seized material — 12,214 case laws

The DCIT-Circle-4(1)(1), Ahmedabad vs. Shree Siddhi Infrabuild Pvt. Ltd, Ahmedabad

Accordingly kept open.\n10. All Revenue appeals fail on merits and are dismissed

ITA 1637/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad05 Dec 2025AY 2014-15

Section 143(3)Section 147Section 148Section 68Section 69A

entries were verified by Shri Ashok S. Vaswani or by Shri Deepak\nB. Vaswani through their initials. The Assessing Officer therefore concluded\nthat the seized material reflected the unaccounted cash transactions of the\nVenus Group which were systematically recorded, authenticated, and\npreserved and could not be dismissed as random loose ... reply before the Assessing Officer, contended that the\nseized diary and vouchers belonged entirely to the Venus Group and that no\nentry in the seized material was in the handwriting of the assessee or signed\nby anyone connected with it. It was contended that the assessee has no\nobligation

The DCIT-Circle-4(1)(1), Ahmedabad vs. Shree Siddhi Infrabuild Pvt. Ltd, Ahmedabad

ITA 1636/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad05 Dec 2025AY 2012-13

Bench: Shri Sanjay Garg & Makarand V. Mahadeokar

For Appellant: Revenue by Shri R.P. Rastogi, CIT-DR

Section 143(3)Section 147Section 148Section 68Section 69A

entries were verified by Shri Ashok S. Vaswani or by Shri Deepak B. Vaswani through their initials. The Assessing Officer therefore concluded that the seized material reflected the unaccounted cash transactions of the Venus Group which were systematically recorded, authenticated, and preserved and could not be dismissed as random loose ... reply before the Assessing Officer, contended that the seized diary and vouchers belonged entirely to the Venus Group and that no entry in the seized material was in the handwriting of the assessee or signed by anyone connected with it. It was contended that the assessee has no obligation

The DCIT-Circle-4(1)(1), Ahmedabad vs. Shree Siddhi Infrabuild Pvt. Ltd, Ahmedabad

ITA 1635/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad05 Dec 2025AY 2011-12

Bench: Shri Sanjay Garg & Makarand V. Mahadeokar

For Appellant: Revenue by Shri R.P. Rastogi, CIT-DR

Section 143(3)Section 147Section 148Section 68Section 69A

entries were verified by Shri Ashok S. Vaswani or by Shri Deepak B. Vaswani through their initials. The Assessing Officer therefore concluded that the seized material reflected the unaccounted cash transactions of the Venus Group which were systematically recorded, authenticated, and preserved and could not be dismissed as random loose ... reply before the Assessing Officer, contended that the seized diary and vouchers belonged entirely to the Venus Group and that no entry in the seized material was in the handwriting of the assessee or signed by anyone connected with it. It was contended that the assessee has no obligation

Deputy Commissioner of Income Tax, Chennai vs. Singhvi Lickmi Chand, Vellore

In the result, all the appeals of the assessee as well as Revenue

ITA 971/CHNY/2025[2019-20]Status: DisposedITAT Chennai05 Dec 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.643, 644, 645, 646 & 647/Chny/2025 िनधा+रण वष+ /Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 Shri Singvi Lickmi Chand, The Dy. Commissioner Of No.3, Kasi Chetty Street, Vs. Income Tax, Ambur – 635 803. Central Circle-3(3), Pan: Aaapl 6736A Chennai.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT

Section 153ASection 69A

from whom loans were taken in his name/family members’ names/group concerns and were subsequently repaid by cheque/RTGS. The Ld. CIT(A), after examining the seized material, noted that the passbooks were seized from the assessee’s residence and the employees had stated that the accounts were opened by the assessee ... directed to verify the peak cash credit working submitted by the appellant in the appeal proceedings with the said bank statements available in the seized material, thereafter, work out the correct peak cash credit to be adopted for the respective year(s) and tax the peak credit of the respective

Deputy Commissioner of Income Tax, Chennai vs. Singhvi Lickmi Chand, Vellore

In the result, all the appeals of the assessee as well as Revenue

ITA 970/CHNY/2025[2018-19]Status: DisposedITAT Chennai05 Dec 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.643, 644, 645, 646 & 647/Chny/2025 िनधा+रण वष+ /Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 Shri Singvi Lickmi Chand, The Dy. Commissioner Of No.3, Kasi Chetty Street, Vs. Income Tax, Ambur – 635 803. Central Circle-3(3), Pan: Aaapl 6736A Chennai.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT

Section 153ASection 69A

from whom loans were taken in his name/family members’ names/group concerns and were subsequently repaid by cheque/RTGS. The Ld. CIT(A), after examining the seized material, noted that the passbooks were seized from the assessee’s residence and the employees had stated that the accounts were opened by the assessee ... directed to verify the peak cash credit working submitted by the appellant in the appeal proceedings with the said bank statements available in the seized material, thereafter, work out the correct peak cash credit to be adopted for the respective year(s) and tax the peak credit of the respective

Deputy Commissioner of Income Tax, Chennai vs. Singhvi Lickmi Chand, Vellore

In the result, all the appeals of the assessee as well as Revenue

ITA 969/CHNY/2025[2017-18]Status: DisposedITAT Chennai05 Dec 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.643, 644, 645, 646 & 647/Chny/2025 िनधा+रण वष+ /Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 Shri Singvi Lickmi Chand, The Dy. Commissioner Of No.3, Kasi Chetty Street, Vs. Income Tax, Ambur – 635 803. Central Circle-3(3), Pan: Aaapl 6736A Chennai.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT

Section 153ASection 69A

from whom loans were taken in his name/family members’ names/group concerns and were subsequently repaid by cheque/RTGS. The Ld. CIT(A), after examining the seized material, noted that the passbooks were seized from the assessee’s residence and the employees had stated that the accounts were opened by the assessee ... directed to verify the peak cash credit working submitted by the appellant in the appeal proceedings with the said bank statements available in the seized material, thereafter, work out the correct peak cash credit to be adopted for the respective year(s) and tax the peak credit of the respective

Deputy Commissioner of Income Tax, Chennai vs. Singhvi Lickmi Chand, Vellore

In the result, all the appeals of the assessee as well as Revenue

ITA 968/CHNY/2025[2016-17]Status: DisposedITAT Chennai05 Dec 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.643, 644, 645, 646 & 647/Chny/2025 िनधा+रण वष+ /Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 Shri Singvi Lickmi Chand, The Dy. Commissioner Of No.3, Kasi Chetty Street, Vs. Income Tax, Ambur – 635 803. Central Circle-3(3), Pan: Aaapl 6736A Chennai.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT

Section 153ASection 69A

from whom loans were taken in his name/family members’ names/group concerns and were subsequently repaid by cheque/RTGS. The Ld. CIT(A), after examining the seized material, noted that the passbooks were seized from the assessee’s residence and the employees had stated that the accounts were opened by the assessee ... directed to verify the peak cash credit working submitted by the appellant in the appeal proceedings with the said bank statements available in the seized material, thereafter, work out the correct peak cash credit to be adopted for the respective year(s) and tax the peak credit of the respective

Deputy Commissioner of Income Tax, Chennai vs. Shri Jaya Pradeep, Chennai

ITA 960/CHNY/2025[2020-21]Status: DisposedITAT Chennai05 Dec 2025AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:960/Chny/2025 निर्धारण वर्ष / Assessment Year: 2020-21 Deputy Commissioner Of Income Tax, Chennai. Vs. Shri. Jaya Pradeep, No.154, S 1 Salma Green Castle, Greenways Road, R.A. Puram, Chennai – 600 028. [Pan:Aixpj-6913-G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Ms. E. Pavuna Sundari, C.I.T. प्रत्यर्थी की ओर से/Respondent By : Shri. R. Venkata Raman, C.A. सुनवाई की तारीख/Date Of Hearing : 12.11.2025 घोषणा की तारीख/Date Of Pronouncement : 05.12.2025 आदेश /Order Per S. R. Raghunatha, Am : The Present Appeal Filed By The Revenue Is Directed Against The Order Dated 16.01.2025 Passed By The Learned Commissioner Of Income Tax (Appeals)-19, Chennai [Hereinafter Referred To As The “Ld.Cit(A)”], Arising From The Assessment Order Dated 28.03.2022 Framed U/S.143(3) R.W.S 153C Of The Income-Tax Act, 1961 (“The Act”) By The Deputy Commissioner Of Income Tax, Central Circle–2(4), Chennai [Hereinafter Referred To As “The Ao”], For The

For Appellant: Ms. E. Pavuna Sundari, C.I.TFor Respondent: Shri. R. Venkata Raman, C.A

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153C

books of account, loose sheets and documents. The statement of Shri Ganesan Saravanakumar, Director of the said company, was recorded with reference to the seized materials. 4. Among the documents seized were loose sheets, books and documents marked as ANN/KP/GS/LS/S and ANN/SJ/GS/B&D/S. The AO while framing the assessment, reproduced ... payments relating, inter alia, to on-money transactions pertaining to the land purchased by the assessee at Rackiyapalam Village. 10. Relying upon (i) the seized materials ANN/KP/GS/LS/S and ANN/SJ/GS/B&D/S-1 to S-4, and (ii) the statements of Shri Ganesan Saravanakumar recorded on 11.03.2021 and 12.03.2021 u/s.132

Singhvi Lickmi Chand, Ambur vs. DCIT Central Circle 3(3), Chennai

In the result, all the appeals of the assessee as well as Revenue

ITA 647/CHNY/2025[2019-20]Status: DisposedITAT Chennai05 Dec 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.643, 644, 645, 646 & 647/Chny/2025 िनधा+रण वष+ /Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 Shri Singvi Lickmi Chand, The Dy. Commissioner Of No.3, Kasi Chetty Street, Vs. Income Tax, Ambur – 635 803. Central Circle-3(3), Pan: Aaapl 6736A Chennai.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT

Section 153ASection 69A

from whom loans were taken in his name/family members’ names/group concerns and were subsequently repaid by cheque/RTGS. The Ld. CIT(A), after examining the seized material, noted that the passbooks were seized from the assessee’s residence and the employees had stated that the accounts were opened by the assessee ... directed to verify the peak cash credit working submitted by the appellant in the appeal proceedings with the said bank statements available in the seized material, thereafter, work out the correct peak cash credit to be adopted for the respective year(s) and tax the peak credit of the respective

Shri Singhvi Lickmi Chand, Ambur vs. DCIT, Central Circle-3(3), Chennai

In the result, all the appeals of the assessee as well as Revenue

ITA 646/CHNY/2025[2018-19]Status: DisposedITAT Chennai05 Dec 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.643, 644, 645, 646 & 647/Chny/2025 िनधा+रण वष+ /Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 Shri Singvi Lickmi Chand, The Dy. Commissioner Of No.3, Kasi Chetty Street, Vs. Income Tax, Ambur – 635 803. Central Circle-3(3), Pan: Aaapl 6736A Chennai.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT

Section 153ASection 69A

from whom loans were taken in his name/family members’ names/group concerns and were subsequently repaid by cheque/RTGS. The Ld. CIT(A), after examining the seized material, noted that the passbooks were seized from the assessee’s residence and the employees had stated that the accounts were opened by the assessee ... directed to verify the peak cash credit working submitted by the appellant in the appeal proceedings with the said bank statements available in the seized material, thereafter, work out the correct peak cash credit to be adopted for the respective year(s) and tax the peak credit of the respective

Shri Singhvi Lickmi Chand, Ambur vs. DCIT, Central Circle-3(3), Chennai

In the result, all the appeals of the assessee as well as Revenue

ITA 645/CHNY/2025[2017-18]Status: DisposedITAT Chennai05 Dec 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.643, 644, 645, 646 & 647/Chny/2025 िनधा+रण वष+ /Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 Shri Singvi Lickmi Chand, The Dy. Commissioner Of No.3, Kasi Chetty Street, Vs. Income Tax, Ambur – 635 803. Central Circle-3(3), Pan: Aaapl 6736A Chennai.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT

Section 153ASection 69A

from whom loans were taken in his name/family members’ names/group concerns and were subsequently repaid by cheque/RTGS. The Ld. CIT(A), after examining the seized material, noted that the passbooks were seized from the assessee’s residence and the employees had stated that the accounts were opened by the assessee ... directed to verify the peak cash credit working submitted by the appellant in the appeal proceedings with the said bank statements available in the seized material, thereafter, work out the correct peak cash credit to be adopted for the respective year(s) and tax the peak credit of the respective

Shri Singhvi Lickmi Chand, Ambur vs. DCIT, Central Circle.3(2), Chennai

In the result, all the appeals of the assessee as well as Revenue

ITA 644/CHNY/2025[2016-17]Status: DisposedITAT Chennai05 Dec 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.643, 644, 645, 646 & 647/Chny/2025 िनधा+रण वष+ /Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 Shri Singvi Lickmi Chand, The Dy. Commissioner Of No.3, Kasi Chetty Street, Vs. Income Tax, Ambur – 635 803. Central Circle-3(3), Pan: Aaapl 6736A Chennai.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT

Section 153ASection 69A

from whom loans were taken in his name/family members’ names/group concerns and were subsequently repaid by cheque/RTGS. The Ld. CIT(A), after examining the seized material, noted that the passbooks were seized from the assessee’s residence and the employees had stated that the accounts were opened by the assessee ... directed to verify the peak cash credit working submitted by the appellant in the appeal proceedings with the said bank statements available in the seized material, thereafter, work out the correct peak cash credit to be adopted for the respective year(s) and tax the peak credit of the respective

Shri Singhvi Lickmi Chand, Ambur vs. DCIT, Central Circle-3(3), Chennai

In the result, all the appeals of the assessee as well as Revenue

ITA 643/CHNY/2025[2015-16]Status: DisposedITAT Chennai05 Dec 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.643, 644, 645, 646 & 647/Chny/2025 िनधा+रण वष+ /Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 Shri Singvi Lickmi Chand, The Dy. Commissioner Of No.3, Kasi Chetty Street, Vs. Income Tax, Ambur – 635 803. Central Circle-3(3), Pan: Aaapl 6736A Chennai.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT

Section 153ASection 69A

from whom loans were taken in his name/family members’ names/group concerns and were subsequently repaid by cheque/RTGS. The Ld. CIT(A), after examining the seized material, noted that the passbooks were seized from the assessee’s residence and the employees had stated that the accounts were opened by the assessee ... directed to verify the peak cash credit working submitted by the appellant in the appeal proceedings with the said bank statements available in the seized material, thereafter, work out the correct peak cash credit to be adopted for the respective year(s) and tax the peak credit of the respective

M/S. Chatrachaya Property Holdings Pvt. Ltd., Hyderabad vs. ACIT, CC-1(2), Chennai

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

ITA 1795/CHNY/2025[2019-20]Status: DisposedITAT Chennai05 Dec 2025AY 2019-20

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1795/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 M/S. Chatrachaya Property Holdings Vs. The Assistant Commissioner Of Private Limited, Studio N - Sy No. 70, Income Tax/Dc, Narne Nagar, Beside Lanco Hills, Central Circle 1(2), Manikonda, Hyderabad 500 075. Chennai. [Pan:Aafcc4753J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. Vinita Shah, Ca (Virtual) ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 02.12.2025 घोषणा की तारीख /Date Of Pronouncement : 05.12.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.05.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Year 2019-20. 2. Besides Challenging The Issue On Merits In Restricting The Addition By The Ld. Cit(A), The Assessee Has Challenged In Invoking The Provisions Of Section 153A Of The Income Tax Act, 1961 [“Act” In Short]

For Appellant: Ms. Vinita Shah, CA (Virtual)For Respondent: Shri Shiva Srinivas, CIT

Section 131Section 132Section 132ASection 153ASection 68

only on the statement of search in the case of M/s. Golden Sheltors Pvt. Ltd., NKV Krishna and the alleged seized material. Therefore, it clearly shows that the impugned addition is only on the basis of the statement of the above said person and also seized material therein. In this ... addition under section 68 of the Act and made thereon under section 153A of the Act based on the statement of searched person and seized material, is not justified in the case of the assessee. 9. The above said conclusion is supported by the decision of the Hon’ble High

Vimalarjun Trust, Lucknow vs. ACIT, Central Circle-2, Delhi

In the result, the appeal of assessee is allowed

ITA 2094/DEL/2024[2017-18]Status: DisposedITAT Delhi05 Dec 2025AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year 2017-18 Vimalarjun Trust, Vs. Acit, 2/652, Vikram Khand, Gomti Circle-2, Nagar, Lucknow Delhi Uttar Pradesh Pin: 226010 Pan No. Aabtv7815R (Appellant) (Respondent)

For Appellant: Shri Ved Jain, Advs. & Shri PawanFor Respondent: Shri Sanjay Kaushal, CIT DR

Section 133ASection 139Section 142(1)Section 143(1)Section 143(2)Section 153Section 153CSection 250

invalidating the consequential proceedings. 5.8 It is a well-settled legal principle that the satisfaction note must clearly spell out the link between the seized material and the income of the person. A vague or mechanical reference to documents, without demonstrating how they bear upon the determination of total income

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 303/AGR/2025[2023-24]Status: DisposedITAT Agra04 Dec 2025AY 2023-24

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR

Section 143(3)Section 147Section 148Section 263Section 40ASection 68

erred in deleting the addition, without appreciating the facts that the Assessing Officer has passed the assessment order after thoroughly examining and analysing the seized material and proper appreciation of facts of bogus purchase of Raw Boneless Meat.” 28 ITA No.251/Agr/2025 and 4 ors. 16. At the time of hearing ... bogus purchases and round tripping of funds, he observed in his order that “the department has categorically inferred, on the basis of analysis of seized material, that the payments made against purchase of raw boneless meat have been routed through companies viz., SMAEPL and MFPCS and the assessee company

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 301/AGR/2025[2021-22]Status: DisposedITAT Agra04 Dec 2025AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR

Section 143(3)Section 147Section 148Section 263Section 40ASection 68

erred in deleting the addition, without appreciating the facts that the Assessing Officer has passed the assessment order after thoroughly examining and analysing the seized material and proper appreciation of facts of bogus purchase of Raw Boneless Meat.” 28 ITA No.251/Agr/2025 and 4 ors. 16. At the time of hearing ... bogus purchases and round tripping of funds, he observed in his order that “the department has categorically inferred, on the basis of analysis of seized material, that the payments made against purchase of raw boneless meat have been routed through companies viz., SMAEPL and MFPCS and the assessee company

ACIT, CC, Agra vs. M/S. United Farm Product Private Limited, Agra

In the result, appeal preferred by the revenue is dismissed

ITA 299/AGR/2025[2022-23]Status: DisposedITAT Agra04 Dec 2025AY 2022-23

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhacit, Cc, Vs. M/S. United Farm Product Pvt. Ltd., 2/220, 2Nd Floor, Glory Plaza, Agra. Soor Sadan, M.G. Road, Agra – 282 002 (Agra) (Pan :Aaccu2505M) (Appellant) (Respondent) Assessee By : Shri Sudhir Sehgal, Advocate Shri Deependra Mohan, Ca Revenue By : Shri Arun Kumar Yadav, Cit Dr Date Of Hearing : 13.10.2025 Date Of Order : 04.12.2025 O R D E R Per S. Rifaur Rahman,Am: 1. This Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income-Tax (Appeals), Kanpur – 4 Dated 28.03.2025 For Assessment Year2022-23 Raising Following Grounds Of Appeal :- “L. Whether On Facts & Circumstances Of The Case & In Law. The Ld. Cit(A)-Iv. Kanpur Has Erred In Deleting The Addition Of Rs.43,71,37,934/- On Account Of Unexplained Expenditure U/S 69C Of The Act Incurred For Construction Of Plant At Mewat, Haryana, Without Appreciating The Fact That The Assessee Company Itself Has Surrendered Amount Of Rs.41,40,35,700/- & Admitted To Take The Unexplained Expenditure At Rs.43,71,37,934/- Incurred In The 2 Construction Of Said Plant. Hence, The Addition Made By The Ao Is Based On Admittance By The Assessee, Which Is Corroborated By The Incriminating Material Found During The Course Of Search. 2. Whether On Facts & Circumstances Of The Case & In Law, Ld. Cit(A)-Iv. Kanpur Has Erred In Deleting The Addition. Without Appreciating The Facts That The Assessing Officer Has Passed The Assessment Order After Thoroughly Examining & Analysing The Seized Material & Proper Appreciation Of Facts Of Unexplained Expenditure U/S 69C Of The Act.”

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR

Section 69C

erred in deleting the addition. without appreciating the facts that the Assessing Officer has passed the assessment order after thoroughly examining and analysing the seized material and proper appreciation of facts of unexplained expenditure u/s 69C of the Act.” 2. This is an appeal filed by the revenue ... submitted that the CIT(A) has deleted the addition without appreciating the facts on record and overlooked the thorough examination and analysis of the seized material. Therefore, he prayed that the addition may be sustained based on the detailed findings of AO. 7. At the time of hearing

ACIT, CC, Agra vs. M/S Federal Agro Industries Pvt. Ltd., New Delhi

In the result, appeal filed by the revenue is dismissed

ITA 297/AGR/2025[2022-23]Status: DisposedITAT Agra04 Dec 2025AY 2022-23

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singh

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR

Section 133(6)Section 143(3)Section 147

erred in deleting the addition, without appreciating the facts that the Assessing Officer has passed the assessment order after thoroughly examining and analysing the seized material and proper appreciation of facts of bogus purchase of Raw Boneless Meat.” 11. At the time of hearing, ld. DR of the Revenue submitted

Hma Agro Industries Limited, Agra vs. Deputy Commissioner of Income-Tax, Central Circle, Agra

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 251/AGR/2025[2018-2019]Status: DisposedITAT Agra04 Dec 2025AY 2018-2019

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR

Section 143(3)Section 147Section 148Section 263Section 40ASection 68

erred in deleting the addition, without appreciating the facts that the Assessing Officer has passed the assessment order after thoroughly examining and analysing the seized material and proper appreciation of facts of bogus purchase of Raw Boneless Meat.” 28 ITA No.251/Agr/2025 and 4 ors. 16. At the time of hearing ... bogus purchases and round tripping of funds, he observed in his order that “the department has categorically inferred, on the basis of analysis of seized material, that the payments made against purchase of raw boneless meat have been routed through companies viz., SMAEPL and MFPCS and the assessee company

“seized material”

Leading authorities on seized material

Judgments citing seized material

The DCIT-Circle-4(1)(1), Ahmedabad vs. Shree Siddhi Infrabuild Pvt. Ltd, Ahmedabad

The DCIT-Circle-4(1)(1), Ahmedabad vs. Shree Siddhi Infrabuild Pvt. Ltd, Ahmedabad

The DCIT-Circle-4(1)(1), Ahmedabad vs. Shree Siddhi Infrabuild Pvt. Ltd, Ahmedabad

Deputy Commissioner of Income Tax, Chennai vs. Singhvi Lickmi Chand, Vellore

Deputy Commissioner of Income Tax, Chennai vs. Singhvi Lickmi Chand, Vellore

Deputy Commissioner of Income Tax, Chennai vs. Singhvi Lickmi Chand, Vellore

Deputy Commissioner of Income Tax, Chennai vs. Singhvi Lickmi Chand, Vellore

Deputy Commissioner of Income Tax, Chennai vs. Shri Jaya Pradeep, Chennai

Singhvi Lickmi Chand, Ambur vs. DCIT Central Circle 3(3), Chennai

Shri Singhvi Lickmi Chand, Ambur vs. DCIT, Central Circle-3(3), Chennai

Shri Singhvi Lickmi Chand, Ambur vs. DCIT, Central Circle-3(3), Chennai

Shri Singhvi Lickmi Chand, Ambur vs. DCIT, Central Circle.3(2), Chennai

Shri Singhvi Lickmi Chand, Ambur vs. DCIT, Central Circle-3(3), Chennai

M/S. Chatrachaya Property Holdings Pvt. Ltd., Hyderabad vs. ACIT, CC-1(2), Chennai

Vimalarjun Trust, Lucknow vs. ACIT, Central Circle-2, Delhi

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

ACIT, CC, Agra vs. M/S. United Farm Product Private Limited, Agra

ACIT, CC, Agra vs. M/S Federal Agro Industries Pvt. Ltd., New Delhi

Hma Agro Industries Limited, Agra vs. Deputy Commissioner of Income-Tax, Central Circle, Agra