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 366,005 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

Skanda Developers & Builders, Kurnool vs. ACIT., Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 533/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…308 to 311/Hyd./2025. presumption u/sec.132(4A) (ii), in respect of the truth of contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of…

Skandhanshi Developers, Kurnool vs. ACIT., Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 527/HYD/2025[2020-21]Status: DisposedITAT Hyderabad20 Aug 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…308 to 311/Hyd./2025. presumption u/sec.132(4A) (ii), in respect of the truth of contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of…

Skanda Infra Projects, Kurnool vs. ACIT., Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 522/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…308 to 311/Hyd./2025. presumption u/sec.132(4A) (ii), in respect of the truth of contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of…

Skanda Infra Projects India Private Limited, Kurnool vs. ACIT., Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 517/HYD/2025[2022-23]Status: DisposedITAT Hyderabad20 Aug 2025AY 2022-23

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…308 to 311/Hyd./2025. presumption u/sec.132(4A) (ii), in respect of the truth of contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of…

Skanda Infra Projects India Private Limited, Kurnool vs. ACIT, Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 514/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…308 to 311/Hyd./2025. presumption u/sec.132(4A) (ii), in respect of the truth of contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of…

ACIT., Central Circle-2(3), Hyderabad vs. Skandhanshi Infra Projects India Pvt. Ltd., Bangalore

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 310/HYD/2025[2021-22]Status: DisposedITAT Hyderabad20 Aug 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…308 to 311/Hyd./2025. presumption u/sec.132(4A) (ii), in respect of the truth of contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of…

ACIT., Central Circle-2(3), Hyderabad vs. Skandhanshi Infra Projects India Pvt. Ltd., Bangalore

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 308/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…308 to 311/Hyd./2025. presumption u/sec.132(4A) (ii), in respect of the truth of contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of…

Assisstant Commissioner of Income Tax, Chennai vs. Bannariamman Educational Trust, Coimbatore

ITA 3357/CHNY/2024[2020]Status: DisposedITAT Chennai14 Aug 2025

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3310 To 3314/Chny/2024 िनधारणवष/Assessment Years: 2017-18 To 2021-22 M/S.Bannari Amman- Educational Trust, 1212, Trichy Road, Coimbatore-641 018. V. The Acit, Central Circle-3(2), Chennai. [Pan: Aaatb 1235 C] (अपीलाथ/Appellant) (यथ/Respondent) आयकर अपील सं./Ita Nos.3353 & 3354 To 3358/Chny/2024 िनधारणवष/Assessment Years: 2015-16 & 2017-18 To 2021-22 & Cross-Objection No.42/Chny/2025 (In Ita No.3353/Chny/2024) िनधारणवष/Assessment Year: 2015-16 The Acit, Central Circle-3(2), Chennai. V. M/S.Bannari Amman- Educational Trust, 1212, Trichy Road, Coimbatore-641 018. [Pan: Aaatb 1235 C] (अपीलाथ/Appellant) (यथ/Respondent/Cross Objector) Assessee By : Mr.Vikram Vijayaraghavan, Advocate (Virtual)/Ld.Ar Department By : Mr.Shiva Srinivasan, Cit/Dr सुनवाईकतारीख/Date Of Hearing : 27.06.2025 घोषणाकतारीख /Date Of Pronouncement : 14.08.2025

For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivasan, CIT/DR
Section 12ASection 132Section 133ASection 143(2)Section 153CSection 250

…asten tax liability on the person whose name appears therein, unless corroborative evidence is brought on record. This is a basic rule of prudence. 8.4 For this, we gainfully refer to the decision of the Hon'ble Supreme Court in the case of V.C. Shukla [1998] 3 SCC 410 wherein, on the evidentiary value of entries found in the books of account of a third party, it was held that such entry will not alone be sufficient evidence to charge any person with liability, even if they are relevant and admissible. It was ITA Nos.3310 to 3314/Chny/2024 (AYs 2017-18 to 2021-22) ITA Nos.3353 & 3354 to 3358/Chny/2024 (AYs 201…

Assisstant Commissioner of Income Tax, Chennai vs. Bannariamman Educational Trust, Coimbatore

ITA 3355/CHNY/2024[2018]Status: DisposedITAT Chennai14 Aug 2025
For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivasan, CIT/DR
Section 12ASection 132Section 133ASection 143(2)Section 153CSection 250

…n tax liability on the person whose name appears therein, unless corroborative evidence is brought on record. This is a basic rule of prudence. 8.4 For this, we gainfully refer to the decision of the Hon’ble Supreme Court in the case of V.C. Shukla [1998] 3 SCC 410 wherein, on the evidentiary value of entries found in the books of account of a third party, it was held that such entry will not alone be sufficient evidence to charge any person with liability, even if they are relevant and admissible. It was ITA Nos.3310 to 3314/Chny/2024 (AYs 2017-18 to 2021-22) ITA Nos.3353 & 3354 to 3358/Chny/2024 (A…

Assisstant Commissioner of Income Tax, Chennai vs. Bannariamman Educational Trust, Coimbatore

ITA 3353/CHNY/2024[2015]Status: DisposedITAT Chennai14 Aug 2025

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3310 To 3314/Chny/2024 िनधारणवष/Assessment Years: 2017-18 To 2021-22 M/S.Bannari Amman- Educational Trust, 1212, Trichy Road, Coimbatore-641 018. V. The Acit, Central Circle-3(2), Chennai. [Pan: Aaatb 1235 C] (अपीलाथ/Appellant) (यथ/Respondent) आयकर अपील सं./Ita Nos.3353 & 3354 To 3358/Chny/2024 िनधारणवष/Assessment Years: 2015-16 & 2017-18 To 2021-22 & Cross-Objection No.42/Chny/2025 (In Ita No.3353/Chny/2024) िनधारणवष/Assessment Year: 2015-16 The Acit, Central Circle-3(2), Chennai. V. M/S.Bannari Amman- Educational Trust, 1212, Trichy Road, Coimbatore-641 018. [Pan: Aaatb 1235 C] (अपीलाथ/Appellant) (यथ/Respondent/Cross Objector) Assessee By : Mr.Vikram Vijayaraghavan, Advocate (Virtual)/Ld.Ar Department By : Mr.Shiva Srinivasan, Cit/Dr सुनवाईकतारीख/Date Of Hearing : 27.06.2025 घोषणाकतारीख /Date Of Pronouncement : 14.08.2025

For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivasan, CIT/DR
Section 12ASection 132Section 133ASection 143(2)Section 153CSection 250

…en tax liability on the person whose name appears therein, unless corroborative evidence is brought on record. This is a basic rule of prudence. 8.4 For this, we gainfully refer to the decision of the Hon'ble Supreme Court in the case of V.C. Shukla [1998] 3 SCC 410 wherein, on the evidentiary value of entries found in the books of account of a third party, it was held that such entry will not alone be sufficient evidence to charge any person with liability, even if they are relevant and admissible. It was ITA Nos.3310 to 3314/Chny/2024 (AYs 2017-18 to 2021-22) ITA Nos.3353 & 3354 to 3358/Chny/2024 (AYs…

Bannariamman Educational Trust, Coimbatore vs. ACIT Central Circle 3(2), Chennai

ITA 3314/CHNY/2024[2021-22]Status: DisposedITAT Chennai14 Aug 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivasan, CIT/DR
Section 12ASection 132Section 133ASection 143(2)Section 153CSection 250

…tax liability on the person whose name appears therein, unless corroborative evidence is brought on record. This is a basic rule of prudence. 8.4 For this, we gainfully refer to the decision of the Hon’ble Supreme Court in the case of V.C. Shukla [1998] 3 SCC 410 wherein, on the evidentiary value of entries found in the books of account of a third party, it was held that such entry will not alone be sufficient evidence to charge any person with liability, even if they are relevant and admissible. It was ITA Nos.3310 to 3314/Chny/2024 (AYs 2017-18 to 2021-22) ITA Nos.3353 & 3354 to 3358/Chny/2024 (AYs…

Bannariamman Educational Trust, Coimbatore vs. ACIT Central Circle 3(2), Chennai

ITA 3311/CHNY/2024[2018-19]Status: DisposedITAT Chennai14 Aug 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3310 To 3314/Chny/2024 िनधारणवष/Assessment Years: 2017-18 To 2021-22 M/S.Bannari Amman- Educational Trust, 1212, Trichy Road, Coimbatore-641 018. V. The Acit, Central Circle-3(2), Chennai. [Pan: Aaatb 1235 C] (अपीलाथ/Appellant) (यथ/Respondent) आयकर अपील सं./Ita Nos.3353 & 3354 To 3358/Chny/2024 िनधारणवष/Assessment Years: 2015-16 & 2017-18 To 2021-22 & Cross-Objection No.42/Chny/2025 (In Ita No.3353/Chny/2024) िनधारणवष/Assessment Year: 2015-16 The Acit, Central Circle-3(2), Chennai. V. M/S.Bannari Amman- Educational Trust, 1212, Trichy Road, Coimbatore-641 018. [Pan: Aaatb 1235 C] (अपीलाथ/Appellant) (यथ/Respondent/Cross Objector) Assessee By : Mr.Vikram Vijayaraghavan, Advocate (Virtual)/Ld.Ar Department By : Mr.Shiva Srinivasan, Cit/Dr सुनवाईकतारीख/Date Of Hearing : 27.06.2025 घोषणाकतारीख /Date Of Pronouncement : 14.08.2025

For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivasan, CIT/DR
Section 12ASection 132Section 133ASection 143(2)Section 153CSection 250

…asten tax liability on the person whose name appears therein, unless corroborative evidence is brought on record. This is a basic rule of prudence. 8.4 For this, we gainfully refer to the decision of the Hon'ble Supreme Court in the case of V.C. Shukla [1998] 3 SCC 410 wherein, on the evidentiary value of entries found in the books of account of a third party, it was held that such entry will not alone be sufficient evidence to charge any person with liability, even if they are relevant and admissible. It was ITA Nos.3310 to 3314/Chny/2024 (AYs 2017-18 to 2021-22) ITA Nos.3353 & 3354 to 3358/Chny/2024 (AYs 2015-1…

Deputy Commissioner of Income Tax, Chennai vs. K S Palanisamy, Erode

In the result, the appeal filed by the Revenue is dismissed

ITA 660/CHNY/2025[2017-18]Status: DisposedITAT Chennai05 Aug 2025AY 2017-18

Bench: Shri George George Kand Ms. S. Padmavathyआयकरअपीलसं/.Ita No.660/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 The Deputy Commissioner Of K.S. Palanisamy, Income Tax, Vs. Kuppagounden Valasu, Central Circle - 2(4), Avalpoondurai, Erode 638 115. Chennai. [Pan: Ajipp-8193-Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. E. Pavuna Sundari, Cit ""यथ" क" ओर से/Respondent By : Shri Y. Sridhar, F.C.A. सुनवाई क" तारीख/Date Of Hearing : 23.07.2025 घोषणा क" तारीख/Date Of Pronouncement : 05.08.2025 आदेश /O R D E R Per George George K: This Appeal At The Instance Of The Revenue Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals) - 19, Chennai Dated 31.12.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Year Is 2017-18. 2. The Solitary Issue Raised In The Appeal Is With Regard To Deletion Of Addition Made On Account Of Alleged Receipts From M/S. Srs Mining.

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri Y. Sridhar, F.C.A
Section 132Section 132(4)Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 250Section 34

…ve any evidentiary value and the fact that search officials had not examined the assessee meant that the proceedings had been initiated on the basis of conjectures. 4. The assessee relied upon the decision in the case of V C Shukla in CBI v. V C Shukla (1998) 3 SCC 410 wherein section 34 of Evidence Act was used to dismiss the entries in a diary to be inadmissible evidence in the absence of any independent and corroborative material. 5. The assessee also sought cross examination of Sh. Srinivasulu and the partners of the Firm, M/s SRS Mining. The Assessing Officer, however, rejected the objections of the assessee…

DCIT Central Circle-2(2) Chennai, Chennai vs. Thangamani Perumal Gounder, Pallipalayam

In the result, both the appeals filed by the Revenue are dismissed

ITA 629/CHNY/2025[2016]Status: DisposedITAT Chennai04 Aug 2025

Bench: Shri George George Kand Ms. S. Padmavathyआयकरअपीलसं/.Ita Nos.:628 & 629/Chny/2025 िनधा"रणवष"/Assessment Years: 2015-16 & 2016-17 The Deputy Commissioner Of Thangamani Perumal Gounder, Income Tax, Vs. 5/6/183, Govindampalayam Central Circle - 2(2), Alampalayam, Pallipalayam 638 008. Chennai. [Pan: Abcpt-7700-K] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. E. Pavuna Sundari, Cit ""यथ" क" ओर से/Respondent By : Shri N. Arjun Raj, Advocate सुनवाई क" तारीख/Date Of Hearing : 23.07.2025 घोषणा क" तारीख/Date Of Pronouncement : 04.08.2025 आदेश /O R D E R Per George George K: These Two Appeals At The Instance Of The Revenue Are Directed Against Two Separate Orders Of The Commissioner Of Income Tax (Appeals) - 19, Chennai Both Dated 10.12.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2015-16 & 2016-17. 2. The Common Issue Involved In Both The Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. The Ita Nos.628 & 629/Chny/2025

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri N. Arjun Raj, Advocate
Section 132Section 132(4)Section 142(1)Section 143(2)Section 153CSection 250

…ipt of the payments as noted in the seized material". It is evident that such a burden has not been discharged by the revenue in the case of the Appellant. 6.4.26 As per the decisions of the Hon'ble Apex Court in the cases of CBI Vs. VC Shukla & Others (1998) 3 SCC 410, Common Cause (A Registered Society) Vs. Union of India (2017) 77 taxmann.com 254 (SC) and Dhakeshwari Cotton Mills Lids. CIT (1954) 26 ITR 775 (SC) corroborative evidence is essential to support the evidence found in third party premise In order to properly appreciate the issue, it is useful to refer to the following extract from the decision of H…

Assistant Commissioner of Income Tax (Central Circle)-1, Raipur vs. M/S. Chhatisgarh Distilleries Limited, Kolkata

In the result, appeal of the revenue in ITA No

ITA 103/RPR/2020[2017-18]Status: DisposedITAT Raipur31 Jul 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं./Ita No.103/Rpr/2020 Co No.15/Rpr/2023 "नधा"रण वष" / Assessment Year : 2017-18 The Assistant Commissioner Of Income Tax (Central Circle)-1, Raipur (C.G.)

For Appellant: Shri S.R Rao, AdvocateFor Respondent: Shri S.L Anuragi, Ld. CIT-DR
Section 115BSection 132Section 132(4)Section 153ASection 69C

…29 of LPS-2 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 “unaccounted sales” by the assessee, which he utterly failed to do so. CRI 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…

DCIT(CC)-8(3), Mumbai vs. Mehta Emporium Jewellers, Mumbai

In the result, appeal of the revenue is partly allowed for statistical purposes

ITA 2830/MUM/2025[2019-20]Status: DisposedITAT Mumbai21 Jul 2025AY 2019-20

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No.2830/Mum/2025 (निर्धारण वर्ा/Assessment Year :2019-20) Deputy Commissioner V/S. Mehta Emporium Of Income Tax- Central बिधम Jewellers Circle 8(3), Mumbai 101, Mehta Arch, S.V. Road, Room No. 656, 6Th Floor, Opp. Natraj Market, Malad Aayakar Bhavan, M.K. (West), Mumbai 400064 Road, Mumbai 400020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aalfm2962N Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी निर्ााररती की ओर से /Assessee By: Shri. Devendra Jain रधजस्व की ओर से /Revenue By: Shri. R.A. Dhyani, Cit Dr

For Appellant: Shri. Devendra JainFor Respondent: Shri. R.A. Dhyani, CIT DR
Section 132Section 143(3)Section 250Section 292CSection 69A

…orthwhile to note that the Courts have time and again examined the authenticity of such documents and have also examined whether addition could be made on the basis of such sheets. The ruling of Hon’ble Supreme court in the case of CBI Vs. V. C. Shukla (1998) 3 SCC 410/ 1998 Taxmann.com 2155 (SC); wherein the apex court of the country held that in order to constitute an evidence within the meaning of section 34 of Indian Evidence Act, it is manifest that to make an entry relevant thereunder it must be shown that it has been made in a book, that book is a book of account and that book of account has been regularly…

Homelife Buildcon Private Limited, Sunview Enclave, Ayali Kalan, Ludhiana, Punjab vs. Smt. Samandeep Kaur DCIT-Central Circle-1, Ludhiana, Punjab

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

ITA 880/CHANDI/2024[2021-2022]Status: DisposedITAT Chandigarh17 Jul 2025AY 2021-2022

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 880/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Ludhiana, Punjab-142027 स्थायी लेखा सं./PAN NO: AABCH5690M अपीलार्थी/Appellant बनाम The DCIT Central Circle-1 Ludhiana, Punjab प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 1036/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 बनाम Homelife Buildcon Private Limited Sunview Enclave, Ayali

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rohit Kapoor, C.AFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 153D

…d. and different Benches of the ITAT are very much relevant, besides the judgment of Sh. Ashwani Kumar Jain, as cited ‘supra’. 66. Reference maybe made in this context to the judgment of Hon’ble Supreme Court in the case of CBI Vs V.C, Shukla & Others (1998) 3 SCC 410, wherein, the Supreme Court considered as to whether the contents of the diary impounded from third party could lead to prove charge against the accused under the prevention of Corruption Act (1998). It was held that as per 53 section 132(4), a person from whom possession, such documents are found, the contents of such documents have to be conside…

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Homelife Buildcon Pvt. Ltd., Ludhiana

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

ITA 1036/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh17 Jul 2025AY 2021-22

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 880/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Ludhiana, Punjab-142027 स्थायी लेखा सं./PAN NO: AABCH5690M अपीलार्थी/Appellant The DCIT Central Circle-1 Ludhiana, Punjab प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 1036/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Lu

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rohit Kapoor, C.AFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 153D

…d. and different Benches of the ITAT are very much relevant, besides the judgment of Sh. Ashwani Kumar Jain, as cited ‘supra’. 66. Reference maybe made in this context to the judgment of Hon’ble Supreme Court in the case of CBI Vs V.C, Shukla & Others (1998) 3 SCC 410, wherein, the Supreme Court considered as to whether the contents of the diary impounded from third party could lead to prove charge against the accused under the prevention of Corruption Act (1998). It was held that as per 53 section 132(4), a person from whom possession, such documents are found, the contents of such documents have to be conside…

Rangamani Krishnan, Chennai vs. ACIT, Central Circle-1(2), Chennai

In the result all the five appeals filed by the assessee for the A

ITA 457/CHNY/2025[2019-20]Status: DisposedITAT Chennai17 Jul 2025AY 2019-20

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

For Appellant: Shri D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 131Section 142Section 142(1)Section 250Section 69

…t be used to draw adverse inference. Such documents, being loose, unauthenticated and unexplained, are of no evidentiary value." (para 14, 20 and 27 of the judgment) :-23-: ITA. Nos:453 to 457/Chny/2025 & SA Nos.41 to 45/Chny/2025 CBI v. V.C. Shukla [(1998) 3 SCC 410] "Loose sheets of paper or data files not forming part of books of account and not maintained in the regular course of business are not admissible as evidence. They are 'dumb documents' unless substantiated." 36. The ld.AR contended that applying the above principles to the present case, the Revenue’s reliance on the digital entry in the pen drive…

Rangamani Krishnan, Chennai vs. ACIT, Central Circle-1(2), Chennai

In the result all the five appeals filed by the assessee for the A

ITA 456/CHNY/2025[2018-19]Status: DisposedITAT Chennai17 Jul 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

For Appellant: Shri D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 131Section 142Section 142(1)Section 250Section 69

…t be used to draw adverse inference. Such documents, being loose, unauthenticated and unexplained, are of no evidentiary value." (para 14, 20 and 27 of the judgment) :-23-: ITA. Nos:453 to 457/Chny/2025 & SA Nos.41 to 45/Chny/2025 CBI v. V.C. Shukla [(1998) 3 SCC 410] "Loose sheets of paper or data files not forming part of books of account and not maintained in the regular course of business are not admissible as evidence. They are 'dumb documents' unless substantiated." 36. The ld.AR contended that applying the above principles to the present case, the Revenue’s reliance on the digital entry in the pen drive…