CIT v. Smt. Suraj Devi

328 ITR 604High Court2010#1963 most cited

What is CIT v. Smt. Suraj Devi authority for?

The primary burden of proof for concealment of income lies with the revenue, and a DVO valuation report can only be relied upon after the revenue has discharged this initial burden.

58

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2010 to 2025.

Also referred to as

CIT v. Smt. Suraj Devi · burden of proof concealment · DVO valuation report · Section 43CA · primary burden on revenue · onus of proof · income tax concealment · valuation report reliance

Also reported as

197 Taxmann 173

Sections most often in play

Section 154Section 143(3)Section 127Section 139Section 143(2)Section 250Section 251Section 43CA
Read the full judgment

Issues it is cited on

section 142asection 44afsection 131(1)(d)section 55asection 150surrender of incomemat creditaccumulated profitssection 158bdsection 142(2)section 80icsection 35ad

Judgments citing CIT v. Smt. Suraj Devi

Mr. Hirjiparbat Gada, Mumbai vs. ITO- Circle 24(1), Mumbai

In the result, In the result, the appeal of the assesse bearing ITA No

ITA 528/MUM/2024[2016-17]Status: DisposedITAT Mumbai11 Aug 2025AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar- A.Y. 2014-15 - A.Y. 2014-15 - A.Y. 2016-17

For Appellant: Shri Vipul Joshi a/w Shri Prashant GhumareFor Respondent: Shri Hemanshu Joshi, SR DR
Section 143(1)Section 143(2)Section 143(3)Section 154Section 2Section 250Section 43CSection 56(2)(vii)Section 6Section 69

…d against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K.P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604/[2011] 197 Taxman 173 (Delhi) (Mag.) wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case…

Mr. Hirjiparbat Gada, Mumbai vs. ITO-Ward 24(1), Mumbai

In the result, In the result, the appeal of the assesse bearing ITA No

ITA 527/MUM/2024[2014-15]Status: DisposedITAT Mumbai11 Aug 2025AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar- A.Y. 2014-15 - A.Y. 2014-15 - A.Y. 2016-17

For Appellant: Shri Vipul Joshi a/w Shri Prashant GhumareFor Respondent: Shri Hemanshu Joshi, SR DR
Section 143(1)Section 143(2)Section 143(3)Section 154Section 2Section 250Section 43CSection 56(2)(vii)Section 6Section 69

…d against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K.P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604/[2011] 197 Taxman 173 (Delhi) (Mag.) wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case…

Mr. Hirjiparbat Gada, Mumbai vs. ITO-Ward 24(1), Mumbai

In the result, In the result, the appeal of the assesse bearing ITA No

ITA 526/MUM/2024[2014-15]Status: DisposedITAT Mumbai11 Aug 2025AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

Section 143(1)Section 143(2)Section 143(3)Section 154Section 250Section 43CSection 56(2)(vii)Section 6Section 69

…d against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K.P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604/[2011] 197 Taxman 173 (Delhi) (Mag.) wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case…

Scott Edil Advance Research Laboratories and Education Limited, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 857/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh03 Mar 2025AY 2016-17
Section 127Section 132Section 153ASection 153DSection 2(22)(e)

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

Scott Edil Advance Research Laboratories and Education Limited, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 856/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh03 Mar 2025AY 2015-16
Section 127Section 132Section 153ASection 153D

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

Scott Edil Advance Research Laboratories and Education Limited, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 845/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh03 Mar 2025AY 2017-18
Section 127Section 132Section 153ASection 153DSection 2(22)(e)

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

Scott Edil Advance Research Laboratories and Education Limited, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 844/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh03 Mar 2025AY 2013-14

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

Section 127Section 132Section 153ASection 153D

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

Scott Edil Advance Research Laboratories and Education Limited, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 843/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh03 Mar 2025AY 2012-13
Section 127Section 132Section 153ASection 153D

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

Scott Edil Pharmacia Ltd., Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 833/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh03 Mar 2025AY 2017-18
Section 127Section 132Section 153ASection 153D

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

Scott Edil Pharmacia Ltd., Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 832/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh03 Mar 2025AY 2016-17
Section 127Section 153DSection 2(22)(e)

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

Scott Edil Pharmacia Ltd., Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 829/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh03 Mar 2025AY 2013-14

Bench: Shri Sanjay Garg & Shri Krinwant Sahayआयकर अपील सं./Ita No. 579/Chd /2023 निर्धारण वर्ष / Assessment Year : 2017-18 & आयकर अपील सं./Ita Nos.582 To 584/Chd/ 2023 निर्धारण वर्ष / Assessment Years : 2014-15 To 2016-17 & आयकर अपील सं./Ita No. 591/Chd /2023 निर्धारण वर्ष / Assessment Year : 2018-19

Section 127Section 132Section 153ASection 153D

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

Shri Balram Krishan, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 732/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh03 Mar 2025AY 2018-19
Section 127Section 132Section 153ASection 153D

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

Shri Balram Krishan, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 731/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh03 Mar 2025AY 2017-18
Section 127Section 132Section 153ASection 153DSection 2(22)

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

Shri Balram Krishan, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 730/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh03 Mar 2025AY 2016-17
Section 127Section 132Section 153ASection 153DSection 2

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

Shri Balram Krishan, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 729/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh03 Mar 2025AY 2015-16
Section 127Section 132Section 153ASection 153D

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

Shri Balram Krishan, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 728/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh03 Mar 2025AY 2014-15

Bench: Shri Sanjay Garg & Shri Krinwant Sahayआयकर अपील सं./Ita No. 579/Chd/2023 निर्धारण वर्ष / Assessment Year : 2017-18 & आयकर अपील सं./Ita Nos.582 To 584/Chd/2023 निर्धारण वर्ष / Assessment Years : 2014-15 To 2016-17 & आयकर अपील सं./Ita No. 591/Chd/2023 निर्धारण वर्ष / Assessment Year : 2018-19 Maxport India Pvt. Ltd. C/O Parikshit Aggarwal, Chartered Accountant, H. No. 3035, Sector 27D, Chandigarh- 160019. स्था.लेखा सं./Pan No: Aaicm9120E अपीलाथ/Appellant बनाम प्रथीय/Respondent Deputy Commissioner Of Income-Tax, Centre Circle-1, Chandigarh. & आयकर अपील सं./Ita Nos.482 & 483/Chd/2023 निर्धारण वर्ष / Assessment Years : 2017-18 & 2018-19 Vaishali Aggarwal C/O Parikshit Aggarwal, Chartered Accountant, H No. 3035, Sector 27D, Chandigarh- 160022. स्था.लेखा सं./Pan No: Aaqpa4025M अपीलाथ/Appellant बनाम प्रथीय/Respondent Deputy Commissioner Of Income-Tax, Centre Circle-1, Chandigarh. & आयकर अपील सं./Ita No. 846/Chd/2023

Section 127Section 132Section 153ASection 153DSection 2(22)(e)

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

Shri Balram Krishan, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 726/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh03 Mar 2025AY 2012-13
Section 153A

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

Maxport India Private Limited, Chandigarh vs. Dy. Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 583/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh03 Mar 2025AY 2015-16
Section 127Section 132Section 153ASection 153DSection 2(22)(e)

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

Maxport India Private Limited, Chandigarh vs. Dy. Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 582/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh03 Mar 2025AY 2014-15
Section 127Section 132Section 153ASection 153D

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…

DCIT, CC 1, Chandigarh vs. Sanjeev Aggarwal, Chandigarh

The appeals of the revenue are treated as dismissed

ITA 505/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh03 Mar 2025AY 2017-18
Section 127Section 153DSection 2

…against the revenue. The Division Bench in the case of Puneet Sabharwal (supra) had also placed reliance on the decision of Supreme Court in K. P. Varghese (supra) as also on another decision of a Division Bench of this Court in CIT v. Smt. Suraj Devi [2010] 328 ITR 604 wherein this Court held that the primary burden of proof with regard to concealment of income was on the revenue and it was only when the said burden was discharged that reliance could be placed on the valuation report of the DVO. There are several other decisions of this Court in the same vein. One such case being the case of CIT v. VinodSinghal…