Commissioner of Income Tax v. Harjeev Aggarwal

290 CTR 263High Court2016#102 most cited

What is Commissioner of Income Tax v. Harjeev Aggarwal authority for?

Assessment based solely on a statement recorded under Section 132(4) of the Income Tax Act requires the statement to be relatable to incriminating material or evidence found during the search, especially when considering Section 158BB(1) which restricts computation of undisclosed income to evidence found during search.

583

judgments rely on this decision, according to BharatTax’s citation analysis of 367,518 Indian tax judgments — from 2017 to 2026.

Also referred to as

CIT v Harjeev Aggarwal · section 132(4) · section 158BB(1) · incriminating material · undisclosed income · search and seizure · statement recorded · income tax assessment

Also reported as

70 Taxmann.com 95

Sections most often in play

Section 143(3)Section 153ASection 132(4)Section 132Section 147Section 148Section 153CSection 69A
Read the full judgment

Issues it is cited on

undisclosed foreign income and assetssection 158b(b)section 158bb(1)section 149(1)(c)section 4(2)section 158bbsection 158basection 153(a)section 201(3)section 150unexplained jewellerystatement under section 132(4)

Judgments citing Commissioner of Income Tax v. Harjeev Aggarwal

Assistant Commissioner of Income Tax, Central Circle-3, Jaipur vs. M/S. Kedia Real Estate LLP, Jaipur

In the result, appeals of the revenue are dismissed whereas appeals of the assessee are allowed in part

ITA 289/JPR/2019[2017-18]Status: DisposedITAT Jaipur03 Jun 2019AY 2017-18
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 132(1)Section 143(3)Section 153A

…as stated hereinabove, which was confirmed by the Tribunal. It would not be out of place to mention that this order of Hon'ble Rajasthan High Court has been confirmed by Hon'ble Supreme Court also. Further, Hon'ble Delhi High court in case of Harjeev Agarwal (70 Taxmann.com 95) held thus: Harjeev Agganval [2016] 70 taxmann.com 95 (Delhi) "...A plain reading of Section 132 (4) of the Act indicates that the authorized officer is empowered to examine on oath any person who is found in possession or control of any books of accounts, documents, money, bullion, jewellery or any other valuable article or thing. The ex…

Deputy Commissioner of Income Tax, Central Circle-3, Jaipur vs. Shri Nirmak Kumar Kedia, Jaipur

In the result, appeals of the revenue are dismissed whereas the appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 288/JPR/2019[2017-18]Status: DisposedITAT Jaipur03 Jun 2019AY 2017-18
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 131Section 132Section 132(1)Section 133ASection 143(3)Section 153ASection 19

…find that the CIT (A) has rightly observed as stated hereinabove, which was confirmed by the Tribunal. It may be pointed out that this judgement has already been confirmed by Hon'ble Supreme Court. Further, Hon'ble Delhi High court in case of Harjeev Agarwal (70 Taxmann.com 95) also has held as under: “A plain reading of Section 132 (4) of the Act indicates that the authorized officer is empowered to examine on oath any person who is found in possession or control of any books of accounts, documents, money, bullion, jewellery or any other valuable article or thing. The explanation to Section 132 (4), which was i…

Assistant Commissioner of Income Tax, Central Circle-3, Jaipur vs. Shri Nirmal Kumar Kedia, Jaipur

In the result, appeals of the revenue are dismissed whereas the appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 287/JPR/2019[2016-17]Status: DisposedITAT Jaipur03 Jun 2019AY 2016-17
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 131Section 132Section 132(1)Section 133ASection 143(3)Section 153ASection 19

…find that the CIT (A) has rightly observed as stated hereinabove, which was confirmed by the Tribunal. It may be pointed out that this judgement has already been confirmed by Hon'ble Supreme Court. Further, Hon'ble Delhi High court in case of Harjeev Agarwal (70 Taxmann.com 95) also has held as under: “A plain reading of Section 132 (4) of the Act indicates that the authorized officer is empowered to examine on oath any person who is found in possession or control of any books of accounts, documents, money, bullion, jewellery or any other valuable article or thing. The explanation to Section 132 (4), which was i…

Assistant Commissioner of Income Tax, Central Circle-3, Jaipur vs. Shri Nitin Kedia, Jaipur

In the result, appeals of the revenue are dismissed whereas the appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 286/JPR/2019[2015-16]Status: DisposedITAT Jaipur03 Jun 2019AY 2015-16
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 131Section 132Section 132(1)Section 133ASection 143(3)Section 153ASection 19

…find that the CIT (A) has rightly observed as stated hereinabove, which was confirmed by the Tribunal. It may be pointed out that this judgement has already been confirmed by Hon'ble Supreme Court. Further, Hon'ble Delhi High court in case of Harjeev Agarwal (70 Taxmann.com 95) also has held as under: “A plain reading of Section 132 (4) of the Act indicates that the authorized officer is empowered to examine on oath any person who is found in possession or control of any books of accounts, documents, money, bullion, jewellery or any other valuable article or thing. The explanation to Section 132 (4), which was i…

Nitin Kedia, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, appeals of the revenue are dismissed whereas appeals of the assessee are allowed in part

ITA 128/JPR/2019[2015-16]Status: DisposedITAT Jaipur03 Jun 2019AY 2015-16
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 132(1)Section 143(3)Section 153A

…as stated hereinabove, which was confirmed by the Tribunal. It would not be out of place to mention that this order of Hon'ble Rajasthan High Court has been confirmed by Hon'ble Supreme Court also. Further, Hon'ble Delhi High court in case of Harjeev Agarwal (70 Taxmann.com 95) held thus: Harjeev Agganval [2016] 70 taxmann.com 95 (Delhi) "...A plain reading of Section 132 (4) of the Act indicates that the authorized officer is empowered to examine on oath any person who is found in possession or control of any books of accounts, documents, money, bullion, jewellery or any other valuable article or thing. The ex…

M/S. Kedia Real Estate LLP, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, appeals of the revenue are dismissed whereas appeals of the assessee are allowed in part

ITA 127/JPR/2019[2017-18]Status: DisposedITAT Jaipur03 Jun 2019AY 2017-18
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 132(1)Section 143(3)Section 153A

…as stated hereinabove, which was confirmed by the Tribunal. It would not be out of place to mention that this order of Hon'ble Rajasthan High Court has been confirmed by Hon'ble Supreme Court also. Further, Hon'ble Delhi High court in case of Harjeev Agarwal (70 Taxmann.com 95) held thus: Harjeev Agganval [2016] 70 taxmann.com 95 (Delhi) "...A plain reading of Section 132 (4) of the Act indicates that the authorized officer is empowered to examine on oath any person who is found in possession or control of any books of accounts, documents, money, bullion, jewellery or any other valuable article or thing. The ex…

Shri Nirmak Kumar Kedia, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, appeals of the revenue are dismissed whereas the appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 126/JPR/2019[2017-18]Status: DisposedITAT Jaipur03 Jun 2019AY 2017-18
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 131Section 132Section 132(1)Section 133ASection 143(3)Section 153ASection 19

…find that the CIT (A) has rightly observed as stated hereinabove, which was confirmed by the Tribunal. It may be pointed out that this judgement has already been confirmed by Hon'ble Supreme Court. Further, Hon'ble Delhi High court in case of Harjeev Agarwal (70 Taxmann.com 95) also has held as under: “A plain reading of Section 132 (4) of the Act indicates that the authorized officer is empowered to examine on oath any person who is found in possession or control of any books of accounts, documents, money, bullion, jewellery or any other valuable article or thing. The explanation to Section 132 (4), which was i…

Shri Nirmal Kumar Kedia, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, appeals of the revenue are dismissed whereas the appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 125/JPR/2019[2016-17]Status: DisposedITAT Jaipur03 Jun 2019AY 2016-17
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 131Section 132Section 132(1)Section 133ASection 143(3)Section 153ASection 19

…find that the CIT (A) has rightly observed as stated hereinabove, which was confirmed by the Tribunal. It may be pointed out that this judgement has already been confirmed by Hon'ble Supreme Court. Further, Hon'ble Delhi High court in case of Harjeev Agarwal (70 Taxmann.com 95) also has held as under: “A plain reading of Section 132 (4) of the Act indicates that the authorized officer is empowered to examine on oath any person who is found in possession or control of any books of accounts, documents, money, bullion, jewellery or any other valuable article or thing. The explanation to Section 132 (4), which was i…

Shri Nirmal Kumar Kedia, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, appeals of the revenue are dismissed whereas the appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 124/JPR/2019[2015-16]Status: DisposedITAT Jaipur03 Jun 2019AY 2015-16
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 131Section 132Section 132(1)Section 133ASection 143(3)Section 153ASection 19

…find that the CIT (A) has rightly observed as stated hereinabove, which was confirmed by the Tribunal. It may be pointed out that this judgement has already been confirmed by Hon'ble Supreme Court. Further, Hon'ble Delhi High court in case of Harjeev Agarwal (70 Taxmann.com 95) also has held as under: “A plain reading of Section 132 (4) of the Act indicates that the authorized officer is empowered to examine on oath any person who is found in possession or control of any books of accounts, documents, money, bullion, jewellery or any other valuable article or thing. The explanation to Section 132 (4), which was i…

Shri Rathi Steel (Dakshin) Ltd., New Delhi vs. ACIT, Central Circle-16, New Delhi

In the result, all the appeals filed by the assessee are allowed

ITA 7973/DEL/2018[2009-10]Status: DisposedITAT Delhi31 May 2019AY 2009-10

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Sanjay Goyal, CIT, DR
Section 132Section 142(1)Section 143(3)Section 153A

…that the ITAT was fully justified in concluding that the assumption of jurisdiction under Section 153A of the Act qua the Assessees herein was not justified in law." 39. We find the Hon'ble Delhi High Court in the case of CIT vs. Harjeev Aggarwal reported in 290 CTR 263 has observed as under :- "23. It is also necessary to mention that the aforesaid interpretation of Section 132(4) of the Act must be read with the explanation to Section 132(4) of the Act which expressly provides that the scope of examination under Section 132(4) of the Act is not limited only to the books of accounts or other assets or material…

Shri Rathi Steel Ltd., New Delhi vs. ACIT, Central Circle-16, New Delhi

In the result, all the appeals filed by the assessee are allowed

ITA 7971/DEL/2018[2009-10]Status: DisposedITAT Delhi31 May 2019AY 2009-10

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Sanjay Goyal, CIT, DR
Section 132Section 142(1)Section 143(3)Section 153A

…that the ITAT was fully justified in concluding that the assumption of jurisdiction under Section 153A of the Act qua the Assessees herein was not justified in law." 39. We find the Hon'ble Delhi High Court in the case of CIT vs. Harjeev Aggarwal reported in 290 CTR 263 has observed as under :- "23. It is also necessary to mention that the aforesaid interpretation of Section 132(4) of the Act must be read with the explanation to Section 132(4) of the Act which expressly provides that the scope of examination under Section 132(4) of the Act is not limited only to the books of accounts or other assets or material…

Deputy Commissioner of Income Tax, Central Circle, Kota vs. M/S. Agrasen Agro Industries Private Limited, Kota

ITA 1205/JPR/2018[2011-12]Status: DisposedITAT Jaipur27 Mar 2019AY 2011-12
Section 143(3)Section 153Section 153ASection 68

…which has not been abated. In support of the contention that the statement cannot be taken as incriminating material, reliance was placed on the following judicial precedents: (i) Hon’ble Delhi Court in Commissioner of Income Tax v. Harjeev Aggarwal (2016) 290 CTR 263 held that statements recorded under Section 132 (4) of the Act of the Act do not by themselves constitute incriminating material. (Copy at Case Law PB 496-508 in case of M/s Kota Dall Mill) (ii) Hon’ble DELHI HIGH COURT [2017] 397 ITR 82 in the case of Principal Commissioner of Income Tax, Delhi Versus Best Infrastructure (India) Pvt. Ltd wherei…

Deputy Commissioner of Income Tax, Central Circle, Kota vs. M/S. Agrasen Agro Industries Private Limited, Kota

ITA 1188/JPR/2018[2010-11]Status: DisposedITAT Jaipur27 Mar 2019AY 2010-11
Section 143(3)Section 153Section 153ASection 68

…which has not been abated. In support of the contention that the statement cannot be taken as incriminating material, reliance was placed on the following judicial precedents: (i) Hon’ble Delhi Court in Commissioner of Income Tax v. Harjeev Aggarwal (2016) 290 CTR 263 held that statements recorded under Section 132 (4) of the Act of the Act do not by themselves constitute incriminating material. (Copy at Case Law PB 496-508 in case of M/s Kota Dall Mill) (ii) Hon’ble DELHI HIGH COURT [2017] 397 ITR 82 in the case of Principal Commissioner of Income Tax, Delhi Versus Best Infrastructure (India) Pvt. Ltd wherei…

M/S. Agrasen Agro Industries Private Limited, Kota vs. Deputy Commissioner of Income Tax, Central Circle, Kota

ITA 1053/JPR/2018[2010-11]Status: DisposedITAT Jaipur27 Mar 2019AY 2010-11
Section 143(3)Section 153Section 153ASection 68

…which has not been abated. In support of the contention that the statement cannot be taken as incriminating material, reliance was placed on the following judicial precedents: (i) Hon’ble Delhi Court in Commissioner of Income Tax v. Harjeev Aggarwal (2016) 290 CTR 263 held that statements recorded under Section 132 (4) of the Act of the Act do not by themselves constitute incriminating material. (Copy at Case Law PB 496-508 in case of M/s Kota Dall Mill) (ii) Hon’ble DELHI HIGH COURT [2017] 397 ITR 82 in the case of Principal Commissioner of Income Tax, Delhi Versus Best Infrastructure (India) Pvt. Ltd wherei…

Smt. Aparna Agrawal, Kota vs. Deputy Commissioner of Income Tax, Kota

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue

ITA 1379/JPR/2018[2016-17]Status: DisposedITAT Jaipur25 Mar 2019AY 2016-17
For Appellant: Shri Vijay Goyal (CA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 132(4)Section 139(1)Section 143(3)Section 153B(1)(b)Section 251(2)Section 271A

…in the Balance Sheet as on 31st March, 2015. Thus the ld. A/R has submitted that the mere statement recorded under section 132(4) does not by itself constitute incriminating material as held by the Hon’ble Delhi High Court in case of CIT vs. Harjeev Aggarwal, 290 CTR 263 (Delhi) as well as in case of Pr. CIT vs. Best Infrastructure (India) Pvt. Ltd., 397 ITR 82 (Delhi). The ld. A/R has also referred to a series of decisions on the point that the penalty under section 271AAB cannot be imposed merely on the surrender made under section 132(4) in the absence of any incriminating material found during the search. He…

Mrs. Reena Jain, Mumbai vs. Deputy Commissioner of Income Tax Central Circle - 8(4), Mumbai

In the result, the appeals are partly allowed

ITA 1007/MUM/2018[2014-15]Status: DisposedITAT Mumbai25 Mar 2019AY 2014-15

Bench: Shri Pawan Singh () & Shri N.K. Pradhan () Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2013-14 Mr. Ratnesh Chand Jain, Deputy Commissioner Of 902/903, A Wing, Kalinga Vs. Income Tax, Central Tower, Nirmal Nagar, Circle-8(4), 658, 6Th Link Road, Mulund (West), Floor, Aayakar Bhavan Mumbai-400080 Mumbai. Pan No. Aabpj0683P Appellant Respondent Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2014-15 Mrs. Reenajain, Deputy Commissioner Of 902/903, A Wing, Kalinga Vs. Income Tax Central Tower, Nirmal Nagar Link Circle-8(4), 658, 6Th Road, Mulund (West), Floor, Aayakar Bhavan Mumbai-400080 Mumbai. Pan No. Aeapj6605C

For Appellant: Mr. Bhupendra Shah, ARFor Respondent: Mr. A.K. Srivastava, DR
Section 131Section 132Section 132(4)Section 143(3)Section 153ASection 271(1)(c)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D” MUMBAI BEFORE SHRI PAWAN SINGH (JUDICIAL MEMBER) AND SHRI N.K. PRADHAN (ACCOUNTANT MEMBER) Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2013-14 Mr. Ratnesh Chand Jain, Deputy Commissioner of 902/903, A Wing, Kalinga Vs. Income Tax, Central Tower, Nirmal Nagar, Circle-8(4), 658, 6th Link Road, Mulund (West), Floor, Aayakar Bhavan Mumbai-400080 Mumbai. PAN No. AABPJ0683P Appellant Respondent Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2014-15 Mrs. ReenaJain, Deputy Commissioner of…

Mr.Ratnesh Chand Jain, Mumbai vs. Deputy Commissioner of Income Tax Central Circle-8(4), Mumbai

In the result, the appeals are partly allowed

ITA 1001/MUM/2018[2009-10]Status: DisposedITAT Mumbai25 Mar 2019AY 2009-10

Bench: Shri Pawan Singh () & Shri N.K. Pradhan () Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2013-14 Mr. Ratnesh Chand Jain, Deputy Commissioner Of 902/903, A Wing, Kalinga Vs. Income Tax, Central Tower, Nirmal Nagar, Circle-8(4), 658, 6Th Link Road, Mulund (West), Floor, Aayakar Bhavan Mumbai-400080 Mumbai. Pan No. Aabpj0683P Appellant Respondent Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2014-15 Mrs. Reenajain, Deputy Commissioner Of 902/903, A Wing, Kalinga Vs. Income Tax Central Tower, Nirmal Nagar Link Circle-8(4), 658, 6Th Road, Mulund (West), Floor, Aayakar Bhavan Mumbai-400080 Mumbai. Pan No. Aeapj6605C

For Appellant: Mr. Bhupendra Shah, ARFor Respondent: Mr. A.K. Srivastava, DR
Section 131Section 132Section 132(4)Section 143(3)Section 153ASection 271(1)(c)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D” MUMBAI BEFORE SHRI PAWAN SINGH (JUDICIAL MEMBER) AND SHRI N.K. PRADHAN (ACCOUNTANT MEMBER) Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2013-14 Mr. Ratnesh Chand Jain, Deputy Commissioner of 902/903, A Wing, Kalinga Vs. Income Tax, Central Tower, Nirmal Nagar, Circle-8(4), 658, 6th Link Road, Mulund (West), Floor, Aayakar Bhavan Mumbai-400080 Mumbai. PAN No. AABPJ0683P Appellant Respondent Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2014-15 Mrs. ReenaJain, Deputy Commissioner of…

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)

…ncome. The ld AR has relied upon the following decisions: (i) Tidewater Marine International Inc V DCIT Spl. Range Dehradun 96 ITD 406 (Delhi). (ii) Deep Chand Kothari V. CIT (1988) 171 ITR 381 (Raj (iii) Commissioner of Income Tax v. Harjeev Aggarwal (2016) 290 CTR 263 (iv) Principal Commissioner of Income Tax, Delhi Vs. Best Infrastructure (India) Pvt. Ltd [2017] 397 ITR 82 The ld. AR has submitted that the Hon’ble High Court has held that statements recorded U/s 132(4) of the Act do not by themselves constitute incriminating material. The ld AR has referred to the various documents produced before the Asse…

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)

…ncome. The ld AR has relied upon the following decisions: (i) Tidewater Marine International Inc V DCIT Spl. Range Dehradun 96 ITD 406 (Delhi). (ii) Deep Chand Kothari V. CIT (1988) 171 ITR 381 (Raj (iii) Commissioner of Income Tax v. Harjeev Aggarwal (2016) 290 CTR 263 (iv) Principal Commissioner of Income Tax, Delhi Vs. Best Infrastructure (India) Pvt. Ltd [2017] 397 ITR 82 The ld. AR has submitted that the Hon’ble High Court has held that statements recorded U/s 132(4) of the Act do not by themselves constitute incriminating material. The ld AR has referred to the various documents produced before the Asse…

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)

…ncome. The ld AR has relied upon the following decisions: (i) Tidewater Marine International Inc V DCIT Spl. Range Dehradun 96 ITD 406 (Delhi). (ii) Deep Chand Kothari V. CIT (1988) 171 ITR 381 (Raj (iii) Commissioner of Income Tax v. Harjeev Aggarwal (2016) 290 CTR 263 (iv) Principal Commissioner of Income Tax, Delhi Vs. Best Infrastructure (India) Pvt. Ltd [2017] 397 ITR 82 The ld. AR has submitted that the Hon’ble High Court has held that statements recorded U/s 132(4) of the Act do not by themselves constitute incriminating material. The ld AR has referred to the various documents produced before the Asse…