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

Sun Jewels Pvt. Ltd. (Formerly Known As Eleganza Jewellery Pvt. Ltd.), Mumbai vs. DCIT - 11(2)(2), Mumbai

In the result, the appeals are allowed for statistical purposes

ITA 322/MUM/2018[2010-11]Status: DisposedITAT Mumbai29 Mar 2019AY 2010-11

Bench: Shri Pawan Singh () & Shri N.K. Pradhan () Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 & Assessment Year: 2013-14 M/S Sun Jewels Pvt. Ltd. Dy. Cit Circle-11(2)(2), (Formerly Known As M/S Vs. Room No. 421, 4Th Floor, Eleganza Jewellery Pvt. Ltd.) Aayakar Bhavan, M.K. Unit No. 102-103, Sdf-Iv, Road, Mumbai-400020. Seepz, Sez, Andheri (E), Mumbai-400096. Pan No. Aabce3519L Appellant Respondent Assessment Year: 2012-13 & Assessment Year: 2013-14 Dy. Cit Circle-11(2)(2), M/S Sun Jewels Pvt. Ltd. Room No. 421, 4Th Floor, Vs. (Formerly Known As M/S Aayakar Bhavan, M.K. Road, Eleganza Jewellery Pvt. Mumbai-400020. Ltd.) Unit No. 102-103, Sdf-Iv, Seepz, Sez, Andheri (E), Mumbai- 400096. Pan No. Aabce3519L Appellant Respondent

For Appellant: Mr. Pramod Kumar Parida & &For Respondent: Mr. B.B. Rajendra Prasad, CIT- DR
Section 115JSection 133(6)Section 142(1)Section 143(3)Section 145Section 148

…it is a case of recorded purchases and not otherwise and no cash element is involved. The Ld. counsels submit that merely on the basis of statement, no addition can be made. In this regard, reliance is placed by them on the decision in CIT v. Ramdas Motor Co. 238 ITR 177 (AP); CIT v. Indian Express 143 ITR 705 (Mad), Del. Iron Syndicate Pvt. Ltd. v. CIT 1979 TLR 1975 (All); New Alfa v. DCIT (2005) 1 SOT 302 (Mum). Also relying on the decision in CIT v. Nikunj Exim Enterprises (2013) 35 taxmann.com 384 (Bom), it is argued that merely because the assessee has failed to produce the party, it is not logical on the pa…

Deputy Commissioner of Income Tax, Kota vs. Shri Vasudev Agrawal, Kota

In the result, appeal of the revenue is dismissed

ITA 1434/JPR/2018[2013-14]Status: DisposedITAT Jaipur22 Mar 2019AY 2013-14
For Appellant: Shri Vijay Goyal (CA) &For Respondent: Shri Varinder Mehta(CIT-DR) fu/kZkfjrh dh vksj ls@
Section 10(38)Section 132Section 132(4)Section 139(1)Section 143(3)Section 153ASection 271(1)(c)

…ed 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 to for an assessment to be based on the statement recorded. 22. 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, Kota vs. Shri Rajendra Agrawal, Kota

In the result, appeal of the revenue is dismissed

ITA 1432/JPR/2018[2013-14]Status: DisposedITAT Jaipur22 Mar 2019AY 2013-14
For Appellant: Shri Vijay Goyal (CA) &For Respondent: Shri Varinder Mehta(CIT-DR) fu/kZkfjrh dh vksj ls@
Section 10(38)Section 132Section 132(4)Section 139(1)Section 143(3)Section 153ASection 271(1)(c)

…ed 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 to for an assessment to be based on the statement recorded. 22. 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, Central Circle, Kota vs. Smt. Jyoti Agarwal, Kota

In the result, appeal of the revenue is dismissed

ITA 1430/JPR/2018[2013-14]Status: DisposedITAT Jaipur22 Mar 2019AY 2013-14
For Appellant: Shri Vijay Goyal (CA) &For Respondent: Shri Varinder Mehta(CIT-DR) fu/kZkfjrh dh vksj ls@
Section 10(38)Section 132Section 132(4)Section 139(1)Section 143(3)Section 153ASection 271(1)(c)

…ed 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 to for an assessment to be based on the statement recorded. 22. 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, Kota vs. Smt. Malti Agarwal, Kota

In the result, appeal of the revenue is dismissed

ITA 1447/JPR/2018[2013-14]Status: DisposedITAT Jaipur21 Mar 2019AY 2013-14
For Appellant: Shri Vijay Goyal (CA) &For Respondent: Shri Varinder Mehta(CIT-DR) fu/kZkfjrh dh vksj ls@
Section 10(38)Section 132Section 132(4)Section 139(1)Section 143(3)Section 153ASection 271(1)(c)

…ed 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 to for an assessment to be based on the statement recorded. 22. 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, Kota vs. Smt. Indira Agrawal, Kota

In the result, appeal of the revenue is dismissed

ITA 1444/JPR/2018[2013-14]Status: DisposedITAT Jaipur21 Mar 2019AY 2013-14
For Appellant: Shri Vijay Goyal (CA) &For Respondent: Shri Varinder Mehta(CIT-DR) fu/kZkfjrh dh vksj ls@
Section 10(38)Section 132Section 132(4)Section 139(1)Section 143(3)Section 153ASection 271(1)(c)

…ed 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 to for an assessment to be based on the statement recorded. 22. 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, Kota vs. Shri Ajay Agarwal, Kota

In the result, appeal of the revenue is dismissed

ITA 1442/JPR/2018[2013-14]Status: DisposedITAT Jaipur21 Mar 2019AY 2013-14
For Appellant: Shri Vijay Goyal (CA) &For Respondent: Shri Varinder Mehta(CIT-DR) fu/kZkfjrh dh vksj ls@
Section 10(38)Section 132Section 132(4)Section 139(1)Section 143(3)Section 153ASection 271(1)(c)

…ed 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 to for an assessment to be based on the statement recorded. 22. 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…

M/S. M.L. Singhi & Associates (P) Ltd., New Delhi vs. DCIT, New Delhi

In the result, we hold that addition of share capital in the year under consideration has been made without relying on any incriminating material found during the course of search

ITA 3337/DEL/2017[2008-09]Status: DisposedITAT Delhi17 Sept 2018AY 2008-09

Bench: Sh. N. K. Saini, Am & Sh. Kuldip Singh, Jm Ita No. 3335/Del/2017 : Asstt. Year : 2006-07

For Appellant: Sh. Gautam Jain, Adv. &For Respondent: Smt. Shefali Swaroop, CIT DR
Section 153ASection 68

…ct may be used for making the assessment but only to the extent it is relatable to the incriminating evidence/material unearthed or found during the course of search. The Hon’ble High Court also cited the decision of CIT Vs. Sh. Ramdas Motor Transport, (1999) 238 ITR 177 of Hon’ble Andhra Pradesh High Court, where it is explained that in case no unaccounted documents or incriminating material is found, the powers under section 132(4) of the Act cannot be invoked. 4.18 Further, as far as the decision of the Hon’ble Supreme Court in the case of Video Master (supra), is concerned, we agree with the argument of the L…

M/S. M.L. Singhi & Associates (P) Ltd., New Delhi vs. DCIT, New Delhi

In the result, we hold that addition of share capital in the year under consideration has been made without relying on any incriminating material found during the course of search

ITA 3336/DEL/2017[2007-08]Status: DisposedITAT Delhi17 Sept 2018AY 2007-08

Bench: Sh. N. K. Saini, Am & Sh. Kuldip Singh, Jm Ita No. 3335/Del/2017 : Asstt. Year : 2006-07

For Appellant: Sh. Gautam Jain, Adv. &For Respondent: Smt. Shefali Swaroop, CIT DR
Section 153ASection 68

…ct may be used for making the assessment but only to the extent it is relatable to the incriminating evidence/material unearthed or found during the course of search. The Hon’ble High Court also cited the decision of CIT Vs. Sh. Ramdas Motor Transport, (1999) 238 ITR 177 of Hon’ble Andhra Pradesh High Court, where it is explained that in case no unaccounted documents or incriminating material is found, the powers under section 132(4) of the Act cannot be invoked. 4.18 Further, as far as the decision of the Hon’ble Supreme Court in the case of Video Master (supra), is concerned, we agree with the argument of the L…

M/S. M.L. Singhi & Associates (P) Ltd., New Delhi vs. DCIT, New Delhi

In the result, we hold that addition of share capital in the year under consideration has been made without relying on any incriminating material found during the course of search

ITA 3335/DEL/2017[2006-07]Status: DisposedITAT Delhi17 Sept 2018AY 2006-07

Bench: Sh. N. K. Saini, Am & Sh. Kuldip Singh, Jm Ita No. 3335/Del/2017 : Asstt. Year : 2006-07

For Appellant: Sh. Gautam Jain, Adv. &For Respondent: Smt. Shefali Swaroop, CIT DR
Section 153ASection 68

…ct may be used for making the assessment but only to the extent it is relatable to the incriminating evidence/material unearthed or found during the course of search. The Hon’ble High Court also cited the decision of CIT Vs. Sh. Ramdas Motor Transport, (1999) 238 ITR 177 of Hon’ble Andhra Pradesh High Court, where it is explained that in case no unaccounted documents or incriminating material is found, the powers under section 132(4) of the Act cannot be invoked. 4.18 Further, as far as the decision of the Hon’ble Supreme Court in the case of Video Master (supra), is concerned, we agree with the argument of the L…

ACIT, New Delhi vs. Sh. Sandeep Bindra, New Delhi

In the result these grounds of appeal of the revenue are dismissed

ITA 2783/DEL/2011[2003-04]Status: DisposedITAT Delhi28 May 2018AY 2003-04

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Rajiv Saxena, AdvFor Respondent: Shri SS Rana, CIT DR
Section 145(3)Section 43B

…ourse of search or otherwise, supporting the statement made, the statement cannot be relied upon for the purpose of making addition. In support of this reliance was placed on the following decisions: i. CIT vs. Sri Ramdas Motor Transport (MANU/AP/0950/1998 : 238 ITR 177) (AP) ii. Kailashben Manharlal Chokshi vs. CIT (MANU/GJ/0744/2008 : 328 ITR 411) (Guj) and iii. Saveetha Institute of Medical & Technical Sciences vs. ACIT 12 ITR (Trib.) 376. g) Kailashben Manharlal Chokshi v. CIT MANU/GJ/0744/2008 : [2010] 328 ITR 411 (guj) h) Hon'ble Apex Court in the case of Pullangode Rubber Produce Co. Ltd. vs. State of Ke…

ACIT, New Delhi vs. Sh. Sandeep Bindra, New Delhi

In the result these grounds of appeal of the revenue are dismissed

ITA 2782/DEL/2011[2002-03]Status: DisposedITAT Delhi28 May 2018AY 2002-03

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Rajiv Saxena, AdvFor Respondent: Shri SS Rana, CIT DR
Section 145(3)Section 43B

…ourse of search or otherwise, supporting the statement made, the statement cannot be relied upon for the purpose of making addition. In support of this reliance was placed on the following decisions: i. CIT vs. Sri Ramdas Motor Transport (MANU/AP/0950/1998 : 238 ITR 177) (AP) ii. Kailashben Manharlal Chokshi vs. CIT (MANU/GJ/0744/2008 : 328 ITR 411) (Guj) and iii. Saveetha Institute of Medical & Technical Sciences vs. ACIT 12 ITR (Trib.) 376. g) Kailashben Manharlal Chokshi v. CIT MANU/GJ/0744/2008 : [2010] 328 ITR 411 (guj) h) Hon'ble Apex Court in the case of Pullangode Rubber Produce Co. Ltd. vs. State of Ke…

Shri Sandeep Bindra, New Delhi vs. ACIT, New Delhi

In the result these grounds of appeal of the revenue are dismissed

ITA 2651/DEL/2011[2006-07]Status: DisposedITAT Delhi28 May 2018AY 2006-07

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Rajiv Saxena, AdvFor Respondent: Shri SS Rana, CIT DR
Section 145(3)Section 43B

…ourse of search or otherwise, supporting the statement made, the statement cannot be relied upon for the purpose of making addition. In support of this reliance was placed on the following decisions: i. CIT vs. Sri Ramdas Motor Transport (MANU/AP/0950/1998 : 238 ITR 177) (AP) ii. Kailashben Manharlal Chokshi vs. CIT (MANU/GJ/0744/2008 : 328 ITR 411) (Guj) and iii. Saveetha Institute of Medical & Technical Sciences vs. ACIT 12 ITR (Trib.) 376. g) Kailashben Manharlal Chokshi v. CIT MANU/GJ/0744/2008 : [2010] 328 ITR 411 (guj) h) Hon'ble Apex Court in the case of Pullangode Rubber Produce Co. Ltd. vs. State of Ke…

Shri Sandeep Bindra, New Delhi vs. ACIT, New Delhi

In the result these grounds of appeal of the revenue are dismissed

ITA 2650/DEL/2011[2005-06]Status: DisposedITAT Delhi28 May 2018AY 2005-06

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Rajiv Saxena, AdvFor Respondent: Shri SS Rana, CIT DR
Section 145(3)Section 43B

…ourse of search or otherwise, supporting the statement made, the statement cannot be relied upon for the purpose of making addition. In support of this reliance was placed on the following decisions: i. CIT vs. Sri Ramdas Motor Transport (MANU/AP/0950/1998 : 238 ITR 177) (AP) ii. Kailashben Manharlal Chokshi vs. CIT (MANU/GJ/0744/2008 : 328 ITR 411) (Guj) and iii. Saveetha Institute of Medical & Technical Sciences vs. ACIT 12 ITR (Trib.) 376. g) Kailashben Manharlal Chokshi v. CIT MANU/GJ/0744/2008 : [2010] 328 ITR 411 (guj) h) Hon'ble Apex Court in the case of Pullangode Rubber Produce Co. Ltd. vs. State of Ke…

Shri Sandeep Bindra, New Delhi vs. ACIT, New Delhi

In the result these grounds of appeal of the revenue are dismissed

ITA 2649/DEL/2011[2004-05]Status: DisposedITAT Delhi28 May 2018AY 2004-05

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Rajiv Saxena, AdvFor Respondent: Shri SS Rana, CIT DR
Section 145(3)Section 43B

…ourse of search or otherwise, supporting the statement made, the statement cannot be relied upon for the purpose of making addition. In support of this reliance was placed on the following decisions: i. CIT vs. Sri Ramdas Motor Transport (MANU/AP/0950/1998 : 238 ITR 177) (AP) ii. Kailashben Manharlal Chokshi vs. CIT (MANU/GJ/0744/2008 : 328 ITR 411) (Guj) and iii. Saveetha Institute of Medical & Technical Sciences vs. ACIT 12 ITR (Trib.) 376. g) Kailashben Manharlal Chokshi v. CIT MANU/GJ/0744/2008 : [2010] 328 ITR 411 (guj) h) Hon'ble Apex Court in the case of Pullangode Rubber Produce Co. Ltd. vs. State of Ke…

Shri Sandeep Bindra, New Delhi vs. ACIT, New Delhi

In the result these grounds of appeal of the revenue are dismissed

ITA 2648/DEL/2011[2003-04]Status: DisposedITAT Delhi28 May 2018AY 2003-04

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Rajiv Saxena, AdvFor Respondent: Shri SS Rana, CIT DR
Section 145(3)Section 43B

…ourse of search or otherwise, supporting the statement made, the statement cannot be relied upon for the purpose of making addition. In support of this reliance was placed on the following decisions: i. CIT vs. Sri Ramdas Motor Transport (MANU/AP/0950/1998 : 238 ITR 177) (AP) ii. Kailashben Manharlal Chokshi vs. CIT (MANU/GJ/0744/2008 : 328 ITR 411) (Guj) and iii. Saveetha Institute of Medical & Technical Sciences vs. ACIT 12 ITR (Trib.) 376. g) Kailashben Manharlal Chokshi v. CIT MANU/GJ/0744/2008 : [2010] 328 ITR 411 (guj) h) Hon'ble Apex Court in the case of Pullangode Rubber Produce Co. Ltd. vs. State of Ke…

M/S Brahmaputra Finlease (P) Ltd., New Delhi vs. DCIT, New Delhi

In the result, we hold that addition of share capital in the year under consideration has been made without relying on any incriminating material found during the course of search

ITA 3332/DEL/2017[2007-08]Status: DisposedITAT Delhi29 Dec 2017AY 2007-08

Bench: Sh. O.P. Kant & Sh. K.N. Charyassessment Year: 2007-08 Vs. Dcit, Central Circle -17, New M/S. Brahmaputra Finlease (P) Ltd., Brahmaputra House, A-7, Delhi Nh-8, Mahipalpur Crossing, Mahipalpur, New Delhi Pan : Aaack3691G (Appellant) (Respondent) Appellant By S/Sh. Gautam Jain & Piyush Kumar Kamal, Advocates Respondent By Smt. Aparna Karan, Cit(Dr) Date Of Hearing 21.12.2017 Date Of Pronouncement 29.12.2017 Order

Section 153ASection 68

…ct may be used for making the assessment but only to the extent it is relatable to the incriminating evidence/material unearthed or found during the course of search. The Hon’ble High Court also cited the decision of CIT Vs. Sh. Ramdas Motor Transport, (1999) 238 ITR 177 of Hon’ble Andhra Pradesh High Court, where it is explained that in case no unaccounted documents or incriminating material is found, the powers under section 132(4) of the Act cannot be invoked. 4.18 Further, as far as the decision of the Hon’ble Supreme Court in the case of Video Master (supra), is concerned, we agree with the argument of the L…

M/S. M.G. Contractors Pvt. Ltd., New Delhi vs. DCIT, Faridabad

In the result, all the appeals of the assessee are allowed

ITA 7034/DEL/2014[2006-07]Status: DisposedITAT Delhi19 Sept 2016AY 2006-07

Bench: Shri I.C. Sudhir & Shri Prashant Maharishi

For Appellant: Sh. P.C. Yadav, AdvFor Respondent: Sh. P. DAM Kanunjna, Sr. DR
Section 143(2)Section 153ASection 271(1)(c)

…. It is submitted that so far as the case of the present assessee is concerned the facts are on better footage. Further assessee seeks to rely on the following decisions. a. CIT Vs Harkaran Das Ved pal- 336 ITR 8(Del) b. CIT Vs Shri Ramdas Motors reported in 238 ITR 177(AP) 30 It is next submitted that provisions of section 271(1)(C) are discretionary provisions as is evident from the fact that the legislature has used the expression “may” and the same are not automatically invoke able in each and every case. In the context reliance can be placed on the decision of Hon‟ble Hyderabad Bench in the case of K. Dhee…

Sh. Ajay Gupta, New Delhi vs. ACIT, New Delhi

In the result, the appeals are allowed

ITA 1259/DEL/2014[2005-06]Status: DisposedITAT Delhi01 Aug 2016AY 2005-06

Bench: Shri R.S. Syal, Am & Ms Suchitra Kamble, Jm

For Appellant: Shri Anil Jain, AdvocateFor Respondent: Shri Ravi Jain, CIT-DR
Section 132Section 153ASection 271(1)(c)

…een taken by the Hon’ble Delhi High Court in an earlier judgment in the case of CIT vs. Sunil Aggarwal (2015) 379 ITR367 (Del). To the similar effect is an earlier decision of the Hon’ble Andhra Pradesh High Court in CIT VS. Shri Ramdas Motor Transport (1999) 238 ITR 177(AP), in which the Hon’ble High Court refused to give any evidentiary value to the statement made by the assessee u/s 132(4) as the Department could not find any unaccounted money, article ITA No.1259 & 1260/Del/2014 or thing or incriminating document either at the premises of the company or at the residence of managing director or other directors…

Sh. Ajay Gupta, Delhi vs. DCIT, New Delhi

In the result, the appeals are allowed

ITA 4144/DEL/2010[2005-06]Status: DisposedITAT Delhi01 Aug 2016AY 2005-06

Bench: Shri R.S. Syal, Am & Ms Suchitra Kamble, Jm

For Appellant: Shri Anil Jain, AdvocateFor Respondent: Shri Ravi Jain, CIT-DR
Section 132Section 153ASection 271(1)(c)

…een taken by the Hon’ble Delhi High Court in an earlier judgment in the case of CIT vs. Sunil Aggarwal (2015) 379 ITR367 (Del). To the similar effect is an earlier decision of the Hon’ble Andhra Pradesh High Court in CIT VS. Shri Ramdas Motor Transport (1999) 238 ITR 177(AP), in which the Hon’ble High Court refused to give any evidentiary value to the statement made by the assessee u/s 132(4) as the Department could not find any unaccounted money, article ITA No.1259 & 1260/Del/2014 or thing or incriminating document either at the premises of the company or at the residence of managing director or other directors…