This compilation indexes twelve Indian income-tax rulings — spanning ITAT benches and High Courts from March 2021 to June 2026 — in which Section 153B of the Income Tax Act, 1961 was cited as a material provision. The cases arise in the context of search assessments under Section 153A and related provisions, and cover questions touching on time-limits for completion of assessments, the interplay of limitation with revision and penalty jurisdiction, and procedural compliance in post-search proceedings. The compilation is intended as a first-look research index for in-house tax teams, Big-4 associates, and law firm researchers tracking the current judicial landscape around Section 153B.

Research index only. This page catalogues publicly available court and tribunal orders for legal research purposes. Nothing on this page constitutes legal advice, tax advice, or a recommendation of any course of action. Readers must verify all information against the full text of the original judgment and consult qualified advisers before acting.

The statutory framework in one paragraph

Section 153B of the Income Tax Act, 1961 prescribes the time-limits within which an Assessing Officer must complete an assessment or reassessment initiated pursuant to a search under Section 132 or a requisition under Section 132A. In broad terms, the section requires that assessments under Section 153A (and, where applicable, Section 153C) be made within a specified period running from the end of the financial year in which the last of the authorisations for search was executed, subject to certain exclusions and extensions provided in the section itself and in related provisions of the Act. The precise computation of the limitation period — including which periods are to be excluded and how the "relevant assessment year" is identified — has given rise to substantial litigation, reflected in the rulings indexed below.

The 12 rulings

1. Sunil Kumar Xalxo vs State Of Chhattisgarh

Bench: Chattisgarh High Court
Date: 17 June 2026
Sections engaged: 153A, 153B, 295A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before the High Court of Chhattisgarh at Bilaspur and is registered as CRMP No. 1532 of 2026, involving multiple petitioners. Per the source preview, the matter engages Sections 153A, 153B, and 295A of the Income Tax Act; the substantive grounds and final directions are not captured in the available text preview.

2. Sri Srinivasa Educational & Charitable vs DCIT, Central Circle-2(3), Bangalore

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 13 November 2025
Sections engaged: 153B, 153A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA No. 939 & 940/Bang/2025) before the Tribunal's 'B' Bench, Bangalore, relate to Assessment Years 2020-21 and 2021-22, and were filed by M/s Sri Srinivasa Educational & Charitable Trust (PAN: AAGCS 0925 B) against the DCIT, Central Circle-2(3), Bangalore. Per the source preview, the proceedings appear to involve a search-related assessment context engaging Sections 153B and 153A; the order was pronounced on 26.11.2025, but the dispositive directions are not captured in the available text preview.

3. Pr. Commissioner Of Income Tax vs Sh. Praveen Sawhney

Bench: Delhi High Court
Date: 13 May 2025
Sections engaged: 143(3), 153A, 153B, 260A, 271(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The judgment delivered on 13.05.2025 consolidates multiple ITA numbers (including ITA 758/2023, ITA 216/2023, ITA 694/2023, ITA 706/2023, ITA 707/2023, ITA 781/2023, ITA 782/2023, ITA 783/2023 and connected matters) filed by the Principal Commissioner of Income Tax-Central-1 before the Delhi High Court against members of the Sawhney family. Per the source preview, the appeals engage Sections 153A, 153B, 260A, 143(3), and 271(1)(c); the detailed grounds and final directions are not captured in the available text preview.

4. Principal Commissioner Of Incme Tax-I vs Shri Ashok Kumar Maheshwari

Bench: Rajasthan High Court - Jaipur
Date: 3 April 2025
Sections engaged: 260A, 153A, 153B
Outcome: Outcome not specified in source
Procedural / substantive ground: This is D.B. Income Tax Appeal No. 332/2018 before the High Court of Judicature for Rajasthan at Jaipur, concerning Assessment Year 2013-14, with a disputed income of Rs. 1,49,78,202/-. Per the source preview, a search was conducted on 18.07.2012 at Nuwal Group, Jaipur, of which the respondent-assessee was a member; proceedings were initiated pursuant to that search and the assessment was finalised on 13.03.2015, with penalty proceedings also recorded — the matter before the High Court engages Sections 260A, 153A, and 153B, and the final directions of the High Court are not captured in the available text preview.

5. Shri Rajnikant Mohanlal vs The Asstt. Commr. Of Income Tax, Cen

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 9 January 2025
Sections engaged: 153, 153B, 153B(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals before the ITAT Rajkot Bench are registered as ITA No. 30-33/RJT/2021 and CO No. 3, 4, 5 & 6-RJT/2021, covering Assessment Years 2006-07 and 2007-08 (PAN: ABNPB9253C). Per the source preview, the proceedings involve a return of income filed under Section 153A on 27.07.2012 for the financial year 2006-07, and the matter engages Sections 153, 153B, and 153B(1); the order was pronounced in open court on 09/01/2025, but the dispositive directions are not captured in the available text preview.

6. Anuradha Bakshi vs The Principal Commissioner Of Income

Bench: Delhi High Court
Date: 19 October 2023
Sections engaged: 263, 153B
Outcome: Outcome not specified in source
Procedural / substantive ground: This writ petition (W.P.(C) 13844/2023 & CM APPLs. 54680-54681/2023) was filed before the Delhi High Court challenging a notice issued on 24th August 2023 by the Principal Commissioner of Income Tax, Central New Delhi-1 invoking revisional jurisdiction under Section 263 in respect of an assessment order pertaining to AY 2015-16 framed on 31st March 2023. Per the source preview, the petitioner contended that the assessment order proposed to be revised under Section 263 was barred by limitation — a jurisdictional issue engaging the interplay of Sections 263 and 153B — and the court was called upon to adjudicate this issue; the final directions are not captured in the available text preview.

7. Sh. Vikram Dhirani, New Delhi vs ACIT, New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 17 April 2023
Sections engaged: 153B
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter before the ITAT Delhi Bench 'G' consolidates multiple ITA numbers, including ITA No. 4100/Del/2016 (AY 2007-08) and ITA Nos. 4647 to 4652/Del/2016 covering AYs 2007-08 through 2012-13, filed by and against Sh. Vikram Dhirani (PAN: AHTPD6528L). Per the source preview, the proceedings engage Section 153B; the order was pronounced on 17.04.2023 but the substantive findings and dispositive directions are not captured in the available text preview.

8. Jami Sivasai, Koraput vs ACIT, Central Circle-1, Bhubaneswar

Bench: Income Tax Appellate Tribunal - Cuttack
Date: 1 December 2022
Sections engaged: 153B, 132
Outcome: Outcome not specified in source
Procedural / substantive ground: These are appeals (IT(ss)A Nos. 151 to 154/CTK/2018) filed by the assessee against separate orders of the CIT(A)-2, Bhubaneswar dated 28.9.2018, for Assessment Years 2013-14 to 2016-17 (PAN: ABTPJ 6346 E). Per the source preview, the appeals were filed on 6.12.2018 and had been posted for hearing on nearly 24 occasions, with the assessee repeatedly seeking adjournments without progressing disposal; the hearing and pronouncement both took place on 1/12/2022, engaging Sections 153B and 132, but the substantive outcome is not captured in the available text preview.

9. … vs The Assistant Commissioner Of Income

Bench: Madras High Court
Date: 27 July 2022
Sections engaged: 153A, 153B, 153C
Outcome: Outcome not specified in source
Procedural / substantive ground: This common order of the Madras High Court disposes of multiple writ petitions (W.P. Nos. 6422, 7291, 7284, 6425, 6426, 6429, 6431 & 7298 of 2019) filed under Article 226 of the Constitution, challenging assessment orders passed by the Assistant Commissioner of Income Tax, Central Circle-1(1), Chennai. Per the source preview, the challenge covers five orders of assessment in respect of M/s. RKM PowerGen Private Limited (PAN: AAICS2163F) for AYs 2010-11 through 2014-15, with the petitions praying for a writ of certiorari to quash those orders; the proceedings engage Sections 153A, 153B, and 153C, and the final directions are not captured in the available text preview.

10. The Principal Commissioner Of vs M/S. Nidan

Bench: Orissa High Court
Date: 13 July 2022
Sections engaged: 153B, 132
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 155 of 2018) was filed by the Revenue before the High Court of Orissa at Cuttack challenging an order dated 16th May 2018 of the ITAT Cuttack Bench in IT(SS)A Nos. 32 to 37/CTK/2018 for AYs 2009-10 to 2015-16; the delay of 51 days in filing was condoned. Per the source preview, a search was conducted under Section 132 of the Act on 20th May 2014 in the case of the respondent-assessee, and a question before the court relates to the despatch and receipt of the assessment order dated 30th December 2016 — engaging the limitation framework under Section 153B; the High Court's final directions are not captured in the available text preview.

11. Shri Ramswaroop Shivhare, Gawaliore vs The ACIT, Central-1, Bhopal

Bench: Income Tax Appellate Tribunal - Indore
Date: 19 April 2022
Sections engaged: 142, 153B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal before the ITAT Indore Bench involves the assessee Shri Ram Swaroop Shivhare and covers multiple assessment years from 2010-11 to 2016-17, with returns filed under Section 153A on 25.03.2017 for AYs 2010-11 through 2015-16; per the source preview, the proceedings also reference an AOP assessment (Shri Ram Swaroop Shivhare & Others, Gwalior Group) under Sections 144/153C read with 153A, with income assessed for certain years including AY 2013-14 at Rs. 8,60,26,366/- and AY 2014-15 at Rs. 2,51,72,607/-. The matter engages Sections 142 and 153B; the substantive findings and dispositive directions of the Tribunal are not captured in the available text preview.

12. Blossom Gold Collection P.Ltd vs Union Of India

Bench: Kerala High Court
Date: 1 March 2021
Sections engaged: 245C, 153B
Outcome: Outcome not specified in source
Procedural / substantive ground: This intra-court writ appeal (W.A. No. 405 of 2021) before the Kerala High Court at Ernakulam was filed by Blossom Gold Collection P. Ltd. against an interim order dated 22.02.2021 that had refused to grant an interim stay of the impugned orders. Per the source preview, the proceedings involve the Income Tax Settlement Commission (Additional Bench, Chennai) and engage Chapter XIX-A of the Income Tax Act dealing with settlement of cases, alongside Section 153B; the final directions of the Division Bench on the writ appeal are not captured in the available text preview.

Patterns across these 12 rulings

Search-triggered assessment as the common origin. Across the cases where sufficient factual detail is visible in the source previews — including the Orissa High Court matter (The Principal Commissioner Of vs M/S. Nidan), the Rajasthan High Court matter (Principal Commissioner Of Incme Tax-I vs Shri Ashok Kumar Maheshwari), and the ITAT Rajkot matter (Shri Rajnikant Mohanlal) — the underlying assessment invariably traces to a search action, with Section 153B providing the governing time-limit framework for completing that assessment. This confirms Section 153B's function as the primary limitation anchor in post-search proceedings.
Multi-year, multi-ITA appeals are the norm. Several rulings in this set — including the ITAT Delhi matter (Sh. Vikram Dhirani, covering AYs 2007-08 through 2012-13), the ITAT Cuttack matter (Jami Sivasai, Koraput, covering AYs 2013-14 to 2016-17), the Madras High Court matter (covering AYs 2010-11 to 2014-15), and the Orissa High Court matter (covering AYs 2009-10 to 2015-16) — involve consolidated proceedings spanning multiple assessment years, reflecting the block-assessment character of the Section 153A regime and the correspondingly extended reach of Section 153B limitation questions.
Interplay with revision and penalty jurisdiction. Two cases in this set specifically raise the intersection of Section 153B limitation with other jurisdictions: the Delhi High Court matter (Anuradha Bakshi) questions whether a Section 263 revision notice can be sustained once the underlying assessment is argued to be time-barred, and the Rajasthan High Court matter (Principal Commissioner Of Incme Tax-I vs Shri Ashok Kumar Maheshwari) involves penalty proceedings initiated alongside a search assessment. These rulings illustrate that Section 153B limitation arguments are raised not only against original assessments but also against downstream revisional and penalty actions.
Settlement commission proceedings as a concurrent track. The Kerala High Court matter (Blossom Gold Collection P.Ltd vs Union Of India) demonstrates that Section 153B limitation questions can arise alongside or within settlement commission proceedings under Chapter XIX-A, suggesting that the Section 153B time-limit framework has relevance beyond the pure assessment track and extends into alternative dispute resolution pathways.
Outcome data absent across all 12 rulings. Notably, the outcome direction for all twelve cases is recorded as "Outcome not specified in source." Researchers should treat this compilation as a case-identification and procedural-context index only, and must retrieve the full text of each judgment to ascertain the actual holdings, orders, and their current status.

How to use this compilation

This index is designed as a starting point for locating rulings that engage Section 153B in varied procedural contexts — search assessments, revision proceedings, settlement commission challenges, and penalty matters. Each entry identifies the forum, the date, the co-engaged provisions, and the procedural posture as far as the source preview allows. Researchers should use the party names, ITA or writ petition numbers, and dates listed here to retrieve the full text of each judgment from indiankanoon.org, the official court portal of the relevant High Court, or the ITAT's e-filing/orders portal, and read the complete reasoning and operative order before drawing any conclusions.

Because outcome data is not available in the source previews for any of the twelve rulings indexed here, researchers must independently verify: (a) the final operative direction of the court or tribunal; (b) whether any ruling has been stayed, reversed, or distinguished by a subsequent order; (c) whether any High Court ruling has been appealed to the Supreme Court; and (d) whether any ITAT ruling has been subjected to further proceedings before a High Court. The dates of orders span 2021 to 2026, and the legal position under Section 153B has been subject to legislative amendment and evolving judicial interpretation across this period — AY-specific and amendment-specific analysis is essential.

Finally, researchers tracking Section 153B should also consult parallel CBDT circulars, instructions, and press releases that have from time to time extended or clarified limitation periods — particularly those issued in response to COVID-19-related disruptions and subsequent Finance Act amendments — as these administrative directions interact directly with the statutory time-limits that form the subject matter of the rulings indexed above.

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 153B Search Assessment Limitation: 12 Rulings (2021–2026)