This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) rulings — spanning the Mumbai, Delhi, Surat, Chennai, Ahmedabad, and Raipur benches — in which proceedings under Section 153A(1) and/or Section 153C of the Income Tax Act, 1961 were in issue. The rulings range from August 2022 to August 2026 and are drawn from the TaxNoticeAI structured legal corpus. They are presented here as a research index for in-house tax teams, Big-4 associates, and law firm researchers who need a consolidated starting point for locating primary source material on search-triggered assessments.

Research index only — not legal or tax advice. Every entry below is a summary reference point. Readers must access and read the full judgment before relying on any ruling for any purpose. Outcomes, holdings, and procedural facts should be independently verified against the original order and any subsequent stays, appeals, or reversals.

The statutory framework in one paragraph

Section 153A(1) of the Income Tax Act, 1961 provides that where a search is initiated under Section 132, or books of account, other documents, or any assets are requisitioned under Section 132A, after the 31st day of May 2003, the Assessing Officer shall issue notice to the person requiring him to furnish, within such period as may be specified, returns of income in respect of each assessment year falling within six assessment years (and, in certain circumstances, up to ten assessment years) immediately preceding the assessment year relevant to the previous year in which the search is conducted or requisition is made; the Assessing Officer shall thereafter assess or reassess the total income of those years. Section 153C, which is closely related and frequently appears alongside Section 153A in the rulings below, governs assessment of income of persons other than the searched person where documents or assets seized belong to or pertain to such other person.

The 12 rulings

1. Span Developers, Maharashtra vs DCIT, Central Circle 1, Thane, Thane

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 24 August 2026
Sections engaged: 132, 153A, 153A(1), 153C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Mumbai's "F" Bench and involved multiple ITA numbers pertaining to Assessment Years 2012-13, 2013-14, and 2014-15, with three related appellant entities — Span Developers (PAN: ABKFS4524N), Span Realtors (PAN: ABTFS2835B), and Span Construction (PAN: ABRFS7795J) — all arrayed against DCIT, Central Circle-1, Thane. The source preview indicates proceedings arising under Sections 132, 153A, and 153C of the Act; the full reasoning and dispositional direction are not available in the source preview.

2. Assistant Commissioner Of Income Tax vs Royal Sales Private Limited, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 24 August 2026
Sections engaged: 143(1), 153A, 153A(1), 153C, 153C(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The Revenue filed appeals in ITA Nos. 2401/DEL/2026 and 2402/DEL/2026 before Delhi Bench 'C' against the order of the Commissioner of Income Tax (Appeals)-25, New Delhi dated 21.11.2025 for Assessment Years 2010-11 and 2011-12. At the time of filing, the Registry noted a defect that the appeals were time-barred by 6 days, in response to which the Revenue submitted there was reasonable cause for the delay and prayed for condonation; the text preview does not disclose the final outcome on merits.

3. DCIT Cc 27, New Delhi vs Shiv Kumar Huf, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 21 August 2026
Sections engaged: 153A, 153A(1), 153C, 153C(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: These are Revenue's appeals filed in ITA Nos. 79/Del/2026 and 80/Del/2026 against the orders of the Commissioner of Income Tax (Appeals)-25, New Delhi, relevant for Assessment Years 2014-15 and 2015-16, involving proceedings under Section 153C of the Act. The source preview notes that both appeals involved identical issues and were heard together and disposed of by a common order, treating ITA No. 79/Del/2026 (AY 2014-15) as the lead case; the original return of income for the assessee was filed on 17.7.2014, though the full dispositional reasoning is not available in the source preview.

4. Vaibhav Garg, New Delhi vs DCIT, Central Circle-26, New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 19 August 2026
Sections engaged: 153A, 153A(1), 153C, 153C(1), 271(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This assessee appeal in ITA No. 1371/Del/2026 was filed against an order dated 08.12.2025 of the Commissioner of Income Tax (Appeals)-25, New Delhi, arising out of an assessment order dated 04.03.2024 for Assessment Year 2014-15. The source preview records that the assessee had filed a return of income on 30.07.2014 declaring total income of Rs. 7,96,710/-, and that a search and seizure operation had been carried out at various premises of a third party and certain close associates; the appeal was adjudicated before Delhi "G" Bench and the full outcome on merits is not available in the source preview.

5. Deputy Commissioner Of Income Tax vs Maxxfun Buildmart Private Limited, New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 18 August 2026
Sections engaged: 132, 132A, 153A, 153A(1), 153C, 153C(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This Revenue appeal in ITA No. 2405/Del/2026 for Assessment Year 2010-11 was directed against an impugned order dated 24.11.2025 (noted in the source preview as wrongly mentioned as 06.03.2026 in Form-36) of the Commissioner of Income Tax (Appeals), Delhi, wherein the CIT(A) had allowed the assessee's appeal and annulled the assessment order dated 05.03.2024 passed under Sections 153C read with 153A of the Act in pursuance of a notice dated 29.06.2022, on the ground that the assessment for A.Y. 2010-11 was beyond the block period of 10 years. The full dispositional reasoning of the ITAT is not available in the source preview.

6. Rajiv Shamsherbahadur vs DCIT, Central Circle 20, Delhi, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 12 August 2026
Sections engaged: 132(4), 153A, 153A(1), 153C, 153C(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This assessee appeal in ITA 8430/DEL/2025 for Assessment Year 2010-11 was filed against an order of the DCIT, Central Circle 20, Delhi, dated 21.10.2025, arising out of the direction of the Dispute Resolution Panel dated 17.12.2022, passed under Section 153A read with other provisions of the Act. The appeal was heard before Delhi Benches "H" on 04.08.2026 and pronounced on 12.08.2026; the full substantive reasoning is not available in the source preview.

7. Ashok Kumar Sethi, I.P Extension, Delhi vs ACIT, Jhandewala Extension

Bench: Income Tax Appellate Tribunal - Delhi
Date: 29 July 2026
Sections engaged: 132, 132A, 148, 153A, 153A(1), 153C, 153C(1), 153C(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: This assessee appeal in ITA No. 4100/DEL/2026 for Assessment Year 2019-20 was filed against an order of the Commissioner of Income Tax (Appeals)-30, New Delhi, dated 13.03.2026, arising out of an assessment order dated 22.03.2024 passed under Section 153C of the Act. The source preview records that at the outset, counsel for the assessee invited the Bench's attention to a legal ground raised as an additional ground, whereby a challenge was made to the action of the Assessing Officer; the full nature of the additional ground and the outcome are not available in the source preview.

8. DCIT Central Circle 32, Delhi vs Excel Insurance Outsourcing Pvt. Ltd

Bench: Income Tax Appellate Tribunal - Delhi
Date: 10 June 2026
Sections engaged: 153C, 153A(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The Revenue filed two appeals in ITA Nos. 1355 & 1356/DEL/2026 before Delhi 'G' Bench against the order of the Principal Commissioner of Income Tax (Appeals)-25, New Delhi dated 10.10.2025, which arose from an assessment order dated 28.03.2024 under Section 153C read with Section 144 of the Act, pertaining to Assessment Years 2010-11 and 2011-12 respectively. The source preview confirms the two appeals were heard together; the full dispositional reasoning is not available in the source preview.

9. Assistant Commissioner Of Income-Tax vs Ms. Janani Exports, Mumbai

Bench: Income Tax Appellate Tribunal - Surat
Date: 31 July 2025
Sections engaged: 153A(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This set of appeals before ITAT Surat Bench involved multiple ITA and IT(SS)A numbers filed by both the Revenue (ACIT, Central Circle-2, Surat) and the assessee (M/s Janani Exports, PAN: AAEFJ3969P), covering Assessment Years 2013-14, 2014-15, 2015-16, 2016-17, 2017-18, 2018-19, and 2019-20 in various combinations. The appeals were heard in hybrid mode and the source preview does not disclose the substantive ground or final outcome of the proceedings.

10. M/S Ksj Infrastructure Pvt. Ltd vs ACIT, Central Circle-1(1), Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 27 September 2024
Sections engaged: 153C, 153A(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals in ITA Nos. 797 & 798/Chny/2024 for Assessment Years 2012-13 and 2013-14 were heard before Chennai 'B' Bench. The source preview contains a computation of the six-year (and extended ten-year) block period as provided under Section 153C of the Act, showing that Assessment Years 2012-13 and 2013-14 fell within the applicable count; the full substantive reasoning and outcome are not available in the source preview.

11. Mihir Subodhbhai Shah, Ahmedabad vs The ACIT, Central Circle-1(2)

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 19 April 2023
Sections engaged: 143(3), 153A(1), 69
Outcome: Outcome not specified in source
Procedural / substantive ground: Multiple appeals were filed before ITAT Ahmedabad by both the Revenue and the assessee, covering Assessment Years 2011-12, 2013-14, 2014-15, and 2015-16 across IT(SS)A Nos. 52-53 & 46-47/AHD/2021 and ITA Nos. 61 & 86/AHD/2021 (PAN: AGSPS7541N). The source preview references figures reflecting payments and receipts across Assessment Years 2013-14, 2014-15, and 2015-16, with a note that the Assessing Officer made additions of unaccounted receipts; the full reasoning and outcome are not available in the source preview.

12. Mahavir Ashok Enterprises (P) Ltd vs D.C.I.T. Central Circle, Raipur

Bench: Income Tax Appellate Tribunal - Raipur
Date: 29 August 2022
Sections engaged: 153A(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This set of seven cross-appeals (ITA Nos. 331 to 337/RPR/2014 filed by the Revenue and CO Nos. 101 to 107/RPR/2015 filed by the assessee) covered Assessment Years 2006-07 through 2012-13 for Mahavir Ashok Enterprises Pvt. Ltd. (PAN: AABCM5742M). The source preview references additions relating to advance for land in A.Y. 2011-12 (Rs. 45,00,000), stock and cash in A.Y. 2012-13, and share capital money received in A.Y. 2006-07 and A.Y. 2008-09; the full dispositional reasoning of the Tribunal is not available in the source preview.

Patterns across these 12 rulings

Section 153C co-engagement is near-universal. Ten of the twelve rulings engage Section 153C alongside Section 153A(1), underscoring that search-triggered assessments in this corpus are frequently invoked against persons other than the directly searched entity, making the interplay between these two provisions the central procedural battleground.
Block-period computation is a recurring live issue. In at least two rulings (Cases 5 and 10), the source previews explicitly reference computation of the applicable block period — whether six years or ten years — as a determinative or prominently argued point, with Case 5 noting that the CIT(A) had annulled the assessment on the ground that the year under appeal was beyond the 10-year block period.
Multi-year, multi-entity, consolidated hearings are common. Several rulings (Cases 1, 9, 12) involve multiple Assessment Years bundled across related entities or the same PAN, reflecting the structural feature of Section 153A that requires assessment of each year within the block, and creating consolidated appeals with numerous ITA numbers.
Delay-in-filing issues arise at the appellate stage. Case 2 illustrates that procedural defects — specifically, time-barred appeals — are identified and addressed at the ITAT registry stage before the merits are reached, with the Revenue required to justify the delay with reasonable cause.
Geographic spread reflects PAN-India applicability. The twelve rulings span six ITAT benches (Mumbai, Delhi, Surat, Chennai, Ahmedabad, and Raipur), confirming that Section 153A(1) and Section 153C disputes are litigated uniformly across jurisdictions and are not concentrated in any single bench.

How to use this compilation

This page is a structured starting point for locating primary source material, not a substitute for reading the full judgments. Every entry in this index should be treated as a pointer to a primary source. Before placing any reliance on a ruling for legal, compliance, or advisory purposes, the researcher should obtain and read the complete order — including the full reasoning, any dissent, and the operative directions — from the original court portal, indiankanoon.org, or the relevant ITAT's official record. Outcome summaries in this index are limited to what appears in the source preview and the structured outcome field; where the source preview is procedural or truncated, the entry says so explicitly.

Researchers should also verify whether any ruling listed here has been the subject of a stay, an appeal to the High Court or Supreme Court, or a subsequent reversal or modification. ITAT orders are routinely challenged under Section 260A before High Courts and may be stayed or set aside. A ruling that was decided against the Revenue at ITAT level may be under contest, or vice versa, and this index does not track post-ITAT litigation history.

Finally, Section 153A(1) and Section 153C are sections whose operative scope has been shaped by Finance Act amendments (including those introduced by the Finance Act, 2021 and Finance Act, 2022), CBDT notifications, and the evolving body of High Court precedent. Researchers should cross-reference applicable CBDT instructions, relevant High Court precedents for the jurisdiction in question, and the version of the statute applicable to the Assessment Year in dispute before drawing conclusions about the legal position in any specific case.

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 153A(1) & 153C Search Assessments: 12 ITAT Rulings (2022–2026)