Nagarjuna Construction Co. Ltd. v. Dy. CIT

23 Taxmann.com 239Income Tax Appellate Tribunal2012#2328 most cited

What is Nagarjuna Construction Co. Ltd. v. Dy. CIT authority for?

Additions cannot be made solely based on unsigned note books or loose slips seized during a search without corroborative material or an established nexus to the accrual or receipt of income, as such documents lack independent evidentiary value.

50

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2025.

Also referred to as

Nagarjuna Construction Co. Ltd. v. Dy. CIT · section 132 · section 292C · unsigned note books · loose slips · seized material · evidentiary value · corroborative evidence · search assessment · additions · dumb documents

Issues it is cited on

Judgments citing Nagarjuna Construction Co. Ltd. v. Dy. CIT

ACIT, CC, AGRA, AGRA vs. M/S. UNITED FARM PRODUCT PRIVATE LIMITED, AGRA

In the result, appeal preferred by the revenue is dismissed

ITA 299/AGR/2025[2022-23]Status: DisposedITAT Agra04 Dec 2025AY 2022-23

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhacit, Cc, Vs. M/S. United Farm Product Pvt. Ltd., 2/220, 2Nd Floor, Glory Plaza, Agra. Soor Sadan, M.G. Road, Agra – 282 002 (Agra) (Pan :Aaccu2505M) (Appellant) (Respondent) Assessee By : Shri Sudhir Sehgal, Advocate Shri Deependra Mohan, Ca Revenue By : Shri Arun Kumar Yadav, Cit Dr Date Of Hearing : 13.10.2025 Date Of Order : 04.12.2025 O R D E R Per S. Rifaur Rahman,Am: 1. This Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income-Tax (Appeals), Kanpur – 4 Dated 28.03.2025 For Assessment Year2022-23 Raising Following Grounds Of Appeal :- “L. Whether On Facts & Circumstances Of The Case & In Law. The Ld. Cit(A)-Iv. Kanpur Has Erred In Deleting The Addition Of Rs.43,71,37,934/- On Account Of Unexplained Expenditure U/S 69C Of The Act Incurred For Construction Of Plant At Mewat, Haryana, Without Appreciating The Fact That The Assessee Company Itself Has Surrendered Amount Of Rs.41,40,35,700/- & Admitted To Take The Unexplained Expenditure At Rs.43,71,37,934/- Incurred In The 2 Construction Of Said Plant. Hence, The Addition Made By The Ao Is Based On Admittance By The Assessee, Which Is Corroborated By The Incriminating Material Found During The Course Of Search. 2. Whether On Facts & Circumstances Of The Case & In Law, Ld. Cit(A)-Iv. Kanpur Has Erred In Deleting The Addition. Without Appreciating The Facts That The Assessing Officer Has Passed The Assessment Order After Thoroughly Examining & Analysing The Seized Material & Proper Appreciation Of Facts Of Unexplained Expenditure U/S 69C Of The Act.”

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 69C

…IN THE INCOME TAX APPELLATE TRIBUNAL AGRA BENCH ‘DB’: AGRA BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER ACIT, CC, vs. M/s. United Farm Product Pvt. Ltd., 2/220, 2nd Floor, Glory Plaza, Agra. Soor Sadan, M.G. Road, Agra – 282 002 (Agra) (PAN :AACCU2505M) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Sudhir Sehgal, Advocate Shri Deependra Mohan, CA REVENUE BY : Shri Arun Kumar Yadav, CIT DR Date of Hearing : 13.10.2025 Date of Order : 04.12.2025 O R D E R PER S. RIFAUR RAHMAN,AM: 1. This appeal is filed by the Revenue against the order of ld. Commissioner of Income-tax (…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. KASTHOORI RAJA DHANUSH, CHENNAI

In the result, all the appeals of the Revenue and Cross-Objections

ITA 3192/CHNY/2024[2020-21]Status: DisposedITAT Chennai30 Jun 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3188 To 3192/Chny/2024 निर्धारणवर्ष/Assessment Years: 2015-16, 2016-17, 2017-18, 2019-20 & 2020-21 & Cross-Objection Nos.22 To 26/Chny/2025 निर्धारणवर्ष/Assessment Years: 2015-16, 2016-17, 2017-18, 2019-20 & 2020-21 The Acit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement V. : : : : Kasthoori Raja Dhanush, Old No.16/5, New No.33/5, Rajamannar Street, Thyagaraya Nagar, Chennai-600 017. [Pan: Actpv 0618 E] (प्रत्यर्थी/Respondent/Cross- Objector) Mrs. Sheila Parthasarthy, Cit Mr. N. Arjun Raj, Advocate 28.04.2025 30.06.2025 आदेश / Order Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals) 19, Chennai (Hereinafter Referred To As `Ld.Cit(A) `) All Dated 17.10.2024 For The

Section 132Section 153ASection 15ASection 271D

…the Ld. CIT(A) had rightly held the impugned seized material to be unreliable and thereby deleted the addition impugned before us. Our view finds support from the decision of this Tribunal at Hyderabad in in case of Nagarjuna Construction Co. Ltd. v. Dy. CIT (52 SOT 178)wherein in similar factual context, it was held as under:- ".The basis for addition is only note book/loose slips. These note books/loose slips are unsigned documents. The Assessing Officer has not ==End of OCR for page 45== established nexus between the note book loose slips with accrual actual/receipt of interest. The note book/loose slips seize…

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