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

Shri Hasmukhlal Inderchand Ranawat, Mumbai vs. The DCIT, Central Circle-8(3), Mumbai

In the result, the appeals of the assessee for AY 2015-16 to 2018-19

ITA 2980/MUM/2023[2018-19]Status: DisposedITAT Mumbai01 Apr 2024AY 2018-19

Bench: Shri B.R. Baskaran (Am) & Shri Aby T. Varkey (Jm)

Section 132Section 133ASection 143(3)Section 153A

…anations furnished by the assessee were not at all examined by the AO, but he has arrived at his decision fully placing reliance on the statement given by the assessee u/s 132(4) of the Act. In the case of Pullangode Rubber Produce Co Ltd vs. State of Kerala (91 ITR 18)(SC), the Hon'ble Supreme Court held that an admission is an extremely important piece of evidence but it cannot be said that it is conclusive. It is open to the person who made the admission to show that it is incorrect. In the instant case, the assessee has furnished credible evidences in order to show that his admission was not correct. In our v…

Shri Hasmukhlal Inderchand Ranawat, Mumbai vs. The DCIT, Central Circle 8(3), Mumbai

In the result, the appeals of the assessee for AY 2015-16 to 2018-19

ITA 2979/MUM/2023[2017-18]Status: DisposedITAT Mumbai01 Apr 2024AY 2017-18

Bench: Shri B.R. Baskaran (Am) & Shri Aby T. Varkey (Jm)

Section 132Section 133ASection 143(3)Section 153A

…anations furnished by the assessee were not at all examined by the AO, but he has arrived at his decision fully placing reliance on the statement given by the assessee u/s 132(4) of the Act. In the case of Pullangode Rubber Produce Co Ltd vs. State of Kerala (91 ITR 18)(SC), the Hon’ble 9 Shri Hasmukhlal Inderchand Ranawat Supreme Court held that an admission is an extremely important piece of evidence but it cannot be said that it is conclusive. It is open to the person who made the admission to show that it is incorrect. In the instant case, the assessee has furnished credible evidences in order to show that…

Shri Hasmukhlal Inderchand Ranawat, Mumbai City vs. The DCIT, Central Circle-8(3), Mumbai

In the result, the appeals of the assessee for AY 2015-16 to 2018-19

ITA 2978/MUM/2023[2016-17]Status: DisposedITAT Mumbai01 Apr 2024AY 2016-17

Bench: Shri B.R. Baskaran (Am) & Shri Aby T. Varkey (Jm)

Section 132Section 133ASection 143(3)Section 153A

…anations furnished by the assessee were not at all examined by the AO, but he has arrived at his decision fully placing reliance on the statement given by the assessee u/s 132(4) of the Act. In the case of Pullangode Rubber Produce Co Ltd vs. State of Kerala (91 ITR 18)(SC), the Hon’ble 9 Shri Hasmukhlal Inderchand Ranawat Supreme Court held that an admission is an extremely important piece of evidence but it cannot be said that it is conclusive. It is open to the person who made the admission to show that it is incorrect. In the instant case, the assessee has furnished credible evidences in order to show that…

Shri Hasmukhlal Inderchand Ranawat, Mumbai City vs. The DCIT, Central Circle-8(3), Mumbai

In the result, the appeals of the assessee for AY 2015-16 to 2018-19

ITA 2977/MUM/2023[2015-16]Status: DisposedITAT Mumbai01 Apr 2024AY 2015-16

Bench: Shri B.R. Baskaran (Am) & Shri Aby T. Varkey (Jm)

Section 132Section 133ASection 143(3)Section 153A

…anations furnished by the assessee were not at all examined by the AO, but he has arrived at his decision fully placing reliance on the statement given by the assessee u/s 132(4) of the Act. In the case of Pullangode Rubber Produce Co Ltd vs. State of Kerala (91 ITR 18)(SC), the Hon’ble 9 Shri Hasmukhlal Inderchand Ranawat Supreme Court held that an admission is an extremely important piece of evidence but it cannot be said that it is conclusive. It is open to the person who made the admission to show that it is incorrect. In the instant case, the assessee has furnished credible evidences in order to show that…

Mr. Abdul Khader Kodi, Kasargod, Karnataka vs. Mr. C. Vijay Jayan, Deputy Commissioner of Income Tax, Mangaluru

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 638/BANG/2023[2018-2019]Status: DisposedITAT Bangalore22 Mar 2024AY 2018-2019

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.636 To 638/Bang/2023 Assessment Years: 2016-17 To 2018-19 Mr. Abdul Khader Kodi Darul Huda, Near Salafi Masjid Kunjathur Via Dcit Manjeshwar Central Circle-2 Vs. Kasargod 671 323 Mangaluru Karnataka Pan No : Alhpk5340F Appellant Respondent Appellant By : Shri Ravishankar S.V., A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: These Appeals By Assessee Are Directed By Different Orders Of Nfac For The Assessment Years 2016-17 To 2018-19 Having Common Date Dated 23.5.2022. 2. The Grounds Raised By The Assessee In All These Appeals Are Common In Nature, Except Change In Figures. We Consider Grounds In Ita No.636/Bang/2023, Which Reads As Follows: 1. The Learned Cit(A)-2, Panaji Erred In Passing The Order In The Manner He Did. 2. The Ld. Cit(A)-2, Panaji Erred In Upholding The Additions Made By The Assessing Officer Amounting To Rs.6,25,000 As Undisclosed Business Income & Rs.1,99,40,000 As Unexplained Investments Under Section 68 Of The Income Tax Act, 1961, Which Was Purely On Assumptions & Presumptions Based On The Loose Sheet Found At The Time Of Search.

For Appellant: Shri Ravishankar S.V., A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 132Section 144Section 153ASection 34Section 68Section 69Section 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 evide…

Mr. Abdul Khader Kodi, Kasargod, Karnataka vs. Mr. C. Vinod Jayan, Deputy Commissioner of Income Tax, Mangalore

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 637/BANG/2023[2017-2018]Status: DisposedITAT Bangalore22 Mar 2024AY 2017-2018

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.636 To 638/Bang/2023 Assessment Years: 2016-17 To 2018-19 Mr. Abdul Khader Kodi Darul Huda, Near Salafi Masjid Kunjathur Via Dcit Manjeshwar Central Circle-2 Vs. Kasargod 671 323 Mangaluru Karnataka Pan No : Alhpk5340F Appellant Respondent Appellant By : Shri Ravishankar S.V., A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: These Appeals By Assessee Are Directed By Different Orders Of Nfac For The Assessment Years 2016-17 To 2018-19 Having Common Date Dated 23.5.2022. 2. The Grounds Raised By The Assessee In All These Appeals Are Common In Nature, Except Change In Figures. We Consider Grounds In Ita No.636/Bang/2023, Which Reads As Follows: 1. The Learned Cit(A)-2, Panaji Erred In Passing The Order In The Manner He Did. 2. The Ld. Cit(A)-2, Panaji Erred In Upholding The Additions Made By The Assessing Officer Amounting To Rs.6,25,000 As Undisclosed Business Income & Rs.1,99,40,000 As Unexplained Investments Under Section 68 Of The Income Tax Act, 1961, Which Was Purely On Assumptions & Presumptions Based On The Loose Sheet Found At The Time Of Search.

For Appellant: Shri Ravishankar S.V., A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 132Section 144Section 153ASection 34Section 68Section 69Section 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 evide…

Mr. Abdul Khader Kodi, Kasargod, Karnataka vs. Mr. C. Vinod Jayan, Deputy Commissioner of Income Tax, Mangalore

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 636/BANG/2023[2016-2017]Status: DisposedITAT Bangalore22 Mar 2024AY 2016-2017

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.636 To 638/Bang/2023 Assessment Years: 2016-17 To 2018-19 Mr. Abdul Khader Kodi Darul Huda, Near Salafi Masjid Kunjathur Via Dcit Manjeshwar Central Circle-2 Vs. Kasargod 671 323 Mangaluru Karnataka Pan No : Alhpk5340F Appellant Respondent Appellant By : Shri Ravishankar S.V., A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: These Appeals By Assessee Are Directed By Different Orders Of Nfac For The Assessment Years 2016-17 To 2018-19 Having Common Date Dated 23.5.2022. 2. The Grounds Raised By The Assessee In All These Appeals Are Common In Nature, Except Change In Figures. We Consider Grounds In Ita No.636/Bang/2023, Which Reads As Follows: 1. The Learned Cit(A)-2, Panaji Erred In Passing The Order In The Manner He Did. 2. The Ld. Cit(A)-2, Panaji Erred In Upholding The Additions Made By The Assessing Officer Amounting To Rs.6,25,000 As Undisclosed Business Income & Rs.1,99,40,000 As Unexplained Investments Under Section 68 Of The Income Tax Act, 1961, Which Was Purely On Assumptions & Presumptions Based On The Loose Sheet Found At The Time Of Search.

For Appellant: Shri Ravishankar S.V., A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 132Section 144Section 153ASection 34Section 68Section 69Section 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 evide…

Assistant Commissioner of Income Tax, Central Circle-2(2), Hyderabad vs. Laxmi Komatireddy, Hyderabad

In the result, appeal of the Revenue is dismissed

ITA 297/HYD/2022[2015-16]Status: DisposedITAT Hyderabad21 Mar 2024AY 2015-16

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH Vijaya Lakshmi, CIT-DR
Section 131(1)Section 132Section 153A

…not tenable as the search was conducted on 21-07-2016 and the dates on the agreement for sale was 20-01-2015. These agreements predate the search. 7.3.6 The Hon'ble Supreme Court in the case of M/s.pullangode Rubber Produce Co. ltd. vs. State of Kerala (1973) 91 ITR 18 (SC) held that an admission is an extremely important piece of evidence but it cannot be set to be conclusive. It is open for the person who makes an admission to show that it is incorrect. In this case the statements were recorded under section 131 of the Act and not under section 132(4) of the Act. These statements were later retracted before the…

Kandathil Jewellers, Kerala vs. DCIT, Circle Ingtl. Txan, Kerala

In the result, the assessee’s appeals are dismissed

ITA 874/COCH/2022[2019-20]Status: DisposedITAT Cochin21 Feb 2024AY 2019-20

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Jyothison J., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 133ASection 148(1)Section 44A

…e’s case for availing the summary procedure u/s. 44AD. What we seek to emphasize is the evidentiary value of the said return/s, a legal document bearing his verification. Admission, as explained in Pullangode Rubber Produce Co. Ltd. vs. State of Kerala [1963] 91 ITR 18 (SC), is an extremely important piece of evidence (Bhagirath Aggarwal v. CIT [2013] 351 ITR 143 (Ker)). That apart, Shri Shukoor, the person managing the business and, further, looking after both it’s purchases and sales (refer answer to Q.4), per his statement dated 15/16.10.2019, admits to disclosing sales at, on an average, 85% of the actual sal…

Kandathil Jewellers, Kerala vs. DCIT, Circle Ingtl. Txan, Kerala

In the result, the assessee’s appeals are dismissed

ITA 873/COCH/2022[2016-17]Status: DisposedITAT Cochin21 Feb 2024AY 2016-17

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Jyothison J., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 133ASection 148(1)Section 44A

…e’s case for availing the summary procedure u/s. 44AD. What we seek to emphasize is the evidentiary value of the said return/s, a legal document bearing his verification. Admission, as explained in Pullangode Rubber Produce Co. Ltd. vs. State of Kerala [1963] 91 ITR 18 (SC), is an extremely important piece of evidence (Bhagirath Aggarwal v. CIT [2013] 351 ITR 143 (Ker)). That apart, Shri Shukoor, the person managing the business and, further, looking after both it’s purchases and sales (refer answer to Q.4), per his statement dated 15/16.10.2019, admits to disclosing sales at, on an average, 85% of the actual sal…

Kandathil Jewellers, Kerala vs. DCIT International Taxation Circle, Trivandrum

In the result, the assessee’s appeals are dismissed

ITA 872/COCH/2022[2015-16]Status: DisposedITAT Cochin21 Feb 2024AY 2015-16

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Jyothison J., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 133ASection 148(1)Section 44A

…e’s case for availing the summary procedure u/s. 44AD. What we seek to emphasize is the evidentiary value of the said return/s, a legal document bearing his verification. Admission, as explained in Pullangode Rubber Produce Co. Ltd. vs. State of Kerala [1963] 91 ITR 18 (SC), is an extremely important piece of evidence (Bhagirath Aggarwal v. CIT [2013] 351 ITR 143 (Ker)). That apart, Shri Shukoor, the person managing the business and, further, looking after both it’s purchases and sales (refer answer to Q.4), per his statement dated 15/16.10.2019, admits to disclosing sales at, on an average, 85% of the actual sal…

Ram Dhan Yadav, Chomu Jaipur vs. Income Tax Officer, ITO 7(3), Jaipur

In the result, both the appeals of the assessee are allowed

ITA 369/JPR/2023[2008-09]Status: DisposedITAT Jaipur20 Feb 2024AY 2008-09

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajesh Soni (C.A.)For Respondent: Shri Anoop Singh (Addl.CIT)
Section 143(3)Section 144Section 147Section 148Section 69B

…he basis of it. Further in such cases of doubtfulness, benefit of doubt should go in favour of assessee. Ashwani kumar Bhardwaj V/s DCIT (Jpr.) 21 TW 358 7. In the case of Pullangode Rubber Products Co. Ltd. V/s State of Kerala &Anr. 1972 CTR (SC) 253 (1973) 91 ITR 18 (SC), the Hon’ble Supreme Court has held that an admission in a statement recorded on oath is an extremely important piece of evidence but it cannot be said that it is conclusive and it is always open to the person who made the admission to show that it is incorrect. Pullangode Rubber Products Co . Ltd. V/s State of Kerala : 91 ITR 18 (SC) 8. Wheth…

Ram Dhan Yadav, Chomu Jaipur vs. ITO, WD 7(3), Jaipur

In the result, both the appeals of the assessee are allowed

ITA 366/JPR/2023[2007-2008]Status: DisposedITAT Jaipur20 Feb 2024AY 2007-2008

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajesh Soni (C.A.)For Respondent: Shri Anoop Singh (Addl.CIT)
Section 143(3)Section 144Section 147Section 148Section 69B

…he basis of it. Further in such cases of doubtfulness, benefit of doubt should go in favour of assessee. Ashwani kumar Bhardwaj V/s DCIT (Jpr.) 21 TW 358 7. In the case of Pullangode Rubber Products Co. Ltd. V/s State of Kerala &Anr. 1972 CTR (SC) 253 (1973) 91 ITR 18 (SC), the Hon’ble Supreme Court has held that an admission in a statement recorded on oath is an extremely important piece of evidence but it cannot be said that it is conclusive and it is always open to the person who made the admission to show that it is incorrect. Pullangode Rubber Products Co . Ltd. V/s State of Kerala : 91 ITR 18 (SC) 8. Wheth…

Sh. Madan Lal Gupta, Keshav Nagar, Alwar vs. Addl. CIT, Central Range, Jaipur

In the result appeal of the assessee in ITA No

ITA 580/JPR/2023[2017-18]Status: DisposedITAT Jaipur09 Feb 2024AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Anoop Singh (Addl. CIT) a
Section 115BSection 132Section 132(4)Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 271D

…ect. The department has no evidence/documents which prove that surrender in statement by assessee is correct, therefore the same cannot be relied upon. The Hon'ble Apex Court in the case of Pullangode Rubber Produce Co Ltd v/s State of Kerala & Another (1973) 91 ITR 18 (SC) has held that admission is an extremely important piece of evidence but it can't be said that it is conclusive. It is upon to the assessee to show that it is incorrect. The Hon'ble Rajasthan High Court in the case of CIT v/s Ashok Kumar Soni 291 ITR 172 (Raj.) has held that admission in Sh. Madan Lal Gupta vs. ACIT statement during search is n…

Sh. Madan Lal Gupta, Keshav Nagar, Alwar vs. ACIT, Central Circle, Alwar

In the result appeal of the assessee in ITA No

ITA 579/JPR/2023[2017-18]Status: DisposedITAT Jaipur09 Feb 2024AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Anoop Singh (Addl. CIT) a
Section 115BSection 132Section 132(4)Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 271D

…ect. The department has no evidence/documents which prove that surrender in statement by assessee is correct, therefore the same cannot be relied upon. The Hon'ble Apex Court in the case of Pullangode Rubber Produce Co Ltd v/s State of Kerala & Another (1973) 91 ITR 18 (SC) has held that admission is an extremely important piece of evidence but it can't be said that it is conclusive. It is upon to the assessee to show that it is incorrect. The Hon'ble Rajasthan High Court in the case of CIT v/s Ashok Kumar Soni 291 ITR 172 (Raj.) has held that admission in Sh. Madan Lal Gupta vs. ACIT statement during search is n…

Sh. Lachhman Dass Bansal, Barnala vs. DCIT, Central Circle, Patiala

The appeal of the assessee is partly allowed

ITA 34/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh12 Jan 2024AY 2018-19

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. D.R
Section 115BSection 133ASection 143(1)Section 143(2)Section 69Section 69A

…t is incorrect and that the assessee should be given a proper opportunity to show that the books of accounts do not correctly disclose the correct state of facts, vide decision of the Apex Court in Pullangode Rubber Produce Co. Ltd. v. State of Kerala, [1973] 91 ITR 18; (ii) In contradistinction to the power under Section 133A, Section 132(4) of the Income Tax Act enables the authorised officer to examine a person on oath and any statement made by such person during such examination can also be used in evidence under the Income Tax Act. On the other hand, whatever statement is recorded under Section 133A of the I…

Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad vs. Varsha Viswanath Properties Private Limited, Hyderabad

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2050/HYD/2018[2016-17]Status: DisposedITAT Hyderabad09 Jan 2024AY 2016-17

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

…these statements - Held, yes [Paras 18 & 20] [In favour of revenue}” The evidentiary value of the statements relied upon is, therefore, undeniable. 5.3.5 The Hon'ble Supreme Court in the case of Pullangode Rubber Products Co. Ltd. Vs. State of Kerala: (1973) 91 ITR 18 SC held that an admission is an extremely important piece of evidence but it cannot be said that it is conclusive. It was contended that it was open to the person who made the statement to show that it was incorrect. There cannot be any doubt about this position in law, but, in the present case the appellant/assessee has not produced any material t…

Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad vs. Varsha Viswanath Properties Private Limited, Hyderabad

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2049/HYD/2018[2015-16]Status: DisposedITAT Hyderabad09 Jan 2024AY 2015-16

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

…these statements - Held, yes [Paras 18 & 20] [In favour of revenue}” The evidentiary value of the statements relied upon is, therefore, undeniable. 5.3.5 The Hon'ble Supreme Court in the case of Pullangode Rubber Products Co. Ltd. Vs. State of Kerala: (1973) 91 ITR 18 SC held that an admission is an extremely important piece of evidence but it cannot be said that it is conclusive. It was contended that it was open to the person who made the statement to show that it was incorrect. There cannot be any doubt about this position in law, but, in the present case the appellant/assessee has not produced any material t…

Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad vs. Varsha Viswanath Properties Private Limited, Hyderabad

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2048/HYD/2018[2014-15]Status: DisposedITAT Hyderabad09 Jan 2024AY 2014-15

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

…these statements - Held, yes [Paras 18 & 20] [In favour of revenue}” The evidentiary value of the statements relied upon is, therefore, undeniable. 5.3.5 The Hon'ble Supreme Court in the case of Pullangode Rubber Products Co. Ltd. Vs. State of Kerala: (1973) 91 ITR 18 SC held that an admission is an extremely important piece of evidence but it cannot be said that it is conclusive. It was contended that it was open to the person who made the statement to show that it was incorrect. There cannot be any doubt about this position in law, but, in the present case the appellant/assessee has not produced any material t…

Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad vs. Varsha Viswanath Properties Private Limited, Hyderabad

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2047/HYD/2018[2013-14]Status: DisposedITAT Hyderabad09 Jan 2024AY 2013-14

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

…these statements - Held, yes [Paras 18 & 20] [In favour of revenue}” The evidentiary value of the statements relied upon is, therefore, undeniable. 5.3.5 The Hon'ble Supreme Court in the case of Pullangode Rubber Products Co. Ltd. Vs. State of Kerala: (1973) 91 ITR 18 SC held that an admission is an extremely important piece of evidence but it cannot be said that it is conclusive. It was contended that it was open to the person who made the statement to show that it was incorrect. There cannot be any doubt about this position in law, but, in the present case the appellant/assessee has not produced any material t…