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 366,005 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

M/S. Barbeque Nation Hospitality Ltd, Bengaluru vs. Deputy Commissioner of Income-Tax, Central Circle-2(2), Bengaluru

In the result, appeals filed by the assessee are partly allowed

ITA 22/BANG/2024[2014-15]Status: DisposedITAT Bangalore31 Oct 2025AY 2014-15

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore
Section 153ASection 234ASection 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.21 to 26/Bang/2024 Assessment Years : 2013-14 to 2018-19 M/s. Barbeque-Nation Hospitality Ltd., Vs. DCIT, Saket Callipolis, Unit No. 601 & 602, Circle – 2(2), 6th Floor, Doddakannalli Village, Bangalore. Varthur Hobli, Sarjapur Road, Bengaluru – 560035. PAN : AAKCS3053N APPELLANT RESPONDENT Assessee by : Shri. A. Shankar, Sr. Advocate Revenue by : Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore. Date of hearing : 18.09.2025 Date of Pronouncement : 31.10.2025 O…

M/S. Barbeque Nation Hospitality Ltd, Bengaluru vs. Deputy Commissioner of Income-Tax, Circle-2(2), Bengaluru

In the result, appeals filed by the assessee are partly allowed

ITA 21/BANG/2024[2013-14]Status: DisposedITAT Bangalore31 Oct 2025AY 2013-14

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore
Section 153ASection 234ASection 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.21 to 26/Bang/2024 Assessment Years : 2013-14 to 2018-19 M/s. Barbeque-Nation Hospitality Ltd., Vs. DCIT, Saket Callipolis, Unit No. 601 & 602, Circle – 2(2), 6th Floor, Doddakannalli Village, Bangalore. Varthur Hobli, Sarjapur Road, Bengaluru – 560035. PAN : AAKCS3053N APPELLANT RESPONDENT Assessee by : Shri. A. Shankar, Sr. Advocate Revenue by : Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore. Date of hearing : 18.09.2025 Date of Pronouncement : 31.10.2025 O…

Sunil Kumar Agarwal, Jaipur vs. ACIT, Cen. Cir-2, Jaipur

In the result the appeal of the assessee in ITA no

ITA 513/JPR/2025[2016-17]Status: DisposedITAT Jaipur14 Oct 2025AY 2016-17
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Anita Rinesh, JCIT, Sr-DR
Section 132Section 139Section 153ASection 234B

…return filing, are admissions in law. The Hon'ble Supreme Court and various High Courts have held that admissions made voluntarily and with legal representation carry significant evidentiary value (refer: Pullangode Rubber Produce Co. Ltd. v. State of Kerala 91 ITR 18 (SC)). Conclusion: The material on Page 27 confirms that both the assessee and his AR were fully conscious of the nature of the transactions as reflected in the seized Excel sheet. The surrender of income and return filed under Section 148. backed by the assessee's own explanation and tax payment, amounts to unequivocal admission of unaccounted inc…

Deputy Commissioner of Income-Tax, Central Circle-3, Jaipur vs. Karnani Solvex Private Limited, Jaipur

In the result, the appeals of the revenue in ITA No

ITA 480/JPR/2025[2014-15]Status: DisposedITAT Jaipur13 Oct 2025AY 2014-15
For Appellant: Shri Deepak Sharma, CAFor Respondent: MS. Alka Gautam, CIT
Section 127Section 132(4)Section 153ASection 68

…t scrutinizing documents. The ld. AO also noted that the statement made by the assessee is binding in nature and the same has not been retracted by him and thereby he relied upon the case law of (i) Pullangode Rubber Produce Co. Ltd. V. State of Kerala [1973] 91 ITR 18 (SC), (ii) Narayan Bhagwantrao Gosavi Balajiwale v. Gopal Vinayak Gosavi Al 1960 SC 100, (iii) Satinder Kumar (HUF) v. CIT [1977] 106 ITR 64 (SC) and (iv) Avadh Kishore Das v. Ram Gopal AIR 1979 SC 861 and thereby he concluded that unsecured loan shown to have been received by the assessee is actually an accommodation entry and thereby he considere…

Asst. Commissioner of Income Tax - 7(1)(1), Mumbai, Maharashtra vs. Master Chain Pvt. Ltd., Mumbai, Maharashtra

In the result, the appeal filed by the revenue stands dismissed

ITA 5397/MUM/2024[2022-23]Status: DisposedITAT Mumbai13 Oct 2025AY 2022-23

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Salil Kapoor a/w Ms. SoumyaFor Respondent: Ms. Kavitha Kaushik (SR DR)
Section 139(1)Section 143(3)Section 250

…evidence to prove this letter, it could be taken into account as evidence. But before the Income Tax Authorities could rely upon it, they were bound to produce it made by him." Hon'ble Apex Court in Pullangode Rubber Produce Co., Ltd V. State of Kerala (1973) 91 ITR 18 (SC) held that the admission is an extremely important piece of evidence, has held that, it cannot be said to be conclusive and the maker can show that it was incorrect. The statement is factually incorrect for the detailed reasons stated above and in the instant case sole reliance is place on such factually incorrect statement.6.22 The Hon'ble Sup…

Deepak Vohra, Delhi vs. DCIT, Central Circle-29, Delhi

ITA 824/DEL/2024[2014-15]Status: DisposedITAT Delhi13 Oct 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 131Section 147Section 69A

…by other evidences brought on record by the AO. Reliance is placed on the judgements of Hon'ble Delhi High Court in the case of CIT Vs S M Agarwal, 93 Taxmann.com 247 and Hon'ble Supreme Court in Pullan-gode Rubber Produce Co. Ltd. v. State of Kerala, (1973) 91 ITR 18. 10.6 In view of the facts stated above, I find that the statement of the appellant and other evidences relied upon by the AO are adequate to prove that the entities namely M/s. S.S. International, M/s. Sunlight Overseas, M/s. Moonlight Overseas and M/s. Jhalak International were managed and controlled by him and money found to be deposited in the…

Deepak Vohra, Delhi vs. Assist. CIT, CC- 29, New Delhi

ITA 1054/DEL/2024[2015-16]Status: DisposedITAT Delhi13 Oct 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 131Section 147Section 69A

…by other evidences brought on record by the AO. Reliance is placed on the judgements of Hon'ble Delhi High Court in the case of CIT Vs S M Agarwal, 93 Taxmann.com 247 and Hon'ble Supreme Court in Pullan-gode Rubber Produce Co. Ltd. v. State of Kerala, (1973) 91 ITR 18. 10.6 In view of the facts stated above, I find that the statement of the appellant and other evidences relied upon by the AO are adequate to prove that the entities namely M/s. S.S. International, M/s. Sunlight Overseas, M/s. Moonlight Overseas and M/s. Jhalak International were managed and controlled by him and money found to be deposited in the…

Bysani Srinath Mamatha, Bengaluru vs. Joint Commissioner of Income Tax (OSD), Central Circle-1(3), Bengaluru

In the result, the appeals of the assessee for

ITA 410/BANG/2025[2018-19]Status: DisposedITAT Bangalore09 Oct 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

…r. 7.2 Before going to the issue, we find pertinent to discuss the evidentiary value of statements recorded during the search and during the post search proceeding. The Hon'ble Supreme Court in Pullangode Rubber Produce Co. Ltd. v. State of Kerala reported in 91 ITR 18 holds that an admission is a very important piece of evidence, but it is not conclusive; the maker can show it was incorrect. On the other hand, where a voluntary statement under oath is clear and later retraction is belated or unsupported, the statement shall be treated as reliable evidence as held by the several courts including Hon'ble Supreme C…

Bysani Srinath Mamatha, Bengaluru vs. Joint Commissioner of Income Tax (OSD) Central Circle-1(3), Bengaluru

ITA 409/BANG/2025[2017-18]Status: DisposedITAT Bangalore09 Oct 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

…. 7.2 Before going to the issue, we find pertinent to discuss the evidentiary value of statements recorded during the search and during the post search proceeding. The Hon'ble Supreme Court in Pullangode Rubber Produce Co. Ltd. v. State of Kerala reported in 91 ITR 18 holds that an admission is a very important piece of evidence, but it is not conclusive; the maker can show it was incorrect. On the other hand, where a voluntary statement under oath is clear and later retraction is belated or unsupported, the statement shall be treated as reliable evidence as held by the several courts including Hon'ble Supreme C…

Bysani Srinath Mamatha, Bengaluru vs. Joint Commissioner of Income Tax(OSD), Central Circle-1(3), Bengaluru

ITA 408/BANG/2025[2016-17]Status: DisposedITAT Bangalore09 Oct 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

…r. 7.2 Before going to the issue, we find pertinent to discuss the evidentiary value of statements recorded during the search and during the post search proceeding. The Hon'ble Supreme Court in Pullangode Rubber Produce Co. Ltd. v. State of Kerala reported in 91 ITR 18 holds that an admission is a very important piece of evidence, but it is not conclusive; the maker can show it was incorrect. On the other hand, where a voluntary statement under oath is clear and later retraction is belated or unsupported, the statement shall be treated as reliable evidence as held by the several courts including Hon'ble Supreme C…

Bysani Srinath Mamatha, Bengaluru vs. Joint Commissioner of Income Tax (OSD) Central Circle-1(3), Bengaluru

In the result, the appeals of the assessee for Assessment Years

ITA 407/BANG/2025[2015-16]Status: DisposedITAT Bangalore09 Oct 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

…r. 7.2 Before going to the issue, we find pertinent to discuss the evidentiary value of statements recorded during the search and during the post search proceeding. The Hon’ble Supreme Court in Pullangode Rubber Produce Co. Ltd. v. State of Kerala reported in 91 ITR 18 holds that an admission is a very important piece of evidence, but it is not conclusive; the maker can show it was incorrect. On the other hand, where a voluntary statement under oath is clear and later retraction is belated or unsupported, the statement shall be treated as reliable evidence as held by the several courts including Hon’ble Supreme C…

Bysani Srinath Mamatha, Bengaluru vs. Joint Commissioner of Income Tax (OSD), Central Circle-1(3), Bengaluru

ITA 406/BANG/2025[2014-15]Status: DisposedITAT Bangalore09 Oct 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

…r. 7.2 Before going to the issue, we find pertinent to discuss the evidentiary value of statements recorded during the search and during the post search proceeding. The Hon'ble Supreme Court in Pullangode Rubber Produce Co. Ltd. v. State of Kerala reported in 91 ITR 18 holds that an admission is a very important piece of evidence, but it is not conclusive; the maker can show it was incorrect. On the other hand, where a voluntary statement under oath is clear and later retraction is belated or unsupported, the statement shall be treated as reliable evidence as held by the several courts including Hon'ble Supreme C…

Bysani Srinath Mamatha, Bengaluru vs. Joint Commissioner of Income Tax, (OSD) Central Circle-1(3), Bengaluru

ITA 405/BANG/2025[2013-14]Status: DisposedITAT Bangalore09 Oct 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

…. 7.2 Before going to the issue, we find pertinent to discuss the evidentiary value of statements recorded during the search and during the post search proceeding. The Hon'ble Supreme Court in Pullangode Rubber Produce Co. Ltd. v. State of Kerala reported in 91 ITR 18 holds that an admission is a very important piece of evidence, but it is not conclusive; the maker can show it was incorrect. On the other hand, where a voluntary statement under oath is clear and later retraction is belated or unsupported, the statement shall be treated as reliable evidence as held by the several courts including Hon'ble Supreme C…

Bysani Adinarayagupatha Srinath, Bengaluru vs. Joint Commissioner of Income Tax (OSD), Central Circle-1(3), Bengaluru

ITA 404/BANG/2025[2018-19]Status: DisposedITAT Bangalore09 Oct 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

…r. 7.2 Before going to the issue, we find pertinent to discuss the evidentiary value of statements recorded during the search and during the post search proceeding. The Hon'ble Supreme Court in Pullangode Rubber Produce Co. Ltd. v. State of Kerala reported in 91 ITR 18 holds that an admission is a very important piece of evidence, but it is not conclusive; the maker can show it was incorrect. On the other hand, where a voluntary statement under oath is clear and later retraction is belated or unsupported, the statement shall be treated as reliable evidence as held by the several courts including Hon'ble Supreme C…

Bysani Adinarayaguptha Srinath, Bengaluru vs. Joint Commissioner of Income Tax (OSD), Central Circle-1(3), Bengaluru

In the result, the appeals of the assessee for Assessment Years

ITA 402/BANG/2025[2016-17]Status: DisposedITAT Bangalore09 Oct 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

…r. 7.2 Before going to the issue, we find pertinent to discuss the evidentiary value of statements recorded during the search and during the post search proceeding. The Hon’ble Supreme Court in Pullangode Rubber Produce Co. Ltd. v. State of Kerala reported in 91 ITR 18 holds that an admission is a very important piece of evidence, but it is not conclusive; the maker can show it was incorrect. On the other hand, where a voluntary statement under oath is clear and later retraction is belated or unsupported, the statement shall be treated as reliable evidence as held by the several courts including Hon’ble Supreme C…

Bysani Adinarayaguptha Srinath, Bengaluru vs. Joint Commissioner of Income Tax (OSD), Central Circle-1(3), Bengaluru

ITA 401/BANG/2025[2015-16]Status: DisposedITAT Bangalore09 Oct 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 131Section 132Section 132(4)Section 153A

…r. 7.2 Before going to the issue, we find pertinent to discuss the evidentiary value of statements recorded during the search and during the post search proceeding. The Hon'ble Supreme Court in Pullangode Rubber Produce Co. Ltd. v. State of Kerala reported in 91 ITR 18 holds that an admission is a very important piece of evidence, but it is not conclusive; the maker can show it was incorrect. On the other hand, where a voluntary statement under oath is clear and later retraction is belated or unsupported, the statement shall be treated as reliable evidence as held by the several courts including Hon'ble Supreme C…

Bysani Adinarayaguptha Srinath, Bengaluru vs. Joint Commissioner of Income Tax(OSD), Central Circle 1(3), Bengaluru

ITA 400/BANG/2025[2014-15]Status: DisposedITAT Bangalore09 Oct 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

…. 7.2 Before going to the issue, we find pertinent to discuss the evidentiary value of statements recorded during the search and during the post search proceeding. The Hon'ble Supreme Court in Pullangode Rubber Produce Co. Ltd. v. State of Kerala reported in 91 ITR 18 holds that an admission is a very important piece of evidence, but it is not conclusive; the maker can show it was incorrect. On the other hand, where a voluntary statement under oath is clear and later retraction is belated or unsupported, the statement shall be treated as reliable evidence as held by the several courts including Hon'ble Supreme C…

Bysani Adinarayaguptha Srinath, Bengaluru vs. Joint Commissioner of Income Tax(OSD), Central Circle-1(3), Bengaluru

ITA 399/BANG/2025[2013-14]Status: DisposedITAT Bangalore09 Oct 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

…. 7.2 Before going to the issue, we find pertinent to discuss the evidentiary value of statements recorded during the search and during the post search proceeding. The Hon'ble Supreme Court in Pullangode Rubber Produce Co. Ltd. v. State of Kerala reported in 91 ITR 18 holds that an admission is a very important piece of evidence, but it is not conclusive; the maker can show it was incorrect. On the other hand, where a voluntary statement under oath is clear and later retraction is belated or unsupported, the statement shall be treated as reliable evidence as held by the several courts including Hon'ble Supreme C…

Brand India Real Estate Private Limited, Jaipur vs. Income Tax Officer Ward 6(1), Jaipur

In the result, appeal of the assessee is allowed

ITA 514/JPR/2025[2012-2013]Status: DisposedITAT Jaipur29 Sept 2025AY 2012-2013
For Appellant: Shri Siddharth Ranka, Adv. &For Respondent: Shri Dharam Singh Meena, JCIT
Section 132Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250

…आयकर अपीलीय अधिकरण, जयपुर न्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR डा० एस. सीतालक्ष्मी, न्यायिक सदस्य एवं श्री गगन गोयल, लेखा सदस्य, के समक्ष BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI GAGAN GOYAL, AM आयकर अपील सं./ITA No. 514/JPR/2025 निर्धारण वर्ष / Assessment Years : 2012-13 Brand India Real Estate Pvt. Ltd. 262, C Block Malviya Nagar, Jaipur. Vs. Income Tax Officer, Ward-6(1), Jaipur. स्थायीलेखा सं. / जीआईआर सं./PAN/GIR No.: AADCP7925K अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओरसे / Assesseeby : Shri Siddharth Ranka, Adv. & Ms. Satwika Jha, Adv. राजस्व की…

Dy.Commissioner of Income Tax, CC-2, Kanpur vs. Shri.Mohammad Asfand Akhtar, Kanpur

In the result, the appeal of Revenue in ITA

ITA 144/LKW/2022[2018-19]Status: DisposedITAT Lucknow26 Sept 2025AY 2018-19

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshraassessment Year: 2018-19 Dcit, Cc-2 V. Shri Mohammad Asfand Laxmi Niwas, 10/503, Akhtar Allenganj, Kanpur-208001. Plot No.02, Block-B, Scheme-39, Ram Rai Ki Sarai, Jajmau, Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Assessment Year: 2018-19 Shri Mohammad Asfand Akhtar V. Dcit, Central Circle-Ii Plot No.02, Block-B, Scheme-39, 10/503, Allenganj, Kanpur- Ram Rai Ki Sarai, Jajmau, 208001. Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Appellant By: Shri Ashish Jaiswal, Advocate Respondent By: Shri R. K. Agarwal, Cit(Dr) O R D E R

For Appellant: Shri Ashish Jaiswal, AdvocateFor Respondent: Shri R. K. Agarwal, CIT(DR)
Section 143(3)Section 36(1)(va)Section 37Section 41Section 41(1)Section 68Section 69C

…et aside and addition of Rs.14,00,000/- is deleted. The appeal of the assessee is accordingly allowed.” 33. It is further humbly submitted that It was held in the case of Paul Mathews & Sons v. CIT reported in 263 ITR 101 (Ker) apex court judgment reported in 91 ITR 18 (SC) and CIT v. S. Khader Khan Son reported in 300 ITR 157 (Mad) that no addition is called for also in view of CBDT Instruction. Section 133A of the Act empower any authority to examine any person on oath, and such statement has an evidentiary value and any admission made during the search such statement cannot be itself be made the basis for addi…