PCIT v. Best Infrastructure (India) (P.) Ltd.

397 ITR 82High Court2017#66 most cited

What is PCIT v. Best Infrastructure (India) (P.) Ltd. authority for?

A statement recorded under Section 132(4) of the Income Tax Act, 1961, does not by itself constitute incriminating material for making additions to income.

786

judgments rely on this decision, according to BharatTax’s citation analysis of 367,725 Indian tax judgments — from 2017 to 2026.

Also referred to as

PCIT v. Best Infrastructure India · Section 132(4) · incriminating material · retracted statement · search assessment · addition without evidence · evidentiary value of statement · statement under search

Also reported as

84 Taxmann.com 2872017 SCC OnLine DEL 9591

Sections most often in play

Section 143(3)Section 153ASection 132(4)Section 132Section 147Section 69ASection 153CSection 148

Issues it is cited on

undisclosed foreign income and assetssection 158b(b)section 149(1)(c)section 158bb(1)section 4(2)section 158basection 153(a)section 158bbsection 201(3)statement under section 132(4)retracted statementsection 150

Judgments citing PCIT v. Best Infrastructure (India) (P.) Ltd.

The Dy.CIT. Central Circle-1, Baroda vs. Smt. Manjulaben Bipinchandra Patel, Baroda

ITA 41/AHD/2020[2000-01]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2000-01

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

The Dy.CIT. Central Circle-1, Baroda vs. Manjulaben B. Patel Legal Heir of Shri Bipinbhai Prabhudas Patel, Baroda

ITA 40/AHD/2020[2016-17]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2016-17

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

The Dy.CIT. Central Circle-1, Baroda vs. Manjulaben B. Patel Legal Heir of Shri Bipinbhai Prabhudas Patel, Baroda

ITA 39/AHD/2020[2009-10]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2009-10

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

The Dy.CIT. Central Circle-1, Baroda vs. Manjulaben B. Patel Legal Heir of Shri Bipinbhai Prabhudas Patel, Baroda

ITA 38/AHD/2020[2008-09]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2008-09

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

The Dy.CIT. Central Circle-1, Baroda vs. Manjulaben B. Patel Legal Heir of Shri Bipinbhai Prabhudas Patel, Baroda

ITA 37/AHD/2020[2007-08]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2007-08

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

The Dy.CIT. Central Circle-1, Baroda vs. Manjulaben B. Patel Legal Heir of Shri Bipinbhai Prabhudas Patel, Baroda

ITA 36/AHD/2020[2006-07]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2006-07

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

The Dy.CIT. Central Circle-1, Baroda vs. Manjulaben B. Patel Legal Heir of Shri Bipinbhai Prabhudas Patel, Baroda

ITA 35/AHD/2020[2005-06]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2005-06

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

The Dy.CIT. Central Circle-1, Baroda vs. Manjulaben B. Patel Legal Heir of Shri Bipinbhai Prabhudas Patel, Baroda

ITA 34/AHD/2020[2004-05]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2004-05

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

The Dy.CIT. Central Circle-1, Baroda vs. Manjulaben B. Patel Legal Heir of Shri Bipinbhai Prabhudas Patel, Baroda

ITA 33/AHD/2020[2002-03]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2002-03

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

The Dy.CIT. Central Circle-1, Baroda vs. Manjulaben B. Patel Legal Heir of Shri Bipinbhai Prabhudas Patel, Baroda

ITA 32/AHD/2020[2001-02]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2001-02

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

The Dy.CIT. Central Circle-1, Baroda vs. Manjulaben B. Patel Lehal Heir of Shri Bipinbhai Prabhudas Patel, Baroda

ITA 31/AHD/2020[2000-01]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2000-01

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

Smt. Manjulaben B. Patel, Baroda vs. The Dy.CIT. Central Circle-1, Baroda

ITA 1915/AHD/2019[2016-17]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2016-17

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

Smt. Manjulaben B. Patel, Baroda vs. The Dy.CIT. Central Circle-1, Baroda

ITA 1914/AHD/2019[2009-10]Status: HeardITAT Ahmedabad10 Sept 2024AY 2009-10

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

Smt. Manjulaben B. Patel, Baroda vs. The Dy.CIT. Central Circle-1, Baroda

ITA 1913/AHD/2019[2008-09]Status: HeardITAT Ahmedabad10 Sept 2024AY 2008-09

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

Smt. Manjulaben B. Patel, Baroda vs. The Dy.CIT. Central Circle-1, Baroda

ITA 1912/AHD/2019[2007-08]Status: HeardITAT Ahmedabad10 Sept 2024AY 2007-08

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

Smt. Manjulaben B. Patel, Baroda vs. The Dy.CIT. Central Circle-1, Baroda

ITA 1911/AHD/2019[2006-07]Status: HeardITAT Ahmedabad10 Sept 2024AY 2006-07

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

Smt. Manjulaben B. Patel, Baroda vs. The Dy.CIT. Central Circle-1, Baroda

ITA 1910/AHD/2019[2005-06]Status: HeardITAT Ahmedabad10 Sept 2024AY 2005-06

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

Smt. Manjulaben B. Patel, Baroda vs. The Dy.CIT. Central Circle-1, Baroda

ITA 1909/AHD/2019[2004-05]Status: HeardITAT Ahmedabad10 Sept 2024AY 2004-05

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

Smt. Manjulaben B. Patel, Baroda vs. The Dy.CIT. Central Circle-1, Baroda

ITA 1908/AHD/2019[2003-04]Status: HeardITAT Ahmedabad10 Sept 2024AY 2003-04

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…

Smt. Manjulaben B. Patel, Baroda vs. The Dy.CIT. Central Circle-1, Baroda

ITA 1907/AHD/2019[2002-03]Status: HeardITAT Ahmedabad10 Sept 2024AY 2002-03

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further submitted that the statements recorded by the Revenue doesn’t constitute incriminating material, for which reliance was placed on the following decisions: i. CIT v. Best Infrastructure Ltd. (2017) 397 ITR 82 (Del-HC) ii. PCIT vs. Anand Kr. Jain & Ors. Manu/DE/0347/7021 (Delhi) iii. CIT vs. Harjeev Aggarwal - [2016] 70 taxmann.com 95 (Delhi) 54. The Ld. Sr. Counsel contended that the material brought by search team along with them during course of search do not constitute incriminating material. In this regard, reliance was placed on the decision of R…