Addl. CIT v. Miss Lata Mangeshkar

97 ITR 696High Court1974#699 most cited

What is Addl. CIT v. Miss Lata Mangeshkar authority for?

An addition to income cannot be made solely based on documents or material found from a third party's premises unless the Assessing Officer conducts an independent investigation, examines the third party, and establishes a clear link between the material and the assessee.

145

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

Addl. CIT v. Miss Lata Mangeshkar · 97 ITR 696 · section 132 · section 132(4A) · documents from third party · material from third party · independent investigation · additions to income · linking evidence · corroboration · unexplained income · 143(3)

Sections most often in play

Section 143(3)Section 132(4A)Section 132Section 132(4)Section 292CSection 69ASection 69CSection 153A

Issues it is cited on

hundi transactionsection 44afjewellery found during searchsection 132(4a)section 65bsection 65dumb documentssection 150unexplained jewellerysection 292cretraction of statementthird party information

Judgments citing Addl. CIT v. Miss Lata Mangeshkar

Oswal Petrochem, Gandhidham vs. DCIT, CC-1, Rajkot

In the result, all these appeals filed by the different assessees, are allowed for

ITA 402/RJT/2023[2021-22]Status: DisposedITAT Rajkot30 May 2025AY 2021-22

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकर अपीलसं./Ita No.400/Rjt/2023

Section 143(3)Section 250

…Supreme Court in the case of CBI Vs. V.C. Shukla &Ors. (1998) 3 SCC 410 • Hon'ble Supreme Court in the case of Vinod Solanki Vs. Uol&Anr (SC-Civil Appeal No.7407 of 2008) • Hon'ble High Court of Bombay in the case of Addl. CIT vs. Miss Lata Mangeshkar (1974) 97 ITR 696 (Bombay), wherein, it held that - “entries in the day-book or the ledger would be a corroborative piece of evidence and once the direct evidence of the person who was said to have made payments in 'black' to the assessee was disbelieved no value could be attached to entries in the ledger or to the entries in the day-book even if one had been produ…

Shri Ramji Hamir Virda, Gandhidham vs. The DCIT, Central Circle-1, Rajkot

In the result, all these appeals filed by the different assessees, are allowed for statistical purposes

ITA 400/RJT/2023[2021-22]Status: DisposedITAT Rajkot30 May 2025AY 2021-22

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकरअपीलसं./Ita No.400/Rjt/2023 Assessment Year: (2021-22)

Section 143(3)Section 250

…Supreme Court in the case of CBI Vs. V.C. Shukla &Ors. (1998) 3 SCC 410  Hon'ble Supreme Court in the case of Vinod Solanki Vs. Uol&Anr (SC-Civil Appeal No.7407 of 2008)  Hon'ble High Court of Bombay in the case of Addl. CIT vs. Miss Lata Mangeshkar (1974) 97 ITR 696 (Bombay), wherein, it held that - “entries in the day-book or the ledger would be a corroborative piece of evidence and once the direct evidence of the person who was said to have made payments in 'black' to the assessee was disbelieved no value could be attached to entries in the ledger or to the entries in the day-book even if one had been produ…

Narayanbhai Manjibhai Bodriya, Mumbai vs. Income Tax Officer, 41(3)(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 4699/MUM/2023[2014-15]Status: DisposedITAT Mumbai30 May 2025AY 2014-15

Bench: Ms Kavitha Rajagopal & Shri Girish Agrawalassessment Year: 2014-15

For Appellant: Shri K.A. Vaidyalingan, ARFor Respondent: Shri Ram Krishn Kedia, Sr. DR
Section 133ASection 143(3)Section 50CSection 56Section 69

…IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH MUMBAI BEFORE MS KAVITHA RAJAGOPAL, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER Assessment Year: 2014-15 Narayanbhai Manjibhai Bodriya Income Tax Officer – B-13, Vinayak Heights, 41(3)(3), Upper Govind Nagar, Mumbai Vs. Kailshpuri, Malad East, Mumbai – 400097 (PAN : AKTPB6156F) (Appellant) (Respondent) Present for: Assessee : Shri K.A. Vaidyalingan, AR Revenue : Shri Ram Krishn Kedia, Sr. DR Date of Hearing : 07.03.2025 Date of Pronouncement : 30.05.2025 O R D E R PER GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the assessee is aga…

ACIT CC -6(1), Mumbai, Bkc vs. Rucha Consultancy LLP, Pune

In the result, the appeal filed by the assessee is allowed and the appeal of the Revenue is dismissed

ITA 5706/MUM/2024[2021-22]Status: DisposedITAT Mumbai07 Apr 2025AY 2021-22

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

For Appellant: Shri Nishit GandhiFor Respondent: Smt. Sanyogita Nagpal, CIT-DR
Section 132Section 139(4)Section 143(2)Section 148Section 65BSection 69A

…hri Ketan O. Der partner of Ohm Developers, there was no other evidence to show that assessee had in fact paid any 'on money' for purchase of flat. He relied upon the decision of Hon'ble Bombay High Court in the case of Addl CIT v. Miss Lata Mangeshkar [1974] 97 ITR 696 (Bom) wherein it was held as under: "3. In our view, the question has been framed by the Department so as to give it a colour of a question of law, for, in our view, having regard to the manner in which the Tribunal has dealt with the said entries, it cannot be said that the Tribunal has ignored the entries in the ledger of Vasu Films relating to…

Rucha Consultancy LLP, Pune vs. DCIT CC 6(1), Mumbai

In the result, the appeal filed by the assessee is allowed and the appeal of the Revenue is dismissed

ITA 4996/MUM/2024[2021-2022]Status: DisposedITAT Mumbai07 Apr 2025AY 2021-2022

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

For Appellant: Shri Nishit GandhiFor Respondent: Smt. Sanyogita Nagpal, CIT-DR
Section 132Section 139(4)Section 143(2)Section 148Section 65BSection 69A

…hri Ketan O. Der partner of Ohm Developers, there was no other evidence to show that assessee had in fact paid any 'on money' for purchase of flat. He relied upon the decision of Hon'ble Bombay High Court in the case of Addl CIT v. Miss Lata Mangeshkar [1974] 97 ITR 696 (Bom) wherein it was held as under: "3. In our view, the question has been framed by the Department so as to give it a colour of a question of law, for, in our view, having regard to the manner in which the Tribunal has dealt with the said entries, it cannot be said that the Tribunal has ignored the entries in the ledger of Vasu Films relating to…

ACIT CC -6(1), Mumbai, Bkc vs. Rajendra Sawaleram Rahane, Sangamner, Maharashtra

In the result, appeals filed by Revenue in case of both the assessees are dismissed

ITA 5668/MUM/2024[2021-22]Status: DisposedITAT Mumbai04 Apr 2025AY 2021-22

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2021-22

For Appellant: Shri Rashmikant Modi and Ms. Ketki Rajeshike, CAsFor Respondent: Smt. Sanyogita Nagpal, CIT DR
Section 132Section 132(4)Section 143(3)Section 148Section 69C

…the AO on the information received from the search on third party. Thus, the aforesaid decisions are not applicable to the present case. 13. Before concluding, gainful reference can be made to the decision in the case of ACIT v/s Miss Lata Mangeshkar, [1974] 97 ITR 696 (Bom.), wherein while dismissing the Revenue’s appeal in a case wherein additions were made on the basis of documents seized and statements recorded from the third party, the Hon’ble Jurisdictional High Court observed as follows: – “The Income-tax Officer came across a sort of a ledger maintained by the firm known as Vasu Films of Madras containi…

ACIT CC -6(1), Mumbai, Bkc vs. Ranjit Rajaram Hande, Solapur

In the result, appeals filed by Revenue in case of both the assessees are dismissed

ITA 5621/MUM/2024[2021-22]Status: DisposedITAT Mumbai04 Apr 2025AY 2021-22

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2021-22

For Appellant: Shri Rashmikant Modi and Ms. Ketki Rajeshike, CAsFor Respondent: Smt. Sanyogita Nagpal, CIT DR
Section 132Section 132(4)Section 143(3)Section 148Section 69C

…the AO on the information received from the search on third party. Thus, the aforesaid decisions are not applicable to the present case. 13. Before concluding, gainful reference can be made to the decision in the case of ACIT v/s Miss Lata Mangeshkar, [1974] 97 ITR 696 (Bom.), wherein while dismissing the Revenue’s appeal in a case wherein additions were made on the basis of documents seized and statements recorded from the third party, the Hon’ble Jurisdictional High Court observed as follows: – “The Income-tax Officer came across a sort of a ledger maintained by the firm known as Vasu Films of Madras containi…

Income Tax Officer, Jamnagar vs. Nilesh Bipinchandra Mehta, Jamnagar

In the result, the appeal of the assessee is allowed

ITA 750/RJT/2024[2011-12]Status: DisposedITAT Rajkot02 Apr 2025AY 2011-12

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No. 750 /Rjt/ 2024 (निर्धारण वर्ष / Assessment Year: (2011-12) (Hybrid Hearing) The Ito, Jamnagar Vs. Nilesh Bipinchandra Mehta Prop. Of B. J. Industries Tej Prakash Society, P. N. Marg Jamnagar 361001, Gujarat India स्थायी लेखासं./जीआइआरसं./Pan/Gir No.: Aaqpm8295H (Appellant) (Respondent) Appellant By : Shri Chetan Agarwal, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख / Date Of Hearing : 07/01/2025 घोषणा की तारीख/Date Of Pronouncement : 02/04/2025 आदेश / Order Per Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee Is Directed Against The Order Passed By The National Faceless Appeal Centre [(In Short “Nfac/Ld. Cit(A)”] Vide Order Dated 21.08.2024, Which In Turn Assessment Order Passed By Assessment Unit, Income Tax Department / Assessing Officer Under Section 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (In Short “The Act"). 1

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 143(3)Section 147Section 148

…ow about parties who have deposited the amount. Since the said amount represents out of books sales/sale consideration of businessmen of Jamnagar, hence liable to pay taxes on them". The counsel for the assessee relied upon the case of ACIT v. Lata Mangeshkar 97 ITR 696, wherein it was held that entries made in the accounts of third-party regarding payment to the assessee is not sufficient as there is no guarantee that the entries were genuine in absence of any corroborative evidence. The counsel for the assessee submitted that the statement of Shri Dharmendra Doshi was accepted by the ADIT at face value, without…

ACIT CC -6(1), Mumbai, Bkc vs. Prashant Prakash Nilawar, Pnue

In the result, appeal of the assessee is partly allowed

ITA 5689/MUM/2024[2021-22]Status: DisposedITAT Mumbai12 Feb 2025AY 2021-22

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2021-22

For Appellant: Shri Nishit Gandhi, ARFor Respondent: Shri Amol Kirtane,CIT-DR and Shri Mahesh Pamnani, Sr.DR
Section 132Section 143(2)Section 143(3)Section 148Section 65BSection 69ASection 69CSection 6C

…gs recorded by the AO is purely on suspicion and surmises manner without any evidences to justify his findings. 9.5. Keeping the context of material found and seized from third parties, we also refer to decision in the case of ACIT vs. Lata Mangeshkar [1974] 97 ITR 696 (Bom) wherein Hon'ble Court has extensively discussed the importance and meaning of primary evidence. In this case, Income-tax authorities came across a sort of a ledger maintained by a firm known as Vasu Films of Madras which was seized by them. Department relied on the entries in the ledger which allegedly reflected payments to Ms. Lata Mangeshk…

Prashant Prakash Nilawar, Pune vs. DCIT CC 6(1)-Mumbai, Mumbai

In the result, appeal of the assessee is partly allowed

ITA 5073/MUM/2024[2021-2022]Status: DisposedITAT Mumbai12 Feb 2025AY 2021-2022

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2021-22

For Appellant: Shri Nishit Gandhi, ARFor Respondent: Shri Amol Kirtane,CIT-DR and Shri Mahesh Pamnani, Sr.DR
Section 132Section 143(2)Section 143(3)Section 148Section 65BSection 69ASection 69CSection 6C

…gs recorded by the AO is purely on suspicion and surmises manner without any evidences to justify his findings. 9.5. Keeping the context of material found and seized from third parties, we also refer to decision in the case of ACIT vs. Lata Mangeshkar [1974] 97 ITR 696 (Bom) wherein Hon'ble Court has extensively discussed the importance and meaning of primary evidence. In this case, Income-tax authorities came across a sort of a ledger maintained by a firm known as Vasu Films of Madras which was seized by them. Department relied on the entries in the ledger which allegedly reflected payments to Ms. Lata Mangeshk…

DCIT CC 1(1), Nagpur vs. Brindesh Goverdhandas Agrawal, Nagpur

In the result, appeal by the Revenue stands dismissed

ITA 258/NAG/2023[2017-18]Status: DisposedITAT Nagpur10 Feb 2025AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mukesh AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 132Section 139(1)Section 143(1)Section 143(3)Section 153CSection 69

…session the document was found. This is in gross violation of the principles of natural justice and, therefore, the addition is illegal and unsustainable in law. In this context assessee relies on judgment in the case of Addl. CIT. Miss Late Mangeshkar [1974] 97 ITR 696 (Bom.) wherein it was held that, "Revenue has got a tendency to make an addition on the basis of entries appearing in the books of a third party or a statement recorded from a third party or loose papers seized from a third party. In all such cases, it is imperative to afford an opportunity to the assesse a cross-examine the said third party." 4.2…

Asstt. Commissioner of Incomet Ax Central Circle-1(1), Nagpur vs. Shri Sanjay Gaurishankar Agrawal, Nagpur

In the result, appeal by the Revenue stands dismissed

ITA 148/NAG/2018[2015-2016]Status: DisposedITAT Nagpur10 Feb 2025AY 2015-2016

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kapil HiraniFor Respondent: Shri Sandipkumar Salunke
Section 132(4)Section 143(3)

…kar Developers v/s ACIT [ITA No. 581/ PN/08) "The presumption u/s. 132(4A) is applicable only against the person from whose possession the books of accounts or other documents were found and not against any other person." iii. ACIT v/s Lata Mangeshkar ((Bom.) 97 ITR 696] "Mere entries in the accounts regarding payment to the assessee was not sufficient as there was no guarantee that the entries were genuine in absence of any corroborative evidence." PRAYER: In view of above submissions, it is humbly requested before Your Honour to kindly delete the addition made in the Assessment Order of Rs. 5,33,55,000/- in the…

ACIT CC -6(1), Mumbai, Bkc vs. Atul Bhikaram Chavan, Aurangabad

In the result appeals filed by the revenue stands dismissed

ITA 5666/MUM/2024[2021-22]Status: DisposedITAT Mumbai31 Jan 2025AY 2021-22

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 132Section 148Section 69C

…/Mum/2024 A.Y. 2021-22 13 received from the search on third party. Thus, the aforesaid decisions are not applicable to the present case. 13. Before concluding, gainful reference can be made to the decision in the case of ACIT v/s Miss Lata Mangeshkar, [1974] 97 ITR 696 (Bom.), wherein while dismissing the Revenue’s appeal in a case wherein additions were made on the basis of documents seized and statements recorded from the third party, the Hon’ble Jurisdictional High Court observed as follows: – “The Income-tax Officer came across a sort of a ledger maintained by the firm known as Vasu Films of Madras containin…

ACIT CC -6(1), Mumbai, Bkc vs. Ajaykumar Baburao Bhosale, Ahmednagar

In the result appeals filed by the revenue stands dismissed

ITA 5663/MUM/2024[2021-22]Status: DisposedITAT Mumbai31 Jan 2025AY 2021-22

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 132Section 148Section 69C

…/Mum/2024 A.Y. 2021-22 13 received from the search on third party. Thus, the aforesaid decisions are not applicable to the present case. 13. Before concluding, gainful reference can be made to the decision in the case of ACIT v/s Miss Lata Mangeshkar, [1974] 97 ITR 696 (Bom.), wherein while dismissing the Revenue’s appeal in a case wherein additions were made on the basis of documents seized and statements recorded from the third party, the Hon’ble Jurisdictional High Court observed as follows: – “The Income-tax Officer came across a sort of a ledger maintained by the firm known as Vasu Films of Madras containin…

ACIT CC-6(1), Mumbai, Bkc vs. Sharad Nagnath Rajbhoj, Pune

In the result, the appeal by the Revenue is dismissed

ITA 5661/MUM/2024[2021-22]Status: DisposedITAT Mumbai24 Jan 2025AY 2021-22

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailacit, Central Circle – 6(1), Room No.445, 4Th Floor, Bkc, Mumbai – 400051 ............... Appellant Pan : Abapr6416N V/S Sharad Nagnath Rajbhoj, 502 Dsk Haiyali Phase-Ii, ……………… Respondent Modi Baug, Shivaji Nagar, Pune - 411005 Assessee By : Shri Rashmikant Modi Ms. Ketki Rajshirke Revenue By : Shri Dr. Kishor Dhule, Cit-Dr

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Dr. Kishor Dhule, CIT-DR
Section 132Section 132(4)Section 147Section 148Section 250Section 69ASection 69C

…the AO on the information received from the search on third party. Thus, the aforesaid decisions are not applicable to the present case. 13. Before concluding, gainful reference can be made to the decision in the case of ACIT v/s Miss Lata Mangeshkar, [1974] 97 ITR 696 (Bom.), wherein while dismissing the Revenue’s appeal in a case wherein additions were made on the basis of documents seized and statements recorded from the third party, the Hon’ble Jurisdictional High Court observed as follows: – “The Income-tax Officer came across a sort of a ledger maintained by the firm known as Vasu Films of Madras containi…

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Ramasamy Natarajan, Trichy

In the result, both the appeals stand dismissed

ITA 2641/CHNY/2024[2015-16]Status: DisposedITAT Chennai22 Jan 2025AY 2015-16

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.2641/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2015-16) Acit Shri Ramasamy Natarajan बनाम Central Circle-2 # 255, Ganapathy Nagar South, / Vs. Trichy. T.V. Kovil Trichy-620005. "थायीलेखासं./ जीआइआरसं./Pan/Gir No. Aabpn-8486-E (अपीलाथ"/Appellant) : (" थ" / Respondent) & 2. आयकरअपील सं./ Ita No.2640/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2016-17) Acit Shri Jayaraman Muthureddiar बनाम #14, Akila Gardens, 1St Street, Central Circle-2 Trichy. Ganapathy Nagar, T.V.Kovil / Vs. Trichy-620005. "थायीलेखासं./ जीआइआरसं./Pan/Gir No. Aadhj-0819-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओर से/ Revenue By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr " थ" की ओर से/ Assessee By : Shri Y. Sridhar (Fca) & Ms. Varshha Sridhar (Ca)-Ld. Ars सुनवाई की तारीख/Date Of Hearing : 02-01-2025 घोषणा की तारीख /Date Of Pronouncement : 22-01-2025 आदेश / O R D E R

For Appellant: Shri Y. Sridhar (FCA) & Ms. VarshhaFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR
Section 131Section 132Section 143(3)Section 153CSection 69

…e assessee also asserted that the presumption u/s 132(4A) is available only in respect of the person from whom the paper is seized and the same could not applied against the assessee as held by Hon/ble Bombay High Court in the case of CIT vs. Lata Mangeshkar (97 ITR 696). 4.6 The Ld. CIT(A) concurring with aforesaid submissions, noted that Ld. AO did not bring on record about the recording of statement from Smt. R. Ezhilarasi from whose residential premises the loose sheet was seized. The AO also did not bring on record as to who was the author of the recording made in the loose sheet. In such a case, the authent…

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Jayaraman Muthureddiar, Trichy

In the result, both the appeals stand dismissed

ITA 2640/CHNY/2024[2016-17]Status: DisposedITAT Chennai22 Jan 2025AY 2016-17

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.2641/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2015-16) Acit Shri Ramasamy Natarajan बनाम Central Circle-2 # 255, Ganapathy Nagar South, / Vs. Trichy. T.V. Kovil Trichy-620005. "थायीलेखासं./ जीआइआरसं./Pan/Gir No. Aabpn-8486-E (अपीलाथ"/Appellant) : (" थ" / Respondent) & 2. आयकरअपील सं./ Ita No.2640/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2016-17) Acit Shri Jayaraman Muthureddiar बनाम #14, Akila Gardens, 1St Street, Central Circle-2 Trichy. Ganapathy Nagar, T.V.Kovil / Vs. Trichy-620005. "थायीलेखासं./ जीआइआरसं./Pan/Gir No. Aadhj-0819-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओर से/ Revenue By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr " थ" की ओर से/ Assessee By : Shri Y. Sridhar (Fca) & Ms. Varshha Sridhar (Ca)-Ld. Ars सुनवाई की तारीख/Date Of Hearing : 02-01-2025 घोषणा की तारीख /Date Of Pronouncement : 22-01-2025 आदेश / O R D E R

For Appellant: Shri Y. Sridhar (FCA) & Ms. VarshhaFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR
Section 131Section 132Section 143(3)Section 153CSection 69

…e assessee also asserted that the presumption u/s 132(4A) is available only in respect of the person from whom the paper is seized and the same could not applied against the assessee as held by Hon/ble Bombay High Court in the case of CIT vs. Lata Mangeshkar (97 ITR 696). 4.6 The Ld. CIT(A) concurring with aforesaid submissions, noted that Ld. AO did not bring on record about the recording of statement from Smt. R. Ezhilarasi from whose residential premises the loose sheet was seized. The AO also did not bring on record as to who was the author of the recording made in the loose sheet. In such a case, the authent…

DCIT-CC-4(2), Mumbai vs. Rajesh Mafatlal Jain, Mumbai

In the result, (a) the appeals filed by the revenue for AY 2018-19 to 2020-21 are

ITA 3952/MUM/2023[2019-20]Status: DisposedITAT Mumbai26 Nov 2024AY 2019-20

Bench: Shri Br Baskaran () & Shri Raj Kumar Chauhan ()

Section 132Section 143(3)Section 69

…ith law. It is pertinent to mention that as per the record, the assessee has vehemently denied having made any cash payment of Rs.37 lakhs towards purchase of shop, over and above the price settled. In addition, in the case of "CIT V/s Lata Mangeshkar" (1974)(97 ITR 696)(Bom), relying on the evidence in the form of statement by two persons, to the effect that they had paid money in black to the assessee, as well as entries in the books belonging to them regarding the alleged payment, the AO made addition to the assessees total income as income from "undisclosed sources". The Tribunal, having found that the eviden…

Rajesh Jain, Mumbai vs. DCIT, Central Circle- 4(2), Mumbai

In the result, (a) the appeals filed by the revenue for AY 2018-19 to 2020-21 are dismissed

ITA 3842/MUM/2023[2020-2021]Status: DisposedITAT Mumbai26 Nov 2024AY 2020-2021

Bench: Shri Br Baskaran () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Rahul HakaniFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 132Section 143(3)Section 69

…ith law. It is pertinent to mention that as per the record, the assessee has vehemently denied having made any cash payment of Rs.37 lakhs towards purchase of shop, over and above the price settled. In addition, in the case of "CIT V/s Lata Mangeshkar" (1974)(97 ITR 696)(Bom), relying on the evidence in the form of statement by two persons, to the effect that they had paid money in black to the assessee, as well as entries in the books belonging to them regarding the alleged payment, the AO made addition to the assessee‟s total income as income from "undisclosed sources". The Tribunal, having found that the evide…

Rajesh Jain, Mumbai vs. DCIT, Central Circle- 4(2), Mumbai

In the result, (a) the appeals filed by the revenue for AY 2018-19 to 2020-21 are dismissed

ITA 3841/MUM/2023[2021-22]Status: DisposedITAT Mumbai26 Nov 2024AY 2021-22

Bench: Shri Br Baskaran () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Rahul HakaniFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 132Section 143(3)Section 69

…ith law. It is pertinent to mention that as per the record, the assessee has vehemently denied having made any cash payment of Rs.37 lakhs towards purchase of shop, over and above the price settled. In addition, in the case of "CIT V/s Lata Mangeshkar" (1974)(97 ITR 696)(Bom), relying on the evidence in the form of statement by two persons, to the effect that they had paid money in black to the assessee, as well as entries in the books belonging to them regarding the alleged payment, the AO made addition to the assessee‟s total income as income from "undisclosed sources". The Tribunal, having found that the evide…