This compilation indexes twelve recent rulings from the Income Tax Appellate Tribunal (ITAT) and various Indian High Courts, all decided between March and April 2026, in which Section 132 of the Income Tax Act, 1961 was a cited provision. The compilation is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who need a structured, citation-ready reference to current judicial activity around income tax search and seizure proceedings and their downstream assessments. Each entry reproduces only the data available in the source judgment record; no editorial interpretation of outcomes has been added where the source record does not support one.

Research index only. This page is a structured index of publicly available court and tribunal orders. It does not constitute legal advice, tax advice, or any form of professional opinion. Readers must independently verify all information against the full text of each judgment before relying on it.

The statutory framework in one paragraph

Section 132 of the Income Tax Act, 1961 confers power on the income tax authorities to conduct search and seizure operations. Where, on the basis of information in their possession, the authorised officer has reason to believe that a person has concealed income or assets, the provision empowers the authorised officer to enter and search premises, inspect books of account and other documents, seize such books or assets, and examine persons found at the searched premises. Sub-section (4) of Section 132 specifically authorises the authorised officer to examine, on oath, any person who is found in possession of or in control of books of account or documents, and any statement made by such a person during examination may be used in evidence in any proceeding under the Act.

The 12 rulings

1. Best Oasis Limited, Mumbai vs The Dy. CIT, Central Circle-1(1)

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 23 April 2026
Sections engaged: 127, 132, 143(2), 144, 144(1), 153A, 2, 234A, 250, 271A, 6(3), 8
Procedural / substantive ground: The appeal before the Ahmedabad ITAT arose for assessment year 2020-21 and involved proceedings in the context of a search, with multiple provisions including those relating to assessment under search conditions and transfer of jurisdiction engaged. The text preview confirms the matter was heard before the Tribunal with representation from both the assessee and the Revenue. No outcome information is available in the source record.

2. Torque Pharmaceuticals Private Limited vs DCIT, Central Circle-2, Chandigarh

Bench: Income Tax Appellate Tribunal - Chandigarh
Date: 21 April 2026
Sections engaged: 1, 11, 110, 11U, 132, 143(3), 147, 148, 148B, 17, 2, 20, 36(1), 36(1)(iii), 37, 533, 56(2), 56(2)(x), 69C, 7
Procedural / substantive ground: The appeal before the Chandigarh ITAT concerned assessment year 2021-22 and engaged a broad range of provisions spanning search, reassessment, and disallowance of expenditure. The citation of multiple provisions including those relating to unexplained expenditure and fair market value of property received reflects the multi-issue character of a post-search assessment. No outcome information is available in the source record.

3. DCIT, Central Circle-25, New Delhi vs Neel Industries P. Ltd, Tamilnadu

Bench: Income Tax Appellate Tribunal - Delhi
Date: 20 April 2026
Sections engaged: 115J, 132, 139, 153A, 153D, 233, 252, 262, 27, 39, 5, 8, 80, 862
Procedural / substantive ground: This batch of 67 appeals before the Delhi ITAT's "C" Bench covered assessment years 2008-09 through 2018-19 and involved parties including JBM Auto Ltd. and JBM Auto System. The engagement of provisions relating to assessment under search and approval of assessment by superior authority indicates post-search assessment disputes spanning multiple years. No outcome information is available in the source record.

4. DCIT, Central Circle 01, New Delhi vs Sanjay Jain, New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 17 April 2026
Sections engaged: 1, 127, 132, 143(3), 153A, 153C, 153D, 85
Procedural / substantive ground: The appeals and cross-objections before the Delhi ITAT related to assessment years 2010-11, 2011-12, and 2012-13, with both Revenue and the assessee filing cross-proceedings. The citation of provisions governing assessment in search cases, satisfaction for proceedings against a third party, and prior approval for assessment in search cases points to a dispute centred on the validity and scope of post-search assessments. No outcome information is available in the source record.

5. M. Rajkumar vs The Director

Bench: Madras High Court
Date: 08 April 2026
Sections engaged: 132, 132(4), 2, 271A, 276C
Procedural / substantive ground: This writ petition before the Madras High Court involved the Director General of Income Tax (Investigation) and the Principal Commissioner of Income Tax (Central) as respondents, suggesting a challenge arising from a search and related proceedings. The engagement of the provision governing statements made during search, together with provisions relating to penalty for failure to maintain books and prosecution for wilful attempt to evade tax, indicates a matter with both penalty and prosecution dimensions. No outcome information is available in the source record.

6. MS Khurana Engineering Limited vs Assistant Commissioner of Income Tax

Bench: Gujarat High Court
Date: 08 April 2026
Sections engaged: 132, 132A, 148, 149, 152(3), 153A, 153C, 9
Procedural / substantive ground: This Special Civil Application before the Gujarat High Court engaged provisions relating to both search and requisition, as well as reassessment and assessment in search cases. The citation of limitation and bar provisions alongside the search and post-search assessment framework suggests the challenge raised questions about the validity or timeliness of proceedings initiated consequent upon a search. No outcome information is available in the source record.

7. West India Infratech Private Limited vs Assistant Commissioner of Income Tax

Bench: Gujarat High Court
Date: 08 April 2026
Sections engaged: 132, 132A, 148, 149, 152(3), 153A, 153C, 36
Procedural / substantive ground: This Special Civil Application before the Gujarat High Court was decided on the same date as the Khurana Engineering matter and engaged a substantially similar set of provisions, indicating that the legal questions raised regarding search, requisition, and consequent assessments were comparable across both petitions. No outcome information is available in the source record.

8. R N Constructions, Hyderabad vs DCIT, Central Circle-1(2), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 25 March 2026
Sections engaged: 11, 132, 139, 143(2), 143(3), 153, 153A, 250, 270, 270A, 270A(9), 274, 35, 51, 67, 7
Procedural / substantive ground: The appeal before the Hyderabad ITAT for assessment year 2017-18 involved a post-search assessment scenario with provisions relating to under-reporting and misreporting of income also being cited, including provisions governing levy of penalty in such cases. The engagement of both the assessment and penalty framework in the same proceedings reflects a composite challenge to both the quantum of addition and the consequent penalty. No outcome information is available in the source record.

9. Kavya Boppana, Hyderabad vs ACIT, Central Circle-2(3), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 25 March 2026
Sections engaged: 1, 115, 115B, 127, 132, 132(4), 139, 139(1), 14, 143(3), 24, 271A, 274, 3, 69, 69A, 74, 770
Procedural / substantive ground: The assessee's appeal for assessment year 2020-21 arose from a penalty order, with the text preview confirming the matter originated from a penalty proceeding arising out of the search framework. The citation of provisions relating to unexplained investments and unexplained money alongside those governing search statements indicates that additions were made on the basis of materials gathered during search. No outcome information is available in the source record.

10. Mukesh Kumar Chaurasia, Guwahati vs ACIT, Central Circle-2, Guwahati

Bench: Income Tax Appellate Tribunal - Gauhati
Date: 19 March 2026
Sections engaged: 132, 132(4), 139(1), 14, 143(2), 143(3), 250, 271A, 450, 5, 56, 7
Procedural / substantive ground: Two appeals filed by the assessee for assessment years 2023-24 and 2024-25 were heard together before the Gauhati Bench sitting at Kolkata. The text preview confirms the appeals were directed against orders of the Commissioner of Income Tax (Appeals)-Central NER, Guwahati passed under the appellate provision. The citation of provisions relating to search statements and books of account penalty alongside scrutiny assessment provisions reflects a dispute involving post-search examination and assessment. No outcome information is available in the source record.

11. Rupam Rajendra Gorecha vs The Director of Income Tax

Bench: Madhya Pradesh High Court
Date: 16 March 2026
Sections engaged: 11, 132, 132A(1), 153A
Outcome: Revenue succeeded
Procedural / substantive ground: The writ petition before the Madhya Pradesh High Court at Indore challenged the authorisation for search and/or requisition proceedings. The court dismissed the petition on the ground that the issue raised — namely, the challenge to the authorisation — was already under consideration in a pending appeal before the High Court of Gujarat at Ahmedabad, as recorded in the outcome field of the source record.

12. Imran Alaudin Mansuri vs Union of India

Bench: Madhya Pradesh High Court
Date: 12 March 2026
Sections engaged: 132
Outcome: Remanded
Procedural / substantive ground: The writ petition before the Madhya Pradesh High Court at Indore was listed for further hearing to address a preliminary objection raised by the respondents regarding maintainability of the petition on the ground of availability of an alternative remedy. The source record records the outcome as remanded, with the court yet to make a final determination on the merits, pending consideration of the maintainability question.

Patterns across these 12 rulings

Convergence of search and post-search assessment provisions. Across the majority of the twelve rulings, Section 132 does not appear in isolation — it is cited alongside provisions governing assessment in search cases and related approval requirements. This pattern is visible in rulings from Delhi, Hyderabad, Ahmedabad, and the Gujarat High Court, suggesting that most disputes involving the search power have migrated into the assessment and penalty stages of proceedings.
Search statement provision cited in penalty and assessment contexts. Sub-section (4) of Section 132, governing statements made on oath during search, appears as a cited provision in rulings from Hyderabad, Gauhati, and the Madras High Court. The co-citation of penalty provisions in these same matters indicates that statements recorded during search continue to form the evidentiary basis for both assessment additions and penalty proceedings.
Jurisdictional and authorisation challenges reaching High Courts. Three of the four High Court rulings in this compilation involve challenges to the authorisation or initiation of search and consequent proceedings rather than disputes over quantum of income. The Madhya Pradesh High Court dismissed one such challenge (Rupam Rajendra Gorecha) on the ground of a pending parallel proceeding, while another (Imran Alaudin Mansuri) remained at the maintainability stage, reflecting a recurring pattern of writ jurisdiction being invoked at the pre- or early-assessment stage.
Multi-year and batch proceedings. Several rulings — notably the Delhi ITAT matter covering assessment years 2008-09 through 2018-19 and the Chandigarh ITAT matter for AY 2021-22 — involve assessments spanning multiple years, consistent with the statutory framework under which a search triggers assessment for multiple preceding years. This generates complex, multi-appeal proceedings before the Tribunal.
Absence of final recorded outcomes in ITAT matters. None of the eight ITAT rulings in this compilation carry a populated outcome field in the source record. This is a data characteristic of recently pronounced orders where structured outcome extraction has not yet been completed, and researchers should access the full text of each order to determine the final direction of the Tribunal.

How to use this compilation

This compilation is a starting-point index, not a substitute for reading the full judgment. Each entry above is derived from structured metadata and text previews available in the TaxNoticeAI corpus. Before placing any reliance on a ruling for a specific matter, researchers should retrieve the full text of the judgment from indiankanoon.org, the official ITAT website, or the relevant High Court portal, and verify that the preview accurately reflects the complete ratio and operative order. Text previews by their nature capture only the opening portion of a judgment and may not reflect the final decision or any later clarification or correction.

Researchers should also check for subsequent developments affecting each ruling. A Tribunal order may have been challenged before a High Court, and a High Court order may be the subject of a Special Leave Petition before the Supreme Court. Stays granted at a higher appellate level may affect the operative effect of the ruling indexed here. The TaxNoticeAI corpus is updated on a rolling basis, but researchers working on live matters must conduct independent checks on the current status of each case.

Finally, where a ruling deals with provisions that are also addressed by Central Board of Direct Taxes circulars, instructions, or press releases, those administrative materials should be consulted alongside the case law. Judicial interpretation and departmental practice can diverge, and the two sources are complementary inputs in a complete research exercise.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 132 Search & Seizure: 12 ITAT & High Court Rulings (2026)