What is ACIT v. Layer Exports P. Ltd. authority for?

Additions to income cannot be sustained solely on the basis of estimations, extrapolations, or rough notings on loose sheets of paper unless supported by independent and corroborative evidence proving unaccounted income, investment, or expenditure.

How many judgments cite ACIT v. Layer Exports P. Ltd.?

52 judgments on BharatTax cite ACIT v. Layer Exports P. Ltd. (184 TTJ 469), spanning 2020 to 2025.

Which sections of the Income Tax Act does ACIT v. Layer Exports P. Ltd. come up under?

It is most often cited in judgments turning on Section 143(3), Section 153A, Section 132, Section 263, Section 69C, Section 147.

ACIT v. Layer Exports P. Ltd. (184 TTJ 469)

ACIT, CC, Agra vs. M/S. United Farm Product Private Limited, Agra

In the result, appeal preferred by the revenue is dismissed

ITA 299/AGR/2025[2022-23]Status: DisposedITAT Agra04 Dec 2025AY 2022-23

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhacit, Cc, Vs. M/S. United Farm Product Pvt. Ltd., 2/220, 2Nd Floor, Glory Plaza, Agra. Soor Sadan, M.G. Road, Agra – 282 002 (Agra) (Pan :Aaccu2505M) (Appellant) (Respondent) Assessee By : Shri Sudhir Sehgal, Advocate Shri Deependra Mohan, Ca Revenue By : Shri Arun Kumar Yadav, Cit Dr Date Of Hearing : 13.10.2025 Date Of Order : 04.12.2025 O R D E R Per S. Rifaur Rahman,Am: 1. This Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income-Tax (Appeals), Kanpur – 4 Dated 28.03.2025 For Assessment Year2022-23 Raising Following Grounds Of Appeal :- “L. Whether On Facts & Circumstances Of The Case & In Law. The Ld. Cit(A)-Iv. Kanpur Has Erred In Deleting The Addition Of Rs.43,71,37,934/- On Account Of Unexplained Expenditure U/S 69C Of The Act Incurred For Construction Of Plant At Mewat, Haryana, Without Appreciating The Fact That The Assessee Company Itself Has Surrendered Amount Of Rs.41,40,35,700/- & Admitted To Take The Unexplained Expenditure At Rs.43,71,37,934/- Incurred In The 2 Construction Of Said Plant. Hence, The Addition Made By The Ao Is Based On Admittance By The Assessee, Which Is Corroborated By The Incriminating Material Found During The Course Of Search. 2. Whether On Facts & Circumstances Of The Case & In Law, Ld. Cit(A)-Iv. Kanpur Has Erred In Deleting The Addition. Without Appreciating The Facts That The Assessing Officer Has Passed The Assessment Order After Thoroughly Examining & Analysing The Seized Material & Proper Appreciation Of Facts Of Unexplained Expenditure U/S 69C Of The Act.”

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR

Section 69C

…se of Shri Neeraj Goel vs. ACIT in ITA No.5951/.Del/2017 vide order dated 21.03.2018 - Mumabi ITAT in the case of ITO vs. Kranti Impex Pvt. Ltd. in ITA No.1229/Mum/2013 vide order dated 28.02.2018 - Mumbai ITAT in case of ACIT vs. Layer Exports P. Ltd. [2017) 184 TTJ 469 (MUM) - In case of PCIT V. Umesh Ishrani [2019} 108 taxmann.com 437 (Bombay) 9 The aforementioned legal position also gathers support from the judgement of the Hon'ble Supreme Court in case of CBI v. V.C. Shukla 1998 taxmann.com 2155 (SC) popularly known as Jain Hawala Case wherein it was held that any presumption of transaction on some vague, t…

Asst. Commissioner of Income Tax Central Circle 3, Delhi vs. Ved Prakash Chanana, Delhi

In the result, the appeal of the assessee for AY 2018-19 is allowed

ITA 4993/DEL/2024[2018-19]Status: DisposedITAT Delhi24 Oct 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Nirbhay Mehta, AdvocateFor Respondent: Shri Jitender Singh, CIT DR

Section 127(1)Section 132Section 143(1)Section 143(2)Section 153ASection 69A

…n hearsay evidence. 90. Recently the Delhi ITAT in case of Shri Neeraj Goel Vs. ACIT in TTA No.5951/Del./2017 vide order dated 21/03/2018 held that addition on account control of the assessee. 91. The Mumbai ITAT in case of ACIT V Layer Exports P. Ltd. [2017] 184 TTJ 469 (MUM) held that additions are to be made on basis of tangible evidence and not solely on basis of estimations and extrapolation theory. Additions could not be sustained merely on the basis of rough notings made on a few loose sheets of papers unless the AO brought on record some independent and corroborative materials to prove irrefutably that th…

Ved Prakash Chanana, Delhi vs. ACIT CC- 3, Delhi

In the result, the appeal of the assessee for AY 2018-19 is allowed

ITA 4644/DEL/2024[2019-20]Status: DisposedITAT Delhi24 Oct 2025AY 2019-20

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Nirbhay Mehta, AdvocateFor Respondent: Shri Jitender Singh, CIT DR

Section 127(1)Section 132Section 143(1)Section 143(2)Section 153ASection 69A

…n hearsay evidence. 90. Recently the Delhi ITAT in case of Shri Neeraj Goel Vs. ACIT in TTA No.5951/Del./2017 vide order dated 21/03/2018 held that addition on account control of the assessee. 91. The Mumbai ITAT in case of ACIT V Layer Exports P. Ltd. [2017] 184 TTJ 469 (MUM) held that additions are to be made on basis of tangible evidence and not solely on basis of estimations and extrapolation theory. Additions could not be sustained merely on the basis of rough notings made on a few loose sheets of papers unless the AO brought on record some independent and corroborative materials to prove irrefutably that th…

Ved Prakash Chanana, Delhi vs. ACIT CC 03, Delhi

In the result, the appeal of the assessee for AY 2018-19 is allowed

ITA 4643/DEL/2024[2018-19]Status: DisposedITAT Delhi24 Oct 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Nirbhay Mehta, AdvocateFor Respondent: Shri Jitender Singh, CIT DR

Section 127(1)Section 132Section 143(1)Section 143(2)Section 153ASection 69A

…n hearsay evidence. 90. Recently the Delhi ITAT in case of Shri Neeraj Goel Vs. ACIT in TTA No.5951/Del./2017 vide order dated 21/03/2018 held that addition on account control of the assessee. 91. The Mumbai ITAT in case of ACIT V Layer Exports P. Ltd. [2017] 184 TTJ 469 (MUM) held that additions are to be made on basis of tangible evidence and not solely on basis of estimations and extrapolation theory. Additions could not be sustained merely on the basis of rough notings made on a few loose sheets of papers unless the AO brought on record some independent and corroborative materials to prove irrefutably that th…