CIT v. Shri Ramdas Motor Transport

238 ITR 177High Court1999#529 most cited

What is CIT v. Shri Ramdas Motor Transport authority for?

The powers under Section 132(4) of the Income-tax Act cannot be invoked when no unaccounted documents or incriminating material is found during a search. An assessment based on a statement recorded under Section 132(4) requires a nexus between the statement and evidence/material found during the search.

181

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2026.

Also referred to as

CIT v. Shri Ramdas Motor Transport · Section 132(4) · search and seizure · incriminating material · undisclosed income · statement under Section 132(4) · assessment based on statement · no unaccounted documents · Section 153A · Section 153C · block assessment · retraction of statement

Also reported as

102 Taxmann 300

Sections most often in play

Section 132(4)Section 143(3)Section 153ASection 153CSection 69ASection 147Section 37(1)Section 133(6)

Issues it is cited on

section 158b(b)section 158bb(1)section 94section 158bbsection 158bcsection 268asection 153(a)retraction of statementstatement under section 132(4)legal expensessection 158bsection 158

Judgments citing CIT v. Shri Ramdas Motor Transport

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7842/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

…thing that may have been found in possession of Sh. Dhananjay Shukla. Accordingly, there is no basis for using such statement as evidence. 1.4 In CIT v. Shri Ramdas Motor Transport CIT v. Shri Ramdas Motor Transport CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177/102 Taxman CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177/102 Taxman [1999] 238 ITR 177/102 Taxman [1999] 238 ITR 177/102 Taxman 300 300, a Division Bench of Andhra Pradesh High Court, reading the 300 300 provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted do…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7841/DEL/2025[2021-22]Status: DisposedITAT Delhi20 Mar 2026AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…ount, documents, money, bullion, jewellery or other valuable article or thing that may have been found in possession of Sh. Dhananjay Shukla. Accordingly, there is no basis for using such statement as evidence. 1.4 In CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177/102 Taxman 300, a Division Bench of Andhra Pradesh High Court, reading the provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under Section 132(4) of the Act cannot be invoked. The relevant passage from the a…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7840/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

…thing that may have been found in possession of Sh. Dhananjay Shukla. Accordingly, there is no basis for using such statement as evidence. 1.4 In CIT v. Shri Ramdas Motor Transport CIT v. Shri Ramdas Motor Transport CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177/102 Taxman CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177/102 Taxman [1999] 238 ITR 177/102 Taxman [1999] 238 ITR 177/102 Taxman 300 300, a Division Bench of Andhra Pradesh High Court, reading the 300 300 provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted do…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7838/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Mar 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…ount, documents, money, bullion, jewellery or other valuable article or thing that may have been found in possession of Sh. Dhananjay Shukla. Accordingly, there is no basis for using such statement as evidence. 1.4 In CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177/102 Taxman 300, a Division Bench of Andhra Pradesh High Court, reading the provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under Section 132(4) of the Act cannot be invoked. The relevant passage from the a…

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT CENTRAL CIRCLE -05 , DELHI

ITA 5521/DEL/2025[2024-25]Status: DisposedITAT Delhi20 Mar 2026AY 2024-25

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

…thing that may have been found in possession of Sh. Dhananjay Shukla. Accordingly, there is no basis for using such statement as evidence. 1.4 In CIT v. Shri Ramdas Motor Transport CIT v. Shri Ramdas Motor Transport CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177/102 Taxman CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177/102 Taxman [1999] 238 ITR 177/102 Taxman [1999] 238 ITR 177/102 Taxman 300 300, a Division Bench of Andhra Pradesh High Court, reading the 300 300 provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted do…

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE-05, DELHI

ITA 5520/DEL/2025[2023-24]Status: DisposedITAT Delhi20 Mar 2026AY 2023-24

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…ount, documents, money, bullion, jewellery or other valuable article or thing that may have been found in possession of Sh. Dhananjay Shukla. Accordingly, there is no basis for using such statement as evidence. 1.4 In CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177/102 Taxman 300, a Division Bench of Andhra Pradesh High Court, reading the provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under Section 132(4) of the Act cannot be invoked. The relevant passage from the a…

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE-05, DELHI

ITA 5517/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…ount, documents, money, bullion, jewellery or other valuable article or thing that may have been found in possession of Sh. Dhananjay Shukla. Accordingly, there is no basis for using such statement as evidence. 1.4 In CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177/102 Taxman 300, a Division Bench of Andhra Pradesh High Court, reading the provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under Section 132(4) of the Act cannot be invoked. The relevant passage from the a…

VESTIGE MARKETING PVT LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 05, DELHI

ITA 5516/DEL/2025[2019-20]Status: DisposedITAT Delhi20 Mar 2026AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…ount, documents, money, bullion, jewellery or other valuable article or thing that may have been found in possession of Sh. Dhananjay Shukla. Accordingly, there is no basis for using such statement as evidence. 1.4 In CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177/102 Taxman 300, a Division Bench of Andhra Pradesh High Court, reading the provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under Section 132(4) of the Act cannot be invoked. The relevant passage from the a…

VESTIGE MARKETING PVT. LTD.,DELHI vs. DCIT, CENTRAL CIRCLE- 05, DELHI

ITA 5515/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Mar 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…ount, documents, money, bullion, jewellery or other valuable article or thing that may have been found in possession of Sh. Dhananjay Shukla. Accordingly, there is no basis for using such statement as evidence. 1.4 In CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177/102 Taxman 300, a Division Bench of Andhra Pradesh High Court, reading the provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under Section 132(4) of the Act cannot be invoked. The relevant passage from the a…

ACIT, CENTRAL CIRCLE-II, LUCKNOW, LUCKNOW vs. RAKESH KUMAR PANDEY, GONDA U.P.

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 460/LKW/2025[2017-18]Status: DisposedITAT Lucknow11 Dec 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

…found during search. In other words, there must be a nexus between the statement recorded and the evidence/material found during search in order to for an assessment to be based on the statement recorded. 22. In CIT v. Sri Ramdas Motor Transport Ltd.: (1999) 238 ITR 177 (AP), a Division Bench of Andhra Pradesh High Court, reading the provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under Section 132(4) of the Act cannot be invoked. The relevant passage from the aforesaid j…

RAKESH KUMAR PANDEY,GONDA vs. DCIT/ACIT (CENTRAL)-2, LUCKNOW

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 351/LKW/2025[2018-19]Status: DisposedITAT Lucknow11 Dec 2025AY 2018-19

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

…found during search. In other words, there must be a nexus between the statement recorded and the evidence/material found during search in order to for an assessment to be based on the statement recorded. 22. In CIT v. Sri Ramdas Motor Transport Ltd.: (1999) 238 ITR 177 (AP), a Division Bench of Andhra Pradesh High Court, reading the provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under Section 132(4) of the Act cannot be invoked. The relevant passage from the aforesaid j…

RAKESH KUMAR PANDEY,GONDA vs. DCIT/ACIT (CENTRAL)-2, LUCKNOW

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 349/LKW/2025[2016-17]Status: DisposedITAT Lucknow11 Dec 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

…found during search. In other words, there must be a nexus between the statement recorded and the evidence/material found during search in order to for an assessment to be based on the statement recorded. 22. In CIT v. Sri Ramdas Motor Transport Ltd.: (1999) 238 ITR 177 (AP), a Division Bench of Andhra Pradesh High Court, reading the provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under Section 132(4) of the Act cannot be invoked. The relevant passage from the aforesaid j…

ACIT CC 2(3) AHMEDABAD, AHMEDABAD vs. AISHA DHIRAJ GOGIA, AHMEDABAD

In the result: 50. To summarize the final outcome:

ITA 1673/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad28 Nov 2025AY 2018-19

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha["ी संजय गग", "ाियक सद" एवं "ी नरे" साद िस!ा, लेखा सद" के सम#।]

…icials. In the facts and circumstances of this case, when seen in the light of above case laws and CBDT circular, additions in this case cannot be said to be justifiably made. 41.6. In the case of “ CIT v. Sri Ramdas Motor Transport Ltd.” Reported in (1999) 238 ITR 177 (AP), Hon’ble Andhra Pradesh High Court, while deliberating upon the provisions of Section 132(4) of the Act has held in cases where no unaccounted documents or incriminating material is found, the powers under Section 132(4) of the Act cannot be invoked. The relevant part of the said order is reproduced below: “A plain reading of sub-section (…

KAYUM RAZAK DHANANI ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

Appeal of the assessee is allowed

ITA 634/BANG/2024[2015-16]Status: DisposedITAT Bangalore24 Nov 2025AY 2015-16

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2015-16

For Appellant: Shri V. Chandrashekar, AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT), Bengaluru
Section 127Section 132Section 139Section 143Section 143(3)Section 153ASection 56(2)(vii)

…thed or found during search. In other words, there must be a nexus between the statement recorded and the evidence/material found during search in order for an assessment to be based on the statement recorded. 20. In CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177 (AP), a Division Bench of the Andhra Pradesh High Court, reading the provision of section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under section 132(4) of the Act cannot be invoked.. .. It is also necessary to mention…

LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, the appeal filed by the assessee is allowed

ITA 412/BANG/2024[2020-21]Status: DisposedITAT Bangalore26 Sept 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 132Section 143(3)Section 144Section 153CSection 153D

…Bang/2024 Page 21 of 40 search. In other words, there must be a nexus between the statement recorded and the evidence/material found during search in order for an assessment to be based on the statement recorded. In CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177 (AP), a Division Bench of the Andhra Pradesh High Court, reading the provision of section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under section 132(4) of the Act cannot be invoked.. .. It is also necessary to mention…

LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3) , BENGALURU

In the result, the appeal filed by the assessee is allowed

ITA 411/BANG/2024[2019-20]Status: DisposedITAT Bangalore26 Sept 2025AY 2019-20

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 132Section 143(3)Section 144Section 153CSection 153D

…Bang/2024 Page 21 of 40 search. In other words, there must be a nexus between the statement recorded and the evidence/material found during search in order for an assessment to be based on the statement recorded. In CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177 (AP), a Division Bench of the Andhra Pradesh High Court, reading the provision of section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under section 132(4) of the Act cannot be invoked.. .. It is also necessary to mention…

LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3) , BENGALURU

In the result, the appeal filed by the assessee is allowed

ITA 410/BANG/2024[2018-19]Status: DisposedITAT Bangalore26 Sept 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 132Section 143(3)Section 144Section 153CSection 153D

…Bang/2024 Page 21 of 40 search. In other words, there must be a nexus between the statement recorded and the evidence/material found during search in order for an assessment to be based on the statement recorded. In CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177 (AP), a Division Bench of the Andhra Pradesh High Court, reading the provision of section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under section 132(4) of the Act cannot be invoked.. .. It is also necessary to mention…

DCIT, CENTRAL CIRCLE-1(3), BENGALURU vs. LATE SHRI MAHABIR PRASAD (LEGAL HEIR MS. PARUL KANSARIA), BENGALURU

In the result, the appeal filed by the assessee is allowed

ITA 170/BANG/2024[2018-19]Status: DisposedITAT Bangalore26 Sept 2025AY 2018-19
Section 132Section 143(3)Section 144Section 153CSection 153D

…170-\nCO 6/Bang/2024\nsearch. In other words, there must be a nexus between\nthe statement recorded and the evidence/material found during\nsearch in order for an assessment to be based on the statement\nrecorded.\nIn CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177 (AP),\na Division Bench of the Andhra Pradesh High Court, reading the\nprovision of section 132(4) of the Act in the context of\ndiscovering undisclosed income, explained that in cases where no\nunaccounted documents or incriminating material is found, the\npowers under section 132(4) of the Act cannot be invoked.. ..\nIt is also necessary to men…

DCIT, CENTRAL CIRCLE-1(3), BAENGALURU vs. LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA), BENGALURU

In the result, the appeal filed by the assessee is allowed

ITA 169/BANG/2024[2017-18]Status: DisposedITAT Bangalore26 Sept 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 132Section 143(3)Section 144Section 153CSection 153D

…Bang/2024 Page 21 of 40 search. In other words, there must be a nexus between the statement recorded and the evidence/material found during search in order for an assessment to be based on the statement recorded. In CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177 (AP), a Division Bench of the Andhra Pradesh High Court, reading the provision of section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under section 132(4) of the Act cannot be invoked.. .. It is also necessary to mention…

DODHIA SYNTHETICS LIMITED,BHIWANDI vs. DCIT-CC-3, THANE, THANE

ITA 2204/MUM/2025[2020-21]Status: DisposedITAT Mumbai17 Sept 2025AY 2020-21
Section 143(3)Section 147Section 250Section 68

…18-12-2014). The\nassessee also relies upon the decision of the decision of\nHon'ble Delhi High Court in the case of Harjeev Aggarwal\n[2016] 70 taxmann.com 95 (Delhi) delivered on 10.03.2016,\ninteralia, relying on CIT v. Shri Ramdas Motor Transport\n[1999] 238 ITR 177/102 Taxman 300 (AP) wherein, it is\nheld that the statements recorded u/s 132(4) of the Act, do\nnot by themselves, constitute incriminating material unless,\nsuch statement relates to any incriminating evidence of\nundisclosed income unearthed during search and seizure.\nThe assessee also places reliance on the judgement of\nJurisdictional Tribu…

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CIT v. Shri Ramdas Motor Transport (238 ITR 177) — Cited in 181 Judgments | BharatTax