Dhirajlal Girdharilal v. CIT

26 ITR 736Supreme Court of India1954#474 most cited

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.

196

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2008 to 2026.

Also referred to as

Dhirajlal Girdharilal v CIT · 26 ITR 736 · suspicion not proof · no addition on surmises · section 143(3) · section 153A · section 132(4) · evidence for assessment · onus of proof · incriminating material

Sections most often in play

Section 143(3)Section 153ASection 132Section 132(4)Section 142(1)Section 147Section 148Section 153C

Issues it is cited on

buyback of sharesabatement of assessmentonus of proofsection 153a proceedingssection 158bdsection 158bbsection 269tthird party informationsection 269ssection 132(4a)dumb documentssection 271e

Judgments citing Dhirajlal Girdharilal v. CIT

M/S. Trishul Buildtech & Infrastructures Pvt. Ltd., Bengaluru vs. The Deputy Commissioner of Income-Tax, Central Circle-2(2), Bengaluru

In the result, assessee’s appeals are partly allowed

ITA 108/BANG/2022[2017-18]Status: DisposedITAT Bangalore14 Nov 2022AY 2017-18

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri A. Shankar, Senior AdvocateFor Respondent: Shri Manjunath Karkihalli, D.R
Section 250

…and Others [(2017) 295 CTR 0466 (Del)], Hon’ble High Court of Delhi while considering the substantial question of law relating to invoking of Section 153A of the Act has analyzed the catena of judgments more particularly, Smt. Dayawanti Gupta V/s. CIT [(1954) 26 ITR 736 (SC)J and Kabul Chawla supra and held that there was a clear admission by the assessee in Dayawanti Gupta supra of a failure in maintaining regular books of accounts, on the basis of material recovered during search, the additions were made for all the years. The Hon’ble Court held that what weighed with the Court in the said decision was the “hab…

M/S. Trishul Buildtech & Infrastructures Pvt. Ltd., Bengaluru vs. The Deputy Commissioner of Income-Tax, Central Circle-2(2), Bengaluru

In the result, assessee’s appeals are partly allowed

ITA 107/BANG/2022[2016-17]Status: DisposedITAT Bangalore14 Nov 2022AY 2016-17

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri A. Shankar, Senior AdvocateFor Respondent: Shri Manjunath Karkihalli, D.R
Section 250

…and Others [(2017) 295 CTR 0466 (Del)], Hon’ble High Court of Delhi while considering the substantial question of law relating to invoking of Section 153A of the Act has analyzed the catena of judgments more particularly, Smt. Dayawanti Gupta V/s. CIT [(1954) 26 ITR 736 (SC)J and Kabul Chawla supra and held that there was a clear admission by the assessee in Dayawanti Gupta supra of a failure in maintaining regular books of accounts, on the basis of material recovered during search, the additions were made for all the years. The Hon’ble Court held that what weighed with the Court in the said decision was the “hab…

ACIT, New Delhi vs. M/S. Majestic Properties Pvt. Ltd., New Delhi

In the result, all the appeals of the revenue are dismissed

ITA 5579/DEL/2011[2007-08]Status: DisposedITAT Delhi14 Oct 2022AY 2007-08

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 5231/Del/2011 : Asstt. Year 2005-06 Ita No. 5392/Del/2011 : Asstt. Year 2006-07 Ita No. 5579/Del/2011 : Asstt. Year 2007-08 Acit, Vs. M/S Majestic Properties (P) Ltd., Central Circle-2, 1/18B, Asaf Ali Road, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaacm7158E Assessee By : Dr. Rakesh Gupta, Adv. & Sh. Deepesh Garg, Adv. Revenue By : Ms. Shivani Singh, Cit Dr Date Of Hearing: 22.07.2022 Date Of Pronouncement: 14.10.2022

For Appellant: Dr. Rakesh Gupta, Adv. &For Respondent: Ms. Shivani Singh, CIT DR
Section 132

…ere existence of reasons for suspicion would not tantamount to evidence. Narayan Chand Baidya Vs. CIT 20 ITR 287 (Cal). it should not be based on mere suspicion, conjecture or guess work or on irrelevant or inadmissible material. Dhirajlal Girdharilal Vs. CIT 26 ITR 736 (SC), Lalchand Bhagar Ambica Ram Vs. CIT 37 ITR 288 (SC), Umacharan Shaw & Bros Vs. CIT 37 ITR 271 (SC), Omar Salay Mohamed Sait Vs. CIT 37 ITR 151 (SC), Page 170 “On no account whatever should the Tribunal base its findings on suspicions, conjectures or surmises nor should it act on no evidence at all or on improper rejection of material and rele…

ACIT, New Delhi vs. M/S. Majestic Properties Pvt. Ltd., New Delhi

In the result, all the appeals of the revenue are dismissed

ITA 5392/DEL/2011[2006-07]Status: DisposedITAT Delhi14 Oct 2022AY 2006-07

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 5231/Del/2011 : Asstt. Year 2005-06 Ita No. 5392/Del/2011 : Asstt. Year 2006-07 Ita No. 5579/Del/2011 : Asstt. Year 2007-08 Acit, Vs. M/S Majestic Properties (P) Ltd., Central Circle-2, 1/18B, Asaf Ali Road, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaacm7158E Assessee By : Dr. Rakesh Gupta, Adv. & Sh. Deepesh Garg, Adv. Revenue By : Ms. Shivani Singh, Cit Dr Date Of Hearing: 22.07.2022 Date Of Pronouncement: 14.10.2022

For Appellant: Dr. Rakesh Gupta, Adv. &For Respondent: Ms. Shivani Singh, CIT DR
Section 132

…ere existence of reasons for suspicion would not tantamount to evidence. Narayan Chand Baidya Vs. CIT 20 ITR 287 (Cal). it should not be based on mere suspicion, conjecture or guess work or on irrelevant or inadmissible material. Dhirajlal Girdharilal Vs. CIT 26 ITR 736 (SC), Lalchand Bhagar Ambica Ram Vs. CIT 37 ITR 288 (SC), Umacharan Shaw & Bros Vs. CIT 37 ITR 271 (SC), Omar Salay Mohamed Sait Vs. CIT 37 ITR 151 (SC), Page 170 “On no account whatever should the Tribunal base its findings on suspicions, conjectures or surmises nor should it act on no evidence at all or on improper rejection of material and rele…

DCIT, New Delhi vs. M/S. Majestic Properties (P) Ltd., New Delhi

In the result, all the appeals of the revenue are dismissed

ITA 5231/DEL/2011[2005-06]Status: DisposedITAT Delhi14 Oct 2022AY 2005-06

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 5231/Del/2011 : Asstt. Year 2005-06 Ita No. 5392/Del/2011 : Asstt. Year 2006-07 Ita No. 5579/Del/2011 : Asstt. Year 2007-08 Acit, Vs. M/S Majestic Properties (P) Ltd., Central Circle-2, 1/18B, Asaf Ali Road, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaacm7158E Assessee By : Dr. Rakesh Gupta, Adv. & Sh. Deepesh Garg, Adv. Revenue By : Ms. Shivani Singh, Cit Dr Date Of Hearing: 22.07.2022 Date Of Pronouncement: 14.10.2022

For Appellant: Dr. Rakesh Gupta, Adv. &For Respondent: Ms. Shivani Singh, CIT DR
Section 132

…ere existence of reasons for suspicion would not tantamount to evidence. Narayan Chand Baidya Vs. CIT 20 ITR 287 (Cal). it should not be based on mere suspicion, conjecture or guess work or on irrelevant or inadmissible material. Dhirajlal Girdharilal Vs. CIT 26 ITR 736 (SC), Lalchand Bhagar Ambica Ram Vs. CIT 37 ITR 288 (SC), Umacharan Shaw & Bros Vs. CIT 37 ITR 271 (SC), Omar Salay Mohamed Sait Vs. CIT 37 ITR 151 (SC), Page 170 “On no account whatever should the Tribunal base its findings on suspicions, conjectures or surmises nor should it act on no evidence at all or on improper rejection of material and rele…

ACIT 2(3) (1), Mumbai vs. M/S. Thakkr Housing Development Pvt. Ltd, Mumbai

In the result all the five appeals filed by the learned assessing officer are dismissed

ITA 2135/MUM/2021[2012-13]Status: DisposedITAT Mumbai22 Aug 2022AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Rishabh Shah, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 245D(4)

…on in the statements given by the vendors. It is settled position of law that the contradictory statement has no evidentiary value and reference in this regard can be made to the decision of Hon'ble Supreme Court in the case of Dhirajlal Giridharilal vs. CIT, 26 ITR 736 (SC). 31. Furthermore, during the course of search and seizure action in the premises of the appellant group, no incriminating material was found suggesting the payment of any on money consideration. It is also settled position of law that no addition can be made the merely based statement u/s 132(4) of the Act by third party in the absence of any…

ACIT 2(3) (1), Mumbai vs. M/S. Thakkar Apana Ghar Pvt. Ltd, Mumbai

In the result all the five appeals filed by the learned assessing officer are dismissed

ITA 2134/MUM/2021[2014-15]Status: DisposedITAT Mumbai22 Aug 2022AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Rishabh Shah, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 245D(4)

…on in the statements given by the vendors. It is settled position of law that the contradictory statement has no evidentiary value and reference in this regard can be made to the decision of Hon'ble Supreme Court in the case of Dhirajlal Giridharilal vs. CIT, 26 ITR 736 (SC). 31. Furthermore, during the course of search and seizure action in the premises of the appellant group, no incriminating material was found suggesting the payment of any on money consideration. It is also settled position of law that no addition can be made the merely based statement u/s 132(4) of the Act by third party in the absence of any…

ACIT 2(3) (1), Mumbai vs. M/S. Thakkar Apna Ghar Nirman Pvt. Ltd, Mumbai

In the result all the five appeals filed by the learned assessing officer are dismissed

ITA 2133/MUM/2021[2012-13]Status: DisposedITAT Mumbai22 Aug 2022AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Rishabh Shah, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 245D(4)

…on in the statements given by the vendors. It is settled position of law that the contradictory statement has no evidentiary value and reference in this regard can be made to the decision of Hon'ble Supreme Court in the case of Dhirajlal Giridharilal vs. CIT, 26 ITR 736 (SC). 31. Furthermore, during the course of search and seizure action in the premises of the appellant group, no incriminating material was found suggesting the payment of any on money consideration. It is also settled position of law that no addition can be made the merely based statement u/s 132(4) of the Act by third party in the absence of any…

ACIT 2(3) 1, Mumbai vs. M/S. Thakkar Grih Nirman Pvt. Ltd, Mumbai

In the result all the five appeals filed by the learned assessing officer are dismissed

ITA 2132/MUM/2021[2014-15]Status: DisposedITAT Mumbai22 Aug 2022AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Rishabh Shah, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 245D(4)

…on in the statements given by the vendors. It is settled position of law that the contradictory statement has no evidentiary value and reference in this regard can be made to the decision of Hon'ble Supreme Court in the case of Dhirajlal Giridharilal vs. CIT, 26 ITR 736 (SC). 31. Furthermore, during the course of search and seizure action in the premises of the appellant group, no incriminating material was found suggesting the payment of any on money consideration. It is also settled position of law that no addition can be made the merely based statement u/s 132(4) of the Act by third party in the absence of any…

ACIT 2(3) (1), Mumbai vs. M/S. Thakkar Housing Developement Pvt. Ltd, Mumbai

In the result all the five appeals filed by the learned assessing officer are dismissed

ITA 2131/MUM/2021[2014-15]Status: DisposedITAT Mumbai22 Aug 2022AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Rishabh Shah, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 245D(4)

…on in the statements given by the vendors. It is settled position of law that the contradictory statement has no evidentiary value and reference in this regard can be made to the decision of Hon'ble Supreme Court in the case of Dhirajlal Giridharilal vs. CIT, 26 ITR 736 (SC). 31. Furthermore, during the course of search and seizure action in the premises of the appellant group, no incriminating material was found suggesting the payment of any on money consideration. It is also settled position of law that no addition can be made the merely based statement u/s 132(4) of the Act by third party in the absence of any…

Sri Rathan Babulal Lath, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle- 1(4), Bangalore

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 157/BANG/2020[2009-10]Status: DisposedITAT Bangalore05 Aug 2022AY 2009-10

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2009-10

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri Vilas V. Shinde, D.R
Section 132Section 153A

…and Others [(2017) 295 CTR 0466 (Del)], Hon’ble High Court of Delhi while considering the substantial question of law relating to invoking of Section 153A of the Act has analyzed the catena of judgments more particularly, Smt. Dayawanti Gupta V/s. CIT [(1954) 26 ITR 736 (SC)J and Kabul Chawla supra and held that there was a clear admission by the assessee in Dayawanti Gupta supra of a failure in maintaining regular books of accounts, on the basis of material recovered during search, the additions were made for all the years. The Hon’ble Court held that what weighed with the Court in the said decision was the “hab…

Deputy Commissioner of Income Tax, Central Circle- 1(3), Bangalore vs. Shri. T. Nadakrishna, Bangalore

In the result, assessee’s appeal in ITA No

ITA 575/BANG/2020[2007-08]Status: DisposedITAT Bangalore27 May 2022AY 2007-08

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

…and Others [(2017) 295 CTR 0466 (Del)], Hon’ble High Court of Delhi while considering the substantial question of law relating to invoking of Section 153A of the Act has analyzed the catena of judgments more particularly, Smt. Dayawanti Gupta V/s. CIT [(1954) 26 ITR 736 (SC)J and Kabul Chawla supra and held that there was a clear admission by the assessee in Dayawanti Gupta supra of a failure in maintaining regular books of accounts, on the basis of material recovered during search, the additions were made for all the years. The Hon’ble Court held that what weighed with the Court in the said decision was the “hab…

M/S. Spr Spirits Private Limited (Formerly Known As Spr Group Holdings Private Limited), Bangalore vs. Deputy Commissioner of Income Tax, Central Circle- 1(3), Bangalore

In the result, assessee’s appeal in ITA No

ITA 127/BANG/2020[2007-08]Status: DisposedITAT Bangalore27 May 2022AY 2007-08

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

…and Others [(2017) 295 CTR 0466 (Del)], Hon’ble High Court of Delhi while considering the substantial question of law relating to invoking of Section 153A of the Act has analyzed the catena of judgments more particularly, Smt. Dayawanti Gupta V/s. CIT [(1954) 26 ITR 736 (SC)J and Kabul Chawla supra and held that there was a clear admission by the assessee in Dayawanti Gupta supra of a failure in maintaining regular books of accounts, on the basis of material recovered during search, the additions were made for all the years. The Hon’ble Court held that what weighed with the Court in the said decision was the “hab…

M/S Spr Spirits Pvt. Ltd., Bengaluru vs. Deputy Commissioner of Income Tax Central Circle -1 (3), Bengaluru

In the result, assessee’s appeal in ITA No

ITA 1661/BANG/2018[2011-12]Status: DisposedITAT Bangalore27 May 2022AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

…and Others [(2017) 295 CTR 0466 (Del)], Hon’ble High Court of Delhi while considering the substantial question of law relating to invoking of Section 153A of the Act has analyzed the catena of judgments more particularly, Smt. Dayawanti Gupta V/s. CIT [(1954) 26 ITR 736 (SC)J and Kabul Chawla supra and held that there was a clear admission by the assessee in Dayawanti Gupta supra of a failure in maintaining regular books of accounts, on the basis of material recovered during search, the additions were made for all the years. The Hon’ble Court held that what weighed with the Court in the said decision was the “hab…

M/S Spr Spirits Pvt. Ltd., Bengaluru vs. Deputy Commissioner of Income Tax Central Circle -1 (3), Bengaluru

In the result, assessee’s appeal in ITA No

ITA 1660/BANG/2018[2010-11]Status: DisposedITAT Bangalore27 May 2022AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

…and Others [(2017) 295 CTR 0466 (Del)], Hon’ble High Court of Delhi while considering the substantial question of law relating to invoking of Section 153A of the Act has analyzed the catena of judgments more particularly, Smt. Dayawanti Gupta V/s. CIT [(1954) 26 ITR 736 (SC)J and Kabul Chawla supra and held that there was a clear admission by the assessee in Dayawanti Gupta supra of a failure in maintaining regular books of accounts, on the basis of material recovered during search, the additions were made for all the years. The Hon’ble Court held that what weighed with the Court in the said decision was the “hab…

M/S Spr Spirits Pvt.Ltd., Bengaluru vs. Deputy Commissioner of Income Tax Central Circle -1 (3), Bengaluru

In the result, assessee’s appeal in ITA No

ITA 1659/BANG/2018[2009-10]Status: DisposedITAT Bangalore27 May 2022AY 2009-10

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

…and Others [(2017) 295 CTR 0466 (Del)], Hon’ble High Court of Delhi while considering the substantial question of law relating to invoking of Section 153A of the Act has analyzed the catena of judgments more particularly, Smt. Dayawanti Gupta V/s. CIT [(1954) 26 ITR 736 (SC)J and Kabul Chawla supra and held that there was a clear admission by the assessee in Dayawanti Gupta supra of a failure in maintaining regular books of accounts, on the basis of material recovered during search, the additions were made for all the years. The Hon’ble Court held that what weighed with the Court in the said decision was the “hab…

M/S Spr Spirits Pvt. Ltd., Bengaluru vs. Deputy Commissioner of Income Tax Central Circle - 1 (3), Bengaluru

In the result, assessee’s appeal in ITA No

ITA 1658/BANG/2018[2008-09]Status: DisposedITAT Bangalore27 May 2022AY 2008-09

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

…and Others [(2017) 295 CTR 0466 (Del)], Hon’ble High Court of Delhi while considering the substantial question of law relating to invoking of Section 153A of the Act has analyzed the catena of judgments more particularly, Smt. Dayawanti Gupta V/s. CIT [(1954) 26 ITR 736 (SC)J and Kabul Chawla supra and held that there was a clear admission by the assessee in Dayawanti Gupta supra of a failure in maintaining regular books of accounts, on the basis of material recovered during search, the additions were made for all the years. The Hon’ble Court held that what weighed with the Court in the said decision was the “hab…

Smt. Anuradha Upadhyay, Jabalpur vs. Income Tax Officer Ward 2(5)

In the result, the appeals by the assessee‟s are dismissed

ITA 22/JAB/2017[2012-13]Status: DisposedITAT Jabalpur08 Apr 2022AY 2012-13

Bench: Shri Sanjay Arora, Hon‟Ble & Shri Manomohan Das, Hon'Ble

For Appellant: Shri Dhiraj Ghai, FCAFor Respondent: Shri U.B. Mishra , CIT-DR
Section 263Section 263(2)

…o by the material on record, and it‟s findings are to be based on relevant material (CIT v. Radha Kishan Nandlal [1975] 99 ITR 143 (SC); Daulat Ram Rawatmull (supra); Oman Salay Mohammed Sait v. CIT [1959] 37 ITR 151 (SC); Dhirajlal Girdhari Lal v. CIT [1954] 26 ITR 736 (SC)). We 6 ITA Nos. 19-21/JAB/2017 (A.Ys. 2010-11 to 2012-13) Suresh Kumar Upadhyay & Sons and Ano. v. ITO have already indicated of a much higher workload attending the year-end, which may explain the time lag of a few days between the date of its passing and the date of its despatch, which is of a certified copy thereof, prepared by the staf…

Suresh Upadhyay and Sons, Jabalpur vs. Income Tax Officer Ward 2(5)

In the result, the appeals by the assessee‟s are dismissed

ITA 21/JAB/2017[2012-13]Status: DisposedITAT Jabalpur08 Apr 2022AY 2012-13

Bench: Shri Sanjay Arora, Hon‟Ble & Shri Manomohan Das, Hon'Ble

For Appellant: Shri Dhiraj Ghai, FCAFor Respondent: Shri U.B. Mishra , CIT-DR
Section 263Section 263(2)

…o by the material on record, and it‟s findings are to be based on relevant material (CIT v. Radha Kishan Nandlal [1975] 99 ITR 143 (SC); Daulat Ram Rawatmull (supra); Oman Salay Mohammed Sait v. CIT [1959] 37 ITR 151 (SC); Dhirajlal Girdhari Lal v. CIT [1954] 26 ITR 736 (SC)). We 6 ITA Nos. 19-21/JAB/2017 (A.Ys. 2010-11 to 2012-13) Suresh Kumar Upadhyay & Sons and Ano. v. ITO have already indicated of a much higher workload attending the year-end, which may explain the time lag of a few days between the date of its passing and the date of its despatch, which is of a certified copy thereof, prepared by the staf…

Suresh Upadhyay and Sons, Jabalpur vs. Income Tax Officer Ward 2(5)

In the result, the appeals by the assessee‟s are dismissed

ITA 20/JAB/2017[2011-12]Status: DisposedITAT Jabalpur08 Apr 2022AY 2011-12

Bench: Shri Sanjay Arora, Hon‟Ble & Shri Manomohan Das, Hon'Ble

For Appellant: Shri Dhiraj Ghai, FCAFor Respondent: Shri U.B. Mishra , CIT-DR
Section 263Section 263(2)

…o by the material on record, and it‟s findings are to be based on relevant material (CIT v. Radha Kishan Nandlal [1975] 99 ITR 143 (SC); Daulat Ram Rawatmull (supra); Oman Salay Mohammed Sait v. CIT [1959] 37 ITR 151 (SC); Dhirajlal Girdhari Lal v. CIT [1954] 26 ITR 736 (SC)). We 6 ITA Nos. 19-21/JAB/2017 (A.Ys. 2010-11 to 2012-13) Suresh Kumar Upadhyay & Sons and Ano. v. ITO have already indicated of a much higher workload attending the year-end, which may explain the time lag of a few days between the date of its passing and the date of its despatch, which is of a certified copy thereof, prepared by the staf…