DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7838/DEL/2025Status: DisposedITAT Delhi20 March 2026AY 2018-1976 pages
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What did the Tribunal hold?

The Tribunal noted that statements recorded under Section 132(4) have evidentiary value, but acknowledged the possibility of pressure and the need for corroborative evidence, especially when statements are retracted. The Tribunal considered the CIT(A)'s partial deletion of additions based on the availability of documentary evidence.

What were the facts?

The Assessing Officer disallowed the assessee's entire purchases of ₹8,86,36,574/- and added ₹40,18,132/- as unexplained money. The CIT(A) partly upheld the purchase disallowance to ₹13,52,382/- and deleted the unexplained money addition.

What were the issues?

The primary issue was the validity of additions made solely on the basis of statements recorded during a search, particularly when those statements were later retracted. The Tribunal also considered the evidentiary value of such statements and the requirement for corroborative evidence.

Which sections of the Income-tax Act were involved?

Section 37(1),Section 69A,Section 132(4)

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Income Tax Appellate Tribunal, DELHI BENCH F: NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI NAVEEN CHANDRA

For Appellant: Shri Amit Goel, Shri Pranav Yadav, Advocates
For Respondent: Ms. Monika Singh, CIT-DR
Hearing: 24.02.2026Pronounced: 20.03.2026

PER BENCH These assessee's and the Revenue's seven cross-appeals each i.e., ITA Nos.5515 to 5521/Del/2025 and ITA Nos.7838 to 7844/Del/2025 for assessment years 2018-19 to 2024-25, arise against the CIT(A)-24, New Delhi orders; all dated 1st September, 2025, in proceedings under Section 147 read with Section 143(3) of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act'), as the case may be, respectively.

2.

Heard both the parties. Case files perused.

3.

We advert to the “lead” assessment year 2018-1

The order continues below.

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