JAYARAMA REDDY BOOPESH REDDY,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRLCE-2(4), BENGALURU

ITA 705/BANG/2025Status: DisposedITAT Bangalore09 October 2025AY 2013-1436 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the assessee's admission in the statement recorded under section 132(4) has evidentiary value and shifts the burden of proof. The assessee failed to provide concrete evidence that the luxury cars were primarily and substantially used for business purposes.

What were the facts?

During a search, the assessee, a proprietor of a construction business, claimed expenses and depreciation on luxury cars. The assessee initially admitted in a statement that these cars were used for both business and personal purposes and offered a disallowance. Later, the assessee argued the cars were used for business branding and promotion.

What were the issues?

Whether expenses and depreciation on luxury cars are allowable when the assessee's use is primarily for business promotion and branding, and the evidentiary value of a statement made under section 132(4).

Which sections of the Income-tax Act were involved?

Section 132(4),Section 131,Section 32,Section 37,Section 143(3),Section 153A

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Income Tax Appellate Tribunal, A BENCH, BANGALORE

Before: SHRI NARENDER KUMAR CHODHRY & SHRI WASEEM AHMED

For Appellant: Shri Bharat, CA
For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Hearing: 07.08.2025Pronounced: 09.10.2025

PER BENCH : All these appeals are filed by the assessee against the order passed by the CIT(A) – 15 Bengaluru vide order dated 31/01/2025 for the assessment years 2013-14, 2014-15, 2015-16, 2016-17, 2018-19, 2020 -21 & 2021-22. 2. First, we take up ITA No. 705/Bang/2025, an appeal by the assessee for A.Y. 2013-14 as a lead case. ITA No.705 - 711/Bang/2025 3. The assessee in the memo of appeal has raised 9 grounds of appeal which are adjudicated here under.

4.

The Ground No. 1 of the assessee's appeal is general in nature which does not require any separate a

The order continues below.

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