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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

ACIT, Chennai vs. Integrated Service Point Limited, Anna Nagar

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 1879/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 ि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

ACIT, Nungambakkam vs. Integrated Service Point Limited, Anna Nagar

ITA 1876/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 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 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

ACIT, Nunagambakkam vs. Integrated Service Point Limited, Anna Nagar

ITA 1874/CHNY/2025[2016]Status: DisposedITAT Chennai30 Dec 2025

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. Pan: Aaaci 9527P Chennai. (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 Integrated Service Point Ltd., Income Tax, Central Circle-2(4), Chennai. (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 घोषणा की तारीख / Date Of Pronouncement 13.10.2025 30.12.2025 - : 2 -:

For Appellant: Mr. Y. Sridhar, FCA
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

Jayantilal Purohit, Mumbai vs. Central Circle 4(2), Mumbai

In the result, the appeals by the assessee are allowed

ITA 5684/MUM/2025[2019-20]Status: DisposedITAT Mumbai30 Dec 2025AY 2019-20

Bench: Shri Sandeep Singh Karhailshri Makarand Vasant Mahadeokar

For Appellant: Shri Vimal PunamiyaFor Respondent: Shri Vivek Perampurna, CIT-DR
Section 132Section 144Section 153CSection 250Section 69

been claimed in the order of assessment that the assessee had paid on money, but again no such statement has been confronted, neither the seized material /documents /pendrive was confronted to the assessee nor the copy of statement of Key person was confronted. 13. Therefore, in our view, the information

Jayantilal Purohit, Mumbai vs. Central Circle 4(2), Mumbai

In the result, the appeals by the assessee are allowed

ITA 5683/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Dec 2025AY 2018-19

Bench: Shri Sandeep Singh Karhailshri Makarand Vasant Mahadeokar

For Appellant: Shri Vimal PunamiyaFor Respondent: Shri Vivek Perampurna, CIT-DR
Section 132Section 144Section 153CSection 250Section 69

been claimed in the order of assessment that the assessee had paid on money, but again no such statement has been confronted, neither the seized material /documents /pendrive was confronted to the assessee nor the copy of statement of Key person was confronted. 13. Therefore, in our view, the information

Jayantilal Purohit, Mumbai vs. Central Circle 4(2), Mumbai

In the result, the appeals by the assessee are allowed

ITA 5682/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18
For Appellant: Shri Vimal PunamiyaFor Respondent: Shri Vivek Perampurna, CIT-DR
Section 132Section 144Section 153CSection 250Section 69

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n“F” BENCH, MUMBAI\nBEFORE SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER\nSHRI

Shri Sanjay Haresh Mulchandani, Mumbai vs. Income Tax Officer Ward 19(3)(1), Mumbai

In the result, the assessee succeeds in the present appeal

ITA 4751/MUM/2025[2011-12]Status: DisposedITAT Mumbai30 Dec 2025AY 2011-12

Bench: Shri Narender Kumar Choudhryassessment Year: 2011-12 Shri Sanjay Haresh The Income Tax Officer, Mulchandani Ward, 19 (3) (1), 4-C Ajanta Apartments, M L Vs. Piramal Chamber, Dhanukar Marg, Peddar Road, Mumbai – 400013. Mumbai – 40026 Pan – Aadpm 3393 B (Appellant) (Respondent) Present For: Assessee By : Shri Harsh Kapadia & Nitin Khinchi, Ld. Ars Revenue By : Shri Sandeep Jumale, Ld. Sr. Dr Date Of Hearing : 20.11.2025 Date Of Pronouncement : 30.12.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 08.07.2025, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2011-12. 2. In The Instant Case, The Assessee Along With His Uncle Had Purchased A Flat In Iscon Platinum, Ahmedabad On A Consideration Of Rs. 59,30,000/- Through Cheques. Subsequently, Search Under Section 132 Of The Act Was Conducted By The Investigation Wing, In The Case Of Jp Iscon

For Appellant: Shri Harsh Kapadia & Nitin KhinchiFor Respondent: Shri Sandeep Jumale, Ld. Sr. DR
Section 132Section 143(1)Section 147Section 148Section 250

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 and hence, the entire proceedings under Section 153C of the IT Act of 1961 stood vitiated. 4. Learned

Mohammad Saleem, New Delhi vs. Assistant Commissioner of Income Tax Central Circle 4(4), Mumbai

ITA 3955/MUM/2025[2019-20]Status: DisposedITAT Mumbai30 Dec 2025AY 2019-20

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

Section 143(3)Section 153CSection 254(1)

other than the searched person. The Hon'ble Court held that the six-year block must be reckoned from the date on which the seized material is handed over to the jurisdictional Assessing Officer of the other person, and not from the date of search in the case ... reference point for computation of the block of six assessment years from the date of search to the date of handing over of seized material or the date of recording of satisfaction, and that any attempt by the Revenue to reckon the block with reference to the date of search

Mohammad Saleem, New Delhi vs. Assistant Commissioner of Income Tax Central Circle 4(4), Mumbai

Accordingly, to give effect to this\norder after factual verification.\n8.14 In result the appeal of assessee in 3950 to\n3954/MUM/2025 for AY 2015-16 to 2018-19, are partly allowed\nfor statistica...

ITA 3954/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Dec 2025AY 2018-19
Section 153CSection 250Section 254(1)

153C block is non est in law.\nRadha Rani v. ACIT, ITA No. 214/Asr/2023, Amritsar Bench, order\ndated 10.01.2024 Held that where seized material is used against a\nnon-searched person, then if the AY falls with immediately six\npreceding years reckoned for the substituted dated of serach

Mohammad Saleem, New Delhi vs. Assistant Commissioner of Income Tax Central Circle 4(4), Mumbai

ITA 3953/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18

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

Section 143(3)Section 153CSection 254(1)

other than the searched person. The Hon'ble Court held that the six-year block must be reckoned from the date on which the seized material is handed over to the jurisdictional Assessing Officer of the other person, and not from the date of search in the case ... reference point for computation of the block of six assessment years from the date of search to the date of handing over of seized material or the date of recording of satisfaction, and that any attempt by the Revenue to reckon the block with reference to the date of search

Mohammad Saleem, New Delhi vs. Assistant Commissioner of Income Tax Central Circle 4(4), Mumbai

ITA 3952/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Dec 2025AY 2016-17

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

Section 143(3)Section 153CSection 254(1)

other than the searched person. The Hon'ble Court held that the six-year block must be reckoned from the date on which the seized material is handed over to the jurisdictional Assessing Officer of the other person, and not from the date of search in the case ... reference point for computation of the block of six assessment years from the date of search to the date of handing over of seized material or the date of recording of satisfaction, and that any attempt by the Revenue to reckon the block with reference to the date of search

Mohammad Saleem, New Delhi vs. Assistant Commissioner of Income Tax Central Circle 4(4), Mumbai

Accordingly, to give effect to this\norder after factual verification.\n8.14 In result, the appeal of assessee in 3950 to\n3954/Mum/2025 for AY 2015-16 to 2018-19, are partly allowed\nfor statistic...

ITA 3951/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Dec 2025AY 2015-16
Section 153CSection 250Section 254(1)

153C block is non est in law.\nRadha Rani v. ACIT, ITA No. 214/Asr/2023, Amritsar Bench, order\ndated 10.01.2024 Held that where seized material is used against a\nnon-searched person, then if the AY falls with immediately six\npreceding years reckoned for the substituted dated of serach

Mohammad Saleem, New Delhi vs. Assistant Commissioner of Income Tax Central Circle 4(4), Mumbai

Accordingly, to give effect to this\norder after factual verification.\n8.14\nIn result the appeal of assessee in 3950 to\n3954/Mum/2025 for AY 2015-16 to 2018-19, are partly allowed\nfor statistic...

ITA 3950/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Dec 2025AY 2014-15
Section 153CSection 250Section 254(1)

153C block is non est in law.\n➤ Radha Rani v. ACIT, ITA No. 214/Asr/2023, Amritsar Bench, order\ndated 10.01.2024 Held that where seized material is used against a\nnon-searched person, then if the AY falls with immediately six\npreceding years reckoned for the substituted dated of serach

Mohammad Saleem, New Delhi vs. Assistant Commissioner of Income Tax Central Circle 4(4), Mumbai

Accordingly, to give effect to this\norder after factual verification.\n8.14\nIn result the appeal of assessee in 3950 to\n3954/Mum/2025 for AY 2015-16 to 2018-19, are partly allowed\nfor statistic...

ITA 3862/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Dec 2025AY 2013-14
Section 153CSection 250Section 254(1)

153C block is non est in law.\nRadha Rani v. ACIT, ITA No. 214/Asr/2023, Amritsar Bench, order\ndated 10.01.2024 Held that where seized material is used against a\nnon-searched person, then if the AY falls with immediately six\npreceding years reckoned for the substituted dated of serach

G S Automobiles Private Limited, Delhi vs. DCIT, Central Circle-6, Delhi

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

ITA 4289/DEL/2025[2015-16]Status: DisposedITAT Delhi30 Dec 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmang.S. Automobiles Private Limited, Vs. Dcit, Central Circle 6, B – 26, Okhla Industrial Area, Phase Ii, Delhi. Delhi – 110 020. (Pan : Aadcg1150B) (Appellant) (Respondent) Assessee By : Shri Neeraj Mangla, Ca Revenue By : Shri Jitender Singh, Cit Dr Date Of Hearing : 19.11.2025 Date Of Order : 30.12.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals), Delhi – 24 [“Ld. Cit(A)”, For Short] Dated 19.06.2025 For The Assessment Year 2015-16 Raising Following Grounds Of Appeal :- “1. That The Orders Passed By Ld. Ao U/S 153C Of The Act As Well As Appellate Order Passed By Ld. Cit(A) Are Bad In Law & Are Passed In Contravention Of Prevailing Law As Well As Facts Of The Case, Therefore Liable To Be Annulled. 2. That Assumption Of Jurisdiction Of Ld. Ao In Consequence Of Order Passed By Ld. Pcit U/S 127(3) Of The Act Of The Act Is Illegal & Not Tenable Under The Law Because Of Said Order Being Mechanical & Being Passed

For Appellant: Shri Neeraj Mangla, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 127(3)Section 153CSection 153DSection 68Section 69C

submitted that from the perusal of said satisfaction note, it is evident that Assessing Officer failed to demonstrate live and direct nexus between the seized material and relevant assessment year and even quantum of alleged undisclosed income was not mentioned in the satisfaction note. He pleaded that the assessment proceedings

Nitin Gupta HUF, Delhi vs. Assistant Commissioner of Income Tax, Central Circle -32, Delhi

ITA 4121/DEL/2025[2015-16]Status: DisposedITAT Delhi30 Dec 2025AY 2015-16

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 4120/Del/2025 : Asstt. Year : 2014-15 Ita No. 4121/Del/2025 : Asstt. Year : 2015-16 Nitin Gupta Huf, Vs Acit, Bt-54, Shalimar Bagh, Central Circle-32, Delhi-110088 New Delhi-110055 (Appellant) (Respondent) Pan No. Aafhn6836G Assessee By : Sh. Sumit Lalchandani, Adv. Revenue By : Sh. Mahesh Kumar, Cit-Dr Date Of Hearing: 18.12.2025 Date Of Pronouncement: 30.12.2025 Order Per Satbeer Singh Godara: These Assessee’S Twin Appeals

For Appellant: Sh. Sumit Lalchandani, AdvFor Respondent: Sh. Mahesh Kumar, CIT-DR
Section 153A(1)Section 153C

below: i) Relating to the date of reckoning for calculating six AYs backwards that can be thrown open for assessment/reassessment after search/handing over of seized material to the AO of the non-searched person; and ii) Relating to whether the assessment/reassessment can be carried out in the instant case being ... decision of the Hon’ble jurisdictional High Court of Delhi thus means six years prior to the assessment year in which the seized material was handed over to the AO of the ‘other’ (non-searched) person/satisfaction note for proceedings u/s 153C was recorded by the concerned AO. As seen from

Nitin Gupta HUF, Delhi vs. Assistant Commissioner of Income Tax, Central Circle -32, Delhi

ITA 4120/DEL/2025[2014-15]Status: DisposedITAT Delhi30 Dec 2025AY 2014-15

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 4120/Del/2025 : Asstt. Year : 2014-15 Ita No. 4121/Del/2025 : Asstt. Year : 2015-16 Nitin Gupta Huf, Vs Acit, Bt-54, Shalimar Bagh, Central Circle-32, Delhi-110088 New Delhi-110055 (Appellant) (Respondent) Pan No. Aafhn6836G Assessee By : Sh. Sumit Lalchandani, Adv. Revenue By : Sh. Mahesh Kumar, Cit-Dr Date Of Hearing: 18.12.2025 Date Of Pronouncement: 30.12.2025 Order Per Satbeer Singh Godara: These Assessee’S Twin Appeals

For Appellant: Sh. Sumit Lalchandani, AdvFor Respondent: Sh. Mahesh Kumar, CIT-DR
Section 153A(1)Section 153C

below: i) Relating to the date of reckoning for calculating six AYs backwards that can be thrown open for assessment/reassessment after search/handing over of seized material to the AO of the non-searched person; and ii) Relating to whether the assessment/reassessment can be carried out in the instant case being ... decision of the Hon’ble jurisdictional High Court of Delhi thus means six years prior to the assessment year in which the seized material was handed over to the AO of the ‘other’ (non-searched) person/satisfaction note for proceedings u/s 153C was recorded by the concerned AO. As seen from

DCIT CC -15, New Delhi vs. Jfc Finance (India) Limited, New Delhi

Appeal is dismissed in above terms

ITA 4103/DEL/2025[2012-13]Status: DisposedITAT Delhi30 Dec 2025AY 2012-13

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 4103/Del/2025 : Asstt. Year : 2012-13 Dcit, Vs Jfc Finance (India) Ltd., Central Circle-15, 944/9 & 944/10, Ground Floor, New Delhi Laxmi Complex, Nehru Road, Arjun Nagar, Kotla Mubarakpur, New Delhi-110003 (Appellant) (Respondent) Pan No. Aaacj9731E Assessee By : Sh. Sh. Gaurav Jain, Adv. & Sh. Tarun Chanana, Adv. Revenue By : Sh. Mahesh Kumar, Cit-Dr Date Of Hearing: 18.12.2025 Date Of Pronouncement: 30.12.2025 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Years 2012-13, Arises Against The Cit(A)-26, New Delhi’S Order Dated 27.02.2025 In Case No. 26/10153/2011-12, In Proceedings U/S 153C R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Sh. Gaurav Jain, Adv. &For Respondent: Sh. Mahesh Kumar, CIT-DR
Section 153A(1)Section 153CSection 153C(1)

question on 18.10.2019 which inter alia followed the searched party’s Assessing Officer’s section 153C satisfaction on 24.06.2022; who handed over the seized material on the very date to the jurisdictional assessing authority. And that this latter Assessing Officer recorded his satisfaction on 13.10.2023. The Revenue could hardly dispute ... this factual backdrop that going by the above date of handing over of the seized material to the assessee’s Assessing Officer is to be treated as the date of search itself u/s 153C(1) 1st proviso. And that the relevant ten assessment years ought to be counted u/s 153A

Prashant Soni, New Delhi vs. DCIT, Central Circle-7, Delhi

In the result, the appeal of the assessee is allowed

ITA 2612/DEL/2022[2015-16]Status: DisposedITAT Delhi30 Dec 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanprashant Soni, Vs. Dcit, Central Circle 7, M-50, First Floor, Delhi. Guru Harkishan Nagar, Sunder Vihar, New Delhi – 110 087. (Pan : Basps5961H) (Appellant) (Respondent) Assessee By : Shri Ankit Kumar, Advocate Revenue By : Shri Jitender Singh, Cit Dr Date Of Hearing : 17.11.2025 Date Of Order : 30.12.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-24, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 30.08.2022 For Assessment Year 2015-16. 2. At The Outset, Ld. Ar Of The Assessee Raised Legal Issue Relating To Assumption Of Jurisdiction Under Section 153C Of The Income-Tax Act, 1961 (For Short ‘The Act’) By Raising Ground Nos.1 & 2 Which Read As Under :- “1. On The Facts & Circumstances Of The Case, The Order Passed By The Ld. Ao & Impugned Order Passed By The Cit (A) Is Bad Both In The Eye Of Law & On Facts.

For Appellant: Shri Ankit Kumar, AdvocateFor Respondent: Shri Jitender Singh, CIT DR
Section 132Section 132(4)Section 153ASection 153BSection 153CSection 292C

further submitted that that neither the records of assessee are referred nor any enquiry conducted to verify that the information contained in seized material has bearing on total income of assessee has been referred. He submitted that the Assessing Officer has proceeded on a complete misconception of factual matrix ... submitted that assessee is regularly assessed to tax and thus it is incumbent to state as to in what manner information contained in the seized material found from third party premises has bearing on total income of assessee, in fact as to how and in what manner such seized material

Umaya Developers Private Limited, Mangalore vs. DCIT, Central Circle-1, Mangalore

In the result the orders of the Ld

ITA 1477/BANG/2025[2017-18]Status: DisposedITAT Bangalore29 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Sandeep Singh Karhail

For Appellant: Shri Narendra Sharma, Advocate
Section 131Section 132Section 143Section 153CSection 153DSection 270A

director of the company. He referred to paragraph No. 5 of the satisfaction note u/s. 153C of the act wherein description of the seized material was stated to be loose sheet comprising of documents seized at the business premises of M/s.Mukka SeaFood Industries Private Limited. Therefore, his submission is that ... case action Lt., 1st Floor, Trinity Complex, under section 153C is proposed N G Road, Attavar, Mangaluru PAN-AABCU1944P 5. Specific details of the seized material on the basis of which action under section 153C is proposed (a) Nature of the seized 1. Books of accounts/ material (money/bullion/ documents jewellery/other