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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)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2018-19
- Courts
- All ITAT, ITAT Delhi
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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...





