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 366,470 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

Dodhia Synthetics Limited, Bhiwandi vs. DCIT-CC-3, Thane

The appeal of the assessee is Allowed on the

ITA 2190/MUM/2025[2013-14]Status: DisposedITAT Mumbai17 Sept 2025AY 2013-14
Section 143(3)Section 147Section 250Section 68

…Dated 18-12-2014). The assessee also relies upon the decision of the decision of Hon'ble Delhi High Court in the case of Harjeev Aggarwal [2016] 70 taxmann.com 95 (Delhi) delivered on 10.03.2016, interalia, relying on CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177/102 Taxman 300 (AP) wherein, it is held that the statements recorded u/s 132(4) of the Act, do 30 not by themselves, constitute incriminating material unless, such statement relates to any incriminating evidence of undisclosed income unearthed during search and seizure. The assessee also places reliance on the judgement of Jurisdictional Tribuna…

DCIT, Central Circle -3, Thane vs. Dodhia Synthetics Limited, Bhiwandi

The appeal of the assessee is Allowed on the

ITA 2105/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Sept 2025AY 2014-15
Section 143(3)Section 147Section 250Section 68

…Dated 18-12-2014). The assessee also relies upon the decision of the decision of Hon'ble Delhi High Court in the case of Harjeev Aggarwal [2016] 70 taxmann.com 95 (Delhi) delivered on 10.03.2016, interalia, relying on CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177/102 Taxman 300 (AP) wherein, it is held that the statements recorded u/s 132(4) of the Act, do not by themselves, constitute incriminating material unless, such statement relates to any incriminating evidence of undisclosed income unearthed during search and seizure. The assessee also places reliance on the judgement of Jurisdictional Tribunal, M…

Deputy Commissioner of Income Tax, Mumbai vs. Mgn Agro Properties Private Limited, Mumbai

In the result, the appeal filed by the revenue has been rendered as dismissed, in terms

ITA 3759/MUM/2024[2018-19]Status: DisposedITAT Mumbai03 Sept 2025AY 2018-19

Bench: Smt. Beena Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Harsh Kapadia a/w. Shri AjayFor Respondent: Shri Umashankar Prasad, (CIT DR)
Section 132(4)Section 143(1)Section 143(2)Section 147Section 148Section 250Section 69A

…the sole basis of drawing any adverse inference in the hands of any assessee, unless it is corroborated by independent evidence. 10.10 The ld. AR invited my attention to the judgment of the Hon'ble AP High Court in the case of CIT vs. Ramdas Motor Transport [238 ITR 177 at 183] with regard to the power of recording statement by the Authorised Officer u/s.132(4). It was held therein as follows:- “Form the above, it is clear that the question of examining any person by the authorized officer arises only when he found such person in possession of any undisclosed money or books of account, Thus, where a person is fo…

M/S. Global Tech Park Pvt Ltd., Bangalore vs. DCIT, Central Circle-1(1), Bengaluru

In the result appeal no 2319/ Bang/2024 filed by the assessee is partly allowed

ITA 2320/BANG/2024[2017-18]Status: DisposedITAT Bangalore31 Jul 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT), Bengaluru
Section 131Section 132(4)Section 143(2)Section 153ASection 153CSection 40aSection 69

…e must be a nexus between the ITA Nos.2315 to 2320 & 2363/Bang/2024 Page 11 of 48 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…

M/S. Global Tech Park Pvt Ltd., Bangalore vs. DCIT, Central Circle-1(1), Bengaluru

ITA 2319/BANG/2024[2016-17]Status: DisposedITAT Bangalore31 Jul 2025AY 2016-17

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT), Bengaluru
Section 131Section 132(4)Section 143(2)Section 153ASection 153CSection 40aSection 69

…unearthed 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. 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 t…

M/S. Global Tech Park Pvt. Ltd., Bangalore vs. DCIT, Central Circle-1(1), Bengaluru

In the result appeal no 2319/ Bang/2024 filed by the assessee is partly allowed

ITA 2318/BANG/2024[2015-16]Status: DisposedITAT Bangalore31 Jul 2025AY 2015-16

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT), Bengaluru
Section 131Section 132(4)Section 143(2)Section 153ASection 153CSection 40aSection 69

…e must be a nexus between the ITA Nos.2315 to 2320 & 2363/Bang/2024 Page 11 of 48 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…

M/S. Global Tech Park Pvt Ltd., Bangalore vs. DCIT, Central Circle-1(1), Bengaluru

In the result appeal no 2319/ Bang/2024 filed by the assessee is partly allowed

ITA 2317/BANG/2024[2014-15]Status: DisposedITAT Bangalore31 Jul 2025AY 2014-15

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT), Bengaluru
Section 131Section 132(4)Section 143(2)Section 153ASection 153CSection 40aSection 69

…e must be a nexus between the ITA Nos.2315 to 2320 & 2363/Bang/2024 Page 11 of 48 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…

M/S. Global Tech Park Pvt. Ltd., Bangalore vs. DCIT, Central Circle-1(1), Bengaluru

In the result appeal no 2319/ Bang/2024 filed by the assessee is partly allowed

ITA 2316/BANG/2024[2013-14]Status: DisposedITAT Bangalore31 Jul 2025AY 2013-14

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT), Bengaluru
Section 131Section 132(4)Section 143(2)Section 153ASection 153CSection 40aSection 69

…e must be a nexus between the ITA Nos.2315 to 2320 & 2363/Bang/2024 Page 11 of 48 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…

M/S. Global Tech Park Pvt Ltd., Bangalore vs. DCIT, Central Circle-1(1), Bengaluru

ITA 2315/BANG/2024[2012-13]Status: DisposedITAT Bangalore31 Jul 2025AY 2012-13

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT), Bengaluru
Section 131Section 132(4)Section 143(2)Section 153ASection 153CSection 40aSection 69

…unearthed 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. 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 t…

Shri Balaji India Private Limited, Gurgaon vs. Assistant Commissioner of Income Tax Central Circle 1, Faridabad

Accordingly, the present appeals, along with all pending applications, are dismissed

ITA 5752/DEL/2024[2021-22]Status: DisposedITAT Delhi15 Jul 2025AY 2021-22

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 5744/Del/2024 : Asstt. Year: 2019-20 Ita No. 5745/Del/2024 : Asstt. Year: 2020-21 Ita No. 5752/Del/2024 : Asstt. Year: 2021-22 Shri Balaji (India) Pvt. Ltd., Vs Acit, Vpo Badshahpur, Near Arya Samaj Central Circle-1, Mandir, Gurgaon-122017 Faridabad-121001 (Appellant) (Respondent) Pan No. Aaccs5328Q Assessee By: Sh. Anshul Mittal, Adv. Revenue By : Sh. Mahesh Kumar, Cit-Dr Date Of Hearing: 15.07.2025 Date Of Pronouncement: 15.07.2025 Order Per Satbeer Singh Godara: These Assessee’S Three Appeals Ita Nos. 5744, 5745 & 5752/Del/2024, For Assessment Years 2019-20, 2020-21 & 2021-22, Arise Against The Cit(A)-3, Gurgaon’S Orders Dated 21St & 22Nd October, 2024 Passed In Case Nos. 10964/2018-19, 10827/2019-20 & 10090/2020-21, In Proceedings U/S 143(3) R.W.S. 153A Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: Sh. Anshul Mittal, AdvFor Respondent: Sh. Mahesh Kumar, CIT-DR
Section 132Section 143(3)Section 148Section 153ASection 153CSection 260A

…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. 26. 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 Shri Balaji (India) Pvt. Ltd. found, the powers under Section 132(4) of the Act cannot be invoked. (…) 27. It…

Shri Balaji India Private Limited, Gurgaon vs. Assistant Commissioner of Income Tax Central Circle 1, Faridabad

Accordingly, the present appeals, along with all pending applications, are dismissed

ITA 5745/DEL/2024[2020-21]Status: DisposedITAT Delhi15 Jul 2025AY 2020-21

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 5744/Del/2024 : Asstt. Year: 2019-20 Ita No. 5745/Del/2024 : Asstt. Year: 2020-21 Ita No. 5752/Del/2024 : Asstt. Year: 2021-22 Shri Balaji (India) Pvt. Ltd., Vs Acit, Vpo Badshahpur, Near Arya Samaj Central Circle-1, Mandir, Gurgaon-122017 Faridabad-121001 (Appellant) (Respondent) Pan No. Aaccs5328Q Assessee By: Sh. Anshul Mittal, Adv. Revenue By : Sh. Mahesh Kumar, Cit-Dr Date Of Hearing: 15.07.2025 Date Of Pronouncement: 15.07.2025 Order Per Satbeer Singh Godara: These Assessee’S Three Appeals Ita Nos. 5744, 5745 & 5752/Del/2024, For Assessment Years 2019-20, 2020-21 & 2021-22, Arise Against The Cit(A)-3, Gurgaon’S Orders Dated 21St & 22Nd October, 2024 Passed In Case Nos. 10964/2018-19, 10827/2019-20 & 10090/2020-21, In Proceedings U/S 143(3) R.W.S. 153A Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: Sh. Anshul Mittal, AdvFor Respondent: Sh. Mahesh Kumar, CIT-DR
Section 132Section 143(3)Section 148Section 153ASection 153CSection 260A

…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. 26. 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 Shri Balaji (India) Pvt. Ltd. found, the powers under Section 132(4) of the Act cannot be invoked. (…) 27. It…

Shri Balaji India Private Limited, Gurugram vs. Assistant Commissioner of Income Tax, Faridabad

Accordingly, the present appeals, along with all pending applications, are dismissed

ITA 5744/DEL/2024[2019-20]Status: DisposedITAT Delhi15 Jul 2025AY 2019-20

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 5744/Del/2024 : Asstt. Year: 2019-20 Ita No. 5745/Del/2024 : Asstt. Year: 2020-21 Ita No. 5752/Del/2024 : Asstt. Year: 2021-22 Shri Balaji (India) Pvt. Ltd., Vs Acit, Vpo Badshahpur, Near Arya Samaj Central Circle-1, Mandir, Gurgaon-122017 Faridabad-121001 (Appellant) (Respondent) Pan No. Aaccs5328Q Assessee By: Sh. Anshul Mittal, Adv. Revenue By : Sh. Mahesh Kumar, Cit-Dr Date Of Hearing: 15.07.2025 Date Of Pronouncement: 15.07.2025 Order Per Satbeer Singh Godara: These Assessee’S Three Appeals Ita Nos. 5744, 5745 & 5752/Del/2024, For Assessment Years 2019-20, 2020-21 & 2021-22, Arise Against The Cit(A)-3, Gurgaon’S Orders Dated 21St & 22Nd October, 2024 Passed In Case Nos. 10964/2018-19, 10827/2019-20 & 10090/2020-21, In Proceedings U/S 143(3) R.W.S. 153A Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: Sh. Anshul Mittal, AdvFor Respondent: Sh. Mahesh Kumar, CIT-DR
Section 132Section 143(3)Section 148Section 153ASection 153CSection 260A

…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. 26. 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 Shri Balaji (India) Pvt. Ltd. found, the powers under Section 132(4) of the Act cannot be invoked. (…) 27. It…

Deputy Commissioner of Income Tax, New Delhi vs. Deepak Narang, New Delhi

In the result, Appeals of the Assessee in ITA Nos

ITA 3947/DEL/2023[2020-21]Status: DisposedITAT Delhi30 Jun 2025AY 2020-21

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Ita No. 3391/Del/2023 (A.Y. 2019-20) Deepak Narang Vs. Dcit A-2/66, Top Floor, Paschim Central Circle-29, 318, Income Vihar, West Delhi Tax Building, E-2, Ara Centre, Pan: Aafpn6476N Jhandewalan Extension, Delhi Appellant Respondent Dcit Vs. Deepak Narang Central Circle-29, 318, A-2/66,Top Floor, Paschim Income Tax Building, E-2, Vihar, Ara Centre, Jhandewalan West Delhi, Extension, Delhi Delhi Pan: Aafpn6476N Appellant Respondent

Section 132(1)Section 153ASection 153C

…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. 26. 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. (...) 27. It is also necessary to mention…

Deepak Narang, Delhi vs. DCIT, Central Circle - 29, Delhi

In the result, Appeals of the Assessee in ITA Nos

ITA 3392/DEL/2023[A.Y. 2020-21]Status: DisposedITAT Delhi30 Jun 2025

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Ita No. 3391/Del/2023 (A.Y. 2019-20) Deepak Narang Vs. Dcit A-2/66, Top Floor, Paschim Central Circle-29, 318, Income Vihar, West Delhi Tax Building, E-2, Ara Centre, Pan: Aafpn6476N Jhandewalan Extension, Delhi Appellant Respondent Dcit Vs. Deepak Narang Central Circle-29, 318, A-2/66,Top Floor, Paschim Income Tax Building, E-2, Vihar, Ara Centre, Jhandewalan West Delhi, Extension, Delhi Delhi Pan: Aafpn6476N Appellant Respondent

Section 132(1)Section 153ASection 153C

…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. 26. 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. (...) 27. It is also necessary to mention…

Deepak Narang, Delhi vs. DCIT, Central Circle -29, Delhi

In the result, Appeals of the Assessee in ITA Nos

ITA 3391/DEL/2023[A.Y. 2019-20]Status: DisposedITAT Delhi30 Jun 2025

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Ita No. 3391/Del/2023 (A.Y. 2019-20) Deepak Narang Vs. Dcit A-2/66, Top Floor, Paschim Central Circle-29, 318, Income Vihar, West Delhi Tax Building, E-2, Ara Centre, Pan: Aafpn6476N Jhandewalan Extension, Delhi Appellant Respondent Dcit Vs. Deepak Narang Central Circle-29, 318, A-2/66,Top Floor, Paschim Income Tax Building, E-2, Vihar, Ara Centre, Jhandewalan West Delhi, Extension, Delhi Delhi Pan: Aafpn6476N Appellant Respondent

Section 132(1)Section 153ASection 153C

…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. 26. 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. (...) 27. It is also necessary to mention…

Deepak Narang, Delhi vs. DCIT, Central Circle - 29, New Delhi

In the result, Appeals of the Assessee in ITA Nos

ITA 3390/DEL/2023[A.Y. 2018-19]Status: DisposedITAT Delhi30 Jun 2025

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Ita No. 3391/Del/2023 (A.Y. 2019-20) Deepak Narang Vs. Dcit A-2/66, Top Floor, Paschim Central Circle-29, 318, Income Vihar, West Delhi Tax Building, E-2, Ara Centre, Pan: Aafpn6476N Jhandewalan Extension, Delhi Appellant Respondent Dcit Vs. Deepak Narang Central Circle-29, 318, A-2/66,Top Floor, Paschim Income Tax Building, E-2, Vihar, Ara Centre, Jhandewalan West Delhi, Extension, Delhi Delhi Pan: Aafpn6476N Appellant Respondent

Section 132(1)Section 153ASection 153C

…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. 26. 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. (...) 27. It is also necessary to mention…

Sushen Mohan Gupta, New Delhi vs. Assistant Commissioner of Income Tax, Central Circle- 15, Delhi

ITA 3005/DEL/2024[2017-18]Status: DisposedITAT Delhi20 May 2025AY 2017-18

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Date of Hearing
Section 132(4)Section 153ASection 50Section 68

…; Best Infrastructure (India) Pvt. Ltd. reported in 397 ITR 82 (Del); PCIT vs. Pavitra Realcon Pvt. Ltd. in ITA No. 579/2018 (Del HC); CIT v. Anand Kumar Jain (HUF) reported in 133 taxmann.com 289 (Del HC) ; and CIT vs. Shri Ramdas Motor Transport reported in 238 ITR 177 (AP), among other Tribunal decisions. 20. Hence, according to the Ld. AR, all the above statements are bereft of any supporting evidence and in any case, do not incriminate the assessee under any stretch of imagination. Besides, none of the three persons have admitted to having incurred any expenditure outside the books of account. 21. The Ld. AR…

Sushen Mohan Gupta, New Delhi vs. Assistant Commissioner of Income Tax, Central Circle- 15, Delhi

ITA 3004/DEL/2024[2016-17]Status: DisposedITAT Delhi20 May 2025AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Debesh Panda, Special counsel for the Department
Section 132(4)Section 153ASection 50Section 68

…; Best Infrastructure (India) Pvt. Ltd. reported in 397 ITR 82 (Del); PCIT vs. Pavitra Realcon Pvt. Ltd. in ITA No. 579/2018 (Del HC); CIT v. Anand Kumar Jain (HUF) reported in 133 taxmann.com 289 (Del HC) ; and CIT vs. Shri Ramdas Motor Transport reported in 238 ITR 177 (AP), among other Tribunal decisions. 20. Hence, according to the Ld. AR, all the above statements are bereft of any supporting evidence and in any case, do not incriminate the assessee under any stretch of imagination. Besides, none of the three persons have admitted to having incurred any expenditure outside the books of account. ITA Nos. 2999…

Sushen Mohan Gupta, New Delhi vs. Assistant Commissioner of Income Tax, Central Circle- 15, Delhi

ITA 3003/DEL/2024[2015-16]Status: DisposedITAT Delhi20 May 2025AY 2015-16

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Ms. Ragini Handa, Adv
Section 132(4)Section 153ASection 50Section 68

…; Best Infrastructure (India) Pvt. Ltd. reported in 397 ITR 82 (Del); PCIT vs. Pavitra Realcon Pvt. Ltd. in ITA No. 579/2018 (Del HC); CIT v. Anand Kumar Jain (HUF) reported in 133 taxmann.com 289 (Del HC) ; and CIT vs. Shri Ramdas Motor Transport reported in 238 ITR 177 (AP), among other Tribunal decisions. 20. Hence, according to the Ld. AR, all the above statements are bereft of any supporting evidence and in any case, do not incriminate the assessee under any stretch of imagination. Besides, none of the three persons have admitted to having incurred any expenditure outside the books of account. 21. The Ld. AR…

Sushen Mohan Gupta, New Delhi vs. Assistant Commissioner of Income Tax, Central Circle- 15, Delhi

ITA 3002/DEL/2024[2014-15]Status: DisposedITAT Delhi20 May 2025AY 2014-15

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Ms. Ragini Handa, Adv
Section 132(4)Section 153ASection 50Section 68

…; Best Infrastructure (India) Pvt. Ltd. reported in 397 ITR 82 (Del); PCIT vs. Pavitra Realcon Pvt. Ltd. in ITA No. 579/2018 (Del HC); CIT v. Anand Kumar Jain (HUF) reported in 133 taxmann.com 289 (Del HC) ; and CIT vs. Shri Ramdas Motor Transport reported in 238 ITR 177 (AP), among other Tribunal decisions. 20. Hence, according to the Ld. AR, all the above statements are bereft of any supporting evidence and in any case, do not incriminate the assessee under any stretch of imagination. Besides, none of the three persons have admitted to having incurred any expenditure outside the books of account. 21. The Ld. AR…