CIT v. Puneet Sabharwal

338 ITR 485High Court2011#1659 most cited

What is CIT v. Puneet Sabharwal authority for?

The revenue must prove that an assessee received extra consideration beyond the declared value; a Departmental Valuation Officer's (DVO) report alone is insufficient to establish such receipt.

69

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Puneet Sabharwal · Puneet Sabharwal · DVO report · Departmental Valuation Officer · extra consideration · declared value · burden of proof · actual receipt · Section 50C · Section 43CA · Section 56(2)(vii)(b) · Section 69

Also reported as

16 Taxmann.com 320204 Taxmann 16

Sections most often in play

Section 143(3)Section 154Section 43CASection 50CSection 56(2)(vii)(b)Section 69Section 143(2)Section 250

Issues it is cited on

section 2(15a)section 142asection 17(2)(iiia)illegal paymentsection 44afsection 131(1)(d)retention moneysection 150surrender of incomemat creditsection 55asection 17(2)

Judgments citing CIT v. Puneet Sabharwal

JAYAKRISHNA NANDAMURI,HYDERABAD vs. DCIT, CIRCLE -2(1) , HYDERABAD

In the result, the appeal of the assessee is dismissed

ITA 1793/HYD/2025[1996-97]Status: DisposedITAT Hyderabad08 Apr 2026AY 1996-97

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1793/Hyd/2025 (िनधा"रण वष"/Assessment Year: 1996-97) Shri Jayakrishna Vs. Dy. Cit Nandamuri Circle 2(1) Hyderabad Hyderabad Pan: Aaxpn3135E (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate A. Harish राज" व "ारा/Revenue By:: Shri R. Kumaran, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 26/03/2026 घोषणा की तारीख/Pronouncement: 08/04/2026 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Advocate A. HarishFor Respondent: : Shri R. Kumaran, Sr.AR
Section 143(3)Section 147Section 148Section 260Section 69B

…issioner of Income Tax and Another (b) 419 ITR 132 (Guj) – Principal Commissioner of Income Tax Vs. Himanshu Chandulal Patel (c) 367 ITR 112 (Delhi) -Pepsi Foods P. Ltd Vs. Assistant commissioner of Income Tax (d) 290 ITR 245 (Delhi) –CIT Vs. Lalit Bhasin (e) 338 ITR 485 -CIT Vs. Puneet Sabharwal (f) KP Varghese Case Hon'ble Supreme Court in 131 ITR 597 (g) ITA No. 55/Hyd/2015 –G Mahesh Babu Vs. DCIT. 8. Per contra, the Learned Departmental Representative (“Ld. DR”) relied on the orders of the lower authorities and submitted that the assessee has failed to satisfactorily explain the source of investment. It was c…

MR. HIRJIPARBAT GADA,MUMBAI vs. ITO- CIRCLE 24(1), MUMBAI

In the result, In the result, the appeal of the assesse bearing ITA No

ITA 528/MUM/2024[2016-17]Status: DisposedITAT Mumbai11 Aug 2025AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar- A.Y. 2014-15 - A.Y. 2014-15 - A.Y. 2016-17

For Appellant: Shri Vipul Joshi a/w Shri Prashant GhumareFor Respondent: Shri Hemanshu Joshi, SR DR
Section 143(1)Section 143(2)Section 143(3)Section 154Section 2Section 250Section 43CSection 56(2)(vii)Section 6Section 69

…s submitted by the learned counsel for the revenue that the Tribunal had erred in deleting the addition. On the other hand the learned counsel for the respondent referred to a Division Bench decision of this Court in the case of CIT v. Puneet Sabharwal [2011] 338 ITR 485/16 taxmann.com 320/[2012] 204 Taxman 16 (Delhi) (Mag.). In that decision a specific question had been raised as to whether the Income Tax Appellate Tribunal was right in holding that notwithstanding the report of the DVO the revenue had to prove that the assessee had received extra consideration over and above the declared value of the same. That…

MR. HIRJIPARBAT GADA,MUMBAI vs. ITO-WARD 24(1), MUMBAI

In the result, In the result, the appeal of the assesse bearing ITA No

ITA 527/MUM/2024[2014-15]Status: DisposedITAT Mumbai11 Aug 2025AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar- A.Y. 2014-15 - A.Y. 2014-15 - A.Y. 2016-17

For Appellant: Shri Vipul Joshi a/w Shri Prashant GhumareFor Respondent: Shri Hemanshu Joshi, SR DR
Section 143(1)Section 143(2)Section 143(3)Section 154Section 2Section 250Section 43CSection 56(2)(vii)Section 6Section 69

…s submitted by the learned counsel for the revenue that the Tribunal had erred in deleting the addition. On the other hand the learned counsel for the respondent referred to a Division Bench decision of this Court in the case of CIT v. Puneet Sabharwal [2011] 338 ITR 485/16 taxmann.com 320/[2012] 204 Taxman 16 (Delhi) (Mag.). In that decision a specific question had been raised as to whether the Income Tax Appellate Tribunal was right in holding that notwithstanding the report of the DVO the revenue had to prove that the assessee had received extra consideration over and above the declared value of the same. That…

MR. HIRJIPARBAT GADA,MUMBAI vs. ITO-WARD 24(1), MUMBAI

In the result, In the result, the appeal of the assesse bearing ITA No

ITA 526/MUM/2024[2014-15]Status: DisposedITAT Mumbai11 Aug 2025AY 2014-15
Section 143(1)Section 143(2)Section 143(3)Section 154Section 43CSection 56(2)(vii)Section 6Section 69

…ubmitted by the learned\ncounsel for the revenue that the Tribunal had erred in deleting the addition. On the other\nhand the learned counsel for the respondent referred to a Division Bench decision of this\nCourt in the case of CIT v. Puneet Sabharwal [2011] 338 ITR 485/16 taxmann.com 320/[2012]\n204 Taxman 16 (Delhi) (Mag.). In that decision a specific question had been raised as to\nwhether the Income Tax Appellate Tribunal was right in holding that notwithstanding the\nreport of the DVO the revenue had to prove that the assessee had received extra\nconsideration over and above the declared value of the same.…

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

ITA 857/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh03 Mar 2025AY 2016-17
Section 127Section 132Section 153ASection 153D

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

ITA 856/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh03 Mar 2025AY 2015-16
Section 127Section 132Section 153ASection 153D

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

ITA 845/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh03 Mar 2025AY 2017-18
Section 127Section 132Section 153ASection 153D

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

ITA 844/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh03 Mar 2025AY 2013-14
Section 132Section 153A

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

ITA 843/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh03 Mar 2025AY 2012-13
Section 127Section 132Section 153ASection 153D

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

ITA 833/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh03 Mar 2025AY 2017-18
Section 127Section 132Section 153ASection 153D

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

ITA 832/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh03 Mar 2025AY 2016-17
Section 127Section 153D

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

ITA 829/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh03 Mar 2025AY 2013-14
Section 132Section 153A

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

ITA 732/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh03 Mar 2025AY 2018-19
Section 132Section 153ASection 153D

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

ITA 731/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh03 Mar 2025AY 2017-18
Section 127Section 132Section 153ASection 153D

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

ITA 730/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh03 Mar 2025AY 2016-17
Section 127Section 132Section 153ASection 153D

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

ITA 729/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh03 Mar 2025AY 2015-16
Section 127Section 132Section 153ASection 153D

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

ITA 728/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh03 Mar 2025AY 2014-15
Section 127Section 132Section 153ASection 153D

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

ITA 726/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh03 Mar 2025AY 2012-13

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,CHANDIGARH, CHANDIGARH

ITA 583/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh03 Mar 2025AY 2015-16
Section 127Section 132Section 153ASection 153D

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,CHANDIGARH, CHANDIGARH

ITA 582/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh03 Mar 2025AY 2014-15
Section 127Section 132Section 153ASection 153D

…ubmitted by the learned counsel for the revenue that the\nTribunal had erred in deleting the addition. On the other hand the learned\ncounsel for the respondent referred to a Division Bench decision of this Court in\nthe case of CIT v. Puneet Sabharwal [2011] 338 ITR 485. In that decision a\nspecific question had been raised as to whether the Income Tax Appellate\nTribunal was right in holding that notwithstanding the report of the DVO the\nrevenue had to prove that the assessee had received extra consideration over and\nabove the declared value of the same. That question was answered by this Court\nin favour of…

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