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 366,470 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

Rangamani Krishnan, Chennai vs. ACIT, Central Circle-1(2), Chennai

In the result all the five appeals filed by the assessee for the A

ITA 456/CHNY/2025[2018-19]Status: DisposedITAT Chennai17 Jul 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

For Appellant: Shri D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 131Section 142Section 142(1)Section 250Section 69

…w recognizes that where a statement is made by a party, it must be considered in its entirety, and not in isolation. This principle, recognized as the “doctrine of whole truth”, prevents selective appreciation of evidence. In Mehta Parikh & Co. v. CIT [(1956) 30 ITR 181 (SC)], the Hon’ble Supreme Court held that where an assessee makes a statement, the entirety of the statement must be evaluated, and it is impermissible for the Department to accept one part while discarding the rest without independent verification. Applying this principle, the Revenue cannot accept the assessee’s :-25-: ITA. Nos:453 to 457/Chny…

Rangamani Krishnan, Chennai vs. ACIT, Central Circle-1(2), Chennai

In the result all the five appeals filed by the assessee for the A

ITA 455/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Jul 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

For Appellant: Shri D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 131Section 142Section 142(1)Section 250Section 69

…w recognizes that where a statement is made by a party, it must be considered in its entirety, and not in isolation. This principle, recognized as the “doctrine of whole truth”, prevents selective appreciation of evidence. In Mehta Parikh & Co. v. CIT [(1956) 30 ITR 181 (SC)], the Hon’ble Supreme Court held that where an assessee makes a statement, the entirety of the statement must be evaluated, and it is impermissible for the Department to accept one part while discarding the rest without independent verification. Applying this principle, the Revenue cannot accept the assessee’s :-25-: ITA. Nos:453 to 457/Chny…

Rangamani Krishnan, Chennai vs. ACIT, Central Circle-1(2), Chennai

In the result all the five appeals filed by the assessee for the A

ITA 454/CHNY/2025[2016-17]Status: DisposedITAT Chennai17 Jul 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

For Appellant: Shri D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 131Section 142Section 142(1)Section 250Section 69

…w recognizes that where a statement is made by a party, it must be considered in its entirety, and not in isolation. This principle, recognized as the “doctrine of whole truth”, prevents selective appreciation of evidence. In Mehta Parikh & Co. v. CIT [(1956) 30 ITR 181 (SC)], the Hon’ble Supreme Court held that where an assessee makes a statement, the entirety of the statement must be evaluated, and it is impermissible for the Department to accept one part while discarding the rest without independent verification. Applying this principle, the Revenue cannot accept the assessee’s :-25-: ITA. Nos:453 to 457/Chny…

Rangamani Krishnan, Chennai vs. ACIT, Central Circle-1(3), Chennai

In the result all the five appeals filed by the assessee for the A

ITA 453/CHNY/2025[2015-16]Status: DisposedITAT Chennai17 Jul 2025AY 2015-16

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

For Appellant: Shri D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 131Section 142Section 142(1)Section 250Section 69

…w recognizes that where a statement is made by a party, it must be considered in its entirety, and not in isolation. This principle, recognized as the “doctrine of whole truth”, prevents selective appreciation of evidence. In Mehta Parikh & Co. v. CIT [(1956) 30 ITR 181 (SC)], the Hon’ble Supreme Court held that where an assessee makes a statement, the entirety of the statement must be evaluated, and it is impermissible for the Department to accept one part while discarding the rest without independent verification. Applying this principle, the Revenue cannot accept the assessee’s :-25-: ITA. Nos:453 to 457/Chny…

Lalit R Jagawat HUF, Mumbai vs. DCIT 23(2), Mumbai

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

ITA 634/MUM/2025[2017-18]Status: DisposedITAT Mumbai01 Jul 2025AY 2017-18

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarआयकर अपील सुं./Ita No. 634/Mum/2025 (नििाारण वर्ा / Assessment Year :2017-18) Lalit R Jagawat Huf V/S. Dcit, 23(2), 80B Patwa Chawl, Room बिाम Mantru Mandir, Room No. No. 41, 3Rd Floor, Sheikh 114, 1St Floor, Tardeo Road, Momon Street, Zaveri Mumbai-400007 Bazar, Mumbai-400002 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aachj7165D Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri Satya Prakash Singh राजस्व की ओर से /Revenue By: Shri Aditya Rai

For Appellant: Shri Satya Prakash SinghFor Respondent: Shri Aditya Rai
Section 115BSection 250Section 68

…d or the facts found were such that no person acting judicially and properly instructed as to the relevant law could have found, or the finding was, in other words, perverse and this court is entitled to interfere. iii. Mehta Parikh and Company vs. CIT (1956) 30 ITR 181 (SC): the decision of the Tribunal must rest not on suspicion but on legal testimony. iv. Dhakeshwari Cotton Mills vs. CIT (1954) 26 ITR 775 (SC): the Income-tax Officer is not fettered by technical rules of evidence and pleadings, and that he is entitled to act on material which may not be accepted as evidence in a court of law, but there the agr…

Anbhao Parkash S/O Darshan Lal, Village Veere Wala Kalan, Faridkot vs. Income Tax Officer, Ward-3(4), Faridkot, Jurisdictional Assessing Officer, ITO Ward 1, Faridkaot

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

ITA 630/ASR/2024[2012-2013]Status: DisposedITAT Amritsar30 Jun 2025AY 2012-2013

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Sudhir Sehgal, A.R
Section 142(1)Section 143(2)Section 144Section 148Section 250oSection 69

…xamination from the deponent then it would not be opened to the revenue authorities to disagree the facts mentioned in the affidavit. 19. Reliance is being placed on the decision laid down by the Supreme Court in the case of Mehta Parikh & Co. v. CIT [1956] 30 ITR 181(copy enclosed at page 78- 84 of paper book), 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,…

Basharat Saleem Rehtoo, Srinagar vs. DCIT, ACIT Cent. Circle, Srinagar

In the result the appeal of the assessee is allowed

ITA 456/ASR/2024[2019-20]Status: DisposedITAT Amritsar30 Jun 2025AY 2019-20

Bench: Sh. Udayan Dasgupta & Sh. Brajesh Kumar Singh

Section 132ASection 143(3)Section 250Section 44ASection 69A

…d in absence of any contrary materials gathered or brought on record to disprove the declaration, the contents of the same cannot be brushed aside has to be accepted as correct as laid down by the Hon’ble Apex court in the case of Mehta Parikh and Co vs CIT [ 30 ITR 181 ( SC ) ] . 10.4 He further relied upon the decision of the jurisdictional High court in the case of CIT vs VP Singh [2013] 40taxmann.com 162 (Punjab and Haryana) [2014] / 220 Taxman 87 [ P & H] , to submit that when cash balance in balance sheet is disclosed and entries in balance sheet are not disputed by the AO , the opening balance cannot be re…

ACIT, Range-1, Lucknow vs. Motor Fab Sales Pvt. Ltd., Lucknow

In the result, Departmental appeal bearing

ITA 431/LKW/2020[2017-18]Status: DisposedITAT Lucknow30 Jun 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2017-18 M/S Motor Fab Sales Pvt. Ltd. V. The Dcit/Acit-4 11, Mahatma Gandhi Marg Lucknow Hazratganj, Lucknow Tan/Pan:Aaccm5754E (Appellant) (Respondent) Assessment Year: 2017-18 Theacit-1 V. M/S Motor Fab Sales Pvt. Ltd. Lucknow 11, Mahatma Gandhi Marg Hazratganj, Lucknow Tan/Pan:Aaccm5754E (Appellant) (Respondent) Assessee By: Shri Rakesh Garg, Advocate Revenue By: Shri H.S. Usmani, Cit(Dr)

For Appellant: Shri Rakesh Garg, AdvocateFor Respondent: Shri H.S. Usmani, CIT(DR)
Section 115BSection 143(3)Section 68

…l Private Limited vs. ACIT, 115 Taxman.com 342 (Delhi Tribunal). Order of the Tribunal has been upheld by the Hon'ble Delhi High Court in the case of PCIT vs. Agson Global Pvt. Ltd. in ITA No. 68-73/2021, order dated 19.01.2022. 16 Mehta Parikh & Co. vs. CIT, 30 ITR 181 (SC). 17 Laxmi Rice Mills vs. CIT, 97 ITR 258 (Patna). 18 Chunnilal Tikam Chand Coal Co. Ltd., 27 ITR 602 (Patna). 19 Atish Singla vs. ITO Ward 43(7) in ITA No. 1185/Del/2021, order dated 06.04.2022, ITAT, Delhi. 20 Yash Ornaments (P) Ltd. vs. ACIT in ITA No.353/LKW/2020, order dated 23.07.2024, ITAT, Lucknow. 21 Harisons Diamond Pvt. Ltd. vs…

M/S. Motor Fab Sales Pvt. Ltd., Lucknow vs. The DCIT/ACIT-4, Lucknow

In the result, Departmental appeal bearing

ITA 351/LKW/2020[2017-18]Status: DisposedITAT Lucknow30 Jun 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2017-18 M/S Motor Fab Sales Pvt. Ltd. V. The Dcit/Acit-4 11, Mahatma Gandhi Marg Lucknow Hazratganj, Lucknow Tan/Pan:Aaccm5754E (Appellant) (Respondent) Assessment Year: 2017-18 Theacit-1 V. M/S Motor Fab Sales Pvt. Ltd. Lucknow 11, Mahatma Gandhi Marg Hazratganj, Lucknow Tan/Pan:Aaccm5754E (Appellant) (Respondent) Assessee By: Shri Rakesh Garg, Advocate Revenue By: Shri H.S. Usmani, Cit(Dr)

For Appellant: Shri Rakesh Garg, AdvocateFor Respondent: Shri H.S. Usmani, CIT(DR)
Section 115BSection 143(3)Section 68

…l Private Limited vs. ACIT, 115 Taxman.com 342 (Delhi Tribunal). Order of the Tribunal has been upheld by the Hon'ble Delhi High Court in the case of PCIT vs. Agson Global Pvt. Ltd. in ITA No. 68-73/2021, order dated 19.01.2022. 16 Mehta Parikh & Co. vs. CIT, 30 ITR 181 (SC). 17 Laxmi Rice Mills vs. CIT, 97 ITR 258 (Patna). 18 Chunnilal Tikam Chand Coal Co. Ltd., 27 ITR 602 (Patna). 19 Atish Singla vs. ITO Ward 43(7) in ITA No. 1185/Del/2021, order dated 06.04.2022, ITAT, Delhi. 20 Yash Ornaments (P) Ltd. vs. ACIT in ITA No.353/LKW/2020, order dated 23.07.2024, ITAT, Lucknow. 21 Harisons Diamond Pvt. Ltd. vs…

DCIT, New Delhi vs. M/S. Majestic Properties Pvt. Ltd., New Delhi

In the result, the appeal of the revenue in ITA 3115/Del/2014 for AY 2010-11 is partly allowed

ITA 3115/DEL/2014[2010-11]Status: DisposedITAT Delhi27 Jun 2025AY 2010-11

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 115JSection 132Section 153ASection 37(1)

…ies. Hence, it was pointed out that the assessee had duly discharged its onus by rebutting the presumption u/s 292C of the Act. The assessee also placed reliance on the decision of the Hon'ble Supreme Court in the case Mehta Parikh and Co. Vs. CIT reported in 30 ITR 181 (SC) which held affidavit cannot be rejected unless it is put to test or verification or cross examination. It is pertinent to note that affidavit of Mr. Saudagar Shah was filed in May 2009 before the Investigation wing and he expired on 13.12.2010. Hence, the department had practically 18 months time to make independent enquiry of Mr. Saudagar Sh…

DCIT, New Delhi vs. M/S. Majestic Properties Pvt. Ltd., New Delhi

In the result, the appeal of the revenue in ITA 3115/Del/2014 for AY 2010-11 is partly allowed

ITA 1748/DEL/2014[2009-10]Status: DisposedITAT Delhi27 Jun 2025AY 2009-10

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 115JSection 132Section 153ASection 37(1)

…ies. Hence, it was pointed out that the assessee had duly discharged its onus by rebutting the presumption u/s 292C of the Act. The assessee also placed reliance on the decision of the Hon'ble Supreme Court in the case Mehta Parikh and Co. Vs. CIT reported in 30 ITR 181 (SC) which held affidavit cannot be rejected unless it is put to test or verification or cross examination. It is pertinent to note that affidavit of Mr. Saudagar Shah was filed in May 2009 before the Investigation wing and he expired on 13.12.2010. Hence, the department had practically 18 months time to make independent enquiry of Mr. Saudagar Sh…

M/S. Majestic Properties Pvt. Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal of the revenue in ITA 3115/Del/2014 for AY 2010-11 is partly allowed

ITA 1623/DEL/2014[2009-10]Status: DisposedITAT Delhi27 Jun 2025AY 2009-10

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 115JSection 132Section 153ASection 37(1)

…ies. Hence, it was pointed out that the assessee had duly discharged its onus by rebutting the presumption u/s 292C of the Act. The assessee also placed reliance on the decision of the Hon'ble Supreme Court in the case Mehta Parikh and Co. Vs. CIT reported in 30 ITR 181 (SC) which held affidavit cannot be rejected unless it is put to test or verification or cross examination. It is pertinent to note that affidavit of Mr. Saudagar Shah was filed in May 2009 before the Investigation wing and he expired on 13.12.2010. Hence, the department had practically 18 months time to make independent enquiry of Mr. Saudagar Sh…

DCIT, New Delhi vs. Sh. Rajat Gupta, New Delhi

In the result, the appeal of the revenue in ITA 3115/Del/2014 for AY 2010-11 is partly allowed

ITA 3525/DEL/2013[2008-09]Status: DisposedITAT Delhi27 Jun 2025AY 2008-09

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 115JSection 132Section 153ASection 37(1)

…ies. Hence, it was pointed out that the assessee had duly discharged its onus by rebutting the presumption u/s 292C of the Act. The assessee also placed reliance on the decision of the Hon'ble Supreme Court in the case Mehta Parikh and Co. Vs. CIT reported in 30 ITR 181 (SC) which held affidavit cannot be rejected unless it is put to test or verification or cross examination. It is pertinent to note that affidavit of Mr. Saudagar Shah was filed in May 2009 before the Investigation wing and he expired on 13.12.2010. Hence, the department had practically 18 months time to make independent enquiry of Mr. Saudagar Sh…

DCIT, New Delhi vs. M/S. Majestic Properties Pvt. Ltd., New Delhi

In the result, the appeal of the revenue in ITA 3115/Del/2014 for AY 2010-11 is partly allowed

ITA 3289/DEL/2013[2008-09]Status: DisposedITAT Delhi27 Jun 2025AY 2008-09

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 115JSection 132Section 153ASection 37(1)

…ies. Hence, it was pointed out that the assessee had duly discharged its onus by rebutting the presumption u/s 292C of the Act. The assessee also placed reliance on the decision of the Hon'ble Supreme Court in the case Mehta Parikh and Co. Vs. CIT reported in 30 ITR 181 (SC) which held affidavit cannot be rejected unless it is put to test or verification or cross examination. It is pertinent to note that affidavit of Mr. Saudagar Shah was filed in May 2009 before the Investigation wing and he expired on 13.12.2010. Hence, the department had practically 18 months time to make independent enquiry of Mr. Saudagar Sh…

M/S Majestic Properties Pvt. Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal of the revenue in ITA 3115/Del/2014 for AY 2010-11 is partly allowed

ITA 3233/DEL/2013[2008-09]Status: DisposedITAT Delhi27 Jun 2025AY 2008-09

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 115JSection 132Section 153ASection 37(1)

…ies. Hence, it was pointed out that the assessee had duly discharged its onus by rebutting the presumption u/s 292C of the Act. The assessee also placed reliance on the decision of the Hon'ble Supreme Court in the case Mehta Parikh and Co. Vs. CIT reported in 30 ITR 181 (SC) which held affidavit cannot be rejected unless it is put to test or verification or cross examination. It is pertinent to note that affidavit of Mr. Saudagar Shah was filed in May 2009 before the Investigation wing and he expired on 13.12.2010. Hence, the department had practically 18 months time to make independent enquiry of Mr. Saudagar Sh…

Hemendra Ramji Vira, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 2472/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Jun 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

…ed by the assessee on 09/12/2017 was not at all cross examined by the revenue. Thus, the correctness of its contents cannot be doubted at this stage now and the same stands accepted in view of the judgment of the Apex Court in Mehta Parikh & Co. vs CIT (1956) 30 ITR 181 (SC) (LB). 27. Appeals for the AYs 2013-14 to 2015-16 having common set of facts; First of all, the appeals of the above three assessment years have been decided as those have separate facts of additions for exempt LTCG on shares u/s 10(38) and notional commissions paid thereon u/s 69C. The Ld. Counsel submitted that in the statements recorded u/…

Hemendra Ramji Vira, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 2471/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Jun 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

…ed by the assessee on 09/12/2017 was not at all cross examined by the revenue. Thus, the correctness of its contents cannot be doubted at this stage now and the same stands accepted in view of the judgment of the Apex Court in Mehta Parikh & Co. vs CIT (1956) 30 ITR 181 (SC) (LB). 27. Appeals for the AYs 2013-14 to 2015-16 having common set of facts; First of all, the appeals of the above three assessment years have been decided as those have separate facts of additions for exempt LTCG on shares u/s 10(38) and notional commissions paid thereon u/s 69C. The Ld. Counsel submitted that in the statements recorded u/…

Hemendra Ramji Vira, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 2470/MUM/2025[2016-17]Status: DisposedITAT Mumbai26 Jun 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

…ed by the assessee on 09/12/2017 was not at all cross examined by the revenue. Thus, the correctness of its contents cannot be doubted at this stage now and the same stands accepted in view of the judgment of the Apex Court in Mehta Parikh & Co. vs CIT (1956) 30 ITR 181 (SC) (LB). 27. Appeals for the AYs 2013-14 to 2015-16 having common set of facts; First of all, the appeals of the above three assessment years have been decided as those have separate facts of additions for exempt LTCG on shares u/s 10(38) and notional commissions paid thereon u/s 69C. The Ld. Counsel submitted that in the statements recorded u/…

Hemendra Ramji Vira, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 2469/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Jun 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

…ed by the assessee on 09/12/2017 was not at all cross examined by the revenue. Thus, the correctness of its contents cannot be doubted at this stage now and the same stands accepted in view of the judgment of the Apex Court in Mehta Parikh & Co. vs CIT (1956) 30 ITR 181 (SC) (LB). 27. Appeals for the AYs 2013-14 to 2015-16 having common set of facts; First of all, the appeals of the above three assessment years have been decided as those have separate facts of additions for exempt LTCG on shares u/s 10(38) and notional commissions paid thereon u/s 69C. The Ld. Counsel submitted that in the statements recorded u/…

Hemendra Ramji Vira, Mumbai vs. DCIT CC-4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 2468/MUM/2025[2014-15]Status: DisposedITAT Mumbai26 Jun 2025AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

…ed by the assessee on 09/12/2017 was not at all cross examined by the revenue. Thus, the correctness of its contents cannot be doubted at this stage now and the same stands accepted in view of the judgment of the Apex Court in Mehta Parikh & Co. vs CIT (1956) 30 ITR 181 (SC) (LB). 27. Appeals for the AYs 2013-14 to 2015-16 having common set of facts; First of all, the appeals of the above three assessment years have been decided as those have separate facts of additions for exempt LTCG on shares u/s 10(38) and notional commissions paid thereon u/s 69C. The Ld. Counsel submitted that in the statements recorded u/…