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Judgment
These assessee’s fo ur appe als ITA Nos. 8041 to 8044/Del/2025 for Assessment Years 2014-15, 2 015-16, 2018-19 & 2019-20 , arise against the CIT(A)-25, New Delhi’s DIN & order Nos. ITBA/APL/M/250/2025-26/1082256595(1), 1082254321(1), 1082254831(1) & 1082255 262(1) dated 03.11.2025, in proceedings u/s 147 r.w.s. 144 r.w.s. 144B and 153C of the Income Tax Act, 1961 (in short “the Act”), respectively.
Heard both the parties at length. Case files perused.
It transpires at the outset that the asse ssee/appellant raises his first and foremost legal arguments/ground challenging validity of all the se section 153C r.w.s. 143(3) assessments dated 28.03.2022 framed by the learned Assessing Officer for the precise reason that the latter’s corresponding satisfaction no te(s) do not satisfy the test of law.
There is hardly any dispute between the parties that the learned depar tmental authorities had carried out the search in issue dated 18.10.2019 in M/s Alankit Group o f cases. That being the case, learned counsel has invited our attention to the Assessing Officer’s section 153C satisfaction recorde d on 24.06.2022 in the assessee’s case(s) nowhere indicating as to whether the corresponding seized material belonged or pertained or related to the assessee; or it had a “bearing” on deter mination of the to tal income forming a condition precedent going by PCIT vs. Ojjus Medicare Pvt. Ltd. & (2 024) 465 ITR 101 (Delhi), PCIT vs. Jasjit Singh (2024 ) 336 CTR 634 (Delhi), CIT Vs. RRJ Securities Ltd. (2016) 380 ITR 0612 and Saksham Commodities L td. vs. ITO (2024 ) 464 ITR 1.
Faced with this situation, learned CIT-DR vehemently argues that the impugned satisfaction note has rightly been recorded strictly in tune with section 153C of the Act wherein it is nowhere mandatory to incorporate the clinching statutory expression “bearing” therein.
We are afraid that the Revenue’s veheme nt contentions hardly deserves to be accepted since going against hon’ble jurisdictional aforesaid landmark decisio ns already settling the issue in assessee’s favour and against the department. We thus conclude in this factual backdrop that both the impugned section 153C satisfactions as well as assessments before us forming subje ct matter of adjudication herein are non-est in very terms. Q uashed accordingly.
All other remaining pleadings between the parties stand rendered academic.
These assessee’s four appeals ITA Nos. 8041 to 8044/Del/2025 are allowed. A copy of this common order be place d in the respective case files.