83 DTR 88 (Del) CIT v. D.D. Gears Ltd. (extracted

75 ITD 1Income Tax Appellate Tribunal2000#4877 most cited

What is 83 DTR 88 (Del) CIT v. D.D. Gears Ltd. (extracted authority for?

Seized documents must be read as they are presented, meaning their contents should be taken at face value without further interpretation or assumption.

24

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2015 to 2026.

Also referred to as

83 DTR 88 · CIT v. D.D. Gears Ltd. · section 132(4) · seized documents · presumption · burden of proof · interpretation of seized material · income tax assessment

Sections most often in play

Section 292CSection 132(4A)Section 132Section 132(4)Section 131Section 133ASection 143(2)Section 143(3)

Issues it is cited on

section 181section 114(e)section 23(3)section 132(4a)section 38percentage completion methodsection 131(1a)section 292ccircle ratesection 91preponderance of probabilitysection 132(1)

Judgments citing 83 DTR 88 (Del) CIT v. D.D. Gears Ltd. (extracted

DCIT, Central Circle-6, Third Floor vs. Rama Shankar Khemka, Ganesh Bazar

In the result, the appeal filed by the revenue and CO filed by the assessee are dismissed

ITA 1005/DEL/2024[2020-21]Status: DisposedITAT Delhi06 Feb 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmandcit Vs. Payal Khemka Central Circle- 6 67/85-2 Jhun Bhawan, Natimalivaranashi Delhi Uttar Pradesh 221001 (Pan: Adtpj2728A) Dcit Vs. Pmk Impex Pvt. Ltd. Central Circle- 6 1 Tolstoy Marg, Connaught Place, Delhi New Delhi, Delhi 110001

For Appellant: Sh. Gautam Jain AdvFor Respondent: Sh. Jitender Singh, CIT DR
Section 132Section 132(4)

…gned addition has been deleted." 27 It is submitted that, it is well settled law that seized documents must be read as such. Reliance is placed on the following judgments: i) 83 DTR 88 (Del) CIT vs. D.D. Gears Ltd. (extracted at page 324 of Paper Book) ii) 75 ITD 1 (Pune) Golani Bros vs. ACIT (extracted at pages 324-325 of Paper Book) 349 ITR 85 (Del) CIT vs. Indeo Airways (P) Ltd. (extracted at pages 322-323 of Paper Book) iv) 142 ITD 394 (Kol) Vivek Kumar Kathotia v. DCIT (extracted at pages 325-326 of Paper Book) 28 STATEMENT OF SH. MAYANK KHEMKA DIRECTOR OF THE ASSESSEE COMPANY IN RESPECT OF THE WHATSAP…

DCIT, Central Circle-6, Third Floor vs. Rajesh Rani Khemka, Ganesh Bazar

In the result, the appeal filed by the revenue and CO filed by the assessee are dismissed

ITA 1004/DEL/2024[2020-21]Status: DisposedITAT Delhi06 Feb 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmandcit Vs. Payal Khemka Central Circle- 6 67/85-2 Jhun Bhawan, Natimalivaranashi Delhi Uttar Pradesh 221001 (Pan: Adtpj2728A) Dcit Vs. Pmk Impex Pvt. Ltd. Central Circle- 6 1 Tolstoy Marg, Connaught Place, Delhi New Delhi, Delhi 110001

For Appellant: Sh. Gautam Jain AdvFor Respondent: Sh. Jitender Singh, CIT DR
Section 132Section 132(4)

…gned addition has been deleted." 27 It is submitted that, it is well settled law that seized documents must be read as such. Reliance is placed on the following judgments: i) 83 DTR 88 (Del) CIT vs. D.D. Gears Ltd. (extracted at page 324 of Paper Book) ii) 75 ITD 1 (Pune) Golani Bros vs. ACIT (extracted at pages 324-325 of Paper Book) 349 ITR 85 (Del) CIT vs. Indeo Airways (P) Ltd. (extracted at pages 322-323 of Paper Book) iv) 142 ITD 394 (Kol) Vivek Kumar Kathotia v. DCIT (extracted at pages 325-326 of Paper Book) 28 STATEMENT OF SH. MAYANK KHEMKA DIRECTOR OF THE ASSESSEE COMPANY IN RESPECT OF THE WHATSAP…

DCIT, Central Circle-6, Income Tax Department vs. Payal Khemka, K

In the result, the appeal filed by the revenue and CO filed by the assessee are dismissed

ITA 1000/DEL/2024[2020-21]Status: DisposedITAT Delhi06 Feb 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmandcit Vs. Payal Khemka Central Circle- 6 67/85-2 Jhun Bhawan, Natimalivaranashi Delhi Uttar Pradesh 221001 (Pan: Adtpj2728A) Dcit Vs. Pmk Impex Pvt. Ltd. Central Circle- 6 1 Tolstoy Marg, Connaught Place, Delhi New Delhi, Delhi 110001

For Appellant: Sh. Gautam Jain AdvFor Respondent: Sh. Jitender Singh, CIT DR
Section 132Section 132(4)

…gned addition has been deleted." 27 It is submitted that, it is well settled law that seized documents must be read as such. Reliance is placed on the following judgments: i) 83 DTR 88 (Del) CIT vs. D.D. Gears Ltd. (extracted at page 324 of Paper Book) ii) 75 ITD 1 (Pune) Golani Bros vs. ACIT (extracted at pages 324-325 of Paper Book) 349 ITR 85 (Del) CIT vs. Indeo Airways (P) Ltd. (extracted at pages 322-323 of Paper Book) iv) 142 ITD 394 (Kol) Vivek Kumar Kathotia v. DCIT (extracted at pages 325-326 of Paper Book) 28 STATEMENT OF SH. MAYANK KHEMKA DIRECTOR OF THE ASSESSEE COMPANY IN RESPECT OF THE WHATSAP…

Shri Swami Vivekanand Nagari Sahakari Pat Sanstha Maryadit, Pandharpur vs. Income Tax Officer Ward 2 Pandharpur, Pandharpur

In the result, appeal filed by the Assessee is dismissed

ITA 1406/PUN/2025[2017-18]Status: DisposedITAT Pune06 Jan 2026AY 2017-18

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Section 139(1)Section 142(1)Section 143(2)Section 144Section 250Section 80ASection 80A(5)Section 80PSection 80P(2)

…hence it was Invalid, non-estReturn of Income. Henec, AO was Right in not issuing Notice u/s 143(2) of the Act. 18 ITA No.1406/PUN/2025 [A] 9.3We find support from the ITAT (Third Member) decision in the case of Bhagat Singh and Virender Singh vs ACIT [2000] 75 ITD 1 (DELHI) (TM). In the said case it was held “7. Once it is decided that the return dated 16-3-1995 filed by the assessee was a non est return, the next question in regard to the issuance ofnotice under section 143(2) becomes insignificant” 9.3.1 The proposition of law laid down in the case of Bhagat Singh and Virender Singh Vs.ACIT (supra) is applic…

ACIT Central Circle 1(4) Mumbai, Mumbai vs. Kalyanee Fortune Constructions, Mumbai

In the result, all the above appeals in ITA Nos

ITA 5779/MUM/2024[2019-20]Status: DisposedITAT Mumbai23 Dec 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Neelkanth Khandelwal, ARFor Respondent: Ms. Kavitha Kaushik, (Sr. DR)
Section 131Section 132(1)Section 133ASection 143(3)

…r could not be ruled out as it was not possible that assessee would accept the on-money in one flat and would not accept in the neighbouring flat. Reliance was placed by the AO on the decision of Hon’ble ITAT, Pune Bench, in the case of Golani Brothers (2000) 75 ITD 1,Overseas Chinese Cuisine vs. Asstt. CIT (1996) 55 TTJ (Bo304 (TM); (1996) 56 ITD 67 (Bom) (TM) and judgement of the Bombay High Court in the case of Harish Textiles Engineers (2015) 128 DTR (Bom) 145,wherein the estimation of on-money was also upheld for the period prior to the period for which evidence was found. In this case, the AO observed P a…

Assistant Commissioner of Income Tax Central Circle 1(4), Mumbai vs. Kalyanee Fortune Constructions, Mumbai

In the result, all the above appeals in ITA Nos

ITA 4448/MUM/2024[2017-18]Status: DisposedITAT Mumbai23 Dec 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Revenue byFor Respondent: Date of Hearing
Section 131Section 132(1)Section 133ASection 143(3)

…r could not be ruled out as it was not possible that assessee would accept the on-money in one flat and would not accept in the neighbouring flat. Reliance was placed by the AO on the decision of Hon'ble ITAT, Pune Bench, in the case of Golani Brothers (2000) 75 ITD 1,Overseas Chinese Cuisine vs. Asstt. CIT (1996) 55 TTJ (B0304 (TM); (1996) 56 ITD 67 (Bom) (TM) and judgement of the Bombay High Court in the case of Harish Textiles Engineers (2015) 128 DTR (Bom) 145,wherein the estimation of on-money was also upheld for the period prior to the period for which evidence was found. In this case, the AO observed Page…

Assistant Commissioner of Income Tax, Mumbai vs. Kalyanee Fortune Constructions, Mumbai

In the result, all the above appeals in ITA Nos

ITA 4445/MUM/2024[2018-19]Status: DisposedITAT Mumbai23 Dec 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Neelkanth Khandelwal, ARFor Respondent: Ms. Kavitha Kaushik, (Sr. DR)
Section 131Section 132(1)Section 133ASection 143(3)

…r could not be ruled out as it was not possible that assessee would accept the on-money in one flat and would not accept in the neighbouring flat. Reliance was placed by the AO on the decision of Hon’ble ITAT, Pune Bench, in the case of Golani Brothers (2000) 75 ITD 1,Overseas Chinese Cuisine vs. Asstt. CIT (1996) 55 TTJ (Bo304 (TM); (1996) 56 ITD 67 (Bom) (TM) and judgement of the Bombay High Court in the case of Harish Textiles Engineers (2015) 128 DTR (Bom) 145,wherein the estimation of on-money was also upheld for the period prior to the period for which evidence was found. In this case, the AO observed P a…

Assistant Commissioner of Income Tax Central Circle 1 4 Mumbai, Mumbai vs. Ms. Kalyanee Fortune Constructions, Mumbai

In the result, all the above appeals in ITA Nos

ITA 4444/MUM/2024[2020-21]Status: DisposedITAT Mumbai23 Dec 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Neelkanth Khandelwal, ARFor Respondent: Ms. Kavitha Kaushik, (Sr. DR)
Section 131Section 132(1)Section 133ASection 143(3)

…r could not be ruled out as it was not possible that assessee would accept the on-money in one flat and would not accept in the neighbouring flat. Reliance was placed by the AO on the decision of Hon'ble ITAT, Pune Bench, in the case of Golani Brothers (2000) 75 ITD 1,Overseas Chinese Cuisine vs. Asstt. CIT (1996) 55 TTJ (B0304 (TM); (1996) 56 ITD 67 (Bom) (TM) and judgement of the Bombay High Court in the case of Harish Textiles Engineers (2015) 128 DTR (Bom) 145,wherein the estimation of on-money was also upheld for the period prior to the period for which evidence was found. In this case, the AO observed Page…

Shree Balaji Realty, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, appeals for

ITA 877/PUN/2024[2019-2020]Status: DisposedITAT Pune07 Feb 2025AY 2019-2020

Bench: Shri R. K. Panda & Ms. Astha Chandra

Section 132Section 143(2)Section 153A

…been destroyed by Assessee after accepting on-money. This clearly proves that Assessee has accepted on-money with respect to others shops/flats sold. In this context reliance is placed on the decision of Hon'ble ITAT Pune in the case of Golani Brothers (2000) 75 ITD 1 wherein the ITAT Pune has upheld the action of the AO in assuming that assessee must have also received the 'on money' in respect of the balance 67 shops sold during these years, when the material found and seized in search contained only a list of 201 shops in respect of which 'on money' was received by the Assessee. The Hon'ble Tribunal Pune Bench…

Shree Balaji Realty, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, appeals for

ITA 876/PUN/2024[2018-19]Status: DisposedITAT Pune07 Feb 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

Section 132Section 143(2)Section 153A

…been destroyed by Assessee after accepting on-money. This clearly proves that Assessee has accepted on-money with respect to others shops/flats sold. In this context reliance is placed on the decision of Hon'ble ITAT Pune in the case of Golani Brothers (2000) 75 ITD 1 wherein the ITAT Pune has upheld the action of the AO in assuming that assessee must have also received the 'on money' in respect of the balance 67 shops sold during these years, when the material found and seized in search contained only a list of 201 shops in respect of which 'on money' was received by the Assessee. The Hon'ble Tribunal Pune Bench…

Shree Balaji Realty, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, appeals for assessment years 2017-18 and 2018-19 are allowed and the appeal for assessment year 2019-20 is partly allowed

ITA 875/PUN/2024[2017-18]Status: DisposedITAT Pune07 Feb 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: S/Shri Amol Kharnar CIT-DR &
Section 132Section 143(2)Section 153A

…been destroyed by Assessee after accepting on-money. This clearly proves that Assessee has accepted on-money with respect to others shops/flats sold. In this context reliance is placed on the decision of Hon'ble ITAT Pune in the case of Golani Brothers (2000) 75 ITD 1 wherein the ITAT Pune has upheld the action of the AO in assuming that assessee must have also received the 'on money' in respect of the balance 67 shops sold during these years, when the material found and seized in search contained only a list of 201 shops in respect of which 'on money' was received by the Assessee. The Hon'ble Tribunal Pune Bench…

Meenamani Ganga Builder LLP, Pune vs. Assistant Commissioner of Income Tax, Central Circle 2(3), Pune

ITA 873/PUN/2024[2019-20]Status: DisposedITAT Pune07 Feb 2025AY 2019-20

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri Amol Kharnar CIT-DR
Section 132Section 143(2)Section 153A

…ossible that the assessee would accept the on-money in one shop and cannot accept in the neighbor shop. Rejecting the various explanations given by the assessee and following the decision of the Pune Bench of the Tribunal in the case of Golani Brothers (2000) 75 ITD 1, the Assessing Officer held that 80% of the consideration as per the registered sale deed can reasonably be estimated as on-money since the consideration received as per the sale deeds varies from shop to shop. The relevant observations of the Assessing Officer read as under: “6.3 Calculation of on-money: The evidences of on-money are found with res…

Meenamani Ganga Builder LLP, Pune vs. Assistant Commissioner of Income Tax, Central Circle 2(3), Pune

In the result, all the three appeals filed by the assessee are partly allowed

ITA 872/PUN/2024[2018-19]Status: DisposedITAT Pune07 Feb 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri Amol Kharnar CIT-DR
Section 132Section 143(2)Section 153A

…ossible that the assessee would accept the on-money in one shop and cannot accept in the neighbor shop. Rejecting the various explanations given by the assessee and following the decision of the Pune Bench of the Tribunal in the case of Golani Brothers (2000) 75 ITD 1, the Assessing Officer held that 80% of the consideration as per the registered sale deed can reasonably be estimated as on-money since the consideration received as per the sale deeds varies from shop to shop. The relevant observations of the Assessing Officer read as under: “6.3 Calculation of on-money: The evidences of on-money are found with r…

Meenamani Ganga Builder Ll, Pune vs. Assistant Commissioner of Income Tax, Central Circle 2(3), Pune

ITA 871/PUN/2024[2017-18]Status: DisposedITAT Pune07 Feb 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri Amol Kharnar CIT-DR
Section 132Section 143(2)Section 153A

…ossible that the assessee would accept the on-money in one shop and cannot accept in the neighbor shop. Rejecting the various explanations given by the assessee and following the decision of the Pune Bench of the Tribunal in the case of Golani Brothers (2000) 75 ITD 1, the Assessing Officer held that 80% of the consideration as per the registered sale deed can reasonably be estimated as on-money since the consideration received as per the sale deeds varies from shop to shop. The relevant observations of the Assessing Officer read as under: "6.3 Calculation of on-money: The evidences of on-money are found with res…

DCIT, CC-28, New Delhi vs. Lumax Auto Technologies Ltd, New Delhi

ITA 948/DEL/2021[2018-19]Status: DisposedITAT Delhi04 Apr 2024AY 2018-19

Bench: DR. B.R.R. KUMAR (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 132(4)Section 69A

…nn.com 244 (Delhi)/349 ITR 85 (Delhi) " The Hon’ble ITAT Delhi on the case of ACIT vs. M/s Vatika Green field (P) Ltd., [2009] 121 TTJ 208 (Delhi) " The Hon’ble Delhi High Court in the case of CIT vs. D.D. Gears Ltd., ITA No.896/2008 " Golani Bros. vs. ACIT ; 75 ITD 1 (Pune) " Vivek Kumar Kathotia vs. DCIT [2013] 32 taxmann.com 331 (Kol-Trib.). 11. It is also found that the survey u/s 133A of the Act was also conducted on total seven suppliers of the assessee company. Out of which five suppliers were surveyed at the same time, who have categorically denied having indulged in any over invoicing of supplies to the…

DCIT, CC-28, New Delhi vs. Lumax Dk Auto Industries Ltd., New Delhi

ITA 947/DEL/2021[2018-19]Status: DisposedITAT Delhi04 Apr 2024AY 2018-19

Bench: DR. B.R.R. KUMAR (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 132(4)Section 69A

…nn.com 244 (Delhi)/349 ITR 85 (Delhi) " The Hon’ble ITAT Delhi on the case of ACIT vs. M/s Vatika Green field (P) Ltd., [2009] 121 TTJ 208 (Delhi) " The Hon’ble Delhi High Court in the case of CIT vs. D.D. Gears Ltd., ITA No.896/2008 " Golani Bros. vs. ACIT ; 75 ITD 1 (Pune) " Vivek Kumar Kathotia vs. DCIT [2013] 32 taxmann.com 331 (Kol-Trib.). 11. It is also found that the survey u/s 133A of the Act was also conducted on total seven suppliers of the assessee company. Out of which five suppliers were surveyed at the same time, who have categorically denied having indulged in any over invoicing of supplies to the…

DCIT Central Circle-28, New Delhi vs. Lumax Industries Limited, New Delhi

ITA 1846/DEL/2020[2018-19]Status: DisposedITAT Delhi04 Apr 2024AY 2018-19

Bench: DR. B.R.R. KUMAR (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 132(4)Section 69A

…nn.com 244 (Delhi)/349 ITR 85 (Delhi) " The Hon’ble ITAT Delhi on the case of ACIT vs. M/s Vatika Green field (P) Ltd., [2009] 121 TTJ 208 (Delhi) " The Hon’ble Delhi High Court in the case of CIT vs. D.D. Gears Ltd., ITA No.896/2008 " Golani Bros. vs. ACIT ; 75 ITD 1 (Pune) " Vivek Kumar Kathotia vs. DCIT [2013] 32 taxmann.com 331 (Kol-Trib.). 11. It is also found that the survey u/s 133A of the Act was also conducted on total seven suppliers of the assessee company. Out of which five suppliers were surveyed at the same time, who have categorically denied having indulged in any over invoicing of supplies to the…

Dy. Commissioner of Income Tax, Central Circle-3, Surat vs. Dmc Construction Pvt. Ltd., Mumbai

In the result, the grounds of Revenue’s appeal are dismissed

ITA 112/SRT/2021[2012-13]Status: DisposedITAT Surat10 Oct 2023AY 2012-13

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.112/Srt/2021 (Ay 2012-13) (Hearing In Physical Court) Deputy Commissioner Of Dmc Construction Pvt. Ltd Income-Tax, Central Circle-3, 9Th Trivedi Niwas, Rashtriya Vs Surat, Room No. 507, 5Th Floor, Shala Road, Ville Parle West, Aayakar Bhawan, Majura Gate, Mumbai-400056 Surat-395001 Pan No. Aadcd 2089 C अपीलाथ"/Appellant ""थ" /Respondent

Section 132Section 133ASection 143(2)Section 143(3)Section 148Section 254(1)

…xmann.com 227 (Delhi),  Tara Singh Vs ITO (2017) 81 taxmann.com 293 (P&H),  ACIT Vs Giriraj Developers (2017) 82 taxmann.com 54 (Mum-Trib),  Overseas Chinese Cuisine (India) Private Limited (1996) 55 TTJ 304 (ITAT-Mumbai)’  Golbami Brothers Vs ACIT (2000) 75 ITD 1 (ITAT-Pune),  JCIT Vs Narayan Land Estate (IT(SS) A No. s 182,184, 185 & 186/Ahd/2019, 704 7 1836/Ahd/ 2019 dated 10.06.2022. 14. On the other hand, Ld. AR for the assessee supported the order of Ld. CIT(A) and submits that the case of assessee was reopened under secretin 147 of the Act on the basis of search conducted on the third party. No satisf…

Deputy Commissioner of Income-Tax vs. Pinnacle Constro & Eco Home Pvt. Ltd., Pune

In the result, all the four appeals by the Revenue are dismissed

ITA 1263/PUN/2016[2010-11]Status: DisposedITAT Pune12 Oct 2018AY 2010-11

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Suhas P. BoraFor Respondent: Ms. Sabhana Parveen
Section 132Section 145Section 153C

…iton Pvt. Ltd. (supra). The Tribunal after placing reliance on the decisions rendered in the cases of Dhanvarsha Builders & Developers (P) Ltd. Vs. Deputy Commissioner of Income Tax (supra) and Golani Bros. Vs. Assistant Commissioner of Income Tax reported as 75 ITD 1 (Pune) held as under : “6. We have heard the parties and perused the record. There is no dispute in this case that the un-recorded entries of cash receipts found were in respect of the sale of the flats. In sum and substance, it was forming the part of the sale consideration of the flats. The names of the buyers of the flats are also available on re…

Deputy Commissioner of Income-Tax vs. Pinnacle Constro & Eco Home Pvt. Ltd., Pune

In the result, all the four appeals by the Revenue are dismissed

ITA 1262/PUN/2016[2009-10]Status: DisposedITAT Pune12 Oct 2018AY 2009-10

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Suhas P. BoraFor Respondent: Ms. Sabhana Parveen
Section 132Section 145Section 153C

…iton Pvt. Ltd. (supra). The Tribunal after placing reliance on the decisions rendered in the cases of Dhanvarsha Builders & Developers (P) Ltd. Vs. Deputy Commissioner of Income Tax (supra) and Golani Bros. Vs. Assistant Commissioner of Income Tax reported as 75 ITD 1 (Pune) held as under : “6. We have heard the parties and perused the record. There is no dispute in this case that the un-recorded entries of cash receipts found were in respect of the sale of the flats. In sum and substance, it was forming the part of the sale consideration of the flats. The names of the buyers of the flats are also available on re…

83 DTR 88 (Del) CIT v. D.D. Gears Ltd. (extracted (75 ITD 1) — Cited in 24 Judgments | BharatTax