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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, 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 3967/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Jan 2026AY 2016-17

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 3966/MUM/2025[2013-14]Status: DisposedITAT Mumbai06 Jan 2026AY 2013-14

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

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

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

ITA 2910/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Jan 2026AY 2016-17

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

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

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

ITA 2909/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

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

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

ITA 2908/MUM/2025[2013-14]Status: DisposedITAT Mumbai06 Jan 2026AY 2013-14

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

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

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

ITA 2907/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

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

In the result, appeal of the assessee is allowed and that by the

ITA 2906/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 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

Virendra Vijaysingh Pardeshi, Nashik vs. Income Tax Office Ward 2(1) Nashik, Nashik

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

ITA 2620/PUN/2025[2020-21]Status: DisposedITAT Pune05 Jan 2026AY 2020-21

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2620/Pun/2025 िनधा"रण वष" / Assessment Year : 2020-21 Virendra Vijaysingh Vs. Ito, Ward-2(1), Nashik. Pardeshi, Row House No.10, Swapnpurti Cooperative Housing Society, Kalptaru Nagar, Nashik- 422006. Pan : Anhpp9809L Appellant Respondent Assessee By : Shri Rakesh Pardeshi Revenue By : Shri Ganesh B. Budruk Date Of Hearing : 18.12.2025 Date Of Pronouncement : 05.01.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.09.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2020-21. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. The Learned Cit-Appeals Erred In Upholding The Addition Of Rs.2500000 Made By The Assessing Officer U/S 69A Of The Income-Tax Act, 1961, Merely For Non-Appearance Relying Solely On Procedural Default & Ignoring That Appellate Proceedings Are Continuation Of Assessment & Must Be Decided On Merits Based On Record & Written Submissions Already Filed.

For Appellant: Shri Rakesh PardeshiFor Respondent: Shri Ganesh B. Budruk
Section 139(4)Section 143(2)Section 147Section 148Section 250(6)Section 271DSection 68Section 69A

significant fact that the Department itself had not made any income addition (u/s 68 or 69A) in A.Y, 2017-18 based on the same seized materials, instead treating the alleged receipt as a cash loan (proposing penalty u/s 271D) The present addition of repayment as "unexplained money" is therefore contradictory

Vikas Motiram Desai, Mumbai vs. ITO Ward 22(3)(5), Mumbai

ITA 4741/MUM/2025[2012-13]Status: DisposedITAT Mumbai05 Jan 2026AY 2012-13

Bench: Shri Sandeep Gosain & Shri Bijayananda Pruseth

Section 132Section 132(4)Section 143Section 148Section 250Section 69A

your good self ready reference). 7. In response to point 4 of your good self letter dated 10.02.2021 this office have not received any seized material pertain to M/s. Evergreen Enterprises. However, the statement of Mr. Nilesh Bharani recorded on 11.10.2017 by the Investigation Wing is available with this office ... signed without understanding as he was in very disturbed state of mind. He has stated that he has not received copy of all seized material 8 Vikas Motiram Desai, Mumbai. In view of the above, the statement qiven by Mr. Nilesh Bharani on 11/10/2017 cannot be relied upon to make

M/S. Shakambhari Ispat & Power Ltd., Kolkata vs. DCIT, Central Circle 3(3), Kolkata

ITA 931/KOL/2025[2019-2020]Status: DisposedITAT Kolkata02 Jan 2026AY 2019-2020
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

appellant is found to be misleading. Reading of the assessment order clearly shows that the complete details of the transactions found in the seized material from the premises of Anup Majee Group had been confronted to the appellant and there only stand was denial. Even in the remand proceedings ... availed this opportunity given by this office. The AO is noted to have nowhere denied the appellant, access or the inspection of the seized material. Understandably, the relevant data found from the premises of the Anup Majee Group was mammoth in nature and most of them were electronic evidences maintained

Deputy Commissioner of Income Tax, Central Circle 3(1), Kolkata vs. Shakambhari Ispat & Power Limited, Kolkata

ITA 1591/KOL/2025[2021-22]Status: DisposedITAT Kolkata02 Jan 2026AY 2021-22
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

appellant is found to be misleading. Reading of the assessment order clearly shows that the complete details of the transactions found in the seized material from the premises of Anup Majee Group had been confronted to the appellant and there only stand was denial. Even in the remand proceedings ... availed this opportunity given by this office. The AO is noted to have nowhere denied the appellant, access or the inspection of the seized material. Understandably, the relevant data found from the premises of the Anup Majee Group was mammoth in nature and most of them were electronic evidences maintained

Deputy Commissioner of Income Tax, Kolkata vs. Shakambhari Ispat & Power Limited, Kolkata

ITA 1561/KOL/2025[2020-21]Status: DisposedITAT Kolkata02 Jan 2026AY 2020-21
Section 132Section 132(1)Section 147Section 148

appellant is found to be misleading. Reading of the assessment order clearly shows that the complete details of the transactions found in the seized material from the premises of Anup Majee Group had been confronted to the appellant and there only stand was denial. Even in the remand proceedings ... availed this opportunity given by this office. The AO is noted to have nowhere denied the appellant, access or the inspection of the seized material. Understandably, the relevant data found from the premises of the Anup Majee Group was mammoth in nature and most of them were electronic evidences maintained

Deputy Commissioner of Income Tax, Kolkata vs. Shakambhari Ispat & Power Limited, Kolkata

ITA 1560/KOL/2025[2019-20]Status: DisposedITAT Kolkata02 Jan 2026AY 2019-20
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

appellant is found to be misleading. Reading of the assessment order clearly shows that the complete details of the transactions found in the seized material from the premises of Anup Majee Group had been confronted to the appellant and there only stand was denial. Even in the remand proceedings ... availed this opportunity given by this office. The AO is noted to have nowhere denied the appellant, access or the inspection of the seized material. Understandably, the relevant data found from the premises of the Anup Majee Group was mammoth in nature and most of them were electronic evidences maintained

D.C.I.T., CC - 3(1), Kolkata vs. Shakambhari Ispat & Power Limited, Kolkata

ITA 1541/KOL/2025[2018-19]Status: DisposedITAT Kolkata02 Jan 2026AY 2018-19
Section 132Section 132(1)Section 147Section 148

appellant is found to be misleading. Reading of the assessment order clearly shows that the complete details of the transactions found in the seized material from the premises of Anup Majee Group had been confronted to the appellant and there only stand was denial. Even in the remand proceedings ... availed this opportunity given by this office. The AO is noted to have nowhere denied the appellant, access or the inspection of the seized material. Understandably, the relevant data found from the premises of the Anup Majee Group was mammoth in nature and most of them were electronic evidences maintained

Deputy Commissioner of Income Tax, Kolkata vs. Shakambhari Ispat & Power Limited, Kolkata

ITA 1515/KOL/2025[2017-18]Status: DisposedITAT Kolkata02 Jan 2026AY 2017-18
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

appellant is found to be misleading. Reading of the assessment order clearly shows that the complete details of the transactions found in the seized material from the premises of Anup Majee Group had been confronted to the appellant and there only stand was denial. Even in the remand proceedings ... availed this opportunity given by this office. The AO is noted to have nowhere denied the appellant, access or the inspection of the seized material. Understandably, the relevant data found from the premises of the Anup Majee Group was mammoth in nature and most of them were electronic evidences maintained

Deputy Commissioner of Income Tax, Central Circle 3.1, Kolkata vs. Shakambhari Ispat & Power Limited, Kolkata

ITA 1436/KOL/2025[2016-17]Status: DisposedITAT Kolkata02 Jan 2026AY 2016-17
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

appellant is found to be misleading. Reading of the assessment order clearly shows that the complete details of the transactions found in the seized material from the premises of Anup Majee Group had been confronted to the appellant and there only stand was denial. Even in the remand proceedings ... availed this opportunity given by this office. The AO is noted to have nowhere denied the appellant, access or the inspection of the seized material. Understandably, the relevant data found from the premises of the Anup Majee Group was mammoth in nature and most of them were electronic evidences maintained

M/S. Shakambhari Ispat & Power Ltd., Kolkata vs. DCIT, Central Circle 3(3), Kolkata

ITA 1198/KOL/2025[2021-2022]Status: DisposedITAT Kolkata02 Jan 2026AY 2021-2022
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

appellant is found to be misleading. Reading of the assessment order clearly shows that the complete details of the transactions found in the seized material from the premises of Anup Majee Group had been confronted to the appellant and there only stand was denial. Even in the remand proceedings ... availed this opportunity given by this office. The AO is noted to have nowhere denied the appellant, access or the inspection of the seized material. Understandably, the relevant data found from the premises of the Anup Majee Group was mammoth in nature and most of them were electronic evidences maintained

M/S. Shakambhari Ispat & Power Ltd., Kolkata vs. DCIT, Central Circle 3(3), Kolkata

ITA 1196/KOL/2025[2018-2019]Status: DisposedITAT Kolkata02 Jan 2026AY 2018-2019
Section 132Section 132(1)Section 147Section 148

appellant is found to be misleading. Reading of the assessment order clearly shows that the complete details of the transactions found in the seized material from the premises of Anup Majee Group had been confronted to the appellant and there only stand was denial. Even in the remand proceedings ... availed this opportunity given by this office. The AO is noted to have nowhere denied the appellant, access or the inspection of the seized material. Understandably, the relevant data found from the premises of the Anup Majee Group was mammoth in nature and most of them were electronic evidences maintained

M/S. Shakambhari Ispat & Power Ltd., Kolkata vs. DCIT, CC - 3(3), Kolkata

ITA 1195/KOL/2025[2017-2018]Status: DisposedITAT Kolkata02 Jan 2026AY 2017-2018
Section 132Section 132(1)Section 147Section 148

appellant is found to be misleading. Reading of the assessment order clearly shows that the complete details of the transactions found in the seized material from the premises of Anup Majee Group had been confronted to the appellant and there only stand was denial. Even in the remand proceedings ... availed this opportunity given by this office. The AO is noted to have nowhere denied the appellant, access or the inspection of the seized material. Understandably, the relevant data found from the premises of the Anup Majee Group was mammoth in nature and most of them were electronic evidences maintained

M/S. Shakambhari Ispat & Power Ltd., Kolkata vs. DCIT, Central Circle 3(3), Kolkata

ITA 1194/KOL/2025[2016-2017]Status: DisposedITAT Kolkata02 Jan 2026AY 2016-2017
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

appellant is found to be misleading. Reading of the assessment order clearly shows that the complete details of the transactions found in the seized material from the premises of Anup Majee Group had been confronted to the appellant and there only stand was denial. Even in the remand proceedings ... availed this opportunity given by this office. The AO is noted to have nowhere denied the appellant, access or the inspection of the seized material. Understandably, the relevant data found from the premises of the Anup Majee Group was mammoth in nature and most of them were electronic evidences maintained