Chand Soni v. DCIT

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE)- 3(1), KOLKATA, KOLKATA vs. AUXINITE SUPPLIERS PRIVATE LIMITED, KOLKATA

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

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Dy. Commissioner Of Income Auxinite Suppliers Private Tax (Cc)-3(1) Limited 4Th Floor, Aaykar Bhawan 44/2A Jain Tower, Hazra Road, Vs. Poorva, 110 Shantipally, Kolkata- Kolkata-700019, West Bengal 700017, West Bengal (Appellant) (Respondent) Pan No. Aaecb3974H Co No. 11/Kol/2025 (Arising In Ita No. 139/Kol/2025 For A.Y. 2019-20) Dy. Commissioner Of Income Auxinite Suppliers Private Tax (Cc)-3(1) Limited 4Th Floor, Aaykar Bhawan 44/2A Jain Tower, Hazra Road, Vs. Poorva, 110 Shantipally, Kolkata- Kolkata-700019, West Bengal 700017, West Bengal (Appellant) (Respondent) Assessee By : S/Shri Rajeeva Kumar & Giridhar Dhelia, Ars Revenue By : Shri V. Vidhyadhar, Dr Date Of Hearing: 11.02.2026 Date Of Pronouncement: 02.04.2026

…ion 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal ITA No. 139/KOL/2025 & CO No. 1/KOL/2025 Auxinite Suppliers Private Limited; A.Y. A.Y. 2019-20 in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) of the Act on a stand-alone basis, without reference to any other material discovered during search and seizure operation, would not empower the AO to make a block ass…

M/S. PEARL TRACOM PVT. LTD., ,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(1), , KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm M/S Pearl Tracom Pvt. Ltd. Dcit, Central Circle 3(1) C/O M/S Salarpuriajajodia& Co.7, Aaykar Bhawan, P-7, C.R. Avenue, 3Rd Floor, Chworinghee Square, Kolkata- Vs. Kolkata-700072, West Bengal 700069, West Bengal (Appellant) (Respondent) Pan No. Aabcp9934G Assessee By : Shri Siddarth Jhajharia, Ar Revenue By : Shri Sanat Kumar Raha, Dr Date Of Hearing: 02.04.2026 Date Of Pronouncement: 02.04.2026

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) of the Act on a stand-alone basis, without reference to any other material discovered during search and seizure operation, would not empower the AO to make a block ass…

KRYPTON DISTRIBUTORS LLP (EARLIER KNOWN AS KRYPTON DISTRIBUTORS PVT. LTD.,),KOLKATA vs. ITO, WARD 12(1),, KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Krypton Distributors Llp (Earlier Known As Krypton Ito, Ward 12(1), Distributors P. Ltd.) Aaykar Bhawan, P-7, Flat No.1A, 1, Abdul Rasul Chowringhee Square, Vs. Avenue, Kalighat, Kolkata-700069, West Bengal Kolkata-700026, West Bengal (Appellant) (Respondent) Pan No. Aadck5298G Assessee By : Shri Manoj Katuruka, Ar Revenue By : Shri Pankaj Pandey, Dr Date Of Hearing: 13.11.2025 Date Of Pronouncement: 02.12.2025

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) ofthe Act on a stand-alone basis, without reference to any other material discovered during search and seizure operation, would not empower the AO to make a block asse…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. SHREE RAMCHANDRA INGOT INDIA PRIVATE LIMITED, KOLKATA

In the result, all six appeals of the assessee are allowed and all six appeals of the revenue are dismissed

Bench: S/Shriand Rajesh Kumar & Pradip Kumar Choubeyita No.1363/Kol/2025: Assessment Year: 2017-18

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) ofthe Act on a stand-alone basis, without P a g e 21 | 29 Shree Ramchandra Ingot India Pvt Ltd., reference to any other material discovered during search and seizur…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. SHREE RAMCHANDRA INGOT INDIA PRIVATE LIMITED, KOLKATA

In the result, all six appeals of the assessee are allowed and all six appeals of the revenue are dismissed

Bench: S/Shriand Rajesh Kumar & Pradip Kumar Choubeyita No.1363/Kol/2025: Assessment Year: 2017-18

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) ofthe Act on a stand-alone basis, without P a g e 21 | 29 Shree Ramchandra Ingot India Pvt Ltd., reference to any other material discovered during search and seizur…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. SHREE RAMCHANDRA INGOT INDIA PRIVATE LIMITED, KOLKATA

In the result, all six appeals of the assessee are allowed and all six\nappeals of the revenue are dismissed

…ses of the assessee during the course of\nsearch, statement of assessee recorded under section\n132(4) would not have any evidentiary value. Similar\nview has been adopted by the Jaipur bench of the\nTribunal in the case of "Shree Chand Soni vs. DCIT"\n(2006) 101 TTJ 1028 (Jodhpur). The Hon'ble Delhi\nHigh Court in the case of “CIT vs. Harjeev Agarwal” in\nITA No.8/2004 vide order dated 10.03.16 has\nobserved that a statement made under section\n132(4) of the Act on a stand-alone basis, without\nreference to any other material discovered during\nsearch and seizure operation, would not empower the\nAO to make a bl…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. SHREE RAMCHANDRA INGOT INDIA PRIVATE LIMITED, KOLKATA

In the result, all six appeals of the assessee are allowed and all six appeals of the revenue are dismissed

Bench: S/Shriand Rajesh Kumar & Pradip Kumar Choubeyita No.1363/Kol/2025: Assessment Year: 2017-18

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) ofthe Act on a stand-alone basis, without P a g e 21 | 29 Shree Ramchandra Ingot India Pvt Ltd., reference to any other material discovered during search and seizur…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. SHREE RAMCHANDRA INGOT INDIA PRIVATE LIMITED, KOLKATA

In the result, all six appeals of the assessee are allowed and all six appeals of the revenue are dismissed

Bench: S/Shriand Rajesh Kumar & Pradip Kumar Choubeyita No.1363/Kol/2025: Assessment Year: 2017-18

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) ofthe Act on a stand-alone basis, without P a g e 21 | 29 Shree Ramchandra Ingot India Pvt Ltd., reference to any other material discovered during search and seizur…

SHREE RAMCHANDRA INGOT INDIA PVT. LTD.,KOLKATA vs. D.C.I.T., CC-4(3),, KOLKATA

In the result, all six appeals of the assessee are allowed and all six appeals of the revenue are dismissed

Bench: S/Shriand Rajesh Kumar & Pradip Kumar Choubeyita No.1363/Kol/2025: Assessment Year: 2017-18

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) ofthe Act on a stand-alone basis, without P a g e 21 | 29 Shree Ramchandra Ingot India Pvt Ltd., reference to any other material discovered during search and seizur…

SHREE RAMCHANDRA INGOT INDIA PVT. LTD.,KOLKATA vs. D.C.I.T., CC - 4(3),, KOLKATA

In the result, all six appeals of the assessee are allowed and all six appeals of the revenue are dismissed

Bench: S/Shriand Rajesh Kumar & Pradip Kumar Choubeyita No.1363/Kol/2025: Assessment Year: 2017-18

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) ofthe Act on a stand-alone basis, without P a g e 21 | 29 Shree Ramchandra Ingot India Pvt Ltd., reference to any other material discovered during search and seizur…

SHREE RAMCHANDRA INGOT INDIA PVT. LTD.,KOLKATA vs. D.C.I.T., CC-4(3), , KOLKATA

In the result, all six appeals of the assessee are allowed and all six\nappeals of the revenue are dismissed

…ses of the assessee during the course of\nsearch, statement of assessee recorded under section\n132(4) would not have any evidentiary value. Similar\nview has been adopted by the Jaipur bench of the\nTribunal in the case of "Shree Chand Soni vs. DCIT"\n(2006) 101 TTJ 1028 (Jodhpur). The Hon'ble Delhi\nHigh Court in the case of “CIT vs. Harjeev Agarwal” in\nITA No.8/2004 vide order dated 10.03.16 has\nobserved that a statement made under section\n132(4) of the Act on a stand-alone basis, without\nreference to any other material discovered during\nsearch and seizure operation, would not empower the\nAO to make a bl…

SHREE RAMCHANDRA INGOT INDIA PVT. LTD.,KOLKATA vs. D.C.I.T., CC-4(3),, KOLKATA

In the result, all six appeals of the assessee are allowed and all six appeals of the revenue are dismissed

Bench: S/Shriand Rajesh Kumar & Pradip Kumar Choubeyita No.1363/Kol/2025: Assessment Year: 2017-18

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) ofthe Act on a stand-alone basis, without P a g e 21 | 29 Shree Ramchandra Ingot India Pvt Ltd., reference to any other material discovered during search and seizur…

SHREE RAMCHANDRA INGOT INDIA PVT. LTD.,KOLKATA vs. D.C.I.T., CC - 4(3),, KOLKATA

In the result, all six appeals of the assessee are allowed and all six appeals of the revenue are dismissed

Bench: S/Shriand Rajesh Kumar & Pradip Kumar Choubeyita No.1363/Kol/2025: Assessment Year: 2017-18

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) ofthe Act on a stand-alone basis, without P a g e 21 | 29 Shree Ramchandra Ingot India Pvt Ltd., reference to any other material discovered during search and seizur…

SHREE RAMCHANDRA INGOT INDIA PVT. LTD.,KOLKATA vs. D.C.I.T., CC-4(3),, KOLKATA

In the result, all six appeals of the assessee are allowed and all six appeals of the revenue are dismissed

Bench: S/Shriand Rajesh Kumar & Pradip Kumar Choubeyita No.1363/Kol/2025: Assessment Year: 2017-18

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) ofthe Act on a stand-alone basis, without P a g e 21 | 29 Shree Ramchandra Ingot India Pvt Ltd., reference to any other material discovered during search and seizur…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 4(3), KOLKATA, KOLKATA vs. AVIMA EXPORTS PRIVATE LIMITED, KOLKATA

Accordingly the ground No. 2 is dismissed by upholding the order of Ld

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Dcit, Central Circle 4(3) Avima Exports Private Limited 4Th Ns Road, Dalhousie, Kolkata, 110, Shantipally, Vs. Kolkata-700107, West Bengal Kolkata-700001, West Bengal (Appellant) (Respondent) Pan No. Aagca5857N Assessee By : Shri Manish Tiwari, Ar Revenue By : Shri Raja Sengupta, Dr Date Of Hearing: 03.09.2025 Date Of Pronouncement: 11.11.2025

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) of the Act on a stand-alone basis, without reference to any other material discovered during search and seizure operation, would not empower the AO to make a block as…

ALCO SUPPLIERS PRIVATE LIMITED,GUWAHATI vs. ITO, WARD 1(1), KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Alco Suppliers Private Limited M/S Alco Suppliers (P) Ltd. National Faceless Assessment C/O Subhas Agarwal & Center, Associates (Advocate) Siddha Assessment Unit, Income Tax Vs. Gibson, 1, Gibson Lane, Suit Department, New Delhi No.213, 2Nd Floor, Kolkata- 700069, West Bengal (Appellant) (Respondent) Pan No. Aacca5182E Assessee By : Shri Siddarth Agarwal, Ar Revenue By : Shri Raja Sengupta, Dr Date Of Hearing: 04.09.2025 Date Of Pronouncement: 04.11.2025

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) of the Act on a stand-alone basis, without reference to any other material discovered during search and seizure operation, would not empower the AO to make a block ass…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. VIVEK GUPTA, KOLKATA

The appeal of the revenue is dismissed

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) of the Act on a stand-alone basis, without reference to any other material discovered during search and seizure operation, would not empower the AO to make a block as…

DEPUTY COMMSSIONER OF INCOME TAX, CENTRAL CIRCLE, 4(3), KOLKATA, KOLKATA vs. PRIVI EXPORTS PRIVATE LIMITED, KOLKATA

Accordingly the ground No. 2 is dismissed by upholding the order of Ld

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made 9 Privi Exports Private Limited under section 132(4) of the Act on a stand-alone basis, without reference to any other material discovered during search and seizure operation, would not…

SUPERDEAL RESOURCES PVT. LTD., ,KOLKATA vs. ITO, WARD 5(1), , KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Superdeal Resources Pvt. Ltd. Ito, Wad 5(1), Kolkata C/O Subash Agarwal & Ito, Ward 5(1), Associates, Advocates Sidha Aaykar Bhavan, P-7, Gibson, 1, Gibson Lane, Suite Vs. Chowringhee Square, 213, 2Nd Floor, Kolkata-700069 Kolkata-70069 West Bengal (Appellant) (Respondent) Pan No. Aadcs7472E Assessee By : Shri Siddarth Agarwal, Ar Revenue By : Shri Sanat Kumar Raha, Dr Date Of Hearing: 30.07.2025 Date Of Pronouncement: 16.09.2025

…premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have any evidentiary value. Similar view has been adopted by the Jaipur bench of the Tribunal in the case of “Shree Chand Soni vs. DCIT” (2006) 101 TTJ 1028 (Jodhpur). The Hon’ble Delhi High Court in the case of “CIT vs. Harjeev Agarwal” in ITA No.8/2004 vide order dated 10.03.16 has observed that a statement made under section 132(4) ofthe Act on a stand-alone basis, without reference to any other material discovered during search and seizure operation, would not empower the AO to make a block asse…