This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) rulings — eleven from the Delhi bench and one from the Chennai bench — all pronounced between 31 July 2026 and 21 August 2026, in which proceedings under Section 153C(1) of the Income-tax Act, 1961 were before the Tribunal. The appeals arise from a range of search and seizure contexts and raise recurring questions about the assumption of jurisdiction under Section 153C, the satisfaction of procedural prerequisites, and the validity of assessment orders framed under that provision. This index is intended for use by in-house tax teams, Big-4 associates, and law-firm researchers who need a structured entry point into this body of recent ITAT jurisprudence.

Research index only — not legal advice. This page is a structured case-law reference compiled for research purposes. Nothing on this page constitutes legal, tax, or professional advice. Readers must consult the full text of each judgment and verify currency before relying on any ruling.

The statutory framework in one paragraph

Section 153C of the Income-tax Act, 1961 provides a mechanism for the assessment of income of a person other than the searched person where, during a search conducted under Section 132 or a requisition under Section 132A, books of account, documents, or assets belonging to or pertaining to such other person are found. Sub-section (1) of Section 153C requires the Assessing Officer of the searched person to record satisfaction and transmit the relevant material to the Assessing Officer having jurisdiction over the other person, who must then issue notice and frame assessment in the manner prescribed under Section 153A. The provision is subject to conditions relating to the relevance of the seized material to the years being assessed, the block period applicable, and the procedural requirements of satisfaction-note recording and notice issuance — all of which have been the subject of extensive litigation before the ITAT.

The 12 rulings

1. 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 against the orders of the Commissioner of Income Tax (Appeals)-25, New Delhi, for assessment years 2014-15 and 2015-16, involving proceedings under Section 153C of the Act. The two appeals raised identical issues and were heard together and disposed of by a common order, with ITA No. 79/Del/2026 (AY 2014-15) treated as the lead case; the assessee (Shiv Kumar HUF, PAN: AASHS3664Q) had filed the original return of income on 17.07.2014.

2. 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 appeal (ITA No. 1371/Del/2026) was filed by the assessee against the order dated 08.12.2025 of CIT(A)-25, New Delhi, arising out of an assessment order dated 04.03.2024 passed under Section 153C of the Act for Assessment Year 2014-15; the assessee (PAN: AKWPG7039B) had filed his return of income on 30.07.2014 declaring total income of Rs. 7,96,710/-. A search and seizure operation was carried out at various premises of Shri Alok Kumar Agarwal, his son Ankit Agarwal, and some of their close associates, following which proceedings under Section 153C were initiated against the appellant.

3. Anant Associates Private vs Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Delhi
Date: 19 August 2026
Sections engaged: 153A, 153C, 153C(1), 153C(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 3214/Del/2026) was filed by the assessee against the order dated 28.01.2026 of CIT(A)-30, New Delhi, arising out of an assessment order dated 19.03.2025 passed under Section 153C of the Act for Assessment Year 2019-20; the assessee (Anant Associates Private Limited, PAN: AABCA0653K) had e-filed its return of income on 01.10.2019 declaring total income of Rs. 54,45,640/-. A search and seizure operation under Section 132 of the Act was carried out at the premises of Shri Sanjay Jain, Girdhari Lal Constructions Pvt. Ltd., Inderjit Mehta Constructions, and others, leading to the initiation of proceedings against the appellant under Section 153C.

4. Radico Khaitan Limited, Rampur vs Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Delhi
Date: 19 August 2026
Sections engaged: 132, 143(3), 148, 153, 153A, 153C, 153C(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 2890/Del/2026) for Assessment Year 2020-21 involved, as its first legal issue, the question of whether the CIT(A) was correct in confirming the Assessing Officer's assumption of jurisdiction under Section 153C of the Act; the primary jurisdictional question was whether the notice issued under Section 153C dated 29.03.2023 complied with the requirements prescribed under that provision. A search under Section 132 of the Act was conducted on 27.02.2020 at various premises of the Raipur Group, Tuteja Group, Bhatia Group, and Dhand Group of cases, during which various papers, documents, digital data, and incriminating material were found.

5. M/S Sumaja Electroinfra Pvt. Ltd, Delhi vs DCIT (Cc)-28, New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 19 August 2026
Sections engaged: 132, 143(3), 148, 153, 153C, 153C(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: Four appeals (ITA Nos. 6201 to 6204/Del/2025) were filed by the assessee against separate orders of CIT(A)-25, New Delhi, for assessment years 2013-14 to 2015-16; the appeals involved similar and identical issues and were heard together and disposed of by a common order, with ITA No. 6201/Del/2025 (AY 2013-14) taken as the lead case. The assessee (Sumaja Electroinfra Pvt. Ltd., PAN: AAKCS3079C) raised common additional grounds on jurisdiction, referring to the NTPC decision, challenging the assumption of jurisdiction under Section 153C of the Act.

6. I Home And Infrastructure Private vs Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Delhi
Date: 19 August 2026
Sections engaged: 132, 132A, 147, 153, 153C, 153C(1), 153C(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: Three appeals (I.T.A. Nos. 1913 to 1915/Del/2026) for assessment years 2014-15 to 2016-17 were disposed of by a common order; the preliminary issue before the Tribunal was whether the Assessing Officer was justified in validly assuming jurisdiction for the assessment years 2014-15 and 2015-16 in the facts and circumstances of the case. A search and seizure operation under Section 132 of the Act was carried out on the Alankit group on 18.10.2019, wherein certain documents pertaining to the appellant were found, forming the basis for the Section 153C proceedings.

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

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 appeal (ITA No. 2405/Del/2026) for Assessment Year 2010-11 was filed by the Revenue against the order dated 24.11.2025 (wrongly mentioned as 06.03.2026 in Form-36) of CIT(A), Delhi, wherein the CIT(A) had allowed the assessee's appeal and annulled the assessment order dated 05.03.2024 passed under Section 153C read with Section 153A of the Act, in pursuance of a notice dated 29.06.2022 for AY 2010-11, on the ground that the assessment was beyond the block period of 10 years. Any delay in filing the Revenue's appeal was condoned by the Tribunal per the source preview.

8. B H Trading Co, Delhi vs DCIT, Central Circle-29, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 14 August 2026
Sections engaged: 132, 143(3), 148, 153, 153A, 153C, 153C(1), 153C(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two appeals (ITA No. 3601/DEL/2025 for B.H. Trading, PAN: AAAFN2870P, and ITA No. 3602/DEL/2025 for Baboo Ram Hari Chand, PAN: AAAFN2868D, both for AY 2020-21) were before the Tribunal; the assessee's counsel argued that CIT(A) erred in confirming the Assessing Officer's assumption of jurisdiction for framing assessment under Section 153C of the Act, which was alleged to be bad in law, illegal, and against the facts and circumstances of the case. A search operation was conducted on Shri Sushil Goel and group on 30.01.2020, during which Shri Sushil Goel and his family were found involved in the business of sale and purchase of foreign currency, leading to proceedings under Section 153C against the appellants.

9. 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 appeal (ITA 8430/DEL/2025) for Assessment Year 2010-11 was filed by the assessee (PAN: BBHPS4880H) against the order of DCIT, Central Circle 20, Delhi, dated 21.10.2025, which arose out of the direction of the Dispute Resolution Panel dated 17.12.2022, passed under Section 153A read with Sections 144C(13) and 144 of the Act. The appeal is procedurally rooted in Section 153A proceedings with Section 153C(1) also engaged, and the source preview indicates the matter proceeded through the DRP mechanism before reaching the Tribunal.

10. Polylab Industries Private vs DCIT, Cc-28, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 12 August 2026
Sections engaged: 132, 132A, 153A, 153C, 153C(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: Five appeals (ITA Nos. 4176, 4177, 4178, 4179, and 4180/DEL/2026) for Assessment Years 2014-15 to 2018-19 were filed by the assessee (Polylab Industries Private Limited, PAN: AADCC3050A) against a common order dated 18.08.2025 of CIT(A)-25, New Delhi, arising out of assessment orders all dated 26.03.2023 passed by DCIT/ACIT, Central Circle-28, New Delhi, under Section 153C of the Act. The five appeals were heard together and disposed of by a common order per the source preview.

11. Chhothamal Parasmal Chennai, Chennai vs DCIT, Central Circle-3(4), Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 11 August 2026
Sections engaged: 153C, 153C(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 4050/Chny/2025) for Assessment Year 2017-18 was preferred by the assessee (PAN: AADPJ8270C) against the order of CIT(A), Chennai-20, dated 17.11.2025, arising from an assessment order dated 08.03.2025 passed by the Deputy Commissioner of Income-tax, Central Circle 3(4), Chennai, under Section 153C of the Act. The appeal is the sole ruling in this compilation from the ITAT Chennai bench, with the substantive issues under Section 153C(1) not further elaborated in the available source preview.

12. Sumitra Devi, Jind vs DCIT, Cc, Karnal

Bench: Income Tax Appellate Tribunal - Delhi
Date: 31 July 2026
Sections engaged: 153C, 153C(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 3301/Del/2026) for Assessment Year 2017-18 was filed by the assessee (PAN: AARPD0958R) against the order dated 13.01.2026 of CIT(A)-3, Gurgaon, involving proceedings under Section 153C of the Act. The assessee's primary legal ground sought to reverse findings by both lower authorities that treated her unsecured loans of Rs. 19,42,500/- as unexplained money in the assessment order dated 27.12.2019, which was upheld in the lower appellate order.

Patterns across these 12 rulings

Jurisdiction under Section 153C is the dominant battleground. Across multiple cases in this set — including the Radico Khaitan, B H Trading, I Home And Infrastructure, and Sumaja Electroinfra matters — the central issue before the Tribunal was whether the Assessing Officer validly assumed jurisdiction under Section 153C(1). This suggests that challenges to the jurisdictional foundation of Section 153C assessments remain among the most frequently litigated grounds at the ITAT level in 2026.
Block period limits are actively contested. In the Maxxfun Buildmart matter (Case 7), the CIT(A) had annulled the assessment order on the ground that the notice under Section 153C was issued beyond the applicable block period of 10 years for AY 2010-11. The Revenue's appeal against that annulment indicates that the temporal limits of the Section 153C block period continue to generate litigation.
Batch and common-order disposal is prevalent. Multiple cases in this compilation — including Sumaja Electroinfra (4 appeals), I Home And Infrastructure (3 appeals), and Polylab Industries (5 appeals) — were heard together and disposed of by common orders. This procedural pattern reflects the Tribunal's practice of consolidating appeals involving identical issues or the same assessee across multiple assessment years, which is itself a recurring feature of Section 153C litigation given that the provision operates across a block of years.
Third-party search triggers are a common factual backdrop. In cases such as Vaibhav Garg (search on Alok Kumar Agarwal group), Anant Associates (search on Sanjay Jain and related entities), I Home And Infrastructure (search on Alankit group), and B H Trading (search on Sushil Goel and group), the Section 153C proceedings were initiated against the appellants not as the searched persons themselves but as third parties in whose premises or records material was allegedly found during searches on other entities. This underscores the derivative nature of Section 153C jurisdiction.
Outcome data is uniformly unavailable in the source corpus for this batch. All twelve rulings carry the designation "Outcome not specified in source," which reflects the limitations of the available text previews rather than any substantive pattern. Researchers should access the full text of each order to determine the Tribunal's operative directions.

How to use this compilation

This index is designed as a first-pass research tool. Each case entry identifies the parties, bench, date, sections engaged, and the procedural or substantive ground visible from the available source material. Researchers should treat these summaries as orientation points, not as substitutes for reading the full judgment. The text previews on which the prose paragraphs are based are excerpts only; the Tribunal's actual reasoning, operative findings, and dispositive directions are contained in the complete order, which should be obtained from indiankanoon.org, the ITAT's official portal, or a primary legal database before any reliance is placed on a ruling.

Before citing any of these rulings in submissions, opinions, or advisory work, researchers should verify: (a) whether the order has been appealed further to a High Court or the Supreme Court; (b) whether any stay has been granted against the order; (c) whether the ruling has been distinguished, followed, or overruled in subsequent ITAT or higher-court decisions; and (d) whether CBDT has issued any circular, instruction, or notification that may affect the legal position addressed in the ruling. Tax litigation is fact-specific, and the applicability of any ruling to a different set of facts requires careful analysis of the distinctions.

Researchers working on Section 153C matters should also cross-reference the relevant CBDT instructions on the conduct of search assessments, the Supreme Court's jurisprudence on satisfaction-note requirements, and the applicable Finance Act amendments that have altered the block period and procedural requirements under Sections 153A and 153C over successive years. This compilation covers rulings pronounced in July and August 2026 only; earlier rulings on the same provision may be equally or more relevant depending on the assessment year and factual context under examination.

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(1) Jurisdiction Disputes: 12 ITAT Rulings (July–August 2026)