Principal Commissioner Income Tax, Central-2 v. Umesh Ishrani

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What is Principal Commissioner Income Tax, Central-2 v. Umesh Ishrani authority for?

Additions under Section 69A cannot be made solely based on entries in seized loose papers or undated/unsigned documents without corroborating them with other evidence and conducting proper inquiry or verification. When the Assessing Officer relies on third-party statements without tangible material linking the assessee, cross-examination must be allowed.

168

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2021 to 2026.

Also referred to as

Umesh Ishrani · PCIT v Umesh Ishrani · Section 69A · Section 132 · Section 292C · search and seizure · loose papers · dumb documents · corroboration of evidence · unexplained money · cross-examination · natural justice

Issues it is cited on

Judgments citing Principal Commissioner Income Tax, Central-2 v. Umesh Ishrani

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 (…

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