CIT v. K. Bhuvanendran

303 ITR 235High Court2008#2900 most cited

What is CIT v. K. Bhuvanendran authority for?

An assessment or addition to income cannot be made solely based on a retracted statement, especially when it is not corroborated by seized material or other concrete evidence. The revenue must produce evidence to establish claims like understatement of sale consideration or 'on-money'.

41

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Also referred to as

CIT v. K. Bhuvanendran · 303 ITR 235 · Section 143(2) · Section 143(3) · Section 147 · Section 148 · retracted statement · assessment without evidence · corroborative evidence · seized material · on-money · understatement of sale consideration

Sections most often in play

Section 143(2)Section 143(3)Section 147Section 148Section 10(1)Section 10(3)Section 10(38)Section 115BBE

Issues it is cited on

section 271aab(1a)section 158basection 158b(b)section 113section 158bb(1)section 158bbpenalty under section 270asection 271aabsection 158bcnon application of mindcreditworthiness of the creditorsection 41(1)

Judgments citing CIT v. K. Bhuvanendran

ITO 41(3)(1), MUMBAI, MUMBAI vs. DEEPIKA ANIL AGARWAL, MUMBAI

In the result the appeal filed by the revenue stands\ndismissed

ITA 1885/MUM/2025[2011-12]Status: DisposedITAT Mumbai06 Aug 2025AY 2011-12
Section 10(38)Section 132Section 132(4)Section 143Section 147Section 263Section 68

…IT v. Calcutta Discount Co. Ltd.', (1973) 91 ITR 8 (SC);\n5. Umacharan Shaw & Bros v. CIT', (1959) 37 ITR 271 (SC\nIncome assessed without evidence is bad-in-law.\nIncome assessed by revenue without supporting material is not justified.\n1. CIT V. BHUVANENDRA 303 ITR 235 (MAD.)\n2. VINOD SOLANKI VS. UOI (233) ELT 157 (S.C.)\n3. CIT V. KASHIRAM TEXTILE MILLS (P) LTD [2006]284 ITR 61 (GUJ)-\n4. SARASWATHI OIL TRADERS V. CIT [2000] 254 ITR 259 (SC)\nIncome cannot be assessed on mere statement basis. For assessment there has to\nbe some evidence.\nIncome cannot be assessed on mere retracted statement If not material…

RAJENDRA KUMAR MUNDRA (HUF),MUMBAI vs. NATIONAL FACELESS ASSESSMENT CENTRE (NFAC), DELHI

In the result the appeal filed by the assessee stands allowed

ITA 1000/MUM/2024[2016-17]Status: DisposedITAT Mumbai06 Aug 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain& Shri Girish Agrawalrajendra Kumar Mundra Vs. Ito, Ward 24(3)(1) (Huf) Piramal Chamber C-28, Ameya Bldg, Behind Lalbaug, Mumbai – Ymca Dn Nagar Andheri (W) 400012. 400053. Pan/Gir No.Aadh6828J (Applicant) (Respondent)

Section 147Section 148Section 2Section 263Section 68Section 69A

…CIT v. Calcutta Discount Co. Ltd.', (1973) 91 ITR 8 (SC); 5. Umacharan Shaw & Bros v. CIT', (1959) 37 ITR 271 (SC) Income assessed without evidence is bad-in-law. Income assessed by revenue without supporting material is not justified. 1. CIT V. BHUVANENDRA 303 ITR 235 (MAD.) 2. VINOD SOLANKI VS. UOI (233) ELT 157 (S.C.) 3. CIT V. KASHIRAM TEXTILE MILLS (P) LTD [2006]284 ITR 61 (GUJ)- 4. SARASWATHI OIL TRADERS V. CIT [2000] 254 ITR 259 (SC) Income cannot be assessed on mere statement basis. For assessment there has to be some evidence. Income cannot be assessed on mere retracted statement If not material to pr…

ACIT CENTRAL CIRCLE-1(3), NAGPUR vs. R.B.S.D. AND F.N. DAS (EXPORT FIRM), VIZIANAGARAM

In the result, appeal filed by the Revenue is dismissed

ITA 27/NAG/2024[2018-19]Status: DisposedITAT Nagpur27 Jan 2025AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mukesh AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 115BSection 133ASection 147Section 148Section 44ASection 69C

…g assessment proceedings also, assessing officers should rely upon the evidences/materials gathered during the course of search/survey operations or thereafter while framing the relevant assessment orders." Hon'ble Madras High Court In CIT v. K. Bhuvanendran (303 ITR 235) has held that the statement recorded from the appellant was subsequently retracted and rebutted Furthermore, the statement was not relatable to any seized material. Therefore, even the statement could not be the basis for making any addition Similarly, in M Narayan & Bros. v. ACIT (243 CTR 588) the Hon'ble Madras High Court considered the circul…

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

ITA 119/NAG/2024[2020-21]Status: DisposedITAT Nagpur26 Dec 2024AY 2020-21

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 132Section 143(2)Section 143(3)Section 153ASection 250Section 68

…hat the contention of the Revenue on the basis of statement of Shri YC Rao that circumstantial evidences clearly suggest payment of on-money to the assessee is totally misplaced and devoid of merits. In this regard, reliance is placed on K Bhuvanendran (2008) 303 ITR 235 (Mad), wherein, the Hon‟ble Madras High Court held that additions made towards on-money receipt in the hands of the seller based solely on the statement of buyer recorded during the course of search is not tenable when no other material is available to show that on-money was paid. There is no evidence to show that there is under statement of sale…

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

ITA 117/NAG/2024[2018-19]Status: DisposedITAT Nagpur26 Dec 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 132Section 143(2)Section 143(3)Section 153ASection 250Section 68

…hat the contention of the Revenue on the basis of statement of Shri YC Rao that circumstantial evidences clearly suggest payment of on-money to the assessee is totally misplaced and devoid of merits. In this regard, reliance is placed on K Bhuvanendran (2008) 303 ITR 235 (Mad), wherein, the Hon‟ble Madras High Court held that additions made towards on-money receipt in the hands of the seller based solely on the statement of buyer recorded during the course of search is not tenable when no other material is available to show that on-money was paid. There is no evidence to show that there is under statement of sale…

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

ITA 116/NAG/2024[2017-18]Status: DisposedITAT Nagpur26 Dec 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 132Section 143(2)Section 143(3)Section 153ASection 250Section 68

…hat the contention of the Revenue on the basis of statement of Shri YC Rao that circumstantial evidences clearly suggest payment of on-money to the assessee is totally misplaced and devoid of merits. In this regard, reliance is placed on K Bhuvanendran (2008) 303 ITR 235 (Mad), wherein, the Hon‟ble Madras High Court held that additions made towards on-money receipt in the hands of the seller based solely on the statement of buyer recorded during the course of search is not tenable when no other material is available to show that on-money was paid. There is no evidence to show that there is under statement of sale…

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

ITA 115/NAG/2024[2016-17]Status: DisposedITAT Nagpur26 Dec 2024AY 2016-17

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 132Section 143(2)Section 143(3)Section 153ASection 250Section 68

…hat the contention of the Revenue on the basis of statement of Shri YC Rao that circumstantial evidences clearly suggest payment of on-money to the assessee is totally misplaced and devoid of merits. In this regard, reliance is placed on K Bhuvanendran (2008) 303 ITR 235 (Mad), wherein, the Hon‟ble Madras High Court held that additions made towards on-money receipt in the hands of the seller based solely on the statement of buyer recorded during the course of search is not tenable when no other material is available to show that on-money was paid. There is no evidence to show that there is under statement of sale…

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

ITA 114/NAG/2024[2015-16]Status: DisposedITAT Nagpur26 Dec 2024AY 2015-16

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 132Section 143(2)Section 143(3)Section 153ASection 250Section 68

…hat the contention of the Revenue on the basis of statement of Shri YC Rao that circumstantial evidences clearly suggest payment of on-money to the assessee is totally misplaced and devoid of merits. In this regard, reliance is placed on K Bhuvanendran (2008) 303 ITR 235 (Mad), wherein, the Hon‟ble Madras High Court held that additions made towards on-money receipt in the hands of the seller based solely on the statement of buyer recorded during the course of search is not tenable when no other material is available to show that on-money was paid. There is no evidence to show that there is under statement of sale…

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P. LTD,BILASPUR vs. ACIT CENTRAL CIRCLE-1(1), NAGPUR

ITA 113/NAG/2024[2014-15]Status: DisposedITAT Nagpur26 Dec 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 132Section 143(2)Section 143(3)Section 153ASection 250Section 68

…hat the contention of the Revenue on the basis of statement of Shri YC Rao that circumstantial evidences clearly suggest payment of on-money to the assessee is totally misplaced and devoid of merits. In this regard, reliance is placed on K Bhuvanendran (2008) 303 ITR 235 (Mad), wherein, the Hon‟ble Madras High Court held that additions made towards on-money receipt in the hands of the seller based solely on the statement of buyer recorded during the course of search is not tenable when no other material is available to show that on-money was paid. There is no evidence to show that there is under statement of sale…

DCIT-CC-1(3), NAGPUR, NAGPUR vs. R.B.S.D. AND F.N. DAS(EXPORT FIRM), VIZIANAGRAM

In the result, appeal filed by the Revenue is dismissed

ITA 234/NAG/2023[2020-21]Status: DisposedITAT Nagpur25 Oct 2024AY 2020-21

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Sandipkumar Salunke
Section 132Section 139(1)Section 142(1)Section 143(2)Section 37(1)Section 69C

…ption. The AO has not supported the disallowance by any tangible evidence. The burden of proving the negative is stringent and subject to a greater degree of rigor of evidence. In this context reliance is placed on following jedgments- CIT v. K. Bhuvanendran (303 ITR 235)(Mad HC) “There was no evidence or material found during the course of search operation. The statement recorded from the appellant was subsequently retracted and rebutted. Furthermore, the statement was not relatable to any seized material. Therefore, even the statement could not be the basis for making any addition. When the sale deed discloses…

NATASHA KOHLI,NEW DELHI vs. ACIT CENTRAL CIRCLE-8, NEW DELHI

In the result, appeal of the assessee stands partly allowed for statistical purposes

ITA 1792/DEL/2020[2014-15]Status: DisposedITAT Delhi29 Feb 2024AY 2014-15

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharatr Assessment Year: 2014-15

Section 143(2)Section 143(3)Section 17(2)(iv)Section 69

…on it is not permissible for him to add back to the assessee's return any fictional income. In our opinion, that conclusion is fully in accordance with law." MADRAS HIGH COURT in the case of COMMISSIONER OF INCOME-TAX VERSUS K. BHUVANENDRAN AND OTHER, [2008] 303 ITR 235 (Mad) “6. The reasoning of the Tribunal is based on valid materials and evidence. In the present cases, the Revenue failed to establish that there is actually on-money passed on to the seller and also there is no evidence to show that there is understatement of sale consideration in the document. If the Revenue is able to produce evidence to sho…

UDAYAN GROVER,MUMBAI vs. NATIONAL FACELESS APPEAL CENTRE(NFAC), DELHI

In the result, appeal filed by the assessee is allowed

ITA 2880/MUM/2023[2015-16]Status: DisposedITAT Mumbai07 Feb 2024AY 2015-16

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleudayan Grover V. National Faceless Appeal Centre Panch Mahal Delhi Panch Sristhi Complex {Acit – 26(3), Bkc, Mumbai} Powai, Mumbai - 400072 Pan: Aclpg0572G (Appellant) (Respondent) Assessee Represented By : Shri Vimal Punmiya Department Represented By : Ms. Kavitha Kaushik

Section 10(38)Section 131Section 133(6)Section 142(1)Section 143(2)Section 57Section 68

…CIT v. Calcutta Discount Co. Ltd.', (1973) 91 ITR 8 (SC); 5. Umacharan Shaw & Bros v. CIT', (1959) 37 ITR 271 (SC) Income assessed without evidence is bad-in-law. Income assessed by revenue without supporting material is not justified. 1. CIT V. BHUVANENDRA 303 ITR 235 (MAD.) 2. VINOD SOLANKI VS. UOI (233) ELT 157 (S.C.) 3. CIT V. KASHIRAM TEXTILE MILLS (P) LTD [2006]284 ITR 61 (GUJ)- 4. SARASWATHI OIL TRADERS V. CIT [2000] 254 ITR 259 (SC) Income cannot be assessed on mere statement basis. For assessment there has to be some evidence. Income cannot be assessed on mere retracted statement If not material to pr…

ACIT, CENTRAL CIRCLE-2, MADURAI, MADURAI vs. VIBGYOR NET CONNECTIONS, KARNATAKA

In the result, appeal filed by the Revenue is dismissed

ITA 631/CHNY/2023[2016-17]Status: DisposedITAT Chennai19 Jan 2024AY 2016-17

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Bleआयकर अपील सं./Ita No.631/Chny/2023 िनधा"रण वष"/Assessment Year: 2016-17 & Cross-Objection No.29/Chny/2023 िनधा"रण वष"/Assessment Year: 2016-17

For Respondent: Shri. Nilay Baran Som, CIT
Section 132Section 69A

…ly suggest payment of on-money to the & CO No.29/Chny/2023 :: 18 :: assessee is totally misplaced and devoid of merits. In this regard, reliance is placed on decision of the Hon’ble Madras High Court in the case of CIT v. K. Bhuvanendran reported in [2008] 303 ITR 235 (Madras), wherein, the Hon’ble Madras High Court held that additions made towards on- money receipt in the hands of the seller based solely on the statement of buyer recorded during the course of search is not tenable when no other material is available to show that on-money was paid. There is no evidence to show that there is under statement…

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL) , JABALPUR vs. M/S. JABALPUR HOSPITAL & RESEARCH CENTER, JABALPUR

In the result, the appeal filed by the revenue is dismissed and the Cross objections filed by the assessee are partly allowed

ITA 19/JAB/2019[2016-17]Status: DisposedITAT Jabalpur20 Nov 2023AY 2016-17

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadaledcit, Vs. Jabalpur Hospital & Central Circle, Researchcentre,Pvtltd Ramnath Russel Crossing, Building,Napier Town, Napier Town, Jabalpur-482001, Jabalpur-482001 Madhya Pradesh. Madhya Pradesh Pan/Gir No. : Aabcj1959K Appellant .. Respondent Co.No.04/Jab/2019 (A.Y. 2016-17) (In Ita No.19/Jab/2019) Jabalpur Hospital & Vs. Dcit, Research Centre Pvt Ltd, Central Circle, Russel Crossing, Ramnath Napier Town, Building,Napier Town, Jabalpur-482001. Jabalpur-482001. Madhya Pradesh. Madhya Pradesh. Pan/Gir No. : Aabcj1959K Appellant .. Respondent

For Appellant: Shri Dhiraj Ghai.CA.ARFor Respondent: Shri Saad Kidwai. CIT-DR
Section 142(1)

…ording a disclosure of undisclosed income under undue pressure/coercion shall be viewed by the Board adversely" (Copy of instructions enclosed to page no 72 to 73) (vi) It has been held by Hon'ble Madras High Court in the case of CIT v K. Bhuvanendran (2008) 303 ITR 235 that no addition can be made solely on the basis of surrender made in the statement ITA No. 19/JAB/2019 & CO. 04/JAB/2019 M/s Jabalpur Hospital & Research Centre, Jabalpur. on oath recorded during the search. The relevant portion from the head note is reproduced hereinafter:- "There was a search in the assessee's residential premises. The asses…

AAKASH FILMS PVT. LTD,MUMBAI vs. CIT -50, MUMBAI

In the result, Ground No. 2 raised by the assessee is allowed

ITA 1762/MUM/2021[2013-14]Status: DisposedITAT Mumbai22 Nov 2022AY 2013-14

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Aakash Films Private Limited V. Income Tax Officer – 16(1)(1) Room No. 436A, Plot No. A-51, Midc Aayakar Bhavan, M.K. Road Marol Industrial Area Next To Aipma Andheri (E), Mumbai - 400093 Mumbai - 400020 Pan: Aahca5657K (Appellant) (Respondent) M/S. Aakash Ashish Realtors Limited V. Cit – 50, Central Circle – 8(3) Cts No. 766, 534 Mumbai S.V. Road, New Oshiwara Station Jogeshwari (W), Mumbai – 400102 Pan: Aaack7241C (Appellant) (Respondent)

Section 133(6)Section 142(1)Section 143(1)Section 143(2)Section 147Section 148

…. CIT v. Calcutta Discount Co. Ltd.', (1973) 91 ITR 8 (SC); 5. Umacharan Shaw & Bros v. CIT1, (1959) 37 ITR 271 (SC) Income assessed without evidence is bad-in-law. Income assessed by revenue without supporting material is not justified. 1. CIT V. BHUVANENDRA 303 ITR 235 (MAD.) 2. VINOD SOLANKI VS. UOI (233) ELT 157 (S.C.) 3. CIT V. KASHIRAM TEXTILE MILLS (P) LTD [2006]284 ITR 61 (GUJ)- 4. SARASWATHI OIL TRADERS V. CIT [2000] 254 ITR 259 (SC) -» Income cannot be assessed on mere statement basis. For assessment there has to be some evidence. Income cannot be assessed on mere retracted statement If no material to p…

DEPUTY COMMISSIONER OF INCOME-TAX vs. SHIKSHANA PRASARAKA MANDALI,, PUNE

In the result, the appeal of Revenue in ITA No

ITA 577/PUN/2016[2011-12]Status: DisposedITAT Pune24 Jun 2021AY 2011-12

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri Dharmesh Shah, ARFor Respondent: Shri Deepak Garg, CIT-DR
Section 132(4)Section 143(2)Section 153C

…ddition in absence of any independent evidence found as a result of search and placed reliance upon the Instruction F.No.286/2/2003-IT (Inv. II), dated 10.03.2003, CBDT letter F. No. 286/98/2013-IT (Inv. II), dated 18.12.2014, CIT Vs. K. Bhuvanendran and Ors [303 ITR 235 (Mad.)], Aishwarya K. Rai Vs. DCIT [104 ITD 166 (Mum) (TM), PushpaVihar Vs. ACIT [48 TT] 389 (Mum)], Jyotichand A.Ys. 2005-06 to 2011-12 Bhaichand Saraf & Sons (P) Ltd Vs. DCIT [139 ITD 10 (Pune)], CIT Vs. Uttamchand Jain [320 ITR 554 (Bom.)]. He argued that the statement of the persons recorded by the search officers cannot be relied against th…

DEPUTY COMMISSIONER OF INCOME-TAX vs. SHIKSHANA PRASARAKA MANDALI,, PUNE

In the result, the appeal of Revenue in ITA No

ITA 576/PUN/2016[2010-11]Status: DisposedITAT Pune24 Jun 2021AY 2010-11

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri Dharmesh Shah, ARFor Respondent: Shri Deepak Garg, CIT-DR
Section 132(4)Section 143(2)Section 153C

…ddition in absence of any independent evidence found as a result of search and placed reliance upon the Instruction F.No.286/2/2003-IT (Inv. II), dated 10.03.2003, CBDT letter F. No. 286/98/2013-IT (Inv. II), dated 18.12.2014, CIT Vs. K. Bhuvanendran and Ors [303 ITR 235 (Mad.)], Aishwarya K. Rai Vs. DCIT [104 ITD 166 (Mum) (TM), PushpaVihar Vs. ACIT [48 TT] 389 (Mum)], Jyotichand A.Ys. 2005-06 to 2011-12 Bhaichand Saraf & Sons (P) Ltd Vs. DCIT [139 ITD 10 (Pune)], CIT Vs. Uttamchand Jain [320 ITR 554 (Bom.)]. He argued that the statement of the persons recorded by the search officers cannot be relied against th…

DEPUTY COMMISSIONER OF INCOME-TAX vs. SHIKSHANA PRASARAKA MANDALI,, PUNE

In the result, the appeal of Revenue in ITA No

ITA 575/PUN/2016[2009-10]Status: DisposedITAT Pune24 Jun 2021AY 2009-10

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri Dharmesh Shah, ARFor Respondent: Shri Deepak Garg, CIT-DR
Section 132(4)Section 143(2)Section 153C

…ddition in absence of any independent evidence found as a result of search and placed reliance upon the Instruction F.No.286/2/2003-IT (Inv. II), dated 10.03.2003, CBDT letter F. No. 286/98/2013-IT (Inv. II), dated 18.12.2014, CIT Vs. K. Bhuvanendran and Ors [303 ITR 235 (Mad.)], Aishwarya K. Rai Vs. DCIT [104 ITD 166 (Mum) (TM), PushpaVihar Vs. ACIT [48 TT] 389 (Mum)], Jyotichand A.Ys. 2005-06 to 2011-12 Bhaichand Saraf & Sons (P) Ltd Vs. DCIT [139 ITD 10 (Pune)], CIT Vs. Uttamchand Jain [320 ITR 554 (Bom.)]. He argued that the statement of the persons recorded by the search officers cannot be relied against th…

DEPUTY COMMISSIONER OF INCOME-TAX vs. SHIKSHANA PRASARAKA MANDALI,, PUNE

In the result, the appeal of Revenue in ITA No

ITA 574/PUN/2016[2008-09]Status: DisposedITAT Pune24 Jun 2021AY 2008-09

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri Dharmesh Shah, ARFor Respondent: Shri Deepak Garg, CIT-DR
Section 132(4)Section 143(2)Section 153C

…ddition in absence of any independent evidence found as a result of search and placed reliance upon the Instruction F.No.286/2/2003-IT (Inv. II), dated 10.03.2003, CBDT letter F. No. 286/98/2013-IT (Inv. II), dated 18.12.2014, CIT Vs. K. Bhuvanendran and Ors [303 ITR 235 (Mad.)], Aishwarya K. Rai Vs. DCIT [104 ITD 166 (Mum) (TM), PushpaVihar Vs. ACIT [48 TT] 389 (Mum)], Jyotichand A.Ys. 2005-06 to 2011-12 Bhaichand Saraf & Sons (P) Ltd Vs. DCIT [139 ITD 10 (Pune)], CIT Vs. Uttamchand Jain [320 ITR 554 (Bom.)]. He argued that the statement of the persons recorded by the search officers cannot be relied against th…

DEPUTY COMMISSIONER OF INCOME-TAX vs. SHIKSHANA PRASARAKA MANDALI,, PUNE

In the result, the appeal of Revenue in ITA No

ITA 573/PUN/2016[2007-08]Status: DisposedITAT Pune24 Jun 2021AY 2007-08

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri Dharmesh Shah, ARFor Respondent: Shri Deepak Garg, CIT-DR
Section 132(4)Section 143(2)Section 153C

…ddition in absence of any independent evidence found as a result of search and placed reliance upon the Instruction F.No.286/2/2003-IT (Inv. II), dated 10.03.2003, CBDT letter F. No. 286/98/2013-IT (Inv. II), dated 18.12.2014, CIT Vs. K. Bhuvanendran and Ors [303 ITR 235 (Mad.)], Aishwarya K. Rai Vs. DCIT [104 ITD 166 (Mum) (TM), PushpaVihar Vs. ACIT [48 TT] 389 (Mum)], Jyotichand A.Ys. 2005-06 to 2011-12 Bhaichand Saraf & Sons (P) Ltd Vs. DCIT [139 ITD 10 (Pune)], CIT Vs. Uttamchand Jain [320 ITR 554 (Bom.)]. He argued that the statement of the persons recorded by the search officers cannot be relied against th…

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