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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

Raja Reddy Nalla, Warangal vs. DCIT., Central Circle-1(3), Hyderabad

In the result, the appeals filed by the assessee are dismissed for both the assessment years

ITA 550/HYD/2025[2014-15]Status: DisposedITAT Hyderabad24 Dec 2025AY 2014-15

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.549 & 550/Hyd/2025 (निर्धारण वर्ा/Assessment Years:2013-14 & 2014-15) Shri Raja Reddy Nalla, Dy. Commissioner Of Income Tax, Vs. Central Circle 1(3), Hyderabad. Warangal. Pan : Aaxpn3602Q (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Poorna Chander Rao, C.A. रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 22/12/2025 घोर्णध की तधरीख/Pronouncement: 24/12/2025

For Appellant: Shri Poorna Chander Rao, C.AFor Respondent: Dr. Sachin Kumar, SR-DR
Section 115BSection 132Section 153ASection 154Section 69

considering relevant submissions of the assessee and also taking note of the fact that the A.O. ;has made additions towards unexplained transactions recorded in seized material u/s. 69 of the Act, held that although the assessee claims that he had acted as a facilitator to help his friends and relatives ... considered u/s. 154 of the Act. The learned counsel for the assessee further submitted that, the assessee has explained the transactions recorded in seized material with reference to notice issued u/s. 142(1) of the Act and claimed that the additional income offered during the course of search for both

Raja Reddy Nalla, Warangal vs. DCIT., Central Circle-1(3), Hyderabad

In the result, the appeals filed by the assessee are dismissed for both the assessment years

ITA 549/HYD/2025[2013-14]Status: DisposedITAT Hyderabad24 Dec 2025AY 2013-14

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.549 & 550/Hyd/2025 (निर्धारण वर्ा/Assessment Years:2013-14 & 2014-15) Shri Raja Reddy Nalla, Dy. Commissioner Of Income Tax, Vs. Central Circle 1(3), Hyderabad. Warangal. Pan : Aaxpn3602Q (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Poorna Chander Rao, C.A. रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 22/12/2025 घोर्णध की तधरीख/Pronouncement: 24/12/2025

For Appellant: Shri Poorna Chander Rao, C.AFor Respondent: Dr. Sachin Kumar, SR-DR
Section 115BSection 132Section 153ASection 154Section 69

considering relevant submissions of the assessee and also taking note of the fact that the A.O. ;has made additions towards unexplained transactions recorded in seized material u/s. 69 of the Act, held that although the assessee claims that he had acted as a facilitator to help his friends and relatives ... considered u/s. 154 of the Act. The learned counsel for the assessee further submitted that, the assessee has explained the transactions recorded in seized material with reference to notice issued u/s. 142(1) of the Act and claimed that the additional income offered during the course of search for both

DCIT., Central Circle-1(3), Hyderabad vs. Light House Movie Makers LLP, Hyderabad

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

ITA 318/HYD/2024[2019-20]Status: DisposedITAT Hyderabad24 Dec 2025AY 2019-20

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.297/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2015-16) Dy. Commissioner Of Income Shri Atchi Reddy Kovvuri, Vs. Hyderabad Tax, Pan : Adopk6018R Central Circle 1(3), Hyderabad. (Appellant) (Respondent) आ.अपी.सं /Ita Nos.318 & 319/Hyd/2024 (निर्धारण वर्ा/Assessment Years:2019-20 & 2020-21) Dy. Commissioner Of Income M/S. Light House Movie Makers Vs. Llp, Hyderabad. Tax, Pan : Aagfl8979H Central Circle 1(3), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessees By: Shri A. Srinivas, C.A. रधजस् व द्वधरध/Revenue By: Smt. U Mini Chandran, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 18/11/2025 घोर्णध की तधरीख/Pronouncement: 24/12/2025 आदेश/Order Per Manjunatha G, A.M. : These Appeals Are Filed By Revenue Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, All Dated 19.11.2024 For The

For Respondent: Smt. U Mini Chandran, CIT-DR
Section 132Section 139Section 142(1)Section 153C

taxmann.com 290 (SC) quashed the assessment order passed by the Assessing Officer, holding that although the Assessing Officer referred to certain seized material found during the course of search vide Annexure UPF/RP/EL-15 (pages 1 to 301), UPF/RP/EL-25 ( pages 1 to 3) and UPF/RP/EL-31 (pages 84 to 91), but there ... consequent assessment order passed by the Assessing Officer, though the Assessing Officer has recorded satisfaction u/s.153C of the Act on the basis of seized material found during ITA Nos.297, 318 & 319/Hyd/2024 16 the course of search and satisfied that the material found during the course of search has bearing

DCIT., Central Circle-1(3), Hyderabad vs. Atchi Reddy Kovuuri, Hhyderabad

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

ITA 297/HYD/2024[2015-16]Status: DisposedITAT Hyderabad24 Dec 2025AY 2015-16

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.297/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2015-16) Dy. Commissioner Of Income Shri Atchi Reddy Kovvuri, Vs. Hyderabad Tax, Pan : Adopk6018R Central Circle 1(3), Hyderabad. (Appellant) (Respondent) आ.अपी.सं /Ita Nos.318 & 319/Hyd/2024 (निर्धारण वर्ा/Assessment Years:2019-20 & 2020-21) Dy. Commissioner Of Income M/S. Light House Movie Makers Vs. Llp, Hyderabad. Tax, Pan : Aagfl8979H Central Circle 1(3), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessees By: Shri A. Srinivas, C.A. रधजस् व द्वधरध/Revenue By: Smt. U Mini Chandran, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 18/11/2025 घोर्णध की तधरीख/Pronouncement: 24/12/2025 आदेश/Order Per Manjunatha G, A.M. : These Appeals Are Filed By Revenue Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, All Dated 19.11.2024 For The

For Respondent: Smt. U Mini Chandran, CIT-DR
Section 132Section 139Section 142(1)Section 153C

taxmann.com 290 (SC) quashed the assessment order passed by the Assessing Officer, holding that although the Assessing Officer referred to certain seized material found during the course of search vide Annexure UPF/RP/EL-15 (pages 1 to 301), UPF/RP/EL-25 ( pages 1 to 3) and UPF/RP/EL-31 (pages 84 to 91), but there ... consequent assessment order passed by the Assessing Officer, though the Assessing Officer has recorded satisfaction u/s.153C of the Act on the basis of seized material found during ITA Nos.297, 318 & 319/Hyd/2024 16 the course of search and satisfied that the material found during the course of search has bearing