DCIT-CENTRAL CIRCLE 8(1), MUMBAI, MUMBAI vs. JSK INDUSTRIES PVT LTD, MUMBAI
In the result, ITA Nos 3297 & 3298/Mum/2024 are dismissed
ITA 3298/MUM/2024[2018-19]Status: DisposedITAT Mumbai20 Sept 2024AY 2018-19
Bench: Shri Anikesh Banerjee & Shri Gagan Goyal
For Appellant: Shri Neelkanth KhandelwalFor Respondent: Shri Vivek Perampurna,CIT-DR
Section 132Section 143(3)Section 147Section 250Section 69C
…nvestment made by the 3 companies as unexplained. In our opinion the statement recorded during survey has no evidentiary value unless corroborated by other evidences. The case of the assessee finds support from the decisions namely CIT v. S. Khader Khan Sons [254 CTR 2289(SC)] confirming the decision in the case of CIT v. S. Khader Khan Son [300 ITR 157] and Paul Mathews and Sons v. CIT [263 ITR 101 (Ker)]. We also take note of the fact that these companies are part of the group companies of the appellant and therefore the creditworthiness as well as capacity of these companies cannot be examined independently an…