Glass Lines Equipments Company Ltd. v. CIT

253 ITR 454High Court2002#661 most cited

What is Glass Lines Equipments Company Ltd. v. CIT authority for?

The Assessing Officer cannot selectively accept parts of a statement or seized evidence that are favourable to the revenue while rejecting other parts favourable to the assessee without proper investigation; the evidence must be considered as a whole. Additions cannot be made based on mere presumptions or surmises without further inquiry.

150

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2025.

Also referred to as

Glass Lines Equipments Co. Ltd. · 253 ITR 454 · seized papers interpretation · selective acceptance of evidence · rejection of evidence · on money receipts · search assessment · AO duty to investigate · statement under Section 132(4)

Also reported as

119 Taxmann.com 813

Issues it is cited on

Judgments citing Glass Lines Equipments Company Ltd. v. CIT

MAYANKKUMAR RAMESHCHANDRA BHATT,VADODARA vs. THE INCOME TAX OFFICER, WARD-1(2)(1), VADODARA

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

ITA 1284/AHD/2024[2007-08]Status: DisposedITAT Ahmedabad29 Jul 2025AY 2007-08

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2007-08 Mayankkumar Rameschandra Ito, Ward-1(2)(1) Bhatt Vs. Vadodara. B/202, Laljikrupa Society B/H. Mothers School Gotri Road, Baroda. Pan : Agypb 2066 R (Applicant) (Responent) : Shri Tushar Hemani, Sr.Advocate Assessee By Revenue By : Shri Umesh Kumar Agrawal, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 24/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 29 /07/2025 आदेश आदेश/O R D E R आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Dated 17.05.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”] By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], For The Assessment Year 2007–08, Arising Out Of The Reassessment Order Dated 27.03.2015 Passed Under Section 144 R.W.S. 147 Of The Act By The Income Tax Officer, Ward 4(2)(4), Vadodara [Hereinafter Referred To As “Assessing Officer Or Ao”].

For Respondent: Shri Umesh Kumar Agrawal, Sr.DR
Section 10(38)Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)(c)Section 69A

…idavit while confirming the addition in paragraph 8.2 of the impugned appellate order. 5.2 In support of the legal proposition, reliance was placed on the judgment of the Hon’ble Gujarat High Court in the case of Glass Lines Equipment Co. Ltd. v. CIT [(2001) 253 ITR 454 (Guj)], wherein it was held that the revenue cannot challenge the correctness of the statement made by the deponent in the affidavit unless the deponent has been cross- 6 examined by the AO. In the present case, no such cross-examination was carried out and the affidavit remains uncontroverted. 5.3 It was further contended that the AO has acted…

THE ITO, WARD-3(3)(12),, AHMEDABAD vs. SHRI CAWAS DARASHA KARAKA, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

ITA 499/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad08 Apr 2025AY 2013-14

Bench: DR. B.R.R. KUMAR, VICE-PRESIDENT\nMS. SUCHITRA KAMBLE, JUDICIAL MEMBER\nI.T.A. No. 499/Ahd/2018\n(Assessment Year: 2013-14)\nIncome-Tax Officer,\nWard-3(3)(12),\nAhmedabad\n(Appellant)\nVs.\nLate Shri Cawas Darasha\nKaraka, Legal Heir M/s.\nCawas Karaka Trust,\n22, Teen Murti Bungalows,\nNr. Devang Bungalows,\nThaltej, Ahmedabad-380054\n[PAN : AGSPK 9616 L]\n(Respondent)\nAppellant by :\nShri Tushar Hemani, Sr. Advocate &\nShri Parimalsinh H. Parmar, ARs\nRespondent by:\nAdjournment applica

For Appellant: \nShri Tushar Hemani, Sr. Advocate &For Respondent: \nAdjournment application filed
Section 143(3)Section 250Section 48Section 49(1)Section 55(2)(a)Section 69A

…the said affidavit have remained uncontroverted.\nThe same was not disproved or found to be false. If that be so Hon'ble Gujarat\nITA No. 499/Ahd/2018\nITO Vs. Shri Cawas Darasha Karaka\nAsst. Year: 2013-14\n-7-\nHigh Coup in the case of Glass Line Equipment 253 ITR 454 has held that\nwhen affidavit was not controverted it has to be taken accepted.\"\n5.3\nThe above finding given by the CIT(A) is not found justified. Initially,\nhe admitted that there is no new evidence. Further, he held that the appellant\nhad paid Rs.3000/j- for waiver of the right as per the affidavit. Here, it is\nrelevant to mention that Rs…

GANADHISH GNP,NAVI MUMBAI vs. DCIT CIRCLE 6(1), MUMBAI, MUMBAI

In the result, all the appeals filed by the assessee are partly allowed and all the appeals filed by the Revenue are dismissed

ITA 3966/MUM/2024[2019-20]Status: DisposedITAT Mumbai17 Mar 2025AY 2019-20

Bench: Shri Amarjit Singh, Hon’Ble & Shri Raj Kumar Chauhan, Hon’Bleita No. 3965/Mum/2024 (A.Y. 2020-21) Ganadhish Gnp Dcit, Circle-6(1), Mumbai Shop No. 1203, 12Th Floor, Rupa Solitaire, Building No. A-I, Vs Sector-I, Millennium Business Park, Mahape Navi Mumbai- 400710. Pan: Aapfg 1164 L (Appellant) (Respondent) Ita No. 4481/Mum/2024 (A.Y. 2021-22) Dcit, Circle-6(1), Ganadhish Gnp Mumbai Shop No. 1203, 12Th Floor, Rupa Solitaire, Building No. A- Vs I, Sector-I, Millennium Business Park, Mahape Navi Mumbai-400710. Pan: Aapfg 1164 L (Appellant) (Respondent)

For Appellant: Shri Nishit Gandhi & Aadnya BhandariFor Respondent: Dr. Kishor Dhule, CIT/DR
Section 132Section 132(4)

…4 M/s. Ganadhish GNP 7.21 In the present case, the AO has accepted the “on money” receipts found in the search but has disregarded the claim of expenses found during the search. The Gujarat High Court in the case of Glass Lines Equipments Co. Ltd reported in 253 ITR 454 (Guj) held that the seized papers have to be interpreted as a whole and AO cannot accept part which is in favour of revenue and ignore the rest for making the addition. Hence, the action of the AO in taxing the “on money” receipts but ignoring the expenses out of “on money” is against the law. Therefore, the AO cannot pick and choose those portio…

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Glass Lines Equipments Company Ltd. v. CIT (253 ITR 454) — Cited in 150 Judgments | BharatTax