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 367,518 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.

Sanjay Bhaskar, New Delhi vs. DCIT Central Cir 13, New Delhi

In the result, appeal of the assessee is allowed

ITA 1650/DEL/2024[2017-18]Status: DisposedITAT Delhi30 Dec 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 132Section 132(1)Section 139(1)Section 142(1)Section 143(2)Section 153ASection 250Section 6(1)

…, there must be a nexus between the statement recorded and the evidence/material found during search in order to for an assessment to be based on the statement recorded...." 26. The hon’ble Delhi High Court in case of PCIT Vs. Best Infrastructure reported in 84 Taxmann.com 287 by following the aforesaid judgement of Harjeev Agarwal observed that “…statements recorded under Section 132 (4) of the Act of the Act do not by themselves constitute incriminating material…..”. 27. In the instant case, merely for the reason that assessee has admitted the receipt of such cash without any corroborative material, the same…

Rameshwar Finvest Private Limited, Kolkata vs. DCIT, Central Circle 3(3), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2107/KOL/2025[2008-2009]Status: DisposedITAT Kolkata23 Dec 2025AY 2008-2009

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Dcit, Central Circle 3(3) Rameshwar Finvest Private Aaykar Bhawan Poorva, Limited Santil Palli, 110, Eastern 111, Park Street, Kolkata- Metropolitan Bypass, Opposite Vs. 700016, West Bengal Ruby, Kasba, Kolkata-700107, West Bengal (Appellant) (Respondent) Pan No. Aabcr1053N Assessee By : Shri S.K. Tulsiyan & Ms. Puja Somani, Ars Revenue By : Shri Sanat Kumar Raha, Dr Date Of Hearing: 17.11.2025 Date Of Pronouncement: 23.12.2025

For Appellant: Shri S.K. Tulsiyan &For Respondent: Shri Sanat Kumar Raha, DR
Section 131Section 131(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 263Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRI PRADIP KUMAR CHOUBEY, JM DCIT, Central Circle 3(3) Rameshwar Finvest Private Aaykar Bhawan Poorva, Limited Santil Palli, 110, Eastern 111, Park Street, Kolkata- Metropolitan Bypass, Opposite Vs. 700016, West Bengal Ruby, kasba, Kolkata-700107, West Bengal (Appellant) (Respondent) PAN No. AABCR1053N Assessee by : Shri S.K. Tulsiyan & Ms. Puja Somani, ARs Revenue by : Shri Sanat Kumar Raha, DR Date of hearing: 17.11.2025 Date of pronouncement: 23.12.2025 O R D E R Per Rajesh Kumar, AM: This is an appeal preferred by the…

Dy.CIT Cent. Cir -6(2), Mumbai vs. Shri Ashok B. Jiwarjka, Mumbai

In the result, the appeals filed by the revenue are hereby dismissed and the cross

ITA 2355/MUM/2021[2012-13]Status: DisposedITAT Mumbai23 Dec 2025AY 2012-13

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Omkareshwar Chidara, Am

For Appellant: Shri. Bharat KumarFor Respondent: Shri. Surendra Mohan (SR-DR)
Section 132(1)Section 250Section 68Section 69C

…said to be incriminating material or documents gathered in the course of search conducted against the assessee. 17. In this regard, we may gainfully refer to judgment of the Hon'ble Delhi High Court in the case of CIT Vs Best Infrastructure (India) Pvt Ltd (397 ITR 82). In this case along with assessee's search, simultaneous search was also conducted upon Mr. T who admitted to providing accommodation entries to the assessee in form of share application monies, in lieu of cash. Relying on the statement of Mr. T, the AO made additions u/s 68 in the assessments framed u/s 153A for unabated AYS 2005- 06 to 2009-10.…

Dy.C.I, T. Cent. Cir -6(2), Mumbai vs. Shri Ashok B. Jiwrajka, Mumbai

In the result, the appeals filed by the revenue are hereby dismissed and the cross

ITA 2353/MUM/2021[2014-15]Status: DisposedITAT Mumbai23 Dec 2025AY 2014-15

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Omkareshwar Chidara, Am

For Appellant: Shri. Bharat KumarFor Respondent: Shri. Surendra Mohan (SR-DR)
Section 132(1)Section 250Section 68Section 69C

…said to be incriminating material or documents gathered in the course of search conducted against the assessee. 17. In this regard, we may gainfully refer to judgment of the Hon'ble Delhi High Court in the case of CIT Vs Best Infrastructure (India) Pvt Ltd (397 ITR 82). In this case along with assessee's search, simultaneous search was also conducted upon Mr. T who admitted to providing accommodation entries to the assessee in form of share application monies, in lieu of cash. Relying on the statement of Mr. T, the AO made additions u/s 68 in the assessments framed u/s 153A for unabated AYS 2005- 06 to 2009-10.…

Dy.C.I.T. Cent. Cir -6(2), Mumbai vs. Shri Ashok B.Jiwrajka, Mumbai

In the result, the appeals filed by the revenue are hereby dismissed and the cross

ITA 2352/MUM/2021[2013-14]Status: DisposedITAT Mumbai23 Dec 2025AY 2013-14

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Omkareshwar Chidara, Am

For Appellant: Shri. Bharat KumarFor Respondent: Shri. Surendra Mohan (SR-DR)
Section 132(1)Section 250Section 68Section 69C

…e said to be incriminating material or documents gathered in the course of search conducted against the assessee. 17. In this regard, we may gainfully refer to judgment of the Hon'ble Delhi High Court in the case of CIT Vs Best Infrastructure (India) Pvt Ltd (397 ITR 82). In this case along with assessee's search, simultaneous search was also conducted upon Mr. T who admitted to providing accommodation entries to the assessee in form of share application monies, in lieu of cash. Relying on the statement of Mr. T, the AO made additions u/s 68 in the assessments framed u/s 153A for unabated AYS 2005- 06 to 2009-10.…

Dy C.I.T. Cent Cir -6(2), `Mumbai vs. Shri Ashok B. Jiwrajka, Mumbai

In the result, the appeals filed by the revenue are hereby dismissed and the cross objections filed by the assessee are allowed

ITA 2351/MUM/2021[2015-16]Status: DisposedITAT Mumbai23 Dec 2025AY 2015-16

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Omkareshwar Chidara, Am

For Appellant: Shri. Bharat KumarFor Respondent: Shri. Surendra Mohan (SR-DR)
Section 132(1)Section 250Section 68Section 69C

…said to be incriminating material or documents gathered in the course of search conducted against the assessee. 17. In this regard, we may gainfully refer to judgment of the Hon'ble Delhi High Court in the case of CIT Vs Best Infrastructure (India) Pvt Ltd (397 ITR 82). In this case along with assessee's search, simultaneous search was also conducted upon Mr. T who admitted to providing accommodation entries to the assessee in form of share application monies, in lieu of cash. Relying on the statement of Mr. T, the AO made additions u/s 68 in the assessments framed u/s 153A for unabated AYS 2005-06 to 2009-10.…

Joint Commissioner of Income Tax (OSD), Central Circle-20, Delhi vs. M B Power (Madhya Pradesh) Ltd., Delhi

In the result, appeal of the Revenue is dismissed

ITA 267/DEL/2024[2021-22]Status: DisposedITAT Delhi19 Dec 2025AY 2021-22

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…. However, this statement cannot, on a standalone basis, without reference to any other material discovered during search and seizure operations, empower the AO to frame the block assessment. This court in Pr. CIT v. Best Infrastructure (India) P. Ltd. [2017] 397 ITR 82 (Del) has inter-alia held that: “38. …statements recorded under Section 132(4) of the Act do not by themselves constitute incriminating material as has been explained by this Court in Harjeev Aggarwal.” 24. With regard to the observations of the AO that the excel sheets of Mr. Rajiv Saxena are also corroborating the payments transferred by the su…

Mb Power (Madhya Pradesh) Limited, Delhi vs. DCIT, Central Circle-20, Delhi

In the result, appeal of the Revenue is dismissed

ITA 211/DEL/2024[2021-22]Status: DisposedITAT Delhi19 Dec 2025AY 2021-22

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…. However, this statement cannot, on a standalone basis, without reference to any other material discovered during search and seizure operations, empower the AO to frame the block assessment. This court in Pr. CIT v. Best Infrastructure (India) P. Ltd. [2017] 397 ITR 82 (Del) has inter-alia held that: “38. …statements recorded under Section 132(4) of the Act do not by themselves constitute incriminating material as has been explained by this Court in Harjeev Aggarwal.” 24. With regard to the observations of the AO that the excel sheets of Mr. Rajiv Saxena are also corroborating the payments transferred by the su…

Deputy Commissioner of Income Tax, Central Circle-20, Delhi vs. Mb Power (Madhya Pradesh) Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 3923/DEL/2023[2018-19]Status: DisposedITAT Delhi19 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…. However, this statement cannot, on a standalone basis, without reference to any other material discovered during search and seizure operations, empower the AO to frame the block assessment. This court in Pr. CIT v. Best Infrastructure (India) P. Ltd. [2017] 397 ITR 82 (Del) has inter-alia held that: “38. …statements recorded under Section 132(4) of the Act do not by themselves constitute incriminating material as has been explained by this Court in Harjeev Aggarwal.” 24. With regard to the observations of the AO that the excel sheets of Mr. Rajiv Saxena are also corroborating the payments transferred by the su…

Deputy Commissioner of Income Tax, Central Circle-20, Delhi vs. M. B. Power (Madhaya Pradesh) Ltd, Delhi

In the result, appeal of the Revenue is dismissed

ITA 3874/DEL/2023[2016-17]Status: DisposedITAT Delhi19 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…. However, this statement cannot, on a standalone basis, without reference to any other material discovered during search and seizure operations, empower the AO to frame the block assessment. This court in Pr. CIT v. Best Infrastructure (India) P. Ltd. [2017] 397 ITR 82 (Del) has inter-alia held that: “38. …statements recorded under Section 132(4) of the Act do not by themselves constitute incriminating material as has been explained by this Court in Harjeev Aggarwal.” 24. With regard to the observations of the AO that the excel sheets of Mr. Rajiv Saxena are also corroborating the payments transferred by the su…

Deputy Commissioner of Income Tax, Central Circle - 20, Delhi vs. M.B. Power (Madhaya Pradesh) Ltd, Delhi

In the result, appeal of the Revenue is dismissed

ITA 3870/DEL/2023[2017-18]Status: DisposedITAT Delhi19 Dec 2025AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…. However, this statement cannot, on a standalone basis, without reference to any other material discovered during search and seizure operations, empower the AO to frame the block assessment. This court in Pr. CIT v. Best Infrastructure (India) P. Ltd. [2017] 397 ITR 82 (Del) has inter-alia held that: “38. …statements recorded under Section 132(4) of the Act do not by themselves constitute incriminating material as has been explained by this Court in Harjeev Aggarwal.” 24. With regard to the observations of the AO that the excel sheets of Mr. Rajiv Saxena are also corroborating the payments transferred by the su…

Mb Power (Madhya Pradesh) Limited, South East Delhi vs. DCIT, Central Circle-20, Delhi

In the result, appeal of the Revenue is dismissed

ITA 3850/DEL/2023[2018-19]Status: DisposedITAT Delhi19 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…. However, this statement cannot, on a standalone basis, without reference to any other material discovered during search and seizure operations, empower the AO to frame the block assessment. This court in Pr. CIT v. Best Infrastructure (India) P. Ltd. [2017] 397 ITR 82 (Del) has inter-alia held that: “38. …statements recorded under Section 132(4) of the Act do not by themselves constitute incriminating material as has been explained by this Court in Harjeev Aggarwal.” 24. With regard to the observations of the AO that the excel sheets of Mr. Rajiv Saxena are also corroborating the payments transferred by the su…

Rakeshkumar Mahendrakumar Shah, Ahmedabad vs. The ACIT, Central Circle-1(3), Ahmedabad

The appeal of the assessee stand dismissed, and the order of the CIT(Appeals) is hereby affirmed in toto

ITA 1724/AHD/2024[2022-23]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Ms. Urvashi Sodhan, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 132Section 132(4)Section 139(1)Section 143(1)Section 143(3)Section 28Section 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE DR. BRR KUMAR, VICE PRESIDENT & SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER I.T.A. No.1713/Ahd/2024 (Assessment Year: 2022-23) Assistant Commissioner of Vs. Rakeshkumar Mahendrakumar Income Tax, Shah, Central Circle-1(3), B-301, Aaryavrat Skies, Ahmedabad Nehrunagar, Ambawadi, Ahmedabad-380015 [PAN No.APUPS9580G] (Appellant) .. (Respondent) I.T.A. No.1724/Ahd/2024 (Assessment Year: 2022-23) Rakeshkumar Mahendrakumar Vs. Assistant Commissioner of Shah, Income Tax, B-301, Aaryavrat Skies, Central Circle-1(3), Nehrunagar, Ambawadi, Ahmedabad Ahmedabad-…

ACIT Central Circle 1(3), Ahmedabad vs. Rakeshkumar Mahendrakumar Shah, Ahmedabad

The appeal of the assessee stand dismissed, and the order of the CIT(Appeals) is hereby affirmed in toto

ITA 1713/AHD/2024[2022-23]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Ms. Urvashi Sodhan, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 132Section 132(4)Section 139(1)Section 143(1)Section 143(3)Section 28Section 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE DR. BRR KUMAR, VICE PRESIDENT & SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER I.T.A. No.1713/Ahd/2024 (Assessment Year: 2022-23) Assistant Commissioner of Vs. Rakeshkumar Mahendrakumar Income Tax, Shah, Central Circle-1(3), B-301, Aaryavrat Skies, Ahmedabad Nehrunagar, Ambawadi, Ahmedabad-380015 [PAN No.APUPS9580G] (Appellant) .. (Respondent) I.T.A. No.1724/Ahd/2024 (Assessment Year: 2022-23) Rakeshkumar Mahendrakumar Vs. Assistant Commissioner of Shah, Income Tax, B-301, Aaryavrat Skies, Central Circle-1(3), Nehrunagar, Ambawadi, Ahmedabad Ahmedabad-…

ACIT, Central Circle-II, Lucknow vs. Rakesh Kumar Pandey, Gonda U.P

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 460/LKW/2025[2017-18]Status: DisposedITAT Lucknow11 Dec 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

…me is dismissed, being devoid of merit. 3. IN THE INCOME TAX APPELLATE TRIBUNAL,DELHI BENCH ACIT,Central Circle-30,New Delhi V. M/s. KuberKhadyanPvt. Ltd., 9.3 We find that Hon’ble Delhi High Court in the case of PCIT Vs Best Infrastructure Private Limited, 397 ITR 82 has held that statement under section 132(4) in the itself does not constitute incriminating material. The relevant finding of the Hon’ble High Court is reproduced as under: “38. Fifthly, statements recorded under Section 132 (4) of the Act of the Act do not by themselves constitute incriminating material as has been explained by this Court in Com…

Rakesh Kumar Pandey, Gonda vs. DCIT/ACIT (Central)-2, Lucknow

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 351/LKW/2025[2018-19]Status: DisposedITAT Lucknow11 Dec 2025AY 2018-19

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

…me is dismissed, being devoid of merit. 3. IN THE INCOME TAX APPELLATE TRIBUNAL,DELHI BENCH ACIT,Central Circle-30,New Delhi V. M/s. KuberKhadyanPvt. Ltd., 9.3 We find that Hon’ble Delhi High Court in the case of PCIT Vs Best Infrastructure Private Limited, 397 ITR 82 has held that statement under section 132(4) in the itself does not constitute incriminating material. The relevant finding of the Hon’ble High Court is reproduced as under: “38. Fifthly, statements recorded under Section 132 (4) of the Act of the Act do not by themselves constitute incriminating material as has been explained by this Court in Com…

Rakesh Kumar Pandey, Gonda vs. DCIT/ACIT (Central)-2, Lucknow

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 349/LKW/2025[2016-17]Status: DisposedITAT Lucknow11 Dec 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

…me is dismissed, being devoid of merit. 3. IN THE INCOME TAX APPELLATE TRIBUNAL,DELHI BENCH ACIT,Central Circle-30,New Delhi V. M/s. KuberKhadyanPvt. Ltd., 9.3 We find that Hon’ble Delhi High Court in the case of PCIT Vs Best Infrastructure Private Limited, 397 ITR 82 has held that statement under section 132(4) in the itself does not constitute incriminating material. The relevant finding of the Hon’ble High Court is reproduced as under: “38. Fifthly, statements recorded under Section 132 (4) of the Act of the Act do not by themselves constitute incriminating material as has been explained by this Court in Com…

Kayum Razak Dhanani, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

Appeal of the assessee is allowed

ITA 634/BANG/2024[2015-16]Status: DisposedITAT Bangalore24 Nov 2025AY 2015-16

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2015-16

For Appellant: Shri V. Chandrashekar, AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT), Bengaluru
Section 127Section 132Section 139Section 143Section 143(3)Section 153ASection 56(2)(vii)

…u/s. 132(4) also cannot be said to be incriminating material. This is also because of the reason that no person can incriminate himself by making a statement against himself. Honourable Delhi High court in case of PCIT V Best Infrastructure Private limited [ 397 ITR 82 ] (Delhi) PCIT vs Best Infrastructure (India) (P) Ltd [TS-5668-HC-2017(Delhi)-O] where the question was. "Whether having regard to the materials seized in the course of search under section 132 and the statements made on behalf of the assessee, additions made by the Assessing Officer under section 153A, were not justified as held by the Income-ta…

Deputy Commissioner of Income Tax, Delhi vs. Indian Hydro Electric Power Pvt. Ltd., Delhi

ITA 3907/DEL/2023[2019-20]Status: DisposedITAT Delhi07 Nov 2025AY 2019-20

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 132Section 132(4)Section 153ASection 250Section 68Section 69C

…er section 153C has not been followed. On this count alone, we find no perversity in the view taken by the ITAT. Therefore, we do not find any substantial question of law that requires our consideration.”  Best Infrastructure (India) (P.) Ltd. vs. CIT [2017] 397 ITR 82 [Delhi High Court – 01.08.2017] “38. Fifthly, statements recorded under Section 132 (4) of the Act of the Act do not by themselves constitute incriminating material as has been explained by this Court in Harjeev Aggarwal (supra). Lastly, as already pointed out hereinbefore, the facts in the present case are different from the facts in Smt. Dayawan…

Deputy Commissioner of Income Tax, Central Circle-20, Delhi vs. Indian Hydro Electric Power Pvt. Ltd., Delhi

ITA 3906/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Nov 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 132Section 132(4)Section 153ASection 250Section 68Section 69C

…er section 153C has not been followed. On this count alone, we find no perversity in the view taken by the ITAT. Therefore, we do not find any substantial question of law that requires our consideration.”  Best Infrastructure (India) (P.) Ltd. vs. CIT [2017] 397 ITR 82 [Delhi High Court – 01.08.2017] “38. Fifthly, statements recorded under Section 132 (4) of the Act of the Act do not by themselves constitute incriminating material as has been explained by this Court in Harjeev Aggarwal (supra). Lastly, as already pointed out hereinbefore, the facts in the present case are different from the facts in Smt. Dayawan…