Society v. UOI

394 ITR 220Supreme Court of India2017#141 most cited

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.

493

judgments rely on this decision, according to BharatTax’s citation analysis of 367,164 Indian tax judgments — from 2018 to 2026.

Also referred to as

Society v. UOI · Common Cause (a registered society) 394 ITR 220 · loose papers evidentiary value · uncorroborated documents search · independent corroboration undisclosed income · Section 132(4) statement · Section 292C · Section 34 Evidence Act

Sections most often in play

Section 132Section 132(4)Section 153ASection 153CSection 143(3)Section 292CSection 132(4A)Section 69A

Issues it is cited on

section 292ccsection 132(4a)dumb documentssection 34retraction of statementsection 292cloose papersretracted statementsection 153c(1)statement under section 132(4)protective assessmentsection 131(1a)

Judgments citing Society v. UOI

Birendra Kumar Sharma, Gwalior vs. ACIT 1(1), Bhopal

In the result these bunch of fourteen appeals of the assessee’s for Assessment Year 2009-10 are partly allowed for statistical purposes

ITA 542/IND/2017[09-10]Status: DisposedITAT Indore04 Jun 2019

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

…Ltd. v. would in any case not applicable DCIT to a third party from whose possession such papers and documents have not been obtained 19 (2006) 99 ITD 177 Dumb Documents or documents Para 136- (Del) with no certainty have no 36 153 evidentiary value 20 (2017) 394 ITR 220 Investigation could not have been 154- (Hon'ble Supreme directed in cas of high public 162 Court) Common functionaries on the basis of cause ( A registered legally inadmissible evidence in Society) v. UOI form of loose papers 21 (2018) 32 ITJ 510 AO made additions without any 36 163- (Trib- Indore) basis and only on the basis of 193 Assessment. C…

Shri Dharmendra Kumar Choudhary, Gwalior vs. The DCIT 1(1), Bhopal

In the result these bunch of fourteen appeals of the assessee’s for Assessment Year 2009-10 are partly allowed for statistical purposes

ITA 710/IND/2016[2009-10]Status: DisposedITAT Indore04 Jun 2019AY 2009-10

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

…Ltd. v. would in any case not applicable DCIT to a third party from whose possession such papers and documents have not been obtained 19 (2006) 99 ITD 177 Dumb Documents or documents Para 136- (Del) with no certainty have no 36 153 evidentiary value 20 (2017) 394 ITR 220 Investigation could not have been 154- (Hon'ble Supreme directed in cas of high public 162 Court) Common functionaries on the basis of cause ( A registered legally inadmissible evidence in Society) v. UOI form of loose papers 21 (2018) 32 ITJ 510 AO made additions without any 36 163- (Trib- Indore) basis and only on the basis of 193 Assessment. C…

Shri Vijay Kumar Shrivastava, Gwalior vs. The DCIT 1(1), Bhopal

In the result these bunch of fourteen appeals of the assessee’s for Assessment Year 2009-10 are partly allowed for statistical purposes

ITA 709/IND/2016[2009-10]Status: DisposedITAT Indore04 Jun 2019AY 2009-10

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

…Ltd. v. would in any case not applicable DCIT to a third party from whose possession such papers and documents have not been obtained 19 (2006) 99 ITD 177 Dumb Documents or documents Para 136- (Del) with no certainty have no 36 153 evidentiary value 20 (2017) 394 ITR 220 Investigation could not have been 154- (Hon'ble Supreme directed in cas of high public 162 Court) Common functionaries on the basis of cause ( A registered legally inadmissible evidence in Society) v. UOI form of loose papers 21 (2018) 32 ITJ 510 AO made additions without any 36 163- (Trib- Indore) basis and only on the basis of 193 Assessment. C…

Shri Ramesh Chandra Parashar, Gwalior vs. The DCIT 1(1), Bhopal

In the result these bunch of fourteen appeals of the assessee’s for Assessment Year 2009-10 are partly allowed for statistical purposes

ITA 708/IND/2016[2009-10]Status: DisposedITAT Indore04 Jun 2019AY 2009-10

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

…Ltd. v. would in any case not applicable DCIT to a third party from whose possession such papers and documents have not been obtained 19 (2006) 99 ITD 177 Dumb Documents or documents Para 136- (Del) with no certainty have no 36 153 evidentiary value 20 (2017) 394 ITR 220 Investigation could not have been 154- (Hon'ble Supreme directed in cas of high public 162 Court) Common functionaries on the basis of cause ( A registered legally inadmissible evidence in Society) v. UOI form of loose papers 21 (2018) 32 ITJ 510 AO made additions without any 36 163- (Trib- Indore) basis and only on the basis of 193 Assessment. C…

Shri Pradeep Kumar Sharma, Dabra vs. The DCIT 1(1), Bhopal

In the result these bunch of fourteen appeals of the assessee’s for Assessment Year 2009-10 are partly allowed for statistical purposes

ITA 707/IND/2016[2009-10]Status: DisposedITAT Indore04 Jun 2019AY 2009-10

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

…Ltd. v. would in any case not applicable DCIT to a third party from whose possession such papers and documents have not been obtained 19 (2006) 99 ITD 177 Dumb Documents or documents Para 136- (Del) with no certainty have no 36 153 evidentiary value 20 (2017) 394 ITR 220 Investigation could not have been 154- (Hon'ble Supreme directed in cas of high public 162 Court) Common functionaries on the basis of cause ( A registered legally inadmissible evidence in Society) v. UOI form of loose papers 21 (2018) 32 ITJ 510 AO made additions without any 36 163- (Trib- Indore) basis and only on the basis of 193 Assessment. C…

Shri Lalta Prasad Choudhary, Gwalior vs. The DCIT 1(1), Bhopal

In the result these bunch of fourteen appeals of the assessee’s for Assessment Year 2009-10 are partly allowed for statistical purposes

ITA 706/IND/2016[2009-10]Status: DisposedITAT Indore04 Jun 2019AY 2009-10

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

…Ltd. v. would in any case not applicable DCIT to a third party from whose possession such papers and documents have not been obtained 19 (2006) 99 ITD 177 Dumb Documents or documents Para 136- (Del) with no certainty have no 36 153 evidentiary value 20 (2017) 394 ITR 220 Investigation could not have been 154- (Hon'ble Supreme directed in cas of high public 162 Court) Common functionaries on the basis of cause ( A registered legally inadmissible evidence in Society) v. UOI form of loose papers 21 (2018) 32 ITJ 510 AO made additions without any 36 163- (Trib- Indore) basis and only on the basis of 193 Assessment. C…

Shri Santosh Kumar Sharma, Gwalior vs. The DCIT 1(1), Bhopal

In the result these bunch of fourteen appeals of the assessee’s for Assessment Year 2009-10 are partly allowed for statistical purposes

ITA 705/IND/2016[2009-10]Status: DisposedITAT Indore04 Jun 2019AY 2009-10

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

…Ltd. v. would in any case not applicable DCIT to a third party from whose possession such papers and documents have not been obtained 19 (2006) 99 ITD 177 Dumb Documents or documents Para 136- (Del) with no certainty have no 36 153 evidentiary value 20 (2017) 394 ITR 220 Investigation could not have been 154- (Hon'ble Supreme directed in cas of high public 162 Court) Common functionaries on the basis of cause ( A registered legally inadmissible evidence in Society) v. UOI form of loose papers 21 (2018) 32 ITJ 510 AO made additions without any 36 163- (Trib- Indore) basis and only on the basis of 193 Assessment. C…

Shri Kamlesh Kumar Choudhary, Gwalior vs. The DCIT 1(1), Bhopal

In the result these bunch of fourteen appeals of the assessee’s for Assessment Year 2009-10 are partly allowed for statistical purposes

ITA 704/IND/2016[2009-10]Status: DisposedITAT Indore04 Jun 2019AY 2009-10

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

…Ltd. v. would in any case not applicable DCIT to a third party from whose possession such papers and documents have not been obtained 19 (2006) 99 ITD 177 Dumb Documents or documents Para 136- (Del) with no certainty have no 36 153 evidentiary value 20 (2017) 394 ITR 220 Investigation could not have been 154- (Hon'ble Supreme directed in cas of high public 162 Court) Common functionaries on the basis of cause ( A registered legally inadmissible evidence in Society) v. UOI form of loose papers 21 (2018) 32 ITJ 510 AO made additions without any 36 163- (Trib- Indore) basis and only on the basis of 193 Assessment. C…

Shri Khemraj Singh Chauhan, Gwalior vs. The DCIT 1(1), Bhopal

In the result these bunch of fourteen appeals of the assessee’s for Assessment Year 2009-10 are partly allowed for statistical purposes

ITA 703/IND/2016[2009-10]Status: DisposedITAT Indore04 Jun 2019AY 2009-10

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

…Ltd. v. would in any case not applicable DCIT to a third party from whose possession such papers and documents have not been obtained 19 (2006) 99 ITD 177 Dumb Documents or documents Para 136- (Del) with no certainty have no 36 153 evidentiary value 20 (2017) 394 ITR 220 Investigation could not have been 154- (Hon'ble Supreme directed in cas of high public 162 Court) Common functionaries on the basis of cause ( A registered legally inadmissible evidence in Society) v. UOI form of loose papers 21 (2018) 32 ITJ 510 AO made additions without any 36 163- (Trib- Indore) basis and only on the basis of 193 Assessment. C…

Shri Sukhdev Singh Dhariwal, Gwalior vs. The DCIT 1(1), Bhopal

In the result these bunch of fourteen appeals of the assessee’s for Assessment Year 2009-10 are partly allowed for statistical purposes

ITA 702/IND/2016[2009-10]Status: DisposedITAT Indore04 Jun 2019AY 2009-10

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

…Ltd. v. would in any case not applicable DCIT to a third party from whose possession such papers and documents have not been obtained 19 (2006) 99 ITD 177 Dumb Documents or documents Para 136- (Del) with no certainty have no 36 153 evidentiary value 20 (2017) 394 ITR 220 Investigation could not have been 154- (Hon'ble Supreme directed in cas of high public 162 Court) Common functionaries on the basis of cause ( A registered legally inadmissible evidence in Society) v. UOI form of loose papers 21 (2018) 32 ITJ 510 AO made additions without any 36 163- (Trib- Indore) basis and only on the basis of 193 Assessment. C…

Shri Sanjay Kumar Sahu, Gwalior vs. The DCIT 1(1), Bhopal

In the result these bunch of fourteen appeals of the assessee’s for Assessment Year 2009-10 are partly allowed for statistical purposes

ITA 701/IND/2016[2009-10]Status: DisposedITAT Indore04 Jun 2019AY 2009-10

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

…Ltd. v. would in any case not applicable DCIT to a third party from whose possession such papers and documents have not been obtained 19 (2006) 99 ITD 177 Dumb Documents or documents Para 136- (Del) with no certainty have no 36 153 evidentiary value 20 (2017) 394 ITR 220 Investigation could not have been 154- (Hon'ble Supreme directed in cas of high public 162 Court) Common functionaries on the basis of cause ( A registered legally inadmissible evidence in Society) v. UOI form of loose papers 21 (2018) 32 ITJ 510 AO made additions without any 36 163- (Trib- Indore) basis and only on the basis of 193 Assessment. C…

The ACIT- 1(1), Bhopal vs. Shri Vinod Vaish, Bhopal

In the result these bunch of fourteen appeals of the assessee’s for Assessment Year 2009-10 are partly allowed for statistical purposes

ITA 189/IND/2013[2009-10]Status: DisposedITAT Indore04 Jun 2019AY 2009-10

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

…Ltd. v. would in any case not applicable DCIT to a third party from whose possession such papers and documents have not been obtained 19 (2006) 99 ITD 177 Dumb Documents or documents Para 136- (Del) with no certainty have no 36 153 evidentiary value 20 (2017) 394 ITR 220 Investigation could not have been 154- (Hon'ble Supreme directed in cas of high public 162 Court) Common functionaries on the basis of cause ( A registered legally inadmissible evidence in Society) v. UOI form of loose papers 21 (2018) 32 ITJ 510 AO made additions without any 36 163- (Trib- Indore) basis and only on the basis of 193 Assessment. C…

Jaswinder Singh Bains Alia Jazzy B, Jalandhar vs. D.C.I.T, Central Circle - II, Jalandhar

In the result, the appeals of the assessee are allowed

ITA 341/ASR/2017[2013-14]Status: DisposedITAT Amritsar27 Mar 2019AY 2013-14

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 337/Asr./2017 : Asstt. Year : 2007-08 Ita No. 338/Asr./2017 : Asstt. Year : 2008-09 Ita No. 339/Asr./2017 : Asstt. Year : 2009-10 Ita No. 340/Asr./2017 : Asstt. Year : 2010-11 Ita No. 341/Asr./2017 : Asstt. Year : 2013-14 Jaswinder Singh Bains Alia Vs Dy. Commissioner Of Income Jazzy B, 10, Seiyu Complex, Tax, Central Circle-Ii, Model Town, Jalandhar Jalandhar (Appellant) (Respondent) Pan No. Amzps7517F Assessee By : Sh. J. S. Bhasin, Adv. Revenue By : Sh. M. P. Singh, Cit Dr Date Of Hearing :21.02.2019 Date Of Pronouncement : 28.03.2019 Order Per N. S. Saini: These Are The Appeals Filed By The Assessee Against The Order Of Cit(A)-1, Jalandhar All Dated 14.03.2017 For The Assessment Years 2007-08, 2008-09, 2009-10, 2010-11 & 2013-14. 2. The Assessee Has Raised Additional Ground Of Appeal In The Assessment Years 2007-08 & 2008-09 Which Reads As Under: “That The Notice Issued U/S 153C For This Year, Not Being Consistent With The First Proviso To Section 153C, Is Illegal & The Consequential Order Under Appeal, Passed Thereupon Is Also Illegal.”

For Appellant: Sh. J. S. Bhasin, AdvFor Respondent: Sh. M. P. Singh, CIT DR
Section 132Section 153C

…the said seized document cannot be treated as an evidence against the assessee. 32. Our above view finds support from the decision of the Hon’ble Supreme Court in the case of Common Cause (A Registered Society) and Others Vs Union of India and Others (2017) 394 ITR 220 (SC) has held as under: “22. In case of Sahara, in addition we have the adjudication by the Income- tax Settlement Commission. The order has been placed on record along with I. A. No. 4. The Settlement Commission has observed that the scrutiny of entries on loose papers, computer prints, hard disk, pen drives, etc. have revealed that the transact…

Jaswinder Singh Bains Alia Jazzy B, Jalandhar vs. D.C.I.T, Central Circle - II, Jalandhar

In the result, the appeals of the assessee are allowed

ITA 340/ASR/2017[2010-11]Status: DisposedITAT Amritsar27 Mar 2019AY 2010-11

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 337/Asr./2017 : Asstt. Year : 2007-08 Ita No. 338/Asr./2017 : Asstt. Year : 2008-09 Ita No. 339/Asr./2017 : Asstt. Year : 2009-10 Ita No. 340/Asr./2017 : Asstt. Year : 2010-11 Ita No. 341/Asr./2017 : Asstt. Year : 2013-14 Jaswinder Singh Bains Alia Vs Dy. Commissioner Of Income Jazzy B, 10, Seiyu Complex, Tax, Central Circle-Ii, Model Town, Jalandhar Jalandhar (Appellant) (Respondent) Pan No. Amzps7517F Assessee By : Sh. J. S. Bhasin, Adv. Revenue By : Sh. M. P. Singh, Cit Dr Date Of Hearing :21.02.2019 Date Of Pronouncement : 28.03.2019 Order Per N. S. Saini: These Are The Appeals Filed By The Assessee Against The Order Of Cit(A)-1, Jalandhar All Dated 14.03.2017 For The Assessment Years 2007-08, 2008-09, 2009-10, 2010-11 & 2013-14. 2. The Assessee Has Raised Additional Ground Of Appeal In The Assessment Years 2007-08 & 2008-09 Which Reads As Under: “That The Notice Issued U/S 153C For This Year, Not Being Consistent With The First Proviso To Section 153C, Is Illegal & The Consequential Order Under Appeal, Passed Thereupon Is Also Illegal.”

For Appellant: Sh. J. S. Bhasin, AdvFor Respondent: Sh. M. P. Singh, CIT DR
Section 132Section 153C

…the said seized document cannot be treated as an evidence against the assessee. 32. Our above view finds support from the decision of the Hon’ble Supreme Court in the case of Common Cause (A Registered Society) and Others Vs Union of India and Others (2017) 394 ITR 220 (SC) has held as under: “22. In case of Sahara, in addition we have the adjudication by the Income- tax Settlement Commission. The order has been placed on record along with I. A. No. 4. The Settlement Commission has observed that the scrutiny of entries on loose papers, computer prints, hard disk, pen drives, etc. have revealed that the transact…

Jaswinder Singh Bains Alia Jazzy B, Jalandhar vs. D.C.I.T, Central Circle - II, Jalandhar

In the result, the appeals of the assessee are allowed

ITA 339/ASR/2017[2009-10]Status: DisposedITAT Amritsar27 Mar 2019AY 2009-10

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 337/Asr./2017 : Asstt. Year : 2007-08 Ita No. 338/Asr./2017 : Asstt. Year : 2008-09 Ita No. 339/Asr./2017 : Asstt. Year : 2009-10 Ita No. 340/Asr./2017 : Asstt. Year : 2010-11 Ita No. 341/Asr./2017 : Asstt. Year : 2013-14 Jaswinder Singh Bains Alia Vs Dy. Commissioner Of Income Jazzy B, 10, Seiyu Complex, Tax, Central Circle-Ii, Model Town, Jalandhar Jalandhar (Appellant) (Respondent) Pan No. Amzps7517F Assessee By : Sh. J. S. Bhasin, Adv. Revenue By : Sh. M. P. Singh, Cit Dr Date Of Hearing :21.02.2019 Date Of Pronouncement : 28.03.2019 Order Per N. S. Saini: These Are The Appeals Filed By The Assessee Against The Order Of Cit(A)-1, Jalandhar All Dated 14.03.2017 For The Assessment Years 2007-08, 2008-09, 2009-10, 2010-11 & 2013-14. 2. The Assessee Has Raised Additional Ground Of Appeal In The Assessment Years 2007-08 & 2008-09 Which Reads As Under: “That The Notice Issued U/S 153C For This Year, Not Being Consistent With The First Proviso To Section 153C, Is Illegal & The Consequential Order Under Appeal, Passed Thereupon Is Also Illegal.”

For Appellant: Sh. J. S. Bhasin, AdvFor Respondent: Sh. M. P. Singh, CIT DR
Section 132Section 153C

…the said seized document cannot be treated as an evidence against the assessee. 32. Our above view finds support from the decision of the Hon’ble Supreme Court in the case of Common Cause (A Registered Society) and Others Vs Union of India and Others (2017) 394 ITR 220 (SC) has held as under: “22. In case of Sahara, in addition we have the adjudication by the Income- tax Settlement Commission. The order has been placed on record along with I. A. No. 4. The Settlement Commission has observed that the scrutiny of entries on loose papers, computer prints, hard disk, pen drives, etc. have revealed that the transact…

Jaswinder Singh Bains Alia Jazzy B, Jalandhar vs. D.C.I.T, Central Circle - II, Jalandhar

In the result, the appeals of the assessee are allowed

ITA 338/ASR/2017[2008-09]Status: DisposedITAT Amritsar27 Mar 2019AY 2008-09

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 337/Asr./2017 : Asstt. Year : 2007-08 Ita No. 338/Asr./2017 : Asstt. Year : 2008-09 Ita No. 339/Asr./2017 : Asstt. Year : 2009-10 Ita No. 340/Asr./2017 : Asstt. Year : 2010-11 Ita No. 341/Asr./2017 : Asstt. Year : 2013-14 Jaswinder Singh Bains Alia Vs Dy. Commissioner Of Income Jazzy B, 10, Seiyu Complex, Tax, Central Circle-Ii, Model Town, Jalandhar Jalandhar (Appellant) (Respondent) Pan No. Amzps7517F Assessee By : Sh. J. S. Bhasin, Adv. Revenue By : Sh. M. P. Singh, Cit Dr Date Of Hearing :21.02.2019 Date Of Pronouncement : 28.03.2019 Order Per N. S. Saini: These Are The Appeals Filed By The Assessee Against The Order Of Cit(A)-1, Jalandhar All Dated 14.03.2017 For The Assessment Years 2007-08, 2008-09, 2009-10, 2010-11 & 2013-14. 2. The Assessee Has Raised Additional Ground Of Appeal In The Assessment Years 2007-08 & 2008-09 Which Reads As Under: “That The Notice Issued U/S 153C For This Year, Not Being Consistent With The First Proviso To Section 153C, Is Illegal & The Consequential Order Under Appeal, Passed Thereupon Is Also Illegal.”

For Appellant: Sh. J. S. Bhasin, AdvFor Respondent: Sh. M. P. Singh, CIT DR
Section 132Section 153C

…the said seized document cannot be treated as an evidence against the assessee. 32. Our above view finds support from the decision of the Hon’ble Supreme Court in the case of Common Cause (A Registered Society) and Others Vs Union of India and Others (2017) 394 ITR 220 (SC) has held as under: “22. In case of Sahara, in addition we have the adjudication by the Income- tax Settlement Commission. The order has been placed on record along with I. A. No. 4. The Settlement Commission has observed that the scrutiny of entries on loose papers, computer prints, hard disk, pen drives, etc. have revealed that the transact…

Jaswinder Singh Bains Alia Jazzy B, Jalandhar vs. D.C.I.T, Central Circle - II, Jalandhar

In the result, the appeals of the assessee are allowed

ITA 337/ASR/2017[2007-08]Status: DisposedITAT Amritsar27 Mar 2019AY 2007-08

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 337/Asr./2017 : Asstt. Year : 2007-08 Ita No. 338/Asr./2017 : Asstt. Year : 2008-09 Ita No. 339/Asr./2017 : Asstt. Year : 2009-10 Ita No. 340/Asr./2017 : Asstt. Year : 2010-11 Ita No. 341/Asr./2017 : Asstt. Year : 2013-14 Jaswinder Singh Bains Alia Vs Dy. Commissioner Of Income Jazzy B, 10, Seiyu Complex, Tax, Central Circle-Ii, Model Town, Jalandhar Jalandhar (Appellant) (Respondent) Pan No. Amzps7517F Assessee By : Sh. J. S. Bhasin, Adv. Revenue By : Sh. M. P. Singh, Cit Dr Date Of Hearing :21.02.2019 Date Of Pronouncement : 28.03.2019 Order Per N. S. Saini: These Are The Appeals Filed By The Assessee Against The Order Of Cit(A)-1, Jalandhar All Dated 14.03.2017 For The Assessment Years 2007-08, 2008-09, 2009-10, 2010-11 & 2013-14. 2. The Assessee Has Raised Additional Ground Of Appeal In The Assessment Years 2007-08 & 2008-09 Which Reads As Under: “That The Notice Issued U/S 153C For This Year, Not Being Consistent With The First Proviso To Section 153C, Is Illegal & The Consequential Order Under Appeal, Passed Thereupon Is Also Illegal.”

For Appellant: Sh. J. S. Bhasin, AdvFor Respondent: Sh. M. P. Singh, CIT DR
Section 132Section 153C

…the said seized document cannot be treated as an evidence against the assessee. 32. Our above view finds support from the decision of the Hon’ble Supreme Court in the case of Common Cause (A Registered Society) and Others Vs Union of India and Others (2017) 394 ITR 220 (SC) has held as under: “22. In case of Sahara, in addition we have the adjudication by the Income- tax Settlement Commission. The order has been placed on record along with I. A. No. 4. The Settlement Commission has observed that the scrutiny of entries on loose papers, computer prints, hard disk, pen drives, etc. have revealed that the transact…

Geefcee Finance Ltd., New Delhi vs. ACIT, Noida

In the result, all the appeals of the appellants in 86

ITA 6714/DEL/2016[2009-10]Status: DisposedITAT Delhi23 Jan 2019AY 2009-10

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble

…sheet No. 8) and not in MR 71/91. Resultantly, in view of our earlier discussion, section 34 cannot at all be pressed into service against him.” 11. Similar view was taken by the Hon'ble Supreme Court in the case of Common Cause, A registered Society Vs. UOI 394 ITR 220. 12. In the light of the ratio laid down by the Hon'ble Supreme Court [supra], notings found in the loose sheets would not do any good to the Revenue. The assessee has claimed 25 paise or 0.25% on the strength of the statement of kingpin Shri Tarun Goyal, who in his statement recorded under oath u/s 132(4) of the Income tax Act, 1961 has categori…

Geefcee Finance Ltd., New Delhi vs. ACIT, Noida

In the result, all the appeals of the appellants in 86

ITA 6713/DEL/2016[2008-09]Status: DisposedITAT Delhi23 Jan 2019AY 2008-09

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble

…sheet No. 8) and not in MR 71/91. Resultantly, in view of our earlier discussion, section 34 cannot at all be pressed into service against him.” 11. Similar view was taken by the Hon'ble Supreme Court in the case of Common Cause, A registered Society Vs. UOI 394 ITR 220. 12. In the light of the ratio laid down by the Hon'ble Supreme Court [supra], notings found in the loose sheets would not do any good to the Revenue. The assessee has claimed 25 paise or 0.25% on the strength of the statement of kingpin Shri Tarun Goyal, who in his statement recorded under oath u/s 132(4) of the Income tax Act, 1961 has categori…

Geefcee Finance Ltd., New Delhi vs. ACIT, Noida

In the result, all the appeals of the appellants in 86

ITA 6712/DEL/2016[2007-08]Status: DisposedITAT Delhi23 Jan 2019AY 2007-08

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble

…sheet No. 8) and not in MR 71/91. Resultantly, in view of our earlier discussion, section 34 cannot at all be pressed into service against him.” 11. Similar view was taken by the Hon'ble Supreme Court in the case of Common Cause, A registered Society Vs. UOI 394 ITR 220. 12. In the light of the ratio laid down by the Hon'ble Supreme Court [supra], notings found in the loose sheets would not do any good to the Revenue. The assessee has claimed 25 paise or 0.25% on the strength of the statement of kingpin Shri Tarun Goyal, who in his statement recorded under oath u/s 132(4) of the Income tax Act, 1961 has categori…