AddI. ITO v. T. Mudduveerappa Sons.

45 ITD 12Income Tax Appellate Tribunal1993#5532 most cited

What is AddI. ITO v. T. Mudduveerappa Sons. authority for?

Loose papers or documents without independent corroboration cannot form the basis for making an addition to income. The Assessing Officer must provide a finding that the assessee is the owner of any money, bullion, jewellery, or valuable article not recorded in the books of account.

21

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2022 to 2025.

Also referred to as

Addl. ITO v. T. Mudduveerappa Sons · 45 ITD 12 · dumb documents · loose papers · uncorroborated evidence · addition to income · onus on AO · ownership of money · search and seizure · section 132(4)

Sections most often in play

Section 132(4)Section 132(4A)Section 143(3)Section 292CSection 115BBESection 69CSection 142(1)Section 143(2)

Issues it is cited on

dumb documentssection 153c(1)section 132(4a)section 131(1)violation of natural justicesection 269tsection 34section 292cloose paperssection 153a(1)(b)on-moneyright to receive

Judgments citing AddI. ITO v. T. Mudduveerappa Sons.

Shro A/ Johnkumar, Pondicherry vs. DCIT, CC-1(4), Chennai

In the result, appeal filed by the Revenue in ITA No

ITA 3028/CHNY/2019[2017-18]Status: DisposedITAT Chennai13 May 2022AY 2017-18

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.3028/Chny/2019 िनधा"रण वष" /Assessment Year: 2017-18 Mr.A. Johnkumar, V. The Dy. Commissioner- No.28, Savari Padayatchi Street, Of Income Tax, Nellithope, Central Circle-1(4), Pondicherry-605 005. Chennai. [Pan: Afnpj 4673 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. S. Xavier Felix, AdvFor Respondent: Mr. M.Rajan, CIT
Section 2(14)(iii)Section 69Section 69C

…of corroborative evidence, addition of undisclosed income could not be made simply on the basis of entries on loose papers recovered from the residence of a third party and certain general statements of said party. 25. In case of T. Mudduveerappa Sons [1993] 45 ITD 12 (Bang.), the Bangalore Bench of ITAT held that in absence of any external evidence, addition cannot be resorted to only on the basis of loose papers. The department had not brought on record any evidence to prove conclusively that the seized documents contained details of secreted profits which were chargeable to tax. No doubt, the seized papers co…