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

DCIT, CC-2, Jaipur vs. M/S. Royal Jewellers, Jaipur

In the result, appeal of the assessee in ITA No

ITA 176/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 143Section 143(3)Section 145(3)

…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. M/S. Royal Jewellers, Jaipur

In the result, appeal of the assessee in ITA No

ITA 175/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 143Section 143(3)Section 145(3)

…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. M/S. Royal Jewellers, Jaipur

In the result, appeal of the assessee in ITA No

ITA 174/JPR/2020[2014-15]Status: DisposedITAT Jaipur07 Jun 2023AY 2014-15

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 143Section 143(3)Section 145(3)

…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…

M/S. Royal Jewellers, Jaipur vs. DCIT, Central Circle, Jaipur

In the result, appeal of the assessee in ITA No

ITA 115/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 143Section 143(3)Section 145(3)

…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…

M/S. Royal Jewellers, Jaipur vs. DCIT, Central Circle, Jaipur

In the result, appeal of the assessee in ITA No

ITA 114/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 143Section 143(3)Section 145(3)

…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…

M/S. Royal Jewellers, Jaipur vs. DCIT, Central Circle, Jaipur

In the result, appeal of the assessee in ITA No

ITA 113/JPR/2020[2014-15]Status: DisposedITAT Jaipur07 Jun 2023AY 2014-15

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 143Section 143(3)Section 145(3)

…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…

Shri Jitendra Kumar Agarwal, Jaipur vs. DCIT, Central Circle-2, Jaipur

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

ITA 112/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…

Shri Jitendra Kumar Agarwal, Jaipur vs. DCIT, Central Circle-2, Jaipur

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

ITA 111/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…

Shri Jitendra Kumar Agarwal, Jaipur vs. DCIT, Central Circle-2, Jaipur

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

ITA 110/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…

Shri Jitendra Kumar Agarwal, Jaipur vs. DCIT, Central Circle-2, Jaipur

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

ITA 109/JPR/2020[2014-15]Status: DisposedITAT Jaipur07 Jun 2023AY 2014-15

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…

Shri Jitendra Kumar Agarwal, Jaipur vs. DCIT, Central Circle-2, Jaipur

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

ITA 108/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…

Shri Jitendra Kumar Agarwal, Jaipur vs. DCIT, Central Circle-2, Jaipur

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

ITA 107/JPR/2020[2012-13]Status: DisposedITAT Jaipur07 Jun 2023AY 2012-13

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…

Shri Jitendra Kumar Agarwal, Jaipur vs. DCIT, Central Circle-2, Jaipur

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

ITA 106/JPR/2020[2011-12]Status: DisposedITAT Jaipur07 Jun 2023AY 2011-12

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…

Harsh Agarwal, Jaipur vs. ACIT Central Circle-1, Jaipur

In the result appeal of the assessee is allowed

ITA 355/JPR/2022[2013-14]Status: DisposedITAT Jaipur13 Apr 2023AY 2013-14

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

For Appellant: Shri Manish Agarwal (C.A)For Respondent: Ms. James Kurian (CIT)
Section 143(3)

…re recorded in books of accounts. Your honours would appreciate that it is a settled principle of law that documents have to be interpreted as a whole and it is not permissible to AO to consider part of the document and ignore the rest. Reliance is placed on: 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) 10 Harsh Agarwal vs. ACIT He…

Deputy Commissioner of Income Tax, Central Circle Ajmer vs. Mukesh Kumar Somani, Kishangarh

In the result appeals of the revenue in ITA Nos

ITA 336/JPR/2022[2019-20]Status: DisposedITAT Jaipur08 Dec 2022AY 2019-20
For Appellant: Shri C. M Agarwal (C.A.)For Respondent: Shri Shailendra Sharma (CIT)
Section 143(3)Section 69

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh]U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA No. 334/JP/2022 fu/kZkj.k o"kZ@Assessment Years : 2019-20 cuke Deputy Commissioner of Income-tax, Sh. Alok Malpani Vs. Central Circle, 8, Panchwati Rajhans Colony, Ajmer Madanganj, Kishangarh, Ajmer LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AGZPM 0083 E vihykFkhZ@Appellant izR;FkhZ@Respondent CO No. 23/JP/2022 (Arising out of ITA No. 334/…

Deputy Commissioner of Income Tax, Central Circle Ajmer vs. Alok Malpani, Kishangarh

In the result appeals of the revenue in ITA Nos

ITA 334/JPR/2022[2019-20]Status: DisposedITAT Jaipur08 Dec 2022AY 2019-20
For Appellant: Shri C. M Agarwal (C.A.)For Respondent: Shri Shailendra Sharma (CIT)
Section 143(3)Section 69

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh]U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA No. 334/JP/2022 fu/kZkj.k o"kZ@Assessment Years : 2019-20 cuke Deputy Commissioner of Income-tax, Sh. Alok Malpani Vs. Central Circle, 8, Panchwati Rajhans Colony, Ajmer Madanganj, Kishangarh, Ajmer LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AGZPM 0083 E vihykFkhZ@Appellant izR;FkhZ@Respondent CO No. 23/JP/2022 (Arising out of ITA No. 334/…

Sh. Gulshan Kumar Prop. G.K. Resorts, Ludhiana vs. DCIT Circle-2, Ludhiana

In the result, the appeal of the assessee is allowed

ITA 488/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh31 Oct 2022AY 2017-18

Bench: Smt.Diva Singh & Shri Vikram Singh Yadavsh. Gulshan Kumar बनाम Deputy Commissioner Of Prop. G. K. Resorts House No. 3, Income Tax, Central Circle-2, Agar Nagar Extension, Ferospur Ludhiana Road, Ludhiana 1410212, Punjab "थायी लेखा सं./Pan No: Aaqpk1200Q

For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Smt. Amanpreet Kaur, Sr. DR
Section 143(2)Section 68

…ng with the affidavits filed by the two sons of the assessee with regard to the gifts and the judgment of Mehta Parikh vs. CIT reported in 30 ITR 181 was relied upon and which have been followed in the case of Glass Lime Equipment Co. Ltd. vs. CIT reported in 253 ITR 454 for the proposition that where the affidavits were filed, then no adverse view can be taken and same arguments were repeated. 15. It was submitted that the submission so filed by the assessee however did not fully find favour with the ld. CIT(A) and he has sustained part addition made by the AO. Regarding the findings of the ld. CIT(A), our refe…

DCIT Circle-3(3), Ahmedabad vs. Shri Alpeshkumar C.Patel, Ahmedabad

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

ITA 1991/AHD/2018[2011-12]Status: DisposedITAT Ahmedabad09 Sept 2022AY 2011-12

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumarआयकर अपील सं./Ita No. 1908/Ahd/2018 िनधा"रण वष"/Asstt. Year: 2011-2012 Alpeshkumar C. Patel, A.C.I.T., 503, Milestone Building, Vs. Circle-3(3), Drive In Road, Ahmedabad. Thaltej, Ahmedabad-380052. Pan: Aeapp9489G

For Appellant: Shri Deepak R. Shah, A.RFor Respondent: Shri Ajay Pratap Singh CIT. D.R with Shri V.K. Singh, Sr.D.R
Section 41(1)Section 54F

…46A of the Act. Affidavits of the parties were placed on record and the contents of the said affidavits 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. From the perusal of the work completion certificate, copy of work agreement furnished by the appellant, details of payment made to the sub contractor by the appellant and IDS made thereon, the argument of the appellant is partly correct though the GP on such advent…

Shri Naresh Jhanwar, Jaipur vs. DCIT, C.C.-3, Jaipur

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

ITA 260/JPR/2020[2017-18]Status: DisposedITAT Jaipur17 Aug 2022AY 2017-18
For Appellant: Sh. P. C. Parwal (CA)For Respondent: Shri Sanjay Dhariwal (CIT)
Section 139Section 143(3)Section 153ASection 199CSection 292CSection 68

…as a rejected as a whole— Navjivan Oil Mills vs. CIT (2001) 170 CTR (Guj) 224: (2001) 252 ITR 417 (Guj), Kantilal Bros. vs. Asstt. CIT (2995) 51 MI (Pune) 513: (1995) 52 ITD 412 (Pune), Glass Lines Equipment Co. Ltd. vs. CIT (2001) 170 CTR (Guj) 470 : (2002) 253 ITR 454 (Guj), Mehta Parikh & Co. vs. C1T (1956) 30 ITR 181 (SC) and Chander Mohan Mehta vs. Asstt. CIT (Inv.) (1999) 65 TTJ (Pune) 327: (1999) 71. ITD 245 (Pune) applied. First thing the AO has to prove is that it is the investment of the assessee. In other words, the ownership of the investment must be proved to be that of the assessee. The onus is on…

Shri Naresh Jhanwar, Jaipur vs. DCIT, C.C.-3, Jaipur

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

ITA 259/JPR/2020[2016-17]Status: DisposedITAT Jaipur17 Aug 2022AY 2016-17
For Appellant: Sh. P. C. Parwal (CA)For Respondent: Shri Sanjay Dhariwal (CIT)
Section 139Section 143(3)Section 153ASection 199CSection 292CSection 68

…as a rejected as a whole— Navjivan Oil Mills vs. CIT (2001) 170 CTR (Guj) 224: (2001) 252 ITR 417 (Guj), Kantilal Bros. vs. Asstt. CIT (2995) 51 MI (Pune) 513: (1995) 52 ITD 412 (Pune), Glass Lines Equipment Co. Ltd. vs. CIT (2001) 170 CTR (Guj) 470 : (2002) 253 ITR 454 (Guj), Mehta Parikh & Co. vs. C1T (1956) 30 ITR 181 (SC) and Chander Mohan Mehta vs. Asstt. CIT (Inv.) (1999) 65 TTJ (Pune) 327: (1999) 71. ITD 245 (Pune) applied. First thing the AO has to prove is that it is the investment of the assessee. In other words, the ownership of the investment must be proved to be that of the assessee. The onus is on…