What is Society v. UOI authority for?

Uncorroborated loose papers or documents found during a search operation have no evidentiary value and cannot be the sole basis for determining undisclosed income. Additions based on such material require independent evidence to establish trustworthiness and a direct link to the assessee.

How many judgments cite Society v. UOI?

493 judgments on BharatTax cite Society v. UOI (394 ITR 220), spanning 2018 to 2026.

Which sections of the Income Tax Act does Society v. UOI come up under?

It is most often cited in judgments turning on Section 132, Section 132(4), Section 153A, Section 153C, Section 143(3), Section 292C.

Society v. UOI (394 ITR 220)

DCIT, CENTRAL CIRCLE-6, THIRD FLOOR vs. RAMA SHANKAR KHEMKA, GANESH BAZAR

In the result, the appeal filed by the revenue and CO filed by the assessee are dismissed

ITA 1005/DEL/2024[2020-21]Status: DisposedITAT Delhi06 Feb 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmandcit Vs. Payal Khemka Central Circle- 6 67/85-2 Jhun Bhawan, Natimalivaranashi Delhi Uttar Pradesh 221001 (Pan: Adtpj2728A) Dcit Vs. Pmk Impex Pvt. Ltd. Central Circle- 6 1 Tolstoy Marg, Connaught Place, Delhi New Delhi, Delhi 110001

For Appellant: Sh. Gautam Jain AdvFor Respondent: Sh. Jitender Singh, CIT DR

Section 132Section 132(4)

…mere seized documents in absence of corroborative evidence and disregard of the seized documents is not in accordance with law. Reliance is placed on the following judgments: i) (1998) 3 SCC 410 CBI vs. V.C. Shukla (extracted at page 305 of Paper Book) ii) 394 ITR 220 (SC) Common Cause (A Registered Society) and Others v. UOI following the judgment in the case of CBI v. V.C. Shukla reported in 3 SCC 410 (extracted at page 305 of Paper Book) iii) 296 ITR 619 (Del) CIT v. Girish Chaudhary (extracted at page 306 of Paper Book) iv) 308 ITR 230 (Del) CIT vs. D.K. Gupta (extracted at page 306-307 of Paper Book) v…

DCIT, CENTRAL CIRCLE-6, THIRD FLOOR vs. RAJESH RANI KHEMKA , GANESH BAZAR

In the result, the appeal filed by the revenue and CO filed by the assessee are dismissed

ITA 1004/DEL/2024[2020-21]Status: DisposedITAT Delhi06 Feb 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmandcit Vs. Payal Khemka Central Circle- 6 67/85-2 Jhun Bhawan, Natimalivaranashi Delhi Uttar Pradesh 221001 (Pan: Adtpj2728A) Dcit Vs. Pmk Impex Pvt. Ltd. Central Circle- 6 1 Tolstoy Marg, Connaught Place, Delhi New Delhi, Delhi 110001

For Appellant: Sh. Gautam Jain AdvFor Respondent: Sh. Jitender Singh, CIT DR

Section 132Section 132(4)

…mere seized documents in absence of corroborative evidence and disregard of the seized documents is not in accordance with law. Reliance is placed on the following judgments: i) (1998) 3 SCC 410 CBI vs. V.C. Shukla (extracted at page 305 of Paper Book) ii) 394 ITR 220 (SC) Common Cause (A Registered Society) and Others v. UOI following the judgment in the case of CBI v. V.C. Shukla reported in 3 SCC 410 (extracted at page 305 of Paper Book) iii) 296 ITR 619 (Del) CIT v. Girish Chaudhary (extracted at page 306 of Paper Book) iv) 308 ITR 230 (Del) CIT vs. D.K. Gupta (extracted at page 306-307 of Paper Book) v…

DCIT, CENTRAL CIRCLE-6, INCOME TAX DEPARTMENT vs. PAYAL KHEMKA , K

In the result, the appeal filed by the revenue and CO filed by the assessee are dismissed

ITA 1000/DEL/2024[2020-21]Status: DisposedITAT Delhi06 Feb 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmandcit Vs. Payal Khemka Central Circle- 6 67/85-2 Jhun Bhawan, Natimalivaranashi Delhi Uttar Pradesh 221001 (Pan: Adtpj2728A) Dcit Vs. Pmk Impex Pvt. Ltd. Central Circle- 6 1 Tolstoy Marg, Connaught Place, Delhi New Delhi, Delhi 110001

For Appellant: Sh. Gautam Jain AdvFor Respondent: Sh. Jitender Singh, CIT DR

Section 132Section 132(4)

…mere seized documents in absence of corroborative evidence and disregard of the seized documents is not in accordance with law. Reliance is placed on the following judgments: i) (1998) 3 SCC 410 CBI vs. V.C. Shukla (extracted at page 305 of Paper Book) ii) 394 ITR 220 (SC) Common Cause (A Registered Society) and Others v. UOI following the judgment in the case of CBI v. V.C. Shukla reported in 3 SCC 410 (extracted at page 305 of Paper Book) iii) 296 ITR 619 (Del) CIT v. Girish Chaudhary (extracted at page 306 of Paper Book) iv) 308 ITR 230 (Del) CIT vs. D.K. Gupta (extracted at page 306-307 of Paper Book) v…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRLCE-1(4), CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

ITA 1597/CHNY/2025[2015-16]Status: DisposedITAT Chennai22 Jan 2026AY 2015-16

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 139Section 142(1)Section 153ASection 153CSection 250

…N/SAA/KSI/LS/S-1,\nPages 48 & 49 cannot be regarded as 'books of accounts' or 'documents'\nseized in course of search. We also gainfully refer to the decision of the\nHon'ble Supreme Court in the case of Common Cause (A Registered\nSociety) Vs Union of India (394 ITR 220)wherein at paragraphs 278\nto 282 of the judgment, it has been observed as under:\n\"278. With respect to the kind of materials which have been placed on\nrecord, this Court in V.C. Shukla case has dealt with the matter though\nat the stage of discharge when investigation had been completed by\nsame is relevant for the purpose of decision of this…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

In the result, all appeals filed by the assessee are allowed and the appeals of the Revenue are dismissed

ITA 1556/CHNY/2025[2016]Status: DisposedITAT Chennai22 Jan 2026

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

…NN/SAA/KSI/LS/S-1, Pages 48 & 49 cannot be regarded as 'books of accounts' or 'documents' seized in course of search. We also gainfully refer to the decision of the Hon'ble Supreme Court in the case of Common Cause (A Registered Society) Vs Union of India (394 ITR 220)wherein at paragraphs 278 to 282 of the judgment, it has been observed as under: "278. With respect to the kind of materials which have been placed on record, this Court in V.C. Shukla case has dealt with the matter though at the stage of discharge when investigation had been completed by same is relevant for the purpose of decision of this cas…

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

ITA 1324/CHNY/2025[2017-18]Status: DisposedITAT Chennai22 Jan 2026AY 2017-18

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 139Section 142(1)Section 153ASection 153CSection 250

…N/SAA/KSI/LS/S-1,\nPages 48 & 49 cannot be regarded as 'books of accounts' or 'documents'\nseized in course of search. We also gainfully refer to the decision of the\nHon'ble Supreme Court in the case of Common Cause (A Registered\nSociety) Vs Union of India (394 ITR 220)wherein at paragraphs 278\nto 282 of the judgment, it has been observed as under:-\…

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

ITA 1322/CHNY/2025[2015-16]Status: DisposedITAT Chennai22 Jan 2026AY 2015-16

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 139Section 142(1)Section 153ASection 153CSection 250

…N/SAA/KSI/LS/S-1,\nPages 48 & 49 cannot be regarded as 'books of accounts' or 'documents'\nseized in course of search. We also gainfully refer to the decision of the\nHon'ble Supreme Court in the case of Common Cause (A Registered\nSociety) Vs Union of India (394 ITR 220)wherein at paragraphs 278\nto 282 of the judgment, it has been observed as under:-\n\"278. With respect to the kind of materials which have been placed on\nrecord, this Court in V.C. Shukla case has dealt with the matter though\nat the stage of discharge when investigation had been completed by\nsame is relevant for the purpose of decision of thi…

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. MUTHULAKSHMI VELLAISAMY, TIRUPUR

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

ITA 610/CHNY/2025[2020-21]Status: DisposedITAT Chennai20 Jan 2026AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 605/Chny/2025 निर्धारण वर्ष / Assessment Year: 2020-21 Deputy Commissioner Of Income Tax, Central Circle-2(4), Chennai. (अपीलार्थी/Appellant) Gnanaguru Lavanya, Vs. 52, Iswarya Garden, Rakkiyapalayam Road, Ammapalayam, Avinashi Road, Tirupur - 641 654. [Pan: Abipl-5558-M] (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.: 610/Chny/2025 निर्धारण वर्ष / Assessment Year: 2020-21 Deputy Commissioner Of Income Tax, Central Circle-2(4), Chennai. Muthulakshmi Vellaisamy, Vs. 52, Iswarya Garden, Rakkiyapalayam Road, Ammapalayam, Avinashi Road, Tirupur - 641 654. [Pan:Afbpg-3703-L] (प्रत्यर्थी/Respondent) (अपीलार्थी/ Appellant) अपीलार्थी की ओर से/Appellant By : Ms. E. Pavuna Sundari, C.I.T. प्रत्यर्थी की ओर से /Respondent By : Shri. R. Venkata Raman, C.A. सुनवाई की तारीख/Date Of Hearing : 12.11.2025 घोषणा की तारीख/Date Of Pronouncement : 20.01.2026 :-2-:

For Appellant: Ms. E. Pavuna Sundari, C.I.TFor Respondent: Shri. R. Venkata Raman, C.A

Section 132Section 132(4)Section 139(4)

…s 13.851/2 acres) showed papers not relatable, documents are incomplete and uncorroborated "dumb documents”, no corroborative evidence of actual cash flow existed, reliance placed solely on such papers is unsustainable in law, supported by SC in Common Cause (394 ITR 220) and various High Courts/Tribunal decisions. Accordingly, this Tribunal dismissed the Revenue's appeal and affirmed Ld.CIT(A)'s deletion of addition in buyer's case. The relevant findings of this Tribunal are as under:- “45. Upon a careful and comprehensive examination of the seized material, being pages 23 to 26 of loose sheets contained in ANN/…

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. GNANAGURU LAVANYA, TIRUPUR

ITA 605/CHNY/2025[2020-21]Status: DisposedITAT Chennai20 Jan 2026AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 605/Chny/2025 निर्धारण वर्ष / Assessment Year: 2020-21 Deputy Commissioner Of Income Tax, Central Circle-2(4), Chennai. (अपीलार्थी/Appellant) Gnanaguru Lavanya, Vs. 52, Iswarya Garden, Rakkiyapalayam Road, Ammapalayam, Avinashi Road, Tirupur - 641 654. [Pan: Abipl-5558-M] (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.: 610/Chny/2025 निर्धारण वर्ष / Assessment Year: 2020-21 Deputy Commissioner Of Income Tax, Central Circle-2(4), Chennai. Muthulakshmi Vellaisamy, Vs. 52, Iswarya Garden, Rakkiyapalayam Road, Ammapalayam, Avinashi Road, Tirupur - 641 654. [Pan:Afbpg-3703-L] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By : Ms. E. Pavuna Sundari, C.I.T. प्रत्यर्थी की ओर से /Respondent By : Shri. R. Venkata Raman, C.A. सुनवाई की तारीख/Date Of Hearing : 12.11.2025 घोषणा की तारीख/Date Of Pronouncement : 20.01.2026 :-2-:

For Appellant: Ms. E. Pavuna Sundari, C.I.TFor Respondent: Shri. R. Venkata Raman, C.A

Section 132Section 132(4)Section 139(4)

…s 13.851/2 acres) showed papers not relatable, documents are incomplete and uncorroborated "dumb documents”, no corroborative evidence of actual cash flow existed, reliance placed solely on such papers is unsustainable in law, supported by SC in Common Cause (394 ITR 220) and various High Courts/Tribunal decisions. Accordingly, this Tribunal dismissed the Revenue's appeal and affirmed Ld.CIT(A)'s deletion of addition in buyer's case. The relevant findings of this Tribunal are as under:- “45. Upon a careful and comprehensive examination of the seized material, being pages 23 to 26 of loose sheets contained in ANN/…

DALAVAI AUDIKESAVULU SRINIVAS L/H OF LATE SMT D A SATHYAPRABHA,BENGALURU vs. DCIT, CENTRAL CIRCLE-2(1), BANGALORE

In the result, the appeal filed by the assessee is allowed

ITA 1050/BANG/2025[2017-18]Status: DisposedITAT Bangalore12 Jan 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri H. Siva Prasad Reddy, ITPFor Respondent: Shri Shivanand H Kalakeri, CIT-DR

Section 132(4)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 234ASection 271(1)(c)Section 69B

…based on the loose sheets/diaries are contrary to law, which require to be set aside in these writ appeals, as the same are void and illegal.” 13. The Hon’ble Jurisdictional High Court had relied on the judgment of the Hon’ble Supreme Court reported in (2017) 394 ITR 220 in the case of Common Cause (A Registered Society) vs. Union of India in coming to the said conclusion. The Hon’ble Jurisdictional High Court also relied on the another judgment of the Hon’ble Supreme Court reported in (1998) 3 SCC 410 in the case of CBI vs. V.C. Shukla. Page 9 of 14 ITA Nos. 1049 & 1050/Bang/2025 14. We have also perused the st…

DALAVAI AUDIKESAVULU SRINIVAS L/H OF LATE SMT D A SATHYAPRABHA,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(1), BANGALORE

In the result, the appeal filed by the assessee is allowed

ITA 1049/BANG/2025[2013-14]Status: DisposedITAT Bangalore12 Jan 2026AY 2013-14

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri H. Siva Prasad Reddy, ITPFor Respondent: Shri Shivanand H Kalakeri, CIT-DR

Section 132(4)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 234ASection 271(1)(c)Section 69B

…based on the loose sheets/diaries are contrary to law, which require to be set aside in these writ appeals, as the same are void and illegal.” 13. The Hon’ble Jurisdictional High Court had relied on the judgment of the Hon’ble Supreme Court reported in (2017) 394 ITR 220 in the case of Common Cause (A Registered Society) vs. Union of India in coming to the said conclusion. The Hon’ble Jurisdictional High Court also relied on the another judgment of the Hon’ble Supreme Court reported in (1998) 3 SCC 410 in the case of CBI vs. V.C. Shukla. Page 9 of 14 ITA Nos. 1049 & 1050/Bang/2025 14. We have also perused the st…

NIMUS PROJECTS LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE-2, NOIDA

The appeal are disposed of as not pressed

ITA 5015/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Jan 2026AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 132Section 142(1)Section 147Section 148Section 69C

…that an alleged paper prepared by third party cannot be made basis of addition against assessee and reliance was placed on V C Shukla ITA No. 5013/Del/2025 & Ors. Nimbus Projects Ltd. [1998] 3 SCC 410 (SC), Common Cause (A Registered Society) v. UOI (2017) 394 ITR 220 (SC). 9. The Ld. CIT(A), while dismissing the appeal, was of the opinion that it is admitted case that the transaction has taken place between the assessee and searched entity and majority of the transactions are recorded in the books of accounts of either the assessee or another entity by the name of M/s. Nimbus Propmart Pvt. Ltd. and said deta…

NIMBUS PROJECTS LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE-2, NOIDA

The appeal are disposed of as not pressed

ITA 5014/DEL/2025[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 132Section 142(1)Section 147Section 148Section 69C

…that an alleged paper prepared by third party cannot be made basis of addition against assessee and reliance was placed on V C Shukla ITA No. 5013/Del/2025 & Ors. Nimbus Projects Ltd. [1998] 3 SCC 410 (SC), Common Cause (A Registered Society) v. UOI (2017) 394 ITR 220 (SC). 9. The Ld. CIT(A), while dismissing the appeal, was of the opinion that it is admitted case that the transaction has taken place between the assessee and searched entity and majority of the transactions are recorded in the books of accounts of either the assessee or another entity by the name of M/s. Nimbus Propmart Pvt. Ltd. and said deta…

NUMBUS PROJECTS LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE-2, NOIDA

The appeal are disposed of as not pressed

ITA 5013/DEL/2025[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 132Section 142(1)Section 147Section 148Section 69C

…that an alleged paper prepared by third party cannot be made basis of addition against assessee and reliance was placed on V C Shukla ITA No. 5013/Del/2025 & Ors. Nimbus Projects Ltd. [1998] 3 SCC 410 (SC), Common Cause (A Registered Society) v. UOI (2017) 394 ITR 220 (SC). 9. The Ld. CIT(A), while dismissing the appeal, was of the opinion that it is admitted case that the transaction has taken place between the assessee and searched entity and majority of the transactions are recorded in the books of accounts of either the assessee or another entity by the name of M/s. Nimbus Propmart Pvt. Ltd. and said deta…