Revenue. In Asstt.CIT v. Ramesh Chandra R. Patel

89 ITD 203Income Tax Appellate Tribunal2004#3776 most cited

What is Revenue. In Asstt.CIT v. Ramesh Chandra R. Patel authority for?

Jewellery within prescribed limits, especially that received during marriage, is presumed explained even if found during a search, based on CBDT instructions. The revenue cannot treat such jewellery as unexplained income simply because it was found.

32

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2024.

Also referred to as

Ramesh Chandra R Patel · 89 ITD 203 · CBDT Instruction 1916 · unexplained jewellery · explained jewellery · search and seizure · section 132(4) · retracted statement · onus of proof · jewellery limits

Issues it is cited on

section 271aabstatement under section 132(4)retracted statementdumb documentssection 271aasection 40a(3)section 271aon-moneysection 40atnmmconcealment of incomerevenue expenditure

Judgments citing Revenue. In Asstt.CIT v. Ramesh Chandra R. Patel

SREENIVASULU BALISETTY,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(2), HYDERABAD

In the result, appeal of the assessee is allowed

ITA 852/HYD/2024[2019-20]Status: DisposedITAT Hyderabad13 Nov 2024AY 2019-20

Bench: Shri Manjunatha G. & Shri K.Narasimha Chary

For Appellant: Md.Afzal, ARFor Respondent: Shri Karthiik Manickam, DR

…, and such instructions have nothing to do with the discharge of burden of the assessee to explain the source for acquisition of such gold jewellery and ornaments, but the judicial opinion is otherwise. 9. In the case of ACIT vs Rameshchandra R. Patel, [2004] 89 ITD 203 (AHD), the Ahmedabad Bench of the Tribunal observed that in view of the CBDT Instruction No. 1916 dated 11/5/1994 which suggest that a family is supposed to hold certain jewelleries received at the time of marriage from parents and in-laws within the said limits, it is to be treated as explained. Though the instruction speaks of not seizing the sa…

M/S HEADMASTER SALOON PVT.LTD.,CHANDIGARH vs. DCIT-CIRCLE-1(1), CHANDIGARH

In the result, appeal of the assessee is allowed for statistical purposes

ITA 111/CHANDI/2020[2014-15]Status: DisposedITAT Chandigarh21 Aug 2024AY 2014-15

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Manpreet Duggal, JCIT, Sr. DR
Section 133ASection 142(1)Section 143(1)Section 143(2)Section 250(6)Section 253

…above, the assessee has failed to prove that the admission made by him was incorrect.” 24. That Ld. AO in assessment order dt. 27/12/2016 has in para 16, 17, 18, 19 has further observed as under: 16. In the case of Assttt. CIT V. Rameschandra R. Patel [2004] 89 ITD 203 (Ahd.)(TM) it was held as under: “ It was accepted that the assessee had a right to retract but that has to be based on evidence on record to the contrary and there must be justifiable reason and material accepting retraction i.e; cogent and sufficient material have to be placed on record for acceptance or retraction. All that has to be done by th…

SAKSHI MAHESHWARI,KOTA RAJASTHAN vs. ACIT, DCIT, CENTRAL CIRCLE, KOTA, KOTA RAJASTHAN

In the result, the appeal of the assesee is allowed

ITA 584/JPR/2023[2017-18]Status: DisposedITAT Jaipur06 May 2024AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR MITHA LAL MEENA (Accountant Member)

For Appellant: Shri Sharwan Kumar GuptaFor Respondent: Shri Anoop Singh, Addl CIT-DR
Section 115BSection 132(1)Section 142(1)Section 143(2)Section 143(3)

…DCIT (ITAT Jaipur)[ ITA No. 918/JP/2019] that Explained Jewellery cannot be included while giving benefit of CBDT Instruction related to Unexplained Jewellery. As explained by Hon’ble Ahmedabad I.T.A.T. in case of Kishorbhai V Sakaria , Rameshchandra R Patel 89 ITD 203 and Manila! S Dave 117 Taxman 23 referred supra wherein it has been explicitly held that though board circular is a guideline for not effecting seizure during the course of search, extended meaning of same shows the intention that the jewellery to the extent mentioned in such circular should be treated as explained jewellery and gold found to that…

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

…t and admissible and they can be used as evidence. In fact, once there is a clear admission, voluntarily made, on the part of assessee, that would constitute a good piece of evidence in the hands of the Revenue. In Asstt.CIT Vs. Ramesh Chandra R. Patel [2004] 89 ITD 203 (Ahd.) (TM), it was accepted that the assessee had a right to retract but that has to be based on-evidence’ brought on record to the contrary and there must be justifiable reason and material accepting Page 15 of 46 M/s. Varsha Viswanath Properties Private Limited batch retraction i.e., cogent and sufficient material have to be placed on record…

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

…t and admissible and they can be used as evidence. In fact, once there is a clear admission, voluntarily made, on the part of assessee, that would constitute a good piece of evidence in the hands of the Revenue. In Asstt.CIT Vs. Ramesh Chandra R. Patel [2004] 89 ITD 203 (Ahd.) (TM), it was accepted that the assessee had a right to retract but that has to be based on-evidence’ brought on record to the contrary and there must be justifiable reason and material accepting Page 15 of 46 M/s. Varsha Viswanath Properties Private Limited batch retraction i.e., cogent and sufficient material have to be placed on record…

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

…t and admissible and they can be used as evidence. In fact, once there is a clear admission, voluntarily made, on the part of assessee, that would constitute a good piece of evidence in the hands of the Revenue. In Asstt.CIT Vs. Ramesh Chandra R. Patel [2004] 89 ITD 203 (Ahd.) (TM), it was accepted that the assessee had a right to retract but that has to be based on-evidence’ brought on record to the contrary and there must be justifiable reason and material accepting Page 15 of 46 M/s. Varsha Viswanath Properties Private Limited batch retraction i.e., cogent and sufficient material have to be placed on record…

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

…t and admissible and they can be used as evidence. In fact, once there is a clear admission, voluntarily made, on the part of assessee, that would constitute a good piece of evidence in the hands of the Revenue. In Asstt.CIT Vs. Ramesh Chandra R. Patel [2004] 89 ITD 203 (Ahd.) (TM), it was accepted that the assessee had a right to retract but that has to be based on-evidence’ brought on record to the contrary and there must be justifiable reason and material accepting Page 15 of 46 M/s. Varsha Viswanath Properties Private Limited batch retraction i.e., cogent and sufficient material have to be placed on record…

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 2046/HYD/2018[2012-13]Status: DisposedITAT Hyderabad09 Jan 2024AY 2012-13

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

…t and admissible and they can be used as evidence. In fact, once there is a clear admission, voluntarily made, on the part of assessee, that would constitute a good piece of evidence in the hands of the Revenue. In Asstt.CIT Vs. Ramesh Chandra R. Patel [2004] 89 ITD 203 (Ahd.) (TM), it was accepted that the assessee had a right to retract but that has to be based on-evidence’ brought on record to the contrary and there must be justifiable reason and material accepting Page 15 of 46 M/s. Varsha Viswanath Properties Private Limited batch retraction i.e., cogent and sufficient material have to be placed on record…

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

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

ITA 1910/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

…t and admissible and they can be used as evidence. In fact, once there is a clear admission, voluntarily made, on the part of assessee, that would constitute a good piece of evidence in the hands of the Revenue. In Asstt.CIT Vs. Ramesh Chandra R. Patel [2004] 89 ITD 203 (Ahd.) (TM), it was accepted that the assessee had a right to retract but that has to be based on-evidence’ brought on record to the contrary and there must be justifiable reason and material accepting Page 15 of 46 M/s. Varsha Viswanath Properties Private Limited batch retraction i.e., cogent and sufficient material have to be placed on record…

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

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

ITA 1909/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

…t and admissible and they can be used as evidence. In fact, once there is a clear admission, voluntarily made, on the part of assessee, that would constitute a good piece of evidence in the hands of the Revenue. In Asstt.CIT Vs. Ramesh Chandra R. Patel [2004] 89 ITD 203 (Ahd.) (TM), it was accepted that the assessee had a right to retract but that has to be based on-evidence’ brought on record to the contrary and there must be justifiable reason and material accepting Page 15 of 46 M/s. Varsha Viswanath Properties Private Limited batch retraction i.e., cogent and sufficient material have to be placed on record…

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

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

ITA 1908/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

…t and admissible and they can be used as evidence. In fact, once there is a clear admission, voluntarily made, on the part of assessee, that would constitute a good piece of evidence in the hands of the Revenue. In Asstt.CIT Vs. Ramesh Chandra R. Patel [2004] 89 ITD 203 (Ahd.) (TM), it was accepted that the assessee had a right to retract but that has to be based on-evidence’ brought on record to the contrary and there must be justifiable reason and material accepting Page 15 of 46 M/s. Varsha Viswanath Properties Private Limited batch retraction i.e., cogent and sufficient material have to be placed on record…

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

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

ITA 1907/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

…t and admissible and they can be used as evidence. In fact, once there is a clear admission, voluntarily made, on the part of assessee, that would constitute a good piece of evidence in the hands of the Revenue. In Asstt.CIT Vs. Ramesh Chandra R. Patel [2004] 89 ITD 203 (Ahd.) (TM), it was accepted that the assessee had a right to retract but that has to be based on-evidence’ brought on record to the contrary and there must be justifiable reason and material accepting Page 15 of 46 M/s. Varsha Viswanath Properties Private Limited batch retraction i.e., cogent and sufficient material have to be placed on record…

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

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

ITA 1906/HYD/2018[2012-13]Status: DisposedITAT Hyderabad09 Jan 2024AY 2012-13

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

…t and admissible and they can be used as evidence. In fact, once there is a clear admission, voluntarily made, on the part of assessee, that would constitute a good piece of evidence in the hands of the Revenue. In Asstt.CIT Vs. Ramesh Chandra R. Patel [2004] 89 ITD 203 (Ahd.) (TM), it was accepted that the assessee had a right to retract but that has to be based on-evidence’ brought on record to the contrary and there must be justifiable reason and material accepting Page 15 of 46 M/s. Varsha Viswanath Properties Private Limited batch retraction i.e., cogent and sufficient material have to be placed on record…

M/S SAI APARTMENTS & INFRASTRUCTURE,PANCHKULA vs. DCIT, C-6(1), MOHALI

In the result, appeal of the assessee is partly allowed

ITA 940/CHANDI/2019[2011-12]Status: HeardITAT Chandigarh27 Apr 2022AY 2011-12
For Appellant: Shri Parikshit Aggarwal, CAFor Respondent: Shri Sarabjit Singh, CIT-DR
Section 133ASection 143(3)Section 148Section 36

…n estoppels and shift the burden of proof on to the person making them. The Supreme Court further held that unless shown or explained to be wrong, they are an efficacious proof of the facts admitted.' In the case of Asstt. CIT v. Rameshchandra R. Patel [2004] 89 ITD 203 (Ahd.)(TM) it was held that: 'It was accepted that the assessee had a right to retract but that has to be based on evidence brought on record to the contrary and there must be justifiable reason and material accepting retraction i.e., cogent and sufficient material have to be placed on record for acceptance or retraction. Ail that has to be done b…

SHRI LALJIBHAI KHIMJIBHAI PATEL,,BHUJ vs. THE INCOME TAX OFFICER, WARD-2,, BHUJ

In the result, appeal of the assessee is partly allowed for statistical purpose

ITA 391/RJT/2013[2007-08]Status: DisposedITAT Rajkot21 Oct 2019AY 2007-08

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

For Appellant: Written SubmissionsFor Respondent: Shri Jitendra Kumar, CIT-DR
Section 132Section 143(2)Section 143(3)Section 153ASection 271(1)(c)

…s ground of appeal. Reliance is also placed on the decision of the Hon'ble Kerala High Court in K Kunhanbam & Sons 219 ITR 235 (Ker) and on the decision of the Hon'ble Third Member Bench of Ahmedabad Tribunal in the case of Asstt.CIT v. Rameshchandra R. Patel 89 ITD 203 (Ahd.) (TM).” 11. The assessee in his submissions has reiterated his stand that no evidence was found at the time of search. Merely on the basis of statement recorded under section 132(4) additions cannot be made. He emphasised that there should be a corroborative evidence of disclosure made by the assessee. For buttressing his submissions the ass…

SHRI LALJIBHAI KHIMJIBHAI PATEL,,BHUJ vs. THE INCOME TAX OFFICER, WARD-2,, BHUJ

In the result, appeal of the assessee is partly allowed for statistical purpose

ITA 390/RJT/2013[2006-07]Status: DisposedITAT Rajkot21 Oct 2019AY 2006-07

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

For Appellant: Written SubmissionsFor Respondent: Shri Jitendra Kumar, CIT-DR
Section 132Section 143(2)Section 143(3)Section 153ASection 271(1)(c)

…s ground of appeal. Reliance is also placed on the decision of the Hon'ble Kerala High Court in K Kunhanbam & Sons 219 ITR 235 (Ker) and on the decision of the Hon'ble Third Member Bench of Ahmedabad Tribunal in the case of Asstt.CIT v. Rameshchandra R. Patel 89 ITD 203 (Ahd.) (TM).” 11. The assessee in his submissions has reiterated his stand that no evidence was found at the time of search. Merely on the basis of statement recorded under section 132(4) additions cannot be made. He emphasised that there should be a corroborative evidence of disclosure made by the assessee. For buttressing his submissions the ass…

SHRI LALJIBHAI KHIMJIBHAI PATEL,,BHUJ vs. THE INCOME TAX OFFICER, WARD-2,, BHUJ

In the result, appeal of the assessee is partly allowed for statistical purpose

ITA 389/RJT/2013[2005-06]Status: DisposedITAT Rajkot21 Oct 2019AY 2005-06

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

For Appellant: Written SubmissionsFor Respondent: Shri Jitendra Kumar, CIT-DR
Section 132Section 143(2)Section 143(3)Section 153ASection 271(1)(c)

…s ground of appeal. Reliance is also placed on the decision of the Hon'ble Kerala High Court in K Kunhanbam & Sons 219 ITR 235 (Ker) and on the decision of the Hon'ble Third Member Bench of Ahmedabad Tribunal in the case of Asstt.CIT v. Rameshchandra R. Patel 89 ITD 203 (Ahd.) (TM).” 11. The assessee in his submissions has reiterated his stand that no evidence was found at the time of search. Merely on the basis of statement recorded under section 132(4) additions cannot be made. He emphasised that there should be a corroborative evidence of disclosure made by the assessee. For buttressing his submissions the ass…

SHRI LALJIBHAI KHIMJIBHAI PATEL,,BHUJ vs. THE INCOME TAX OFFICER, WARD-2,, BHUJ

In the result, appeal of the assessee is partly allowed for statistical purpose

ITA 388/RJT/2013[2001-02]Status: DisposedITAT Rajkot21 Oct 2019AY 2001-02

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

For Appellant: Written SubmissionsFor Respondent: Shri Jitendra Kumar, CIT-DR
Section 132Section 143(2)Section 143(3)Section 153ASection 271(1)(c)

…s ground of appeal. Reliance is also placed on the decision of the Hon'ble Kerala High Court in K Kunhanbam & Sons 219 ITR 235 (Ker) and on the decision of the Hon'ble Third Member Bench of Ahmedabad Tribunal in the case of Asstt.CIT v. Rameshchandra R. Patel 89 ITD 203 (Ahd.) (TM).” 11. The assessee in his submissions has reiterated his stand that no evidence was found at the time of search. Merely on the basis of statement recorded under section 132(4) additions cannot be made. He emphasised that there should be a corroborative evidence of disclosure made by the assessee. For buttressing his submissions the ass…

SHRI LALJI KHIMJI PATEL,,BHUJ vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRASL CIRCLE-II,, RAJKOT-GUJARAT

In the result, appeal of the assessee is partly allowed for statistical purpose

ITA 715/RJT/2010[2007-08]Status: DisposedITAT Rajkot21 Oct 2019AY 2007-08

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

For Appellant: Written SubmissionsFor Respondent: Shri Jitendra Kumar, CIT-DR
Section 132Section 143(2)Section 143(3)Section 153ASection 271(1)(c)

…s ground of appeal. Reliance is also placed on the decision of the Hon'ble Kerala High Court in K Kunhanbam & Sons 219 ITR 235 (Ker) and on the decision of the Hon'ble Third Member Bench of Ahmedabad Tribunal in the case of Asstt.CIT v. Rameshchandra R. Patel 89 ITD 203 (Ahd.) (TM).” 11. The assessee in his submissions has reiterated his stand that no evidence was found at the time of search. Merely on the basis of statement recorded under section 132(4) additions cannot be made. He emphasised that there should be a corroborative evidence of disclosure made by the assessee. For buttressing his submissions the ass…

SHRI LALJI KHIMJI PATEL,,BHUJ vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRASL CIRCLE-II,, RAJKOT-GUJARAT

In the result, appeal of the assessee is partly allowed for statistical purpose

ITA 714/RJT/2010[2006-07]Status: DisposedITAT Rajkot21 Oct 2019AY 2006-07

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

For Appellant: Written SubmissionsFor Respondent: Shri Jitendra Kumar, CIT-DR
Section 132Section 143(2)Section 143(3)Section 153ASection 271(1)(c)

…s ground of appeal. Reliance is also placed on the decision of the Hon'ble Kerala High Court in K Kunhanbam & Sons 219 ITR 235 (Ker) and on the decision of the Hon'ble Third Member Bench of Ahmedabad Tribunal in the case of Asstt.CIT v. Rameshchandra R. Patel 89 ITD 203 (Ahd.) (TM).” 11. The assessee in his submissions has reiterated his stand that no evidence was found at the time of search. Merely on the basis of statement recorded under section 132(4) additions cannot be made. He emphasised that there should be a corroborative evidence of disclosure made by the assessee. For buttressing his submissions the ass…

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