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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, Chennai vs. Mohanlal Jewellers Private Limited, Chennai

ITA 1393/CHNY/2025[2017-18]Status: DisposedITAT Chennai26 Sept 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1178 To 1182/Chny/2025 िनधारण वष/Assessment Years: 2017-18 To 2021-22 M/S. Mohanlal Jewellers Pvt. Ltd, Old No.68-69, Nsc Bose Road, Sowcarpet, Chennai-600 001. V. The Dcit, Central Circle-3(3), Chennai. [Pan: Aafcm 9906 M] (अपीलाथ/Appellant) (यथ/Respondent) आयकर अपील सं./Ita Nos.1393 To 1397/Chny/2025 िनधारण वष/Assessment Years: 2017-18 To 2021-22 The Dcit, Central Circle-3(3), Chennai. V. M/S. Mohanlal – Jewellers Pvt. Ltd., Old No.68-69, Nsc Bose Road, Sowcarpet, Chennai-600 001. [Pan: Aafcm 9906 M] (अपीलाथ/Appellant) (यथ/Respondent) Assessee By : Mr. D. Anand, Advocate Department By : Ms. E. Pavuna Sundari, Cit सुनवाई क तारीख/Date Of Hearing : 05.08.2025 घोषणा क तारीख /Date Of Pronouncement : 26.09.2025

For Appellant: Mr. D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 132Section 143(3)Section 153A

decipher as to how these entries were made in the ‘Ghat’ Ledger. The Ld. CIT(A) is noted to have called for the relevant seized material for verification and after undertaking an elaborate analysis, he concluded that, the entries in this ‘Ghat’ ledger did not comprise of any ‘metal’ addition ... 1182/Chny/2025 & ITA Nos.1393 to 1397/Chny/2025 & (AYs: 2017-18 to 2021-22) M/s. Mohanlal Jewellers Pvt. Ltd ::34 :: powers, he had called for the entire seized material and thereafter himself verified the ‘ghat’ entries randomly on test-check basis, particularly where the gold was being re-made into new gold ornaments

Mohanlal Jewellers Pvt. Ltd., Chennai vs. DCIT, Central Circle-3(3), Chennai

ITA 1180/CHNY/2025[2019-20]Status: DisposedITAT Chennai26 Sept 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकरअपीलसं./Ita Nos.1178 To 1182/Chny/2025 िनधारणवष/Assessment Years: 2017-18 To 2021-22 M/S. Mohanlal Jewellers Pvt. Ltd., Old No.68-69, Nsc Bose Road, Sowcarpet, Chennai-600 001. V. The Dcit, Central Circle-3(3), Chennai. [Pan: Aafcm 9906 M] (अपीलाथ/Appellant) (यथ/Respondent) आयकरअपीलसं./Ita Nos.1393 To 1397/Chny/2025 िनधारणवष/Assessment Years: 2017-18 To 2021-22 The Dcit, Central Circle-3(3), Chennai. V. M/S. Mohanlal Jewellers Pvt. Ltd., Old No.68-69, Nsc Bose Road, Sowcarpet, Chennai-600 001. [Pan: Aafcm 9906 M] (अपीलाथ/Appellant) (यथ/Respondent) Assessee By : Mr. D. Anand, Advocate Department By : Ms. E. Pavuna Sundari, Cit सुनवाई क तारीख/Date Of Hearing : 05.08.2025 घोषणा क तारीख /Date Of Pronouncement : 26.09.2025

For Appellant: Mr. D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 132Section 143(3)Section 153A

decipher as to how these entries were made in the ‘Ghat’ Ledger. The Ld. CIT(A) is noted to have called for the relevant seized material for verification and after undertaking an elaborate analysis, he concluded that, the entries in this ‘Ghat’ ledger did not comprise of any ‘metal’ addition ... 1182/Chny/2025 & ITA Nos.1393 to 1397/Chny/2025 (AYs: 2017-18 to 2021-22) M/s. Mohanlal Jewellers Pvt. Ltd ::34 :: powers, he had called for the entire seized material and thereafter himself verified the ‘ghat’ entries randomly on test-check basis, particularly where the gold was being re-made into new gold ornaments

Mohanlal Jewellers Pvt. Ltd., Chennai vs. DCIT, Central Circle-3(3), Chennai

ITA 1178/CHNY/2025[2017-18]Status: DisposedITAT Chennai26 Sept 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1178 To 1182/Chny/2025 िनधारण वर्ष/Assessment Years: 2017-18 To 2021-22 M/S. Mohanlal Jewellers Pvt. Ltd, Old No.68-69, Nsc Bose Road, Sowcarpet, Chennai-600 001. V. The Dcit, Central Circle-3(3), Chennai. [Pan: Aafcm 9906 M] (अपीलाथ/Appellant) (प्रत्यथ/Respondent) आयकर अपील सं./Ita Nos.1393 To 1397/Chny/2025 िनधारण वर्ष/Assessment Years: 2017-18 To 2021-22 The Dcit, Central Circle-3(3), Chennai. V. M/S. Mohanlal Jewellers Pvt. Ltd., Old No.68-69, Nsc Bose Road, Sowcarpet, Chennai-600 001. [Pan: Aafcm 9906 M] (अपीलाथ/Appellant) (प्रत्यथ/Respondent) Assessee By : Mr. D. Anand, Advocate Department By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 05.08.2025 घोषणा की तारीख /Date Of Pronouncement : 26.09.2025

For Appellant: Mr. D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 132Section 143(3)Section 153A

decipher as to how these entries were made in the ‘Ghat’ Ledger. The Ld. CIT(A) is noted to have called for the relevant seized material for verification and after undertaking an elaborate analysis, he concluded that, the entries in this ‘Ghat’ ledger did not comprise of any ‘metal’ addition ... 1182/Chny/2025 & ITA Nos.1393 to 1397/Chny/2025 (AYs: 2017-18 to 2021-22) M/s. Mohanlal Jewellers Pvt. Ltd ::34 :: powers, he had called for the entire seized material and thereafter himself verified the ‘ghat’ entries randomly on test-check basis, particularly where the gold was being re-made into new gold ornaments