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 367,154 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

Gd Foods Manufacturing (India) Pvt. Ltd., New Delhi vs. ACIT, Central Circle- 26, New Delhi

The appeal of the revenue is dismissed

ITA 1181/DEL/2018[2015-16]Status: DisposedITAT Delhi06 Sept 2018AY 2015-16

Bench: Shri Prashant Maharishi & Shri K. N. Chary

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Sanjit Singh, CIT DR
Section 132Section 153A

…8,1186/Del/2018,1180/Del/2018 1181/Del/2018 ( By Revenue) 1464/Del/2018, 1465/Del/2018, 1466/Del/2018, 1467/Del/2018, 1468/Del/2018, 1469/Del/2018, 1470/Del/2018 Assessment Year 2009-10 to 2015-16 a. Kishinchand Chellaram v. Commissioner of Income-tax (1980) 125 ITR 713 (SC); b. Additional Income-tax Officer v. Ponkunnam Traders [1976] 102 ITR 366 (Kerala); c. Babcock Power (Overseas Projects) Ltd v. Deputy Commissioner of Income- tax [2003] 131 Taxman 86 (Delhi) (Mag.) ITA No. 1388 and 1389 (Delhi) of 1993; d. Smt. Surjeet Kaur v. Income-tax Officer [2001] 119 Taxman 33 (Hyd.) (Mag.) ITA No. 354 (Hyd.) of 19…

Gd Foods Manufacturing (India) Pvt. Ltd., New Delhi vs. ACIT, Central Circle- 26, New Delhi

The appeal of the revenue is dismissed

ITA 1180/DEL/2018[2014-15]Status: DisposedITAT Delhi06 Sept 2018AY 2014-15

Bench: Shri Prashant Maharishi & Shri K. N. Chary

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Sanjit Singh, CIT DR
Section 132Section 153A

…8,1186/Del/2018,1180/Del/2018 1181/Del/2018 ( By Revenue) 1464/Del/2018, 1465/Del/2018, 1466/Del/2018, 1467/Del/2018, 1468/Del/2018, 1469/Del/2018, 1470/Del/2018 Assessment Year 2009-10 to 2015-16 a. Kishinchand Chellaram v. Commissioner of Income-tax (1980) 125 ITR 713 (SC); b. Additional Income-tax Officer v. Ponkunnam Traders [1976] 102 ITR 366 (Kerala); c. Babcock Power (Overseas Projects) Ltd v. Deputy Commissioner of Income- tax [2003] 131 Taxman 86 (Delhi) (Mag.) ITA No. 1388 and 1389 (Delhi) of 1993; d. Smt. Surjeet Kaur v. Income-tax Officer [2001] 119 Taxman 33 (Hyd.) (Mag.) ITA No. 354 (Hyd.) of 19…

Jagmohan Agarwal, Kolkata vs. ACIT, Circle - 35, Kolkata

ITA 604/KOL/2018[2014-15]Status: DisposedITAT Kolkata05 Sept 2018AY 2014-15

Bench: "ी ऐ. ट". वक", "यायीक सद"य एवं/And "ी एम .बालागणेश, लेखा सद"य) [Before Shri A. T. Varkey, Jm & Shri M. Balaganesh, Am]

Section 133(6)Section 68

…1 Jagmohan Agarwal, AY 2014-15 आयकर अपील"य अधीकरण, "यायपीठ – “D” कोलकाता, IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH: KOLKATA (सम")Before "ी ऐ. ट". वक", "यायीक सद"य एवं/and "ी एम .बालागणेश, लेखा सद"य) [Before Shri A. T. Varkey, JM & Shri M. Balaganesh, AM] I.T.A. No. 604/Kol/2018 Assessment Year: 2014-15 Jagmohan Agarwal Vs. Assistant Commissioner of Income- (PAN: ACGPA6150K) tax, Circle-35, Kolkata. Appellant Respondent Date of Hearing 21.06.2018 Date of Pronouncement 05.09.2018 For the Appellant Shri Miraj D. Shah, AR For the Respondent Shri Saurabh Kumar, Addl. CIT ORDER Per Shri A.T.Varkey, JM This…

Himanshu Kohli, New Delhi vs. ACIT, Central Circle- 28, New Delhi

The appeal is allowed

ITA 6592/DEL/2017[2015-16]Status: DisposedITAT Delhi05 Sept 2018AY 2015-16

Bench: Sh. N.K.Billaiya & Sh. Sudhanshu Srivastava

For Appellant: Sh. Sri Gautam Jain & Piyush K. KamalFor Respondent: Sh. Sanjit Singh, CIT DR
Section 132Section 132(4)Section 139Section 143(1)Section 153A

…statements of those witnesses were made the basis of the impugned order, amounted to a serious lapse which makes the order a nullity as it amounted to violation of principles of natural justice. Also in the case of Kishanichand Chellaram v. CIT reported in 125 ITR 713 (SC) it was held that any material collected at the back of the assessee and the assessee not being confronted with the same and no opportunity having been given the assessee to cross-examine, such material cannot be relied upon against the assessee. We are also guided by the judicial precedents as laid down in CIT v. Sunil Agarwal 379 ITR 367…

Himanshu Kohli, New Delhi vs. ACIT, Central Circle- 28, New Delhi

The appeal is allowed

ITA 6591/DEL/2017[2014-15]Status: DisposedITAT Delhi05 Sept 2018AY 2014-15

Bench: Sh. N.K.Billaiya & Sh. Sudhanshu Srivastava

For Appellant: Sh. Sri Gautam Jain & Piyush K. KamalFor Respondent: Sh. Sanjit Singh, CIT DR
Section 132Section 132(4)Section 139Section 143(1)Section 153A

…statements of those witnesses were made the basis of the impugned order, amounted to a serious lapse which makes the order a nullity as it amounted to violation of principles of natural justice. Also in the case of Kishanichand Chellaram v. CIT reported in 125 ITR 713 (SC) it was held that any material collected at the back of the assessee and the assessee not being confronted with the same and no opportunity having been given the assessee to cross-examine, such material cannot be relied upon against the assessee. We are also guided by the judicial precedents as laid down in CIT v. Sunil Agarwal 379 ITR 367…

Himanshu Kohli, New Delhi vs. ACIT, Central Circle- 28, New Delhi

The appeal is allowed

ITA 6590/DEL/2017[2013-14]Status: DisposedITAT Delhi05 Sept 2018AY 2013-14

Bench: Sh. N.K.Billaiya & Sh. Sudhanshu Srivastava

For Appellant: Sh. Sri Gautam Jain & Piyush K. KamalFor Respondent: Sh. Sanjit Singh, CIT DR
Section 132Section 132(4)Section 139Section 143(1)Section 153A

…statements of those witnesses were made the basis of the impugned order, amounted to a serious lapse which makes the order a nullity as it amounted to violation of principles of natural justice. Also in the case of Kishanichand Chellaram v. CIT reported in 125 ITR 713 (SC) it was held that any material collected at the back of the assessee and the assessee not being confronted with the same and no opportunity having been given the assessee to cross-examine, such material cannot be relied upon against the assessee. We are also guided by the judicial precedents as laid down in CIT v. Sunil Agarwal 379 ITR 367…

Rajendra M. Gadhecha, Mumbai vs. ITO 29(3)(1), Mumbai

ITA 1605/MUM/2017[2009-10]Status: DisposedITAT Mumbai30 Aug 2018AY 2009-10

Bench: Hon’Ble Shri R. C. Sharma, Am & Hon’Ble Shri Sandeep Gosain, Jm आयकरअपीलसं./ I.T.A. No. 1605/Mum/2017, (िनधा"रणवष" / Assessment Year: 2009-10)

For Appellant: ShriDevendra Jain, ARFor Respondent: Shri Chaitanya Anjaria
Section 143(3)Section 147

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE HON’BLE SHRI R. C. SHARMA, AM, & HON’BLE SHRI SANDEEP GOSAIN, JM आयकरअपीलसं./ I.T.A. No. 1605/Mum/2017, (िनधा"रणवष" / Assessment Year: 2009-10) Rajendra M. Gadhecha ITO 29(3)(1) बनाम/ 4-B, Aarti Apartment, S. N. Mumbai Road, Mulund(west) Pin- Vs. Mumbai-400080 "थायीलेखासं./जीआइआरसं./PAN/GIR No. AEDPG5052M (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant by : ShriDevendra Jain, AR ""थ"कीओरसे/Respondentby : Shri Chaitanya Anjaria, DR सुनवाईकीतारीख/ : 09/08/2018 Date of Hearing घोषणाकीतारीख / : 30.08.2018 Date of Pronouncement आदेश / O…

DCIT Cent. Cir. - 1(3), Mumbai vs. Jainam Investments, Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 6099/MUM/2016[2012-13]Status: DisposedITAT Mumbai10 Aug 2018AY 2012-13

Bench: Shri B.R. Baskaran (Am) & Shri Ramlal Negi (Jm)

Section 68

…at the assessing officer is not entitled to rely upon the documents collected behind the back of the assessee. In this regard, the Ld A.R placed his reliance on the decision rendered by Hon’ble Supreme Court in the case of Kishinchand Chellaram vs. CIT (1980)(125 ITR 713). He further submitted that the assessing officer has not provided opportunity to cross examine the parties who gave adverse statements. He submitted that the Hon’ble Supreme Court has held in the case of Andaman Timber Industries vs. CIT (Civil Appeal No.4228 of 2006 dated 02-09-2015) that, not allowing cross examination of witnesses by the adju…

Sunita Khemka, New Delhi vs. ACIT, Central Circle- 15, Jhandewalan Extn., New Delhi

In the result, Appeal of assessee is allowed

ITA 389/DEL/2018[2014-15]Status: DisposedITAT Delhi02 Aug 2018AY 2014-15

Bench: Shri Bhavnesh Saini

For Appellant: Shri Raj Kumar, C.A. &For Respondent: Shri S.L. Anuragi, Sr. D.R
Section 10Section 10(38)

…of these persons for indulging in taking accommodation entries. He has, therefore, submitted that such evidence cannot be read in evidence against the assessee and relied upon the decision of the Hon’ble Supreme Court in the case of Kishan Chand Chela Ram 125 ITR 713 (SC). He has submitted that for claiming exemption u/s 10(38) of the Act, the assessee shall have to prove twin conditions i.e. the income arise from the 38 ITA.No.389/Del./2018 Smt. Sunita Khemka, New Delhi. transfer of long term capital asset and being equity share in a company where the transfer of sale of such equity share is entered into on…

Asst CIT 19(1), Mumbai vs. Dilip Chimanlal Gandhi, Mumbai

In the result, this appeal by the Revenue stands dismissed

ITA 7079/MUM/2016[2012-13]Status: DisposedITAT Mumbai01 Aug 2018AY 2012-13

Bench: Shri Shamim Yahya, Am & Shri Pawan Singh, Jm

For Appellant: Shri Virendar SinghFor Respondent: Shri Suchek Anchaliya
Section 132

…t his observation. The case laws referred by him are as under: 1) H. R. Mehta (in ITA No. 58 of 2001 vide order dated 30.06.2016); 2) Andaman Timber Industries (Civil Appeal No. 4228 of 2006 vide order dated 02.09.2015); 3) KishinchandChellaram vs. CIT [1980] 125 ITR 713 (SC); 4) Roshan Di Hatti vs. CIT [1977] 107 ITR 938 (SC); 5) A. Govindarajulu Mudaliar vs. CIT [1958] 34 ITR 807 (SC); 6) Rohini Builders [2002] 256 ITR 360 (Guj); 7) CIT vs. Smt. Sushiladevikhadaria [2009] 319 ITR (Bom); 8) ITO vs. Anant Shelters (P) Ltd. [2012] 51 SOT 234; 9) CIT vs. Varinder Rawlley [2014] 366 ITR 232 (P&H); 10) CIT vs. Jai Ku…

DCIT, New Delhi vs. M/S. Padmini Vna Mechatronics Pvt. Ltd., New Delhi

In the result, Departmental Appeal for A

ITA 1809/DEL/2014[2008-09]Status: DisposedITAT Delhi01 Aug 2018AY 2008-09

Bench: Shri Bhavnesh Saini & Shri L.P. Sahu

For Appellant: Sh. Rajkumar Gupta, CA &For Respondent: Sh. S.R. Senpati, Sr.DR
Section 133Section 143Section 147Section 148

…he assessee; therefore, it cannot be read in evidence against the assessee. The assessee relied upon the 7 ITA No.-1807/Del/2014 & two others. M/s Padmini VNA Mechatronics Pvt. Ltd. decision of the Supreme Court in the case of Kishinchand Chellaram vs. CIT 125 ITR 713 (SC). Assessee submitted that explanation of the assessee was supported by documentary evidences which have not been verified by the AO. The transaction was conducted through banking channel. Report of the Postal Department and Inspector, that the above Parties have left the said premises would show that they existed at the address given by the…

DCIT, New Delhi vs. M/S. Padmini Vna Mechatronics Pvt. Ltd., New Delhi

In the result, Departmental Appeal for A

ITA 1808/DEL/2014[2007-08]Status: DisposedITAT Delhi01 Aug 2018AY 2007-08

Bench: Shri Bhavnesh Saini & Shri L.P. Sahu

For Appellant: Sh. Rajkumar Gupta, CA &For Respondent: Sh. S.R. Senpati, Sr.DR
Section 133Section 143Section 147Section 148

…he assessee; therefore, it cannot be read in evidence against the assessee. The assessee relied upon the 7 ITA No.-1807/Del/2014 & two others. M/s Padmini VNA Mechatronics Pvt. Ltd. decision of the Supreme Court in the case of Kishinchand Chellaram vs. CIT 125 ITR 713 (SC). Assessee submitted that explanation of the assessee was supported by documentary evidences which have not been verified by the AO. The transaction was conducted through banking channel. Report of the Postal Department and Inspector, that the above Parties have left the said premises would show that they existed at the address given by the…

DCIT, New Delhi vs. M/S. Padmini Vna Mechatronics Pvt. Ltd., New Delhi

In the result, Departmental Appeal for A

ITA 1807/DEL/2014[2006-07]Status: DisposedITAT Delhi01 Aug 2018AY 2006-07

Bench: Shri Bhavnesh Saini & Shri L.P. Sahu

For Appellant: Sh. Rajkumar Gupta, CA &For Respondent: Sh. S.R. Senpati, Sr.DR
Section 133Section 143Section 147Section 148

…he assessee; therefore, it cannot be read in evidence against the assessee. The assessee relied upon the 7 ITA No.-1807/Del/2014 & two others. M/s Padmini VNA Mechatronics Pvt. Ltd. decision of the Supreme Court in the case of Kishinchand Chellaram vs. CIT 125 ITR 713 (SC). Assessee submitted that explanation of the assessee was supported by documentary evidences which have not been verified by the AO. The transaction was conducted through banking channel. Report of the Postal Department and Inspector, that the above Parties have left the said premises would show that they existed at the address given by the…

DCIT, New Delhi vs. M/S. Suncity Projects Pvt. Ltd., New Delhi

ITA 5740/DEL/2013[2003-04]Status: DisposedITAT Delhi12 Jul 2018AY 2003-04

Bench: Sh. N. K. Saini, Am & Ms. Suchitra Kamble, Jm

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Sh. S. S. Rana, CIT DR
Section 132Section 143(1)Section 143(3)Section 147Section 153ASection 68

…tement was made by the Assessing Officer in Addition to other evidence. The assessee was not given opportunity to cross-examine despite having asked. The ITAT, after considering the decision of Hon'ble Supreme Court in the case of Kishanchand Chelaram vs CIT, 125 ITR 713 deleted the addition by holding that the assessing officer's failure to allow cross-examination vitiates the entire addition. The observations of the Bench in the order dated July 2, 2004 are as under: "The assessee further requested specifically to the Assessing Officer to allow him to cross-examine Anand Prakash. Despite these two requests, Ana…

Shikha Dhawan, Gurgaon vs. ITO, Ward- 4(2), Gurgaon

In the result, the appeal of the assessee is allowed

ITA 3035/DEL/2018[2014-15]Status: DisposedITAT Delhi27 Jun 2018AY 2014-15

Bench: Sh.Bhavnesh Saini[Assessment Year: 2014-15] Vs Smt. Shikha Dhawan, Ito, C-101, Centre Park, Ward-4(2), Sector-42, Gurgaon. Gurgaon. Pan-Ccbps1718L (Appellant) (Respondent) Appellant By Sh. Gautam Jain & Sh. Peeyush Kamal, Advocate Respondent By Sh. S.L.Anuragi, Sr.Dr Date Of Hearing 11.06.2018 Date Of Pronouncement 27.06.2018

Section 10(38)Section 68

…y of these persons for indulging in taking accommodation entries. He has, therefore, submitted that such evidence cannot be read in evidence against the assessee and relied upon the decision of the Hon’ble Supreme Court in the case of Kishan Chand Chela Ram 125 ITR 713 (SC). He has submitted that for claiming exemption u/s 10(38) of the Act, the assessee shall have to prove twin conditions i.e. the income arise from the transfer of long term capital asset and being equity share in a company where the transfer of sale of such equity share is entered into on or after the date of which Chapter-VII of the Finance…

ACIT 30(3), Mumbai vs. Shreedham Builders, Mumbai

ITA 5589/MUM/2017[2012-13]Status: DisposedITAT Mumbai22 Jun 2018AY 2012-13

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2012-13 Acit-30(3), Shreedham Builders, R. No.510, 5Th Floor, 105/106, 1St Floor, बनाम/ Pratayakshkar Bhavan, Vijay Indl. Estate, Vs. Bandra Kurla Complex, Malad (W), Bandra (East), Mumbai-400064 Mumbai-400051 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Abdfs0133N

Section 143(1)Section 143(2)Section 68

…inciple of natural justice and since the statements could not be utilized against the assessee without giving full and proper opportunity of cross examination. He relied on the decision of the Hon'ble Supreme Court in the case of Kishanchand Chellaram v. CIT [125 ITR 713]. He also observed that assessee submitted the confirmations from the parties, filed audit reports of the parties along with the copy of ITR and bank statements and therefore since the assessee has discharged its primary onus, the onus had shifted to the Assessing Officer and the Assessing Officer has not made any inquiries from the alleged lende…

ITO, Jaipur vs. Land Mark Dilsay P Ltd, Jaipur

Appeals are dismissed in limine but without any order as to costs

ITA 178/JPR/2015[2006-07]Status: DisposedITAT Jaipur08 Jun 2018AY 2006-07
For Appellant: Shri P.C. Parwal (CA)For Respondent: Smt. Seema Meena (JCIT) fu/kZkfjrh dh vksj ls@
Section 143(1)Section 148

…amely, Sh. S K Jain or Sh. V K Jain or Sh. Assem Kumar Gupta or Sh. Rajesh Agrawal whose statements have referred/relied in the assessment order. Reference in this regard can be made to the decisions in the case of R.B. Shreeram Durga Prasad 176 ITR 169 (SC), 125 ITR 713 (SC), Jindal Vegetable (order of Hon'ble Delhi High Court in ITA no. 428 of 2007, 174 Taxmann 440 (Raj.) and Laxman Bhai Patel (order of Hon'ble Gujarat High Court dated 22/07/2008 in ITR no. 41/1997). Admittedly, these statements were not recorded by the AO but were recorded by the Investigation Wing Delhi at the back of the assessee. AO ITA 1…

ITO, Jaipur vs. Land Mark Dilsay P Ltd, Jaipur

Appeals are dismissed in limine but without any order as to costs

ITA 177/JPR/2015[2005-06]Status: DisposedITAT Jaipur08 Jun 2018AY 2005-06
For Appellant: Shri P.C. Parwal (CA)For Respondent: Smt. Seema Meena (JCIT) fu/kZkfjrh dh vksj ls@
Section 143(1)Section 148

…ely, Sh. S K Jain or Sh. V K Jain or Sh. Assem Kumar Gupta or Sh. Rajesh Agrawal whose statements have referred / relied in the assessment order. Reference in this regard can be made to the decisions in the case of R.B. Shreeram Durga Prasad 176 ITR 169 (SC), 125 ITR 713 (SC), Jindal Vegetable (order of Hon'ble Delhi High Court in ITA no. 428 of 2007, 174 Taxmann 440 (Raj.) and Laxman Bhai Patel (order of Hon'ble Gujarat High Court dated 22/07/2008 in ITR no. 41/1997). ITA 177/JP/2015 & C.O. 17/JP/2015_ 6 ITO Vs M/s Land Mark Dealers (P) Ltd. Admittedly, these statements were not recorded by the AO but were reco…

M/S Shree Balaji Landmark Hotels Pvt. Ltd., Indore vs. The ACIT 3(1), Indore

In the result, the appeal of the assessee is allowed

ITA 865/IND/2016[2011-12]Status: DisposedITAT Indore07 Jun 2018AY 2011-12

Bench: Shri Kul Bharat, Hon’Ble & Shri Manish Borad, Hon’Blea.Y. 2011-12 M/S Shree Balaji Landmark Hotel Private Limited Indore ::: Appellant Vs Acit 3(1) Indore ::: Respondent Appellant By Shri Pankaj Shah Respondent By Shri K.G. Goyal Date Of Hearing 4.6.2018 Date Of Pronouncement 8.6.2018 O R D E R Per Shri Manish Borad, Am

Section 143(3)

…inaccurate particulars of income. Reliance was further placed on the following decisions :- (i) Babulal C. Borana vs. ITO (2006) 282 ITR 251 (Bom) (ii) ACIT vs. Kishan Lal Jewels Pvt. Ltd. (2012) 147 TTJ 308(Del) (Tri.) (iii) Kishinchand Chellaram vs. CIT; 125 ITR 713 (iv) Manjunath Cotton & Ginning Factory 395 ITR 565) 6. On the other hand, the learned DR vehemently argued supporting the orders of the lower authorities. 7. We have heard both the parties and perused the material available on record as also the judgments relied upon by the learned counsel for the assessee. 8. The sole grievances relates to…

Mohd Rizwan Mohd Kallan Khan, Mumbai vs. Income Tax Officer 26(3)(4), Mumbai

In the result, appeal filed by assessee is partly allowed

ITA 1141/MUM/2018[2009-10]Status: DisposedITAT Mumbai31 May 2018AY 2009-10

Bench: Shri G.S. Pannu & Shri Pawan Singhmd. Rizwan Mohd Kallan Ito 26(3)(4) Room No. 711, 7Th Floor, Khan, Plot No. 603, Flat No.13, Bldg No. 7 D, Bombay Taxi C-11, Pratyakshakar Bhavan, Men’S Co-Operative Society, Vs. Bandra (East), Mumbai-51. Lbs Marg, Kurla (West), Mumbai-400070 Pan: Agjpk2270K Appellant Respondent Appellant By : Shri Vimal Punmiya (Ar) Respondent By : Shri Rajesh Kumar Yadav (Ar) Date Of Hearing :25.04.2018 Date Of Pronouncement : 31.05.2018 Order Per Pawan Singh; 1. The Instant Appeal By Assessee Under Section 253 Of The Income-Tax Act (The Act) Is Directed Against The Order Of Ld. Commissioner Of Income-Tax

For Appellant: Shri Vimal Punmiya (AR)For Respondent: Shri Rajesh Kumar Yadav (AR)
Section 143Section 143(1)Section 143(3)Section 145(3)Section 147Section 148Section 234ASection 253Section 274Section 3

…1] CIT V /s M K Bros. [163 ITR 249] CIT V. Kashiram Textile Mills P Ltd. [2006] 284 ITR 61 (GUJ) Saraswathi Oil Traders V. CIT [2000] 254 ITR 259 (SC)174 CTR 108 (SC) 7 AO relied on third party Kishan Chand Chella Ram v. CIT information without cross- [1980] 125 ITR 713 (SC) examination. Hence, can't be Marneedi Satyam V/s Masimukkula relied: Venkataswami [AIR 1949 Mad 689] ITO V/s Permanand [2008 25 SOT 11] 8 AO failed to discharge his duty to ITO V/s Permanand [2008 25 SOT prove the transaction as bogus: 11] DCIT v. Shri Rajeev G. Kalathil, (Mum) (Trib) (ITA No. 6727/M/2012 dt.20/8/2014. 9 Payments were made…