What is Deepchand & Co. v. Asstt. CIT authority for?

A statement made during a search or survey that is later retracted is not, by itself, sufficient to establish incriminating material or support additions to income. The retraction must be considered, and the authorities must demonstrate a basis for the additions beyond the retracted statement.

How many judgments cite Deepchand & Co. v. Asstt. CIT?

23 judgments on BharatTax cite Deepchand & Co. v. Asstt. CIT (51 TTJ 421), spanning 2018 to 2026.

Which sections of the Income Tax Act does Deepchand & Co. v. Asstt. CIT come up under?

It is most often cited in judgments turning on Section 37(1), Section 132(4), Section 133(6), Section 143(3), Section 147, Section 69A.

Deepchand & Co. v. Asstt. CIT (51 TTJ 421)

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

…threat", the Courts have taken the view that such stereotype declarations at the conclusion of statement do not support the Revenue's contention. In this connection, I would like to make a reference to the Bombay Tribunal in Deepchand & Co. v. Asstt. CIT 1995 51 TTJ 421, which has observed thus: "The stereotyped mention it the end of the statement that whatever was stated was true and to the best of the knowledge and belief and the statement given was voluntary without any threat, force or undue influence, would not mean that they agreed for making additions Putting certain expression at the end of the statement…

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

…threat", the Courts have taken the view that such stereotype declarations at the conclusion of statement do not support the Revenue's contention. In this connection, I would like to make a reference to the Bombay Tribunal in Deepchand & Co. v. Asstt. CIT 1995 51 TTJ 421, which has observed thus: "The stereotyped mention it the end of the statement that whatever was stated was true and to the best of the knowledge and belief and the statement given was voluntary without any threat, force or undue influence, would not mean that they agreed for making additions Putting certain expression at the end of the statement…

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

…threat", the Courts have taken the view that such stereotype declarations at the conclusion of statement do not support the Revenue's contention. In this connection, I would like to make a reference to the Bombay Tribunal in Deepchand & Co. v. Asstt. CIT 1995 51 TTJ 421, which has observed thus: "The stereotyped mention it the end of the statement that whatever was stated was true and to the best of the knowledge and belief and the statement given was voluntary without any threat, force or undue influence, would not mean that they agreed for making additions Putting certain expression at the end of the statement…

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

…threat", the Courts have taken the view that such stereotype declarations at the conclusion of statement do not support the Revenue's contention. In this connection, I would like to make a reference to the Bombay Tribunal in Deepchand & Co. v. Asstt. CIT 1995 51 TTJ 421, which has observed thus: "The stereotyped mention it the end of the statement that whatever was stated was true and to the best of the knowledge and belief and the statement given was voluntary without any threat, force or undue influence, would not mean that they agreed for making additions Putting certain expression at the end of the statement…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. INDIAN HYDRO ELECTRIC POWER PVT. LTD., DELHI

ITA 3907/DEL/2023[2019-20]Status: DisposedITAT Delhi07 Nov 2025AY 2019-20

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 132Section 132(4)Section 153ASection 250Section 68Section 69C

…upon the appellants. Our conclusion find support from the Circular dated 10.03.2003 issued by the Central Board of Direct Taxes, which took exception to the initiation of the proceedings on the basis of retracted statements.”  DEEPCHAND & CO. v. ACIT [1995] 51 TTJ 421 [Bombay Tribunal - 27- 07-1994] The stereotyped mention at the end of the statement that whatever was stated was true and to the best of the knowledge and belief and the statement given was voluntary without any threat, force or undue influence, would not mean that the partners agreed for making additions. Putting certain expression at the end of…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-20, DELHI vs. INDIAN HYDRO ELECTRIC POWER PVT. LTD., DELHI

ITA 3906/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Nov 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 132Section 132(4)Section 153ASection 250Section 68Section 69C

…upon the appellants. Our conclusion find support from the Circular dated 10.03.2003 issued by the Central Board of Direct Taxes, which took exception to the initiation of the proceedings on the basis of retracted statements.”  DEEPCHAND & CO. v. ACIT [1995] 51 TTJ 421 [Bombay Tribunal - 27- 07-1994] The stereotyped mention at the end of the statement that whatever was stated was true and to the best of the knowledge and belief and the statement given was voluntary without any threat, force or undue influence, would not mean that the partners agreed for making additions. Putting certain expression at the end of…

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

…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 Tribunal, Mumbai in the case of Deepchand\nand Co. v. ACIT (1995) 51 TTJ 421 (Mum).\n33\nNow for reaching to conclusion, it is necessary and\nimperative to analyse the statement of Shri Divyesh Dhanani,\nShri Pardeep Dodhia and Shri Bhadresh Dodhia it can be\nobserved that it is nowhere alleged that the said cash receipts\nbelong to the assessee company namely Dodhia Synthetics\nLimited. In fact, the letter dated 27.09.202…

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

The appeal of the assessee is Allowed on the\nlegal issue

ITA 2190/MUM/2025[2013-14]Status: DisposedITAT Mumbai17 Sept 2025AY 2013-14

Section 143(3)Section 147Section 250Section 68

…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 Tribunal, Mumbai in the case of Deepchand\nand Co. v. ACIT (1995) 51 TTJ 421 (Mum).\n\n33.\nNow for reaching to conclusion, it is necessary and\nimperative to analyse the statement of Shri Divyesh Dhanani,\nShri Pardeep Dodhia and Shri Bhadresh Dodhia it can be\nobserved that it is nowhere alleged that the said cash receipts\nbelong to the assessee company namely Dodhia Synthetics\nLimited. In fact, the letter dated 27.09.…

DCIT, CENTRAL CIRCLE -3, THANE, THANE vs. DODHIA SYNTHETICS LIMITED, BHIWANDI

The appeal of the assessee is Allowed on the\nlegal issue

ITA 2105/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Sept 2025AY 2014-15

Section 143(3)Section 147Section 250Section 68

…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 Tribunal, Mumbai in the case of Deepchand\nand Co. v. ACIT (1995) 51 TTJ 421 (Mum).\n33. Now for reaching to conclusion, it is necessary and\nimperative to analyse the statement of Shri Divyesh Dhanani,\nShri Pardeep Dodhia and Shri Bhadresh Dodhia it can be\nobserved that it is nowhere alleged that the said cash receipts\nbelong to the assessee company namely Dodhia Synthetics\nLimited. In fact, the letter dated 27.09.202…

DY. CIT, CENTRAL CIRCLE, VARANASI vs. SHRI ASHOK AGRAWAL, VARANASI

In the result, the appeal filed by the assessee is treated as allowed and the appeal of the revenue is dismissed

ITA 23/VNS/2023[2016-2017]Status: DisposedITAT Varanasi21 Nov 2023AY 2016-2017

Bench: Shri B R Baskaran, Hon’Ble & Shri Amit Shukla, Hon’Bleshri Ashok Agrawal, Dy.Cit Central Circle, J-12/120, Dhoopchandi, Varanasi Jagatganj, Varanasi 221001

For Appellant: Shri V K Jindal & Sh Ashish JindalFor Respondent: Shri Robin Chaudhary, CIT

Section 132(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL VARANASI BENCH, VARANASI Before Shri B R Baskaran, Hon’ble Accountant Member, & Shri Amit Shukla, Hon’ble Judicial Member Shri Ashok Agrawal, Dy.CIT Central Circle, J-12/120, Dhoopchandi, Varanasi Jagatganj, Varanasi 221001 PAN AGEPA0153G (Appellant) (Respondent) Dy.CIT Central Circle, Shri Ashok Agrawal, Varanasi J-12/120, Dhoopchandi, Jagatganj, Varanasi 221001 PAN AGEPA0153G (Appellant) (Respondent) For the Assessee : Shri V K Jindal & Sh Ashish Jindal For the Revenue : Shri Robin Chaudhary, CIT Date of Hearing : 27.09.2023 Date of Pronouncement : 21.11.2023 O R D E R…

ASHOK KUMAR AGRAWAL,VARANASI vs. DC/ACIT, CC, VARANASI

In the result, the appeal filed by the assessee is treated as allowed and the appeal of the revenue is dismissed

ITA 52/VNS/2022[2016-2017]Status: DisposedITAT Varanasi21 Nov 2023AY 2016-2017

Bench: Shri B R Baskaran, Hon’Ble & Shri Amit Shukla, Hon’Bleshri Ashok Agrawal, Dy.Cit Central Circle, J-12/120, Dhoopchandi, Varanasi Jagatganj, Varanasi 221001

For Appellant: Shri V K Jindal & Sh Ashish JindalFor Respondent: Shri Robin Chaudhary, CIT

Section 132(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL VARANASI BENCH, VARANASI Before Shri B R Baskaran, Hon’ble Accountant Member, & Shri Amit Shukla, Hon’ble Judicial Member Shri Ashok Agrawal, Dy.CIT Central Circle, J-12/120, Dhoopchandi, Varanasi Jagatganj, Varanasi 221001 PAN AGEPA0153G (Appellant) (Respondent) Dy.CIT Central Circle, Shri Ashok Agrawal, Varanasi J-12/120, Dhoopchandi, Jagatganj, Varanasi 221001 PAN AGEPA0153G (Appellant) (Respondent) For the Assessee : Shri V K Jindal & Sh Ashish Jindal For the Revenue : Shri Robin Chaudhary, CIT Date of Hearing : 27.09.2023 Date of Pronouncement : 21.11.2023 O R D E R…