Jyotibhaichand Bhaichand Saraf & Sons (P) Ltd. v. DCIT

139 ITD 10Income Tax Appellate Tribunal2012#3251 most cited

What is Jyotibhaichand Bhaichand Saraf & Sons (P) Ltd. v. DCIT authority for?

Admissions made under section 132(4) during search proceedings are not conclusive and can be retracted by the assessee if a mistaken belief of fact or law is shown.

36

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2026.

Also referred to as

Jyotibhaichand Bhaichand Saraf & Sons (P) Ltd. v. DCIT · 139 ITD 10 · section 132(4) · admission during search · retraction of statement · mistaken belief · onus of proof · search and seizure

Sections most often in play

Section 143(3)Section 153ASection 153CSection 69CSection 132Section 147Section 148Section 153D

Issues it is cited on

section 132(5)section 100section 153(c)(1)section 94abatement of assessmentanonymous donationsection 153(c)section 164third party informationonus of proofincome tax settlement commissionsection 31

Judgments citing Jyotibhaichand Bhaichand Saraf & Sons (P) Ltd. v. DCIT

DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. APOORVA SAROVAR, KURNOOL

In the result, appeal of the Revenue is dismissed

ITA 181/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam17 Apr 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Omkareshwar Chidaraआ.अपी.सं /Ita No.181/Viz./2025 Assessment Year 2018-2019 The Dcit, Apoorva Sarovar, Central Circle-2, Vs. Kurnool – 518 004. Guntur – 522 004. State Of Andhra Pradesh. State Of Andhra Pradesh. Pan Abefa4123B (Appellant) (Respondent) For Assessee : Sri C Subrahmanyam, Ca For Revenue : Sri Badicala Yadagiri, Cit-Dr Date Of Hearing : 18.03.2026 Date Of Pronouncement : 17.04.2026 आदेश/Order Per Vijay Pal Rao, V.P. :

For Appellant: Sri C Subrahmanyam, CAFor Respondent: Sri Badicala Yadagiri, CIT-DR
Section 133A

…IN THE INCOME TAX APPELLATE TRIBUNAL VISAKHAPATNAM “DB” BENCH : VISAKHAPATNAM AT HYDERABAD BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI OMKARESHWAR CHIDARA, ACCOUNTANT MEMBER आ.अपी.सं /ITA No.181/VIZ./2025 Assessment Year 2018-2019 The DCIT, Apoorva Sarovar, Central Circle-2, vs. KURNOOL – 518 004. GUNTUR – 522 004. State of Andhra Pradesh. State of Andhra Pradesh. PAN ABEFA4123B (Appellant) (Respondent) For Assessee : Sri C Subrahmanyam, CA For Revenue : Sri Badicala Yadagiri, CIT-DR Date of Hearing : 18.03.2026 Date of Pronouncement : 17.04.2026 आदेश/ORDER PER VIJAY PAL RAO, V.P. : This appeal by the…

DCIT CENT, CIRCLE 1(3), NAGPUR vs. RADHIKA VEGETABLE OILS PVT LIMITED, VIZIANAGARAM

In the result, appeal filed by the Revenue is dismissed

ITA 17/NAG/2024[2019-20]Status: DisposedITAT Nagpur27 Jan 2025AY 2019-20

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mukesh AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 115BSection 132Section 143(3)Section 147Section 148Section 40A(3)Section 69A

…vt. Ltd., ITA no.290/Ahd./2012 and ITA no.3187/Ahd./2011, order dated 17/05/2017; g) ITO v/s Saikrupa Construction Co., [2007] 13 SOT 459 (Mum. ITAT); h) CIT v/s Hariram Bhambhani, [2015] 92 CCH 46 (Bom.); and i) JyotibhaichandBhaichand Saraf v/s DCIT, [2012] 139 ITD 10 (Pune ITAT). We have gone through order of the learned CIT(A) as well as judgment cited by the assessee supporting the case of the assessee. We find that the Assessing Officer has held that the entire undisclosed sales is undisclosed income of the assessee. The learned Departmental Representative strongly argued by relying upon the order of the As…

DCIT, CC-1(3), NAGPUR, NAGPUR vs. RADHIKA VEGETABLES OILS PVT. LTD., VIZIANAGRAM

In the result, appeal filed by the assessee is partly allowed

ITA 236/NAG/2023[2021-22]Status: DisposedITAT Nagpur25 Oct 2024AY 2021-22

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Sandipkumar Salunke
Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 69A

…Ltd., ITA no.290/Ahd./2012 and ITA no.3187/Ahd./2011, order dated 17/05/2017; vii) ITO v/s Saikrupa Construction Co., [2007] 13 SOT 459 (Mum. ITAT); viii) CIT v/s Hariram Bhambhani, [2015] 92 CCH 46 (Bom.); ix) Jyotibhaichand Bhaichand Saraf v/s DCIT, [2012] 139 ITD 10 (Pune ITAT). 9. We have gone through order of the learned CIT(A) as well as judgment cited by the assessee supporting the case of the assessee. We find that the Assessing Officer has held that the entire undisclosed sales is undisclosed income of the assessee. The learned Departmental Representative strongly argued by relying upon the order of th…

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

ITA 2938/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Aug 2024AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…ven on the search day, then the court or Tribunal should try to ascertain the reasons or circumstances from such person for doing so and, if satisfied, not to place heavy reliance on such earlier statement which has subsequently been denied and retracted. xi) 139 ITD 10 (Pune) Jyotichand Bhaichand Saraf & Sons (P) Ltd. vs. DCIT Section 132 of the Income-tax Act, 1961 - Search and Seizure - Whether admission made under section 132(4), though important piece of evidence, is not conclusive - Held, yes - Whether assessee can retract from it showing that it was made under mistaken belief of fact or law - Held, yes [Pa…

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

ITA 2937/DEL/2023[2016-17]Status: DisposedITAT Delhi30 Aug 2024AY 2016-17

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…ven on the search day, then the court or Tribunal should try to ascertain the reasons or circumstances from such person for doing so and, if satisfied, not to place heavy reliance on such earlier statement which has subsequently been denied and retracted. xi) 139 ITD 10 (Pune) Jyotichand Bhaichand Saraf & Sons (P) Ltd. vs. DCIT Section 132 of the Income-tax Act, 1961 - Search and Seizure - Whether admission made under section 132(4), though important piece of evidence, is not conclusive - Held, yes - Whether assessee can retract from it showing that it was made under mistaken belief of fact or law - Held, yes [Pa…

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

ITA 2936/DEL/2023[2015-16]Status: DisposedITAT Delhi30 Aug 2024AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…ven on the search day, then the court or Tribunal should try to ascertain the reasons or circumstances from such person for doing so and, if satisfied, not to place heavy reliance on such earlier statement which has subsequently been denied and retracted. xi) 139 ITD 10 (Pune) Jyotichand Bhaichand Saraf & Sons (P) Ltd. vs. DCIT Section 132 of the Income-tax Act, 1961 - Search and Seizure - Whether admission made under section 132(4), though important piece of evidence, is not conclusive - Held, yes - Whether assessee can retract from it showing that it was made under mistaken belief of fact or law - Held, yes [Pa…

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

ITA 2935/DEL/2023[2014-15]Status: DisposedITAT Delhi30 Aug 2024AY 2014-15

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…ven on the search day, then the court or Tribunal should try to ascertain the reasons or circumstances from such person for doing so and, if satisfied, not to place heavy reliance on such earlier statement which has subsequently been denied and retracted. xi) 139 ITD 10 (Pune) Jyotichand Bhaichand Saraf & Sons (P) Ltd. vs. DCIT Section 132 of the Income-tax Act, 1961 - Search and Seizure - Whether admission made under section 132(4), though important piece of evidence, is not conclusive - Held, yes - Whether assessee can retract from it showing that it was made under mistaken belief of fact or law - Held, yes [Pa…

INCOME TAX OFFICER, WARD-2(1), VIJAYAWADA vs. AJAY ELECTRONICS, VIJAYAWADA

In the result, appeal of the Revenue is partly allowed

ITA 272/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam22 Dec 2023AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri GVN Hari, ARFor Respondent: Sri Madhukar Aves, Sr. AR
Section 132Section 142(1)Section 143(1)Section 143(3)Section 69A

…ion of sale. Similar view was taken in the case of CIT vs. Gurubachhan Singh J. Juneja [215 CTR 509] (Gujarat HC) and CIT vs. Sharada Real Estate (P) Ltd., [99 DTR 100] (MP- HC) and in the case of Jyotibhaichand Bhaichand Saraf & Sons 8 (P) Ltd., vs. DCIT [139 ITD 10] the Coordinate Bench at Pune has confirmed the addition could only be made only to an extent of gross profit earned on an unaccounted/suppressed sales and not on the entire sales itself. Similar view was taken in the case of ACIT vs. M/s. Archana Trading Co., in ITA Nos. 351 & 352/Coch/2011, dated 28/02/2013 and also ACIT vs. Pahal Food [IT(SS)…

YUGAANDHAR HOUSING PVT LTD,VIJAYAWADA vs. ACIT, CENTRAL CERCLE, VIJAYAWADA

In the result, all the six appeals of the assessee are allowed

ITA 88/VIZ/2022[2018-2019]Status: DisposedITAT Visakhapatnam30 Aug 2022AY 2018-2019

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri MV Prasad, CAFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 132(4)Section 143(3)

…iguration of sale. Similar view was taken in the case of CIT vs. Gurubachhan Singh J. Juneja [215 CTR 509] (Gujarat HC) and CIT vs. Sharada Real Estate (P) Ltd., [99 DTR 100] (MP-HC) and in the case of Jyotibhaichand Bhaichand Saraf & Sons (P) Ltd., vs. DCIT [139 ITD 10] the Coordinate Bench at Pune has confirmed the addition could only be made only to an extent of gross profit earned on an unaccounted/suppressed sales and not on the entire sales itself. Similar view was taken in the case of ACIT vs. M/s. Archana Trading Co., in ITA Nos. 351 & 352/Coch/2011, dated 28/02/2013 and also ACIT vs. Pahal Food [IT(SS)A…

YUGAANDHAR HOUSING PVT LTD,VIJAYAWADA vs. ACIT, CENTRAL CERCLE, VIJAYAWADA

In the result, all the six appeals of the assessee are allowed

ITA 87/VIZ/2022[2016-2017]Status: DisposedITAT Visakhapatnam30 Aug 2022AY 2016-2017

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri MV Prasad, CAFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 132(4)Section 143(3)

…iguration of sale. Similar view was taken in the case of CIT vs. Gurubachhan Singh J. Juneja [215 CTR 509] (Gujarat HC) and CIT vs. Sharada Real Estate (P) Ltd., [99 DTR 100] (MP-HC) and in the case of Jyotibhaichand Bhaichand Saraf & Sons (P) Ltd., vs. DCIT [139 ITD 10] the Coordinate Bench at Pune has confirmed the addition could only be made only to an extent of gross profit earned on an unaccounted/suppressed sales and not on the entire sales itself. Similar view was taken in the case of ACIT vs. M/s. Archana Trading Co., in ITA Nos. 351 & 352/Coch/2011, dated 28/02/2013 and also ACIT vs. Pahal Food [IT(SS)A…

YUGAANDHAR HOUSING PVT LTD,VIJAYAWADA vs. ACIT, CENTRAL CERCLE, VIJAYAWADA

In the result, all the six appeals of the assessee are allowed

ITA 86/VIZ/2022[2015-2016]Status: DisposedITAT Visakhapatnam30 Aug 2022AY 2015-2016

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri MV Prasad, CAFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 132(4)Section 143(3)

…iguration of sale. Similar view was taken in the case of CIT vs. Gurubachhan Singh J. Juneja [215 CTR 509] (Gujarat HC) and CIT vs. Sharada Real Estate (P) Ltd., [99 DTR 100] (MP-HC) and in the case of Jyotibhaichand Bhaichand Saraf & Sons (P) Ltd., vs. DCIT [139 ITD 10] the Coordinate Bench at Pune has confirmed the addition could only be made only to an extent of gross profit earned on an unaccounted/suppressed sales and not on the entire sales itself. Similar view was taken in the case of ACIT vs. M/s. Archana Trading Co., in ITA Nos. 351 & 352/Coch/2011, dated 28/02/2013 and also ACIT vs. Pahal Food [IT(SS)A…

YUGAANDHAR HOUSING PVT LTD,VIJAYAWADA vs. ACIT, CENTRAL CERCLE, VIJAYAWADA

In the result, all the six appeals of the assessee are allowed

ITA 85/VIZ/2022[2014-2015]Status: DisposedITAT Visakhapatnam30 Aug 2022AY 2014-2015

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri MV Prasad, CAFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 132(4)Section 143(3)

…iguration of sale. Similar view was taken in the case of CIT vs. Gurubachhan Singh J. Juneja [215 CTR 509] (Gujarat HC) and CIT vs. Sharada Real Estate (P) Ltd., [99 DTR 100] (MP-HC) and in the case of Jyotibhaichand Bhaichand Saraf & Sons (P) Ltd., vs. DCIT [139 ITD 10] the Coordinate Bench at Pune has confirmed the addition could only be made only to an extent of gross profit earned on an unaccounted/suppressed sales and not on the entire sales itself. Similar view was taken in the case of ACIT vs. M/s. Archana Trading Co., in ITA Nos. 351 & 352/Coch/2011, dated 28/02/2013 and also ACIT vs. Pahal Food [IT(SS)A…

YUGAANDHAR HOUSING PVT LTD,VIJAYAWADA vs. ACIT, CENTRAL CERCLE, VIJAYAWADA

In the result, all the six appeals of the assessee are allowed

ITA 84/VIZ/2022[2013-2014]Status: DisposedITAT Visakhapatnam30 Aug 2022AY 2013-2014

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri MV Prasad, CAFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 132(4)Section 143(3)

…iguration of sale. Similar view was taken in the case of CIT vs. Gurubachhan Singh J. Juneja [215 CTR 509] (Gujarat HC) and CIT vs. Sharada Real Estate (P) Ltd., [99 DTR 100] (MP-HC) and in the case of Jyotibhaichand Bhaichand Saraf & Sons (P) Ltd., vs. DCIT [139 ITD 10] the Coordinate Bench at Pune has confirmed the addition could only be made only to an extent of gross profit earned on an unaccounted/suppressed sales and not on the entire sales itself. Similar view was taken in the case of ACIT vs. M/s. Archana Trading Co., in ITA Nos. 351 & 352/Coch/2011, dated 28/02/2013 and also ACIT vs. Pahal Food [IT(SS)A…

YUGAANDHAR HOUSING PVT LTD,VIJAYAWADA vs. ACIT, CENTRAL CERCLE, VIJAYAWADA

In the result, all the six appeals of the assessee are allowed

ITA 83/VIZ/2022[2012-2013]Status: DisposedITAT Visakhapatnam30 Aug 2022AY 2012-2013

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri MV Prasad, CAFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 132(4)Section 143(3)

…iguration of sale. Similar view was taken in the case of CIT vs. Gurubachhan Singh J. Juneja [215 CTR 509] (Gujarat HC) and CIT vs. Sharada Real Estate (P) Ltd., [99 DTR 100] (MP-HC) and in the case of Jyotibhaichand Bhaichand Saraf & Sons (P) Ltd., vs. DCIT [139 ITD 10] the Coordinate Bench at Pune has confirmed the addition could only be made only to an extent of gross profit earned on an unaccounted/suppressed sales and not on the entire sales itself. Similar view was taken in the case of ACIT vs. M/s. Archana Trading Co., in ITA Nos. 351 & 352/Coch/2011, dated 28/02/2013 and also ACIT vs. Pahal Food [IT(SS)A…

DAMODAR REDDY KAITI ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of the assessee in ITA

ITA 1631/HYD/2018[2014-15]Status: DisposedITAT Hyderabad18 Jul 2022AY 2014-15

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Sri K.A. Sai Prasad, C.AFor Respondent: Sri K.P.R. Murthy
Section 132Section 143(3)Section 153ASection 44A

…ration of sales. Similar view was taken in the case of CIT Vs. Gurubachhan Singh J. Juneja [215 CTR 509] (Gujarat-High Court) and CIT Vs. Sharda Real Estate (P.) Ltd., [99 DTR 100] (MP-HC). In the case of Jyotichand Bhaichand Saraf & Sons (P.) Ltd., Vs. DCIT [139 ITD 10] the Co-ordinate Bench at Pune has confirmed that the addition could only be made only to an extent of gross profit earned on an unaccounted / suppress sales and not on the entire sales itself. Similar view was also taken in the case of ACIT, Cir1 Vs. M/s. Archana Trading Co in ITA No. 351 & 352/Coch/2011, dt. 28-02-2013 and also ACIT Vs. Pahal Fo…

DAMODAR REDDY KAITI ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of the assessee in ITA

ITA 1630/HYD/2018[2013-14]Status: DisposedITAT Hyderabad18 Jul 2022AY 2013-14

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Sri K.A. Sai Prasad, C.AFor Respondent: Sri K.P.R. Murthy
Section 132Section 143(3)Section 153ASection 44A

…ration of sales. Similar view was taken in the case of CIT Vs. Gurubachhan Singh J. Juneja [215 CTR 509] (Gujarat-High Court) and CIT Vs. Sharda Real Estate (P.) Ltd., [99 DTR 100] (MP-HC). In the case of Jyotichand Bhaichand Saraf & Sons (P.) Ltd., Vs. DCIT [139 ITD 10] the Co-ordinate Bench at Pune has confirmed that the addition could only be made only to an extent of gross profit earned on an unaccounted / suppress sales and not on the entire sales itself. Similar view was also taken in the case of ACIT, Cir1 Vs. M/s. Archana Trading Co in ITA No. 351 & 352/Coch/2011, dt. 28-02-2013 and also ACIT Vs. Pahal Fo…

DEPUTY COMMISSIONER OF INCOME-TAX vs. SHIKSHANA PRASARAKA MANDALI,, PUNE

In the result, the appeal of Revenue in ITA No

ITA 577/PUN/2016[2011-12]Status: DisposedITAT Pune24 Jun 2021AY 2011-12

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

For Appellant: Shri Dharmesh Shah, ARFor Respondent: Shri Deepak Garg, CIT-DR
Section 132(4)Section 143(2)Section 153C

…013-IT (Inv. II), dated 18.12.2014, CIT Vs. K. Bhuvanendran and Ors [303 ITR 235 (Mad.)], Aishwarya K. Rai Vs. DCIT [104 ITD 166 (Mum) (TM), PushpaVihar Vs. ACIT [48 TT] 389 (Mum)], Jyotichand A.Ys. 2005-06 to 2011-12 Bhaichand Saraf & Sons (P) Ltd Vs. DCIT [139 ITD 10 (Pune)], CIT Vs. Uttamchand Jain [320 ITR 554 (Bom.)]. He argued that the statement of the persons recorded by the search officers cannot be relied against the assessee. 17. Having heard both as to why retraction of statements recorded u/s. 132(4) of the Act is not valid, the contention of ld. DR is that the statement recorded u/s. 132(4) of the…

DEPUTY COMMISSIONER OF INCOME-TAX vs. SHIKSHANA PRASARAKA MANDALI,, PUNE

In the result, the appeal of Revenue in ITA No

ITA 576/PUN/2016[2010-11]Status: DisposedITAT Pune24 Jun 2021AY 2010-11

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

For Appellant: Shri Dharmesh Shah, ARFor Respondent: Shri Deepak Garg, CIT-DR
Section 132(4)Section 143(2)Section 153C

…013-IT (Inv. II), dated 18.12.2014, CIT Vs. K. Bhuvanendran and Ors [303 ITR 235 (Mad.)], Aishwarya K. Rai Vs. DCIT [104 ITD 166 (Mum) (TM), PushpaVihar Vs. ACIT [48 TT] 389 (Mum)], Jyotichand A.Ys. 2005-06 to 2011-12 Bhaichand Saraf & Sons (P) Ltd Vs. DCIT [139 ITD 10 (Pune)], CIT Vs. Uttamchand Jain [320 ITR 554 (Bom.)]. He argued that the statement of the persons recorded by the search officers cannot be relied against the assessee. 17. Having heard both as to why retraction of statements recorded u/s. 132(4) of the Act is not valid, the contention of ld. DR is that the statement recorded u/s. 132(4) of the…

DEPUTY COMMISSIONER OF INCOME-TAX vs. SHIKSHANA PRASARAKA MANDALI,, PUNE

In the result, the appeal of Revenue in ITA No

ITA 575/PUN/2016[2009-10]Status: DisposedITAT Pune24 Jun 2021AY 2009-10

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

For Appellant: Shri Dharmesh Shah, ARFor Respondent: Shri Deepak Garg, CIT-DR
Section 132(4)Section 143(2)Section 153C

…013-IT (Inv. II), dated 18.12.2014, CIT Vs. K. Bhuvanendran and Ors [303 ITR 235 (Mad.)], Aishwarya K. Rai Vs. DCIT [104 ITD 166 (Mum) (TM), PushpaVihar Vs. ACIT [48 TT] 389 (Mum)], Jyotichand A.Ys. 2005-06 to 2011-12 Bhaichand Saraf & Sons (P) Ltd Vs. DCIT [139 ITD 10 (Pune)], CIT Vs. Uttamchand Jain [320 ITR 554 (Bom.)]. He argued that the statement of the persons recorded by the search officers cannot be relied against the assessee. 17. Having heard both as to why retraction of statements recorded u/s. 132(4) of the Act is not valid, the contention of ld. DR is that the statement recorded u/s. 132(4) of the…

DEPUTY COMMISSIONER OF INCOME-TAX vs. SHIKSHANA PRASARAKA MANDALI,, PUNE

In the result, the appeal of Revenue in ITA No

ITA 574/PUN/2016[2008-09]Status: DisposedITAT Pune24 Jun 2021AY 2008-09

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

For Appellant: Shri Dharmesh Shah, ARFor Respondent: Shri Deepak Garg, CIT-DR
Section 132(4)Section 143(2)Section 153C

…013-IT (Inv. II), dated 18.12.2014, CIT Vs. K. Bhuvanendran and Ors [303 ITR 235 (Mad.)], Aishwarya K. Rai Vs. DCIT [104 ITD 166 (Mum) (TM), PushpaVihar Vs. ACIT [48 TT] 389 (Mum)], Jyotichand A.Ys. 2005-06 to 2011-12 Bhaichand Saraf & Sons (P) Ltd Vs. DCIT [139 ITD 10 (Pune)], CIT Vs. Uttamchand Jain [320 ITR 554 (Bom.)]. He argued that the statement of the persons recorded by the search officers cannot be relied against the assessee. 17. Having heard both as to why retraction of statements recorded u/s. 132(4) of the Act is not valid, the contention of ld. DR is that the statement recorded u/s. 132(4) of the…

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Jyotibhaichand Bhaichand Saraf & Sons (P) Ltd. v. DCIT (139 ITD 10) — Cited in 36 Judgments | BharatTax