SKANDA INFRA PROJECTS INDIA PRIVATE LIMITED,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

ITA 515/HYD/2025Status: DisposedITAT Hyderabad20 August 2025AY 2020-21106 pages
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What did the Tribunal hold?

The Tribunal held that the presumption of truth under Section 132(4A) and 292C of the Income Tax Act applies to all entries in seized material, both receipts and expenditures. Cherry-picking favorable data by the AO is not permissible, and a holistic view of the seized material must be taken.

What were the facts?

A search and seizure operation was conducted on the assessee and its group concerns, leading to the seizure of various materials including loose sheets and electronic data. The Assessing Officer (AO) quantified suppressed sales turnover and estimated income based on seized material, while the assessee argued the seized documents were unreliable and lacked corroboration.

What were the issues?

Whether the presumption of truth under Section 132(4A) and 292C applies to all entries in seized material, and whether the AO can selectively use favorable entries while disregarding others.

Which sections of the Income-tax Act were involved?

Section 132(4A),Section 292C

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Cases cited in this judgment(6)Show list

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IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD “B” BENCH: HYDERABAD BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI MANJUNATHA G, ACCOUNTANT MEMBER

Sl. No. I.T.A.No. Name of Appellant Name of Respondent A.Y. Appealed against the Order of the CIT(A)-12, Hyderabad Dated 1. 514/Hyd./2025 Skanda Infra Projects India Private Limited, KURNOOL. PIN – 518 002 Andhra Pradesh PAN AAOCS8382G The ACIT, Central Circle 2(3), HYDERABAD. PIN – 500 004 2019-20 26.12.2024 2. 515/Hyd./2025 2020-21 26.12.2024 3. 516/Hyd./2025 2021-22 06.01.2025 4. 517/Hyd./2025 2022-23 26.12.2024 5. 518/Hyd./2025 Skandhanshi Infra Projects India Private Limited, KURNOOL. PIN – 518 002 Andhra Pradesh PAN AAWCS0746E The ACIT, Central Circle 2(3), HYDERABAD. PIN – 500 004 2019-20 26.12.2024 6. 519/Hyd./2025 2020-21 Appeal No.CIT(A), 019-20 dated NIL 7. 520/Hyd./2025 2021-22 Dated 26.12.2024 8. 521/Hyd./2025 2022-23 26.12.2024 9. 308/Hyd./2025 The ACIT, Central Circle-2(3), HYDERABAD. PIN – 500 004 Skandhanshi Infra Projects India Private Limited, KURNOOL. PIN – 518 002 Andhra Pradesh PAN AAWCS0746E 2019-20 26.12.2024 10. 309/Hyd./2025 2020-21 Appeal No.CIT(A), 019-20 dated NI

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