What is Dhirajlal Girdharilal v. CIT authority for?

Income tax additions cannot be made based on mere suspicion, surmises, or presumptions; the assessing officer must rely on concrete proof and material evidence. Suspicion, however strong, cannot take the place of legal proof.

How many judgments cite Dhirajlal Girdharilal v. CIT?

196 judgments on BharatTax cite Dhirajlal Girdharilal v. CIT (26 ITR 736), spanning 2008 to 2026.

Which sections of the Income Tax Act does Dhirajlal Girdharilal v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 153A, Section 132, Section 132(4), Section 142(1), Section 147.

Dhirajlal Girdharilal v. CIT (26 ITR 736)

Rachna Gupta, New Delhi vs. ACIT, Central Circle- 29, New Delhi

In the result, appeal filed by the assessee is allowed

ITA 5418/DEL/2018[2015-16]Status: DisposedITAT Delhi20 Dec 2024AY 2015-16

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Shri Saubhagya Agarwal, AdvocateFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 131Section 143Section 143(2)Section 143(3)Section 68

…assessee, the assessee should be given an opportunity of doing so. On no account whatever should the Tribunal base its findings on be liable to be set aside by this Court." The Hon’ble Supreme Court had previously so held in DhirajlalGirdharilal v. CIT (1954) 26 ITR 736 as follows: "It is well established that when a court of fact acts on material, partly relevant and partly irrelevant, it is impossible to say to what extent the mind of the court was affected by the irrelevant material used by it in arriving at its finding. Such a finding is vitiated because of the use of inadmissible material and thereby an issu…

DCIT, Central Circle-15, New Delhi vs. Dmg Finance Investment Private Limited, New Delhi

ITA 3432/DEL/2023[2011-12]Status: DisposedITAT Delhi28 Nov 2024AY 2011-12

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Year: 2011-12 Dcit, Vs Dmg Finance Investment Private Central Circle-15, Limited, New Delhi. Flat No.1, First Floor, Dakshineshwar, 10 Hailey Road, New Delhi – 110 001. Pan: Aaacd3459K

For Appellant: Shri Ajay Wadhwa, Advocate &For Respondent: Shri Debesh Panda, Special Counsel

Section 132(4)Section 139Section 153A

…5. There is no gainsaying that the findings returned by the Ld. CIT (A) are also on conjectures and surmises, and without any cogent material. This is plainly impermissible as per the law declared by Hon’ble Supreme Court in DhirajlalGirdharlal v. CIT, (1954) 26 ITR 736. 16. During the course of the hearing, an observation fell from this Hon’ble Tribunal that the Revenue’s criticism of the impugned order of the Ld. CIT (A) equally well applies to the order of the Ld. AO as well. With utmost respect, it is submitted that the belief created in the mind of the Ld. AO from the seized documents is discernible from the…

Amol Awasthi, New Delhi vs. DCIT, Central Circle-I, New Delhi

In the result, appeals are allowed, as indicated

ITA 1348/DEL/2024[2018-19]Status: DisposedITAT Delhi13 Sept 2024AY 2018-19

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR

Section 132Section 143(3)Section 144CSection 153ASection 153C

…nce of irrelevant cannot be determined therein. It is trite law that when irrelevant material has been taken into consideration, entire proceeding is vitiated as held in Ascu Arch Timber Protection Ltd 2004 taxmann.com 1408 (SC), Dhirajlal Girdharilal Vs. CIT 26 ITR 736 (SC), Sagar Enterprises (2002) 124 Taxman 641 (Guj), Indian Metals And Ferro Alloys Limited Vs UOI 195 ITR 539 (Ori), Choithram Begraj Lalvaney Vs CIT 197 ITR 302 (Bom). Thus, the impugned satisfaction note is illegal ab initio and the consequent all assessment orders in appeal need to be quashed. No such addition u/s 69A of the Act is permissible…

Amol Awasthi, New Delhi vs. DCIT, Central Circle-1, New Delhi

In the result, appeals are allowed, as indicated

ITA 1347/DEL/2024[2016-17]Status: DisposedITAT Delhi13 Sept 2024AY 2016-17

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR

Section 132Section 143(3)Section 144CSection 153ASection 153C

…nce of irrelevant cannot be determined therein. It is trite law that when irrelevant material has been taken into consideration, entire proceeding is vitiated as held in Ascu Arch Timber Protection Ltd 2004 taxmann.com 1408 (SC), Dhirajlal Girdharilal Vs. CIT 26 ITR 736 (SC), Sagar Enterprises (2002) 124 Taxman 641 (Guj), Indian Metals And Ferro Alloys Limited Vs UOI 195 ITR 539 (Ori), Choithram Begraj Lalvaney Vs CIT 197 ITR 302 (Bom). Thus, the impugned satisfaction note is illegal ab initio and the consequent all assessment orders in appeal need to be quashed. No such addition u/s 69A of the Act is permissible…

Amol Awasthi, New Delhi vs. DCIT, C.C.1, New Delhi

In the result, appeals are allowed, as indicated

ITA 1346/DEL/2024[2015-16]Status: DisposedITAT Delhi13 Sept 2024AY 2015-16

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR

Section 132Section 143(3)Section 144CSection 153ASection 153C

…nce of irrelevant cannot be determined therein. It is trite law that when irrelevant material has been taken into consideration, entire proceeding is vitiated as held in Ascu Arch Timber Protection Ltd 2004 taxmann.com 1408 (SC), Dhirajlal Girdharilal Vs. CIT 26 ITR 736 (SC), Sagar Enterprises (2002) 124 Taxman 641 (Guj), Indian Metals And Ferro Alloys Limited Vs UOI 195 ITR 539 (Ori), Choithram Begraj Lalvaney Vs CIT 197 ITR 302 (Bom). Thus, the impugned satisfaction note is illegal ab initio and the consequent all assessment orders in appeal need to be quashed. No such addition u/s 69A of the Act is permissible…

Amol Awasthi, New Delhi vs. DCIT, Central Circle-1, New Delhi

In the result, appeals are allowed, as indicated

ITA 1345/DEL/2024[2014-15]Status: DisposedITAT Delhi13 Sept 2024AY 2014-15

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR

Section 132Section 143(3)Section 144CSection 153ASection 153C

…nce of irrelevant cannot be determined therein. It is trite law that when irrelevant material has been taken into consideration, entire proceeding is vitiated as held in Ascu Arch Timber Protection Ltd 2004 taxmann.com 1408 (SC), Dhirajlal Girdharilal Vs. CIT 26 ITR 736 (SC), Sagar Enterprises (2002) 124 Taxman 641 (Guj), Indian Metals And Ferro Alloys Limited Vs UOI 195 ITR 539 (Ori), Choithram Begraj Lalvaney Vs CIT 197 ITR 302 (Bom). Thus, the impugned satisfaction note is illegal ab initio and the consequent all assessment orders in appeal need to be quashed. No such addition u/s 69A of the Act is permissible…

Amol Awasthi, New Delhi vs. DCIT, C.C.1, New Delhi

In the result, appeals are allowed, as indicated

ITA 1344/DEL/2024[2013-14]Status: DisposedITAT Delhi13 Sept 2024AY 2013-14

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR

Section 132Section 143(3)Section 144CSection 153ASection 153C

…nce of irrelevant cannot be determined therein. It is trite law that when irrelevant material has been taken into consideration, entire proceeding is vitiated as held in Ascu Arch Timber Protection Ltd 2004 taxmann.com 1408 (SC), Dhirajlal Girdharilal Vs. CIT 26 ITR 736 (SC), Sagar Enterprises (2002) 124 Taxman 641 (Guj), Indian Metals And Ferro Alloys Limited Vs UOI 195 ITR 539 (Ori), Choithram Begraj Lalvaney Vs CIT 197 ITR 302 (Bom). Thus, the impugned satisfaction note is illegal ab initio and the consequent all assessment orders in appeal need to be quashed. No such addition u/s 69A of the Act is permissible…

Amol Awasthi, New Delhi vs. DCIT, C.C.1, New Delhi

In the result, appeals are allowed, as indicated

ITA 1343/DEL/2024[2012-13]Status: DisposedITAT Delhi13 Sept 2024AY 2012-13

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR

Section 132Section 143(3)Section 144CSection 153ASection 153C

…nce of irrelevant cannot be determined therein. It is trite law that when irrelevant material has been taken into consideration, entire proceeding is vitiated as held in Ascu Arch Timber Protection Ltd 2004 taxmann.com 1408 (SC), Dhirajlal Girdharilal Vs. CIT 26 ITR 736 (SC), Sagar Enterprises (2002) 124 Taxman 641 (Guj), Indian Metals And Ferro Alloys Limited Vs UOI 195 ITR 539 (Ori), Choithram Begraj Lalvaney Vs CIT 197 ITR 302 (Bom). Thus, the impugned satisfaction note is illegal ab initio and the consequent all assessment orders in appeal need to be quashed. No such addition u/s 69A of the Act is permissible…

Amol Awasthi, New Delhi vs. DCIT, C.C.1, New Delhi

In the result, appeals are allowed, as indicated

ITA 1342/DEL/2024[2011-12]Status: DisposedITAT Delhi13 Sept 2024AY 2011-12

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR

Section 132Section 143(3)Section 144CSection 153ASection 153C

…nce of irrelevant cannot be determined therein. It is trite law that when irrelevant material has been taken into consideration, entire proceeding is vitiated as held in Ascu Arch Timber Protection Ltd 2004 taxmann.com 1408 (SC), Dhirajlal Girdharilal Vs. CIT 26 ITR 736 (SC), Sagar Enterprises (2002) 124 Taxman 641 (Guj), Indian Metals And Ferro Alloys Limited Vs UOI 195 ITR 539 (Ori), Choithram Begraj Lalvaney Vs CIT 197 ITR 302 (Bom). Thus, the impugned satisfaction note is illegal ab initio and the consequent all assessment orders in appeal need to be quashed. No such addition u/s 69A of the Act is permissible…

Khoobsoorat Fabrics Pvt Ltd., New Delhi vs. ITO Ward 14(3), New Delhi

Appeal are allowed

ITA 428/DEL/2024[2017-18]Status: DisposedITAT Delhi11 Sept 2024AY 2017-18

Bench: Shri Kul Bharat[Assessment Year: 2017-18

Section 115BSection 68

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “SMC”: NEW DELHI BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER [Assessment Year: 2017-18 M/s Khoobsoorat Fabrics Pvt. Ltd., Vs Income-tax Officer, Plot no. 122, Ist Floor, Ward-14(3), Delhi. Patparganj Industrial Area, Delhi-110092. PAN- AAACK 3072 B APPELLANT RESPONDENT Appellant by Shri Gautam Jain, Adv.; & Shri Lalit Mohan, CA Respondent by Shri Sanjay Kumar, Sr. DR Date of hearing 14.08.2024 Date of pronouncement 11.08.2024 O R D E R PER KUL BHARAT, JM: This appeal, by the assessee, is directed against the order of the learned Commissioner of Income-tax (Appeal…

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2938/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Aug 2024AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR

Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…is a fundamental rule of justice and established legal proposition that there may be something more than bare suspicion, to support the findings, in the assessment order, as held by the Hon'ble Supreme Court, in the case of Dhirajlal Girdharilal v. CIT [1954] 26 ITR 736; Omar Salay Md. Sait v. CIT [1959] 37 ITR 151 (SC), Dhakeswari Cotton Mills Ltd.v. CIT [1954] 26 ITR 775 (SC); Lal Chand Bhagat Ambica v. CIT [1959] 37 ITR 288 (SC). In the present case, AO had not made any enquiry except quoting Question No. 10 and reply thereto. The AO, further, failed, to bring any material on record, even prima-facie to sugges…

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2937/DEL/2023[2016-17]Status: DisposedITAT Delhi30 Aug 2024AY 2016-17

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR

Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…is a fundamental rule of justice and established legal proposition that there may be something more than bare suspicion, to support the findings, in the assessment order, as held by the Hon'ble Supreme Court, in the case of Dhirajlal Girdharilal v. CIT [1954] 26 ITR 736; Omar Salay Md. Sait v. CIT [1959] 37 ITR 151 (SC), Dhakeswari Cotton Mills Ltd.v. CIT [1954] 26 ITR 775 (SC); Lal Chand Bhagat Ambica v. CIT [1959] 37 ITR 288 (SC). In the present case, AO had not made any enquiry except quoting Question No. 10 and reply thereto. The AO, further, failed, to bring any material on record, even prima-facie to sugges…

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2936/DEL/2023[2015-16]Status: DisposedITAT Delhi30 Aug 2024AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR

Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…is a fundamental rule of justice and established legal proposition that there may be something more than bare suspicion, to support the findings, in the assessment order, as held by the Hon'ble Supreme Court, in the case of Dhirajlal Girdharilal v. CIT [1954] 26 ITR 736; Omar Salay Md. Sait v. CIT [1959] 37 ITR 151 (SC), Dhakeswari Cotton Mills Ltd.v. CIT [1954] 26 ITR 775 (SC); Lal Chand Bhagat Ambica v. CIT [1959] 37 ITR 288 (SC). In the present case, AO had not made any enquiry except quoting Question No. 10 and reply thereto. The AO, further, failed, to bring any material on record, even prima-facie to sugges…

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2935/DEL/2023[2014-15]Status: DisposedITAT Delhi30 Aug 2024AY 2014-15

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR

Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…is a fundamental rule of justice and established legal proposition that there may be something more than bare suspicion, to support the findings, in the assessment order, as held by the Hon'ble Supreme Court, in the case of Dhirajlal Girdharilal v. CIT [1954] 26 ITR 736; Omar Salay Md. Sait v. CIT [1959] 37 ITR 151 (SC), Dhakeswari Cotton Mills Ltd.v. CIT [1954] 26 ITR 775 (SC); Lal Chand Bhagat Ambica v. CIT [1959] 37 ITR 288 (SC). In the present case, AO had not made any enquiry except quoting Question No. 10 and reply thereto. The AO, further, failed, to bring any material on record, even prima-facie to sugges…

Shri Rampriya Developers Private Limited, Hyderabad vs. Deputy Commissioner of Incometax, Circle-3(1), Hyderabad

In the result, appeal filed by the assessee is dismissed

ITA 1946/HYD/2017[1999-2000]Status: DisposedITAT Hyderabad14 Aug 2024AY 1999-2000

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.1946/Hyd/2017 (िनधा"रण वष"/Assessment Year: 1999-2000) Shri Rampriya Developers Vs. Dy. C. I. T. (P) Ltd Circle 3(1) Hyderabad Hyderabad Pan:Aajcs6629P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A.V. Raghuram, Advocate राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 09/07/2024 घोषणा की तारीख/Pronouncement: 14/08/2024 आदेश/Order

For Appellant: Shri A.V. Raghuram, AdvocateFor Respondent: : Shri Shakeer Ahmed, DR

Section 143(3)Section 14A

…agency firm was not genuine and the agreement was only a make-believe arrangement and that it was merely a device to minimize the assessee's tax liability. After considering a number of earlier decisions of the Supreme Court, Dhirajlal Girdharilal v. CIT(954) 26 ITR 736 (SC),, CIT v. Rajasthan Mines. Ltd. [1970) 78 ITR 45 (SC), CIT V. A. Raman & Co. [19681 67 ITR 11 (SC), CIT V. Indian Woollen Textile Mills(1964) 51 ITR 291 (SC) and CIT v. Durga Prasad More (197l) 82 ITR 540 (SC), the court concluded by holding as follows': “In our, opinion, the facts of this case come within the rule laid down by this court in S…

Ram Kumar Gupta, Kolkata vs. ACIT, Cir. 43, Kolkata

In the result, the appeal of the assessee stands allowed

ITA 309/KOL/2024[2017-18]Status: DisposedITAT Kolkata09 Aug 2024AY 2017-18

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.309/Kol/2024 Assessment Year: 2017-18 Ram Kumar Gupta…...…………….....……………………....………....Appellant 67/46, Posta Chowrasta, Kolkata -700007. [Pan: Adrpg8556B] Vs. Acit, Circle-43, Kolkata…...................................................…..…..... Respondent Appearances By: Shri Rajiva Kumar, Ar, Appeared On Behalf Of The Appellant. Shri Abhijit Kundu, Cit- Dr On Behalf Of P. P. Barman, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 30, 2024 Date Of Pronouncing The Order : August 09, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 07.12.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Agitated Against The Confirmation Of Addition Of Rs.1,10,46,000/- Made By The Assessing Officer On Account Of Cash Deposits In The Bank Account Of The Assessee During Demonetization Period. 3. The Brief Facts Of The Case Are That The Assessee Derives Income From Retail Trading In The Name Of M/S R. Kumar & Co. The Assessee Filed His Return Of Income On 28.07.2017 Declaring A Total Income Of Rs.8,19,420/-. The Return Was Selected For Scrutiny & Notices U/S

Section 250Section 44ASection 68

…n assessment based on mere conjecture, surmise' or suspicion or irrelevant and inadmissible evidence and material is invalid and unsustainable in law. Reliance, for this proposition, is placed on the orders in the cases of Dhirajlal Giridharilal Vs CIT (1954) 26 ITR 736 (SC); Lalchand Bhagat Ambica Ram Vs CIT (1959) 37 ITR 288 (SC); Umacharan Shaw & Bros Vs,.ClT (1959) 37 ITR 271 (SC); Omar Salay Mohamad Sait Vs CIT (1959) 37 ITR 151 (SC). I.T.A. No.309/Kol/2024 Assessment Year: 2017-18 Ram Kumar Gupta 1.20 In view of the facts of the case and the case laws discussed in the preceding paragraphs, it is submitted…

Ram Ratan Jangir, Amer vs. Income Tax Officer, Ward -7(2), Jaipur

In the result ground no. 1 raised by the

ITA 550/JPR/2024[2013-14]Status: DisposedITAT Jaipur22 Jul 2024AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Anoop Bhatiya, CAFor Respondent: Smt. Monisha Choudhary (Addl. CIT)

Section 143(3)Section 147Section 148

…ee prays accordingly. 10 Ram Ratan Jangir vs. ITO • Umacharan Shaw& Bros vs. CIT 37 ITR 271 (SC) : There are many surmises and conjectures, and the conclusion here is the result of suspicion which cannot take place of proof. • Dhiraj lal Girdharilal vs. CIT 26 ITR 736 (SC) : The mere existence of suspicion would not tantamount to evidence. Satisfaction should not be based on mere suspicion, conjecture or guess work. • CIT vs. Anupam Kapoor (2008) 299 ITR 179 (P&H) : It is a settled law that suspicion however strong cannot take the place of legal proof. Consequently, no question of law, much less a substantial q…

DCIT Central, Bhopal vs. Sharad Sharma, Bhopal

ITA 309/IND/2023[2012-13]Status: DisposedITAT Indore19 Jul 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniit(Ss)A No. 29/Ind/2023 (Ay: 2010-11) It(Ss)A No. 32/Ind/2023 (Ay: 2015-16) Shri Sharad Sharma, Acit, Central, बनाम/ H-3B, Nishant Colony, Gwalior Vs. 74 Bunglows, (Stationed At Bhopal) Tt Nagar, Bhopal (Pan: Amzps9791D) (Assessee/Appellant) (Revenue/Respondent)

Section 132Section 132(4)Section 143(3)Section 153A

…and guess work. It has been held in the case of Umacharan Saha & Bros co. v/s CIT 37 ITR 21 (SC) that suspicion, however strong cannot take place of evidence. Similar views have been expressed by Apex court in the case of Dhiraj Lal Girdharilal v/s CIT (1954) 26 ITR 736 (SC). 3.3.8 In view of the above discussion, material evidences on record and case laws cited, firstly, the loose papers or rather say it as dumb document should be a speaking one having direct nexus with the impugned investment, which was not in the case of appellant. Secondly, the loose paper is not signed by the appellant. The appellant has al…

DCIT Central, Bhopal vs. Sharad Sharma, Bhopal

ITA 304/IND/2023[2015-16]Status: DisposedITAT Indore19 Jul 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniit(Ss)A No. 29/Ind/2023 (Ay: 2010-11) It(Ss)A No. 32/Ind/2023 (Ay: 2015-16) Shri Sharad Sharma, Acit, Central, बनाम/ H-3B, Nishant Colony, Gwalior Vs. 74 Bunglows, (Stationed At Bhopal) Tt Nagar, Bhopal (Pan: Amzps9791D) (Assessee/Appellant) (Revenue/Respondent)

Section 132Section 132(4)Section 143(3)Section 153A

…and guess work. It has been held in the case of Umacharan Saha & Bros co. v/s CIT 37 ITR 21 (SC) that suspicion, however strong cannot take place of evidence. Similar views have been expressed by Apex court in the case of Dhiraj Lal Girdharilal v/s CIT (1954) 26 ITR 736 (SC). 3.3.8 In view of the above discussion, material evidences on record and case laws cited, firstly, the loose papers or rather say it as dumb document should be a speaking one having direct nexus with the impugned investment, which was not in the case of appellant. Secondly, the loose paper is not signed by the appellant. The appellant has al…

Mohammed Ibrabim Mohideen, Kerala vs. Asst. Commissioner of Income Tax, Central Circle-2, Mangaluru

In the result, appeal of the assessee in ITA

ITA 486/BANG/2024[2018-19]Status: DisposedITAT Bangalore08 Jul 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri D.K. Mishra, D.R

Section 153ASection 69B

…at no addition in the assessment can be made merely based on assumptions, suspicion, guess work and conjuncture or on irrelevant inadmissible material. Reliance can be placed in this regard on the following decisions: (i) Dhirajlal Girdharilal vs. CIT (1954) 26 ITR 736 (SC) (ii) Dhakeswari Cotton Mills Ltd. vs. CIT (1954) 26 ITR 775 (SC) (iii) CIT vs. Maharajadhiraja Kameshwar Singh of Darbhanga (1933) 1 ITR 94 (PC) (iv) Lalchand Bhagat Ambica Ram vs. CIT (1959) 37 ITR 288 (SC) ITA Nos.463 to 466, 485 & 486/Bang/2024 Mohammed Ibrahim Mohideen, Kasargod, Kerala Page 26 of 62 (v) Umacharan Shaw & Bros vs. CIT…

Dhirajlal Girdharilal v. CIT

What is Dhirajlal Girdharilal v. CIT authority for?

Also referred to as

Sections most often in play

Issues it is cited on

Judgments citing Dhirajlal Girdharilal v. CIT

Rachna Gupta, New Delhi vs. ACIT, Central Circle- 29, New Delhi

DCIT, Central Circle-15, New Delhi vs. Dmg Finance Investment Private Limited, New Delhi

Amol Awasthi, New Delhi vs. DCIT, Central Circle-I, New Delhi

Amol Awasthi, New Delhi vs. DCIT, Central Circle-1, New Delhi

Amol Awasthi, New Delhi vs. DCIT, C.C.1, New Delhi

Amol Awasthi, New Delhi vs. DCIT, Central Circle-1, New Delhi

Amol Awasthi, New Delhi vs. DCIT, C.C.1, New Delhi

Amol Awasthi, New Delhi vs. DCIT, C.C.1, New Delhi

Amol Awasthi, New Delhi vs. DCIT, C.C.1, New Delhi

Khoobsoorat Fabrics Pvt Ltd., New Delhi vs. ITO Ward 14(3), New Delhi

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

Shri Rampriya Developers Private Limited, Hyderabad vs. Deputy Commissioner of Incometax, Circle-3(1), Hyderabad

Ram Kumar Gupta, Kolkata vs. ACIT, Cir. 43, Kolkata

Ram Ratan Jangir, Amer vs. Income Tax Officer, Ward -7(2), Jaipur

DCIT Central, Bhopal vs. Sharad Sharma, Bhopal

DCIT Central, Bhopal vs. Sharad Sharma, Bhopal

Mohammed Ibrabim Mohideen, Kerala vs. Asst. Commissioner of Income Tax, Central Circle-2, Mangaluru