Pankajkumar Kanaiyalal Soni Vs ITO (Gujarat High Court)
The Gujarat High Court heard a petition under Article 226 of the Constitution challenging the notice dated 09.07.2021 issued under Section 153C of the Income-tax Act, 1961 for Assessment Year (AY) 2010-11, the assessment order dated 20.02.2026 passed under Sections 144, 153C and 250 of the Act, and the consequential demand notice issued under Section 156.
The petitioner stated that a search under Section 132 of the Act was conducted on 06.03.2018 in the case of third parties. During the search, digital data allegedly revealed that the petitioner had purchased a unit in the project “Satyam Sentossa Greenland Phase A-B,” registered on 31.12.2009 for Rs. 89,01,000/-, out of which Rs. 63,50,000/- was alleged to have been paid in cash. Satisfaction notes were recorded by the Assessing Officer of the searched person as well as by the petitioner’s Assessing Officer, stating that the seized digital data had a bearing on determination of the petitioner’s income for AY 2010-11.
The petitioner filed objections on 12.01.2026 challenging the initiation of proceedings under Section 153C and requested that they be dropped. The objections were rejected by order dated 02.02.2026. Thereafter, the Assessing Officer completed the assessment on 20.02.2026, making an addition of Rs. 63,50,000/- and raising a demand of Rs. 70,52,650/-. The petitioner challenged the proceedings principally on the ground of limitation.
