to the Assessing Officer having jurisdiction over the assessee

Deepak Kakubhai Mehta, Mumbai vs. DCIT Central Circle - 4(1), Mumbai

ITA 6505/MUM/2025[2012-13]Status: DisposedITAT Mumbai06 Jan 2026AY 2012-13
Section 1Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 56Section 69

which could justify the additions made in the assessment orders. The learned counsel emphasised that the assessment orders themselves do not refer to any seized material found from the assessee. Mr Bindal the Ld. Counsel of the assessee submitted that in the statements recorded ... specific and exclusive mechanism under section 153C of the Act. 36.1. Section 153C mandates, as a condition precedent, the recording of satisfaction that the seized material belongs to or pertains to the assessee, followed by the lawful transmission of such material to the Assessing Officer having jurisdiction over the assessee

DCIT, Central Circle 7(1), Mumbai vs. Subhkaran & Sons, Mumbai

In the result, appeal of the assessee is allowed and that by the revenue is dismissed, for Assessment Year 2013-14

ITA 3986/MUM/2025[2014-15]Status: DisposedITAT Mumbai06 Jan 2026AY 2014-15

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Snehal Shah, CAFor Respondent: Shri R A Dhyani, CIT DR
Section 1Section 132

Officer erred in issuing notice u/s 153A of the Income Tax Act, 1961 without appreciating the fact that there are no incriminating documents in seized material suggesting that any income has escaped assessment. Hence, the notice issued u/s 153A of the Act is clearly Bad in Law, illegal and ultra

DCIT, Central Circle 7(1), Mumbai vs. Subhkaran & Sons, Mumbai

In the result, appeal of the assessee is allowed and that by the revenue is dismissed, for Assessment Year 2013-14

ITA 3969/MUM/2025[2015-16]Status: DisposedITAT Mumbai06 Jan 2026AY 2015-16

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Snehal Shah, CAFor Respondent: Shri R A Dhyani, CIT DR
Section 1Section 132

Officer erred in issuing notice u/s 153A of the Income Tax Act, 1961 without appreciating the fact that there are no incriminating documents in seized material suggesting that any income has escaped assessment. Hence, the notice issued u/s 153A of the Act is clearly Bad in Law, illegal and ultra

DCIT, Central Circle 7(1), Mumbai vs. Subhkaran & Sons, Mumbai

In the result, appeal of the assessee is allowed and that by the revenue is dismissed, for Assessment Year 2013-14

ITA 3968/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Jan 2026AY 2017-18

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Snehal Shah, CAFor Respondent: Shri R A Dhyani, CIT DR
Section 1Section 132

Officer erred in issuing notice u/s 153A of the Income Tax Act, 1961 without appreciating the fact that there are no incriminating documents in seized material suggesting that any income has escaped assessment. Hence, the notice issued u/s 153A of the Act is clearly Bad in Law, illegal and ultra