This compilation indexes twelve recent rulings — from the Income Tax Appellate Tribunal (ITAT) benches across India and two High Courts — in which Section 153C of the Income Tax Act, 1961 was among the sections engaged. The cases span April–May 2026 and arise from a range of factual contexts including search and seizure actions, reassessment proceedings, revision orders, and satisfaction-note disputes. This index is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who need a structured starting point for primary-source research on Section 153C litigation.

Research index only. This page is a structured case-law reference tool. Nothing on this page constitutes legal advice, tax advice, or a recommendation of any kind. Readers must verify each ruling against the full, official judgment text before relying on it for any purpose.

The statutory framework in one paragraph

Section 153C of the Income Tax Act, 1961 governs the assessment of income of a person other than the person searched. Where the Assessing Officer of the searched person is satisfied that any money, bullion, jewellery, other valuable article or thing, or any books of account or documents seized or requisitioned belong to, or any information contained therein relates to, a person other than the searched person, such material is to be handed over to the Assessing Officer having jurisdiction over that other person, who may then issue notice and make assessment or reassessment for the relevant assessment years in accordance with the provisions of Section 153A. The section has been the subject of extensive litigation on questions including the adequacy of the satisfaction note, the jurisdictional link between the seized material and the person assessed, limitation periods, and the interaction with other provisions such as Sections 132, 153A, 147, 148, and 263.

The 12 rulings

1. Afreed Mohammad,Hyderabad vs ITO, Ward-9(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 15 May 2026
Sections engaged: 147, 148, 148A, 148A(b), 148A(d), 149, 151, 153A, 153C, 163
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 495/Hyd/2026) was filed for Assessment Year 2015-2016. Per the source preview, the Tribunal prioritised ground no. 1(b) — a legal challenge to the validity of the notice issued under Section 148 of the Act on the ground that it was barred by limitation — as it went to the root of the matter. The source preview also records that the Assessing Officer had issued a show cause notice under Section 148A in connection with the proceedings.

2. Penugonda Yaganasree,Tadepalligudem vs Income Tax Officer, Ward-1

Bench: Income Tax Appellate Tribunal - Vizag
Date: 14 May 2026
Sections engaged: 147, 148, 148A, 149, 151, 153A, 153C, 163
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 722/VIZ./2025) relates to Assessment Year 2015-2016 and was heard through hybrid mode. Per the source preview, the Tribunal took up ground no. 3 first as it was legal in nature and went to the root of the matter; the substantive content of that ground is not reproduced in the available preview. The appeal was filed against the order of the Income Tax Officer, Ward-1, Tadepalligudem.

3. Kangan Jewels Private Limited,Surat vs ITO 1(1)(3), Surat, Surat

Bench: Income Tax Appellate Tribunal - Surat
Date: 6 May 2026
Sections engaged: 132, 145(3), 153C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA Nos. 998 to 1003/SRT/2025) cover Assessment Years 2009-10 to 2014-15, arising from a search and seizure action under Section 132 of the Act. Per the source preview, the Tribunal took ITA No. 1002/SRT/2025 (relating to Assessment Year 2013-14) as the lead case, and the preview notes factors including categorical admission of the Director, falsity of books of account and recorded transactions, and failure of the assessee to disclose the true nature of its business activities.

4. Dilip Patel vs The Principal Commissioner Of Income

Bench: Gujarat High Court
Date: 1 May 2026
Sections engaged: 263, 153C
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter was heard as Special Civil Application No. 4314 of 2026 (with SCA No. 4316 of 2026) before the Gujarat High Court and was reserved on 27 April 2026. Per the source preview, the assessee's submissions included a challenge to the satisfaction note — arguing that it recorded the full amount of Rs. 39.32 crores — and noted that the buyers had challenged notices issued under Section 153C before the court. The interaction between Section 263 revision proceedings and the Section 153C assessment framework appears to be central to the dispute, per the source preview.

5. Assistant Commissioner Of Income Tax vs Venkata Rosaiah Kilari, Guntur

Bench: Income Tax Appellate Tribunal - Vizag
Date: 30 April 2026
Sections engaged: 132(4), 153C
Outcome: Outcome not specified in source
Procedural / substantive ground: Two cross-appeals were filed for Assessment Year 2017-18 (ITA No. 353/Viz/2025 and ITA No. 425/Viz/2025). Per the source preview, the assessee raised additional grounds of appeal challenging the validity of the notice issued by the Assessing Officer under Section 153C of the Act; the Tribunal took up that question — described as going to the root of the matter — for adjudication. The full reasoning on the validity challenge is not reproduced in the available preview.

6. Krishna Murthy Paivardan,Warangal vs ITO, Ward-1, Warangal

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 30 April 2026
Sections engaged: 147, 148, 148A, 148A(b), 148A(d), 149(1), 151, 151A, 153A, 153C, 163, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 2326/Hyd/2025) relates to Assessment Year 2015-2016. Per the source preview, the assessee challenged the order passed under Section 148A(d) on the ground that it was vitiated in law due to non-compliance with the statutory procedure and safeguards mandated under Section 148A, and also raised the ground that reassessment proceedings were invalid for violation of the faceless assessment regime. The Ld. CIT(A) was alleged to have erred in sustaining the reassessment without examining these procedural infirmities.

7. Bharath Kumar Kondreddy,Hyderabad vs DCIT, Central Circle-1(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 30 April 2026
Sections engaged: 132(4), 143(3), 148, 148A, 151, 153A, 153C, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: The order covers five consolidated appeals (ITA Nos. 310 to 312/Hyd/2026 and ITA Nos. 940 and 941/Hyd/2026) relating to Assessment Years 2020-21, 2021-22, and 2022-23. Per the source preview, the appeals arose from orders of the CIT(A)-11, Hyderabad. The full substantive reasoning is not reproduced in the available preview; the appeal was filed against orders dated 08.12.2025 and 09.12.2025 respectively.

8. The Deputy Commissioner Of Income Tax vs Sri C R Ram Mohan Raju

Bench: Karnataka High Court
Date: 24 April 2026
Sections engaged: 153A, 153C
Outcome: Outcome not specified in source
Procedural / substantive ground: This is a Writ Appeal (WA No. 382 of 2026) filed by the Revenue before the Karnataka High Court, praying to set aside the order passed by the learned Single Judge in WP No. 33057/2024 (T-IT) dated 27.10.2025. Per the source preview, the matter was reserved on 01.04.2026 and pronounced on 24.04.2026. The substantive grounds of the original writ petition and the disposition of the writ appeal are not reproduced in the available preview.

9. DCIT Central Circle -2(2), Pune vs Ramesh Pannalal Ranka, Pune

Bench: Income Tax Appellate Tribunal - Pune
Date: 21 April 2026
Sections engaged: 132, 153A, 153C
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter involves IT(SS)A Nos. 31 & 32/PUN/2025 for Assessment Years 2013-14 and 2014-15, and ITA No. 2944/PUN/2025 for Assessment Year 2014-15. Per the source preview, the assessee is an individual Chartered Accountant who filed his original return on 22.04.2013 declaring total income of Rs. 7,33,747/-; a search and seizure action under Section 132 of the Act was conducted on 06.08.2013 and was finally concluded on 01.10.2013 in the case of Sinhagad Technical Education Society and Maruti (name truncated in preview).

10. Rameshkumar Puraji Jain,Mumbai vs DCIT 4(2), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 21 April 2026
Sections engaged: 153C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA Nos. 8519 & 8520/Mum/2025) relate to Assessment Years 2019-20 and 2020-21. Per the source preview, which contains payment details referencing Bank of India account transactions totalling Rs. 18,41,100/- dated 16.11.2020, the proceedings appear to involve financial transactions examined in the context of the Section 153C assessment. The substantive grounds and outcome are not reproduced in the available preview.

11. Naresh Chandra Agarwal,Morena vs Income Tax Officer, Ward 1, Morena

Bench: Income Tax Appellate Tribunal - Agra
Date: 20 April 2026
Sections engaged: 143(2), 148, 148A, 153(1), 153B(1), 153C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 460/AGR/2014) relates to Assessment Year 2018-19. Per the source preview, the Tribunal examined a timeline of relevant dates: the date of search in the case of Narayan Hari Gupta (22.02.2018), the date on which information was received by the Assessing Officer of the appellant from the ACIT, Central Circle, Gwalior (20.02.2020), and the date of completion of assessment under Section 153B(1) computed as 21 months from the end of the financial year in which the last search authorisation was executed (i.e. 31.12.2019). These dates appear central to the limitation analysis under the provisions engaged.

12. DCIT, Central Circle-8(1), Mumbai vs Ajit Anantrao Pawar, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 20 April 2026
Sections engaged: 153C, 143(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The Revenue preferred this appeal (ITA No. 2173/MUM/2025) against the order dated 30.01.2025 passed by the Ld. Commissioner of Income Tax (Appeals) for Assessment Year 2020-21. Per the source preview, the Ld. CIT(A) had quashed the assessment framed under Section 153C of the Income Tax Act, 1961, and the Revenue, being aggrieved by that action, filed the present appeal before the Tribunal.

Patterns across these 12 rulings

Section 153C as a jurisdictional flashpoint. Across multiple cases — including cases 5, 8, and 12 — the validity of the Section 153C notice or assessment is the primary ground of challenge. The threshold requirement that seized material must belong to or relate to the person other than the searched person continues to be contested frequently before both ITAT benches and High Courts.
Intersection with reassessment provisions. Cases 1, 2, 6, and 11 involve Section 153C alongside the reassessment framework of Sections 147, 148, and 148A. This clustering suggests that in practice, disputes arising from search-linked proceedings frequently engage both the special search-assessment regime (Sections 153A/153C) and the general reopening provisions, requiring courts to adjudicate the interaction between the two regimes.
Limitation and timeline disputes. Case 11 (Naresh Chandra Agarwal) illustrates that precise computation of limitation periods — including the date of search, date of information transmission, and the outer limit under the relevant provision — is a recurring substantive issue in Section 153C litigation. Case 1 similarly raises a limitation challenge to a notice under Section 148.
Revenue appeals against CIT(A) quashing orders. Case 12 (DCIT, Central Circle-8(1) vs Ajit Anantrao Pawar) involves the Revenue challenging a CIT(A) order quashing the Section 153C assessment, reflecting a pattern in which first-appellate orders granting relief to assessees are contested before the Tribunal by the Revenue.
Multi-year, consolidated appeals. Several orders — including cases 3 (six years, AYs 2009-10 to 2014-15), 7 (three assessment years), and 9 (two assessment years) — consolidate appeals across multiple assessment years arising from a single search action. This structural feature is characteristic of Section 153C proceedings, where a single search event triggers assessments for up to six (or, post-amendment, ten) preceding years.

How to use this compilation

This compilation is a structured index of case references, not a substitute for reading the full judgment text of each ruling. Before relying on any case listed above for any purpose — whether for drafting, advising, filing, or research — readers should obtain and read the complete order from the official source (indiankanoon.org, the relevant ITAT bench portal, or the relevant High Court portal). Summaries drawn from text previews may not capture the full reasoning, all grounds decided, or the precise operative portion of the order.

Researchers should also check whether any listed ruling has been stayed, reversed, or appealed to a higher forum subsequent to its pronouncement. ITAT orders may be challenged before the relevant High Court under Section 260A, and High Court orders may be challenged before the Supreme Court. A ruling that appears final at the ITAT level may have subsequent appellate proceedings that alter its effect.

Finally, readers should cross-reference any ruling against current CBDT circulars, instructions, and any legislative amendments to the relevant provisions (including Sections 132, 153A, 153C, 147, 148, and 148A) that may post-date the ruling, as statutory amendments can affect the applicability of judicial reasoning to current or prospective proceedings.

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 153C Income Tax: 12 ITAT and HC Rulings (2026)