CIT v. S.V. Sreenivasan

404 ITR 433High Court2018#2346 most cited

What is CIT v. S.V. Sreenivasan authority for?

The case clarifies principles for relying on seized documents, including those found from third parties, to make additions to an assessee's income, emphasizing the need for corroboration of such material.

49

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2019 to 2022.

Also referred to as

CIT v. S.V. Sreenivasan · 2018 · Madras High Court · seized documents · loose papers · third-party documents · evidentiary value · addition to income · undisclosed income · hundi transactions · on-money · section 131(1) · corroboration

Issues it is cited on

hundi transactionsection 23(1)(a)section 23(1)annual letting valuesection 245d(4)section 131(1)annual valueincome tax settlement commissionsection 65bsection 65on-moneyloose papers

Judgments citing CIT v. S.V. Sreenivasan

ACIT - 17(1), MUMBAI vs. SHRI ANAND JAIKUMAR JAIN, MUMBAI

ITA 3823/MUM/2019[2008-09]Status: DisposedITAT Mumbai22 Apr 2022AY 2008-09

Bench: Shri Amarjit Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Vijay MehtaFor Respondent: Shri O.P. Singh
Section 131(1)Section 143(3)Section 148

…money are duly recorded in the books of the group entities of the assessee, which is sufficient corroboration of the seized material. The Ld. DR has also relied upon several decisions in support of his arguments, they are: - a. CIT v. S.V. Sreenivasan [2018] 404 ITR 433 (Madras) b. Smt Dayawanti v. CIT [2017] 390 ITR 496 (Del.) c. Smt. Vasantibai N. Shah v. CIT [1995] 213 ITR 805 (Bombay). d. Smt. Tara Devi Aggarwal v. CIT [1973] 88 ITR 323 (SC) e. S. P. Jaiswal v. CIT [1973] 224 ITR 619 (SC) 14. On the other hand, Ld. AR submitted that the real issue to be decided in the present case is not as to whether the s…

ACIT - 17(1), MUMBAI vs. SHRI ANAND JAIKUMAR JAIN, MUMBAI

ITA 3822/MUM/2019[2009-10]Status: DisposedITAT Mumbai22 Apr 2022AY 2009-10

Bench: Shri Amarjit Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Vijay MehtaFor Respondent: Shri O.P. Singh
Section 131(1)Section 143(3)Section 148

…money are duly recorded in the books of the group entities of the assessee, which is sufficient corroboration of the seized material. The Ld. DR has also relied upon several decisions in support of his arguments, they are: - a. CIT v. S.V. Sreenivasan [2018] 404 ITR 433 (Madras) b. Smt Dayawanti v. CIT [2017] 390 ITR 496 (Del.) c. Smt. Vasantibai N. Shah v. CIT [1995] 213 ITR 805 (Bombay). d. Smt. Tara Devi Aggarwal v. CIT [1973] 88 ITR 323 (SC) e. S. P. Jaiswal v. CIT [1973] 224 ITR 619 (SC) 14. On the other hand, Ld. AR submitted that the real issue to be decided in the present case is not as to whether the s…

ACIT - 17(1), MUMBAI vs. SHRI ANAND JAIKUMAR JAIN, MUMBAI

ITA 3821/MUM/2019[2010-11]Status: DisposedITAT Mumbai22 Apr 2022AY 2010-11

Bench: Shri Amarjit Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Vijay MehtaFor Respondent: Shri O.P. Singh
Section 131(1)Section 143(3)Section 148

…money are duly recorded in the books of the group entities of the assessee, which is sufficient corroboration of the seized material. The Ld. DR has also relied upon several decisions in support of his arguments, they are: - a. CIT v. S.V. Sreenivasan [2018] 404 ITR 433 (Madras) b. Smt Dayawanti v. CIT [2017] 390 ITR 496 (Del.) c. Smt. Vasantibai N. Shah v. CIT [1995] 213 ITR 805 (Bombay). d. Smt. Tara Devi Aggarwal v. CIT [1973] 88 ITR 323 (SC) e. S. P. Jaiswal v. CIT [1973] 224 ITR 619 (SC) 14. On the other hand, Ld. AR submitted that the real issue to be decided in the present case is not as to whether the s…

ACIT - 17(1), MUMBAI vs. SHRI ANAND JAIKUMAR JAIN, MUMBAI

ITA 3820/MUM/2019[2011-12]Status: DisposedITAT Mumbai22 Apr 2022AY 2011-12

Bench: Shri Amarjit Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Vijay MehtaFor Respondent: Shri O.P. Singh
Section 131(1)Section 143(3)Section 148

…money are duly recorded in the books of the group entities of the assessee, which is sufficient corroboration of the seized material. The Ld. DR has also relied upon several decisions in support of his arguments, they are: - a. CIT v. S.V. Sreenivasan [2018] 404 ITR 433 (Madras) b. Smt Dayawanti v. CIT [2017] 390 ITR 496 (Del.) c. Smt. Vasantibai N. Shah v. CIT [1995] 213 ITR 805 (Bombay). d. Smt. Tara Devi Aggarwal v. CIT [1973] 88 ITR 323 (SC) e. S. P. Jaiswal v. CIT [1973] 224 ITR 619 (SC) 14. On the other hand, Ld. AR submitted that the real issue to be decided in the present case is not as to whether the s…

THUSE ELEKTRONICS PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 7,, PUNE

In the result, the appeal is partly allowed for statistical purposes

ITA 563/PUN/2019[2010-11]Status: DisposedITAT Pune26 Sept 2019AY 2010-11

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

DINESH SHRIVALLABH RATHI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 3,, PUNE

In the result, the appeal is partly allowed for statistical purposes

ITA 975/PUN/2018[2009-10]Status: DisposedITAT Pune26 Sept 2019AY 2009-10

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

M/S. PNG JEWELLERY & GEMS,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,CENTRAL CIRCLE -1(2),, PUNE

In the result, the appeal is partly allowed for statistical purposes

ITA 863/PUN/2018[2011-12]Status: DisposedITAT Pune26 Sept 2019AY 2011-12

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

DEPUTY COMMISSIONER OF INCOME-TAX, PANVEL CIRCLE,, PANVEL vs. M/S. NYKA STEEL PVT.LTD,, RAIGAD

In the result, the appeal is partly allowed for statistical purposes

ITA 451/PUN/2018[2011-12]Status: DisposedITAT Pune26 Sept 2019AY 2011-12

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

ASHOK TANNA,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

In the result, the appeal is partly allowed for statistical purposes

ITA 354/PUN/2018[2010-11]Status: DisposedITAT Pune26 Sept 2019AY 2010-11

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

DADASAHEB VITTHALRAO URHE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

In the result, the appeal is partly allowed for statistical purposes

ITA 306/PUN/2018[2011-12]Status: DisposedITAT Pune26 Sept 2019AY 2011-12

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

DADASAHEB VITTHALRAO URHE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

In the result, the appeal is partly allowed for statistical purposes

ITA 305/PUN/2018[2010-11]Status: DisposedITAT Pune26 Sept 2019AY 2010-11

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

DADASAHEB VITTHALRAO URHE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

In the result, the appeal is partly allowed for statistical purposes

ITA 304/PUN/2018[2009-10]Status: DisposedITAT Pune26 Sept 2019AY 2009-10

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

RENUKA AUTO COMPONENTS INDIA PVT.LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 10,, PUNE

In the result, the appeal is partly allowed for statistical purposes

ITA 1660/PUN/2018[2010-11]Status: DisposedITAT Pune26 Sept 2019AY 2010-11

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

RENUKA AUTO COMPONENTS INDIA PVT.LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 10,, PUNE

In the result, the appeal is partly allowed for statistical purposes

ITA 1659/PUN/2018[2009-10]Status: DisposedITAT Pune26 Sept 2019AY 2009-10

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

BALRAJ SINGH MANDER,,RAIGAD vs. DEPUTY COMMISSIONER OF INCOME-TAX, PANVEL CIRCLE,, PANVEL

In the result, the appeal is partly allowed for statistical purposes

ITA 1520/PUN/2018[2011-12]Status: DisposedITAT Pune26 Sept 2019AY 2011-12

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

BALRAJ SINGH MANDER,,RAIGAD vs. DEPUTY COMMISSIONER OF INCOME-TAX, PANVEL CIRCLE,, PANVEL

In the result, the appeal is partly allowed for statistical purposes

ITA 1519/PUN/2018[2010-11]Status: DisposedITAT Pune26 Sept 2019AY 2010-11

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1,, NASHIK vs. CHANDRASHEKHAR ASHOK JOSHI,, NASHIK

In the result, the appeal is partly allowed for statistical purposes

ITA 1507/PUN/2018[2010-11]Status: DisposedITAT Pune26 Sept 2019AY 2010-11

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

ADROIT ENTERPRISES,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2),, PUNE

In the result, the appeal is partly allowed for statistical purposes

ITA 12/PUN/2018[2011-12]Status: DisposedITAT Pune26 Sept 2019AY 2011-12

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

DEPUTY COMMISSIONER OF INCOME-TAX, PANVEL CIRCLE,, PANVEL vs. M/S. AGARWAL PETROCHEM PRIVATE LIMITED,, RAIGAD

In the result, the appeal is partly allowed for statistical purposes

ITA 1094/PUN/2018[2011-12]Status: DisposedITAT Pune26 Sept 2019AY 2011-12

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

DEPUTY COMMISSIONER OF INCOME-TAX, PANVEL CIRCLE,, PANVEL vs. M/S. AGARWAL PETROCHEM PRIVATE LIMITED,, RAIGAD

In the result, the appeal is partly allowed for statistical purposes

ITA 1093/PUN/2018[2010-11]Status: DisposedITAT Pune26 Sept 2019AY 2010-11

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

…29 (Delhi), following M. Pirai Choodi (supra), has restored the matter in the absence of the AO granting opportunity to cross- examine the witnesses, which formed the basis for addition. 32. The Hon’ble Madras High Court in CIT Vs. S.V. Sreenivasan (2018) 404 ITR 433 (Madras) considered both the judgments of Hon’ble Supreme Court, namely, Andaman Timber Industries (supra) and M. Pirai Choodi (supra) and decided similar issue raised through question no.2 in favour of the Revenue by holding that the Tribunal was not right in deleting additions made in the block assessment on the ground that no opportunity t…

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CIT v. S.V. Sreenivasan (404 ITR 433) — Cited in 49 Judgments | BharatTax