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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. Yardley Investment and Trading Company Pvt Ltd, Mumbai

Accordingly, the cross-objection filed by the assessee is allowed, and the appeal by the Revenue is dismissed

ITA 4725/MUM/2025[2013-14]Status: DisposedITAT Mumbai02 Jan 2026AY 2013-14

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankarassessment Year : 2013-14 Deputy Commissioner Of Income Tax, Central Circle - 7(1), Room No.653, 6Th Floor Aayakar Bhavan, M.K. Road, ……………. Appellant Mumbai – 400020 V/S Yardley Investment & Trading Company Pvt. Ltd. 1, Pearl Mansion N, 91, M.K. Road, Mumbai – 400020 ……………. Respondent Pan: Aaacy0327M

For Appellant: Shri Snehal ShahFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 132Section 153ASection 250Section 68

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 ... reflected in regular books or documents did not represent the true state of affairs. these conditions are satisfied, it cannot be held that every seized material or document or information is, incriminating in nature justifying the additions in unabated assessments.” ITA No.4725/Mum/2025 & CO No.223/Mum/2025

Assistant Commissioner of Income Tax, CC-30, New Delhi vs. Sh. Radhey Shyam Bansal, New Delhi

Accordingly. Hence, the AO is directed to restrict the additions only to the income on account of commission @0.50% as mentioned in the table above. These grounds may be treated as partly allowed

ITA 5721/DEL/2025[2012-13]Status: DisposedITAT Delhi02 Jan 2026AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 1Section 132(4)Section 143(3)Section 250Section 68

entries therein except stating the dairies are rough and not relatable to any transactions either in the bank or in books of accounts. The seized material has been gone through. The content ITA No.5719 to 5721/Del/2025 ACIT Vs. Radhey Shyam Bansal of the dairy narrate a true transaction

Assistant Commissioner of Income Tax, CC-30, New Delhi vs. Sh. Radhey Shyam Bansal, New Delhi

Accordingly. Hence, the AO is directed to restrict the additions only to the income on account of commission @0.50% as mentioned in the table above. These grounds may be treated as partly allowed

ITA 5720/DEL/2025[2011-12]Status: DisposedITAT Delhi02 Jan 2026AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 1Section 132(4)Section 143(3)Section 250Section 68

entries therein except stating the dairies are rough and not relatable to any transactions either in the bank or in books of accounts. The seized material has been gone through. The content ITA No.5719 to 5721/Del/2025 ACIT Vs. Radhey Shyam Bansal of the dairy narrate a true transaction

Assistant Commissioner of Income Tax, CC-30, New Delhi vs. Sh. Radhey Shyam Bansal, New Delhi

Accordingly. Hence, the AO is directed to restrict the additions only to the income on account of commission @0.50% as mentioned in the table above. These grounds may be treated as partly allowed

ITA 5719/DEL/2025[2010-11]Status: DisposedITAT Delhi02 Jan 2026AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 1Section 132(4)Section 143(3)Section 250Section 68

entries therein except stating the dairies are rough and not relatable to any transactions either in the bank or in books of accounts. The seized material has been gone through. The content ITA No.5719 to 5721/Del/2025 ACIT Vs. Radhey Shyam Bansal of the dairy narrate a true transaction

Ashokkumar Prahladbai Patel, India vs. DCIT, Circle 2(1)(1), India

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

ITA 1300/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2016-17

Section 132Section 143(3)Section 69A

been explained by the Assessing Officer while proceeding against the assessee. The statements of the persons recorded during search with reference to the alleged, seized material, was not provided to the assessee Ashokkumar Prahladbai Patel vs DCIT Page 8 of 9 and hence, the entire proceedings under Section 153C

Shamkant Keshav Kotkar (Prop. Nandan Builders), Pune vs. Pr. Commissioner of Income Tax (Central), Pune

In the result, appeal of the assessee is allowed

ITA 1358/PUN/2025[2017-18]Status: DisposedITAT Pune31 Dec 2025AY 2017-18

Bench: SHRI VINAY BHAMORE (Judicial Member)

Section 132Section 142(1)Section 143(3)Section 153Section 153ASection 153CSection 26Section 263Section 40

PCIT erred in law and on fact in not appreciating that, there is no mention of Appellant or any related group / individual in the seized material of Mr. Sachin Nahar, or of the alleged cash transaction with Mr. Sachin Nahar on the basis of which it has been concluded that

Rainbow Vanijya Pvt Ltd., New Delhi vs. ACIT, Kolkata

In the result, the appeal of the assessee is allowed

ITA 1891/KOL/2025[2020-21]Status: DisposedITAT Kolkata31 Dec 2025AY 2020-21
Section 142(1)Section 143(2)Section 143(3)Section 144BSection 44A

corroboration. Suspicion, however strong, cannot replace evidence. In the present case, the AO did not establish any direct nexus between the assessee and the seized material. The assessee categorically denied having any business transaction with M/s J.M. Jain LLP and produced purchase bills and confirmations from other regular suppliers ... justified in making an addition of ₹61,49,041/- without rejecting the books of account under section 145(3), furnishing seized materials to the assessee and (establishing any nexus between the assessee and the alleged unaccounted purchases. Accordingly, we hold that the said addition of Rs.61,49,041/- is unjustified

Preeti Pankaj Patel, Navi Mumbai vs. ACIT, Central Circle-2, Thane

In the result, the appeal of the assessee is allowed

ITA 3249/MUM/2025[2020-21]Status: DisposedITAT Mumbai31 Dec 2025AY 2020-21

Bench: Shri Pawan Singh& Shri Omkareshwar Chidara(Physical Hearing) Preeti Pankaj Patel Acit,Central Circle -2, Thane Flat No. 1401, 14Th Floor, D Wing, Ashar It Park, 6Th Floor, Wagale Vs Palm Beach Residency, Navi Mumbai, Industrial Estate, Thane – Thane – 400706. 400604. [Pan: Aujpp1319G] Appellant / Assessee Respondent / Revenue

Section 143(2)Section 254(1)Section 68

assessee is daughter of head of group. During the search action, statement of key person of group was recorded. In the statement seized material was explained to the satisfaction of authorised officer. The assessee while filing return of income has declared income of Rs. 5,97,880/-. The assessing officer

Dy. Commissioner of Income Tax, Central Circle-3, Delhi vs. Apoorva Leasing Finance and Investment Company Ltd., Delhi

In the result, the appeal is partly allowed

ITA 635/DEL/2025[2011-12]Status: DisposedITAT Delhi31 Dec 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarassessment Year : 2011-12 Dcit, Vs. Apoorva Leasing Finance & Central Circle-3, Investment Company Ltd., Delhi. Third Floor, 13/331, Geeta Colony, Delhi – 110 031. Pan: Aabca0282A Co No.179/Del/2025 (Ita No.635/Del/2025) Assessment Year : 2011-12 Apoorva Leasing Finance & Vs. Dcit, Investment Company Ltd., Circle-3(1), Third Floor, 13/331, New Delhi. Geeta Colony, Delhi – 110 031. Pan: Aabca0282A (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate & Shri Somil Agarwal, Advocate Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 30.10.2025 Date Of Pronouncement : 31.12.2025 Order Per Vimal Kumar, Jm:

For Appellant: Dr. Rakesh Gupta, Advocate &For Respondent: Shri Om Parkash, Sr. DR
Section 143(1)Section 143(3)Section 147Section 148Section 153CSection 250

belonging to the assessee company were found and seized to initiate the proceedings u/s 153C of the Act. It clearly establishes that all the seized material during the search and all the information gathered after the search were taken into account while framing this assessment ... April 2010 which means that these transactions were well before the date of search and had gone through the scrutiny along with all the seized material proving that there was nothing adverse found even during the search for these transactions. The detail as referred here along with submission

Manohar Filaments Pvt Ltd, Delhi vs. PCIT, Central-3, Delhi

In the result, the appeal of the assessee is partly allowed as indicated above

ITA 2645/DEL/2025[2017-18]Status: DisposedITAT Delhi31 Dec 2025AY 2017-18

Bench: Shri C.N. Prasad & Shri M. Balaganesh[Assessment Year: 2017-18 ] Manohar & Filaments Pvt. `Vs. Pcit, (Central)-3, Delhi Ltd, B-59, G. T. Karnal Road, Industrial, Area, New Delhi Pan No.Aaacm1116E Appellant Respondent

Section 153ASection 153CSection 153DSection 263

assessment order to make enquiries in respect of loan transactions amounting to Rs.5,50,000/- when the loan transactions are not part of any seized material nor they are part of the satisfaction note recorded by the AO. Therefore, the Ld. Counsel submitted that the Ld.PCIT travelled beyond the scope

Assistant Commissioner of Income Tax, Delhi vs. The Indure Private Limited, Delhi

In the result, the appeal filed by the Department of Revenue is dismissed

ITA 4640/DEL/2024[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2013-14 Assistant Commissioner Of Vs. The Indure Private Limited, Income Tax, Indure House, Greater Kailash Part Ii, Delhi South Delhi 1100 48 Pan :Aaact0121C (Appellant) (Respondent)

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 250Section 69C

Commissioner of Income Tax vs Ashwani Gupta, 2010(2) TMI 42 which states about the principles of natural justice to assessee 7 where seized material is not provided nor cross exammation of the person on whose statements the Assessing officer relied upon granted. e) assessee's contention is that

Deputy Commissioner of Income Tax, Meerut vs. Sunder Singh, Ghaziabad

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

ITA 376/DEL/2024[2016-17]Status: DisposedITAT Delhi31 Dec 2025AY 2016-17

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 143(2)Section 153ASection 68

submitted that the AO made additions u/s.68 in respect of unexplained loans and cash credits for all these assessment years based on seized materials and there was no compliance by the assessee during the course of assessment proceedings. The Ld. DR submitted that despite summon issued u/s.131

Deputy Commissioner of Income Tax, Meerut vs. Sunder Singh, Ghaziabad

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

ITA 369/DEL/2024[2015-16]Status: DisposedITAT Delhi31 Dec 2025AY 2015-16

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 143(2)Section 153ASection 68

submitted that the AO made additions u/s.68 in respect of unexplained loans and cash credits for all these assessment years based on seized materials and there was no compliance by the assessee during the course of assessment proceedings. The Ld. DR submitted that despite summon issued u/s.131

Deputy Commissioner of Income Tax, Meerut vs. Sunder Singh, Ghaziabad

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

ITA 368/DEL/2024[2014-15]Status: DisposedITAT Delhi31 Dec 2025AY 2014-15

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 143(2)Section 153ASection 68

submitted that the AO made additions u/s.68 in respect of unexplained loans and cash credits for all these assessment years based on seized materials and there was no compliance by the assessee during the course of assessment proceedings. The Ld. DR submitted that despite summon issued u/s.131

Deputy Commissioner of Income Tax, Meerut vs. Sunder Singh, Ghaziabad

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

ITA 367/DEL/2024[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 143(2)Section 153ASection 68

submitted that the AO made additions u/s.68 in respect of unexplained loans and cash credits for all these assessment years based on seized materials and there was no compliance by the assessee during the course of assessment proceedings. The Ld. DR submitted that despite summon issued u/s.131

Shri Shah Afroze Hossain, Bhagalpur vs. Dy. CIT, Cent, Cir-2, Patna

In the result, the appeal of the assessee is partly allowed in terms indicated above

ITA 711/PAT/2024[2022-23]Status: DisposedITAT Patna30 Dec 2025AY 2022-23

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.711/Pat/2024 Assessment Year: 2022-23 Shri Shah Afroze Hossain.….…………………....…………………....Appellant 12, Shahganjhi, Habibpur, Bhagalpur, Bihar-812006. [Pan: Aapph1112D] Vs. Dcit, Central Circle-2, Patna..………....…..………………….…..... Respondent Appearances By: Shri Manish Rastogi, Adv., Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : December 30, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A), Patna-3 (Hereinafter Referred To As “Ld. Cit(A)”) Dated 22.10.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Assessment Year 2022–23 Declaring A Total Income Of ₹75,56,770, Comprising The Income From Business Of ₹6,54,569, Long- Term Capital Gains: ₹49,60,293 & Income From Other Sources Of ₹19,35,912. A Search & Seizure Operation Under Section 132 Of The Act Was Carried Out On 29.12.2022 At The Residential & Business Premises Of The Assessee Pursuant To A Warrant Of Authorisation Issued By The Director Of Investigation, Patna. During The Course Of The Search

Section 132Section 142(1)Section 143(2)Section 250Section 50CSection 50C(2)

money introduced in business of ₹26,50,000, Addition under section 50C of the Act of ₹76,93,500 and unexplained expenditure based on seized material of ₹10,85,000. Thus, total additions of ₹1,76,51,420 were made. 3. Aggrieved by the assessment order, the assessee preferred ... issue No. 1 relating to addition on account of Undisclosed Business Income, the Ld. AR stated that the Assessing Officer, on the basis of seized material marked MBF-14 to MBF-19, worked out gross receipts at ₹2,90,34,175 and corresponding expenses at ₹3,08,62,320. After

Deputy Commisioner of Income Tax Central Circle 1(4) Ahmedabad, Ahmedabad vs. Falguni Suryakant Thakar, Ahmedabad

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

ITA 1563/AHD/2025[2009-10]Status: DisposedITAT Ahmedabad30 Dec 2025AY 2009-10

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 139Section 142(1)Section 153ASection 153A(1)Section 153CSection 271(1)(c)Section 69

covered u/s. 153A, or, 153C, as the case may be. ii. I have carefully perused the details of ledger presented to me in the seized material. The date of search is 06.03.2018. The relevant Search assessment year is AY. 2018-19. The ledger in the seized material suggests a prima ... which appears to be a date around the time the AO of the appellant has received seized material and recorded satisfaction. This pertains to AY 2022-23, or, in other words, "Search" relevant AY becomes AY 2022-23. On backward calculation, the six years would be between

Integrated Service Point Ltd., Chennai vs. ACIT, CC-2(4), Chennai

ITA 1883/CHNY/2025[2022-23]Status: DisposedITAT Chennai30 Dec 2025AY 2022-23

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Pvt. Ltd.,) Vs. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing घोषण की तारीख / Date Of Pronouncement : 13.10.2025 : 30.12.2025 :- 2 -:

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

goods made are bogus in nature. This deposition of Shri Stanley Babu was partially affirmed by the Director, Shri Karlapatti Srikanth Apparao. The seized material in the form of an excel sheet contained in the hard disk drive had entries which the DDIT (Inv.) Unit-3(4), Chennai could correspond ... arise. 3.2 It is learnt that the company, subsequent to the conclusion of search proceedings in January 2023 and on obtaining the copies of seized materials and sworn statements, it had filed a letter before the DDIT(inv) dated 22.03.2023, in which it had covered all the issues

Integrated Service Point Ltd., Chennai vs. ACIT, Central Circle-2(4), Chennai

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

ITA 1882/CHNY/2025[2019-20]Status: DisposedITAT Chennai30 Dec 2025AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

goods made are bogus in nature. This deposition of Shri Stanley Babu was partially affirmed by the Director, Shri Karlapatti Srikanth Apparao. The seized material in the form of an excel sheet contained in the hard disk drive had entries which the DDIT (Inv.) Unit-3(4), Chennai could correspond ... arise. 3.2 It is learnt that the company, subsequent to the conclusion of search proceedings in January 2023 and on obtaining the copies of seized materials and sworn statements, it had filed a letter before the DDIT(inv) dated 22.03.2023, in which it had covered all the issues

Integrated Service Point Ltd., Chennai vs. ACIT, Central Circle-2(4), Chennai

ITA 1881/CHNY/2025[2016-17]Status: DisposedITAT Chennai30 Dec 2025AY 2016-17

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Income Tax, Pvt. Ltd.,) The Dy./Asst. Commissioner Of Central Circle-2(4), 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Chennai. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 13.10.2025 घोषण की तारीख / Date Of Pronouncement : 30.12.2025 :- 2 -:

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

goods made are bogus in nature. This deposition of Shri Stanley Babu was partially affirmed by the Director, Shri Karlapatti Srikanth Apparao. The seized material in the form of an excel sheet contained in the hard disk drive had entries which the DDIT (Inv.) Unit-3(4), Chennai could correspond ... arise. 3.2 It is learnt that the company, subsequent to the conclusion of search proceedings in January 2023 and on obtaining the copies of seized materials and sworn statements, it had filed a letter before the DDIT(inv) dated 22.03.2023, in which it had covered all the issues