2) In Om Parkash Jindal v. Union of India

104 ITR 389High Court1976#5641 most cited

What is 2) In Om Parkash Jindal v. Union of India authority for?

A restraint order under Section 132(3) of the Income Tax Act, 1961 can only be issued if the authorised officer reasonably believes that the property represents undisclosed income, and seizure is impracticable due to the nature, location, or peculiar circumstances of the property. It cannot be used to avoid seizure until statements under Section 132(4) are verified.

20

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2023 to 2025.

Also referred to as

Om Parkash Jindal v Union of India · 104 ITR 389 · section 132(3) · restraint order · search and seizure · undisclosed property · impracticability of seizure · authorised officer

Sections most often in play

Section 153BSection 115BBESection 132(3)Section 132(8A)Section 153ASection 68Section 69CSection 250

Issues it is cited on

section 132(5)section 132(3)section 132(2)section 65(b)section 65asection 158besection 153b(1)(a)section 62section 119(1)section 153(2)warrant of authorisationtime barred assessment

Judgments citing 2) In Om Parkash Jindal v. Union of India

Mr Ismail Muhammad Khan, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle-1(2), Mumbai

In the result all the appeals filed by both the assessees are stands allowed

ITA 4289/MUM/2023[2018-19]Status: DisposedITAT Mumbai20 Jun 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…n why the things could not be seized on 26.03.2021. Out of 4 things placed under restraint, 200 SIM Cards were seized and backup of one server was taken on 24.05.2021. Such an order does not extend the search. 2) In Om Parkash Jindal vs Union of India [1976] 104 ITR 389 (P&H) [Pg 6-13] it is held as under: [Rel Pg 10-11]. Restraint order u/s 132(3) can be passed only when the authorised officer can reasonably believe that the bullion, jewellry etc represented undisclosed property. But if he is not so satisfied or has doubts then he cannot have recourse to Section 132(3). The stand that the restraint order is pa…

Mr Ismail Muhammad Khan, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle-1(2), Mumbai

In the result all the appeals filed by both the assessees are stands allowed

ITA 4288/MUM/2023[2019-20]Status: DisposedITAT Mumbai20 Jun 2025AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…n why the things could not be seized on 26.03.2021. Out of 4 things placed under restraint, 200 SIM Cards were seized and backup of one server was taken on 24.05.2021. Such an order does not extend the search. 2) In Om Parkash Jindal vs Union of India [1976] 104 ITR 389 (P&H) [Pg 6-13] it is held as under: [Rel Pg 10-11]. Restraint order u/s 132(3) can be passed only when the authorised officer can reasonably believe that the bullion, jewellry etc represented undisclosed property. But if he is not so satisfied or has doubts then he cannot have recourse to Section 132(3). The stand that the restraint order is pa…

Mr Ismail Muhammad Khan, Mumbai vs. Assisatnt Commissioner of Income Tax, Central Circle-1(2), Mumbai

In the result all the appeals filed by both the assessees are stands allowed

ITA 4286/MUM/2023[2020-21]Status: DisposedITAT Mumbai20 Jun 2025AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…n why the things could not be seized on 26.03.2021. Out of 4 things placed under restraint, 200 SIM Cards were seized and backup of one server was taken on 24.05.2021. Such an order does not extend the search. 2) In Om Parkash Jindal vs Union of India [1976] 104 ITR 389 (P&H) [Pg 6-13] it is held as under: [Rel Pg 10-11]. Restraint order u/s 132(3) can be passed only when the authorised officer can reasonably believe that the bullion, jewellry etc represented undisclosed property. But if he is not so satisfied or has doubts then he cannot have recourse to Section 132(3). The stand that the restraint order is pa…

Ismail Muhammad Khan, Mumbai vs. Assistant Commissioner of Income Tax Central Circle-1(2), Mumbai

In the result all the appeals filed by both the assessees are stands allowed

ITA 4273/MUM/2023[2016-17]Status: DisposedITAT Mumbai20 Jun 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…n why the things could not be seized on 26.03.2021. Out of 4 things placed under restraint, 200 SIM Cards were seized and backup of one server was taken on 24.05.2021. Such an order does not extend the search. 2) In Om Parkash Jindal vs Union of India [1976] 104 ITR 389 (P&H) [Pg 6-13] it is held as under: [Rel Pg 10-11]. Restraint order u/s 132(3) can be passed only when the authorised officer can reasonably believe that the bullion, jewellry etc represented undisclosed property. But if he is not so satisfied or has doubts then he cannot have recourse to Section 132(3). The stand that the restraint order is pa…

Ismail Muhammad Khan, Mumbai vs. Assistant Commissioner of Income, Central Circle-1 (2), Mumbai

In the result all the appeals filed by both the assessees are stands allowed

ITA 4272/MUM/2023[2017-18]Status: DisposedITAT Mumbai20 Jun 2025AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…n why the things could not be seized on 26.03.2021. Out of 4 things placed under restraint, 200 SIM Cards were seized and backup of one server was taken on 24.05.2021. Such an order does not extend the search. 2) In Om Parkash Jindal vs Union of India [1976] 104 ITR 389 (P&H) [Pg 6-13] it is held as under: [Rel Pg 10-11]. Restraint order u/s 132(3) can be passed only when the authorised officer can reasonably believe that the bullion, jewellry etc represented undisclosed property. But if he is not so satisfied or has doubts then he cannot have recourse to Section 132(3). The stand that the restraint order is pa…

Ismail Muhammad Khan, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle-1(2), Mumbai

In the result all the appeals filed by both the

ITA 4267/MUM/2023[2011-12]Status: DisposedITAT Mumbai20 Jun 2025AY 2011-12

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…n why the things could not be seized on 26.03.2021. Out of 4 things placed under restraint, 200 SIM Cards were seized and backup of one server was taken on 24.05.2021. Such an order does not extend the search. 2) In Om Parkash Jindal vs Union of India [1976] 104 ITR 389 (P&H) [Pg_6-13] it is held as under: [Rel Pg 10-11]. Restraint order u/s 132(3) can be passed only when the authorised officer can reasonably believe that the bullion, jewellry etc represented undisclosed property. But if he is not so satisfied or has doubts then he cannot have recourse to Section 132(3). The stand that the restraint order is p…

M/S. Index Logistics Pvt Ltd, Mumbai vs. ACIT CC 1 (2), Mumbai

In the result all the appeals filed by both the assessees are stands allowed

ITA 3362/MUM/2023[2018-19]Status: DisposedITAT Mumbai20 Jun 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…n why the things could not be seized on 26.03.2021. Out of 4 things placed under restraint, 200 SIM Cards were seized and backup of one server was taken on 24.05.2021. Such an order does not extend the search. 2) In Om Parkash Jindal vs Union of India [1976] 104 ITR 389 (P&H) [Pg 6-13] it is held as under: [Rel Pg 10-11]. Restraint order u/s 132(3) can be passed only when the authorised officer can reasonably believe that the bullion, jewellry etc represented undisclosed property. But if he is not so satisfied or has doubts then he cannot have recourse to Section 132(3). The stand that the restraint order is pa…

M/S. Index Logistics Pvt Ltd, Mumbai vs. ACIT CC 1 (2), Mumbai

In the result all the appeals filed by both the assessees are stands allowed

ITA 3361/MUM/2023[2019-20]Status: DisposedITAT Mumbai20 Jun 2025AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…n why the things could not be seized on 26.03.2021. Out of 4 things placed under restraint, 200 SIM Cards were seized and backup of one server was taken on 24.05.2021. Such an order does not extend the search. 2) In Om Parkash Jindal vs Union of India [1976] 104 ITR 389 (P&H) [Pg 6-13] it is held as under: [Rel Pg 10-11]. Restraint order u/s 132(3) can be passed only when the authorised officer can reasonably believe that the bullion, jewellry etc represented undisclosed property. But if he is not so satisfied or has doubts then he cannot have recourse to Section 132(3). The stand that the restraint order is pa…

M/S. Index Logistics Pvt Ltd, Mumbai vs. ACIT CC 1 (2), Mumbai

In the result all the appeals filed by both the assessees are stands allowed

ITA 3360/MUM/2023[2020-21]Status: DisposedITAT Mumbai20 Jun 2025AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…n why the things could not be seized on 26.03.2021. Out of 4 things placed under restraint, 200 SIM Cards were seized and backup of one server was taken on 24.05.2021. Such an order does not extend the search. 2) In Om Parkash Jindal vs Union of India [1976] 104 ITR 389 (P&H) [Pg 6-13] it is held as under: [Rel Pg 10-11]. Restraint order u/s 132(3) can be passed only when the authorised officer can reasonably believe that the bullion, jewellry etc represented undisclosed property. But if he is not so satisfied or has doubts then he cannot have recourse to Section 132(3). The stand that the restraint order is pa…

M/S. Index Logistics Pvt Ltd, Mumbai vs. ACIT CC 1 (2), Mumbai

In the result all the appeals filed by both the assessees are stands allowed

ITA 3347/MUM/2023[2016-17]Status: DisposedITAT Mumbai20 Jun 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…n why the things could not be seized on 26.03.2021. Out of 4 things placed under restraint, 200 SIM Cards were seized and backup of one server was taken on 24.05.2021. Such an order does not extend the search. 2) In Om Parkash Jindal vs Union of India [1976] 104 ITR 389 (P&H) [Pg 6-13] it is held as under: [Rel Pg 10-11]. Restraint order u/s 132(3) can be passed only when the authorised officer can reasonably believe that the bullion, jewellry etc represented undisclosed property. But if he is not so satisfied or has doubts then he cannot have recourse to Section 132(3). The stand that the restraint order is pa…

M/S. Index Logistics Pvt Ltd, Mumbai vs. ACIT CC 1 (2), Mumbai

In the result all the appeals filed by both the assessees are stands allowed

ITA 3346/MUM/2023[2017-18]Status: DisposedITAT Mumbai20 Jun 2025AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…n why the things could not be seized on 26.03.2021. Out of 4 things placed under restraint, 200 SIM Cards were seized and backup of one server was taken on 24.05.2021. Such an order does not extend the search. 2) In Om Parkash Jindal vs Union of India [1976] 104 ITR 389 (P&H) [Pg 6-13] it is held as under: [Rel Pg 10-11]. Restraint order u/s 132(3) can be passed only when the authorised officer can reasonably believe that the bullion, jewellry etc represented undisclosed property. But if he is not so satisfied or has doubts then he cannot have recourse to Section 132(3). The stand that the restraint order is pa…

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 180/VIZ/2023[2020-21]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ries made in various bank accounts in question represent wholly or partly the undisclosed income of the assessees. This Court in Visa Comtrade Ltd. (supra), referring to the judgment of Punjab & Haryana High Court in Om Prakash Jindal v. Union of India [1976] 104 ITR 389 and the decision of Allahabad High Court in the case of Sriram Jaiswal v. Union of India [1989] 176 ITR 261/42 Taxman 83 held that prohibitory order under s. 132(3) of the Act issued in respect of bank accounts without forming any belief or without any material on record to conclude that the amount deposited in such bank accounts is either wholly…

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 179/VIZ/2023[2019-20]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2019-20

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ries made in various bank accounts in question represent wholly or partly the undisclosed income of the assessees. This Court in Visa Comtrade Ltd. (supra), referring to the judgment of Punjab & Haryana High Court in Om Prakash Jindal v. Union of India [1976] 104 ITR 389 and the decision of Allahabad High Court in the case of Sriram Jaiswal v. Union of India [1989] 176 ITR 261/42 Taxman 83 held that prohibitory order under s. 132(3) of the Act issued in respect of bank accounts without forming any belief or without any material on record to conclude that the amount deposited in such bank accounts is either wholly…

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 178/VIZ/2023[2018-19]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ries made in various bank accounts in question represent wholly or partly the undisclosed income of the assessees. This Court in Visa Comtrade Ltd. (supra), referring to the judgment of Punjab & Haryana High Court in Om Prakash Jindal v. Union of India [1976] 104 ITR 389 and the decision of Allahabad High Court in the case of Sriram Jaiswal v. Union of India [1989] 176 ITR 261/42 Taxman 83 held that prohibitory order under s. 132(3) of the Act issued in respect of bank accounts without forming any belief or without any material on record to conclude that the amount deposited in such bank accounts is either wholly…

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 177/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ries made in various bank accounts in question represent wholly or partly the undisclosed income of the assessees. This Court in Visa Comtrade Ltd. (supra), referring to the judgment of Punjab & Haryana High Court in Om Prakash Jindal v. Union of India [1976] 104 ITR 389 and the decision of Allahabad High Court in the case of Sriram Jaiswal v. Union of India [1989] 176 ITR 261/42 Taxman 83 held that prohibitory order under s. 132(3) of the Act issued in respect of bank accounts without forming any belief or without any material on record to conclude that the amount deposited in such bank accounts is either wholly…

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 176/VIZ/2023[2016-17]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ries made in various bank accounts in question represent wholly or partly the undisclosed income of the assessees. This Court in Visa Comtrade Ltd. (supra), referring to the judgment of Punjab & Haryana High Court in Om Prakash Jindal v. Union of India [1976] 104 ITR 389 and the decision of Allahabad High Court in the case of Sriram Jaiswal v. Union of India [1989] 176 ITR 261/42 Taxman 83 held that prohibitory order under s. 132(3) of the Act issued in respect of bank accounts without forming any belief or without any material on record to conclude that the amount deposited in such bank accounts is either wholly…

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 175/VIZ/2023[2015-16]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ries made in various bank accounts in question represent wholly or partly the undisclosed income of the assessees. This Court in Visa Comtrade Ltd. (supra), referring to the judgment of Punjab & Haryana High Court in Om Prakash Jindal v. Union of India [1976] 104 ITR 389 and the decision of Allahabad High Court in the case of Sriram Jaiswal v. Union of India [1989] 176 ITR 261/42 Taxman 83 held that prohibitory order under s. 132(3) of the Act issued in respect of bank accounts without forming any belief or without any material on record to conclude that the amount deposited in such bank accounts is either wholly…

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 174/VIZ/2023[2014-15]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ries made in various bank accounts in question represent wholly or partly the undisclosed income of the assessees. This Court in Visa Comtrade Ltd. (supra), referring to the judgment of Punjab & Haryana High Court in Om Prakash Jindal v. Union of India [1976] 104 ITR 389 and the decision of Allahabad High Court in the case of Sriram Jaiswal v. Union of India [1989] 176 ITR 261/42 Taxman 83 held that prohibitory order under s. 132(3) of the Act issued in respect of bank accounts without forming any belief or without any material on record to conclude that the amount deposited in such bank accounts is either wholly…

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 173/VIZ/2023[2013-14]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ries made in various bank accounts in question represent wholly or partly the undisclosed income of the assessees. This Court in Visa Comtrade Ltd. (supra), referring to the judgment of Punjab & Haryana High Court in Om Prakash Jindal v. Union of India [1976] 104 ITR 389 and the decision of Allahabad High Court in the case of Sriram Jaiswal v. Union of India [1989] 176 ITR 261/42 Taxman 83 held that prohibitory order under s. 132(3) of the Act issued in respect of bank accounts without forming any belief or without any material on record to conclude that the amount deposited in such bank accounts is either wholly…

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 172/VIZ/2023[2012-13]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2012-13

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ries made in various bank accounts in question represent wholly or partly the undisclosed income of the assessees. This Court in Visa Comtrade Ltd. (supra), referring to the judgment of Punjab & Haryana High Court in Om Prakash Jindal v. Union of India [1976] 104 ITR 389 and the decision of Allahabad High Court in the case of Sriram Jaiswal v. Union of India [1989] 176 ITR 261/42 Taxman 83 held that prohibitory order under s. 132(3) of the Act issued in respect of bank accounts without forming any belief or without any material on record to conclude that the amount deposited in such bank accounts is either wholly…

2) In Om Parkash Jindal v. Union of India (104 ITR 389) — Cited in 20 Judgments | BharatTax