SC upholds HC ruling that Section 153C notices invalid without incriminating material for specific assessment years The SC dismissed a special leave petition challenging an HC judgment that allowed the assessee's appeal regarding notices issued under Section 153C. The ...
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
SC upholds HC ruling that Section 153C notices invalid without incriminating material for specific assessment years
The SC dismissed a special leave petition challenging an HC judgment that allowed the assessee's appeal regarding notices issued under Section 153C. The HC held that the jurisdictional AO's satisfaction note failed to refer to any incriminating material for the relevant assessment years, making it evident that no such material existed. The court ruled that the AO must first be satisfied that received material likely impacts total income of specific years within the block period before issuing notices under Section 153C. Without material casting doubt on income estimation, the AO cannot justify invoking Section 153C powers.
The Supreme Court, in a partial bench comprising Hon'ble Mr. Justice Rajesh Bindal and Hon'ble Mr. Justice R. Mahadevan, heard the Special Leave Petition (SLP) against a common impugned judgment of the High Court. The Court "condoned delay" but noted that a similar batch of petitions had already been dismissed by this Court's order dated 16.05.2025 (SLP(C) Diary No. 18596 of 2025). Consequently, the present Special Leave Petition was "dismissed," and all pending applications were disposed of.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
