← All Phrases

“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

Pravin Khetaram Purohit, Mumbai vs. DCIT, Central Circle (4)2, Mumbai

In the result, all the appeals filed by the assessee

ITA 4744/MUM/2025[2020-21]Status: DisposedITAT Mumbai15 Oct 2025AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain & Hon'Ble Shri Girish Agrawal

Section 143(3)Section 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

Pravin Khetaram Purohit, Mumbai vs. DCIT Central Circle 4(2), Mumbai

In the result, all the appeals filed by the assessee stands allowed

ITA 4743/MUM/2025[2018-19]Status: DisposedITAT Mumbai15 Oct 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Girish Agrawal

Section 143(3)Section 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

Pravin Khetaram Purohit, Mumbai vs. DCIT, Central Circle 4(2), Mubmai

In the result, all the appeals filed by the assessee

ITA 4742/MUM/2025[2017-18]Status: DisposedITAT Mumbai15 Oct 2025AY 2017-18

Bench: Hon'Ble Shri Sandeep Gosain & Hon'Ble Shri Girish Agrawal

Section 143(3)Section 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

Glacier Tradex Pvt Ltd, Delhi vs. ACIT, CC-29, Delhi

ITA 487/DEL/2025[2018-19]Status: DisposedITAT Delhi15 Oct 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 153CSection 153C(1)(a)

factual position, learned CIT(DR) could hardly dispute that the above extracted section 153C satisfaction has nowhere made it clear as to which specific seized material found during the course of search either belonged or pertained or related to the assessee thereby having a bearing on its income

Glacier Tradex (P) Ltd, New Delhi vs. ACIT.Central Circle-29, Delhi

ITA 486/DEL/2025[2017-18]Status: DisposedITAT Delhi15 Oct 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 153CSection 153C(1)(a)

factual position, learned CIT(DR) could hardly dispute that the above extracted section 153C satisfaction has nowhere made it clear as to which specific seized material found during the course of search either belonged or pertained or related to the assessee thereby having a bearing on its income

Raghav Kumar, New Delhi vs. ACIT Central Circle-29, New Delhi

In the result, the appeal filed by the assessee being ITA

ITA 3215/DEL/2025[2021-22]Status: DisposedITAT Delhi15 Oct 2025AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

For Appellant: Shri R.S. Singhvi, AdvocateFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 132Section 153CSection 69Section 69A

assessment order. d. Copy of panchnama and search warrant in the case of Praveen Kumar Jain and Vaibhav Jain. e. Certified copy of seized material based on which satisfaction u/s 153C was recorded including: i. Clear copy of envelops extracted at Page 3 of the assessment order ii. Complete whatsapp ... Shri Gopal Krishnanatsa Katigar (ITA No. 1143/Bang/24) (02/06/25) (ITAT Bangalore) 31.3 The AO placed significant reliance on the initials “GK” found in the seized material to conclude that the assessee was involved in cash transactions with the Mishra Group. However, no substantive evidence was presented to establish that these entries

Raghav Kumar, Delhi vs. ACIT Central Circle 29, New Delhi

In the result, the appeal filed by the assessee being ITA

ITA 3214/DEL/2025[2020-21]Status: DisposedITAT Delhi15 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

For Appellant: Shri R.S. Singhvi, AdvocateFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 132Section 153CSection 69Section 69A

assessment order. d. Copy of panchnama and search warrant in the case of Praveen Kumar Jain and Vaibhav Jain. e. Certified copy of seized material based on which satisfaction u/s 153C was recorded including: i. Clear copy of envelops extracted at Page 3 of the assessment order ii. Complete whatsapp ... Shri Gopal Krishnanatsa Katigar (ITA No. 1143/Bang/24) (02/06/25) (ITAT Bangalore) 31.3 The AO placed significant reliance on the initials “GK” found in the seized material to conclude that the assessee was involved in cash transactions with the Mishra Group. However, no substantive evidence was presented to establish that these entries

Kanchanjunga Power Company Private Limited, Delhi vs. Deputy Commissioner of Income Tax, New Delhi

Appeal is allowed

ITA 2662/DEL/2025[2019-20]Status: DisposedITAT Delhi15 Oct 2025AY 2019-20

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Sh. Upvan Gupta, Adv. (Virtual)For Respondent: Adjournment Application by CIT DR
Section 153CSection 153C(1)Section 37

date of satisfaction u/s 153C(1) 1st proviso wherein any additions has to be made in the assessee’s hands based on the specific seized material only as per PCIT Vs. Abhisar Builwell P. Ltd. (2023) 454 ITR 212 (SC). 4. Learned CIT-DR at this stage seeks to postpone ... instant assessee’s appeal. We are of the considered view that given the fact that there is no addition made on the basis of seized material, we reject the Revenue’s adjournment to accept the assessee’s instant appeal in very terms. Ordered accordingly. 6. This assessee’s appeal

Hiteshi Leasing and Housing Pvt Ltd, New Delho vs. DCIT, Circle-1, Faridabad

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

ITA 4620/DEL/2024[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarhiteshi Leasing & Housing Pvt. Ltd., Vs. Dcit, Circle 1, Yogi Associates, Faridabad. E – 335, East Of Kailash, New Delhi – 110 005. (Pan : Aaach8298J) (Appellant) (Respondent) Assessee By : Shri Pushpdeep Singh, Advocate Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 28.08.2025 Date Of Order : 15.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income-Tax (Appeals), Gurgaon-3 [For Short ‘Ld. Cit (A)] Dated 04.081.2024 For Assessment Year 2011-12 Raising Following Grounds Of Appeal :- “(A) That On The Facts & Circumstances Of The Case The Learned Assessing Officer & Cit(A), While Passing The Order Erred In: A. Passing The Assessment Order Dated 26.03.2015 U/S 153A Despite The Fact The Assessee Was Not Searched & The Assessee Was Issued Notice Under Section 153C On 29.1 1.2013. This Is A Jurisdictional Error

For Appellant: Shri Pushpdeep Singh, AdvocateFor Respondent: Shri Kailash Dan Ratnoo, CIT DR
Section 131Section 153ASection 153CSection 68

time limit for issuing a notice under section 143(2) expired on 30.09.2012 whereas the satisfaction note is dated 29.11.2013 and the seized material was received by the A.O. of the Assessee on 23.07.20l3 and referred Para 1 & 2 of the Assessment Order. He submitted that the search action ... ratio of Hon’ble jurisdictional High Court, in the case of Dayawanti v. CIT (2017)390 ITR 496, to argue that once the seized material gives rise to ‘belief’ in the mind of the assessing officer, then that is sufficient to consider the ‘seized material’ to be ‘incriminating material

Deputy Commissioner of Income-Tax, Central Circle-3, Jaipur vs. Sapna Karnani, Tonk Phatak

In the result, the appeals of the revenue in ITA No

ITA 712/JPR/2025[2017-18]Status: DisposedITAT Jaipur14 Oct 2025AY 2017-18
For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR
Section 127Section 139(1)Section 153ASection 153CSection 68Section 69C

153C. The two pre-requisites are that the AO dealing with the assessee on whom search was conducted or requisition made, being satisfied that seized material belongs or relates to other assessee shall hand over it to AO having jurisdiction of such assessee Thereafter, the satisfaction of AO receiving ... seized material that the material handed over has a bearing for determination of total income of such other person for the relevant preceding years. On fulfillment of twin conditions the AO shall proceed in accordance with the provisions of Section 153A 26. Special procedure is prescribed under Section 153A

Deputy Commissioner of Income-Tax, Central Circle-3, Jaipur vs. Sapna Karnani, Tonk Phatak

ITA 711/JPR/2025[2016-17]Status: DisposedITAT Jaipur14 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR
Section 127Section 139(1)Section 153ASection 153CSection 68Section 69C

153C. The two pre-requisites are that the AO dealing with the assessee on whom search was conducted or requisition made, being satisfied that seized material belongs or relates to other assessee shall hand over it to AO having jurisdiction of such assessee Thereafter, the satisfaction of AO receiving ... seized material that the material handed over has a bearing for determination of total income of such other person for the relevant preceding years. On fulfillment of twin conditions the AO shall proceed in accordance with the provisions of Section 153A 26. Special procedure is prescribed under Section 153A

Deputy Commissioner of Income-Tax, Central Circle-3, Jaipur vs. Sapna Karnani, Tonk Phatak

In the result, the appeals of the revenue in ITA No

ITA 710/JPR/2025[2014-15]Status: DisposedITAT Jaipur14 Oct 2025AY 2014-15
For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR
Section 127Section 139(1)Section 153ASection 153CSection 68Section 69C

153C. The two pre-requisites are that the AO dealing with the assessee on whom search was conducted or requisition made, being satisfied that seized material belongs or relates to other assessee shall hand over it to AO having jurisdiction of such assessee Thereafter, the satisfaction of AO receiving ... seized material that the material handed over has a bearing for determination of total income of such other person for the relevant preceding years. On fulfillment of twin conditions the AO shall proceed in accordance with the provisions of Section 153A 26. Special procedure is prescribed under Section 153A

Deputy Commissioner of Income-Tax, Central Circle-3, Jaipur vs. Sapna Karnani, Tonk Phatak

In the result, the appeals of the revenue in ITA No

ITA 709/JPR/2025[2013-14]Status: DisposedITAT Jaipur14 Oct 2025AY 2013-14
For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR
Section 127Section 139(1)Section 153ASection 153CSection 68Section 69C

153C. The two pre-requisites are that the AO dealing with the assessee on whom search was conducted or requisition made, being satisfied that seized material belongs or relates to other assessee shall hand over it to AO having jurisdiction of such assessee Thereafter, the satisfaction of AO receiving ... seized material that the material handed over has a bearing for determination of total income of such other person for the relevant preceding years. On fulfillment of twin conditions the AO shall proceed in accordance with the provisions of Section 153A 26. Special procedure is prescribed under Section 153A

Sunil Kumar Agarwal, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle-2, Jaipur

ITA 521/JPR/2025[2020-21]Status: DisposedITAT Jaipur14 Oct 2025AY 2020-21

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, \nvk;dj vihy la-@ITA Nos.513 & 519 to 521/JP/2025\nfu/k Zkj.k o\"kZ@Assessment Years : 2016-17 & 2018-19 to 2020-21\n\nSunil Kumar Agarwal\n395, Narnoli Mansion, Outside\nSanganeri Gate, Jaipur\ncuke\nVs.\nACIT,\nCentral Circle-2,\nJaipur\nLFkk;h y s[kk l a-@thvkb Zvkj la-@PAN/GIR No.: ABRPA9601M\nvihykFkhZ@Appellant i zR;Fkh Z@Respondent\n\nvk;dj vihy la-@ITSS No. 03/JP/2025\nfu/k Zkj.k o\"kZ@Assessment Year : 2015-16\

For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Anita Rinesh, JCIT, Sr-DR
Section 132Section 139Section 153ASection 234B

profit was added on the following page which were seized and the same is tabulated herein below ; Sr.No. Reference to the seized material Amount of sales Rs. 10% of profit in Rs. 1. Page no. 17 of Exhibit 15 of the party1 [ discussed as above ... 521/JP/2025 Sunil Kumar Agarwal As regards the addition of based on the third party search Shri Nikhil Kumar Goyal he submitted that on this seized material the assessee was not confronted and no statement was recorded. These pages do not contain the name, address, phone number even the names

Sunil Kumar Agarwal, Jaipur vs. ACIT, Cen. Cir-2, Jaipur

In the result the appeal of the assessee in ITA no

ITA 513/JPR/2025[2016-17]Status: DisposedITAT Jaipur14 Oct 2025AY 2016-17
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Anita Rinesh, JCIT, Sr-DR
Section 132Section 139Section 153ASection 234B

profit was added on the following page which were seized and the same is tabulated herein below ; Sr.No. Reference to the seized material Amount of sales Rs. 10% of profit in Rs. 1. Page no. 17 of Exhibit 15 of the 20,35,000 2,03,500 party1 [ discussed ... addition made by the learned AO is not solely on the basis of statement. The addition has been made on the basis of seized material pertaining to the appellant as have been found from the premises of Sh. Nikhil Kumar Goyal. Further the documents cannot be disregarded merely

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. M/S Home Construction Co., Ludhiana

In the result, the appeal of the Revenue is dismissed

ITA 351/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh14 Oct 2025AY 2020-21
For Appellant: Shri Sudhir Sehgal, AdocateFor Respondent: Smt. Tarundeep Kaur, CIT, DR
Section 147Section 65B

incriminating material being seized from Shri Ravi Kapoor, who was allegedly a key person of the group. (ii) That in such cases, extrapolation from seized material was permissible to determine suppressed sales. 5. During the course of hearing the Ld. DR for the Revenue supported the assessment order. He contended

DCIT, CC-2, Chandigarh vs. M/S Mubarikpur Royalty Company, Mohali

ITA 15/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh14 Oct 2025AY 2018-19

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No. 729/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2017-18) & 2. आयकर अपील सं. / Ita No. 15/Chandi/2023 (िनधा"रण वष" / Assessment Year: 2018-19) Acit-Central Circle 2 M/S Mubarikpur Royalty Company बनाम/ Vs. Cr Building, Sector 17 1, Mubarikpur To Ramgarh Road Chandigarh – 160017 Vpo Mubarikpur, Mohali (Punjab) "ायीलेखासं./जीआइआरसं./Pan/Gir No. Abafm-6580-C (अपीलाथ"/Appellant) : (""थ" / Respondent) & 3. Co. No.39/Chandi/2024 (In Ita No. No. 729/Chandi/2022) (िनधा"रण वष" / Assessment Year: 2017-18) & 4. Co. No.40/Chandi/2024 (In Ita No. No. 15/Chandi/2023) (िनधा"रण वष" / Assessment Year: 2018-19) M/S Mubarikpur Royalty Company Acit-Central Circle 2 बनाम/ Sco 506, Chirag Homes-2 Cr Building, Sector 17 Near Arista Place, Sector 123 Chandigarh – 160017 Vs. Sunny Enclave, Mohali (Punjab)-140301 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Abafm-6580-C (Cross Objector) (Respondent) : Revenue By : Smt. Kusum Bansal (Cit) – Ld. Dr Assessee By : Sh. Harry Rikhy (Advocate)-Ld. Ar

For Appellant: Sh. Harry Rikhy (Advocate)-Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR
Section 132Section 153A

rejecting comparable entities of the assessee as well as selected by Ld. AO since the additions are to be based on seized material as found during the search and the same could not be estimated by taking mean profit rate of other entities as disclosed by them in their audited ... seized document. 6. It has been stated by Ld. AR that to estimate the NP rates, Ld. CIT(A) has made computations from combined seized material which include Profit & Loss Account as found in the pen-drive in the name of M/s GM & Co. and mining details as noted

ACIT, CC-2, Chandigarh vs. M/S Mubarikpur Royalty Company, Mohali

ITA 729/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh14 Oct 2025AY 2017-18

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No. 729/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2017-18) & 2. आयकर अपील सं. / Ita No. 15/Chandi/2023 (िनधा"रण वष" / Assessment Year: 2018-19) Acit-Central Circle 2 M/S Mubarikpur Royalty Company बनाम/ Vs. Cr Building, Sector 17 1, Mubarikpur To Ramgarh Road Chandigarh – 160017 Vpo Mubarikpur, Mohali (Punjab) "ायीलेखासं./जीआइआरसं./Pan/Gir No. Abafm-6580-C (अपीलाथ"/Appellant) : (""थ" / Respondent) & 3. Co. No.39/Chandi/2024 (In Ita No. No. 729/Chandi/2022) (िनधा"रण वष" / Assessment Year: 2017-18) & 4. Co. No.40/Chandi/2024 (In Ita No. No. 15/Chandi/2023) (िनधा"रण वष" / Assessment Year: 2018-19) M/S Mubarikpur Royalty Company Acit-Central Circle 2 बनाम/ Sco 506, Chirag Homes-2 Cr Building, Sector 17 Near Arista Place, Sector 123 Chandigarh – 160017 Vs. Sunny Enclave, Mohali (Punjab)-140301 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Abafm-6580-C (Cross Objector) (Respondent) : Revenue By : Smt. Kusum Bansal (Cit) – Ld. Dr Assessee By : Sh. Harry Rikhy (Advocate)-Ld. Ar

For Appellant: Sh. Harry Rikhy (Advocate)-Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR
Section 132Section 153A

rejecting comparable entities of the assessee as well as selected by Ld. AO since the additions are to be based on seized material as found during the search and the same could not be estimated by taking mean profit rate of other entities as disclosed by them in their audited ... seized document. 6. It has been stated by Ld. AR that to estimate the NP rates, Ld. CIT(A) has made computations from combined seized material which include Profit & Loss Account as found in the pen-drive in the name of M/s GM & Co. and mining details as noted

Ashish Kalra, New Delhi vs. ACIT, Central Circle-4, New Delhi

In the result, the appeal of the assessee for Assessment Year 2008-09 in ITA

ITA 4309/DEL/2019[2009-10]Status: DisposedITAT Delhi14 Oct 2025AY 2009-10

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.4309/Del/2019 (Assessment Year 2009-10) Mr. Ashish Kalra Acit, C-3/313, Mig Flats, Janakpuri, Central Circle-4, New Delhi-110058. Vs. New Delhi. Pan-Aippk0526N (Appellant) (Respondent) Assessee By Shri Tarandeep Singh, Adv. Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 16/07/2025 Date Of Pronouncement 14/10/2025 O R D E R Per Manish Agarwal, Am: These Two Appeals Are Filed By The Assessee Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [Cit(A), In Short] Dated 28.01.2019 In Appeal No. 159/2016-17 & 3/2017-18 For Asst. Years 2008-09 & 2009-10 Respectively, Both Arising Out Of Order Passed U/S 147 R.W.S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’). 2. Since, Both The Appeals Are Having Identical Issues, Therefore, They Are Adjudicated By A Common Order. First We Take Up The Appeal For Assessment Year 2008-09 In Ita No.4308/Del/2019. Ashish Kalra Vs. Acit

Section 139(1)Section 147Section 148Section 153CSection 251

notice u/s 148 of the Act. Before us, the Ld. AR of the assessee submits that the sole basis initiation of proceedings is the seized material titled as Annexure-A-29 and A-30 wherein huge payments in cash was recorded. The AR submits that neither ... reasons recorded by AO u/s 148(2) of the Act is at pages 2 and 3 of AO order. Reasons recorded rely upon "seized material contained in Annexure A-29 and A- 30", Premised this piece of evidence it is alleged in the reasons that "huge payments have been made

Ashish Kalra, New Delhi vs. ACIT, Central Circle-4, New Delhi

In the result, the appeal of the assessee for Assessment Year 2008-09 in ITA

ITA 4308/DEL/2019[2008-09]Status: DisposedITAT Delhi14 Oct 2025AY 2008-09

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.4309/Del/2019 (Assessment Year 2009-10) Mr. Ashish Kalra Acit, C-3/313, Mig Flats, Janakpuri, Central Circle-4, New Delhi-110058. Vs. New Delhi. Pan-Aippk0526N (Appellant) (Respondent) Assessee By Shri Tarandeep Singh, Adv. Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 16/07/2025 Date Of Pronouncement 14/10/2025 O R D E R Per Manish Agarwal, Am: These Two Appeals Are Filed By The Assessee Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [Cit(A), In Short] Dated 28.01.2019 In Appeal No. 159/2016-17 & 3/2017-18 For Asst. Years 2008-09 & 2009-10 Respectively, Both Arising Out Of Order Passed U/S 147 R.W.S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’). 2. Since, Both The Appeals Are Having Identical Issues, Therefore, They Are Adjudicated By A Common Order. First We Take Up The Appeal For Assessment Year 2008-09 In Ita No.4308/Del/2019. Ashish Kalra Vs. Acit

Section 139(1)Section 147Section 148Section 153CSection 251

notice u/s 148 of the Act. Before us, the Ld. AR of the assessee submits that the sole basis initiation of proceedings is the seized material titled as Annexure-A-29 and A-30 wherein huge payments in cash was recorded. The AR submits that neither ... reasons recorded by AO u/s 148(2) of the Act is at pages 2 and 3 of AO order. Reasons recorded rely upon "seized material contained in Annexure A-29 and A- 30", Premised this piece of evidence it is alleged in the reasons that "huge payments have been made