Kishanchand Chellaram v. CIT

125 ITR 713Supreme Court of India1980#46 most cited

What is Kishanchand Chellaram v. CIT authority for?

An assessee is entitled to be confronted with evidence used against them and to an opportunity for cross-examination, especially when that evidence is from a third party or a retracted statement. Failure to provide such an opportunity violates the principles of natural justice.

962

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2013 to 2026.

Also referred to as

Kishanchand Chellaram v. CIT · 125 ITR 713 · natural justice · cross-examination · evidence · third party statement · retracted statement · opportunity to rebut · assessment proceedings

Sections most often in play

Section 143(3)Section 147Section 132Section 153ASection 153CSection 148Section 132(4)Section 69C

Issues it is cited on

section 158bbsection 292cretracted statementdumb documentssection 132(4a)on-moneyloose papersdocuments seizedlive linksection 34section 69bsection 292

Judgments citing Kishanchand Chellaram v. CIT

DCIT-3(1)(1), Mumbai, Aayakar Bhawan vs. Export Import Bank of India, Mumbai

In the result, all the appeals by the Revenue are dismissed

ITA 9461/MUM/2025[2005-06]Status: DisposedITAT Mumbai30 Mar 2026AY 2005-06

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailita No. 9460/Mum/2025 (Assessment Year: 1999-00) (Assessment Year: 2004-05) Ita No. 9457/Mum/2025 Ita No. 9461/Mum/2025 (Assessment Year: 2000-01) (Assessment Year: 2005-06) Ita No. 9462/Mum/2025 (Assessment Year: 2001-02) (Assessment Year: 2006-07) Deputy Commissioner Of Income Tax – 3(1)(1), Room No.607, 6Th Floor, Aayakar Bhawan, ............... Appellant Mumbai – 400020 V/S Export Import Bank Of India, Centre One Building, Floor 21, World Trade Centre Complex, ……………… Respondent Cuffe Parade, Mumbai – 400005 Pan : Aaace2769D

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri Ritesh Misra, CIT-DR
Section 115Section 2(22)Section 23(2)Section 237Section 250

…e of Smt. Mrudulaben B. Patel v. Asstt. CIT (2003) 85 ITD 463 (Ahd.) (SMC), the question was whether any part undisclosed income of a company received by director could be said to be income chargeable to tax. In the case of Kishanchand Chellaram v. CIT (1962) 46 ITR 640 (SC), the question was whether payment made as dividend by a company to its shareholders would lose the character of dividend merely because it was paid out of capital. In all these, there existed share capital of company as well as shareholders. Thus, the facts of those cases were entirely different from the present case inasmuch as in the presen…

DCIT-3(1)(1), Mumbai, Aayakar Bhawan vs. Export Import Bank of India, Mumbai

In the result, all the appeals by the Revenue are dismissed

ITA 9460/MUM/2025[2004-05]Status: DisposedITAT Mumbai30 Mar 2026AY 2004-05

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailita No. 9460/Mum/2025 (Assessment Year: 1999-00) (Assessment Year: 2004-05) Ita No. 9457/Mum/2025 Ita No. 9461/Mum/2025 (Assessment Year: 2000-01) (Assessment Year: 2005-06) Ita No. 9462/Mum/2025 (Assessment Year: 2001-02) (Assessment Year: 2006-07) Deputy Commissioner Of Income Tax – 3(1)(1), Room No.607, 6Th Floor, Aayakar Bhawan, ............... Appellant Mumbai – 400020 V/S Export Import Bank Of India, Centre One Building, Floor 21, World Trade Centre Complex, ……………… Respondent Cuffe Parade, Mumbai – 400005 Pan : Aaace2769D

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri Ritesh Misra, CIT-DR
Section 115Section 2(22)Section 23(2)Section 237Section 250

…e of Smt. Mrudulaben B. Patel v. Asstt. CIT (2003) 85 ITD 463 (Ahd.) (SMC), the question was whether any part undisclosed income of a company received by director could be said to be income chargeable to tax. In the case of Kishanchand Chellaram v. CIT (1962) 46 ITR 640 (SC), the question was whether payment made as dividend by a company to its shareholders would lose the character of dividend merely because it was paid out of capital. In all these, there existed share capital of company as well as shareholders. Thus, the facts of those cases were entirely different from the present case inasmuch as in the presen…

DCIT-3(1)(1), Mumbai, Aayakar Bhawan vs. Export Import Bank of India, Mumbai

In the result, all the appeals by the Revenue are dismissed

ITA 9459/MUM/2025[2003-04]Status: DisposedITAT Mumbai30 Mar 2026AY 2003-04

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailita No. 9460/Mum/2025 (Assessment Year: 1999-00) (Assessment Year: 2004-05) Ita No. 9457/Mum/2025 Ita No. 9461/Mum/2025 (Assessment Year: 2000-01) (Assessment Year: 2005-06) Ita No. 9462/Mum/2025 (Assessment Year: 2001-02) (Assessment Year: 2006-07) Deputy Commissioner Of Income Tax – 3(1)(1), Room No.607, 6Th Floor, Aayakar Bhawan, ............... Appellant Mumbai – 400020 V/S Export Import Bank Of India, Centre One Building, Floor 21, World Trade Centre Complex, ……………… Respondent Cuffe Parade, Mumbai – 400005 Pan : Aaace2769D

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri Ritesh Misra, CIT-DR
Section 115Section 2(22)Section 23(2)Section 237Section 250

…e of Smt. Mrudulaben B. Patel v. Asstt. CIT (2003) 85 ITD 463 (Ahd.) (SMC), the question was whether any part undisclosed income of a company received by director could be said to be income chargeable to tax. In the case of Kishanchand Chellaram v. CIT (1962) 46 ITR 640 (SC), the question was whether payment made as dividend by a company to its shareholders would lose the character of dividend merely because it was paid out of capital. In all these, there existed share capital of company as well as shareholders. Thus, the facts of those cases were entirely different from the present case inasmuch as in the presen…

DCIT-3(1)(1), Mumbai, Aayakar Bhawan vs. Export Import Bank of India, Mumbai

In the result, all the appeals by the Revenue are dismissed

ITA 9458/MUM/2025[2001-02]Status: DisposedITAT Mumbai30 Mar 2026AY 2001-02

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailita No. 9460/Mum/2025 (Assessment Year: 1999-00) (Assessment Year: 2004-05) Ita No. 9457/Mum/2025 Ita No. 9461/Mum/2025 (Assessment Year: 2000-01) (Assessment Year: 2005-06) Ita No. 9462/Mum/2025 (Assessment Year: 2001-02) (Assessment Year: 2006-07) Deputy Commissioner Of Income Tax – 3(1)(1), Room No.607, 6Th Floor, Aayakar Bhawan, ............... Appellant Mumbai – 400020 V/S Export Import Bank Of India, Centre One Building, Floor 21, World Trade Centre Complex, ……………… Respondent Cuffe Parade, Mumbai – 400005 Pan : Aaace2769D

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri Ritesh Misra, CIT-DR
Section 115Section 2(22)Section 23(2)Section 237Section 250

…e of Smt. Mrudulaben B. Patel v. Asstt. CIT (2003) 85 ITD 463 (Ahd.) (SMC), the question was whether any part undisclosed income of a company received by director could be said to be income chargeable to tax. In the case of Kishanchand Chellaram v. CIT (1962) 46 ITR 640 (SC), the question was whether payment made as dividend by a company to its shareholders would lose the character of dividend merely because it was paid out of capital. In all these, there existed share capital of company as well as shareholders. Thus, the facts of those cases were entirely different from the present case inasmuch as in the presen…

DCIT-3(1)(1), Mumbai, Aayakar Bhawan vs. Export Import Bank of India, Mumbai

In the result, all the appeals by the Revenue are dismissed

ITA 9457/MUM/2025[2000-01]Status: DisposedITAT Mumbai30 Mar 2026AY 2000-01

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailita No. 9460/Mum/2025 (Assessment Year: 1999-00) (Assessment Year: 2004-05) Ita No. 9457/Mum/2025 Ita No. 9461/Mum/2025 (Assessment Year: 2000-01) (Assessment Year: 2005-06) Ita No. 9462/Mum/2025 (Assessment Year: 2001-02) (Assessment Year: 2006-07) Deputy Commissioner Of Income Tax – 3(1)(1), Room No.607, 6Th Floor, Aayakar Bhawan, ............... Appellant Mumbai – 400020 V/S Export Import Bank Of India, Centre One Building, Floor 21, World Trade Centre Complex, ……………… Respondent Cuffe Parade, Mumbai – 400005 Pan : Aaace2769D

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri Ritesh Misra, CIT-DR
Section 115Section 2(22)Section 23(2)Section 237Section 250

…e of Smt. Mrudulaben B. Patel v. Asstt. CIT (2003) 85 ITD 463 (Ahd.) (SMC), the question was whether any part undisclosed income of a company received by director could be said to be income chargeable to tax. In the case of Kishanchand Chellaram v. CIT (1962) 46 ITR 640 (SC), the question was whether payment made as dividend by a company to its shareholders would lose the character of dividend merely because it was paid out of capital. In all these, there existed share capital of company as well as shareholders. Thus, the facts of those cases were entirely different from the present case inasmuch as in the presen…

DCIT-3(1)(1), Mumbai, Aayakar Bhawan vs. Export Import Bank of India, Mumbai

In the result, all the appeals by the Revenue are dismissed

ITA 9456/MUM/2025[1999-2000]Status: DisposedITAT Mumbai30 Mar 2026AY 1999-2000

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailita No. 9460/Mum/2025 (Assessment Year: 1999-00) (Assessment Year: 2004-05) Ita No. 9457/Mum/2025 Ita No. 9461/Mum/2025 (Assessment Year: 2000-01) (Assessment Year: 2005-06) Ita No. 9462/Mum/2025 (Assessment Year: 2001-02) (Assessment Year: 2006-07) Deputy Commissioner Of Income Tax – 3(1)(1), Room No.607, 6Th Floor, Aayakar Bhawan, ............... Appellant Mumbai – 400020 V/S Export Import Bank Of India, Centre One Building, Floor 21, World Trade Centre Complex, ……………… Respondent Cuffe Parade, Mumbai – 400005 Pan : Aaace2769D

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri Ritesh Misra, CIT-DR
Section 115Section 2(22)Section 23(2)Section 237Section 250

…e of Smt. Mrudulaben B. Patel v. Asstt. CIT (2003) 85 ITD 463 (Ahd.) (SMC), the question was whether any part undisclosed income of a company received by director could be said to be income chargeable to tax. In the case of Kishanchand Chellaram v. CIT (1962) 46 ITR 640 (SC), the question was whether payment made as dividend by a company to its shareholders would lose the character of dividend merely because it was paid out of capital. In all these, there existed share capital of company as well as shareholders. Thus, the facts of those cases were entirely different from the present case inasmuch as in the presen…

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

…आयकर अपीलीय न्यायाधिकरण में, हैदराबाद ‘बी’ बेंच, हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad “B” Bench, Hyderabad श्री विजय पाल राि, माननीय उपाध्यक्ष एिं श्री मंजूनाथ जी, माननीय लेखा सदस्य SHRI VIJAY PAL RAO, HON’BLE VICE PRESIDENT AND SHRI MANJUNATHA G, HON’BLE ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A.Nos.484 to 486/Hyd/2025 (निर्धारण वर्ा/ Assessment Years: 2018-19 to 2020-21) Expressway Services Pvt. Vs. The Deputy Commissioner of Ltd., Income Tax, Hyderabad. Central Circle – 2(4), Hyderabad. PAN : AACCE9241Q. (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ : Shri K.C. Devdas,…

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

…आयकर अपीलीय न्यायाधिकरण में, हैदराबाद ‘बी’ बेंच, हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad “B” Bench, Hyderabad श्री विजय पाल राि, माननीय उपाध्यक्ष एिं श्री मंजूनाथ जी, माननीय लेखा सदस्य SHRI VIJAY PAL RAO, HON’BLE VICE PRESIDENT AND SHRI MANJUNATHA G, HON’BLE ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A.Nos.484 to 486/Hyd/2025 (निर्धारण वर्ा/ Assessment Years: 2018-19 to 2020-21) Expressway Services Pvt. Vs. The Deputy Commissioner of Ltd., Income Tax, Hyderabad. Central Circle – 2(4), Hyderabad. PAN : AACCE9241Q. (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ : Shri K.C. Devdas,…

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

…आयकर अपीलीय न्यायाधिकरण में, हैदराबाद ‘बी’ बेंच, हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad “B” Bench, Hyderabad श्री विजय पाल राि, माननीय उपाध्यक्ष एिं श्री मंजूनाथ जी, माननीय लेखा सदस्य SHRI VIJAY PAL RAO, HON’BLE VICE PRESIDENT AND SHRI MANJUNATHA G, HON’BLE ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A.Nos.484 to 486/Hyd/2025 (निर्धारण वर्ा/ Assessment Years: 2018-19 to 2020-21) Expressway Services Pvt. Vs. The Deputy Commissioner of Ltd., Income Tax, Hyderabad. Central Circle – 2(4), Hyderabad. PAN : AACCE9241Q. (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ : Shri K.C. Devdas,…

Hariram Jagaji Chaudhary, Mumbai vs. DCIT, Central Circle 4(2), Mumbai

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

ITA 8343/MUM/2025[2021-22]Status: DisposedITAT Mumbai27 Mar 2026AY 2021-22

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Bharat KumarFor Respondent: Mr. Ritesh Misra, CIT. DR
Section 132

…m requirement of fairness when used against an assessee. The Hon’ble Supreme Court in Kishinchand Chellaram against an assessee. The Hon’ble Supreme Court in Kishinchand Chellaram against an assessee. The Hon’ble Supreme Court in Kishinchand Chellaram v. CIT (125 ITR 713) has unequivocally held that any material collected 25 ITR 713) has unequivocally held that any material collected 25 ITR 713) has unequivocally held that any material collected behind the back of the assessee, if proposed to be used against him, must be behind the back of the assessee, if proposed to be used against him, must be behind the back…

Hariram Jagaji Chaudhary, Mumbai vs. DCIT, Circle 4(2), Mumbai

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

ITA 8342/MUM/2025[2019-20]Status: DisposedITAT Mumbai27 Mar 2026AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Bharat KumarFor Respondent: Mr. Ritesh Misra, CIT. DR
Section 132

…m requirement of fairness when used against an assessee. The Hon’ble Supreme Court in Kishinchand Chellaram against an assessee. The Hon’ble Supreme Court in Kishinchand Chellaram against an assessee. The Hon’ble Supreme Court in Kishinchand Chellaram v. CIT (125 ITR 713) has unequivocally held that any material collected 25 ITR 713) has unequivocally held that any material collected 25 ITR 713) has unequivocally held that any material collected behind the back of the assessee, if proposed to be used against him, must be behind the back of the assessee, if proposed to be used against him, must be behind the back…

Hariram Jagaji Chaudhary, Mumbai vs. DCIT, Central Circle 4(2), Mumbai

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

ITA 8341/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Bharat KumarFor Respondent: Mr. Ritesh Misra, CIT. DR
Section 132

…m requirement of fairness when used against an assessee. The Hon’ble Supreme Court in Kishinchand Chellaram against an assessee. The Hon’ble Supreme Court in Kishinchand Chellaram against an assessee. The Hon’ble Supreme Court in Kishinchand Chellaram v. CIT (125 ITR 713) has unequivocally held that any material collected 25 ITR 713) has unequivocally held that any material collected 25 ITR 713) has unequivocally held that any material collected behind the back of the assessee, if proposed to be used against him, must be behind the back of the assessee, if proposed to be used against him, must be behind the back…

Hariram Jagaji Chaudhary, Mumbai vs. DCIT, Central Circle 4(2), Mumbai

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

ITA 8340/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Mar 2026AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Bharat KumarFor Respondent: Mr. Ritesh Misra, CIT. DR
Section 132

…m requirement of fairness when used against an assessee. The Hon’ble Supreme Court in Kishinchand Chellaram against an assessee. The Hon’ble Supreme Court in Kishinchand Chellaram against an assessee. The Hon’ble Supreme Court in Kishinchand Chellaram v. CIT (125 ITR 713) has unequivocally held that any material collected 25 ITR 713) has unequivocally held that any material collected 25 ITR 713) has unequivocally held that any material collected behind the back of the assessee, if proposed to be used against him, must be behind the back of the assessee, if proposed to be used against him, must be behind the back…

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7842/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

…nts: i) 303 ITR 95 (Del) CIT vs. Pradeep Kumar Gupta ii) 456 ITR 84 (Del) Pr. CIT vs. Prabhu Dayal Aggarwal iii) 418 ITR 315 (SC) CIT v. Odeon Builders (P) Ltd. 28 ITA-5515/Del/2025 & 13 others iv) 62 taxmann.com 3 (SC) Andaman Timber Industries vs. CCE v) 125 ITR 713 (SC) Kishnichand Chellaram vs. CIT vi) 288 ITR 345 (Del.) CIT vs. SMC Share Broker Limited vii) 293 ITR 43 (Del) CIT vs. S.M. Aggarwal 2.1 It was explained to the AO that transactions undertaken with these parties were duly recorded in the books of accounts of the appellant company, however, these parties while recording the statement has denied…

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7841/DEL/2025[2021-22]Status: DisposedITAT Delhi20 Mar 2026AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…n the following judicial pronouncements: i) 303 ITR 95 (Del) CIT vs. Pradeep Kumar Gupta ii) 456 ITR 84 (Del) Pr. CIT vs. Prabhu Dayal Aggarwal iii) 418 ITR 315 (SC) CIT v. Odeon Builders (P) Ltd. iv) 62 taxmann.com 3 (SC) Andaman Timber Industries vs. CCE v) 125 ITR 713 (SC) Kishnichand Chellaram vs. CIT vi) 288 ITR 345 (Del.) CIT vs. SMC Share Broker Limited vii) 293 ITR 43 (Del) CIT vs. S.M. Aggarwal 2.1 It was explained to the AO that transactions undertaken with these parties were duly recorded in the books of accounts of the appellant company, however, these parties while recording the statement has denied…

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7840/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

…nts: i) 303 ITR 95 (Del) CIT vs. Pradeep Kumar Gupta ii) 456 ITR 84 (Del) Pr. CIT vs. Prabhu Dayal Aggarwal iii) 418 ITR 315 (SC) CIT v. Odeon Builders (P) Ltd. 28 ITA-5515/Del/2025 & 13 others iv) 62 taxmann.com 3 (SC) Andaman Timber Industries vs. CCE v) 125 ITR 713 (SC) Kishnichand Chellaram vs. CIT vi) 288 ITR 345 (Del.) CIT vs. SMC Share Broker Limited vii) 293 ITR 43 (Del) CIT vs. S.M. Aggarwal 2.1 It was explained to the AO that transactions undertaken with these parties were duly recorded in the books of accounts of the appellant company, however, these parties while recording the statement has denied…

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7838/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Mar 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…n the following judicial pronouncements: i) 303 ITR 95 (Del) CIT vs. Pradeep Kumar Gupta ii) 456 ITR 84 (Del) Pr. CIT vs. Prabhu Dayal Aggarwal iii) 418 ITR 315 (SC) CIT v. Odeon Builders (P) Ltd. iv) 62 taxmann.com 3 (SC) Andaman Timber Industries vs. CCE v) 125 ITR 713 (SC) Kishnichand Chellaram vs. CIT vi) 288 ITR 345 (Del.) CIT vs. SMC Share Broker Limited vii) 293 ITR 43 (Del) CIT vs. S.M. Aggarwal 2.1 It was explained to the AO that transactions undertaken with these parties were duly recorded in the books of accounts of the appellant company, however, these parties while recording the statement has denied…

Vestige Marketing Pvt Ltd, Delhi vs. DCIT Central Circle -05, Delhi

ITA 5521/DEL/2025[2024-25]Status: DisposedITAT Delhi20 Mar 2026AY 2024-25

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

…nts: i) 303 ITR 95 (Del) CIT vs. Pradeep Kumar Gupta ii) 456 ITR 84 (Del) Pr. CIT vs. Prabhu Dayal Aggarwal iii) 418 ITR 315 (SC) CIT v. Odeon Builders (P) Ltd. 28 ITA-5515/Del/2025 & 13 others iv) 62 taxmann.com 3 (SC) Andaman Timber Industries vs. CCE v) 125 ITR 713 (SC) Kishnichand Chellaram vs. CIT vi) 288 ITR 345 (Del.) CIT vs. SMC Share Broker Limited vii) 293 ITR 43 (Del) CIT vs. S.M. Aggarwal 2.1 It was explained to the AO that transactions undertaken with these parties were duly recorded in the books of accounts of the appellant company, however, these parties while recording the statement has denied…

Vestige Marketing Pvt Ltd, Delhi vs. DCIT, Central Circle-05, Delhi

ITA 5520/DEL/2025[2023-24]Status: DisposedITAT Delhi20 Mar 2026AY 2023-24

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…n the following judicial pronouncements: i) 303 ITR 95 (Del) CIT vs. Pradeep Kumar Gupta ii) 456 ITR 84 (Del) Pr. CIT vs. Prabhu Dayal Aggarwal iii) 418 ITR 315 (SC) CIT v. Odeon Builders (P) Ltd. iv) 62 taxmann.com 3 (SC) Andaman Timber Industries vs. CCE v) 125 ITR 713 (SC) Kishnichand Chellaram vs. CIT vi) 288 ITR 345 (Del.) CIT vs. SMC Share Broker Limited vii) 293 ITR 43 (Del) CIT vs. S.M. Aggarwal 2.1 It was explained to the AO that transactions undertaken with these parties were duly recorded in the books of accounts of the appellant company, however, these parties while recording the statement has denied…

Vestige Marketing Pvt Ltd, Delhi vs. DCIT, Central Circle-05, Delhi

ITA 5517/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…n the following judicial pronouncements: i) 303 ITR 95 (Del) CIT vs. Pradeep Kumar Gupta ii) 456 ITR 84 (Del) Pr. CIT vs. Prabhu Dayal Aggarwal iii) 418 ITR 315 (SC) CIT v. Odeon Builders (P) Ltd. iv) 62 taxmann.com 3 (SC) Andaman Timber Industries vs. CCE v) 125 ITR 713 (SC) Kishnichand Chellaram vs. CIT vi) 288 ITR 345 (Del.) CIT vs. SMC Share Broker Limited vii) 293 ITR 43 (Del) CIT vs. S.M. Aggarwal 2.1 It was explained to the AO that transactions undertaken with these parties were duly recorded in the books of accounts of the appellant company, however, these parties while recording the statement has denied…