Glass Lines Equipments Company Ltd. v. CIT

253 ITR 454High Court2002#663 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 366,470 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

Sections most often in play

Section 69CSection 143(3)Section 68Section 132Section 44ADSection 37(1)Section 147Section 148
Read the full judgment

Issues it is cited on

undisclosed foreign income and assetssection 149(1)(c)section 4(2)section 201(3)section 158baunexplained jewellerysection 150section 70section 69dbeyond four yearssection 18statement under section 132(4)

Judgments citing Glass Lines Equipments Company Ltd. v. CIT

Sh. Parshotam Lal, Ludhiana vs. DCIT, CC-1, Ludhiana

In the result, we upheld the addition totaling to Rs 18,31,800/- towards cash seized u/s 69A in A

ITA 108/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh15 Apr 2024AY 2017-18

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishabh Marwah, C.AFor Respondent: Smt. Kusum, CIT, DR
Section 115BSection 69A

…आयकर अपीलीय अिधकरण,च"डीगढ़ "यायपीठ “बी” , च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “B”, CHANDIGARH HEARING THROUGH: PHYSICAL MODE "ी आकाश दीप जैन, उपा"य" एवं "ी िव"म "सह यादव, लेखा सद"य BEFORE: SHRI. AAKASH DEEP JAIN, VP & SHRI. VIKRAM SINGH YADAV, AM आयकर अपील सं./ ITA NO. 105 To 111/Chd/2023 िनधा"रण वष" / Assessment Year : 2014-15 To 2020-21 Shri Parshotam Lal बनाम The DCIT S/o Shri Raj Kumar Central Circle-1, Ludhiana H.No. 8/152, Mandi Mullanpur, Ludhiana – 141101, Punjab "थायी लेखा सं./PAN NO: BCPPL1074H अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रती क" ओर से/Assessee by : Shri Sudhir Sehga…

Sh. Parshotam Lal, Ludhiana vs. DCIT, CC-1, Ludhiana

In the result, we upheld the addition totaling to Rs 18,31,800/- towards cash seized u/s 69A in A

ITA 107/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh15 Apr 2024AY 2016-17

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishabh Marwah, C.AFor Respondent: Smt. Kusum, CIT, DR
Section 115BSection 69A

…आयकर अपीलीय अिधकरण,च"डीगढ़ "यायपीठ “बी” , च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “B”, CHANDIGARH HEARING THROUGH: PHYSICAL MODE "ी आकाश दीप जैन, उपा"य" एवं "ी िव"म "सह यादव, लेखा सद"य BEFORE: SHRI. AAKASH DEEP JAIN, VP & SHRI. VIKRAM SINGH YADAV, AM आयकर अपील सं./ ITA NO. 105 To 111/Chd/2023 िनधा"रण वष" / Assessment Year : 2014-15 To 2020-21 Shri Parshotam Lal बनाम The DCIT S/o Shri Raj Kumar Central Circle-1, Ludhiana H.No. 8/152, Mandi Mullanpur, Ludhiana – 141101, Punjab "थायी लेखा सं./PAN NO: BCPPL1074H अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रती क" ओर से/Assessee by : Shri Sudhir Sehga…

Sh. Parshotam Lal, Ludhiana vs. DCIT, CC-1, Ludhiana

In the result, we upheld the addition totaling to Rs 18,31,800/- towards cash seized u/s 69A in A

ITA 106/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh15 Apr 2024AY 2015-16

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishabh Marwah, C.AFor Respondent: Smt. Kusum, CIT, DR
Section 115BSection 69A

…आयकर अपीलीय अिधकरण,च"डीगढ़ "यायपीठ “बी” , च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “B”, CHANDIGARH HEARING THROUGH: PHYSICAL MODE "ी आकाश दीप जैन, उपा"य" एवं "ी िव"म "सह यादव, लेखा सद"य BEFORE: SHRI. AAKASH DEEP JAIN, VP & SHRI. VIKRAM SINGH YADAV, AM आयकर अपील सं./ ITA NO. 105 To 111/Chd/2023 िनधा"रण वष" / Assessment Year : 2014-15 To 2020-21 Shri Parshotam Lal बनाम The DCIT S/o Shri Raj Kumar Central Circle-1, Ludhiana H.No. 8/152, Mandi Mullanpur, Ludhiana – 141101, Punjab "थायी लेखा सं./PAN NO: BCPPL1074H अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रती क" ओर से/Assessee by : Shri Sudhir Sehga…

Sh. Parshotam Lal, Ludhiana vs. DCIT, CC-1, Ludhiana

In the result, we upheld the addition totaling to Rs 18,31,800/- towards cash seized u/s 69A in A

ITA 105/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh15 Apr 2024AY 2014-15

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishabh Marwah, C.AFor Respondent: Smt. Kusum, CIT, DR
Section 115BSection 69A

…आयकर अपीलीय अिधकरण,च"डीगढ़ "यायपीठ “बी” , च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “B”, CHANDIGARH HEARING THROUGH: PHYSICAL MODE "ी आकाश दीप जैन, उपा"य" एवं "ी िव"म "सह यादव, लेखा सद"य BEFORE: SHRI. AAKASH DEEP JAIN, VP & SHRI. VIKRAM SINGH YADAV, AM आयकर अपील सं./ ITA NO. 105 To 111/Chd/2023 िनधा"रण वष" / Assessment Year : 2014-15 To 2020-21 Shri Parshotam Lal बनाम The DCIT S/o Shri Raj Kumar Central Circle-1, Ludhiana H.No. 8/152, Mandi Mullanpur, Ludhiana – 141101, Punjab "थायी लेखा सं./PAN NO: BCPPL1074H अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रती क" ओर से/Assessee by : Shri Sudhir Sehga…

The ITO, Ward-3(2)(4), Ahmedabad vs. M/S. Radhe Krishna Developers, Ahmedabad

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 418/AHD/2020[2010-11]Status: DisposedITAT Ahmedabad05 Apr 2024AY 2010-11

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 133ASection 143(3)Section 40A(3)Section 69Section 69B

…g confirmations, PAN, affidavits etc. Affidavit placed on record and the contents of the said affidavit have remained uncontroverted. The same was not disproved or found to be false. If that be so Hon'ble Gujarat High Court in the case of Glass Line Equipment 253 ITR 454 has held that when affidavit was not controverted, it has to be taken as accepted. The affidavit is accepted as genuine and the addition of Rs.54,50,000/- is deleted. Ground no. 3 is allowed.” I.T.A No. 418/Ahd/2020 A.Y. 2010-11 Page No 12 ITO Vs. M/s. Radhe Krishna Developers 9. The Ld. Sr. D.R. appearing for the Revenue could not contravent t…

Shri Ashok Bhawarlal Jain, Pune vs. ACIT, Central Circle 1(1), Pune

In the result, the appeal filed by the assessee in ITA

ITA 1123/PUN/2023[2018-19]Status: DisposedITAT Pune27 Mar 2024AY 2018-19

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: S/Shri Pawan Chakrapani &For Respondent: Shri Keyur Patel
Section 132(4)Section 153A

…contents of the diary which are detrimental to the AO. In this regard, reliance can be placed in the cases of Mehta Parikh & Co. vs. CIT (1956) 30 ITR 181 (SC), Navjivan Oil Mills vs. CIT (2001) 252 ITR 417 (Guj), Glass Lines Equipment Co Ltd. Vs. CIT (2002) 253 ITR 454 (Guj). The Pune Tribunal in the case of Kantilal & Bros. reported in 52 ITD 412 after making reference to judicial precedence referred supra, deduced the following principles : & IT(SS)A No. 22/PUN/2023 (i) A document seized in the search should be read as a whole. (ii) No party can pick and choose one part of document for its advantage. (iii) I…

Shri Ashok Bhawarlal Jain, Pune vs. ACIT Central Circle 1(1), Pune

In the result, the appeal filed by the assessee in ITA

ITA 1122/PUN/2023[A.Y- 2014-15]Status: DisposedITAT Pune27 Mar 2024

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: S/Shri Pawan Chakrapani &For Respondent: Shri Keyur Patel
Section 132(4)Section 153A

…contents of the diary which are detrimental to the AO. In this regard, reliance can be placed in the cases of Mehta Parikh & Co. vs. CIT (1956) 30 ITR 181 (SC), Navjivan Oil Mills vs. CIT (2001) 252 ITR 417 (Guj), Glass Lines Equipment Co Ltd. Vs. CIT (2002) 253 ITR 454 (Guj). The Pune Tribunal in the case of Kantilal & Bros. reported in 52 ITD 412 after making reference to judicial precedence referred supra, deduced the following principles : & IT(SS)A No. 22/PUN/2023 (i) A document seized in the search should be read as a whole. (ii) No party can pick and choose one part of document for its advantage. (iii) I…

DCIT Central Circle - 6(1), Mumbai vs. Gnp Consultancy and Solutions Private Limited, Thane

ITA 3110/MUM/2023[2021-22]Status: DisposedITAT Mumbai20 Mar 2024AY 2021-22

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

For Appellant: Shri Nishit Gandhi , AdvocateFor Respondent: Shri Dr . Kishor Dhule, CIT DR
Section 143Section 69

…regard is also submitted that the AO cannot accept the content of the document in part and ignore the rest has this is not permitted under the law. In this regard the assessee has relied on the decision of glass lines equipments Co Ltd versus CIT reported in 253 ITR 454 (Gujarat)…….. 12.4 assessee also submitted that it has filed a fund flow statement of unaccounted income offered by the group and its application on page number 44 of the paper book and there was a cash balance available of ₹ 14.27 crores at the end of the year out of a additional income offered by the group up to 31/3/2021 and the said balance a…

Gnp Consultancy and Solutions Pvt Ltd, Nariman Point vs. DCIT Circle-6(1), Mumbai, Nariman Point

ITA 2547/MUM/2023[2021-22]Status: DisposedITAT Mumbai20 Mar 2024AY 2021-22

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Gnp Consultancy & Dcit Solutions Private Limited Central Circle-6(1) Room No.1905, 19 Th Floor, Plot No.91, Shop No.1 Channel Classic Chs Sector Air India Building, Nariman Vs. Point 4 Kopar Khairne, Thane Mumbai-400 021 Mumbai-400 709 (Respondent) (Appellant) Pan No. Aadcg3716B Gnp Consultancy & Dcit Solutions Private Limited Central Circle-6(1) Plot No.91, Shop No.1 Room No.1905, 19 Th Floor, Channel Classic Chs Sector Air India Building, Nariman Vs. Point 4 Kopar Khairne, Thane Mumbai-400 021 Mumbai-400 709 (Appellant) (Respondent) Assessee By : Shri Nishit Gandhi, Advocate Revenue By : Shri Dr. Kishor Dhule, Cit Dr Date Of Hearing: 23.01.2024 Date Of Pronouncement : 20.03.2024

For Appellant: Shri Nishit Gandhi, AdvocateFor Respondent: Shri Dr. Kishor Dhule, CIT DR
Section 143Section 69

…regard is also submitted that the AO cannot accept the content of the document in part and ignore the rest has this is not permitted under the law. In this regard the assessee has relied on the decision of glass lines equipments Co Ltd versus CIT reported in 253 ITR 454 (Gujarat)……. 12.4 assessee also submitted that it has filed a fund flow statement of unaccounted income offered by the group and its application on page number 44 of the paper book and there was a cash balance available of ₹ 14.27 crores at the end of the year out of a additional income offered by the group up to 31/3/2021 and the said balance al…

Ram Dhan Yadav, Chomu Jaipur vs. Income Tax Officer, ITO 7(3), Jaipur

In the result, both the appeals of the assessee are allowed

ITA 369/JPR/2023[2008-09]Status: DisposedITAT Jaipur20 Feb 2024AY 2008-09

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajesh Soni (C.A.)For Respondent: Shri Anoop Singh (Addl.CIT)
Section 143(3)Section 144Section 147Section 148Section 69B

…ation of documents - Documents must be read as a whole. It is a well settled canon of interpretation that a document has to be read as a whole" it is not permissible to accept a part and ignore the rest of the document. Glass Lines Equipments Co. Ltd. V/s CIT 253 ITR 454 (Guj.) 6. Addition cannot be made on the basis of the papers, ownership of which is doubtful, since the burden to prove the ownership of such paper is on the department when it desires to make any addition on the basis of it. Further in such cases of doubtfulness, benefit of doubt should go in favour of assessee. Ashwani kumar Bhardwaj V/s DCIT (…

Ram Dhan Yadav, Chomu Jaipur vs. ITO, WD 7(3), Jaipur

In the result, both the appeals of the assessee are allowed

ITA 366/JPR/2023[2007-2008]Status: DisposedITAT Jaipur20 Feb 2024AY 2007-2008

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajesh Soni (C.A.)For Respondent: Shri Anoop Singh (Addl.CIT)
Section 143(3)Section 144Section 147Section 148Section 69B

…ation of documents - Documents must be read as a whole. It is a well settled canon of interpretation that a document has to be read as a whole" it is not permissible to accept a part and ignore the rest of the document. Glass Lines Equipments Co. Ltd. V/s CIT 253 ITR 454 (Guj.) 6. Addition cannot be made on the basis of the papers, ownership of which is doubtful, since the burden to prove the ownership of such paper is on the department when it desires to make any addition on the basis of it. Further in such cases of doubtfulness, benefit of doubt should go in favour of assessee. Ashwani kumar Bhardwaj V/s DCIT (…

The ITO, Patan Ward-5, Mehsana vs. M/S. Shubh Developers, Mehsana

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 1125/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad05 Jan 2024AY 2014-15

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 133ASection 143(3)

…The assessee also filed detailed submissions of each Projects undertaken by the assessee firm. However the same was also not considered by the Assessing Officer. Jurisdictional High Court in the case of Glass Line Equipment Co. Ltd. vs. CIT reported in (2002) 253 ITR 454 held as follows: "In the present case, we find that Commissioner (Appeals) while dealing with the affidavit, has conveniently chosen to accept only one part of the statement which was in favour of the revenue and against the assessee while ignoring the rest of the portion wherein specific averments were made in relation to the balance items of ex…

Shri Jashandeep Singh Sidhu, Bathinda vs. Income Tax Officer Ward- 1 (3), Bathinda

In the result, the appeal of the assessee bearing ITA No

ITA 11/ASR/2023[2010-11]Status: HeardITAT Amritsar20 Sept 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 144Section 144aSection 147Section 148Section 151Section 250Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR. BEFORE DR. M. L. MEENA, ACCOUNTANT MEMBER AND SH. ANIKESH BANERJEE, JUDICIAL MEMBER I.T.A. No. 310/Asr/2019& ITA 11/Asr/2023 Assessment Year: 2010-11 Sh. Jashandeep Singh Sidhu Vs. ITO, Ward-1(3), Patti Janike, VPO Bhai Rupa, Bathinda. Bathinda. [PAN: -CBPPS9297F] (Appellant) (Respondent) Appellant by Sh.Sudhir Sehgal & Sh. P. N. Arora, Adv Sh. Manoj Aggarwal, Sr. DR. Respondent by Date of Hearing 13.09.2023 20.09.2023 Date of Pronouncement ORDER Per: Anikesh Banerjee, JM: These two appeals of the same assessee were filed against the order of the…

Shri Jashandeep Singh Sidhu, Bathinda vs. Income Tax Officer Ward-1(3), Bathinda

In the result, the appeal of the assessee bearing ITA No

ITA 310/ASR/2019[2010-11]Status: HeardITAT Amritsar20 Sept 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 144Section 144aSection 147Section 148Section 151Section 250Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR. BEFORE DR. M. L. MEENA, ACCOUNTANT MEMBER AND SH. ANIKESH BANERJEE, JUDICIAL MEMBER I.T.A. No. 310/Asr/2019& ITA 11/Asr/2023 Assessment Year: 2010-11 Sh. Jashandeep Singh Sidhu Vs. ITO, Ward-1(3), Patti Janike, VPO Bhai Rupa, Bathinda. Bathinda. [PAN: -CBPPS9297F] (Appellant) (Respondent) Appellant by Sh.Sudhir Sehgal & Sh. P. N. Arora, Adv Sh. Manoj Aggarwal, Sr. DR. Respondent by Date of Hearing 13.09.2023 20.09.2023 Date of Pronouncement ORDER Per: Anikesh Banerjee, JM: These two appeals of the same assessee were filed against the order of the…

Shri Bhavish Harilal Moradia, Rajkot vs. The ITO Ward-1 (1) (3), Rajkot

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

ITA 63/RJT/2023[2009-10]Status: DisposedITAT Rajkot02 Aug 2023AY 2009-10

Bench: SHRI WASEEM AHMED (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)

For Appellant: Shri M. N. Manvar, A.RFor Respondent: Shri K. L. Solanki, Sr. D.R
Section 132Section 147Section 148Section 153C

…efore the AO but the AO on one hand relied upon the affidavit of third party but rejected the affidavit of assessee without assigning any A.Y.2009-10 reason to it. The Hon’ble Gujarat High Court in the case of Glass Line Equipments Co. Ltd vs. CIT reported in 253 ITR 454 held it is not open for the revenue to rely upon part of the affidavit which is favorable to department and against the assessee. The relevant observation of the Hon’ble High Court reads as under: As laid down by the Supreme Court in the case of Mehta Parikh & Co. v. CIT [1956] 30 ITR 181, none of the authorities considered it necessary to cross-…

Shri Gamdoor Singh, Mansa vs. Income Tax Officer Ward- 1 (5), Mansa

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

ITA 149/ASR/2023[2013-14]Status: DisposedITAT Amritsar07 Jul 2023AY 2013-14

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR BEFORE DR. M. L. MEENA, ACCOUNTANT MEMBER AND SH. ANIKESH BANERJEE, JUDICIAL MEMBER I.T.A. No. 149/Asr/2023 Assessment Year: 2013-14 Gamdoor Singh V. Income Tax Officer, Near Atta Chakki, Ward-1(5), Mansa Vill. Talabwala VPO Boha The Budhlada, Mansa 151 503 [PAN: GXIPS 1950Q] (Respondent) (Appellant) Appellant by Sh. Sudhir Sehgal & Sh. P.K. Singla, Adv. Respondent by Sh. Prashant Singh, Sr. DR Date of Hearing : 21.06.2023 Date of Pronouncement : 07.07.2023 ORDER Per Dr. M. L. Meena, AM: This appeal has been filed by the assessee against…

DCIT, CC-2, Jaipur vs. Shri Jitendra Kumar Agarwal, Jaipur

In the result, appeal of the assessee is dismissed and that of the revenue is also stands dismissed

ITA 181/JPR/2020[2017-18]Status: DisposedITAT Jaipur07 Jun 2023AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

…whole and the entries of expenses as well as receipts cannot be considered in isolation rather it has to be worked out by giving full coherence for working of the additional income based on such papers / documents. Reliance is placed on following caselaws: 253 ITR 454 (Guj.) Glass Lines Equipments Co. Ltd. V/s CIT: Interpretation of documents - Documents must be read as a whole. It is a well settled canon of interpretation that a document has to be read as a whole" it is not permissible to accept a part and ignore the rest of the document. 22 TW 684Hissaria Brothers V/s ACIT (Jpr.): Shri Jitendra Kumar Agarw…

DCIT, CC-2, Jaipur vs. Shri Jitendra Kumar Agarwal, Jaipur

In the result, based on the discussion so recorded here in above both

ITA 180/JPR/2020[2016-17]Status: DisposedITAT Jaipur07 Jun 2023AY 2016-17

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

…whole and the entries of expenses as well as receipts cannot be considered in isolation rather it has to be worked out by giving full coherence for working of the additional income based on such papers / documents. Reliance is placed on following case laws: 253 ITR 454 (Guj.) Glass Lines Equipments Co. Ltd. V/s CIT: Interpretation of documents - Documents must be read as a whole. It is a well settled canon of interpretation that a document has to be read as a whole" it is not permissible to accept a part and ignore the rest of the document. 22 TW 684 Hissaria Brothers V/s ACIT (Jpr.): Held that the seized docu…

DCIT, CC-2, Jaipur vs. Shri Jitendra Kumar Agarwal, Jaipur

In the result, based on the discussion so recorded here in above both

ITA 179/JPR/2020[2015-16]Status: DisposedITAT Jaipur07 Jun 2023AY 2015-16

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

…whole and the entries of expenses as well as receipts cannot be considered in isolation rather it has to be worked out by giving full coherence for working of the additional income based on such papers / documents. Reliance is placed on following case laws: 253 ITR 454 (Guj.) Glass Lines Equipments Co. Ltd. V/s CIT: Interpretation of documents - Documents must be read as a whole. It is a well settled canon of interpretation that a document has to be read as a whole" it is not permissible to accept a part and ignore the rest of the document. 22 TW 684 Hissaria Brothers V/s ACIT (Jpr.): Held that the seized docu…

DCIT, CC-2, Jaipur vs. Shri Jitendra Kumar Agarwal, Jaipur

In the result, based on the discussion so recorded here in above both

ITA 178/JPR/2020[2013-14]Status: DisposedITAT Jaipur07 Jun 2023AY 2013-14

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

…whole and the entries of expenses as well as receipts cannot be considered in isolation rather it has to be worked out by giving full coherence for working of the additional income based on such papers / documents. Reliance is placed on following case laws: 253 ITR 454 (Guj.) Glass Lines Equipments Co. Ltd. V/s CIT: Interpretation of documents - Documents must be read as a whole. It is a well settled canon of interpretation that a document has to be read as a whole" it is not permissible to accept a part and ignore the rest of the document. 22 TW 684 Hissaria Brothers V/s ACIT (Jpr.): Held that the seized docu…