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ITAT Invalidates Section 153C Invocation: Distinction Between “Belonging” & “Pertaining/Relating” Proved Crucial

Case Law Details

Case Name
Rachita Sahgal Vs ACIT (ITAT Delhi)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2018-19
Advertisement Rachita Sahgal Vs ACIT (ITAT Delhi) Income Tax Appellate Tribunal (ITAT) Delhi has quashed tax additions totaling ₹42.94 lakh each against a couple, Rachita Sahgal and Vivek Sahgal, citing an invalid “satisfaction” recorded under Section 153C of the Income Tax Act, 1961. The ruling, delivered on February 7, 2025, highlights a critical distinction between seized material “belonging” to an assessee and merely “pertaining” or “relating” to them. The case originated from a search action conducted on January 3, 2018, against the M/s...
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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 18,778

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