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

ITA 706/BANG/2025Status: DisposedITAT Bangalore09 October 2025AY 2014-1536 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the voluntary admission made by the assessee under Section 132(4) of the Income Tax Act, 1961, carries significant evidentiary value and cannot be easily retracted. The AO's disallowance based on this admission was upheld.

What were the facts?

The assessee claimed expenses and depreciation on luxury cars, later offering a voluntary disallowance of over ₹5.46 crores during search proceedings. The assessee argued these cars were used for business branding and promotion, not personal use, and that the statement was given under stress without verification.

What were the issues?

Whether a voluntary admission made during search proceedings under Section 132(4) can be the sole basis for disallowing expenses and depreciation on luxury cars, even if the assessee later attempts to retract it.

Which sections of the Income-tax Act were involved?

Section 132(4),Section 131,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.

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 adjudication. Hence the same is being dis

The order continues below.

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