How many judgments cite Chand Soni v. DCIT?

58 judgments on BharatTax cite Chand Soni v. DCIT (101 TTJ 1028), spanning 2016 to 2026.

Which sections of the Income Tax Act does Chand Soni v. DCIT come up under?

It is most often cited in judgments turning on Section 68, Section 143(3), Section 133A, Section 131, Section 132(4), Section 132.

Chand Soni v. DCIT

101 TTJ 1028Income Tax Appellate Tribunal2006#1955 most cited

What is Chand Soni v. DCIT authority for?

A statement made by an assessee under section 132(4) during a search operation lacks evidentiary value if it is not supported by incriminating material found from the premises.

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2016 to 2026.

Also referred to as

Chand Soni v. DCIT · Shree Chand Soni vs. DCIT · Section 132(4) · Section 132 · evidentiary value of statement · statement during search · unsupported by incriminating material · standalone statement · admission during search · block assessment · surrender of income

Sections most often in play

Section 68 Section 143(3)Section 133A Section 131 Section 132(4)Section 132 Section 148 Section 147

Issues it is cited on

surrender of income section 142a section 150 mat credit retracted statement shell company accumulated profits section 158bd section 80ic section 134 section 2(22)section 142(2a)

Judgments citing Chand Soni v. DCIT

Deputy Commissioner of Income Tax (Central Circle)- 3(1), Kolkata vs. Auxinite Suppliers Private Limited, Kolkata

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

ITA 139/KOL/2025[2019-2020]Status: DisposedITAT Kolkata02 Apr 2026AY 2019-2020

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

For Appellant: S/Shri Rajeeva Kumar &For Respondent: Shri V. Vidhyadhar, DR

Section 132Section 133(6)Section 143(2)Section 153CSection 68

…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

ITA 1201/KOL/2025[2019-2020]Status: HeardITAT Kolkata02 Apr 2026AY 2019-2020

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

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: Shri Sanat Kumar Raha, DR

Section 133(6)Section 133ASection 143(3)Section 148Section 69C

…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

ITA 1733/KOL/2025[2013-2014]Status: DisposedITAT Kolkata02 Dec 2025AY 2013-2014

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

For Appellant: Shri Manoj Katuruka, ARFor Respondent: Shri Pankaj Pandey, DR

Section 139(1)Section 147Section 148Section 68

…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…

ACIT CC 2(3) Ahmedabad, Ahmedabad vs. Aisha Dhiraj Gogia, Ahmedabad

In the result: 50. To summarize the final outcome:

ITA 1673/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad28 Nov 2025AY 2018-19

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha["ी संजय गग", "ाियक सद" एवं "ी नरे" साद िस!ा, लेखा सद" के सम#।]

…the assessee during the course of search, statement of assessee recorded under section 132(4) of the Act 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 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

ITA 1555/KOL/2025[2020-21]Status: DisposedITAT Kolkata19 Nov 2025AY 2020-21

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

For Appellant: Shri Manish Rastogi, AdvFor Respondent: Shri Sanat Kumar Raha, CIT DR

Section 115JSection 132Section 139(1)Section 143(3)Section 147Section 148

…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 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

ITA 1554/KOL/2025[2019-20]Status: DisposedITAT Kolkata19 Nov 2025AY 2019-20

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

For Appellant: Shri Manish Rastogi, AdvFor Respondent: Shri Sanat Kumar Raha, CIT DR

Section 115JSection 132Section 139(1)Section 143(3)Section 147Section 148

…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 vs. Shree Ramchandra Ingot India Private Limited, Kolkata

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

ITA 1553/KOL/2025[2018-19]Status: DisposedITAT Kolkata19 Nov 2025AY 2018-19

Bench: S/Shriand Rajesh Kumar & Pradip Kumar Choubey

For Appellant: Shri Manish Rastogi, AdvFor Respondent: Shri Sanat Kumar Raha, CIT DR

Section 115JSection 132Section 139(1)Section 143(3)Section 147Section 148

…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 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

ITA 1552/KOL/2025[2017-18]Status: DisposedITAT Kolkata19 Nov 2025AY 2017-18

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

For Appellant: Shri Manish Rastogi, AdvFor Respondent: Shri Sanat Kumar Raha, CIT DR

Section 115JSection 132Section 139(1)Section 143(3)Section 147Section 148

…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 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

ITA 1551/KOL/2025[2016-17]Status: DisposedITAT Kolkata19 Nov 2025AY 2016-17

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

For Appellant: Shri Manish Rastogi, AdvFor Respondent: Shri Sanat Kumar Raha, CIT DR

Section 115JSection 132Section 139(1)Section 143(3)Section 147Section 148

…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

ITA 1368/KOL/2025[2016-2017]Status: DisposedITAT Kolkata19 Nov 2025AY 2016-2017

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

For Appellant: Shri Manish Rastogi, AdvFor Respondent: Shri Sanat Kumar Raha, CIT DR

Section 115JSection 132Section 139(1)Section 143(3)Section 147Section 148

…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

ITA 1367/KOL/2025[2021-2022]Status: DisposedITAT Kolkata19 Nov 2025AY 2021-2022

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

For Appellant: Shri Manish Rastogi, AdvFor Respondent: Shri Sanat Kumar Raha, CIT DR

Section 115JSection 132Section 139(1)Section 143(3)Section 147Section 148

…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

ITA 1366/KOL/2025[2020-2021]Status: DisposedITAT Kolkata19 Nov 2025AY 2020-2021

Bench: S/Shri & Rajesh Kumar & Pradip Kumar Choubey

For Appellant: Shri Manish Rastogi, AdvFor Respondent: Shri Sanat Kumar Raha, CIT DR

Section 115JSection 132Section 139(1)Section 143(3)Section 147Section 148

…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…

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

ITA 1365/KOL/2025[2019-2020]Status: DisposedITAT Kolkata19 Nov 2025AY 2019-2020

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

For Appellant: Shri Manish Rastogi, AdvFor Respondent: Shri Sanat Kumar Raha, CIT DR

Section 115JSection 132Section 139(1)Section 143(3)Section 147Section 148

…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

ITA 1364/KOL/2025[2018-2019]Status: DisposedITAT Kolkata19 Nov 2025AY 2018-2019

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

For Appellant: Shri Manish Rastogi, AdvFor Respondent: Shri Sanat Kumar Raha, CIT DR

Section 115JSection 132Section 139(1)Section 143(3)Section 147Section 148

…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

ITA 1363/KOL/2025[2017-2018]Status: DisposedITAT Kolkata19 Nov 2025AY 2017-2018

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

For Appellant: Shri Manish Rastogi, AdvFor Respondent: Shri Sanat Kumar Raha, CIT DR

Section 115JSection 132Section 139(1)Section 143(3)Section 147Section 148

…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 vs. Avima Exports Private Limited, Kolkata

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

ITA 1439/KOL/2025[2014-15]Status: DisposedITAT Kolkata11 Nov 2025AY 2014-15

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

For Appellant: Shri Manish Tiwari, ARFor Respondent: Shri Raja Sengupta, DR

Section 131Section 133ASection 143(3)Section 68

Alco Suppliers Private Limited, Guwahati vs. ITO, Ward 1(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 933/KOL/2025[2022-2023]Status: DisposedITAT Kolkata04 Nov 2025AY 2022-2023

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

For Appellant: Shri Siddarth Agarwal, ARFor Respondent: Shri Raja Sengupta, DR

Section 143(2)Section 143(3)Section 144BSection 68

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Vivek Gupta, Kolkata

The appeal of the revenue is dismissed

ITA 1557/KOL/2025[2013-14]Status: DisposedITAT Kolkata28 Oct 2025AY 2013-14

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

Section 131Section 133ASection 143(3)Section 195Section 250Section 40Section 68

Deputy Commssioner of Income Tax, Central Circle, 4(3), Kolkata vs. Privi Exports Private Limited, Kolkata

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

ITA 1456/KOL/2025[2017-18]Status: DisposedITAT Kolkata28 Oct 2025AY 2017-18

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

Section 131Section 133ASection 250Section 68

…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

ITA 726/KOL/2025[2022-2023]Status: DisposedITAT Kolkata16 Sept 2025AY 2022-2023

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

For Appellant: Shri Siddarth Agarwal, ARFor Respondent: Shri Sanat Kumar Raha, DR

Section 115BSection 133(6)Section 143(1)Section 68

…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…