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6262, 6264 & 6265/Del/2025 Saroj Gupta (AY: 2017-18, 2018-19 & 2020-21)

,IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, DELHI

BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER &

SHRI MANISH AGARWAL, ACCOUNTANT MEMBER

ITA Nos. 6262, 6264 & 6265/Del/2025 (Assessment Years: 2017-18, 2018-19 & 2020-21)

Saroj Gupta Vs. DCIT, CC-27 C-115, Mahendra Enclave, Room No. 348, ARA

Delhi – 110033 Centre, JhandewalanExtn New Delhi – 110055

(cid:1)थायीलेखासं./जीआइआरसं./PAN/GIR No: AAHPG7894D Appellant .. Respondent

Appellant by : Sh. Sumit Lalchandani, Adv.

Sh. Shivam Yadav, Adv.

Ms. Ananya Kapoor, Adv.

Respondent by : Sh. Jitender Singh, CIT, DR Date of Hearing 18.02.2026 Date of Pronouncement 25.03.2026

O R D E R

PER ANUBHAV SHARMA, JM:

These are appeals preferred by the Assesseeagainst the orders of the

Ld. Commissioner of Income-tax (Appeals) (hereinafter referred to as the First Appellate Authority or ‘the ld. FAA’ for short) in appeals filed before

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6262, 6264 & 6265/Del/2025 Saroj Gupta (AY: 2017-18, 2018-19 & 2020-21)

him against the orders of the ld. Assessing Officer (hereinafter referred to as the Ld. AO, for short) passed u/s 153A/153C of the Income-tax Act, 1961 (hereafter referred to as ‘the Act’). Further details of the orders of the lower

authorities are as under:-

2. These cases were heard together as the assessee had raised common

question of law and the background giving rise to the same question of law. A search and seizure operation was carried out in the Alankit Group of cases on 18.10.2019. Subsequently, the said group of cases were centralized for assessment and during the course of assessment proceedings of the Alankit Group material/documents allegedly relating to cases of present assessee

were found.

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6262, 6264 & 6265/Del/2025 Saroj Gupta (AY: 2017-18, 2018-19 & 2020-21)

3. The facts relevant to AY 2017-18 are material as allegedly in the case of assessee some incriminating documents are found from the premises in the form of hard data as well as digital data. Statements were also recorded and it was alleged that assessee had received Rs.10,60,707/- from Alankit Assignment Limited. during the Financial Year 2016-17 relevant to AY: 2017-18 the conclusion was that bogus LTCG claim was raised with respect

to sale of shares of Alankit Assignments Ltd.

4. Now before us ld. Counsel has submitted that assumption of jurisdiction on the basis of the satisfaction note recorded u/s 153C is not valid as for the purpose of Section 153C there is no mention about the fact as to how the seized material had bearing on the income of the assessee for the

each year under consideration.

5. Ld. DR has defended the same by submitting that in the satisfaction note there is specific mention of the seized evidences and the nature of transactions but what we notice is that satisfaction note records about a laptop of Shri Sunil Kumar Gupta being found and seized from his residencewith some transaction unearthed concerning assessee for Financial Year 2015-16 only. However, satisfaction note has been recorded cumulatively for AY:

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6262, 6264 & 6265/Del/2025 Saroj Gupta (AY: 2017-18, 2018-19 & 2020-21)

2014-15 to 2020-21. As for completeness we consider it necessary to

reproduce the satisfaction note:

“1. A search and seizure operation was carried out in the Alankit Group of cases on

18.10.2019 subsequently the said group was centralized to the jurisdiction of the undersigned.Accordingly, during the course of assessment proceedings u/s 153A of Alankit Group, material/ documents related to case of Saroj Gupta have been

found.

2. The same is being corroborated from the ledger of HDFC Bank in the books of Diwakar obtained from laptop of Sh. Sunil Kumar Gupta found and seized from the residence of Sh. Sunil Kumar Gupta, at 3584/4, Narang Colony, Gali No. 4 Tri Nagar Delhi (Path: F:ISKGRA-32\SUNIL KUMAR GUPTA HP LAPTOPIEXTRACTED DATA Tally\[root].1\Local Disk\OFFICE TALLY\2014-

2015 DCPL CASE AY1213.

3. The tran