(iii) CIT v. Concorde Capital Management Co Ltd.

334 ITR 346High Court2009#5766 most cited

What is (iii) CIT v. Concorde Capital Management Co Ltd. authority for?

Additions to income cannot be made solely on the basis of third-party statements without confronting the assessee with the statement and corroborating evidence.

20

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2017 to 2026.

Also referred to as

CIT v. Concorde Capital Management Co. Ltd. · 334 ITR 346 · additions based on third party statement · corroborated evidence · section 68 additions · natural justice · confrontation of evidence

Sections most often in play

Section 115BBESection 132Section 133ASection 142(1)Section 143(3)Section 147Section 153BSection 153C

Issues it is cited on

section 127(2)section 35adsection 35asection 140section 142asection 292cmiscellaneous applicationappeal before cit(a)section 158section 69bdocuments seizedsection 132a

Judgments citing (iii) CIT v. Concorde Capital Management Co Ltd.

Expressway Services Pvt Ltd, Hyderabad vs. DCIT., Central Circle-2(4), Hyderabad

In the result, the appeals filed by the assessee in ITA Nos

ITA 486/HYD/2025[2020-21]Status: DisposedITAT Hyderabad27 Mar 2026AY 2020-21
Section 132(4)Section 153C

…was held that no addition can be made u/s 68 on the basis of a statement by a third party which was not confronted to the assessee along with other supporting evidence. A similar view has been taken in the case of CIT v. Concorde Capital Management Co. [2009] 334 ITR 346 (Del)). The case of Addl. CIT v. Miss Lata Expressway Services Pvt. Ltd. Mangeshkar [1974] 97 ITR 696 (Bom) is a landmark ruling on the use of third-party evidence in tax assessments. The court held that entries in a third party's books of accounts. statements, or loose papers cannot form the sole basis for an addition unless corroborated by pri…

Expressway Services Pvt Ltd, Hyderabad vs. DCIT., Central Circle -2(4), Hyderabad

In the result, the appeals filed by the assessee in ITA Nos

ITA 485/HYD/2025[2019-20]Status: DisposedITAT Hyderabad27 Mar 2026AY 2019-20
Section 132(4)Section 153C

…was held that no addition can be made u/s 68 on the basis of a statement by a third party which was not confronted to the assessee along with other supporting evidence. A similar view has been taken in the case of CIT v. Concorde Capital Management Co. [2009] 334 ITR 346 (Del)). The case of Addl. CIT v. Miss Lata Expressway Services Pvt. Ltd. Mangeshkar [1974] 97 ITR 696 (Bom) is a landmark ruling on the use of third-party evidence in tax assessments. The court held that entries in a third party's books of accounts. statements, or loose papers cannot form the sole basis for an addition unless corroborated by pri…

Expressway Services Private Limited, Hyderabad vs. DCIT., Central Circle-2(4), Hyderabad

In the result, the appeals filed by the assessee in ITA Nos

ITA 484/HYD/2025[2018-19]Status: DisposedITAT Hyderabad27 Mar 2026AY 2018-19
Section 132(4)Section 153C

…was held that no addition can be made u/s 68 on the basis of a statement by a third party which was not confronted to the assessee along with other supporting evidence. A similar view has been taken in the case of CIT v. Concorde Capital Management Co. [2009] 334 ITR 346 (Del)). The case of Addl. CIT v. Miss Lata Expressway Services Pvt. Ltd. Mangeshkar [1974] 97 ITR 696 (Bom) is a landmark ruling on the use of third-party evidence in tax assessments. The court held that entries in a third party's books of accounts. statements, or loose papers cannot form the sole basis for an addition unless corroborated by pri…

Indravadan Hanjarimal Jain, Mumbai vs. Circle 42(2)(1), Mumbai

In the result, all the appeals filed by the assessee stands allowed

ITA 6281/MUM/2024[2009-10]Status: DisposedITAT Mumbai04 Apr 2025AY 2009-10

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankar

Section 142(1)Section 143(1)Section 147Section 250Section 271(1)(c)

…one who had obtained bogus loans, would not be sufficient to hold that the assessee's income had escaped assessment. b) Further the additions merely on third party statement are not justified as held in the case of CIT v. Concorde Capital Management Co. Ltd. 334 ITR 346 (Del) and Dr. R. L. Narang 174 Taxman 96 (Chd)(Mag). c) In the case of Saveetha Institute of Medical and Technical Sciences v. ACIT (2011) 012 ITR (Trib) 376 (Chen), wherein addition towards capitation fee allegedly collected by the institute was made solely on the basis of statements of students and staff recorded u/s 132(4) of the Act was made…

Indravadan Hanjarimal Jain, Mumbai vs. Circle 42(2)(1), Mumbai

In the result, all the appeals filed by the assessee stands allowed

ITA 6280/MUM/2024[2008-09]Status: DisposedITAT Mumbai04 Apr 2025AY 2008-09

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankar

Section 142(1)Section 143(1)Section 147Section 250Section 271(1)(c)

…one who had obtained bogus loans, would not be sufficient to hold that the assessee's income had escaped assessment. b) Further the additions merely on third party statement are not justified as held in the case of CIT v. Concorde Capital Management Co. Ltd. 334 ITR 346 (Del) and Dr. R. L. Narang 174 Taxman 96 (Chd)(Mag). c) In the case of Saveetha Institute of Medical and Technical Sciences v. ACIT (2011) 012 ITR (Trib) 376 (Chen), wherein addition towards capitation fee allegedly collected by the institute was made solely on the basis of statements of students and staff recorded u/s 132(4) of the Act was made…

Indravadan Hanjarimal Jain, Mumbai vs. Circle 42(2)(1), Mumbai

In the result, all the appeals filed by the assessee stands allowed

ITA 6279/MUM/2024[2007-08]Status: DisposedITAT Mumbai04 Apr 2025AY 2007-08

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankar

Section 142(1)Section 143(1)Section 147Section 250Section 271(1)(c)

…one who had obtained bogus loans, would not be sufficient to hold that the assessee's income had escaped assessment. b) Further the additions merely on third party statement are not justified as held in the case of CIT v. Concorde Capital Management Co. Ltd. 334 ITR 346 (Del) and Dr. R. L. Narang 174 Taxman 96 (Chd)(Mag). c) In the case of Saveetha Institute of Medical and Technical Sciences v. ACIT (2011) 012 ITR (Trib) 376 (Chen), wherein addition towards capitation fee allegedly collected by the institute was made solely on the basis of statements of students and staff recorded u/s 132(4) of the Act was made…

Khanna Infrabuild Private Limited 2000-1A, Sukhdev Nagar Ferozepur Road, Ludhiana vs. The Deputy Commissioner of Income Tax Central Circle-2 Ludhiana, Ludhiana

In the result, the ground of appeal is allowed

ITA 679/CHANDI/2023[2019-2020]Status: DisposedITAT Chandigarh28 Jun 2024AY 2019-2020

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

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT, DR
Section 115BSection 145(3)Section 153ASection 35ASection 69

…आयकर अपीलीय अिधकरण,च"डीगढ़ "यायपीठ “ए” , च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, 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 Nos.663, 668 & 679/Chd/2023 िनधा"रण वष" / Assessment Years : 2017-18, 2018-19 & 2019-20 Khanna Infrabuild Private Limited बनाम The DCIT 2000/1A, Sukhdev Nagar, Ferozepur Central Circle-2, Ludhiana Road, Ludhiana "थायी लेखा सं./PAN NO: AAFCK0050Q अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रती क" ओर से/Assessee by : Shri Sudhir Sehg…

Khanna Infrabuild Private Limited, Ludhiana vs. The Deputy Commissioner of Income Tax (Central Circle)-2, Ludhiana

In the result, the ground of appeal is allowed

ITA 668/CHANDI/2023[2018-2019]Status: DisposedITAT Chandigarh28 Jun 2024AY 2018-2019

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

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT, DR
Section 115BSection 145(3)Section 153ASection 35ASection 69

…आयकर अपीलीय अिधकरण,च"डीगढ़ "यायपीठ “ए” , च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, 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 Nos.663, 668 & 679/Chd/2023 िनधा"रण वष" / Assessment Years : 2017-18, 2018-19 & 2019-20 Khanna Infrabuild Private Limited बनाम The DCIT 2000/1A, Sukhdev Nagar, Ferozepur Central Circle-2, Ludhiana Road, Ludhiana "थायी लेखा सं./PAN NO: AAFCK0050Q अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रती क" ओर से/Assessee by : Shri Sudhir Sehg…

Khanna Infrabuild Private Limited, Ludhiana vs. The Deputy Commissioner of Income Tax (Central Circle)-2 Ludhiana, Ludhiana

In the result, the ground of appeal is allowed

ITA 663/CHANDI/2023[2017-2018]Status: DisposedITAT Chandigarh28 Jun 2024AY 2017-2018

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

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT, DR
Section 115BSection 145(3)Section 153ASection 35ASection 69

…आयकर अपीलीय अिधकरण,च"डीगढ़ "यायपीठ “ए” , च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, 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 Nos.663, 668 & 679/Chd/2023 िनधा"रण वष" / Assessment Years : 2017-18, 2018-19 & 2019-20 Khanna Infrabuild Private Limited बनाम The DCIT 2000/1A, Sukhdev Nagar, Ferozepur Central Circle-2, Ludhiana Road, Ludhiana "थायी लेखा सं./PAN NO: AAFCK0050Q अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रती क" ओर से/Assessee by : Shri Sudhir Sehg…

D' Decor Exports P. Ltd., Mumbai vs. Dy CIT-CC-6(4), Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 1057/MUM/2021[2015-16]Status: DisposedITAT Mumbai22 Apr 2022AY 2015-16

Bench: Shri Amarjit Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Jitendra JainFor Respondent: Shri Sanjeev Kashyap
Section 127(2)Section 143(1)Section 143(2)Section 153A

…the CIT(A)}— Specific bank transactions referred to by the AO have not been cross verified with the exact amounts shown as investments in the documents seized from A Group— Addition rightly deleted by Tribunal” (iii) CIT vs Concorde Capital Management Co Ltd [334 ITR 346] “Search and Seizure—Block assessment in search cases—No incriminating material found during search— Addition towards undisclosed income on the basis of statement of a third party not sustainable” (iv) DCIT vs Mahendra Ambalal Patel [40 DTR 243 Guj] “Income from undisclosed sources—Addition—Validity— Addition made towards sale of land based on th…

D' Decor Exports P.L Td, Mumbai vs. Dy CIT-CC-6(4), Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 1056/MUM/2021[2016-17]Status: DisposedITAT Mumbai22 Apr 2022AY 2016-17

Bench: Shri Amarjit Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Jitendra JainFor Respondent: Shri Sanjeev Kashyap
Section 127(2)Section 143(1)Section 143(2)Section 153A

…the CIT(A)}— Specific bank transactions referred to by the AO have not been cross verified with the exact amounts shown as investments in the documents seized from A Group— Addition rightly deleted by Tribunal” (iii) CIT vs Concorde Capital Management Co Ltd [334 ITR 346] “Search and Seizure—Block assessment in search cases—No incriminating material found during search— Addition towards undisclosed income on the basis of statement of a third party not sustainable” (iv) DCIT vs Mahendra Ambalal Patel [40 DTR 243 Guj] “Income from undisclosed sources—Addition—Validity— Addition made towards sale of land based on th…

D' Decor Exports P. Ltd., Mumbai vs. Dy CIT-CC-6(4), Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 1055/MUM/2021[2017-18]Status: DisposedITAT Mumbai22 Apr 2022AY 2017-18

Bench: Shri Amarjit Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Jitendra JainFor Respondent: Shri Sanjeev Kashyap
Section 127(2)Section 143(1)Section 143(2)Section 153A

…the CIT(A)}— Specific bank transactions referred to by the AO have not been cross verified with the exact amounts shown as investments in the documents seized from A Group— Addition rightly deleted by Tribunal” (iii) CIT vs Concorde Capital Management Co Ltd [334 ITR 346] “Search and Seizure—Block assessment in search cases—No incriminating material found during search— Addition towards undisclosed income on the basis of statement of a third party not sustainable” (iv) DCIT vs Mahendra Ambalal Patel [40 DTR 243 Guj] “Income from undisclosed sources—Addition—Validity— Addition made towards sale of land based on th…

D' Decor Exports P. Ltd., Mumbai vs. Dy CIT-CC-6(4), Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 1053/MUM/2021[2012-13]Status: DisposedITAT Mumbai22 Apr 2022AY 2012-13

Bench: Shri Amarjit Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Jitendra JainFor Respondent: Shri Sanjeev Kashyap
Section 127(2)Section 143(1)Section 143(2)Section 153A

…the CIT(A)}— Specific bank transactions referred to by the AO have not been cross verified with the exact amounts shown as investments in the documents seized from A Group— Addition rightly deleted by Tribunal” (iii) CIT vs Concorde Capital Management Co Ltd [334 ITR 346] “Search and Seizure—Block assessment in search cases—No incriminating material found during search— Addition towards undisclosed income on the basis of statement of a third party not sustainable” (iv) DCIT vs Mahendra Ambalal Patel [40 DTR 243 Guj] “Income from undisclosed sources—Addition—Validity— Addition made towards sale of land based on th…

D' Decor Exports P. Ltd, Mumbai vs. Dy CIT-CC-6(4_, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 1052/MUM/2021[2013-14]Status: DisposedITAT Mumbai22 Apr 2022AY 2013-14

Bench: Shri Amarjit Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Jitendra JainFor Respondent: Shri Sanjeev Kashyap
Section 127(2)Section 143(1)Section 143(2)Section 153A

…the CIT(A)}— Specific bank transactions referred to by the AO have not been cross verified with the exact amounts shown as investments in the documents seized from A Group— Addition rightly deleted by Tribunal” (iii) CIT vs Concorde Capital Management Co Ltd [334 ITR 346] “Search and Seizure—Block assessment in search cases—No incriminating material found during search— Addition towards undisclosed income on the basis of statement of a third party not sustainable” (iv) DCIT vs Mahendra Ambalal Patel [40 DTR 243 Guj] “Income from undisclosed sources—Addition—Validity— Addition made towards sale of land based on th…

D, Decor Exporter, Mumbai vs. Dy CIT-CC-6(4), Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 1051/MUM/2021[2014-15]Status: DisposedITAT Mumbai22 Apr 2022AY 2014-15

Bench: Shri Amarjit Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Jitendra JainFor Respondent: Shri Sanjeev Kashyap
Section 127(2)Section 143(1)Section 143(2)Section 153A

…the CIT(A)}— Specific bank transactions referred to by the AO have not been cross verified with the exact amounts shown as investments in the documents seized from A Group— Addition rightly deleted by Tribunal” (iii) CIT vs Concorde Capital Management Co Ltd [334 ITR 346] “Search and Seizure—Block assessment in search cases—No incriminating material found during search— Addition towards undisclosed income on the basis of statement of a third party not sustainable” (iv) DCIT vs Mahendra Ambalal Patel [40 DTR 243 Guj] “Income from undisclosed sources—Addition—Validity— Addition made towards sale of land based on th…

D, Decor Exporter P. Ltd, Mumbai vs. Dy CIT-CC-6(4), Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 1050/MUM/2021[2014-15]Status: DisposedITAT Mumbai22 Apr 2022AY 2014-15

Bench: Shri Amarjit Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Jitendra JainFor Respondent: Shri Sanjeev Kashyap
Section 127(2)Section 143(1)Section 143(2)Section 153A

…the CIT(A)}— Specific bank transactions referred to by the AO have not been cross verified with the exact amounts shown as investments in the documents seized from A Group— Addition rightly deleted by Tribunal” (iii) CIT vs Concorde Capital Management Co Ltd [334 ITR 346] “Search and Seizure—Block assessment in search cases—No incriminating material found during search— Addition towards undisclosed income on the basis of statement of a third party not sustainable” (iv) DCIT vs Mahendra Ambalal Patel [40 DTR 243 Guj] “Income from undisclosed sources—Addition—Validity— Addition made towards sale of land based on th…

M/S.Killi Constructions, Trivandrum vs. The DCIT, Trivandrum

In the result, the appeals filed by the Revenue, the appeal filed by the

ITA 369/COCH/2016[2005-06]Status: DisposedITAT Cochin29 Jan 2018AY 2005-06

Bench: S/Shri Chandra Poojari , Am & George George K., Jm

Section 68

….14/C/2017 6. Both the deed of agreement and confirmation letter are not verifiable as Mr. Subir Khan is no more and died in August, 2009 itself. 7. The decision of Hon’ble Delhi High Court in the case of CIT vs. Concorde Capital Management Company Limited (334 ITR 346) relied on by the appellant is totally misquoted since no addition was made based on third party statement but on the balance sheet signed by the managing partner. 4.3 In view of the above mentioned reasons, the addition made on account of unexplained credit is hereby confirmed and appeal on this ground is therefore dismissed.” 4. Against the d…

The ACIT, Trivandrum vs. M/S. Killi Constructions, Trivandrum

In the result, the appeals filed by the Revenue, the appeal filed by the

ITA 299/COCH/2016[2007-08]Status: DisposedITAT Cochin29 Jan 2018AY 2007-08

Bench: S/Shri Chandra Poojari , Am & George George K., Jm

Section 68

….14/C/2017 6. Both the deed of agreement and confirmation letter are not verifiable as Mr. Subir Khan is no more and died in August, 2009 itself. 7. The decision of Hon’ble Delhi High Court in the case of CIT vs. Concorde Capital Management Company Limited (334 ITR 346) relied on by the appellant is totally misquoted since no addition was made based on third party statement but on the balance sheet signed by the managing partner. 4.3 In view of the above mentioned reasons, the addition made on account of unexplained credit is hereby confirmed and appeal on this ground is therefore dismissed.” 4. Against the d…

The ACIT, Trivandrum vs. M/S. Killi Constructions, Trivandrum

In the result, the appeals filed by the Revenue, the appeal filed by the

ITA 298/COCH/2016[2006-07]Status: DisposedITAT Cochin29 Jan 2018AY 2006-07

Bench: S/Shri Chandra Poojari , Am & George George K., Jm

Section 68

….14/C/2017 6. Both the deed of agreement and confirmation letter are not verifiable as Mr. Subir Khan is no more and died in August, 2009 itself. 7. The decision of Hon’ble Delhi High Court in the case of CIT vs. Concorde Capital Management Company Limited (334 ITR 346) relied on by the appellant is totally misquoted since no addition was made based on third party statement but on the balance sheet signed by the managing partner. 4.3 In view of the above mentioned reasons, the addition made on account of unexplained credit is hereby confirmed and appeal on this ground is therefore dismissed.” 4. Against the d…

Heeralal Meghraj Doshi, Mumbai vs. Asst CIT 18(2), Mumbai

In the result, the appeals filed by the revenue are dismissed

ITA 3015/MUM/2015[2009-10]Status: DisposedITAT Mumbai15 Feb 2017AY 2009-10

Bench: Shri B.R. Baskaran (Am) & Shri Amit Shukla (Jm)

Section 133(6)Section 143(1)Section 143(3)

…he same is required to be deleted on the ground of violation of the principles of natural justice. (y) The appellant further submits that no addition could be made relying upon the third party statement as held in- CIT v. Concord Capital Management Co. Ltd. 334 ITR 346 (Del) Dr. R.L. Narang 174 Taxman 96 (Chd)(Mag) 12 M/s. Heeralal Meghraj Doshi (z) In view of the above, the appellant submits that the disallowance out of purchases of Rs,2,35,04,632/- is without any justification and liable to be deleted. Without prejudice to above, the appellant submits that similar disallowance of purchases has been in the…