How many judgments cite Chuharmal v. CIT?

340 judgments on BharatTax cite Chuharmal v. CIT (172 ITR 250), spanning 2007 to 2026.

Which sections of the Income Tax Act does Chuharmal v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 69A, Section 142(1), Section 250, Section 148, Section 147.

Chuharmal v. CIT

172 ITR 250Supreme Court of India1988#225 most cited

What is Chuharmal v. CIT authority for?

The expression 'income' under Section 69A of the Income-tax Act, 1961, has a wide meaning, encompassing anything that comes in or results in gain. Therefore, an assessee's unexplained investments, such as purchasing articles or depositing cash, can legitimately be inferred and deemed as income under this section.

340

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2007 to 2026.

Also referred to as

Chuharmal v. CIT · Section 69A · 172 ITR 250 · 3 SCC 588 · 'income' wide meaning · unexplained investments · deemed income · unexplained money · source of investment · gain

Also reported as

3 SCC 588

Sections most often in play

Section 143(3)Section 69A Section 142(1)Section 250 Section 148 Section 147 Section 143(2)Section 115BBE

Issues it is cited on

section 110 section 153(a)section 132(4a)section 65b section 65 survey under section 133a violation of natural justice panchnama section 271a section 292c dumb documents section 250(4)

Judgments citing Chuharmal v. CIT

Subhash Stone Product (P) Ltd., Sonebhadra vs. Asstt. Commissioner of Income Tax Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 107/ALLD/2019[2008-09]Status: DisposedITAT Allahabad31 Oct 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh

Section 132(1)Section 153Section 153ASection 153DSection 250

…fore natural that the Department would offer evidence to counter this ground only after the issue had been raised by the assessee in appeal. The ld. DRs also drew our attention through the decision of the Hon’ble Supreme Court in the case of Chuharmal vs. CIT 172 ITR 250. It was submitted that in the said case, the Hon’ble Supreme Court had held that there was a presumption in law, specifically section 114(e) of the Evidence Act that Judicial and Official Acts supposed to be performed in a particular manner had actually been performed in the way they were supposed to be conducted. There could not be presumption o…

Shri Jitendra Behl, Sriganganagar vs. ITO, Ward-3(2), Jaipur

In the result, the appeal of the assessee is allowed

ITA 1080/JPR/2024[2017-18]Status: DisposedITAT Jaipur30 Oct 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Mrs. Raksha Birla, C.AFor Respondent: Shri Gautam Singh Choudhary, JCIT a

Section 143(3)Section 250Section 69A

…ving been satisfactorily proved, the Revenue was justified in holding the same as assessable income of the assessee from undisclosed sources. Reliance is also placed on the decision of the Hon'ble Apex Court in the case of Chuharmal Vs. CIT (1988) reported in 172 ITR 250 in which similar issue was adjudicated in favour of the Revenue.  While affirming the view of MP HC held that the expression 'income' as used in section 69A, has a wide meaning which meant anything which came in resulted in gain and on this basis concluded that assessee had income which he had invested in purchasing article and he could be held…

Sunil Kumar Agarwal, Jaipur vs. ACIT, Cen. Cir-2, Jaipur

In the result the appeal of the assessee in ITA no

ITA 513/JPR/2025[2016-17]Status: DisposedITAT Jaipur14 Oct 2025AY 2016-17

For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Anita Rinesh, JCIT, Sr-DR

Section 132Section 139Section 153ASection 234B

…CIT [(1995) 214 ITR 801 3 evidentiary value unless 7-9 (SC)] rebutted Telescoping denied when CIT v. Devi Prasad Vishwanath Prasad income not accepted or nexus 4 10-11 [(1969) 72 ITR 194 (SC)] not proved Seized documents presumed true Chuharmal v. CIT [(1988) 172 ITR 250 5 12-13 under 292C (SC)] Addition on unaccounted CIT v. President Industries [(2002) 258 6 14-15 sales — only GP can be taxed ITR 654 (Guj.)] GP addition upheld on CIT v. N.K. Industries [(2016) 72 7 16-17 unaccounted purchases/sales taxmann.com 289 (Guj.)] CIT v. Sanjay Oilcake Industries [(2009) 8 18-19 unaccounted stock 316 ITR 274 (Guj.)] AO'…

Gulshan Homes and Infrastructure (P) Ltd, New Delhi vs. Dr. Manoj Kumar, DCIT, Central Circle-31, New Delhi

ITA 1595/DEL/2025[2020-21]Status: DisposedITAT Delhi30 Sept 2025AY 2020-21

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Revenue byFor Respondent: Shri Vinod Bindal, CA

Section 153C

…ng to prejudice to the Hon'ble Appellate Authorities by misquoting and incorrectly relying on the judgments of the Hon'ble Apex Court in the case of Sinhgad Technical Education Society 2017-TIOL-309- SC-IT (Para 6.3 of the CIT(A)'s order) and Chuharmal (1998) 172 ITR 250 (Para 10.3 of the CIT(A)'s order) whereas there were no such findings of the Apex Courts mentioned by him. Thus, basing his decision on clear incorrect appreciation, deserves to be reversed. 9. The CIT(A) erred in law and on fact in not appreciating that though no incriminating material was found even in respect of Mr Gulshan who admittedly is a…

Sagarmal Khemraj Dagalia, Mumbai vs. Income Tax Officer 23(3)(5), Mumbai

The appeal of the assessee is allowed for statistical purposes

ITA 4125/MUM/2025[2017-18]Status: DisposedITAT Mumbai22 Sept 2025AY 2017-18

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Shri Bhavin Solanki, ARFor Respondent: Shri Swapnil Choudhary, CIT-DR

Section 115BSection 133(6)Section 143(3)Section 234BSection 250Section 271ASection 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VP & MS PADMAVATHY S, AM I.T.A. No. 4125/Mum/2025 (Assessment Year: 2017-18) Sagarmal Khemraj Dagalia, Income Tax Officer-23(3)(5), Shop No.13, 1st Floor, 26A 121, 1st Floor, Matru Mandir, Mumadevi, Zaveri Bazar, Vs. Tardeo Road, Mumbai-400007. Mumbai-400002. PAN: AAEPD6176C Appellant) : Respondent) Assessee / Appellant by : Shri Bhavin Solanki, AR Revenue / Respondent by : Shri Swapnil Choudhary, CIT-DR : 11.09.2025 Date of Hearing Date of Pronouncement : 22.09.2025 O R D E R Per Padmavathy S, AM: This appeal by the assessee is aga…

Sh. Mahendra Kumar Goyal, Sikar vs. ACIT, Central Circle-3, Jaipur

In the result of the appeal of the assessee are disposed off as under

ITA 500/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR

Section 127Section 143(2)Section 143(3)Section 153ASection 69

…tion • Once documents/assets are found, initial burden lies on the assessee to explain the contents. • AO is not required to disprove them at the threshold. 32 ITA Nos. 493. 495 to 498/JP/2025 Sh. Mahendra Kumar Goyal Citations: • CIT v. Chuharmal (1988) 172 ITR 250 (SC) • CIT v. P.V. Kalyanasundaram (2007) 294 ITR 49 (Mad) • Shashi Garg v. CIT (2007) 162 Taxman 171 (Del) This is not the duty or power of AO to disprove the incriminating document. It is the assesee who need to explain the details with evidence. Here assesee faile dto do so. Only oral argument without any evidence are not enough to rule out t…

Sh. Mahendra Kumar Goyal, Sikar vs. DCIT, Central Circle-3, Jaipur

In the result of the appeal of the assessee are disposed off as under

ITA 498/JPR/2025[2020-21]Status: DisposedITAT Jaipur15 Sept 2025AY 2020-21

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR

Section 127Section 143(2)Section 143(3)Section 153ASection 69

…does not belong to assessee. 3. Onus on Assessee to Rebut Presumption • Once documents/assets are found, initial burden lies on the assessee to explain the contents. • AO is not required to disprove them at the threshold. Citations: • CIT v. Chuharmal (1988) 172 ITR 250 (SC) CIT v. P.V. Kalyanasundaram (2007) 294 ITR 49 (Mad) Shashi Garg v. CIT (2007) 162 Taxman 171 (Del) This is not the duty or power of AO to disprove the incriminating document. It is the assesee who need to explain the details with evidence. Here assesee faile dto do so. Only oral argument without any evidence are not enough to rule out the…

Sh. Mahendra Kumar Goyal, Sikar vs. ACIT, Central Circle-3, Jaipur

In the result of the appeal of the assessee are disposed off as under

ITA 497/JPR/2025[2019-20]Status: DisposedITAT Jaipur15 Sept 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आंकड़ुठरधारी आइटीएए सं.र@ITA Nos.493, 495 to 498, 500/JP/2025 निर्धारण वर्ष@Assessment Years : 2014-15 to 2016-17, 2018-19 to 2020-21 Mahendra Kumar Goyal चुके Vs. ACIT/DCIT Ward No. 2, Shahpura Road Neem Ka Thana, Sikar Central Circle-03, Jaipur लेखा संख्याल्लेय सं.जीआइआर सं.पान@PAN/GIR No.: ACFPG0306G अपीलार्थी@Appellant प्रत्यार्थी@Respondent निर्धारीती की आर से@ Assessee by : Shri P. C. Parwal, CA राजस्व की आर से@ R

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR

Section 127Section 143(2)Section 143(3)Section 153ASection 69

Sh. Mahendra Kumar Goyal, Sikar vs. ACIT, Central Circle-3, Jaipur

In the result of the appeal of the assessee are disposed off as under

ITA 496/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Sept 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR

Section 127Section 143(2)Section 143(3)Section 153ASection 69

Sh. Mahendra Kumar Goyal, Sikar vs. ACIT, Central Circle-3, Jaipur

In the result of the appeal of the assessee are disposed off as under

ITA 493/JPR/2025[2014-15]Status: DisposedITAT Jaipur15 Sept 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR

Section 127Section 143(2)Section 143(3)Section 153ASection 69

Mahant Pandey, Rohtas vs. NFAC, Delhi

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 182/PAT/2025[2017-18]Status: DisposedITAT Patna21 Aug 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 271ASection 271FSection 272A(1)(d)

…espite giving sufficient opportunities failed to respond to the notices issued. The Assessing Officer (hereinafter referred to as Ld. 'AO') examined the provision of section 69A of the Act and the judicial pronouncement in the case of Chuharmal vs. CIT (1988) 172 ITR 250 (SC) and made an addition of ₹1,25,24,480/- u/s 69A of the Act for the cash deposits in the bank account maintained with the Bank of Baroda which remained unexplained. An addition of ₹4,35,720/- appearing as gross salary received from the employer as per Form No. 26AS was also made. Another sum of ₹7,09,800/- from Executive Officer Nagar Parishad…

Mahant Pandey, Rohtas vs. NFAC, Delhi

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 181/PAT/2025[2017-18]Status: DisposedITAT Patna21 Aug 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 271ASection 271FSection 272A(1)(d)

Mahesh Mittal, Lucknow vs. ACIT, Range-5, Lucknow

In the result, the appeal of the assessee is partly allowed

ITA 73/LKW/2023[2014-15]Status: DisposedITAT Lucknow14 Aug 2025AY 2014-15

Bench: Shri Kul Bharat & Shri Anadee Nath Misshramahesh Mittal V. Acit, Range-5 1/16, Vinay Khand Gomti Income Tax Office Ashok Nagar, Lucknow-226010. Marg, Lucknow-226001. Pan:Acqpm4459B (Appellant) (Respondent) Appellant By: Shri Akshay Agarwal, Adv Respondent By: Shri Amit Singh Chauhan, Cit(Dr) O R D E R

For Appellant: Shri Akshay Agarwal, AdvFor Respondent: Shri Amit Singh Chauhan, CIT(DR)

Section 10(38)Section 68

…f 31 8.8 Further, the Hon'ble Supreme Court, in the well-known Daksheshwari Cotton Mills case (26 ITR 775 at 782), ruled that the Evidence Act may have no application to tax assessment proceedings. However, the court also clarified later, in Chuharmal vs CIT (172 ITR 250 at 255 SC) that when the taxing authorities are desirous of invoking the principles of the Evidence Act in proceedings before them, they are not prevented from doing so, All that is required is that whatever material they collect will have to be placed before the tax-paying assessee if adverse inference is going to be drawn - audi alteram partem…

Amitkumar Navnitbhai Patel, Ahmedabad vs. The ACIT, Circle-2(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 984/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad14 Aug 2025AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.984/Ahd/2023 िनधा"रण वष" /Assessment Year : 2017-18 Amitkumar Navnitbhai Patel The Acit बनाम/ A/1-1, Madhav Apartment Circle 2(1)(1) V/S. Opp. Municipal Garden Ahmedabad – 380 015 Vasna Ahmedabad – 390 007 "थायी लेखा सं./Pan: Amppp 5605 F अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri P.F. Jain, Ca Revenue By : Shri Atul Pandey, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 13/08/2025 घोषणा की तारीख /Date Of Pronouncement: 14/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri P.F. Jain, CAFor Respondent: Shri Atul Pandey, Sr.DR

Section 115BSection 143(3)Section 69Section 69A

…oks of account for the year. The CIT(A) thus confirmed the AO’s action in treating the said amount as undisclosed income and taxing it under section 115BBE of the Act. 4. The CIT(A) placed reliance on several judicial precedents, including Chuharmal vs. CIT (172 ITR 250), Smt. Srilekha Banerjee vs. CIT (1964 AIR 697), Smt. S. Sakunthala Sivan (Madras High Court, 2022), K.V. Mathew vs. ITO (Kerala High Court, 2014), and Roshan Di Hatti vs. CIT (2 SCC 378), to hold that unexplained cash deposits and receipts, when not satisfactorily explained, are liable to be taxed as deemed income under section 69A and section 6…

Selvam Baskar, Salem vs. ITO Ward 1(1), Salem

In the result the appeal of the assessee is allowed

ITA 2838/CHNY/2024[2017-18]Status: DisposedITAT Chennai12 Aug 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2838/Chny/2024 धनिाारण वर्ा / Assessment Year: 2017-18 Selvam Baskar Income Tax Officer, 118 – Pl Prop; Gomathy Jewellers, Vs. Ward 1(1), Gopal Chetty Street, Salem. Ponnammapet, Salem – 636 003. [Pan: Atjpb5735B] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. N. Arjun Raj, Advocate. प्रत्यथी की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 25.06.2025 घोर्णा की तारीख/Date Of Pronouncement : 12.08.2025

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 115BSection 143(3)Section 69A

…o justify the accumulation. The AO and CIT(A) found that the assessee’s explanation lacked supporting evidence, such as sale records or proof of cash generation, particularly for the deposits made after 12.11.2016. The ld. DR relies on Chuharmal vs CIT (1988) 172 ITR 250 (SC), where the Hon’ble Supreme Court held that cash found in the assessee’s possession without a satisfactory explanation, can be treated as income u/s.69A of the Act. 8. We have heard both the parties, perused material available on record, gone through the order of the authorities below along with the judicial decisions relied on. The fact rel…

Bheru Lal Kumawat, Vill Kulthana vs. ITO Pratapgarh, Pratapgarh

In the result, the appeal of the assessee is allowed

ITA 1288/JPR/2024[2016-17]Status: DisposedITAT Jaipur06 Aug 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT

Section 143(2)Section 143(3)

…applicability in the determination of matters under taxing statutes. In the present case, it is clear that apparent is not the real as evidenced from the observation made by the Ld AO. Further, the Hon'ble Supreme Court, in the case of Chuhar Mal V CIT (1988) 172 ITR 250, highlighted the fact that the principle of evidence law are not to be ignored by the authorities, but at the same time, human probability has to be the guiding principle, since the AO is not fettered, by 8 Bheru Lal Kumawat vs. ITO technical rules of evidence, as held by the Hon'ble Supreme Court in the case of Dhakeshwari Cotton Mills v CIT (1…

Kalavathi Devi Sharma, Hyderabad vs. ITO, Ward-1, Nanded

In the result, appeal of the assessee is dismissed

ITA 1519/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17

Bench: Dr.Manish Borad

For Appellant: NoneFor Respondent: Shri S. Sadananda Singh, JCIT

Section 10(38)Section 147Section 148Section 148ASection 149Section 250Section 68

…ed fictitious gain claimed as exemption. The AO has made the addition u/s. 69A by relying on the judicial decisions of the Hon'ble Supreme Court in CIT Vs. Durga Prasad More [1971] 82 ITR 540, Sumati Dayal Vs. CIT (214 ITR 801) (SC), Chuhar Mal Vs. CIT (1988) 172 ITR 250 and McDowell Vs. CTO. The case laws relied upon by the appellant cannot be applied in the present case as the appellant has failed to prove the test of human probabilities and failed to establish the circumstantial evidence to prove the transaction is not on manipulative basis. 10.5. Further, it is seen that SEBI has levied a penalty on M/s. Ach…

Sachin Bhandari, Jaipur vs. Itd WD 6(4), Jpr, Jaipur

In the result, the appeal filed by the assessee is allowed for statistical

ITA 354/JPR/2025[2017-18]Status: DisposedITAT Jaipur25 Jun 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Rajat Choudhary, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT

Section 143(3)Section 271ASection 69A

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR Mk0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, vk;dj vihy la-@ITA No. 354/JP/2025 fu/kZkj.k o"kZ@Assessment Year : 2017-18 cuke Sachin Bhandari ITO, Vs. 60, Ram Nagar Shopping Ward 6(4), Center, Shastri Nagar, Jaipur Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: ALZPB1178Q vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Rajat Choudhary, Adv. jktLo dh vksj ls@ Revenue…

Rishi Agarwal, Guwahati vs. ITO, Ward-2(2), Guwahati

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 266/GTY/2024[2021-22]Status: DisposedITAT Guwahati24 Jun 2025AY 2021-22

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 143(3)Section 250Section 69C

…I.T.A. No.: 266/GTY/2024 Assessment Year: 2021-22 Rishi Agarwal. xi. Thus, this Appellate authority places its reliance on the following judgments of the Hon’ble Supreme Court and High court: a. The Hon’ble Supreme Court in the case of Chuharmal Vs CIT (1988) 172 ITR 250 while affirming the view of the Madhya Pradesh High Court has held that ‘the expression ‘INCOME’ as used in Section 69A of the Act, 1961 had a wide meaning which meant anything which came in or resulted in gain and on this basis, concluded that the assessee had income which he had invested in purchasing article and he could be held to be owner an…

Gajendra Mohanty, Malkangiri vs. Income Tax Officer, Jeypore Ward, Jeypore

In the result, the appeal filed for AY 2017-18 is partly allowed and the appeal filed for AY 2018-19 is dismissed

ITA 161/CTK/2025[2018-19]Status: DisposedITAT Cuttack04 Jun 2025AY 2018-19

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 144Section 250Section 3Section 69A

…no applicability in the determination of matters under taxing statutes. In the present case, it is clear that apparent is not the real as evidenced from the observation made by Ld. AO. Further, the Hon'ble Supreme Court, in the case of Chuhar Mal V CIT (1988) 172 ITR 250, highlighted the fact that the principle of evidence law are not to be ignored by the authorities, but at the same time, human probability has to be the guiding principle, since the AO is not fettered, by technical rules of evidence, as held by the Hon'ble Supreme Court in the case of Dhakeshwari Cotton Mills v CIT (1954) 261 TR 775. The Hon'ble…