What is 370 (Gujarat) 8. T. Lakhamshi Ladha & Co. v. CIT authority for?

When an assessee claims coercion and pressure for eleven months without reporting it to higher authorities, it is considered an afterthought to support retraction. Additions under Section 68 of the Income Tax Act may be upheld if incriminating evidence is gathered regarding share application, premium, advances, or loans.

How many judgments cite 370 (Gujarat) 8. T. Lakhamshi Ladha & Co. v. CIT?

29 judgments on BharatTax cite 370 (Gujarat) 8. T. Lakhamshi Ladha & Co. v. CIT (6 SOT 18), spanning 2019 to 2026.

Which sections of the Income Tax Act does 370 (Gujarat) 8. T. Lakhamshi Ladha & Co. v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 131, Section 132(4), Section 153A, Section 132, Section 133A.

370 (Gujarat) 8. T. Lakhamshi Ladha & Co. v. CIT (6 SOT 18)

THIPPAREDDY GOVINDAREDDY MALLI REDDY,BENGALURU vs. DCIT, CENTRAL CIRCLE 2(3), BENGALURU

In the result appeal of assessee is dismissed

ITA 685/BANG/2025[AY 2017-18]Status: DisposedITAT Bangalore20 Feb 2026

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian, Jt.CIT (DR)(ITAT), Bengaluru

Section 132Section 139(1)Section 143(2)Section 153Section 153CSection 69A

…im during the assessment and appellate proceedings, he confirmed the addition. The ld. CIT(A) relied upon the decision of Bannalal Jat Constructions (P.) Ltd. v. ACIT [2019] 106 taxmann.com 127 (Raj.) and further the decision of the Coordinate Bench in [2006] 6 SOT 18 (Mumbai) [07-11-2005] [Mum]. He also referred to several judicial precedents and precisely was of the view that as the assessee has disclosed the above sum u/s. 132(4) of the Act, the addition deserves to be confirmed. Accordingly, he confirmed the addition. Page 8 of 19 13. The ld CIT (A) also perused the loose sheet and stated that as the seized…

DCIT CC 7(3), MUMBAI vs. SMT. SAKHIBEN PATEL, MUMBAI

In the result, appeal of the Revenue stands dismissed

ITA 1596/MUM/2019[2013-14]Status: DisposedITAT Mumbai19 Sept 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar & Deputy Commissioner Of V/S. Smt. Sakhiben Patel, Income Tax, Central Circle बनाम 601, 6Th Floor, Petit Towers, –7(3), Room No. 655, 6Th August Kranti Marg, Kemps Floor, Aaykar Bhawan, M.K. Corner, Mumbai – 400 036, Road, Mumbai - 400 020, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aalpp1508R Appellant/अपीलाथी .. Respondent/प्रतिवादी प्रत्याक्षेपसं/C.O. No.71/Mum/2020 (Arising Out Of Ita No. 1595/Mum/2019) (A.Y. 2012-13) Smt. Sakhiben Patel, V/S. Deputy Commissioner Of 601, 6Th Floor, Petit Towers, बनाम Income Tax, Central Circle –7(3), Room No. 655, 6Th August Kranti Marg, Kemps Floor, Aaykar Bhawan, M.K. Corner, Mumbai – 400 036, Road, Mumbai - 400 020, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aalpp1508R Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Rushabh Mehta, ARFor Respondent: Shri Ritesh Misra, (CIT-DR)

Section 131(1)Section 132Section 143(3)Section 153ASection 68

…gation wing or even to CBDT. Whether since assessee had no report to higher authorities in respect of coercion and pressure of eleven months, theory of coercion and pressure was only an afterthought just to support retraction-Held yes(ManmohansinghVig vs DCIT 6 SOT 18(MUM) 4.18 Based on the detailed discussion regarding incriminating evidence gathered by the department in connection with share application/share premium/advances/loans claimed by various entities of Lotus Group in the name of 4 entities namely BCPL, DCPL. RTPL and SPL as brought out by the assessing officer in the assessments of relevant entities,…

DCIT CC 7(3), MUMBAI vs. SMT. SAKHIBEN PATEL, MUMBAI

In the result, appeal of the Revenue stands dismissed

ITA 1595/MUM/2019[2012-13]Status: DisposedITAT Mumbai19 Sept 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar & Deputy Commissioner Of V/S. Smt. Sakhiben Patel, Income Tax, Central Circle बनाम 601, 6Th Floor, Petit Towers, –7(3), Room No. 655, 6Th August Kranti Marg, Kemps Floor, Aaykar Bhawan, M.K. Corner, Mumbai – 400 036, Road, Mumbai - 400 020, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aalpp1508R Appellant/अपीलाथी .. Respondent/प्रतिवादी प्रत्याक्षेपसं/C.O. No.71/Mum/2020 (Arising Out Of Ita No. 1595/Mum/2019) (A.Y. 2012-13) Smt. Sakhiben Patel, V/S. Deputy Commissioner Of 601, 6Th Floor, Petit Towers, बनाम Income Tax, Central Circle –7(3), Room No. 655, 6Th August Kranti Marg, Kemps Floor, Aaykar Bhawan, M.K. Corner, Mumbai – 400 036, Road, Mumbai - 400 020, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aalpp1508R Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Rushabh Mehta, ARFor Respondent: Shri Ritesh Misra, (CIT-DR)

Section 131(1)Section 132Section 143(3)Section 153ASection 68

…gation wing or even to CBDT. Whether since assessee had no report to higher authorities in respect of coercion and pressure of eleven months, theory of coercion and pressure was only an afterthought just to support retraction-Held yes(ManmohansinghVig vs DCIT 6 SOT 18(MUM) 4.18 Based on the detailed discussion regarding incriminating evidence gathered by the department in connection with share application/share premium/advances/loans claimed by various entities of Lotus Group in the name of 4 entities namely BCPL, DCPL. RTPL and SPL as brought out by the assessing officer in the assessments of relevant entities,…

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 812/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)

Section 143(3)Section 37(1)

…Tribunal, therefore, was not justified in reversing the order of the AO which was affirmed by the CIT(A) also." Professional Automotives Private Limited vs. ACIT (Emphasis supplied) In ManmohansinghVig v Deputy Commissioner of Income Tax, Circle 1(1), (2006) 6 SOT 18 (Mumbai) [07-11-2005), the Hon'ble ITAT while coming to a conclusion as to the admissibility of a retraction made on an affidavit by the assessee, laid out certain reasoning for not admitting the same. The conclusions drawn by the Tribunal gives an insight to ascertain as to what the Courts have regard to, while dealing with retractions and how a re…

DCIT CC 7(3), MUMBAI vs. M/S LOTUS LOGISTICS AND DEVELOPERS PVT LTD., MUMBAI

ITA 4058/MUM/2019[2008-09]Status: DisposedITAT Mumbai04 Apr 2025AY 2008-09

Bench: Shri B.R. Baskaran () & Shri Anikesh Banerjee ()

For Appellant: Shri Rishabh MehtaFor Respondent: Dr. K.R. Subhash (CIT-DR.)

Section 132Section 250Section 68Section 69C

…gation wing or even to CBDT. Whether since assessee had no report to higher authorities in respect of coercion and pressure of eleven months, theory of coercion and pressure was only an afterthought just to support retraction-Held yes(ManmohansinghVig vs DCIT 6 SOT 18(MUM) 4.18 Based on the detailed discussion regarding incriminating evidence gathered by the department in connection with share application/share premium/advances/loans claimed by various entities of Lotus Group in the name of 4 entities namely BCPL, DCPL. RTPL and SPL as brought out by the assessing officer in the assessments of relevant entities,…

DCIT - CC -7(3), MUMBAI vs. M/S A. M. CONSTRUCTIONS, MUMBAI

In the result, the appeal of the revenue bearing ITA No

ITA 3115/MUM/2019[2011-12]Status: DisposedITAT Mumbai04 Apr 2025AY 2011-12

Section 132Section 68Section 69C

…ion wing or even to CBDT. Whether since assessee\nhad no report to higher authorities in respect of coercion and pressure of eleven\nmonths, theory of coercion and pressure was only an afterthought just to support\nretraction-Held yes(ManmohansinghVig vs DCIT 6 SOT 18(MUM)\n4.18 Based on the detailed discussion regarding incriminating evidence gathered\nby the department in connection with share application/share\npremium/advances/loans claimed by various entities of Lotus Group in the name\nof 4 entities namely BCPL, DCPL. RTPL and SPL as brought out by the assessing\nofficer in the assessments of relevant entit…

DCIT, CC - 7(3), MUMBAI vs. M/S A. M. DEVELOPERS AND REALTORS, MUMBAI

ITA 3041/MUM/2019[2012-13]Status: DisposedITAT Mumbai04 Apr 2025AY 2012-13

Bench: Shri B.R. Baskaran () & Shri Anikesh Banerjee ()

For Appellant: Shri Rishabh MehtaFor Respondent: Dr. K.R. Subhash (CIT-DR.)

Section 132Section 250Section 68Section 69C

…gation wing or even to CBDT. Whether since assessee had no report to higher authorities in respect of coercion and pressure of eleven months, theory of coercion and pressure was only an afterthought just to support retraction-Held yes(ManmohansinghVig vs DCIT 6 SOT 18(MUM) 4.18 Based on the detailed discussion regarding incriminating evidence gathered by the department in connection with share application/share premium/advances/loans claimed by various entities of Lotus Group in the name of 4 entities namely BCPL, DCPL. RTPL and SPL as brought out by the assessing officer in the assessments of relevant entities,…

DCIT - CC -7(3), MUMBAI vs. M/S A. M. CONSTRUCTIONS, MUMBAI

ITA 3040/MUM/2019[2011-12]Status: DisposedITAT Mumbai04 Apr 2025AY 2011-12

Bench: Shri B.R. Baskaran () & Shri Anikesh Banerjee ()

For Appellant: Shri Rishabh MehtaFor Respondent: Dr. K.R. Subhash (CIT-DR.)

Section 132Section 250Section 68Section 69C

…gation wing or even to CBDT. Whether since assessee had no report to higher authorities in respect of coercion and pressure of eleven months, theory of coercion and pressure was only an afterthought just to support retraction-Held yes(ManmohansinghVig vs DCIT 6 SOT 18(MUM) 4.18 Based on the detailed discussion regarding incriminating evidence gathered by the department in connection with share application/share premium/advances/loans claimed by various entities of Lotus Group in the name of 4 entities namely BCPL, DCPL. RTPL and SPL as brought out by the assessing officer in the assessments of relevant entities,…

DCIT-CC-7(3), MUMBAI vs. M/S LOTUS BUILDSPACE LLP, MUMBAI

In the result, the appeal of the revenue bearing ITA No

ITA 1485/MUM/2019[2014-15]Status: DisposedITAT Mumbai04 Apr 2025AY 2014-15

Section 132Section 68Section 69C

…ion wing or even to CBDT. Whether since assessee\nhad no report to higher authorities in respect of coercion and pressure of eleven\nmonths, theory of coercion and pressure was only an afterthought just to support\nretraction-Held yes(ManmohansinghVig vs DCIT 6 SOT 18(MUM)\n4.18 Based on the detailed discussion regarding incriminating evidence gathered\nby the department in connection with share application/share\npremium/advances/loans claimed by various entities of Lotus Group in the name\nof 4 entities namely BCPL, DCPL. RTPL and SPL as brought out by the assessing\nofficer in the assessments of relevant entit…

KIRAN FINE JEWELLERS PRIVATE LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 1232/JPR/2024[2018-19]Status: DisposedITAT Jaipur25 Feb 2025AY 2018-19

For Appellant: Shri S.R. Sharma, CA and Shri R.K. Bhatra, CAFor Respondent: Shri P.P. Meena, CIT-DR (Thru” V.H.)

Section 115BSection 132(4)Section 69A

…C/T[1987] 35 Taxman 153/168 ITR 375 (Bom.), Dr. S.C. Gupta (supra), C/Tv, Hotel Meriya [2010] 195 Taxman 459/[2011] 332 ITR 537 (Ker.), O. Abdul Razak (supra)" (Emphasis Supplied) In. Manmohansingh Vig v Deputy Commissioner of Income Tax, Circle 1(1), [2006] 6 SOT 18 (Mum), the ITAT while coming to a conclusion as to the admissibility of a retraction made on an affidavit by the assessee, laid out certain reasoning for not admitting the same. The conclusions drawn by the Tribunal would be useful for us and gives us an insight to ascertain as to what the Courts 10 M/S. KIRAN FINE JEWELLERS PVT LTD VS DCIT, CENTR…

JAGDISH KUMAR ARORA,BHAWANIMANDI vs. DCIT, CENTRAL CIRCLE- KOTA, KOTA

In the result, the appeal of the assessee is allowed

ITA 1195/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Feb 2025AY 2017-18

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-Sr. DR

Section 115BSection 143(3)Section 145(3)Section 234ASection 69

…The statements in the retraction has to be duly supported with evidences. Similarly the allegations of coercion etc., if any, in the retraction has to be supported with evidences. In Manmohansingh Vig v Deputy Commissioner of Income Tax, Circle 1(1), [2006] 6 SOT 18 (Mum), the ITAT while coming to a conclusion as to the admissibility of a retraction made on an affidavit by the assessee, laid out certain reasoning for not admitting the same. The conclusions drawn by the Tribunal would be useful for us and gives us an insight to ascertain as to what the Courts have regard to, while dealing with retractions and ho…

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

The appeal of the assessee is partly allowed and that of the revenue stands dismissed

ITA 177/JPR/2020[2017-18]Status: DisposedITAT Jaipur07 Jun 2023AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &

Section 132Section 143Section 143(3)Section 145(3)Section 68

…3 taxmann.com 247 (Delhi) 6. Ravindra Kumar Verma Vs CIT [2013] 30 taxmann.com 367 (All) 7. Sudharshan P. Amin Vs ACIT [2013] 35 taxmann.com 370 (Gujarat) 8. T. Lakhamshi Ladha & Co. Vs CIT 2016] 73 taxmann.com 117 (Bombay) 9. Manmohansingh Vig Vs DCIT [2006] 6 SOT 18 (MUM.) 5.7 It is therefore, in view of the above judicial pronouncements and looking to the facts of the case, humbly submitted that the addition made by the AO on account of excess stock found during the course of search, as deleted by the ld. CIT(A), may kindly be restored as the facts and circumstances of the case do not warrant such deletion. T…

M/S. ROYAL JEWELLERS,JAIPUR vs. DCIT, CENTRAL CIRCLE, JAIPUR

The appeal of the assessee is partly allowed and that of the revenue stands dismissed

ITA 116/JPR/2020[2017-18]Status: DisposedITAT Jaipur07 Jun 2023AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &

Section 132Section 143Section 143(3)Section 145(3)Section 68

…3 taxmann.com 247 (Delhi) 6. Ravindra Kumar Verma Vs CIT [2013] 30 taxmann.com 367 (All) 7. Sudharshan P. Amin Vs ACIT [2013] 35 taxmann.com 370 (Gujarat) 8. T. Lakhamshi Ladha & Co. Vs CIT 2016] 73 taxmann.com 117 (Bombay) 9. Manmohansingh Vig Vs DCIT [2006] 6 SOT 18 (MUM.) 5.7 It is therefore, in view of the above judicial pronouncements and looking to the facts of the case, humbly submitted that the addition made by the AO on account of excess stock found during the course of search, as deleted by the ld. CIT(A), may kindly be restored as the facts and circumstances of the case do not warrant such deletion. T…

M/S JEWELS EMPORIUM,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1 , JAIPUR

In the result, appeal of the assessee is allowed whereas appeal of the revenue is dismissed

ITA 303/JPR/2019[2015-16]Status: DisposedITAT Jaipur15 Sept 2020AY 2015-16

For Appellant: Shri Manish Agarwal (CA)For Respondent: Shri B.K. Gupta (CIT-DR)

Section 132Section 143(3)

…) 99 taxmann.com 39 (Mad.) (viii) CIT Vs M.S. Aggarwal (2018) 93 taxmann.com 247 (Delhi). (ix) Ravindra Kr. Verma Vs CIT (2013) 30 taxmann.com 367 (All) (x) T. Lakhamshi Ladha & Co. Vs CIT (2016) 73 taxmann.com 117 (Bom) (xi) Manmohan Singh Vig Vs DCIT (2006) 6 SOT 18 (Mum). 8. On the other hand, the ld AR has reiterated the contentions raised before the ld. CIT(A). 9. We have considered the rival contentions and carefully gone through the orders of the authorities below. We had also deliberated on the judicial pronouncements referred by the lower authorities in their respective orders 8 ITA 303 & 234/JP/2019_…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1 , JAIPUR vs. M/S JEWELS EMPORIUM, JAIPUR

In the result, appeal of the assessee is allowed whereas appeal of the revenue is dismissed

ITA 234/JPR/2019[2015-16]Status: DisposedITAT Jaipur15 Sept 2020AY 2015-16

For Appellant: Shri Manish Agarwal (CA)For Respondent: Shri B.K. Gupta (CIT-DR)

Section 132Section 143(3)

…) 99 taxmann.com 39 (Mad.) (viii) CIT Vs M.S. Aggarwal (2018) 93 taxmann.com 247 (Delhi). (ix) Ravindra Kr. Verma Vs CIT (2013) 30 taxmann.com 367 (All) (x) T. Lakhamshi Ladha & Co. Vs CIT (2016) 73 taxmann.com 117 (Bom) (xi) Manmohan Singh Vig Vs DCIT (2006) 6 SOT 18 (Mum). 8. On the other hand, the ld AR has reiterated the contentions raised before the ld. CIT(A). 9. We have considered the rival contentions and carefully gone through the orders of the authorities below. We had also deliberated on the judicial pronouncements referred by the lower authorities in their respective orders 8 ITA 303 & 234/JP/2019_…