CBI v. V.C. Shukla

3 SCC 410Supreme Court of India1998#161 most cited

What is CBI v. V.C. Shukla authority for?

Loose sheets of paper, excel sheets, or diaries, often referred to as 'dumb documents,' are wholly irrelevant as evidence and not admissible under Section 34 of the Evidence Act if they lack evidentiary value. Additions to income cannot be made solely based on such documents without corroborating, reliable, and admissible evidence supported by other circumstances.

442

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2003 to 2026.

Also referred to as

CBI v. V.C. Shukla · evidentiary value · loose sheets · dumb documents · Section 34 Evidence Act · Section 292C · admissibility of evidence · books of account · uncorroborated evidence · Section 132(4A)

Also reported as

138 Taxmann 1903 AIR 410

Sections most often in play

Section 143(3)Section 132Section 153CSection 292CSection 153ASection 132(4)Section 132(4A)Section 115BBE

Issues it is cited on

dumb documentssection 132(4a)section 292csection 34section 269tsection 158bdloose papersonus of proofsection 269sincome tax settlement commissiondocuments seizedsection 269ss

Judgments citing CBI v. V.C. Shukla

The ACIT, (Central)-1, Indore vs. M/S. Prakash Ashphlting & Toll Highway Ltd., Indore

Appeals are dismissed

ITA 798/IND/2019[2014-15]Status: DisposedITAT Indore31 Jan 2024AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 269SSection 271DSection 271E

…under consideration as "deaf & dumb document". The onus was solely on the AO to fill such vital gaps by bringing positive evidence on record and prove the allegation about alleged cash loans by the assessee, which he utterly failed to do so. CBI vs VC Shukla 3 SCC 410 The Hon'ble Supreme Court has held that loose sheets of paper cannot be termed as 'book' within the meaning of s. 34 of Evidence Act. It has also been held therein by the Hon'ble Supreme Court that even correct and authentic entries in books of account cannot, without independent evidence of their trustworthiness, fix a liability upon a person. The…

The ACIT, (Central)-1, Indore vs. M/S. Prakash Ashphlting & Toll Highway Ltd., Indore

Appeals are dismissed

ITA 797/IND/2019[2013-14]Status: DisposedITAT Indore31 Jan 2024AY 2013-14

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 269SSection 271DSection 271E

…under consideration as "deaf & dumb document". The onus was solely on the AO to fill such vital gaps by bringing positive evidence on record and prove the allegation about alleged cash loans by the assessee, which he utterly failed to do so. CBI vs VC Shukla 3 SCC 410 The Hon'ble Supreme Court has held that loose sheets of paper cannot be termed as 'book' within the meaning of s. 34 of Evidence Act. It has also been held therein by the Hon'ble Supreme Court that even correct and authentic entries in books of account cannot, without independent evidence of their trustworthiness, fix a liability upon a person. The…

The ACIT, (Central)-1, Indore vs. M/S. Prakash Ashphlting & Toll Highway Ltd., Indore

Appeals are dismissed

ITA 796/IND/2019[2012-13]Status: DisposedITAT Indore31 Jan 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 269SSection 271DSection 271E

…under consideration as "deaf & dumb document". The onus was solely on the AO to fill such vital gaps by bringing positive evidence on record and prove the allegation about alleged cash loans by the assessee, which he utterly failed to do so. CBI vs VC Shukla 3 SCC 410 The Hon'ble Supreme Court has held that loose sheets of paper cannot be termed as 'book' within the meaning of s. 34 of Evidence Act. It has also been held therein by the Hon'ble Supreme Court that even correct and authentic entries in books of account cannot, without independent evidence of their trustworthiness, fix a liability upon a person. The…

The ACIT, (Central)-1, Indore vs. M/S. Prakash Ashphlting & Toll Highway Ltd., Indore

Appeals are dismissed

ITA 795/IND/2019[2011-12]Status: DisposedITAT Indore31 Jan 2024AY 2011-12

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 269SSection 271DSection 271E

…under consideration as "deaf & dumb document". The onus was solely on the AO to fill such vital gaps by bringing positive evidence on record and prove the allegation about alleged cash loans by the assessee, which he utterly failed to do so. CBI vs VC Shukla 3 SCC 410 The Hon'ble Supreme Court has held that loose sheets of paper cannot be termed as 'book' within the meaning of s. 34 of Evidence Act. It has also been held therein by the Hon'ble Supreme Court that even correct and authentic entries in books of account cannot, without independent evidence of their trustworthiness, fix a liability upon a person. The…

The ACIT, (Central)-1, Indore vs. M/S. Prakash Ashphlting & Toll Highway Ltd., Indore

Appeals are dismissed

ITA 794/IND/2019[2010-11]Status: DisposedITAT Indore31 Jan 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 269SSection 271DSection 271E

…under consideration as "deaf & dumb document". The onus was solely on the AO to fill such vital gaps by bringing positive evidence on record and prove the allegation about alleged cash loans by the assessee, which he utterly failed to do so. CBI vs VC Shukla 3 SCC 410 The Hon'ble Supreme Court has held that loose sheets of paper cannot be termed as 'book' within the meaning of s. 34 of Evidence Act. It has also been held therein by the Hon'ble Supreme Court that even correct and authentic entries in books of account cannot, without independent evidence of their trustworthiness, fix a liability upon a person. The…

The ACIT, (Central)-1, Indore vs. M/S. Prakash Ashphlting & Toll Highway Ltd., Indore

Appeals are dismissed

ITA 793/IND/2019[2009-10]Status: DisposedITAT Indore31 Jan 2024AY 2009-10

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 269SSection 271DSection 271E

…under consideration as "deaf & dumb document". The onus was solely on the AO to fill such vital gaps by bringing positive evidence on record and prove the allegation about alleged cash loans by the assessee, which he utterly failed to do so. CBI vs VC Shukla 3 SCC 410 The Hon'ble Supreme Court has held that loose sheets of paper cannot be termed as 'book' within the meaning of s. 34 of Evidence Act. It has also been held therein by the Hon'ble Supreme Court that even correct and authentic entries in books of account cannot, without independent evidence of their trustworthiness, fix a liability upon a person. The…

ACIT(Central)-1, Indore vs. Shri Punit Agrawal, Mhow

Appeals are dismissed

ITA 791/IND/2019[2010-11]Status: DisposedITAT Indore31 Jan 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

Section 132Section 153ASection 269SSection 269TSection 271DSection 271E

…under consideration as "deaf & dumb document". The onus was solely on the AO to fill such vital gaps by bringing positive evidence on record and prove the allegation about alleged cash loans by the assessee, which he utterly failed to do so. CBI vs VC Shukla 3 SCC 410 The Hon'ble Supreme Court has held that loose sheets of paper cannot be termed as 'book' within the meaning of s. 34 of Evidence Act. It has also been held therein by the Hon'ble Supreme Court that even correct and authentic entries in books of account cannot, without independent evidence of their trustworthiness, fix a liability upon a person. The…

ACIT(Central)-1, Indore vs. Shri Punit Agrawal, Mhow

Appeals are dismissed

ITA 790/IND/2019[2009-10]Status: DisposedITAT Indore31 Jan 2024AY 2009-10

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

Section 132Section 153ASection 269SSection 269TSection 271DSection 271E

…under consideration as "deaf & dumb document". The onus was solely on the AO to fill such vital gaps by bringing positive evidence on record and prove the allegation about alleged cash loans by the assessee, which he utterly failed to do so. CBI vs VC Shukla 3 SCC 410 The Hon'ble Supreme Court has held that loose sheets of paper cannot be termed as 'book' within the meaning of s. 34 of Evidence Act. It has also been held therein by the Hon'ble Supreme Court that even correct and authentic entries in books of account cannot, without independent evidence of their trustworthiness, fix a liability upon a person. The…

ACIT(Central)-1, Indore vs. Shri Punit Agrawal, Mhow

Appeals are dismissed

ITA 789/IND/2019[2012-13]Status: DisposedITAT Indore31 Jan 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

Section 132Section 153ASection 269SSection 269TSection 271DSection 271E

…under consideration as "deaf & dumb document". The onus was solely on the AO to fill such vital gaps by bringing positive evidence on record and prove the allegation about alleged cash loans by the assessee, which he utterly failed to do so. CBI vs VC Shukla 3 SCC 410 The Hon'ble Supreme Court has held that loose sheets of paper cannot be termed as 'book' within the meaning of s. 34 of Evidence Act. It has also been held therein by the Hon'ble Supreme Court that even correct and authentic entries in books of account cannot, without independent evidence of their trustworthiness, fix a liability upon a person. The…

ACIT(Central)-1, Indore vs. Shri Punit Agrawal, Mhow

Appeals are dismissed

ITA 788/IND/2019[2010-11]Status: DisposedITAT Indore31 Jan 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

Section 132Section 153ASection 269SSection 269TSection 271DSection 271E

…under consideration as "deaf & dumb document". The onus was solely on the AO to fill such vital gaps by bringing positive evidence on record and prove the allegation about alleged cash loans by the assessee, which he utterly failed to do so. CBI vs VC Shukla 3 SCC 410 The Hon'ble Supreme Court has held that loose sheets of paper cannot be termed as 'book' within the meaning of s. 34 of Evidence Act. It has also been held therein by the Hon'ble Supreme Court that even correct and authentic entries in books of account cannot, without independent evidence of their trustworthiness, fix a liability upon a person. The…

ACIT(Central)-1, Indore vs. Shri Punit Agrawal, Mhow

Appeals are dismissed

ITA 787/IND/2019[2009-10]Status: DisposedITAT Indore31 Jan 2024AY 2009-10

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

Section 132Section 153ASection 269SSection 269TSection 271DSection 271E

…under consideration as "deaf & dumb document". The onus was solely on the AO to fill such vital gaps by bringing positive evidence on record and prove the allegation about alleged cash loans by the assessee, which he utterly failed to do so. CBI vs VC Shukla 3 SCC 410 The Hon'ble Supreme Court has held that loose sheets of paper cannot be termed as 'book' within the meaning of s. 34 of Evidence Act. It has also been held therein by the Hon'ble Supreme Court that even correct and authentic entries in books of account cannot, without independent evidence of their trustworthiness, fix a liability upon a person. The…

Rswm Ltd, Bhilwara vs. DCIT Central Circle-31, New Delhi

In the result, the Appeals filed by the assessee in ITA No

ITA 146/DEL/2021[2015-16]Status: DisposedITAT Delhi31 Jan 2024AY 2015-16

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.Ita Nos.145 & 146 /Del/2021 (Assessment Years 2014-15 & 2015-16)

Section 115JSection 14ASection 14A(2)Section 37(1)Section 40Section 69

…orroborative evidence to prove the authenticity of the seized material, the AO cannot make additions in assessee’s income on the basis of said loose paper. The assessee has relied on the following judicial pronouncements:- i) CBI v. V. C. Shukla & Ors. 1998 (3 SCC 410) (SC) ii) Common Cause v. UOI [2017] 394 ITR 220 (SC) iii) T. S. Venkatesan v. ACIT [2000] 74 ITD 298 (Cal.) M/s RSWM Ltd. vs. DCIT iv) D.S. Suresh v. ACIT (ITA No.462 & 463/Bang/2020, dated 22-02- 2021) v) Aurum Platz Pvt. Ltd. v. DCIT (2004 & 2005/Mum/2021, dated 20- 03-2023) 14. The Ld. Counsel for the assessee further submitted that, the ass…

Rswm Ltd, Bhilwara vs. DCIT Central Circle-31, New Delhi

In the result, the Appeals filed by the assessee in ITA No

ITA 145/DEL/2021[2014-15]Status: DisposedITAT Delhi31 Jan 2024AY 2014-15

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.Ita Nos.145 & 146 /Del/2021 (Assessment Years 2014-15 & 2015-16)

Section 115JSection 14ASection 14A(2)Section 37(1)Section 40Section 69

…orroborative evidence to prove the authenticity of the seized material, the AO cannot make additions in assessee’s income on the basis of said loose paper. The assessee has relied on the following judicial pronouncements:- i) CBI v. V. C. Shukla & Ors. 1998 (3 SCC 410) (SC) ii) Common Cause v. UOI [2017] 394 ITR 220 (SC) iii) T. S. Venkatesan v. ACIT [2000] 74 ITD 298 (Cal.) M/s RSWM Ltd. vs. DCIT iv) D.S. Suresh v. ACIT (ITA No.462 & 463/Bang/2020, dated 22-02- 2021) v) Aurum Platz Pvt. Ltd. v. DCIT (2004 & 2005/Mum/2021, dated 20- 03-2023) 14. The Ld. Counsel for the assessee further submitted that, the ass…

DCIT Central Circle-31, New Delhi vs. Rswm Ltd, Kharigram

In the result, the Appeals filed by the assessee in ITA No

ITA 1929/DEL/2020[2015-16]Status: DisposedITAT Delhi31 Jan 2024AY 2015-16

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.Ita Nos.145 & 146 /Del/2021 (Assessment Years 2014-15 & 2015-16)

Section 115JSection 14ASection 14A(2)Section 37(1)Section 40Section 69

…orroborative evidence to prove the authenticity of the seized material, the AO cannot make additions in assessee’s income on the basis of said loose paper. The assessee has relied on the following judicial pronouncements:- i) CBI v. V. C. Shukla & Ors. 1998 (3 SCC 410) (SC) ii) Common Cause v. UOI [2017] 394 ITR 220 (SC) iii) T. S. Venkatesan v. ACIT [2000] 74 ITD 298 (Cal.) M/s RSWM Ltd. vs. DCIT iv) D.S. Suresh v. ACIT (ITA No.462 & 463/Bang/2020, dated 22-02- 2021) v) Aurum Platz Pvt. Ltd. v. DCIT (2004 & 2005/Mum/2021, dated 20- 03-2023) 14. The Ld. Counsel for the assessee further submitted that, the ass…

DCIT Central Circle-31, New Delhi vs. Rswm Ltd, Kharigram

In the result, the Appeals filed by the assessee in ITA No

ITA 1928/DEL/2020[2014-15]Status: DisposedITAT Delhi31 Jan 2024AY 2014-15

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.Ita Nos.145 & 146 /Del/2021 (Assessment Years 2014-15 & 2015-16)

Section 115JSection 14ASection 14A(2)Section 37(1)Section 40Section 69

…orroborative evidence to prove the authenticity of the seized material, the AO cannot make additions in assessee’s income on the basis of said loose paper. The assessee has relied on the following judicial pronouncements:- i) CBI v. V. C. Shukla & Ors. 1998 (3 SCC 410) (SC) ii) Common Cause v. UOI [2017] 394 ITR 220 (SC) iii) T. S. Venkatesan v. ACIT [2000] 74 ITD 298 (Cal.) M/s RSWM Ltd. vs. DCIT iv) D.S. Suresh v. ACIT (ITA No.462 & 463/Bang/2020, dated 22-02- 2021) v) Aurum Platz Pvt. Ltd. v. DCIT (2004 & 2005/Mum/2021, dated 20- 03-2023) 14. The Ld. Counsel for the assessee further submitted that, the ass…

DCIT Central Circle 2(1), Chennai vs. M/S Appu Food Products, Cuddalore Chennai

ITA 667/CHNY/2023[2019-20]Status: DisposedITAT Chennai24 Jan 2024AY 2019-20

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita Nos.: 663, 664 & 667/Chny/2023 & Co Nos.: 30, 31 & 32/Chny/2023 िनधा"रणवष" / Assessment Years: 2017-18, 2018-19 &2019-20 Deputy Commissioner Of Income M/S. Appu Food Products, Tax, V. K-1, Sidco Industrial Estates, Central Circle 2(1), Vadalur, Cuddalore – 607 303. Room No. B3, Ground Floor, [Pan: Aabfa-1499-G] Investigation Building, Chennai – 34. (अपीलाथ"/Appellant) (Respondent/Cross Objector) अपीलाथ"क"ओरसे/Appellant By : Shri. Nilay Baran Som, Cit Respondent/Cross Objector By : Shri. M. V. Prasad, Ca सुनवाई क" तारीख/Date Of Hearing : 21.12.2023 घोषणा क" तारीख/Date Of Pronouncement : 24.01.2024

For Appellant: Shri. Nilay Baran Som, CIT
Section 132

…has furnished detailed written submissions on the issue along with certain judicial precedents :-11-: ITA. Nos: 663, 664 & 667/Chny/2023 & CO Nos: 30, 31 & 32/Chny/2023 including the decision of Hon’ble Supreme Court in the case of CBI vs V.C. Shukla [1998] 3 SCC 410 and in Common Cause (A Registered Society) vs Union of India and argued that, additions made by the Assessing Officer u/s. 69A of the Act, on the basis of loose sheets found in the possession of third party without confronting those loose sheets to the appellant is not sustainable. The appellant had also furnished details with regard to the alleged…

DCIT Central Circle 2(1), Chennai vs. M/S. Appu Direct Pvt. Ltd., Cuddalore

ITA 666/CHNY/2023[2018-19]Status: DisposedITAT Chennai24 Jan 2024AY 2018-19

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita Nos.: 665 & 666/Chny/2023 & Co Nos.: 37 & 38/Chny/2023 िनधा"रणवष" / Assessment Years: 2017-18 & 2018-19 Deputy Commissioner Of Income M/S. Appu Direct Pvt Ltd., Tax, V. S.No. 544/4A, 4B Opposite To Central Circle 2(1), National College, Kumbakonam, Room No. B3, Ground Floor, Panruti, Cuddalore – 607 103. Investigation Building, [Pan: Aawcs-9382-A] Chennai – 34. (अपीलाथ"/Appellant) (Respondent/Cross Objector) अपीलाथ"क"ओरसे/Appellant By : Shri. Nilay Baran Som, Cit Respondent/Cross Objector By : Shri. M. V. Prasad, Ca सुनवाई क" तारीख/Date Of Hearing : 21.12.2023 घोषणा क" तारीख/Date Of Pronouncement : 24.01.2024

For Appellant: Shri. Nilay Baran Som, CIT
Section 132

…dated 07.03.2023. During the course of appellant proceedings, the assessee has furnished detailed written submissions on the issue along with certain judicial precedents including the decision of Hon’ble Supreme Court in the case of CBI vs V.C. Shukla [1998] 3 SCC 410 and in Common Cause (A Registered Society) vs Union of India and argued that, additions made by the Assessing Officer u/s. 69A of the Act, on the basis of loose sheets found in the possession of third party without confronting those loose sheets to the appellant is not sustainable. The appellant had also furnished details with regard to the alleged…

DCIT Central Circle 2(1), Chennai vs. M/S. Appu Direct Pvt. Ltd., Cuddalore

ITA 665/CHNY/2023[2017-18]Status: DisposedITAT Chennai24 Jan 2024AY 2017-18

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita Nos.: 665 & 666/Chny/2023 & Co Nos.: 37 & 38/Chny/2023 िनधा"रणवष" / Assessment Years: 2017-18 & 2018-19 Deputy Commissioner Of Income M/S. Appu Direct Pvt Ltd., Tax, V. S.No. 544/4A, 4B Opposite To Central Circle 2(1), National College, Kumbakonam, Room No. B3, Ground Floor, Panruti, Cuddalore – 607 103. Investigation Building, [Pan: Aawcs-9382-A] Chennai – 34. (अपीलाथ"/Appellant) (Respondent/Cross Objector) अपीलाथ"क"ओरसे/Appellant By : Shri. Nilay Baran Som, Cit Respondent/Cross Objector By : Shri. M. V. Prasad, Ca सुनवाई क" तारीख/Date Of Hearing : 21.12.2023 घोषणा क" तारीख/Date Of Pronouncement : 24.01.2024

For Appellant: Shri. Nilay Baran Som, CIT
Section 132

…dated 07.03.2023. During the course of appellant proceedings, the assessee has furnished detailed written submissions on the issue along with certain judicial precedents including the decision of Hon’ble Supreme Court in the case of CBI vs V.C. Shukla [1998] 3 SCC 410 and in Common Cause (A Registered Society) vs Union of India and argued that, additions made by the Assessing Officer u/s. 69A of the Act, on the basis of loose sheets found in the possession of third party without confronting those loose sheets to the appellant is not sustainable. The appellant had also furnished details with regard to the alleged…

DCIT Central Circle 2(1), Chennai vs. M/S Appu Food Products, Cuddalore Chennai

ITA 664/CHNY/2023[2018-19]Status: DisposedITAT Chennai24 Jan 2024AY 2018-19

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita Nos.: 663, 664 & 667/Chny/2023 & Co Nos.: 30, 31 & 32/Chny/2023 िनधा"रणवष" / Assessment Years: 2017-18, 2018-19 &2019-20 Deputy Commissioner Of Income M/S. Appu Food Products, Tax, V. K-1, Sidco Industrial Estates, Central Circle 2(1), Vadalur, Cuddalore – 607 303. Room No. B3, Ground Floor, [Pan: Aabfa-1499-G] Investigation Building, Chennai – 34. (अपीलाथ"/Appellant) (Respondent/Cross Objector) अपीलाथ"क"ओरसे/Appellant By : Shri. Nilay Baran Som, Cit Respondent/Cross Objector By : Shri. M. V. Prasad, Ca सुनवाई क" तारीख/Date Of Hearing : 21.12.2023 घोषणा क" तारीख/Date Of Pronouncement : 24.01.2024

For Appellant: Shri. Nilay Baran Som, CIT
Section 132

…has furnished detailed written submissions on the issue along with certain judicial precedents :-11-: ITA. Nos: 663, 664 & 667/Chny/2023 & CO Nos: 30, 31 & 32/Chny/2023 including the decision of Hon’ble Supreme Court in the case of CBI vs V.C. Shukla [1998] 3 SCC 410 and in Common Cause (A Registered Society) vs Union of India and argued that, additions made by the Assessing Officer u/s. 69A of the Act, on the basis of loose sheets found in the possession of third party without confronting those loose sheets to the appellant is not sustainable. The appellant had also furnished details with regard to the alleged…

DCIT Central Circle 2(1), Chennai vs. M/S Appu Food Products, Cuddalore Chennai

ITA 663/CHNY/2023[2017-18]Status: DisposedITAT Chennai24 Jan 2024AY 2017-18

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita Nos.: 663, 664 & 667/Chny/2023 & Co Nos.: 30, 31 & 32/Chny/2023 िनधा"रणवष" / Assessment Years: 2017-18, 2018-19 &2019-20 Deputy Commissioner Of Income M/S. Appu Food Products, Tax, V. K-1, Sidco Industrial Estates, Central Circle 2(1), Vadalur, Cuddalore – 607 303. Room No. B3, Ground Floor, [Pan: Aabfa-1499-G] Investigation Building, Chennai – 34. (अपीलाथ"/Appellant) (Respondent/Cross Objector) अपीलाथ"क"ओरसे/Appellant By : Shri. Nilay Baran Som, Cit Respondent/Cross Objector By : Shri. M. V. Prasad, Ca सुनवाई क" तारीख/Date Of Hearing : 21.12.2023 घोषणा क" तारीख/Date Of Pronouncement : 24.01.2024

For Appellant: Shri. Nilay Baran Som, CIT
Section 132

…has furnished detailed written submissions on the issue along with certain judicial precedents :-11-: ITA. Nos: 663, 664 & 667/Chny/2023 & CO Nos: 30, 31 & 32/Chny/2023 including the decision of Hon’ble Supreme Court in the case of CBI vs V.C. Shukla [1998] 3 SCC 410 and in Common Cause (A Registered Society) vs Union of India and argued that, additions made by the Assessing Officer u/s. 69A of the Act, on the basis of loose sheets found in the possession of third party without confronting those loose sheets to the appellant is not sustainable. The appellant had also furnished details with regard to the alleged…