SANJAY BHASKAR,NEW DELHI vs. DCIT CENTRAL CIR 13 , NEW DELHI

ITA 1654/DEL/2024Status: DisposedITAT Delhi30 December 2025AY 2019-2029 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that a statement recorded under Section 132(4) of the Income Tax Act, 1961, cannot solely form the basis for an addition without corroborative material. Retracted statements, without supporting evidence, are insufficient to sustain additions.

What were the facts?

During a search operation, the assessee's residential status was questioned. The assessee claimed to be a non-resident, but the Assessing Officer (AO) determined them to be a resident based on their stay in India. The CIT(A) upheld the AO's decision.

What were the issues?

Whether a retracted statement recorded under Section 132(4) can be the sole basis for making an addition to income, and whether the assessee's residential status was correctly determined.

Which sections of the Income-tax Act were involved?

Section 132(4),Section 6(1)(c)

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Cases cited in this judgment(12)Show list

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Income Tax Appellate Tribunal, DELHI “G” BENCH: NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWAL

For Appellant: Shri Ankit Kumar, Adv
For Respondent: Ms. Rupinder Kaur, CIT DR
Hearing: 17.11.2025Pronounced: 30.12.2025

PER MANISH AGARWAL, AM : The captioned appeals are filed by assessee against the different orders of Ld. CIT(A)-26, New Delhi u/s 250 of the Income Tax Act, 1961 [“the Act”] all are dt. 21.03.2024 arising out of different assessment orders for various assessment years tabulated as below: ITA Nos. Sr. Asstt. Assessment Assessment Order Nos. Order dated under section Year 1 18.04.2022 2017-18 153A r.w.s. 143(3) of the Income Tax Act, 1961. 2. 18.04.2022 - do - 2018-19 3. 18.04.2022 - do - 2019-20 4. 2020-21 06.05.2022 - do -

2.

The issues in all these appeals being common, interlinked and related to the same assessee for v

The order continues below.

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