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 367,154 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 153ASection 132Section 132(4)Section 69ASection 147Section 69Section 153C

Issues it is cited on

section 158bb(1)retraction of statementsection 158bbsection 131(1a)section 292cstatement under section 132(4)section 132(4a)panchnamasection 153c(1)loose paperssection 132(4)dumb documents

Judgments citing Mehta Parikh & Co. v. CIT

ACIT, Central Circle- 28, New Delhi vs. Agson Global Pvt. Ltd., Delhi

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 5264/DEL/2019[2012-13]Status: DisposedITAT Delhi31 Oct 2019AY 2012-13

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

…nd properly instructed as to the relevant law could have found, or the finding was, in other words, perverse and the Court is entitled to interfere. [para 23] xxviii. On similar facts, the Hon’ble Supreme Court in the case of Mehta Parikh & Co. Vs. CIT (1956) 30 ITR 181 held as under: “The finding of the Tribunal that high denomination notes of the value of Rs. 30,000 represented the concealed profits of the appellant is not supported by any evidence, and is, in consequence, erroneous in point of law and liable to be set aside. The accounts of the appellant have been accepted by the Tribunal as genuine, and it is…

Agson Global Pvt. Ltd, Delhi vs. ACIT CC-28, New Delhi

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 3746/DEL/2019[2017-18]Status: DisposedITAT Delhi31 Oct 2019AY 2017-18

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

…nd properly instructed as to the relevant law could have found, or the finding was, in other words, perverse and the Court is entitled to interfere. [para 23] xxviii. On similar facts, the Hon’ble Supreme Court in the case of Mehta Parikh & Co. Vs. CIT (1956) 30 ITR 181 held as under: “The finding of the Tribunal that high denomination notes of the value of Rs. 30,000 represented the concealed profits of the appellant is not supported by any evidence, and is, in consequence, erroneous in point of law and liable to be set aside. The accounts of the appellant have been accepted by the Tribunal as genuine, and it is…

Agson Global Pvt. Ltd, Delhi vs. ACIT Central Circle-28, New Delhi

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 3745/DEL/2019[2016-17]Status: DisposedITAT Delhi31 Oct 2019AY 2016-17

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

…nd properly instructed as to the relevant law could have found, or the finding was, in other words, perverse and the Court is entitled to interfere. [para 23] xxviii. On similar facts, the Hon’ble Supreme Court in the case of Mehta Parikh & Co. Vs. CIT (1956) 30 ITR 181 held as under: “The finding of the Tribunal that high denomination notes of the value of Rs. 30,000 represented the concealed profits of the appellant is not supported by any evidence, and is, in consequence, erroneous in point of law and liable to be set aside. The accounts of the appellant have been accepted by the Tribunal as genuine, and it is…

Agson Global Pvt. Ltd, Delhi vs. ACIT CC-28, New Delhi

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 3744/DEL/2019[2015-16]Status: DisposedITAT Delhi31 Oct 2019AY 2015-16

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

…nd properly instructed as to the relevant law could have found, or the finding was, in other words, perverse and the Court is entitled to interfere. [para 23] xxviii. On similar facts, the Hon’ble Supreme Court in the case of Mehta Parikh & Co. Vs. CIT (1956) 30 ITR 181 held as under: “The finding of the Tribunal that high denomination notes of the value of Rs. 30,000 represented the concealed profits of the appellant is not supported by any evidence, and is, in consequence, erroneous in point of law and liable to be set aside. The accounts of the appellant have been accepted by the Tribunal as genuine, and it is…

Bina Aggarwal, New Delhi vs. ACIT Central Circle-08, New Delhi

Appeal of the assessee is allowed and the stay application is dismissed

ITA 2349/DEL/2019[2015-16]Status: DisposedITAT Delhi30 Oct 2019AY 2015-16

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

Section 132Section 139(1)Section 139(4)Section 153ASection 69A

…serving document and the facts stated therein cannot be accepted as evidence. It is the settled principle of law that the decision must rest not on suspicion but on legal testimony. The Ld. AR relied upon the decision of Mehta Parikh & Co. vs. CIT reported in 30 ITR 181 (SC). Thus, the Ld. AR submitted that it is well established by the assessee during the assessment proceedings that the assessee has not sold any part of the jewellery and accordingly the allegations made by the Assessing Officer and the CIT(A) are merely on the basis of surmises and are without any cogent evidence. The Ld. AR prayed that the addi…

Sri Vikas Baburao Jadhav, Ramanagar vs. The Income Tax Officer Ward-1, Ramanagar

In the result, the assessee’s appeal for Assessment Year 2009-10 is allowed

ITA 3051/BANG/2018[2009-10]Status: DisposedITAT Bangalore04 Sept 2019AY 2009-10

Bench: Shri Jason P. Boazassessment Year : 2009-10 Shri. Vikas Baburao Jadhav, Vs. The Income-Tax Officer, No.616, Thulasi Gardens Street, Ward – 1, Channapatna, Ramanagar. Ramanagar – 562 160. Pan : Ajopj 2076 Q Appellant Respondent

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Ganesh R. G., Advocate
Section 133ASection 143(3)Section 144

…mounts to the assessee; which details has been noted by the AO at para 10 on page 9 of the impugned order of assessment. In this regard, the learned AR placed reliance on the decision of the Hon’ble Apex Court in the case of Mehta Parikh & Co., Vs. CIT (1956) 30 ITR 181 (SC) for the proposition that once an Affidavit is filed, the same cannot be brushed aside or discarded and has to be duly considered as a valid piece of evidence. It was prayed that the addition of Rs.23,18,590/- on account of unsecured loan creditors be deleted in the light of the fact that the assessee has discharged the onus by filing the loan…

DCIT Cen Cir 23 Cen RG 7, Mumbai vs. Kanakia Hospitality P.Ltd, Mumbai

ITA 3186/MUM/2014[2011-12]Status: DisposedITAT Mumbai07 Aug 2019AY 2011-12

Bench: Shri G. Manjunatha & Shri Ravish Sooddeputy Commissioner Of Kanakia Hospitality Pvt. Ltd. Income Tax, Central Circle-23, 10Th Floor, 215, Autrium Room No. 409, 4Th Floor, Andheri Kurla Road, Vs. Aayakar Bhavan, Andheri (East) M.K. Road, Churchgate, Mumbai 400 059 Mumbai – 400020 Pan – Aacck7755R (Appellant) (Respondent) Kanakia Hospitality Pvt. Ltd. Deputy Commissioner Of 10Th Floor, 215 Autrium, Income Tax, Central Circle-23, Near Meriott Courtyad Hotel, Room No. 409, 4Th Floor, Andheri Kurla Road, Vs. Aayakar Bhavan, Andheri (East) M.K. Road, New Marine Lines, Mumbai 400 053 Mumbai – 400 020

For Appellant: Shri B.Srinivas, D.RFor Respondent: Shri Vijay Mehta, A.R
Section 132Section 143(3)

…(2001)170 CTR (GuI) 224: (2001) 252 ITR 417 (Guj), Kantilal Bros. vs. Asstt. CIT (1995) 51 TTJ (Pune) 513 : (1995) 52 ITD 412 (Pune), Glass Lines Equipment Co. Ltd. vs. 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 vs. Asstt. CIT (Inv.) (1999) 65 1TJ (Pune) 327: (1999) 71 ITD 245 (Rune) applied.” 14. It has also been brought to my notice by the appellant that the Hon'ble Settlement Commission, Mumbai Bench, had allowed capitalization of various expenses out of bogus purchases in the case of M/s. Kanakia Spaces Pvt. Ltd., appellan…

Asst CIT 25(3), Mumbai vs. Rajul V. Vora, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 2575/MUM/2017[2012-13]Status: DisposedITAT Mumbai26 Jul 2019AY 2012-13

Bench: Shri G.S. Pannu & Shri Ram Lal Negi: A.Y : 2012-13

For Appellant: Dr. Rajeev HaritFor Respondent: Dr. K. Shivaram
Section 143(3)Section 69

…M/s. Dosti Enterprises. It was thus argued that when an Affidavit is filed, the same is deemed to be correct unless proved otherwise. In support of this, he relied on the decision of the Hon'ble Supreme Court in the case of Mehta Parikh & Co. vs. CIT, (1956) 30 ITR 181 (SC). It was also argued that when the government authorities concerned with the development of land has considered the firm as the owner, the Department cannot take a different stand. 12. We have carefully considered the rival submissions and perused the material on record. We find that the limited issue before us is as to whether the property a…

Yug Developers, Mumbai vs. ACIT-17(3), Mumbai

In the result, both the appeals of the assessee are partly allowed

ITA 7130/MUM/2018[2013-14]Status: DisposedITAT Mumbai17 Jul 2019AY 2013-14

Bench: Shri Pawan Singh, Jm & Shri M.Balaganesh, Am

Section 143(3)

…ions before the ld AO which had not been disputed. Once the averments made in an affidavit are not disputed or refuted, the same are to be construed as true and correct, as held by the Hon’ble Supreme Court in the case of Mehta Parikh & Co. vs CIT reported in 30 ITR 181 (SC). 6.7. With regard to the reliance placed by the ld DR on the decision of Hon’ble Gujarat High Court in the case of Pavankumar M Sanghvi vs ITO reported in 404 ITR 601 (Guj) , we find that in that case , the assessee received loans from two companies who were found to be shell companies not doing any businesses and were maintaining minimum ba…

ACIT, Cir--1, Thane vs. Devilal B.Jain, Thane

ITA 4230/MUM/2017[2010-11]Status: DisposedITAT Mumbai17 Jun 2019AY 2010-11

Bench: Hon’Ble Sh. Sandeep Gosain, Jm & Hon’Ble Sh. M. Balaganesh, Am आयकरअपीलसं./ I.T.A. No. 4230/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2010-11) In The Matter Of:-

For Respondent: Shri Nilesh Joshi, AR
Section 143(3)Section 3Section 68

…n. The affidavits have also been given by them in a very causal and routine manner without application of mind. In this background, the said suppliers were required to be examined as held by Hon'ble Supreme Court in the case of Mehat Parikh & Co v. CIT (1956) 30 ITR 181. Further the assessee has also submitted that he was making the purchases through the broker and hardly came in contact these parties. The broker in his statement has also stated that in case the ^suppliers were not able to provides the bill for the supply made by them, he arranged bills for the material from the other contacts in the market. The…

Shri Ramesh Chand Mittal, Kota vs. Income Tax Officer, Ward-2-2, Kota

In the result, appeal of the assessee is allowed in part

ITA 954/JPR/2018[2012-13]Status: DisposedITAT Jaipur11 Jun 2019AY 2012-13
For Appellant: Shri B.L. Bhojwani (CA)For Respondent: Shri Karni Dan (JCIT)
Section 143(3)Section 68

…fidavit unless the person who gave the affidavit was put to cross examination and, if put to cross examination, not unless the Assessing Officer has found fault with the same : 4 ITA 954/JP/2018_ Ramesh Chand Mittal Vs. ITO - Mehta Parikh & Co. v. CIT (1956) 30 ITR 181 (SC) - Dilip Kumar Roy v. CIT (1974) 94 ITR 1 (Bom.) - Rajshree Synthetics P. Ltd. v. CIT (2002) 256 ITR 331 (Raj.) 7. From the record we found that income of the donor during the year was Rs. 2,49,712/-. She was mother in law of the assessee having sufficient cash in hand as on 31/03/2011. For this effect, the assessee has also filed statement s…

Assistant Commissioner of Income Tax, Central Circle-3, Jaipur vs. M/S. Kedia Real Estate LLP, Jaipur

In the result, appeals of the revenue are dismissed whereas appeals of the assessee are allowed in part

ITA 289/JPR/2019[2017-18]Status: DisposedITAT Jaipur03 Jun 2019AY 2017-18
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 132(1)Section 143(3)Section 153A

…t should be accepted as admissible evidence. The AO has not rebutted the contents of the affidavits. The contents of affidavits, which are not vague should be accepted correct. Reliance is placed on the following decisions:- (i) Mehta Parikh & Co v CIT [1958] 30 ITR 181 (SC) (ii) Dilip Kumar Rao Vs CIT (1974) 94 ITR 1 (Bom); (iii) Malwa Knitting Works Vs CIT (1977) 107 ITR 379, 381 MP 73. With regard to addition of Rs. 33,14,580/- as per Ext.-10 Annexure-A, we observe that the assessee gave the following explanation to AO: - “This is rough estimates made regarding Sanganer office renovation expenses. Actually no…

Deputy Commissioner of Income Tax, Central Circle-3, Jaipur vs. Shri Nirmak Kumar Kedia, Jaipur

In the result, appeals of the revenue are dismissed whereas the appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 288/JPR/2019[2017-18]Status: DisposedITAT Jaipur03 Jun 2019AY 2017-18
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 131Section 132Section 132(1)Section 133ASection 143(3)Section 153ASection 19

…vidence, in so far as the AO has not rebutted the contents of the affidavits. The contents of affidavits, which are not vague should be accepted correct. For this proposition, reliance is placed on the following decisions: - (i) Mehta Parikh & Co v CIT [1958] 30 ITR 181 (SC) (ii) Dilip Kumar Rao Vs CIT (1974) 94 ITR 1 (Born); (iii) Malwa Knitting Works Vs CIT (1977) 107 ITR 379, 381 MP (iv) Sri Krishna Vs CIT (1983) 142 ITR 618 (All). 23. While deleting the addition of Rs. 1,14,16,666/- out of addition of Rs. 1,22,26,044/-, the ld. CIT (A) sustained the addition of Rs. 50 ITA 124 to 126/JP/2019 & 286 to 288/JP/…

Assistant Commissioner of Income Tax, Central Circle-3, Jaipur vs. Shri Nirmal Kumar Kedia, Jaipur

In the result, appeals of the revenue are dismissed whereas the appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 287/JPR/2019[2016-17]Status: DisposedITAT Jaipur03 Jun 2019AY 2016-17
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 131Section 132Section 132(1)Section 133ASection 143(3)Section 153ASection 19

…vidence, in so far as the AO has not rebutted the contents of the affidavits. The contents of affidavits, which are not vague should be accepted correct. For this proposition, reliance is placed on the following decisions: - (i) Mehta Parikh & Co v CIT [1958] 30 ITR 181 (SC) (ii) Dilip Kumar Rao Vs CIT (1974) 94 ITR 1 (Born); (iii) Malwa Knitting Works Vs CIT (1977) 107 ITR 379, 381 MP (iv) Sri Krishna Vs CIT (1983) 142 ITR 618 (All). 23. While deleting the addition of Rs. 1,14,16,666/- out of addition of Rs. 1,22,26,044/-, the ld. CIT (A) sustained the addition of Rs. 50 ITA 124 to 126/JP/2019 & 286 to 288/JP/…

Assistant Commissioner of Income Tax, Central Circle-3, Jaipur vs. Shri Nitin Kedia, Jaipur

In the result, appeals of the revenue are dismissed whereas the appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 286/JPR/2019[2015-16]Status: DisposedITAT Jaipur03 Jun 2019AY 2015-16
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 131Section 132Section 132(1)Section 133ASection 143(3)Section 153ASection 19

…vidence, in so far as the AO has not rebutted the contents of the affidavits. The contents of affidavits, which are not vague should be accepted correct. For this proposition, reliance is placed on the following decisions: - (i) Mehta Parikh & Co v CIT [1958] 30 ITR 181 (SC) (ii) Dilip Kumar Rao Vs CIT (1974) 94 ITR 1 (Born); (iii) Malwa Knitting Works Vs CIT (1977) 107 ITR 379, 381 MP (iv) Sri Krishna Vs CIT (1983) 142 ITR 618 (All). 23. While deleting the addition of Rs. 1,14,16,666/- out of addition of Rs. 1,22,26,044/-, the ld. CIT (A) sustained the addition of Rs. 50 ITA 124 to 126/JP/2019 & 286 to 288/JP/…

Nitin Kedia, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, appeals of the revenue are dismissed whereas appeals of the assessee are allowed in part

ITA 128/JPR/2019[2015-16]Status: DisposedITAT Jaipur03 Jun 2019AY 2015-16
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 132(1)Section 143(3)Section 153A

…t should be accepted as admissible evidence. The AO has not rebutted the contents of the affidavits. The contents of affidavits, which are not vague should be accepted correct. Reliance is placed on the following decisions:- (i) Mehta Parikh & Co v CIT [1958] 30 ITR 181 (SC) (ii) Dilip Kumar Rao Vs CIT (1974) 94 ITR 1 (Bom); (iii) Malwa Knitting Works Vs CIT (1977) 107 ITR 379, 381 MP 73. With regard to addition of Rs. 33,14,580/- as per Ext.-10 Annexure-A, we observe that the assessee gave the following explanation to AO: - “This is rough estimates made regarding Sanganer office renovation expenses. Actually no…

M/S. Kedia Real Estate LLP, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, appeals of the revenue are dismissed whereas appeals of the assessee are allowed in part

ITA 127/JPR/2019[2017-18]Status: DisposedITAT Jaipur03 Jun 2019AY 2017-18
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 132(1)Section 143(3)Section 153A

…t should be accepted as admissible evidence. The AO has not rebutted the contents of the affidavits. The contents of affidavits, which are not vague should be accepted correct. Reliance is placed on the following decisions:- (i) Mehta Parikh & Co v CIT [1958] 30 ITR 181 (SC) (ii) Dilip Kumar Rao Vs CIT (1974) 94 ITR 1 (Bom); (iii) Malwa Knitting Works Vs CIT (1977) 107 ITR 379, 381 MP 73. With regard to addition of Rs. 33,14,580/- as per Ext.-10 Annexure-A, we observe that the assessee gave the following explanation to AO: - “This is rough estimates made regarding Sanganer office renovation expenses. Actually no…

Shri Nirmak Kumar Kedia, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, appeals of the revenue are dismissed whereas the appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 126/JPR/2019[2017-18]Status: DisposedITAT Jaipur03 Jun 2019AY 2017-18
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 131Section 132Section 132(1)Section 133ASection 143(3)Section 153ASection 19

…vidence, in so far as the AO has not rebutted the contents of the affidavits. The contents of affidavits, which are not vague should be accepted correct. For this proposition, reliance is placed on the following decisions: - (i) Mehta Parikh & Co v CIT [1958] 30 ITR 181 (SC) (ii) Dilip Kumar Rao Vs CIT (1974) 94 ITR 1 (Born); (iii) Malwa Knitting Works Vs CIT (1977) 107 ITR 379, 381 MP (iv) Sri Krishna Vs CIT (1983) 142 ITR 618 (All). 23. While deleting the addition of Rs. 1,14,16,666/- out of addition of Rs. 1,22,26,044/-, the ld. CIT (A) sustained the addition of Rs. 50 ITA 124 to 126/JP/2019 & 286 to 288/JP/…

Shri Nirmal Kumar Kedia, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, appeals of the revenue are dismissed whereas the appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 125/JPR/2019[2016-17]Status: DisposedITAT Jaipur03 Jun 2019AY 2016-17
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 131Section 132Section 132(1)Section 133ASection 143(3)Section 153ASection 19

…vidence, in so far as the AO has not rebutted the contents of the affidavits. The contents of affidavits, which are not vague should be accepted correct. For this proposition, reliance is placed on the following decisions: - (i) Mehta Parikh & Co v CIT [1958] 30 ITR 181 (SC) (ii) Dilip Kumar Rao Vs CIT (1974) 94 ITR 1 (Born); (iii) Malwa Knitting Works Vs CIT (1977) 107 ITR 379, 381 MP (iv) Sri Krishna Vs CIT (1983) 142 ITR 618 (All). 23. While deleting the addition of Rs. 1,14,16,666/- out of addition of Rs. 1,22,26,044/-, the ld. CIT (A) sustained the addition of Rs. 50 ITA 124 to 126/JP/2019 & 286 to 288/JP/…

Shri Nirmal Kumar Kedia, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, appeals of the revenue are dismissed whereas the appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 124/JPR/2019[2015-16]Status: DisposedITAT Jaipur03 Jun 2019AY 2015-16
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 131Section 132Section 132(1)Section 133ASection 143(3)Section 153ASection 19

…vidence, in so far as the AO has not rebutted the contents of the affidavits. The contents of affidavits, which are not vague should be accepted correct. For this proposition, reliance is placed on the following decisions: - (i) Mehta Parikh & Co v CIT [1958] 30 ITR 181 (SC) (ii) Dilip Kumar Rao Vs CIT (1974) 94 ITR 1 (Born); (iii) Malwa Knitting Works Vs CIT (1977) 107 ITR 379, 381 MP (iv) Sri Krishna Vs CIT (1983) 142 ITR 618 (All). 23. While deleting the addition of Rs. 1,14,16,666/- out of addition of Rs. 1,22,26,044/-, the ld. CIT (A) sustained the addition of Rs. 50 ITA 124 to 126/JP/2019 & 286 to 288/JP/…