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

A Govindaraj, Deputy Commissioner of Income Tax, Central Circle -2 Madurai, Central Range, Madurai vs. Chelladhurai Rajasingh, Sivakasi

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

ITA 130/CHNY/2024[2013-2014]Status: DisposedITAT Chennai28 Aug 2024AY 2013-2014

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.130/Chny/2024 िनधा"रण वष"/Assessment Year: 2013-14 V. The Dcit, Shri Chelladhurai Rajasingh, Central Circle-2, No.84, Railway Feeder Road, Madurai. Kamarajar Road, Sivakasi-626 123. [Pan: Aaqpr 9845 L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri I. Dinesh, AdvocateFor Respondent: Shri R. Clement Ramesh-
Section 132Section 132(4)Section 153C

…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-30, New Delhi vs. Urmila Goyal, New Delhi

In the result, the appeal of the revenue is dismissed

ITA 1651/DEL/2020[2016-17]Status: DisposedITAT Delhi28 Aug 2024AY 2016-17

Bench: Sh. Dr. B.R.R. Kumar & Sh. Sudhir Kumarassessment Year: 2016-17 Dcit Central Vs Smt Urmila Goyal Circle – 30 K-69 Hauz Khas Enclave New Delhi Delhi Pan No.Aaopg3349Q (Appellant) (Respondent) Appellants By Smt Sapana Bhatia Cit-Dr Respondent By Sh. Prateek Mittal Ca

Section 132Section 132(4)Section 139Section 153ASection 69

…ng the search. He has further submitted that the statement of Dhruva Goel has no value because this is a retracted statement. 7. Reliance has placed on the following judgments:- 1. Pullangode Rubber Produce Company Ltd. Vs. State of Kerala and Another (1973) 91 ITR 18 (SC) 2. Hon’ble Rajasthan High Court in case of CIT Vs. Ashok Kumar Soni (2007) 291 ITR 172 (Raj) 3. Asstt. CIT Vs. Jorawar Singh M. Rathod [2005] 94 TTJ (Ahd.) 867 8. The Ld CIT(A) has observed in his order us under :- “12. In this case the Assessing Officer has made protective addition of Rs.6,25,00,000/- u/s. 69 of the Act, to the income of the…

DCIT Central Circle- 30, New Delhi vs. Dhruva Goel, New Delhi

In the result, the appeals of the revenue and assessee are dismissed

ITA 1648/DEL/2020[2016-17]Status: DisposedITAT Delhi28 Aug 2024AY 2016-17

Bench: Sh. Dr B.R.R Kumar & Sh. Sudhir Kumarassessment Year: 2016-17 Dcit Central Vs Dhruva Goel Circle – 30 K-69, Hauz Khas New Delhi Enclave, New Delhi Pan No. Aazpg0330Q (Appellant) (Respondent) Assessment Year: 2016-17 Dhruva Goel Vs Dcit Central K-69, Hauz Khas Enclave, Circle – 30 New Delhi New Delhi Pan No. Aazpg0330Q (Appellant) (Respondent) Appellants By Smt Sapana Bhatia Cit-Dr Respondent By Sh. Prateek Mittal Ca

Section 132Section 132(4)Section 139Section 153ASection 69

…proceedings. He has further submitted that the statement of Dhruva Goel has no value because this is a retracted statement. 7. Reliance has placed on the following judgments :- 1. Pullangode Rubber Produce Company Ltd. Vs. State of Kerala and Another (1973) 91 ITR 18 (SC) 2. Hon’ble Rajasthan High Court in case of CIT Vs. Ashok Kumar Soni (2007) 291 ITR 172 (Raj) 3. Asstt. CIT Vs. Jorawar Singh M. Rathod [2005] 94 TTJ (Ahd.) 867 8. The Ld CIT(A) has observed in his order are as under :- 10.5 I have carefully gone through the assessment order, the written submissions of the appellant and the relevant case laws.…

Dhruva Goel, New Delhi vs. ACIT Central Circle-30, New Delhi

In the result, the appeals of the revenue and assessee are dismissed

ITA 1604/DEL/2020[2016-17]Status: DisposedITAT Delhi28 Aug 2024AY 2016-17

Bench: Sh. Dr B.R.R Kumar & Sh. Sudhir Kumarassessment Year: 2016-17 Dcit Central Vs Dhruva Goel Circle – 30 K-69, Hauz Khas New Delhi Enclave, New Delhi Pan No. Aazpg0330Q (Appellant) (Respondent) Assessment Year: 2016-17 Dhruva Goel Vs Dcit Central K-69, Hauz Khas Enclave, Circle – 30 New Delhi New Delhi Pan No. Aazpg0330Q (Appellant) (Respondent) Appellants By Smt Sapana Bhatia Cit-Dr Respondent By Sh. Prateek Mittal Ca

Section 132Section 132(4)Section 139Section 153ASection 69

…proceedings. He has further submitted that the statement of Dhruva Goel has no value because this is a retracted statement. 7. Reliance has placed on the following judgments :- 1. Pullangode Rubber Produce Company Ltd. Vs. State of Kerala and Another (1973) 91 ITR 18 (SC) 2. Hon’ble Rajasthan High Court in case of CIT Vs. Ashok Kumar Soni (2007) 291 ITR 172 (Raj) 3. Asstt. CIT Vs. Jorawar Singh M. Rathod [2005] 94 TTJ (Ahd.) 867 8. The Ld CIT(A) has observed in his order are as under :- 10.5 I have carefully gone through the assessment order, the written submissions of the appellant and the relevant case laws.…

Assistant Commissioner of Income Tax, Central Circle, Kota vs. Nisha Jain, Kota

In the result, the appeal of the Revenue is dismissed with no orders as to cost

ITA 378/JPR/2024[2017-18]Status: DisposedITAT Jaipur05 Aug 2024AY 2017-18
For Appellant: Shri Mahendra Gargieya AdvFor Respondent: Shri A.S. Nehra, Addl. CIT-DR fu/kZkfjrh dh vksj ls@
Section 131

…ce against such person, if shown to be out of ambiguity, under tension or was against the facts or misconception of law, can be validly retracted. It has been held by the Hon’ble Supreme Court in Pullangode Rubber Produce Co. Ltd. vs. State of Kerala & Others 91 ITR 18 (SC): “Such admission is an extremely important piece of evidence, but it cannot be said that it is conclusive. It is open to the assessee who made the admission to show that it is incorrect, and the assessee should be given a proper opportunity to show that the books of accounts do not disclose the correct state of facts”. 4.4.2 The Hon’ble Apex C…

Assistant Commissioner of Income Tax, Central Circle, Kota vs. Naresh Jain, Kota

ITA 374/JPR/2024[2017-18]Status: DisposedITAT Jaipur05 Aug 2024AY 2017-18
For Appellant: Shri Mahendra Gargieya AdvFor Respondent: Shri A.S. Nehra, Addl. CIT-DR
Section 131Section 133ASection 133A(3)(iii)

…ce against such person, if shown to be out of ambiguity, under tension or was against the facts or misconception of law, can be validly retracted. It has been held by the Hon'ble Supreme Court in Pullangode Rubber Produce Co. Ltd. vs. State of Kerala & Others 91 ITR 18 (SC): “Such admission is an extremely important piece of evidence, but it cannot be said that it is conclusive. It is open to the assessee who made the admission to show that it is incorrect, and the assessee should be given a proper opportunity to show that the books of accounts do not disclose the correct state of facts". 3.4.2 The Hon'ble Apex C…

Neeraj Jain, Delhi vs. DCIT, Central Circle-31, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 1591/DEL/2023[2019-20]Status: DisposedITAT Delhi25 Jul 2024AY 2019-20

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Usassessment Year 2019-20

For Respondent: Shri Subhra Jyoti Chakraborty, CIT-DR
Section 131Section 132Section 143(2)Section 143(3)Section 153DSection 3Section 69A

…ve been made based on so called confessional statement nor could have been made merely on the basis of bald statement in the light of the judgment of Hon’ble Supreme Court in the case of Pullangode Rubber and Produce Company Limited vs. State of Kerala (1973) 91 ITR 18 (SC) wherein it is held that an admission made is not conclusive and it is open to the person who made the addition to show that it is incorrect. (c) The CBDT vide Instruction No.286/2/2023 IT(Inv.) has lent emphasis that during the search and seizure, there should be focus and concentration on collection of evidence of income and no attempt shoul…

Gipskarton India Private Limited, New Delhi vs. ACIT, Central Circle-7, New Delhi

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

ITA 1475/DEL/2023[2021-22]Status: DisposedITAT Delhi24 Jul 2024AY 2021-22

Bench: Shri Saktijit Dey & Shri Naveen Chandra

For Appellant: Ms. Rano Jain, AdvFor Respondent: Shri T James Singson, CIT-DR
Section 132(4)Section 69A

…see to establish that the admission made in the statements are incorrect/wrong and that burden has to be discharged by an assessee at the earliest point of time. As held by the Supreme Court in Pullan- gode Rubber Produce Co. Ltd. v. State of Kerala, (1973) 91 ITR 18 an admission is an extremely important piece of evidence though it is not conclusive. Therefore, a statement made voluntarily by the assessee could form the basis of assessment. 26. We are fortified in our view by the decisions of the Hon’ble Supreme Court Of India in Kuwer Fibres (P.) Ltd v Commissioner of Income-tax reported in [2023] 146 taxm…

M/S. Atri Developers, Ahmedabad vs. The Dy. Commissioner of Income Tax, Circle-3(3), Ahmedabad

Appeal is dismissed

ITA 2859/AHD/2016[2013-14]Status: DisposedITAT Ahmedabad23 Jul 2024AY 2013-14

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2013-14 The Dcit, Cir.3(3) M/S.Atri Developers Ahmedabad. Vs 19, Ambalal House Mayur Park Society Satellite Road Ahmedabad. Pan : Aatfa 1086 D Assessment Year : 2013-14 M/S.Atri Developers The Dcit, Cir.3(3) 19, Ambalal House Vs Ahmedabad. Mayur Park Society Satellite Road Ahmedabad. Pan : Aatfa 1086 D

For Appellant: Shri Mohit Balani, ARFor Respondent: Shri Prateek Sharma, Sr.DR
Section 133ASection 250

…आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण, अहमदाबाद "यायपीठ आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण अहमदाबाद "यायपीठ अहमदाबाद "यायपीठ ‘C’ अहमदाबाद। अहमदाबाद "यायपीठ अहमदाबाद। अहमदाबाद। अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, AHMEDABAD ] ] BEFORE SMT.ANNAPURNA GUPTA, ACCOUNTANT MEMBER AND SHRI T.R. SENTHIL KUMAR, JUDICIAL MEMBER Assessment Year : 2013-14 The DCIT, Cir.3(3) M/s.Atri Developers Ahmedabad. Vs 19, Ambalal House Mayur Park Society Satellite Road Ahmedabad. PAN : AATFA 1086 D Assessment Year : 2013-14 M/s.Atri Developers The DCIT, Cir.3(3) 19, Ambalal House Vs Ahmedabad. Mayur Park Society…

The Dy. Commissioner of Income Tax Circle-3(3), Ahmedabad vs. M/S. Atri Developers, Ahmedabad

Appeal is dismissed

ITA 2855/AHD/2016[2013-14]Status: DisposedITAT Ahmedabad23 Jul 2024AY 2013-14

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2013-14 The Dcit, Cir.3(3) M/S.Atri Developers Ahmedabad. Vs 19, Ambalal House Mayur Park Society Satellite Road Ahmedabad. Pan : Aatfa 1086 D Assessment Year : 2013-14 M/S.Atri Developers The Dcit, Cir.3(3) 19, Ambalal House Vs Ahmedabad. Mayur Park Society Satellite Road Ahmedabad. Pan : Aatfa 1086 D

For Appellant: Shri Mohit Balani, ARFor Respondent: Shri Prateek Sharma, Sr.DR
Section 133ASection 250

…आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण, अहमदाबाद "यायपीठ आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण अहमदाबाद "यायपीठ अहमदाबाद "यायपीठ ‘C’ अहमदाबाद। अहमदाबाद "यायपीठ अहमदाबाद। अहमदाबाद। अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, AHMEDABAD ] ] BEFORE SMT.ANNAPURNA GUPTA, ACCOUNTANT MEMBER AND SHRI T.R. SENTHIL KUMAR, JUDICIAL MEMBER Assessment Year : 2013-14 The DCIT, Cir.3(3) M/s.Atri Developers Ahmedabad. Vs 19, Ambalal House Mayur Park Society Satellite Road Ahmedabad. PAN : AATFA 1086 D Assessment Year : 2013-14 M/s.Atri Developers The DCIT, Cir.3(3) 19, Ambalal House Vs Ahmedabad. Mayur Park Society…

DCIT Central, Bhopal vs. Sharad Sharma, Bhopal

ITA 309/IND/2023[2012-13]Status: DisposedITAT Indore19 Jul 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniit(Ss)A No. 29/Ind/2023 (Ay: 2010-11) It(Ss)A No. 32/Ind/2023 (Ay: 2015-16) Shri Sharad Sharma, Acit, Central, बनाम/ H-3B, Nishant Colony, Gwalior Vs. 74 Bunglows, (Stationed At Bhopal) Tt Nagar, Bhopal (Pan: Amzps9791D) (Assessee/Appellant) (Revenue/Respondent)

Section 132Section 132(4)Section 143(3)Section 153A

…its favour. It has been held by Hon’ble Supreme Court and other courts that it is open to an assessee show that the admission made in the statement was not correct. The decision of Hon’ble Supreme Court in the case of Pullangode Rubber Produce Company Limited 91 ITR 18 (SC), Nagubai Amal vs B Sharma Rao AIR 1956 (SC) 593 and Awad Kishore Dass AIR 1979 (SC) 861 are squarely applicable to the case of the appellant. In the case of Pullangode Rubber Produce Co Ltd (Supra), it has been 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 ass…

DCIT Central, Bhopal vs. Sharad Sharma, Bhopal

ITA 304/IND/2023[2015-16]Status: DisposedITAT Indore19 Jul 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniit(Ss)A No. 29/Ind/2023 (Ay: 2010-11) It(Ss)A No. 32/Ind/2023 (Ay: 2015-16) Shri Sharad Sharma, Acit, Central, बनाम/ H-3B, Nishant Colony, Gwalior Vs. 74 Bunglows, (Stationed At Bhopal) Tt Nagar, Bhopal (Pan: Amzps9791D) (Assessee/Appellant) (Revenue/Respondent)

Section 132Section 132(4)Section 143(3)Section 153A

…its favour. It has been held by Hon’ble Supreme Court and other courts that it is open to an assessee show that the admission made in the statement was not correct. The decision of Hon’ble Supreme Court in the case of Pullangode Rubber Produce Company Limited 91 ITR 18 (SC), Nagubai Amal vs B Sharma Rao AIR 1956 (SC) 593 and Awad Kishore Dass AIR 1979 (SC) 861 are squarely applicable to the case of the appellant. In the case of Pullangode Rubber Produce Co Ltd (Supra), it has been 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 ass…

Rajesh Products, Tonk, Rajasthan vs. ACIT, Jaipur

Appeal is dismissed

ITA 626/JPR/2023[2016-17]Status: DisposedITAT Jaipur18 Jul 2024AY 2016-17
For Appellant: Shri Mahesh Jain, CA (Th. V.C)For Respondent: Shri Bhanwar Singh Ratnu, (CIT-DR)
Section 132(1)Section 132(4)Section 142(1)Section 143(2)Section 143(3)

…there was additional income as sought to be assessed and that there was no material to support that there was such income, this contention in our view is not correct. As held by the Supreme Court in Pullangode Rubber Produce Co. Ltd. v. State of Kerala (1973) 91 ITR 18 an admission is an extremely important piece of evidence though it not conclusive. Therefore, a statement made voluntarily by the assessee could form the basis of assessment. The mere fact that the assessee retracted the statement could not make the statement unacceptable. The burden lay on the assessee to establish that the admission made in the s…

Srishti Associates, Kota, Rajasthan vs. ACIT, Central Circle, Kota, Kota-Rajasthan

ITA 587/JPR/2024[2018-19]Status: DisposedITAT Jaipur16 Jul 2024AY 2018-19
Section 132Section 132(4)Section 139(1)Section 143(2)Section 153CSection 153DSection 246ASection 44A

…are supported by some other conclusive evidence found during the search. In this regard the Ld AR of the assessee placed the reliance on the judgements of Hon'ble Apex Court in the case of Pullangode Rubber Produce Co Ltd v/s State of Kerala & Anothers (1973) 91 ITR 18 (SC) (ii) Hon'ble Rajasthan High Court in the case of CIT v/s Ashok Kumar Soni 291 ITR 172 (Raj.). (iii) Hon'ble Rajasthan High Court in the case of Mantri Share Brokers PL (96 taxmann.com 279). (iv) Best Infrastructure (India) P. Ltd. v. PCIT [2017] 84 taxmann.com 287 (Delhi) (v) Harjeev Aggarwal v. CIT [2016] 70 taxmann.com 95 (Delhi) (vi) Hon'bl…

J C Home Tex, Jaipur vs. Assistant Commissioner of Income Tax Circle - 7, Jaipur

ITA 292/JPR/2024[2016-17]Status: DisposedITAT Jaipur10 Jul 2024AY 2016-17
For Appellant: Sh. Tarun Mittal, CA &For Respondent: Sh. Anoop Singh (Addl. CIT)
Section 133ASection 142(1)Section 143(1)Section 143(2)Section 143(3)Section 145(3)

…there was additional income as sought to be assessed and that there was no material to support that there was such income, this contention in our view is not correct. As held by the Supreme Court in Pullangode Rubber Produce Co. Ltd. v. State of Kerala [1973] 91 ITR 18 an admission is an extremely important piece of evidence though it is not conclusive. Therefore, a statement made voluntarily by the assessee could form the basis of assessment. The mere fact that the assessee retracted the statement could not make the statement unacceptable. The burden lay on the assessee to establish that the admission made in th…

ACIT, Central Circle-2(2), Hyderabad vs. Syed Irfanuddin, Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 442/HYD/2022[2018-9]Status: DisposedITAT Hyderabad08 Jul 2024

Bench: Shri Laliet Kumar & Shri Manjunatha, G.S.No Appeal In Ita No Revenue Assessee A.Y 1 432/Hyd/2022 Acit, Syed 2018- Central Zeeshanuddin 19 Circle 2(2) Hyderabad Hyderabad Pan:Bqgps0128A 2 436/Hyd/2022 & -Do- Syed Imranuddin 2017- 437/Hyd/2022 Hyderabad 18 3 Pan:Aajpi6494F 4 442/Hyd/2022 -Do- Syed Irfanuddin 2018- Hyderabad 19 Pan:Aappi4693A िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Shakeer Ahmed, DR
Section 132(4)

…upreme Court in the case of Bannalal Jat Constructions Pvt.Ltd. v. Asst.CIT reported in [2019] 413 ITR (St.) 322 (SC) ; [2019] 106 taxmann.com 128 (SC), after referring to the judgment of Pullangode Rubber Proudce co.Ltd. v. State of Kerala reported in [1973] 91 ITR 18 (SC), the legal position in relation to a statement under section 132(4) of the Income-tax Act, 1961 was set out as under:- (a) An admission is an extremely important piece of evidence though it is not conclusive. (b) A statement made voluntarily by the appellant could form the basis of assessment. (c) The mere fact that the appellant retraced the…

ACIT, Central Circle-2(2), Hyderabad vs. Syed Imranuddin, Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 437/HYD/2022[2018-19]Status: DisposedITAT Hyderabad08 Jul 2024AY 2018-19

Bench: Shri Laliet Kumar & Shri Manjunatha, G.S.No Appeal In Ita No Revenue Assessee A.Y 1 432/Hyd/2022 Acit, Syed 2018- Central Zeeshanuddin 19 Circle 2(2) Hyderabad Hyderabad Pan:Bqgps0128A 2 436/Hyd/2022 & -Do- Syed Imranuddin 2017- 437/Hyd/2022 Hyderabad 18 3 Pan:Aajpi6494F 4 442/Hyd/2022 -Do- Syed Irfanuddin 2018- Hyderabad 19 Pan:Aappi4693A िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Shakeer Ahmed, DR
Section 132(4)

…upreme Court in the case of Bannalal Jat Constructions Pvt.Ltd. v. Asst.CIT reported in [2019] 413 ITR (St.) 322 (SC) ; [2019] 106 taxmann.com 128 (SC), after referring to the judgment of Pullangode Rubber Proudce co.Ltd. v. State of Kerala reported in [1973] 91 ITR 18 (SC), the legal position in relation to a statement under section 132(4) of the Income-tax Act, 1961 was set out as under:- (a) An admission is an extremely important piece of evidence though it is not conclusive. (b) A statement made voluntarily by the appellant could form the basis of assessment. (c) The mere fact that the appellant retraced the…

ACIT, Central Circle-2(2), Hyderabad vs. Syed Imranuddin, Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 436/HYD/2022[2017-18]Status: DisposedITAT Hyderabad08 Jul 2024AY 2017-18

Bench: Shri Laliet Kumar & Shri Manjunatha, G.S.No Appeal In Ita No Revenue Assessee A.Y 1 432/Hyd/2022 Acit, Syed 2018- Central Zeeshanuddin 19 Circle 2(2) Hyderabad Hyderabad Pan:Bqgps0128A 2 436/Hyd/2022 & -Do- Syed Imranuddin 2017- 437/Hyd/2022 Hyderabad 18 3 Pan:Aajpi6494F 4 442/Hyd/2022 -Do- Syed Irfanuddin 2018- Hyderabad 19 Pan:Aappi4693A िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Shakeer Ahmed, DR
Section 132(4)

…upreme Court in the case of Bannalal Jat Constructions Pvt.Ltd. v. Asst.CIT reported in [2019] 413 ITR (St.) 322 (SC) ; [2019] 106 taxmann.com 128 (SC), after referring to the judgment of Pullangode Rubber Proudce co.Ltd. v. State of Kerala reported in [1973] 91 ITR 18 (SC), the legal position in relation to a statement under section 132(4) of the Income-tax Act, 1961 was set out as under:- (a) An admission is an extremely important piece of evidence though it is not conclusive. (b) A statement made voluntarily by the appellant could form the basis of assessment. (c) The mere fact that the appellant retraced the…

ACIT Central Circle-2(2), Hyderabad vs. Syed Zeeshanuddin, Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 432/HYD/2022[2018-19]Status: DisposedITAT Hyderabad08 Jul 2024AY 2018-19

Bench: Shri Laliet Kumar & Shri Manjunatha, G.S.No Appeal In Ita No Revenue Assessee A.Y 1 432/Hyd/2022 Acit, Syed 2018- Central Zeeshanuddin 19 Circle 2(2) Hyderabad Hyderabad Pan:Bqgps0128A 2 436/Hyd/2022 & -Do- Syed Imranuddin 2017- 437/Hyd/2022 Hyderabad 18 3 Pan:Aajpi6494F 4 442/Hyd/2022 -Do- Syed Irfanuddin 2018- Hyderabad 19 Pan:Aappi4693A िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Shakeer Ahmed, DR
Section 132(4)

…upreme Court in the case of Bannalal Jat Constructions Pvt.Ltd. v. Asst.CIT reported in [2019] 413 ITR (St.) 322 (SC) ; [2019] 106 taxmann.com 128 (SC), after referring to the judgment of Pullangode Rubber Proudce co.Ltd. v. State of Kerala reported in [1973] 91 ITR 18 (SC), the legal position in relation to a statement under section 132(4) of the Income-tax Act, 1961 was set out as under:- (a) An admission is an extremely important piece of evidence though it is not conclusive. (b) A statement made voluntarily by the appellant could form the basis of assessment. (c) The mere fact that the appellant retraced the…

Mohammed Ibrabim Mohideen, Kerala vs. Asst. Commissioner of Income Tax, Central Circle-2, Mangaluru

In the result, appeal of the assessee in ITA

ITA 486/BANG/2024[2018-19]Status: DisposedITAT Bangalore08 Jul 2024AY 2018-19

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…