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 366,470 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

Ramrao Adik Education Society, Mumbai vs. Deputy Commissioner of Incometax Central Circle 7(1), Mumbai

Accordingly. The ground raised by the revenue is partly allowed for

ITA 1513/MUM/2025[2015-16]Status: DisposedITAT Mumbai04 Sept 2025AY 2015-16

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Respondent: Shri Rajiv Khandelwal, CA
Section 12ASection 132Section 132(4)Section 153CSection 250Section 68Section 9

…s do not constitute books of account. Revenue has not even alleged that the entries in these loose sheets and electronic data have been kept regularly during the course of business. The Apex Court in the case of Common Cause (A Registered Society) reported in 394 ITR 220 has held that such detailed documents recovered by the authorities have no evidentiary value. Uncorroborated loose papers found in the search cannot be taken as a sole basis for determination of undisclosed income. 14. 7. The Supreme Court in the case of CBI vs V.C. Shukla and Ors has held that - “In Mukundram (supra) after dealing with the word…

Ramrao Adik Education Society, Mumbai vs. Deputy Commissioner of Income Tax Central Circle 7(1), Mumbai

Accordingly. The ground raised by the revenue is partly allowed for

ITA 1511/MUM/2025[2013-14]Status: DisposedITAT Mumbai04 Sept 2025AY 2013-14

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 12ASection 132Section 132(4)Section 153CSection 250Section 4Section 68

…s do not constitute books of account. Revenue has not even alleged that the entries in these loose sheets and electronic data have been kept regularly during the course of business. The Apex Court in the case of Common Cause (A Registered Society) reported in 394 ITR 220 has held that such detailed documents recovered by the authorities have no evidentiary value. Uncorroborated loose papers found in the search cannot be taken as a sole basis for determination of undisclosed income. 14. 7. The Supreme Court in the case of CBI vs V.C. Shukla and Ors has held that - “In Mukundram (supra) after dealing with the word…

Ramrao Adik Education Society, Mumbai vs. Deputy Commissioner of Income Tax Central Circle 7(1), Mumbai

Accordingly. The ground raised by the revenue is partly allowed for

ITA 1510/MUM/2025[2012-13]Status: DisposedITAT Mumbai04 Sept 2025AY 2012-13

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 11Section 12ASection 132Section 132(4)Section 153CSection 250Section 4Section 68

…s do not constitute books of account. Revenue has not even alleged that the entries in these loose sheets and electronic data have been kept regularly during the course of business. The Apex Court in the case of Common Cause (A Registered Society) reported in 394 ITR 220 has held that such detailed documents recovered by the authorities have no evidentiary value. Uncorroborated loose papers found in the search cannot be taken as a sole basis for determination of undisclosed income. 14. 7. The Supreme Court in the case of CBI vs V.C. Shukla and Ors has held that - “In Mukundram (supra) after dealing with the word…

Ramrao Adik Education Society, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle 7(1), Mumbai

Accordingly. The ground raised by the revenue is partly allowed for

ITA 1509/MUM/2025[2011-12]Status: DisposedITAT Mumbai04 Sept 2025AY 2011-12

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 12ASection 132Section 132(4)Section 153CSection 250Section 68Section 9

…s do not constitute books of account. Revenue has not even alleged that the entries in these loose sheets and electronic data have been kept regularly during the course of business. The Apex Court in the case of Common Cause (A Registered Society) reported in 394 ITR 220 has held that such detailed documents recovered by the authorities have no evidentiary value. Uncorroborated loose papers found in the search cannot be taken as a sole basis for determination of undisclosed income. 14. 7. The Supreme Court in the case of CBI vs V.C. Shukla and Ors has held that - “In Mukundram (supra) after dealing with the word…

Suresh Kumar Reddy Krishnapuram, Kurnool vs. ACIT., Central Circle - 2(3), Hyderabad

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 538/HYD/2025[2021-22]Status: DisposedITAT Hyderabad20 Aug 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…f contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of other seized documents. In this connection, he invited to the material seized…

Suresh Kumar Reddy Krishnapuram, Kurnool vs. ACIT., Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 537/HYD/2025[2020-21]Status: DisposedITAT Hyderabad20 Aug 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…f contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of other seized documents. In this connection, he invited to the material seized…

Skandhanshi Infra Projects, Kurnool vs. ACIT., Central Circle-2(3), Hyderabad

ITA 535/HYD/2025[2020-21]Status: DisposedITAT Hyderabad20 Aug 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…d in certain portions of the seized material while disregarding entries that clearly indicated suppressed turnover and cash receipts. Such selective reliance undermines the credibility of the appellant's submissions. As held in Common Cause v. Union of India (394 ITR 220), seized material must be evaluated holistically, and selective reliance by the assessee is impermissible. viii) The appellant argued that the additional income disclosed was an estimate made in good faith. Even though, the appellant made an estimate of the additional income, the same is based on seized material which formed the basis for admiss…

Skandhanshi Infra Projects, Kurnool vs. ACIT., Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 534/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…f contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of other seized documents. In this connection, he invited to the material seized…

Skanda Developers & Builders, Kurnool vs. ACIT., Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 533/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…f contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of other seized documents. In this connection, he invited to the material seized…

Skanda Builders, Kurnool vs. ACIT., Central Circle - 2(3), Hyderabad

ITA 532/HYD/2025[2021-22]Status: DisposedITAT Hyderabad20 Aug 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…d in certain portions of the seized material while disregarding entries that clearly indicated suppressed turnover and cash receipts. Such selective reliance undermines the credibility of the appellant’s submissions. As held in Common Cause v. Union of India (394 ITR 220), seized material must be evaluated holistically, and selective reliance by the assessee is impermissible. vii) The appellant argued that the additional income disclosed was an estimate made in good faith. Even though, the appellant made an estimate of the additional income, the same is based on seized material which formed the basis for admissio…

Skandhanshi Developers, Kurnool vs. ACIT., Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 527/HYD/2025[2020-21]Status: DisposedITAT Hyderabad20 Aug 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…f contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of other seized documents. In this connection, he invited to the material seized…

Skanda Infra Projects, Kurnool vs. ACIT., Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 522/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…f contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of other seized documents. In this connection, he invited to the material seized…

Skandhanshi Infra Projects India Private Limited, Kurnool vs. ACIT., Central Circle-2(3), Hyderabad

ITA 519/HYD/2025[2020-21]Status: DisposedITAT Hyderabad20 Aug 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…d in certain portions of the seized material while disregarding entries that clearly indicated suppressed turnover and cash receipts. Such selective reliance undermines the credibility of the appellant’s submissions. As held in Common Cause v. Union of India (394 ITR 220), seized material must be evaluated holistically, and selective reliance by the assessee is impermissible. viii) The appellant argued that the seized material lacked "general discrepancies" rather than actual suppression of turnover is contradicted by specific details in the seized documents showing unaccounted cash transactions. Further, admissi…

Skandhanshi Infra Projects India Private Limited, Kurnool vs. ACIT., Central Circle-2(3), Hyderabad

ITA 518/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…d in certain portions of the seized material while disregarding entries that clearly indicated suppressed turnover and cash receipts. Such selective reliance undermines the credibility of the appellant's submissions. As held in Common Cause v. Union of India (394 ITR 220), seized material must be evaluated holistically, and selective reliance by the assessee is impermissible. viii) The appellant argued that the additional income disclosed was an estimate made in good faith. Even though, the appellant made an estimate of the additional income, the same is based on seized material which formed the basis for admiss…

Skanda Infra Projects India Private Limited, Kurnool vs. ACIT., Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 517/HYD/2025[2022-23]Status: DisposedITAT Hyderabad20 Aug 2025AY 2022-23

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…f contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of other seized documents. In this connection, he invited to the material seized…

Skanda Infra Projects India Private Limited, Kurnool vs. ACIT., Central Circle-2(3), Hyderabad

ITA 515/HYD/2025[2020-21]Status: DisposedITAT Hyderabad20 Aug 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…d in certain portions of the seized material while disregarding entries that clearly indicated suppressed turnover and cash receipts. Such selective reliance undermines the credibility of the appellant's submissions. As held in Common Cause v. Union of India (394 ITR 220), seized material must be evaluated holistically, and selective reliance by the assessee is impermissible. viii) The appellant argued that the additional income disclosed was voluntary and conditional and unsupported by the facts. The disclosure was made in response to incriminating evidence uncovered during the search, and the subsequent filing…

Skanda Infra Projects India Private Limited, Kurnool vs. ACIT, Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 514/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…f contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of other seized documents. In this connection, he invited to the material seized…

ACIT., Central Circle-2(3), Hyderabad vs. Skandhanshi Infra Projects India Pvt. Ltd., Bangalore

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 310/HYD/2025[2021-22]Status: DisposedITAT Hyderabad20 Aug 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…f contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of other seized documents. In this connection, he invited to the material seized…

ACIT., Central Circle-2(3), Hyderabad vs. Skandhanshi Infra Projects India Pvt. Ltd., Bangalore

In the result, all the appeals filed by the different Assessee’s are allowed

ITA 308/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

…f contents of the document, cannot be drawn. In this regard, he relied on the decisions of Hon’ble Supreme Court in the case of Central Bureau ofInvestigation vs., VC Shukla [1998] 3 SCC 410 (SC) and also in the case of Common Cause vs., Union of India [2017] 394 ITR 220 (SC). 15. Learned Counsel for the Assessee further referring to lose sheets found during the course of search submitted that, apart from the fact that, the seized loose sheet no.5 lacks evidentiary value, the same is also not reliable when considered in the company of other seized documents. In this connection, he invited to the material seized…

Assisstant Commissioner of Income Tax, Chennai vs. Bannariamman Educational Trust, Coimbatore

ITA 3357/CHNY/2024[2020]Status: DisposedITAT Chennai14 Aug 2025

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3310 To 3314/Chny/2024 िनधारणवष/Assessment Years: 2017-18 To 2021-22 M/S.Bannari Amman- Educational Trust, 1212, Trichy Road, Coimbatore-641 018. V. The Acit, Central Circle-3(2), Chennai. [Pan: Aaatb 1235 C] (अपीलाथ/Appellant) (यथ/Respondent) आयकर अपील सं./Ita Nos.3353 & 3354 To 3358/Chny/2024 िनधारणवष/Assessment Years: 2015-16 & 2017-18 To 2021-22 & Cross-Objection No.42/Chny/2025 (In Ita No.3353/Chny/2024) िनधारणवष/Assessment Year: 2015-16 The Acit, Central Circle-3(2), Chennai. V. M/S.Bannari Amman- Educational Trust, 1212, Trichy Road, Coimbatore-641 018. [Pan: Aaatb 1235 C] (अपीलाथ/Appellant) (यथ/Respondent/Cross Objector) Assessee By : Mr.Vikram Vijayaraghavan, Advocate (Virtual)/Ld.Ar Department By : Mr.Shiva Srinivasan, Cit/Dr सुनवाईकतारीख/Date Of Hearing : 27.06.2025 घोषणाकतारीख /Date Of Pronouncement : 14.08.2025

For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivasan, CIT/DR
Section 12ASection 132Section 133ASection 143(2)Section 153CSection 250

…Trust :: 33 :: held that, even then, independent evidence is necessary to establish the trustworthiness of those entries, which is a requirement to fasten the liability. The Hon'ble Supreme Court in case of Common Cause (A Registered Society) & Ors Vs. UOI (394 ITR 220) following the judgment rendered in case of V.C. Shukla (supra) explained that, ordinarily entries in loose papers/sheets are irrelevant and not admissible under Section 34 of the Evidence Act. It was held that, entries in books of account are not by themselves sufficient to charge any person with liability, the reason being that a man cannot be…