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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

Deputy Commissioner of Income Tax, Central Circle vs. Maruti Enterprise, Rajkot

ITA 228/RJT/2023[2019-20]Status: DisposedITAT Rajkot22 Dec 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhasr. It(Ss)A No Assessment Assessee Name Respondent Name No. Year 1. 12/Rjt/2024 2014-15 Deputy Commissioner Shri Chetan Dhirajlal Rokad Of Income-Tax, Central 1, Pearl Plaza, 150 Ft Ring Circle-1, Rajkot, Road, Near G.T. School “Amruta Estate” 2Nd Rajkot-360 001 Floor, M.G. Road, Rajkot-360 001 Pan.:Afkpr4637P 2. 13/Rjt/2024 2014-15 Deputy Commissioner Shri Nikhilbhai Jamnadas Of Income-Tax, Central Patel Circle-1, Rajkot, P-1, Decora Highland, “Amruta Estate” 2Nd Avadh Main Road, Opp. Floor, M.G. Road, Classic Party Plot Rajkot- Rajkot-360 001 360 005 Pan No.: Agipp 1294 K 3. 17/Rjt/2024 2013-14 Deputy Commissioner Shri Dhirajlal Ravji Rokad Of Income-Tax, Central 1, Pearl Plaza, 150 Ft Ring Circle-1, Rajkot, Road, Near G.T. School “Amruta Estate” 2Nd Rajkot-360 001 Floor, M.G. Road, Rajkot-360 001 Panno.:Abopr5408A 19 & 2017-18 & Deputy Commissioner Shri Rohitkumar Maganlal 4. 20/Rjt/2024 2018-19 Of Income-Tax, Central Sanepara Circle-1, Rajkot, Kangshiyani Road, Opp. “Amruta Estate” 2Nd Sundaram Vidhyalaya, Floor, M.G. Road, Dholra Chokdi, Kothariya, Rajkot-360 001 Rajkot-360 004 Panno.:Aaopp4848H 5. 59-60/Rjt/2023 2017-18 & Deputy Commissioner M/S Maruti Enterprise 2018-19 Of Income-Tax, Central Decora West Hills, Near Classic Party Plot, Opp. Circle-1, Rajkot, Kalawa Road, Rajkot-360 “Amruta Estate” 2Nd 005 Floor, M.G. Road, Rajkot-360 001 Panno.:Abdfm3140K 6. 228/Rjt/2023 2019-20 Deputy Commissioner M/S Maruti Enterprise Of Income-Tax, Central

Section 250

Rs.5,75,00,000/- + Rs. 4,68,00,000/-). This matches with the actual registered document. From the said seized material, it is clear that the contents of page No. 2, shows Rs. 60,02,08,110/-. Out of this, cash component is Rs. 38,01,00,000/- and cheque ... shown at Rs.10,43,00,000/- This corroborates with the actual documents already executed. Hence, it is clear that the contents of the seized materials are totally true and correct. The bifurcation of the cash components matches with the actual partnership stakes held by the partners. The seized document clearly

Biren Manna, Mumbai vs. ITO -Ward-23(1)(6), Mumbai

In the result, the appeal of the assessee is allowed

ITA 6373/MUM/2025[2022-23]Status: DisposedITAT Mumbai22 Dec 2025AY 2022-23

Bench: Shri Om Prakash Kant ()\Nand\Nshri Rahul Chaudhary ()\N\Nita No. 6373/Mum/2025\N Assessment Year: 2022-23\N\Nshri Biren Manna,\N5/7, Vithoba Lane, 4Th Floor,\Nroom No. 40, Vithalwadi,\Nkalbadevi,\Nmumbai-400 002.\Npan No. Aadpm 0809 N\Nappellant\Nassessee By\Nrevenue By\Nvs.\Nito Ward 23 Ward 23(1)(6),\Npirmal Chamber,\Nmumbai-400012.\Nrespondent\Nmr. Paras B. Jain\Nmr. Leyaqat Ali Aafaqui, Sr. Dr\Ndate Of Hearing\Ndate Of Pronouncement\N:\N:\N01/12/2025\N22/12/2025\N\Norder\Nper Om Prakash Kant, Am\N\Nthis Appeal By The Assessee Is Directed Against Order Dated\N03.09.2025 Passed By The Ld. Commissioner Of Income-Tax\N(Appeals) – National Faceless Appeal Centre, Delhi [In Short ‘The Ld.\Ncit(A)'] For Assessment Year 2022-23, Raising Following Grounds:\N\N1. Void Order\N1.

Section 115BSection 132Section 143(3)Section 69Section 69B

controlling the affairs of the said group were\nalso recorded, wherein receipt of cash components was admitted as\na general practice.\n4.1 From the seized material, the Assessing Officer noted that the\nassessee had purchased Flat No. 4304 in the project Ruparel Jewel\nand, according to the notings found during ... show cause notice\ncalling upon the assessee to explain the source of the alleged cash\npayment of ₹81,00,000/- reflected in the seized material found at\nthe premises of the Ruparel Realty Group. In response, the assessee\ncategorically denied having made any cash payment to the\ndeveloper