CIT v. P. Balasubramanian

354 ITR 116High Court2013#1945 most cited

What is CIT v. P. Balasubramanian authority for?

An addition to income can be made based on an assessee's statement recorded during a survey under Section 133A only if it is substantiated by relevant supporting material and not solely on the statement itself.

59

judgments rely on this decision, according to BharatTax’s citation analysis of 366,315 Indian tax judgments — from 2016 to 2026.

Also referred to as

CIT v. P. Balasubramanian · P. Balasubramanian 354 ITR 116 · statement under Section 133A · survey statement evidentiary value · addition based on survey statement · material to substantiate addition · corroboration of statement · Section 132(4) statement · search and seizure assessment · Madras High Court

Also reported as

231 CTR 165

Sections most often in play

Section 132(4)Section 133ASection 131Section 132(4A)Section 143(3)Section 147Section 153ASection 292C

Issues it is cited on

section 23(3)section 181section 114(e)abatement of assessmentsection 153(c)section 153a proceedingsthird party informationsection 132(4a)circle ratesection 158bdpercentage completion methodstatement under section 132(4)

Judgments citing CIT v. P. Balasubramanian

Deputy Commissioner of Income Tax, Central Circle, Panaji vs. M/S Mohit Ispat Ltd., Kundaim

Appeal of the Revenue is PARTLY ALLOWED in aforestated terms

ITA 9/PAN/2020[2016-17]Status: DisposedITAT Panaji13 Oct 2026AY 2016-17

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2016-17 Dy. Commissioner Of Income Tax, Central Circle, Panaji, Goa. . . . . . . . Appellant V/S M/S Mohit Ispat Limited 339/340, Kundaim Industrial Estate, Goa-403115 Pan: Aaccm8154E . . . . . . . Respondent Represented Assessee By: Mr Shriniwas Naik & Narchiva Lotlikar [‘Ld. Ar’] Revenue By: Mr Naveen Kumar [‘Ld. Dr’] Date Of Conclusive Hearing : 04/02/2026 Date Of Pronouncement : 27/02/2026 Order Per G. D. Padmahshali; This Appeal Of The Revenue Instituted U/S 253(2) Of The Income-Tax Act, 1961 [‘The Act’] Challenges Order Dt. 04/10/2019 Passed U/S 250 Of The Act By The Commissioner Of Income Tax Appeals-2, Panaji Goa [‘Ld. Cit(A)’] Which In Turn Sprung From Order Of Assessment Dt. 30/12/2017 Passed U/S 143(3) Of The Act By Acit, Central Circle, Panaji Goa [‘Ld. Ao’] Anent To Assessment Year 2016-17.[‘Ay’]

For Appellant: Mr Shriniwas Naik & Narchiva Lotlikar [‘Ld. AR’]For Respondent: Mr Naveen Kumar [‘Ld. DR’]
Section 132Section 133ASection 139(1)Section 143(3)Section 246ASection 250Section 253Section 253(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL, PANAJI BENCH, GOA BEFORE HON’BLE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND SHRI G. D. PADMAHSHALI, ACCOUNTANT MEMBER Assessment Years: 2016-17 Dy. Commissioner of Income Tax, Central Circle, Panaji, Goa. . . . . . . . Appellant V/s M/s Mohit Ispat Limited 339/340, Kundaim Industrial Estate, Goa-403115 PAN: AACCM8154E . . . . . . . Respondent Represented Assessee by: Mr Shriniwas Naik & Narchiva Lotlikar [‘Ld. AR’] Revenue by: Mr Naveen Kumar [‘Ld. DR’] Date of conclusive Hearing : 04/02/2026 Date of Pronouncement : 27/02/2026 ORDER PER G. D. PADMAHSHALI; This appeal of t…

Shri Narayan Rao Hebri vs. The Assistant Commissioner of Income Tax

The appeal stands dismissed

ITA/166/2025HC Karnataka20 Feb 2026

Bench: S.G.PANDIT,K. V. ARAVIND

Section 115BSection 133ASection 143(2)Section 260Section 260A

…- 1 - ITA No. 166 of 2025 Reserved on : 20.01.2026 Pronounced on : 20.02.2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 20TH DAY OF FEBRUARY, 2026 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE K. V. ARAVIND INCOME TAX APPEAL No. 166 OF 2025 BETWEEN: 1. SHRI NARAYAN RAO HEBRI, (PAN: AASPH2926A; S/O SHRI DHUMANNA, AGE ABOUT 71 YEARS) (RESIDING AT No.1, CHINNA, S. N. NAGAR MAIN ROAD, SAGAR 577204). …APPELLANT (BY SRI K.K. CHYTHANYA, SENIOR COUNSEL A/W SRI TATA KRISHNA, ADVOCATE) AND: 1. THE ASSISTANT COMMISSIO…

ACIT Central Circle 1(4) Mumbai, Mumbai vs. Kalyanee Fortune Constructions, Mumbai

In the result, all the above appeals in ITA Nos

ITA 5779/MUM/2024[2019-20]Status: DisposedITAT Mumbai23 Dec 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Neelkanth Khandelwal, ARFor Respondent: Ms. Kavitha Kaushik, (Sr. DR)
Section 131Section 132(1)Section 133ASection 143(3)

…he provisions of section 133A of the Act does not empower any ITO to examine any person on oath and the statement recorded u/s 133A of the Act has no evidentiary value. 37. We find the Hon’ble Madras High Court in the case of CIT vs. P. Balasubramanian (2013) 354 ITR 116 (Mad) has held that the addition can be made on the basis of assessee’s statement in survey only if it is supported by the relevant material to substantiate the same. 38. We find the Mumbai Bench of the Tribunal in the case of Smt. Madhu Gupta vs. DCIT (2006) 8 SOT 691 (Mum), has held that the statements which are not confronted to any of the par…

Assistant Commissioner of Income Tax Central Circle 1(4), Mumbai vs. Kalyanee Fortune Constructions, Mumbai

In the result, all the above appeals in ITA Nos

ITA 4448/MUM/2024[2017-18]Status: DisposedITAT Mumbai23 Dec 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Revenue byFor Respondent: Date of Hearing
Section 131Section 132(1)Section 133ASection 143(3)

…he provisions of section 133A of the Act does not empower any ITO to examine any person on oath and the statement recorded u/s 133A of the Act has no evidentiary value. 37. We find the Hon'ble Madras High Court in the case of CIT vs. P. Balasubramanian (2013) 354 ITR 116 (Mad) has held that the addition can be made on the basis of assessee's statement in survey only if it is supported by the relevant material to substantiate the same. 38. We find the Mumbai Bench of the Tribunal in the case of Smt. Madhu Gupta vs. DCIT (2006) 8 SOT 691 (Mum), has held that the statements which are not confronted to any of the par…

Assistant Commissioner of Income Tax, Mumbai vs. Kalyanee Fortune Constructions, Mumbai

In the result, all the above appeals in ITA Nos

ITA 4445/MUM/2024[2018-19]Status: DisposedITAT Mumbai23 Dec 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Neelkanth Khandelwal, ARFor Respondent: Ms. Kavitha Kaushik, (Sr. DR)
Section 131Section 132(1)Section 133ASection 143(3)

…he provisions of section 133A of the Act does not empower any ITO to examine any person on oath and the statement recorded u/s 133A of the Act has no evidentiary value. 37. We find the Hon’ble Madras High Court in the case of CIT vs. P. Balasubramanian (2013) 354 ITR 116 (Mad) has held that the addition can be made on the basis of assessee’s statement in survey only if it is supported by the relevant material to substantiate the same. 38. We find the Mumbai Bench of the Tribunal in the case of Smt. Madhu Gupta vs. DCIT (2006) 8 SOT 691 (Mum), has held that the statements which are not confronted to any of the par…

Assistant Commissioner of Income Tax Central Circle 1 4 Mumbai, Mumbai vs. Ms. Kalyanee Fortune Constructions, Mumbai

In the result, all the above appeals in ITA Nos

ITA 4444/MUM/2024[2020-21]Status: DisposedITAT Mumbai23 Dec 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Neelkanth Khandelwal, ARFor Respondent: Ms. Kavitha Kaushik, (Sr. DR)
Section 131Section 132(1)Section 133ASection 143(3)

…he provisions of section 133A of the Act does not empower any ITO to examine any person on oath and the statement recorded u/s 133A of the Act has no evidentiary value. 37. We find the Hon'ble Madras High Court in the case of CIT vs. P. Balasubramanian (2013) 354 ITR 116 (Mad) has held that the addition can be made on the basis of assessee's statement in survey only if it is supported by the relevant material to substantiate the same. 38. We find the Mumbai Bench of the Tribunal in the case of Smt. Madhu Gupta vs. DCIT (2006) 8 SOT 691 (Mum), has held that the statements which are not confronted to any of the par…

Ganraj Homes LLP, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, all the three appeals filed by the assessee are allowed

ITA 879/PUN/2024[2018-19]Status: DisposedITAT Pune07 Feb 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: S/Shri Amol Khairnar CIT-DR &
Section 132Section 133ASection 143(2)Section 153A

…of Paul Mathews & Son vs. CIT (2003) 263 ITR 101 (Kar) has held that the provisions of section 133A of statement recorded u/s 133A of the Act has no evidentiary value. 37. We find the Hon‟ble Madras High Court in the case of CIT vs. P. Balasubramanian (2013) 354 ITR 116 (Mad) has held that the addition can be made on the basis of assessee‟s statement in survey only if it is supported by the relevant material to substantiate the same. 38. We find the Mumbai Bench of the Tribunal in the case of Smt. Madhu Gupta vs. DCIT (2006) 8 SOT 691 (Mum), has held that the statements which are not confronted to any of the pa…

Ganraj Homes LLP, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, all the three appeals filed by the assessee are allowed

ITA 878/PUN/2024[2017-18]Status: DisposedITAT Pune07 Feb 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: S/Shri Amol Khairnar CIT-DR &
Section 132Section 133ASection 143(2)Section 153A

…of Paul Mathews & Son vs. CIT (2003) 263 ITR 101 (Kar) has held that the provisions of section 133A of statement recorded u/s 133A of the Act has no evidentiary value. 37. We find the Hon‟ble Madras High Court in the case of CIT vs. P. Balasubramanian (2013) 354 ITR 116 (Mad) has held that the addition can be made on the basis of assessee‟s statement in survey only if it is supported by the relevant material to substantiate the same. 38. We find the Mumbai Bench of the Tribunal in the case of Smt. Madhu Gupta vs. DCIT (2006) 8 SOT 691 (Mum), has held that the statements which are not confronted to any of the pa…

Shree Balaji Realty, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, appeals for

ITA 877/PUN/2024[2019-2020]Status: DisposedITAT Pune07 Feb 2025AY 2019-2020

Bench: Shri R. K. Panda & Ms. Astha Chandra

Section 132Section 143(2)Section 153A

…he provisions of section 133A of the Act does not empower any ITO to examine any person on oath and the statement recorded u/s 133A of the Act has no evidentiary value. 38. We find the Hon'ble Madras High Court in the case of CIT vs. P. Balasubramanian (2013) 354 ITR 116 (Mad) has held that the addition can be made on the basis of assessee's statement in survey only if it is supported by the relevant material to substantiate the same. 39. We find the Mumbai Bench of the Tribunal in the case of Smt. Madhu Gupta vs. DCIT (2006) 8 SOT 691 (Mum), has held that the statements which are not confronted to any of the par…

Shree Balaji Realty, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, appeals for

ITA 876/PUN/2024[2018-19]Status: DisposedITAT Pune07 Feb 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

Section 132Section 143(2)Section 153A

…he provisions of section 133A of the Act does not empower any ITO to examine any person on oath and the statement recorded u/s 133A of the Act has no evidentiary value. 38. We find the Hon'ble Madras High Court in the case of CIT vs. P. Balasubramanian (2013) 354 ITR 116 (Mad) has held that the addition can be made on the basis of assessee's statement in survey only if it is supported by the relevant material to substantiate the same. 39. We find the Mumbai Bench of the Tribunal in the case of Smt. Madhu Gupta vs. DCIT (2006) 8 SOT 691 (Mum), has held that the statements which are not confronted to any of the par…

Shree Balaji Realty, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, appeals for assessment years 2017-18 and 2018-19 are allowed and the appeal for assessment year 2019-20 is partly allowed

ITA 875/PUN/2024[2017-18]Status: DisposedITAT Pune07 Feb 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: S/Shri Amol Kharnar CIT-DR &
Section 132Section 143(2)Section 153A

…e provisions of section 133A of the Act does not empower any ITO to examine any person on oath and the statement recorded u/s 133A of the Act has no evidentiary value. 38. We find the Hon’ble Madras High Court in the case of CIT vs. P. Balasubramanian (2013) 354 ITR 116 (Mad) has held that the addition can be made on the basis of assessee’s statement in survey only if it is supported by the relevant material to substantiate the same. 39. We find the Mumbai Bench of the Tribunal in the case of Smt. Madhu Gupta vs. DCIT (2006) 8 SOT 691 (Mum), has held that the statements which are not confronted to any of the pa…

Ganraj Homes LLP, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, all the three appeals filed by the assessee are allowed

ITA 874/PUN/2024[2019-20]Status: DisposedITAT Pune07 Feb 2025AY 2019-20

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: S/Shri Amol Khairnar CIT-DR &
Section 132Section 133ASection 143(2)Section 153A

…of Paul Mathews & Son vs. CIT (2003) 263 ITR 101 (Kar) has held that the provisions of section 133A of statement recorded u/s 133A of the Act has no evidentiary value. 37. We find the Hon‟ble Madras High Court in the case of CIT vs. P. Balasubramanian (2013) 354 ITR 116 (Mad) has held that the addition can be made on the basis of assessee‟s statement in survey only if it is supported by the relevant material to substantiate the same. 38. We find the Mumbai Bench of the Tribunal in the case of Smt. Madhu Gupta vs. DCIT (2006) 8 SOT 691 (Mum), has held that the statements which are not confronted to any of the pa…

Meenamani Ganga Builder LLP, Pune vs. Assistant Commissioner of Income Tax, Central Circle 2(3), Pune

In the result, all the three appeals filed by the assessee are partly allowed

ITA 872/PUN/2024[2018-19]Status: DisposedITAT Pune07 Feb 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri Amol Kharnar CIT-DR
Section 132Section 143(2)Section 153A

…e provisions of section 133A of the Act does not empower any ITO to examine any person on oath and the statement recorded u/s 133A of the Act has no evidentiary value. 40. We find the Hon’ble Madras High Court in the case of CIT vs. P. Balasubramanian (2013) 354 ITR 116 (Mad) has held that the addition can be made on the basis of assessee’s statement in survey only if it is supported by the relevant material to substantiate the same. 41. We find the Mumbai Bench of the Tribunal in the case of Smt. Madhu Gupta vs. DCIT (2006) 8 SOT 691 (Mum), has held that the statements which are not confronted to any of the par…

Income Tax Officer W 1, Hassan vs. Ramachandra Setty and Sons, Hassan

In the result, appeal of the assessee in ITA

ITA 1166/BANG/2023[2017-18]Status: DisposedITAT Bangalore10 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

…Hassan Page 95 of 104 residence could not have been brought to tax under the provisions of section 115BBE of the act instead of section 28 of the act. He relied on the ratio laid down by the High Court of Madras in the case of CIT V. P. Balasubramanian (2013) 354 ITR 116 (Madras). He also relied on the following decisions on the same issue. (i) Fashion World V. Asst. CIT (ITA No.1634/Ahd/2006) dated 12.02.2010. (ii) Arora Alloys Ltd V. Dy. CIT (ITA No. 1481/Chand/2017), dated 06.11.2019. (iii) Jasvinder Singh V. Deputy Commissioner of Income Tax (2024) 109 ITR (Trib) 377 (Chandigarh) 16.5.4 He further relied on…

Income Tax Officer, W-1, Vijayanagar vs. Ramachandra Setty and Sons, Hassan

In the result, appeal of the assessee in ITA

ITA 1165/BANG/2023[2015-16]Status: DisposedITAT Bangalore10 Jun 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

…Hassan Page 95 of 104 residence could not have been brought to tax under the provisions of section 115BBE of the act instead of section 28 of the act. He relied on the ratio laid down by the High Court of Madras in the case of CIT V. P. Balasubramanian (2013) 354 ITR 116 (Madras). He also relied on the following decisions on the same issue. (i) Fashion World V. Asst. CIT (ITA No.1634/Ahd/2006) dated 12.02.2010. (ii) Arora Alloys Ltd V. Dy. CIT (ITA No. 1481/Chand/2017), dated 06.11.2019. (iii) Jasvinder Singh V. Deputy Commissioner of Income Tax (2024) 109 ITR (Trib) 377 (Chandigarh) 16.5.4 He further relied on…

Income Tax Officer Ward-1 Hassan, Hassan vs. Ramachandra Setty and Songs, Hassan

In the result, appeal of the assessee in ITA

ITA 1164/BANG/2023[2014-15]Status: DisposedITAT Bangalore10 Jun 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

…Hassan Page 95 of 104 residence could not have been brought to tax under the provisions of section 115BBE of the act instead of section 28 of the act. He relied on the ratio laid down by the High Court of Madras in the case of CIT V. P. Balasubramanian (2013) 354 ITR 116 (Madras). He also relied on the following decisions on the same issue. (i) Fashion World V. Asst. CIT (ITA No.1634/Ahd/2006) dated 12.02.2010. (ii) Arora Alloys Ltd V. Dy. CIT (ITA No. 1481/Chand/2017), dated 06.11.2019. (iii) Jasvinder Singh V. Deputy Commissioner of Income Tax (2024) 109 ITR (Trib) 377 (Chandigarh) 16.5.4 He further relied on…

Income Tax Officer, W-1, Hassan vs. Ramachandra Setty & Sons, Hassan

In the result, appeal of the assessee in ITA

ITA 1163/BANG/2023[2013-14]Status: DisposedITAT Bangalore10 Jun 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

…Hassan Page 95 of 104 residence could not have been brought to tax under the provisions of section 115BBE of the act instead of section 28 of the act. He relied on the ratio laid down by the High Court of Madras in the case of CIT V. P. Balasubramanian (2013) 354 ITR 116 (Madras). He also relied on the following decisions on the same issue. (i) Fashion World V. Asst. CIT (ITA No.1634/Ahd/2006) dated 12.02.2010. (ii) Arora Alloys Ltd V. Dy. CIT (ITA No. 1481/Chand/2017), dated 06.11.2019. (iii) Jasvinder Singh V. Deputy Commissioner of Income Tax (2024) 109 ITR (Trib) 377 (Chandigarh) 16.5.4 He further relied on…

M/S. S. Ramashandra Setty & Sons, Hassan vs. Income Tax Officer, Ward-1, Hassan

In the result, appeal of the assessee in ITA

ITA 1156/BANG/2023[2017-18]Status: DisposedITAT Bangalore10 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

…Hassan Page 95 of 104 residence could not have been brought to tax under the provisions of section 115BBE of the act instead of section 28 of the act. He relied on the ratio laid down by the High Court of Madras in the case of CIT V. P. Balasubramanian (2013) 354 ITR 116 (Madras). He also relied on the following decisions on the same issue. (i) Fashion World V. Asst. CIT (ITA No.1634/Ahd/2006) dated 12.02.2010. (ii) Arora Alloys Ltd V. Dy. CIT (ITA No. 1481/Chand/2017), dated 06.11.2019. (iii) Jasvinder Singh V. Deputy Commissioner of Income Tax (2024) 109 ITR (Trib) 377 (Chandigarh) 16.5.4 He further relied on…

Dy CIT CC 6(4), Mumbai vs. Arshiya Ltd., Mumbai

ITA 971/MUM/2020[2013-14]Status: DisposedITAT Mumbai08 Apr 2024AY 2013-14

Bench: Shri Aby T Varkey & Shri Amarjit Singh

For Appellant: Ajay ChandraFor Respondent: Piyush Chhajed
Section 10(34)Section 143(2)Section 143(3)Section 14A

…er Produce Co. Ltd. vs. State of Kerala [1973] 91 ITR 18 1313 Decision of the Hon. Delhi High Court in the case of CIT vs. Dhingra Metal Works [2010] 328 ITR 384 1.3.1.4. Decision of the Hon. Madras High Court in the case of CTT vs. P. Balasubramanian" [2013] 354 ITR 116 Page 9 ITA No.3952/Mum/2015 & 971/Mum/2020, ITA No.7900/Mum/2019 ACIT, CC 6(4) Vs. M/s Arshiya Limited 1.3.15 Decision of the Hon. Jaipur ITAT in the case of Unique Art Age vs. ACIT [2014] 29 TTR(T) 547 1.3.1.6. Decision of the Hon. Bombay High Court in the case of Dr. Dinesh Jain vs. ITO [2014] 363 ITR 210 1.4 The Hon. Bombay High Court in the c…

M/S Arshiya Ltd., Mumbai vs. DCIT CC 6 (4), Mumbai

In the result, the appeal of the revenue vide ITA No

ITA 7900/MUM/2019[2013-14]Status: DisposedITAT Mumbai08 Apr 2024AY 2013-14

Bench: Shri Aby T Varkey & Shri Amarjit Singhacit, Cc-6(4) Vs. M/S Arshiya Ltd. R. No. 32(1), 308, Level 3, Ceejay Ground Floor, Aayakar House, F Block Shiv Bhavan, M.K. Road, Sagar Estate, Dr. A.B. Mumbai -400 020 Road, Worli, Mumbai – 400018 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaaci2679A Appellant .. Respondent Dcit, Cc-6(4) Vs. M/S Arshiya Ltd. R. No. 1925, 19Th Floor, 308, Level 3, Ceejay Air India Building, House, F Block Shiv Nariman Point, Sagar Estate, Dr. A.B. Mumbai -400 021 Road, Worli, Mumbai – 400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaaci2679A Appellant .. Respondent M/S Arshiya Ltd. Vs. Dcit, Cc-6(4) 308, Level 3, Ceejay R. No. 1925, 19Th Floor, House, F Block Shiv Sagar Air India Building, Estate, Dr. A.B. Road, Nariman Point, Worli, Mumbai – 400018 Mumbai -400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaaci2679A Appellant .. Respondent

For Appellant: Ajay ChandraFor Respondent: Piyush Chhajed
Section 10(34)Section 143(2)Section 143(3)Section 14A

…er Produce Co. Ltd. vs. State of Kerala [1973] 91 ITR 18 1313 Decision of the Hon. Delhi High Court in the case of CIT vs. Dhingra Metal Works [2010] 328 ITR 384 1.3.1.4. Decision of the Hon. Madras High Court in the case of CTT vs. P. Balasubramanian" [2013] 354 ITR 116 P a g e | 9 ITA No.3952/Mum/2015 & 971/Mum/2020, ACIT, CC 6(4) Vs. M/s Arshiya Limited 1.3.15 Decision of the Hon. Jaipur ITAT in the case of Unique Art Age vs. ACIT [2014] 29 TTR(T) 547 1.3.1.6. Decision of the Hon. Bombay High Court in the case of Dr. Dinesh Jain vs. ITO [2014] 363 ITR 210 1.4 The Hon. Bombay High Court in the case of Dr. Din…