Shanmugasundaram Manoharan Vs DCIT (ITAT Chennai)
The Chennai Bench of the Income Tax Appellate Tribunal adjudicated four appeals concerning Assessment Years 2015-16, 2016-17, 2017-18 and 2018-19. The assessee preferred ITA Nos. 1607, 1608 and 1609/Chny/2025, while the Revenue preferred ITA No. 1648/Chny/2025. The appeals arose from different orders of the CIT(A), NFAC, Delhi, all dated 14.08.2025.
The assessee, an individual engaged in the restaurant business under the name and style of M/s. MuruganIdli Shop, had originally filed his return for the relevant period declaring total income of Rs. 2,28,59,370/-. His case had earlier been scrutinised, and proceedings under Section 153C were subsequently initiated following a search and seizure operation conducted on 05.02.2020 in the case of Shri G. N. Anbuchezian and others.
During the search, various materials concerning cash transactions were seized. The material was found to contain details of transactions between the assessee and Shri G. N. Anbuchezian. The assessee’s case was thereafter centralised through notification dated 15.03.2022. A satisfaction note was recorded stating that the seized materials pertained to the assessee and had a bearing on determination of his total income. Notices under Section 153C were issued to the assessee on 08.09.2022 for A.Ys. 2014-15 to 2020-21.
Before the Tribunal, the assessee raised a jurisdictional challenge, primarily contending that the Section 153C notices issued on 08.09.2022 did not comply with Section 153C(3). The assessee relied upon the judgment of the jurisdictional Madras High Court in Harigovind vs. Assistant Commissioner of Income-tax Non-corporate.
