Paramjit Singh v. ITO

323 ITR 588High Court2010#1947 most cited

What is Paramjit Singh v. ITO authority for?

A registered sale deed, including the sale consideration disclosed therein, cannot be disregarded or contradicted by oral evidence, as documents containing all terms and conditions preclude such oral testimony.

59

judgments rely on this decision, according to BharatTax’s citation analysis of 366,459 Indian tax judgments — from 2014 to 2026.

Also referred to as

Paramjit Singh v. ITO · 323 ITR 588 · registered sale deed · sale consideration · oral evidence inadmissible · Section 69 · Section 69B · Section 69C · evidentiary value · written document · unexplained investments · income tax

Issues it is cited on

Judgments citing Paramjit Singh v. ITO

Mangal Annasaheb Jadhav, Pune vs. Income Tax Officer, Ahmednagar

In the result, Ground No.1 and 2 are dismissed and Ground

ITA 665/PUN/2017[2012-13]Status: DisposedITAT Pune06 May 2022AY 2012-13

Bench: Shri Satbeer Singh Godara, Jm & Dr. Dipak P. Ripote, Am आयकरअपीलसं. / Ita No.665/Pun/2017 िनधा"रणवष" / Assessment Year : 2012-13 Mangal A. Jadhav, The Income Tax Officer, Ward-1, M/S.Shah Khandelwal Jain & Vs Ahmednagar. Associates, Level 3, Riverside Business Bay, Plot No.84, Wellesley Road, Near Rto, Pune - 411001. Pan: Ahypj 9285 D Appellant/ Revenue Respondent/ Assessee Assessee By Shri Rajiv Thakkar – Ar Revenue By Shri S P Walimbe - Dr Date Of Hearing 19/04/2022 Date Of Pronouncement 06/05/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)-2, Pune Dated 09.12.2016For The Assessment Year 2012-13. The Assessee Raised The Following Grounds Of Appeal: “1. On Facts & Circumstances Prevailing In The Case & As Per Provisions Fit Scheme Of The Income-Tax Act, 1961 (‘The Act’) It Be Held That Addition Of Rs. 10,57,073/- Made By The Ao, Doubting The Opening Cash Balance Which Is Further Deposited Into Bank & Upheld By Cit(A), Is Merely On- Guesswork & Conjectures & Is Improper, Unjustified, Incorrect & Contrary To Provisions Of Law & Facts Prevailing In The Case. No Such Addition Is Warranted In The Case Of The Appellant. The Addition Made By The Ao & Upheld By Cit (A) Be Deleted. The Appellant Be Granted Just & Proper Relief In This Respect. 2. On Facts & Circumstances Prevailing In The Case & As Per Provisions & Scheme Of The Income-Tax Act, 1961 (‘The Act’) It Be Held That Addition Of Rs. 60,00,000/- Made By Theao, Doubting The Advances Against Booking Of Flats Received In Cash In Which Were Further Deposited Into Bank & Upheld By Cit(A), Is Merely On Guesswork & Conjectures & Is Improper, Unjustified, Incorrect & Contrary To Provisions Of Law & Facts Prevailing

…title always follows possession. Chuharmal vs CIT (1988) 172 ITR 250 (SC). Documentary evidence plays an important part in law. The Courts attach great value for documentary evidence. The Punjab & Haryana High Court in the case of Paramjit Singh Vs ITO (2010) 323 ITR 588 (P & H) pointed out that oral evidence is not conclusive as against documentary evidence under sections 91 and 92 of the Indian Evidence Act, 1872. 4.2.13 In view of the aforesaid discussion on the facts of the case and decisions cited, I hold that the Assessing Officer has rightly treated the amount of Rs.60,00,000/- shown to have been received…

Sh.Baljit Singh Bachal, Ambala vs. ITO, W-1, Amabal

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

ITA 12/CHANDI/2020[2012-13]Status: DisposedITAT Chandigarh30 Jul 2021AY 2012-13

Bench: Shri N.K. Saini & Shri R.L Negiआयकरअपीलसं./Ita No.12/Chd/2020 "नधा"रणवष" / Assessment Year :2012-13 Sh. Baljit Singh Bachal, बनाम The Ito, Vpo-Panjokhera Sahib, Ward-1, Ambala 134011 Ambala "थायीलेखासं./Pan No: Banpb3278H अपीलाथ"/Appellant ""यथ"/Respondent Hearing Through Video Conferencing "नधा"रतीक"ओरसे/Assessee By : Sh. Sudhir Sehgal, Advocate राज"वक"ओरसे/ Revenue By : Smt. Meenahkshi Vohra, Addl. Cit सुनवाईक"तार"ख/Date Of Hearing : 04.05.2021 उदघोषणाक"तार"ख/Date Of Pronouncement : 30. 07.2021 आदेश/Order Perr.L. Negi:

For Appellant: Sh. Sudhir Sehgal, AdvocateFor Respondent: Smt. Meenahkshi Vohra, Addl. CIT
Section 142(1)Section 143(2)Section 144Section 147Section 148

…Bachal, Ambala 5 confirming the addition of Rs. 1,26,00,000/- as undisclosed investment u/s 69 of the Income Tax Act. 4. That the reliance by the Ld. CIT(A) on the judgment of Hon'ble Punjab a Haryana High Court in the case of Paramjit Vs ITO as reported in 323 ITR 588, is wholly misconceived and it is not applicable the facts of the case. 5. That the appellant craves leave to add or amend the grounds of appeal before the appeal is finally heard or disposed of. 6. At the outset the learned counsel for the assessee submitted that the assessee does not want to press ground No. 1 and 2 of its appeal. Accordingly…

DCIT, New Delhi vs. M/S. Sindhu Trade Links Ltd., New Delhi

The appeals are partly allowed for statistical purpose

ITA 2652/DEL/2014[2008-09]Status: DisposedITAT Delhi11 Sept 2020AY 2008-09

Bench: Shri R. K. Panda & Ms Suchitra Kamblesindhu Trade Links Ltd. Vs Addl. Cit(A) 129, Transport Centre, New Range-8 Rohtak Road New Delhi Punjabi Bagh New Delhi (Respondent) Aaacs0447A (Appellant) Dcit Vs Sindhu Trade Links Ltd. Central Circle-21 129, Transport Centre, New New Delhi Rohtak Road (Appellant) Punjabi Bagh New Delhi Aaacs0447A (Respondent) Vs Sindhu Trade Links Ltd. Dcit 129, Transport Centre, New Circle-8(1) Rohtak Road New Delhi Punjabi Bagh New Delhi (Respondent) Aaacs0447A (Appellant) Appellant By Sh. Salil Kapoor, Adv Respondent By Sh. Saras Kumar, Sr. Dr Date Of Hearing 16.07.2020 Date Of Pronouncement 11.09.2020 Orders Dated 21/2/2014 For Assessment Year 2008-09 & 2009-10 Respectively Passed By Cit(A)’S-Xi, New Delhi.

Section 14ASection 2(22)Section 69

…ence, no addition can be made merely on the basis of presumption. The onus is on the revenue to prove the same. The Ld. AR relied upon the following decisions: a. ITO vs. Venue Proteins Industries (2010) 195 Taxman 14 (Ahmd.) b. Paramjit Singh vs. ITO (2010) 323 ITR 588 (P & H HC) 25. We have heard both the parties and perused all the relevant material available on record. It can be seen that the assessee company had purchased land at Tifra Bilaspur for Rs. 55,44,800/- including stamp duty and registration charges of Rs. 7,06,705/-. The Ld. DR submitted that as per the observations of the Assessing Officer there…

M/S. Sindhu Trade Links Ltd., New Delhi vs. DCIT, New Delhi

The appeals are partly allowed for statistical purpose

ITA 2429/DEL/2014[2009-10]Status: DisposedITAT Delhi11 Sept 2020AY 2009-10

Bench: Shri R. K. Panda & Ms Suchitra Kamblesindhu Trade Links Ltd. Vs Addl. Cit(A) 129, Transport Centre, New Range-8 Rohtak Road New Delhi Punjabi Bagh New Delhi (Respondent) Aaacs0447A (Appellant) Dcit Vs Sindhu Trade Links Ltd. Central Circle-21 129, Transport Centre, New New Delhi Rohtak Road (Appellant) Punjabi Bagh New Delhi Aaacs0447A (Respondent) Vs Sindhu Trade Links Ltd. Dcit 129, Transport Centre, New Circle-8(1) Rohtak Road New Delhi Punjabi Bagh New Delhi (Respondent) Aaacs0447A (Appellant) Appellant By Sh. Salil Kapoor, Adv Respondent By Sh. Saras Kumar, Sr. Dr Date Of Hearing 16.07.2020 Date Of Pronouncement 11.09.2020 Orders Dated 21/2/2014 For Assessment Year 2008-09 & 2009-10 Respectively Passed By Cit(A)’S-Xi, New Delhi.

Section 14ASection 2(22)Section 69

…ence, no addition can be made merely on the basis of presumption. The onus is on the revenue to prove the same. The Ld. AR relied upon the following decisions: a. ITO vs. Venue Proteins Industries (2010) 195 Taxman 14 (Ahmd.) b. Paramjit Singh vs. ITO (2010) 323 ITR 588 (P & H HC) 25. We have heard both the parties and perused all the relevant material available on record. It can be seen that the assessee company had purchased land at Tifra Bilaspur for Rs. 55,44,800/- including stamp duty and registration charges of Rs. 7,06,705/-. The Ld. DR submitted that as per the observations of the Assessing Officer there…

M/S. Sindhu Trade Links Ltd., New Delhi vs. Addl.CIT, New Delhi

The appeals are partly allowed for statistical purpose

ITA 2428/DEL/2014[2008-09]Status: DisposedITAT Delhi11 Sept 2020AY 2008-09

Bench: Shri R. K. Panda & Ms Suchitra Kamblesindhu Trade Links Ltd. Vs Addl. Cit(A) 129, Transport Centre, New Range-8 Rohtak Road New Delhi Punjabi Bagh New Delhi (Respondent) Aaacs0447A (Appellant) Dcit Vs Sindhu Trade Links Ltd. Central Circle-21 129, Transport Centre, New New Delhi Rohtak Road (Appellant) Punjabi Bagh New Delhi Aaacs0447A (Respondent) Vs Sindhu Trade Links Ltd. Dcit 129, Transport Centre, New Circle-8(1) Rohtak Road New Delhi Punjabi Bagh New Delhi (Respondent) Aaacs0447A (Appellant) Appellant By Sh. Salil Kapoor, Adv Respondent By Sh. Saras Kumar, Sr. Dr Date Of Hearing 16.07.2020 Date Of Pronouncement 11.09.2020 Orders Dated 21/2/2014 For Assessment Year 2008-09 & 2009-10 Respectively Passed By Cit(A)’S-Xi, New Delhi.

Section 14ASection 2(22)Section 69

…ence, no addition can be made merely on the basis of presumption. The onus is on the revenue to prove the same. The Ld. AR relied upon the following decisions: a. ITO vs. Venue Proteins Industries (2010) 195 Taxman 14 (Ahmd.) b. Paramjit Singh vs. ITO (2010) 323 ITR 588 (P & H HC) 25. We have heard both the parties and perused all the relevant material available on record. It can be seen that the assessee company had purchased land at Tifra Bilaspur for Rs. 55,44,800/- including stamp duty and registration charges of Rs. 7,06,705/-. The Ld. DR submitted that as per the observations of the Assessing Officer there…