Pullangode Rubber Produce Co. Ltd. v. State of Kerala

91 ITR 18Supreme Court of India1973#84 most cited

What is Pullangode Rubber Produce Co. Ltd. v. State of Kerala authority for?

Admissions, whether made through entries in account books or statements, are important pieces of evidence but are not conclusive. An assessee has the right to demonstrate that an admission made by them is incorrect or can be retracted.

666

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2009 to 2026.

Also referred to as

Pullangode Rubber Produce Co. Ltd. v. State of Kerala · 91 ITR 18 · admission not conclusive · retraction of statement · statement under section 132(4) · evidentiary value of admissions · entries in account books as evidence · proving admission incorrect · Section 68 · Section 69A

Sections most often in play

Section 132(4)Section 143(3)Section 153ASection 132Section 147Section 68Section 69ASection 142(1)

Issues it is cited on

retraction of statementretracted statementstatement under section 132(4)section 158bbsection 132(4a)dumb documentssection 132(4)on-moneysection 69bloose paperspanchnamasection 158b

Judgments citing Pullangode Rubber Produce Co. Ltd. v. State of Kerala

Mohammed Ibrahim Mohideen, Kerala vs. Asst. Commissioner of Income Tax, Central Circle-2, Mangalore

In the result, appeal of the assessee in ITA

ITA 466/BANG/2024[2017-18]Status: DisposedITAT Bangalore08 Jul 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 153ASection 69B

…roper opportunity to show that the books of accounts did not correct disclose the correct state of facts. The principle is supported by the decision of Hon’ble Supreme Court in the case of Pullangode Rubber Produce Company Ltd. Vs. State of Kerala reported in 91 ITR 18 (SC). 3.3 In this factual background, if we examine the facts of present case, one has to see whether addition made by AO towards unaccounted cash receipts received from various persons as recorded in seized document, which is being a scribbling pad. Admittedly, incriminating material found during the course of search does not bare the signature of…

Mohammed Ibrahim Mohideen, Kerala vs. Asst. Commissioner of Income Tax, Central Circle-2, Mangalore

In the result, appeal of the assessee in ITA

ITA 464/BANG/2024[2015-16]Status: DisposedITAT Bangalore08 Jul 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 153ASection 69B

…roper opportunity to show that the books of accounts did not correct disclose the correct state of facts. The principle is supported by the decision of Hon’ble Supreme Court in the case of Pullangode Rubber Produce Company Ltd. Vs. State of Kerala reported in 91 ITR 18 (SC). 3.3 In this factual background, if we examine the facts of present case, one has to see whether addition made by AO towards unaccounted cash receipts received from various persons as recorded in seized document, which is being a scribbling pad. Admittedly, incriminating material found during the course of search does not bare the signature of…

Mohammed Ibrahim Mohideen, Kerala vs. Asst. Commissioner of Income Tax, Central Circle-2, Mangalore

In the result, appeal of the assessee in ITA

ITA 463/BANG/2024[2014-15]Status: DisposedITAT Bangalore08 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 153ASection 69B

…roper opportunity to show that the books of accounts did not correct disclose the correct state of facts. The principle is supported by the decision of Hon’ble Supreme Court in the case of Pullangode Rubber Produce Company Ltd. Vs. State of Kerala reported in 91 ITR 18 (SC). 3.3 In this factual background, if we examine the facts of present case, one has to see whether addition made by AO towards unaccounted cash receipts received from various persons as recorded in seized document, which is being a scribbling pad. Admittedly, incriminating material found during the course of search does not bare the signature of…

Enn Vee Holdings Pvt Ltd, New Delhi vs. DCIT Central Circle 31, New Delhi

In the result, the addition made u/s 68 and u/s 56(2)(viib) in the case of M/s Realtime Marketing Pvt

ITA 1195/DEL/2023[2016-17]Status: DisposedITAT Delhi05 Jul 2024AY 2016-17

Bench: Dr. B. R. R. Kumar, Sh. Yogesh Kumar Us

For Appellant: Sh. Neeraj Jain, Adv. &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 132Section 132(4)Section 143(1)Section 143(2)Section 153ASection 68

…ed, the addition made by the AO correctly needs to be approved. Realtime Marketing & ENN VEE Holdings Pvt. Ltd. 13. The ld. DR argued at length relying on the judgment of Hon’ble Supreme Court in the case of Pullangode Rubber Produce Co. Ltd. state of Kerala (91 ITR 18). It was argued that the Hon’ble Apex court held that an admission is an extremely important piece of evidence. Hence, the ld. DR argued that the statement of Sh. Ashok Jain has to be considered and the retraction made thereafter must not be considered. The ld. DR has also relied on the judgment of Hon’ble High Court of Kerala in CIT Vs. Abdul Raza…

DCIT, CC-31, New Delhi vs. Enn Vee Holdings Pvt. Ltd., New Delhi

ITA 1841/DEL/2021[2015-16]Status: DisposedITAT Delhi05 Jul 2024AY 2015-16

Bench: Dr. B. R. R. Kumar, Sh. Yogesh Kumar Us

For Appellant: Sh. Neeraj Jain, Adv. &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 132(4)

…was only a self-serving afterthought. 5. Whether in the facts and circumstances of the case, the Ld. CIT(A) has erred in law in ignoring the pronouncement of Hon’ble Supreme Court in the case of Pullan-gode Rubber Produce Co. Ltd. vs. State of Kerala, (1973) 91 ITR 18, wherein it was held that an admission is an extremely important piece of evidence. 6. Whether in the facts and circumstances of the case, the Ld. CIT(A) has erred in law in ignoring the pronouncement of Hon’ble Kerala High Court in the case of CIT vs. Abdul Razak [2012] 20 taxmann.com 48 (Ker.) wherein it was held that a self-serving retraction, w…

DCIT, CC-31, New Delhi vs. Enn Vee Holdings Pvt. Ltd., New Delhi

ITA 1840/DEL/2021[2014-15]Status: DisposedITAT Delhi05 Jul 2024AY 2014-15

Bench: Dr. B. R. R. Kumar, Sh. Yogesh Kumar Us

For Appellant: Sh. Neeraj Jain, Adv. &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 132(4)

…was only a self-serving afterthought. 5. Whether in the facts and circumstances of the case, the Ld. CIT(A) has erred in law in ignoring the pronouncement of Hon’ble Supreme Court in the case of Pullan-gode Rubber Produce Co. Ltd. vs. State of Kerala, (1973) 91 ITR 18, wherein it was held that an admission is an extremely important piece of evidence. 6. Whether in the facts and circumstances of the case, the Ld. CIT(A) has erred in law in ignoring the pronouncement of Hon’ble Kerala High Court in the case of CIT vs. Abdul Razak [2012] 20 taxmann.com 48 (Ker.) wherein it was held that a self-serving retraction, w…

DCIT, CC-31, New Delhi vs. Realtime Marketing Pvt. Ltd., Delhi

In the result, the addition made u/s 68 and u/s 56(2)(viib) in the case of M/s Realtime Marketing Pvt

ITA 1839/DEL/2021[2015-16]Status: DisposedITAT Delhi05 Jul 2024AY 2015-16

Bench: Dr. B. R. R. Kumar, Sh. Yogesh Kumar Us

For Appellant: Sh. Neeraj Jain, Adv. &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 132Section 132(4)Section 143(1)Section 143(2)Section 153ASection 68

…ed, the addition made by the AO correctly needs to be approved. Realtime Marketing & ENN VEE Holdings Pvt. Ltd. 13. The ld. DR argued at length relying on the judgment of Hon’ble Supreme Court in the case of Pullangode Rubber Produce Co. Ltd. state of Kerala (91 ITR 18). It was argued that the Hon’ble Apex court held that an admission is an extremely important piece of evidence. Hence, the ld. DR argued that the statement of Sh. Ashok Jain has to be considered and the retraction made thereafter must not be considered. The ld. DR has also relied on the judgment of Hon’ble High Court of Kerala in CIT Vs. Abdul Raza…

DCIT, CC-31, New Delhi vs. Realtime Marketing Pvt. Ltd., Delhi

ITA 1838/DEL/2021[2014-15]Status: DisposedITAT Delhi05 Jul 2024AY 2014-15

Bench: Dr. B. R. R. Kumar, Sh. Yogesh Kumar Us

For Appellant: Sh. Neeraj Jain, Adv. &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 132(4)

…was only a self-serving afterthought. 5. Whether in the facts and circumstances of the case, the Ld. CIT(A) has erred in law in ignoring the pronouncement of Hon’ble Supreme Court in the case of Pullan-gode Rubber Produce Co. Ltd. vs. State of Kerala, (1973) 91 ITR 18, wherein it was held that an admission is an extremely important piece of evidence. 6. Whether in the facts and circumstances of the case, the Ld. CIT(A) has erred in law in ignoring the pronouncement of Hon’ble Kerala High Court in the case of CIT vs. Abdul Razak [2012] 20 taxmann.com 48 (Ker.) wherein it was held that a self-serving retraction, w…

DCIT- CC-31, New Delhi vs. Realtime Marketing Pvt. Ltd., Delhi

ITA 1837/DEL/2021[2012-13]Status: DisposedITAT Delhi05 Jul 2024AY 2012-13

Bench: Dr. B. R. R. Kumar, Sh. Yogesh Kumar Us

For Appellant: Sh. Neeraj Jain, Adv. &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 132(4)

…was only a self-serving afterthought. 5. Whether in the facts and circumstances of the case, the Ld. CIT(A) has erred in law in ignoring the pronouncement of Hon’ble Supreme Court in the case of Pullan-gode Rubber Produce Co. Ltd. vs. State of Kerala, (1973) 91 ITR 18, wherein it was held that an admission is an extremely important piece of evidence. 6. Whether in the facts and circumstances of the case, the Ld. CIT(A) has erred in law in ignoring the pronouncement of Hon’ble Kerala High Court in the case of CIT vs. Abdul Razak [2012] 20 taxmann.com 48 (Ker.) wherein it was held that a self-serving retraction, w…

M/S. Hindusthan Bawa Builders, Mangalore vs. Assistant Commissioner of Income Tax, Central Circle-1, Mangalore

In the result, appeals of the assessee in ITA Nos

ITA 271/BANG/2024[2018-19]Status: DisposedITAT Bangalore04 Jul 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 153CSection 69B

…er opportunity to show that the books of account did not correctly disclose the correct state of facts. This principle is supported by the decision of the Hon’ble Supreme Court in the case of Pullangode Rubber Produce Co. Ltd. vs. State of Kerala & Anr (1973) 91 ITR 18. 9.5. In this factual and legal background, if we examine the facts of present case, one has to see whether additions made by the AO towards unaccounted cash introduction as recorded in seized incriminating document being scribbling pad/loose paper is in fact the undisclosed income of the assessee or which is a non- speaking document having no evid…

M/S. Hindusthan Bawa Builders, Mangalore vs. Assistant Commissioner of Income Tax, Central Circle-1, Mangalore

In the result, appeals of the assessee in ITA Nos

ITA 270/BANG/2024[2017-18]Status: DisposedITAT Bangalore04 Jul 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 153CSection 69B

…er opportunity to show that the books of account did not correctly disclose the correct state of facts. This principle is supported by the decision of the Hon’ble Supreme Court in the case of Pullangode Rubber Produce Co. Ltd. vs. State of Kerala & Anr (1973) 91 ITR 18. 9.5. In this factual and legal background, if we examine the facts of present case, one has to see whether additions made by the AO towards unaccounted cash introduction as recorded in seized incriminating document being scribbling pad/loose paper is in fact the undisclosed income of the assessee or which is a non- speaking document having no evid…

M/S. Hindusthan Bawa Builders, Mangalore vs. Assistant Commissioner of Income Tax, Central Circle-1, Mangalore

In the result, appeals of the assessee in ITA Nos

ITA 269/BANG/2024[2016-17]Status: DisposedITAT Bangalore04 Jul 2024AY 2016-17

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 153CSection 69B

…er opportunity to show that the books of account did not correctly disclose the correct state of facts. This principle is supported by the decision of the Hon’ble Supreme Court in the case of Pullangode Rubber Produce Co. Ltd. vs. State of Kerala & Anr (1973) 91 ITR 18. 9.5. In this factual and legal background, if we examine the facts of present case, one has to see whether additions made by the AO towards unaccounted cash introduction as recorded in seized incriminating document being scribbling pad/loose paper is in fact the undisclosed income of the assessee or which is a non- speaking document having no evid…

M/S. Hindusthan Bawa Builders, Mangalore vs. Assistant Commissioner of Income Tax, Central Circle-2, Mangalore

In the result, appeals of the assessee in ITA Nos

ITA 268/BANG/2024[2014-15]Status: DisposedITAT Bangalore04 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 153CSection 69B

…er opportunity to show that the books of account did not correctly disclose the correct state of facts. This principle is supported by the decision of the Hon’ble Supreme Court in the case of Pullangode Rubber Produce Co. Ltd. vs. State of Kerala & Anr (1973) 91 ITR 18. 9.5. In this factual and legal background, if we examine the facts of present case, one has to see whether additions made by the AO towards unaccounted cash introduction as recorded in seized incriminating document being scribbling pad/loose paper is in fact the undisclosed income of the assessee or which is a non- speaking document having no evid…

DCIT, Central Circle - 3, Coimbatore vs. Smt.Vanitha Mohan, Coimbatre

In the result, the appeal by the assessee in ITA No

ITA 498/CHNY/2022[2013-14]Status: DisposedITAT Chennai03 Jul 2024AY 2013-14

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

For Appellant: Shri T. Banusekar, AdvocateFor Respondent: Shri V. Nandakumar, CIT
Section 132Section 132(4)

…correct based on mistake of fact or that it was not voluntarily obtained, but due to threat, coercion, promise etc., is upon the maker of statement. In this context, the Hon'ble Apex Court in the case of Pullengole Rubber Produce Co. Ltd. v. State of Kerala (91 ITR 18) has held that although an admission is an extremely important piece of evidence but it cannot be said that it is conclusive. It was held that, it is open to the assessee who made the admission to show that it is incorrect based on mistake of fact. An oral statement on a relevant fact is a piece of evidence, and the weight to be attached to it m…

DCIT, Central Circle - 3, Coimbatore vs. Shri D Vijay Mohan, Coimbatore

In the result, the appeal by the assessee in ITA No

ITA 497/CHNY/2022[2013-14]Status: DisposedITAT Chennai03 Jul 2024AY 2013-14

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

For Appellant: Shri T. Banusekar, AdvocateFor Respondent: Shri V. Nandakumar, CIT
Section 132Section 132(4)

…correct based on mistake of fact or that it was not voluntarily obtained, but due to threat, coercion, promise etc., is upon the maker of statement. In this context, the Hon'ble Apex Court in the case of Pullengole Rubber Produce Co. Ltd. v. State of Kerala (91 ITR 18) has held that although an admission is an extremely important piece of evidence but it cannot be said that it is conclusive. It was held that, it is open to the assessee who made the admission to show that it is incorrect based on mistake of fact. An oral statement on a relevant fact is a piece of evidence, and the weight to be attached to it m…

Vanitha Mohan, Coimbatore vs. DCIT Central Circle-3, Coimbatore

In the result, the appeal by the assessee in ITA No

ITA 268/CHNY/2022[2013-14]Status: DisposedITAT Chennai03 Jul 2024AY 2013-14

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

For Appellant: Shri T. Banusekar, AdvocateFor Respondent: Shri V. Nandakumar, CIT
Section 132Section 132(4)

…correct based on mistake of fact or that it was not voluntarily obtained, but due to threat, coercion, promise etc., is upon the maker of statement. In this context, the Hon'ble Apex Court in the case of Pullengole Rubber Produce Co. Ltd. v. State of Kerala (91 ITR 18) has held that although an admission is an extremely important piece of evidence but it cannot be said that it is conclusive. It was held that, it is open to the assessee who made the admission to show that it is incorrect based on mistake of fact. An oral statement on a relevant fact is a piece of evidence, and the weight to be attached to it m…

Vijay Mohan, Coimbaore vs. DCIT, Central Circle-(3)(I/C), Coimbatore

In the result, the appeal by the assessee in ITA No

ITA 267/CHNY/2022[2013-14]Status: DisposedITAT Chennai03 Jul 2024AY 2013-14

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

For Appellant: Shri T. Banusekar, AdvocateFor Respondent: Shri V. Nandakumar, CIT
Section 132Section 132(4)

…correct based on mistake of fact or that it was not voluntarily obtained, but due to threat, coercion, promise etc., is upon the maker of statement. In this context, the Hon'ble Apex Court in the case of Pullengole Rubber Produce Co. Ltd. v. State of Kerala (91 ITR 18) has held that although an admission is an extremely important piece of evidence but it cannot be said that it is conclusive. It was held that, it is open to the assessee who made the admission to show that it is incorrect based on mistake of fact. An oral statement on a relevant fact is a piece of evidence, and the weight to be attached to it m…

M/S. Mukka Proteins Limited (Formerly Know As Mukka Sea Food Industries Ltd., Mangalore vs. Deputy Commissioner of Income Tax, Central Circle-1, Mangalore

ITA 434/BANG/2024[2016-17]Status: DisposedITAT Bangalore03 Jul 2024AY 2016-17

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 132Section 132(4)Section 153ASection 153DSection 234A

…ITA Nos.431 to 435/Bang/2024 M/s. Mukka Proteins Limited, Mangaluru IN THE INCOME TAX APPELLATE TRIBUNAL "C" BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.431 to 435/Bang/2024 Assessment Years: 2013-14 to 2017-18 M/s. Mukka Proteins Limited (Formerly known as Mukka Sea Food Industries Ltd.), # 18-2-16/4, Mukka Corporate House, First Cross N.G. Road, Attavar Manguluru 575 001 Karnataka PAN NO: AAGCM8310E APPELLANT Appellant by Respondent by Date of Hearing Date of Pronouncement DCIT Vs. Central Circle-1 Manguluru RESPONDENT Sri Narendra Sharma, A.R.…

M/S. Mukka Proteins Limited (Formerly Know As Mukka Sea Food Industries Ltd., Mangalore vs. Deputy Commissioner of Income Tax, Central Circle-1, Mangaluru

In the result, appeals of the assessee in ITA Nos

ITA 431/BANG/2024[2013-14]Status: DisposedITAT Bangalore03 Jul 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Sri Narendra Sharma, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 132Section 132(4)Section 153ASection 153DSection 234A

…are not conclusively proved as against admitted proof. In the absence of rebuttable conclusion, admission bind the maker when these are not rebuttable or retracted. It was held by the Supreme Court in the case of Pullengode Rubber Produce vs. State of Kerala (91 ITR 18) that an admission is an extremely important piece of evidence but it cannot be said that it is conclusive and the maker can show that it was incorrect. In the case of Satinder Kumar (HUF) vs. CIT (106 ITR 64), the High Court of Himachal Pradesh held that the admission made by an assessee constitute a relevant piece of evidence but if the assessee…

Greenworld Construction Private Limited, Mumbai vs. DCIT CC-4(2), Mumbai

In the result, the appeal of the assessee stands allowed

ITA 3436/MUM/2023[2021-22]Status: DisposedITAT Mumbai07 Jun 2024AY 2021-22

Bench: Shri Br Baskaran, Am & Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T.A. No.3436/Mum/2023 (ननधधारण वर्ा / Assessment Year: 2021-22) Greenworld Construction बनधम/ Dcit, Central Circle-4(2) 19Th Floor, Air India Pvt. Ltd. Vs. Shop No. 101, 1St Floor, Building, Nariman Point, Raja Ram Mohan Roy Mumbai-400021. Road, Orion Bldg, Girgaon, Grant Road, Mumbai स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aafcg4251K (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Mani Jain, Fca Revenue By: Smt Sanyogita Nagpal, Cit

For Appellant: Shri Mani Jain, FCAFor Respondent: Smt Sanyogita Nagpal, CIT
Section 132(4)Section 133(6)

…that the statement was not correct or that it was not voluntarily obtained, but due to threat, coercion, promise etc, is upon the maker of statement. In this context, the Hon'ble Apex Court in the case of Pullengole Rubber Produce Co. Ltd. v. State of Kerala (91 ITR 18) has held that although an admission is an extremely important piece of evidence but it cannot be said that it is conclusive. It was held that, it is open to the assessee who made the admission to show that it is incorrect. A statement is only a piece of evidence, and the weight to be attached to it must depend on the circumstances in which it is m…