MANISH AGARWAL,BALLYGUNGE vs. ACIT, CENTRAL CIRCLE-2, RANCHI
In the result, the appeal of the assessee is allowed
ITA 16/RAN/2024[2011-12]Status: DisposedITAT Ranchi06 Jan 2026AY 2011-12
Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.16/Ran/2024 Assessment Year: 201-12 Manish Agarwal……….…………….…….…............................……….……Appellant 35A, Tirumala Apartment, Ballygunge Park, Kol- 700019. [Pan: Acdpa1176E] Vs. Acit, Central Circle-1, Ranchi......…..…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Sunit Dasgupta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 28.11.2023 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That A Search & Seizure Operation Under Section 132 Of The Act Was Conducted In The Case Of The Assessee Group On 23.10.2019. Pursuant To The Said Search, The Assessing Officer (Ao) Issued A Notice Under Section 153A Of The Act Calling Upon The Assessee To File Its Return Of Income For Six Assessment Years Preceding The Year Of Search. In Response To The Notice Under Section 153A, The Assessee Filed Its Return Of Income For Assessment Year 2011–12, Declaring A Total Income Of ₹6,95,180/-. During The Course Of Assessment Proceedings, Several Statutory Notices Were Issued To The Assessee, Which
Section 132Section 139Section 143(3)Section 147Section 148Section 149Section 151Section 153Section 153ASection 153C
153C and the provisos thereto (as applicable), assessments can be reopened only up to six years, and in specified cases, up to seven years, subject to the condition that income escaping assessment exceeds ₹50 lakh. The ld. counsel in this respect has referred to section 153A which reads as under:
"153A. Assessment in case of search or requisition - (1) Notwithstanding
