How many judgments cite Mehta Parikh & Co. v. CIT?

396 judgments on BharatTax cite Mehta Parikh & Co. v. CIT (30 ITR 181), spanning 2012 to 2026.

Which sections of the Income Tax Act does Mehta Parikh & Co. v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 153A, Section 132, Section 132(4), Section 69A, Section 147.

Mehta Parikh & Co. v. CIT

30 ITR 181Supreme Court of India1956#185 most cited

What is Mehta Parikh & Co. v. CIT authority for?

If the Assessing Officer or appellate authority does not rebut the facts stated in an affidavit, those facts are binding on the tax authorities.

396

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2012 to 2026.

Also referred to as

Mehta Parikh & Co. v. CIT · 30 ITR 181 · affidavit not rebutted · binding on AO · facts in affidavit · tax authorities bound by affidavit · statement in affidavit

Sections most often in play

Section 143(3)Section 153A Section 132 Section 132(4)Section 69A Section 147 Section 69 Section 153C

Issues it is cited on

section 158bb(1)retraction of statement section 158bb section 131(1a)section 292c statement under section 132(4)section 132(4a)panchnama section 153c(1)loose papers section 132(4)dumb documents

Judgments citing Mehta Parikh & Co. v. CIT

Shri Bhavish Harilal Moradia, Rajkot vs. The ITO Ward-1 (1) (3), Rajkot

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

ITA 63/RJT/2023[2009-10]Status: DisposedITAT Rajkot02 Aug 2023AY 2009-10

Bench: SHRI WASEEM AHMED (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)

For Appellant: Shri M. N. Manvar, A.RFor Respondent: Shri K. L. Solanki, Sr. D.R

Section 132Section 147Section 148Section 153C

…for the revenue to rely upon part of the affidavit which is favorable to department and against the assessee. The relevant observation of the Hon’ble High Court reads as under: As laid down by the Supreme Court in the case of Mehta Parikh & Co. v. CIT [1956] 30 ITR 181, none of the authorities considered it necessary to cross-examine the deponent with reference to the statement made in the affidavit, and, hence, under these circumstances it was not open to the revenue to challenge the correctness of the statement made by the deponent in the affidavit. In other words, consequently, the assessee was entitled to as…

Home Developers Project Pvt. Ltd., New Delhi vs. DCIT, Central Circle- 14, New Delhi

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

ITA 390/DEL/2019[2012-13]Status: DisposedITAT Delhi26 Jul 2023AY 2012-13

Bench: Sh. N. K. Billaiya & Sh. Anubhav Sharmaassessment Year: 2012-13

Section 234BSection 271(1)Section 68

…eir statements then authorities would not be justified in doubting the correctness of the statement made by the deponents in the affidavits. For this proposition we draw support from the decision of Hon’ble Supreme Court in the case of Mehta Parik and company 30 ITR 181. 15. Surprisingly we find that the entire addition is based upon the statement of alleged entry operator Himsanshu Verma but he was never produced for cross-examination. The onus of ensuring his presence was on the AO but even the AO showed his inability to produce Himsanshu Verma for cross-examination. 16. It is incorrect on the part of the CIT…

Dinesh Kumar Chaurasia, Tonk vs. PCIT Central, Jaipur

In the result, appeal of the assessee is dismissed

ITA 102/JPR/2023[2018-19]Status: DisposedITAT Jaipur17 Jul 2023AY 2018-19

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Mahendra Gargieya (Adv.)For Respondent: Sh. Ajey Malik (CIT)

Section 143(3)Section 263Section 5

…CIT dismissed. — CIT vs. Smt. P.K. Noorjahan (1980) 15 CTR (Ker) 138: (1980) 123 ITR 3 (Ker):42R.1622, affirmed.” 3.4 Normally, in absence of any contrary material the averments made in the affidavits should be accepted. Ref : Mehta Parikh & Co. v. CIT (1956) 30 ITR 181 (SC). In this case no such material is referred even by the CIT. 3.5 A pertinent fact having a direct bearing cannot be lost sight off / ignored that a survey was carried out during the course of which some papers were impounded and that the AO made detailed inquiries seeking clarifications on each aspect, duly submitted by the assessee. Even subs…

ACIT, CC-14, New Delhi vs. Pramaditya, Rajasthan

In the result, the appeal of the revenue is dismissed and cross objection of the assessee is allowed

ITA 1861/DEL/2021[2017-18]Status: DisposedITAT Delhi27 Jun 2023AY 2017-18

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2017-18 Acit, Vs Pramaditya, Cc-14, 67, Mahaveer Nagar, 2Nd Maharani Farm, New Delhi. Durgapur, Jaipur, Rajasthan – 302018. Pan: Ajppp2281E Co No.29/Del/2022 Assessment Year: 2017-18 Pramaditya, Vs. Acit, 67, Mahaveer Nagar, Cc-14, 2Nd Maharani Farm, New Delhi. Durgapur, Jaipur, Rajasthan – 302018. Pan: Ajppp2281E

For Appellant: Shri Hiren Mehta, CAFor Respondent: Ms Sapna Bhatia, CIT, DR

Section 127Section 132Section 143(3)Section 153CSection 69A

…m regarding the affidavit filed. This goes to categorically prove that the contents of the affidavit were accepted to be true by the investigation wing. In this regard, the decision of Hon’ble Supreme Court in the case of Mehta Parikh & Co. vs CIT reported in 30 ITR 181 (SC) would support the case of the assessee. Further the Hon’ble Supreme Court in the case of Senior Bhosale Estate (HUF) vs ACIT in Civil Appeal Nos. 6671-6676 of 2010 14 CO No.29/Del/2022 with Civil Appeal Nos. 6677-6690 of 2010 dated 07.11.2019 explained the credibility of an affidavit in the context of condonation of delay had held as under:-…

Tara Raju Patel, Valsad vs. Income Tax Officer, International Taxation, Surat

In the result, the appeal of assessee is allowed

ITA 195/SRT/2023[2012-13]Status: DisposedITAT Surat26 Jun 2023AY 2012-13

Bench: Shri Pawan Singh(Virtual Hearing) Raju Maganlal Patel, I.T.O. C/O-Dinkarbhai T. Patel, Shankar (International Taxation), Vs. Talao, Via-Dungri, Valsad. Surat. Pan No. Auspp 1436 F Appellant/ Assessee Respondent/ Revenue Tara Raju Patel, I.T.O. C/O-Dinkarbhai T. Patel, Shankar (International Taxation), Vs. Talao, Via-Dungri, Valsad. Surat. Pan No. Avdpp 6714 G Appellant/ Assessee Respondent/ Revenue

Section 133(6)Section 144Section 147Section 148Section 254(1)Section 69

…aur Vs ITO 88 ITR 414 (Chd. Trib) (iii) DCIT Vs Dharmndrabhai M. Sutaria (HUF) ITA No. 795/Ahd/2019 with CO No. 169/Ahd/2019 order dated 27/04/2022 (iv) Ashish Natvarlal Vashi Vs ITO ITA No. 3522/Srt/2016 dated 19/04/2021. (v) Mehta Parikh & Co. Vs ITO (1956) 30 ITR 181 and Daulat Ram Rawatmal Vs CIT (1973) 87 ITR 349 (SC). (vi) Brijindrapal Singh Bhullar Vs ITO (2022) 188 TER(A) 648 (Asr Trib). 9. On the other hand, the ld. Sr. DR for the revenue supported the order of ld. CIT(A). The ld. Sr. DR for the revenue submits that all the arguments and submissions as made before the Bench was considered by the ld. CIT(…

Shri Raju Maganlal Patel, Valsad vs. Income Tax Officer, Int. Taxation, Surat

In the result, the appeal of assessee is allowed

ITA 188/SRT/2023[2011-12]Status: DisposedITAT Surat26 Jun 2023AY 2011-12

Section 133(6)Section 144Section 147Section 148Section 254(1)Section 69

Vachitra Builders Pvt Ltd, New Delhi vs. ITO Ward - 26(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 8148/DEL/2019[2015-16]Status: DisposedITAT Delhi20 Jun 2023AY 2015-16

Bench: Shri G. S. Pannua N D Shri Challa Nagendra Prasad

For Appellant: Shri Shyam Sunder, Adv

Section 115BSection 131Section 133(6)Section 143(3)Section 68

…TA No. 71/2015 dated 12.8.2015 (Del)]. 22. Ld. Counsel submitted that it is well-settled law that if no effort is made to controvert the contents of the affidavit, the same has to be accepted as true as held in the case of Mehta Parikh and Co. vs. CIT (1956) 30 ITR 181 (SC). 23. The ld. Counsel for the assessee further submits that in the course of assessment proceedings and also the appellate proceedings before the ld. CIT (Appeals) the following documents were furnished in respect of the lenders to prove the identity, creditworthiness and genuineness of the transactions:- 20 I.T.A. No. 8148/Del/2019 “Shyam…

Shri Nirvair Singh, Amritsar vs. Income Tax Officer Ward- 4 (3), Amritsar

In the result, the appeal of the assessee bearing ITA No

ITA 719/ASR/2019[2011-12]Status: DisposedITAT Amritsar17 May 2023AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 133(6)Section 147Section 148Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR. BEFORE DR. M. L. MEENA, ACCOUNTANT MEMBER AND SH. ANIKESH BANERJEE, JUDICIAL MEMBER I.T.A. No.719/Asr/2019 Assessment Year: 2011-12 Sh. Nirvair Singh, Village Vs. ITO, 4(3) Bhagatupura H. No. 14, Daburji Amritsar. GT Road, Amritsar. [PAN:CVBPS0398R] (Respondent) (Appellant) Appellant by Sh. Nipun Khanna, CA Respondent by Sh. RadheyShyam Jaiswal, Sr. DR Date of Hearing 10.05.2023 Date of Pronouncement 17.05.2023 ORDER Per:Anikesh Banerjee, JM: The instant appeal of the assessee was filed against the order of the ld. Commissioner of Income Tax…

Sh. Mukesh Kumar Jangam, Plot No.75, Gali No.2, Rishi Galeeb Nagar, Galta Gate, Jaipur vs. DCIT, Central Circle-4, Jaipur

In the result, this appeal of the assessee is allowed

ITA 161/JPR/2023[2019-20]Status: DisposedITAT Jaipur10 May 2023AY 2019-20

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal (CA)For Respondent: Smt. Monisha Choudhary (Addl.CIT)

Section 115BSection 131Section 132ASection 194CSection 250Section 69A

…ee (PB 22). Further in affidavit dated 12.04.2021 (PB 26-29) the assessee has explained in detail that cash found from him belongs to himself and of his brothers. This affidavit is not controverted. Hon’ble Supreme Court in case of Mehta Parikh & Co. Vs. CIT 30 ITR 181 at Pg 187 has held that the rejection of affidavit filed by the assessee is not justified unless the deponent has either been discredited in cross examination or has failed to produce other supporting evidence when called upon to do so. This is also reiterated by Hon’ble ITAT, Jaipur Bench in case of Kuldeep Chand Garg Vs. ITO 37 Tax World 127…

ACIT, New Delhi vs. M/S. Bptp Ltd., New Delhi

In the result, the appeals of the Revenue are dismissed

ITA 2665/DEL/2014[2008-09]Status: DisposedITAT Delhi28 Apr 2023AY 2008-09

Bench: Sh. C. M. Gargdr. B. R. R. Kumarita No. 2663/Del/2014 : Asstt. Year : 2006-07 Ita No. 2664/Del/2014 : Asstt. Year : 2007-08 Ita No. 2665/Del/2014 : Asstt. Year : 2008-09 Acit, Vs M/S Bptp Ltd., Central Circle-23, M-11, Middle Circle, Connaught Place, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaccb2442A Assessee By : Sh. Ajay Bhagwani, Ca Revenue By : Sh. P. Praveen Sidharth, Cit Dr Date Of Hearing: 15.02.2023 Date Of Pronouncement: 28.04.2023

For Appellant: Sh. Ajay Bhagwani, CAFor Respondent: Sh. P. Praveen Sidharth, CIT DR

Section 132(4)Section 132ASection 139(1)Section 139(5)Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’, NEW DELHI Before Sh. C. M. Garg, Judicial Member Dr. B. R. R. Kumar, Accountant Member ITA No. 2663/Del/2014 : Asstt. Year : 2006-07 ITA No. 2664/Del/2014 : Asstt. Year : 2007-08 ITA No. 2665/Del/2014 : Asstt. Year : 2008-09 ACIT, Vs M/s BPTP Ltd., Central Circle-23, M-11, Middle Circle, Connaught Place, New Delhi New Delhi (APPELLANT) (RESPONDENT) PAN No. AACCB2442A Assessee by : Sh. Ajay Bhagwani, CA Revenue by : Sh. P. Praveen Sidharth, CIT DR Date of Hearing: 15.02.2023 Date of Pronouncement: 28.04.2023 ORDER Per Dr. B. R. R. Kumar, Accountant Member…

ACIT, New Delhi vs. M/S. Bptp Ltd., New Delhi

In the result, the appeals of the Revenue are dismissed

ITA 2663/DEL/2014[2006-07]Status: DisposedITAT Delhi28 Apr 2023AY 2006-07

For Appellant: Sh. Ajay Bhagwani, CAFor Respondent: Sh. P. Praveen Sidharth, CIT DR

Section 132(4)Section 132ASection 139(1)Section 139(5)Section 153A

M/S Saket Infraprojecs P.Ltd, Mumbai vs. Dy CIT CC-1(4), Mumbai

In the result, the three appeals filed by the assessee are allowed

ITA 2055/MUM/2020[2014-15]Status: DisposedITAT Mumbai10 Apr 2023AY 2014-15

Bench: Shri B R Baskaran & Shri Pavan Kumar Gadale

For Appellant: Shri JP BairagraFor Respondent: Shri Dr. Kishor Dhule, CIT DR &

Section 133ASection 142(1)Section 143(1)Section 143(2)Section 250Section 68

…nd over looked the explanations of the assessee. The judicial decisions relied by the Ld.AR are as under: i.Kishinchand Chellaram vs. CIT (1980) (125 ITR 713)(SC) ii.Andaman Timber Industries vs. CIT 2015-TIOL- 255(SC) iii. Mehta Parikh & Co. V. CIT [1956] 30 ITR 181(SC) iv.Dy.CIT CC 7(2) v. M/s. Manba Finance Ltd(ITA.No1448&1467/Mum/2017) v. Dy. CIT CC 6(3) v. M/s. Marathon Fiscal Pvt Ltd(ITA 5783&5784/Mum/2017) vi.ITO 15(1)(3) v. M/s. Celebrity Lifespace Pvt Ltd(ITA.No 6301/Mum/2017) vii. Pr CIT, Central -2 Vs. Skylark Build in ITA No. 616 of 2016( 2018-TIOL-2323)(Mum) ITA Nos. 2055, 2056 & 2057/Mum/20…

Amar Singh Saharan, Churu vs. ITO, Ward-2, Churu

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

ITA 83/JODH/2020[2013-14]Status: DisposedITAT Jodhpur24 Mar 2023AY 2013-14

Bench: Shri Kul Bharatshri Manish Boradshri Amar Singh Saharan, Vs Ito, S/O-Shri Chimna Ram, Ward-2, Dhani-Asha, Tehsil- Churu Taranagar, Churu-331304. (Appellant) (Respondent) Pan No. Drbps4493E Assessee By Shri Suresh Ojha, Advocate Revenue By Shri S.M.Joshi, Jcit Dr Date Of Hearing 23/03/2023 Date Of 24/03/2023 Pronouncement

Section 147

…n affidavit was filed which has already been placed on record. The Assessing Officer (“AO”) did not opt for cross-examining the assessee. Therefore, in view of the judgement of the Hon’ble Supreme Court rendered in the case of Mehta Parikh & Co. Vs CIT [1956] 30 ITR 181 (SC), the Ld.CIT(A) ought to have deleted the addition treating the contents 11 | P a g e of the affidavit as true and correct. It is also brought to our notice that under the identical facts, the Tribunal in the case of Ashok Kumar Banthia vs. DCIT in ITA No.297/Jodh/2019 [Assessment Year 2012-13] order dated 06.09.2021, has held as under:- 10.…

DCIT, Central Circle-1, Noida vs. Aashikyana Civil Contractors P.Ltd, New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 9025/DEL/2019[2014-15]Status: DisposedITAT Delhi23 Mar 2023AY 2014-15

Bench: Sh. C. M. Gargdr. B. R. R. Kumar

For Appellant: NoneFor Respondent: Sh. Kanv Bali, Sr. DR

Section 132Section 153ASection 250(4)Section 68

…tion must be related to some evidence or material placed on record. We relied on following decisions rendered:  Commissioner of Income-tax vs. Greaves Cotton & Co. Ltd., 68 ITR 200, SUPREME COURT OF INDIA  Mehta Parikh & Co. vs. Commissioner of Income-tax, 30 ITR 181, SUPREME COURT OF INDIA  Omar Salay Mohatned Sait Commissioner bf Income-tax, 37 ITR 151, SUPREME COURT OF INDIA  Assistant Commissioner of Income-tax, Central Circle-13, New Delhi vs. Vikrant Puri [2017] 82 taxmann.com 48 (Delhi-Trib.)  Mehul V. Vyas vs. Income-tax Officer, 23(2)(3), Mumbai, [2017] 80 taxmann.com 311 (Mumbai - Trib.)  Income-…

DCIT Circle-3, Mirzapur vs. Shri Neeraj Agrawal, Mirzapur

ITA 138/ALLD/2017[2012-13]Status: DisposedITAT Allahabad14 Mar 2023AY 2012-13

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

For Appellant: Shri. Divyanshu Agrawal, Adv.,Shri RajeevFor Respondent: Shri. A.K. Singh Sr.D.R

Section 143(3)

…the same is discredited in the cross examination or the assessee had failed to produce other supporting evidences which the assessee was called upon to produce. The assessee relied upon following judgments : (i) Mehta Parikh & Co. v. CIT , reported in (1956) 30 ITR 181 (SC) (ii) CIT v. Dharam Pal Premchand Ltd. - 295 ITR (Del HC). Assessment Year: 2012-2013 Mr. Neeraj Agrwal, Mirzapur, U.P. (iii) CIT v. Shankar Lal Ved Prakash – 300 ITR 243 (Del HC). The assessee further submitted before ld. CIT(A) that the allegation of the Ld. AO that the stock register and other documents were not found during the survey or w…

Neeraj Agrawal, Mirzapur vs. DCIT, Mirzapur

ITA 100/ALLD/2017[2012-2013]Status: DisposedITAT Allahabad14 Mar 2023AY 2012-2013

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

For Appellant: Shri. Divyanshu Agrawal, Adv.,Shri RajeevFor Respondent: Shri. A.K. Singh Sr.D.R

Section 143(3)

Dhimant A. Sanghavi, Mumbai vs. ITO-33(1)(4), Mumbai

In the result, the appeal by the assessee is dismissed

ITA 567/MUM/2019[2009-10]Status: DisposedITAT Mumbai11 Jan 2023AY 2009-10

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Prayag JhaFor Respondent: Smt. Mahita Nair

Section 131Section 143(3)Section 250Section 69A

…ted illegal transactions done by him with a clear Intention to evade taxable Income by using various means. v) The affidavit filed by the assessee cannot be taken as evidence as per Hon'ble Supreme Court decision in the case of Mehta Parekh & Co. Vs. CIT (SC) 30 ITR 181. In this case the assessee failed to produce any supporting evidence and parties to prove the truthfulness and correctness of statement made in affidavit. Again the Hon'ble Supreme Court stated in the case A.K.K. Namblar Vs. Union of India AIR 1970 SC 652 pp 654 that If the affidavit is not properly verified it cannot be admitted in evidence as It…

M/S. Srinivas Institute of Medical Science and Research Centre, Mangalroe vs. The Principal Commissioner of Income Tax (Central), Bengaluru

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

ITA 533/BANG/2022[N/A]Status: DisposedITAT Bangalore30 Dec 2022

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: N.A.

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Dr. G. Manoj Kumar, D.R

Section 10Section 11Section 12ASection 269S

…rder on the reason of not providing cross-examination of witnesses whose statements were recorded. M/s. Srinivas Institute of Medical Science and Research Centre, Mangalore Page 42 of 50 (K). The Hon’ble Supreme Court in the case of Mehta Parikh & Co. v. CIT, 30 ITR 181 held as under:- “In the instant case a mere calculation of the nature indulged in by the ITO or the AAC was not enough, without any further scrutiny, to dislodge the position taken up by the assessee, supported as it was, by the entries in the cash book and the affidavits put in by the assessee before the AAC. The Tribunal also fell into the same…

Shrimati. Harbhajan Kaur, Jalandhar vs. Income Tax Officer Ward -1 (20, Jalandhar

In the result, the appeal of the assessee is allowed

ITA 104/ASR/2021[2012-13]Status: DisposedITAT Amritsar20 Dec 2022AY 2012-13

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Surinder Mahajan, CAFor Respondent: Mrs. Kanchan Garg, Sr. DR

Section 142(1)Section 143(2)Section 147Section 148Section 149Section 69

…IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR BEFORE DR. M. L. MEENA, ACCOUNTANT MEMBER AND SH. ANIKESH BANERJEE, JUDICIAL MEMBER I.T.A. No. 104/Asr/2021 Assessment Year: 2012-13 Smt. Harbhajan Kaur, Vs. Income Tax Officer, W/o Sh. Tarlok Singh, Ward-1(2), 1-Virk Enclave, Nakodar Jalandhar Road, Jalandhar (Punjab) [PAN: EPIPB 8277M] (Appellant) (Respondent) Appellant by : Sh. Surinder Mahajan, CA Respondent by : Mrs. Kanchan Garg, Sr. DR Date of Hearing: 17.11.2022 Date of Pronouncement: 20.12.2022 ORDER Per Dr. M. L. Meena, AM: The present appeal has been filed by the assessee ag…

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

…CET (2001) 170 CTR (Guj) 224 (2001) 252 ITR 417 (Guj), Kantilal Bros, vs. Asstt. CIT 1995) 51 TTJ (Pune) 513: (1995) 52 ITO 412 (Pune), Glass Lines Equipment Co. Ltd. v. CIT (2001) 170 CTR (Guj) 470 (2002) 253 ITR 454 (Guj). Mehta Parikh & Co. vs. CIT (1956) 30 ITR 181 (SC) and Chander Mohan Mehta va, Asstt. CIT (Inv.] (1999) 65 TTJ (Pune) 327: (1999) 71 ITD 245 (Pune) applied. (vi) Thus, as per provisions of section 292C and 132(4A) of the Income Tax Act, 1961, the contents of such books of account and other documents seized during the course of search are true and the contents of the seized documents are itse…