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

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 Navneet Dawar gr...