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 367,154 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

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

ITA 3355/CHNY/2024[2018]Status: DisposedITAT Chennai14 Aug 2025
For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivasan, CIT/DR
Section 12ASection 132Section 133ASection 143(2)Section 153CSection 250

…:: 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 canno…

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

ITA 3353/CHNY/2024[2015]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

…st :: 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 canno…

Bannariamman Educational Trust, Coimbatore vs. ACIT Central Circle 3(2), Chennai

ITA 3314/CHNY/2024[2021-22]Status: DisposedITAT Chennai14 Aug 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Jagadish

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

…:: 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 canno…

Bannariamman Educational Trust, Coimbatore vs. ACIT Central Circle 3(2), Chennai

ITA 3311/CHNY/2024[2018-19]Status: DisposedITAT Chennai14 Aug 2025AY 2018-19

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

…l 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…

DCIT Central Circle-2(2) Chennai, Chennai vs. Thangamani Perumal Gounder, Pallipalayam

In the result, both the appeals filed by the Revenue are dismissed

ITA 629/CHNY/2025[2016]Status: DisposedITAT Chennai04 Aug 2025

Bench: Shri George George Kand Ms. S. Padmavathyआयकरअपीलसं/.Ita Nos.:628 & 629/Chny/2025 िनधा"रणवष"/Assessment Years: 2015-16 & 2016-17 The Deputy Commissioner Of Thangamani Perumal Gounder, Income Tax, Vs. 5/6/183, Govindampalayam Central Circle - 2(2), Alampalayam, Pallipalayam 638 008. Chennai. [Pan: Abcpt-7700-K] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. E. Pavuna Sundari, Cit ""यथ" क" ओर से/Respondent By : Shri N. Arjun Raj, Advocate सुनवाई क" तारीख/Date Of Hearing : 23.07.2025 घोषणा क" तारीख/Date Of Pronouncement : 04.08.2025 आदेश /O R D E R Per George George K: These Two Appeals At The Instance Of The Revenue Are Directed Against Two Separate Orders Of The Commissioner Of Income Tax (Appeals) - 19, Chennai Both Dated 10.12.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2015-16 & 2016-17. 2. The Common Issue Involved In Both The Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. The Ita Nos.628 & 629/Chny/2025

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri N. Arjun Raj, Advocate
Section 132Section 132(4)Section 142(1)Section 143(2)Section 153CSection 250

…n Minister in the Government of Tamilnadu (clearly mentioned as 'Minister Industries', "M (Industries)", "Thangamani(M)", "M (I)"" Ind (M)") (iii) The decision of the Hon'ble Supreme Court in the case of Common Cause (A Registered Society) Vs. Union of India (394 ITR 220) and other judicial decision are distinguishable in the case of the assessee, for the simple reason that the evidences found were not simple loose sheets or arbitrary notings. The entries found in the seized materials were in the form of proper accounts, maintained systematically, on daily basis, with tick marks showing that the entries have been…

DCIT Central Circle-2(2) Chennai, Chennai vs. Thangamani Perumal Gounder, Pallipalayam

ITA 628/CHNY/2025[2015]Status: DisposedITAT Chennai04 Aug 2025

Bench: Shri George George K & Ms. S. Padmavathyआयकर अपील सं./Ita Nos.:628 & 629/Chny/2025 निर्धारण वर्ष/Assessment Years: 2015-16 & 2016-17 The Deputy Commissioner Of Income Tax, Central Circle - 2(2), Chennai. (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख/Date Of Hearing : घोषणा की तारीख/Date Of Pronouncement : Thangamani Perumal Gounder, Vs.5/6/183, Govindampalayam Alampalayam, Pallipalayam 638 008. [Pan: Abcpt-7700-K] (प्रत्यर्थी/Respondent) Ms. E. Pavuna Sundari, Cit Shri N. Arjun Raj, Advocate 23.07.2025 04.08.2025 आदेश / Order Per George George K: These Two Appeals At The Instance Of The Revenue Are Directed Against Two Separate Orders Of The Commissioner Of Income Tax (Appeals) - 19, Chennai Both Dated 10.12.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called 'The Act'). The Relevant

Section 132Section 132(4)Section 142(1)Section 143(2)Section 153CSection 250

…n Minister in the Government of Tamilnadu (clearly mentioned as 'Minister Industries', "M (Industries)", "Thangamani(M)", "M (I)'' Ind (M)") (iii) The decision of the Hon'ble Supreme Court in the case of Common Cause (A Registered Society) Vs. Union of India (394 ITR 220) and other judicial decision are distinguishable in the case of the assessee, for the simple reason that the evidences found were not simple loose sheets or arbitrary notings. The entries found in the seized materials were in the form of proper accounts, maintained systematically, on daily basis, with tick marks showing that the entries have been…

Dy. Commissioner of Income Tax, Central Circle 5(1), Mumbai. vs. Sarvapriya Leasing Pvt. Ltd., Mumbai

In the result, the appeal filed by the revenue bearing ITA No 3108/Mum/2023 is dismissed

ITA 3109/MUM/2023[2018-19]Status: DisposedITAT Mumbai23 Jul 2025AY 2018-19

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjee

Section 132Section 153CSection 250Section 69A

…ed to the assessee during the search action or his statement was recorded for such image. Thus, in absence of any corroborative evidence, we do not find any justification for making such addition. Hon'ble Supreme Court in Common Cause v. Union of India (2017) 394 ITR 220 SC also held that loose sheets of papers are wholly irrelevant as evidence being not admissible under section 34, so as to constitute evidence with respect to transaction mentioned therein being of no evidentiary value. Thus, we affirm the order of Id. CIT(A) on our aforesaid additional observation." Respectfully following the ratio laid down in…

Dy. Commissioner of Income Tax, Central Circle 5(1), Mumbai. vs. Sarvapriya Leasing Pvt. Ltd., Mumbai

In the result, the appeal filed by the revenue bearing ITA No 3108/Mum/2023 is dismissed

ITA 3108/MUM/2023[2019-20]Status: DisposedITAT Mumbai23 Jul 2025AY 2019-20

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeedeputy Commissioner Of Vs Saarrthi Reality & Infra Llp, 2Nd Floor, Geetai Sankul, Paud Road, Income-Tax, Central Circle 5(1), Mumbai Kothrud, Pune, Pin-411037 Room No. 1928, 19Th Floor, Air India Building, Nariman Point, Pan: Acmfs8187L Mumbai-400021 Appellant Respondent - A.Y. 2019-20 - A.Y. 2018-19

For Appellant: Shri Jaiprakash Bairagra & Ms. Rupa NandaFor Respondent: Shri Dr. Kishore Dhule – CIT DR
Section 132Section 153CSection 250Section 69A

…ed to the assessee during the search action or his statement was recorded for such image. Thus, in absence of any corroborative evidence, we do not find any justification for making such addition. Hon'ble Supreme Court in Common Cause v. Union of India (2017) 394 ITR 220 SC also held that loose sheets of papers are wholly irrelevant as evidence being not admissible 12 ITA 3106,3108 & 3109/Mum /2023 Saarrthi Reality and Infra LLP & Others under section 34, so as to constitute evidence with respect to transaction mentioned therein being of no evidentiary value. Thus, we affirm the order of ld. CIT(A) on our afores…

Dy. Commissioner of Income-Tax, Central Circle-5(1), Mumbai. vs. Saarrthi Realty and Infra Limited Liability Partnership, Mumbai

In the result, the appeal filed by the revenue bearing ITA No 3108/Mum/2023 is dismissed

ITA 3106/MUM/2023[2019-20]Status: DisposedITAT Mumbai23 Jul 2025AY 2019-20

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeedeputy Commissioner Of Vs Saarrthi Reality & Infra Llp, 2Nd Floor, Geetai Sankul, Paud Road, Income-Tax, Central Circle 5(1), Mumbai Kothrud, Pune, Pin-411037 Room No. 1928, 19Th Floor, Air India Building, Nariman Point, Pan: Acmfs8187L Mumbai-400021 Appellant Respondent - A.Y. 2019-20 - A.Y. 2018-19

For Appellant: Shri Jaiprakash Bairagra & Ms. Rupa NandaFor Respondent: Shri Dr. Kishore Dhule – CIT DR
Section 132Section 153CSection 250Section 69A

…ed to the assessee during the search action or his statement was recorded for such image. Thus, in absence of any corroborative evidence, we do not find any justification for making such addition. Hon'ble Supreme Court in Common Cause v. Union of India (2017) 394 ITR 220 SC also held that loose sheets of papers are wholly irrelevant as evidence being not admissible 12 ITA 3106,3108 & 3109/Mum /2023 Saarrthi Reality and Infra LLP & Others under section 34, so as to constitute evidence with respect to transaction mentioned therein being of no evidentiary value. Thus, we affirm the order of ld. CIT(A) on our afores…

Virendra Prakash Sharma, Jaipur vs. DCIT Circle (Intl Tax), Jaipur

In the result, the appeal of the assessee is allowed

ITA 286/JPR/2025[2020-21]Status: DisposedITAT Jaipur16 Jul 2025AY 2020-21
For Appellant: Shri Rajeev Sogani, CA &For Respondent: Smt. Runi Pal, CIT (Th. VC)
Section 132Section 143(3)Section 144C(13)Section 144C(5)Section 153CSection 69

…value" and "corroborative evidence", the Court on the facts came to the conclusion that entries made in Jain Hawala Diaries though admissible u/s.34, but truthfulness, thereof, was not proved by any independent evidence. 1.9.v In Common Causes v. UOI [2017] 394 ITR 220 (SC), it was held that Entries in loose papers/ sheets are irrelevant and inadmissible as evidence. Such loose papers are not “books of account” and the entries therein are not sufficient to charge a person with liability. Even if books of account are regularly kept in the ordinary course of business, the entries therein shall not alone be suffic…

Ram Mohana Reddy Baddigam, Hyderabad vs. DCIT., Central Circle-3(4), Hyderabad

Accordingly, the grounds raised by the assessee are allowed

ITA 422/HYD/2025[2019-20]Status: DisposedITAT Hyderabad30 Jun 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA P. Murali Mohan RaoFor Respondent: Shri Gurpreet Singh, Sr. AR
Section 153CSection 69A

…h Bench in the case of DSG Papers (P.) Ltd., vs., ACIT/Dy.CIT (supra). The Learned Counsel for the Assessee further drew the attention of the Bench decision of Hon’ble Supreme Court in the case of Common Cause (A Registered Society) vs., Union of India [2017] 394 ITR 220 (SC) on identical circumstances wherein the Hon’ble Apex Court held that, investigation could not have been directed on the basis of legally inadmissible evidence in form of ‘loose papers’ and make addition u/sec.69A of the Act. Learned Counsel for the Assessee further relied on the following decisions in support of the above contentions : 15 IT…

Ram Mohana Reddy Baddigam, Hyderabad vs. DCIT., Central Circle-3(4), Hyderabad

Accordingly, the grounds raised by the assessee are allowed

ITA 421/HYD/2025[2018-19]Status: DisposedITAT Hyderabad30 Jun 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA P. Murali Mohan RaoFor Respondent: Shri Gurpreet Singh, Sr. AR
Section 153CSection 69A

…h Bench in the case of DSG Papers (P.) Ltd., vs., ACIT/Dy.CIT (supra). The Learned Counsel for the Assessee further drew the attention of the Bench decision of Hon’ble Supreme Court in the case of Common Cause (A Registered Society) vs., Union of India [2017] 394 ITR 220 (SC) on identical circumstances wherein the Hon’ble Apex Court held that, investigation could not have been directed on the basis of legally inadmissible evidence in form of ‘loose papers’ and make addition u/sec.69A of the Act. Learned Counsel for the Assessee further relied on the following decisions in support of the above contentions : 15 IT…

Ram Mohana Reddy Baddigam, Guntur vs. DCIT., Central Circle-3(4), Hyderabad

Accordingly, the grounds raised by the assessee are allowed

ITA 420/HYD/2025[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA P. Murali Mohan RaoFor Respondent: Shri Gurpreet Singh, Sr. AR
Section 153CSection 69A

…h Bench in the case of DSG Papers (P.) Ltd., vs., ACIT/Dy.CIT (supra). The Learned Counsel for the Assessee further drew the attention of the Bench decision of Hon’ble Supreme Court in the case of Common Cause (A Registered Society) vs., Union of India [2017] 394 ITR 220 (SC) on identical circumstances wherein the Hon’ble Apex Court held that, investigation could not have been directed on the basis of legally inadmissible evidence in form of ‘loose papers’ and make addition u/sec.69A of the Act. Learned Counsel for the Assessee further relied on the following decisions in support of the above contentions : 15 IT…

Ram Mohana Reddy Baddigam, Guntur vs. DCIT., Central Circle-3(4), Hyderabad

Accordingly, the grounds raised by the assessee are allowed

ITA 419/HYD/2025[2016-17]Status: DisposedITAT Hyderabad30 Jun 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA P. Murali Mohan RaoFor Respondent: Shri Gurpreet Singh, Sr. AR
Section 153CSection 69A

…h Bench in the case of DSG Papers (P.) Ltd., vs., ACIT/Dy.CIT (supra). The Learned Counsel for the Assessee further drew the attention of the Bench decision of Hon’ble Supreme Court in the case of Common Cause (A Registered Society) vs., Union of India [2017] 394 ITR 220 (SC) on identical circumstances wherein the Hon’ble Apex Court held that, investigation could not have been directed on the basis of legally inadmissible evidence in form of ‘loose papers’ and make addition u/sec.69A of the Act. Learned Counsel for the Assessee further relied on the following decisions in support of the above contentions : 15 IT…

Assistant Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Kasthoori Raja Dhanush, Chennai

In the result, all the appeals of the Revenue and Cross-Objections

ITA 3192/CHNY/2024[2020-21]Status: DisposedITAT Chennai30 Jun 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3188 To 3192/Chny/2024 निर्धारणवर्ष/Assessment Years: 2015-16, 2016-17, 2017-18, 2019-20 & 2020-21 & Cross-Objection Nos.22 To 26/Chny/2025 निर्धारणवर्ष/Assessment Years: 2015-16, 2016-17, 2017-18, 2019-20 & 2020-21 The Acit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement V. : : : : Kasthoori Raja Dhanush, Old No.16/5, New No.33/5, Rajamannar Street, Thyagaraya Nagar, Chennai-600 017. [Pan: Actpv 0618 E] (प्रत्यर्थी/Respondent/Cross- Objector) Mrs. Sheila Parthasarthy, Cit Mr. N. Arjun Raj, Advocate 28.04.2025 30.06.2025 आदेश / Order Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals) 19, Chennai (Hereinafter Referred To As `Ld.Cit(A) `) All Dated 17.10.2024 For The

Section 132Section 153ASection 15ASection 271D

…is of the above, the decision relied on by the assessee in the case cited above is not applicable to the facts and circumstances of his case. (vi) The decision of the Hon'ble Supreme Court in the case of Common Cause (A Registered Society) Vs. Union of India (394 ITR 220) is distinguishable in the case of the assessee, for the simple reason that the evidences found were not simple loose sheets or arbitrary notings. The entries found in the seized materials were in the form of proper accounts, maintained systematically, on daily basis. The entries have been logically explained by the author of the entries, during…

Assistant Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Kasthoori Raja Dhanush, Chennai

ITA 3191/CHNY/2024[2019-20]Status: DisposedITAT Chennai30 Jun 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3188 To 3192/Chny/2024 निर्धारणवर्ष/Assessment Years: 2015-16, 2016-17, 2017-18, 2019-20 & 2020-21 & Cross-Objection Nos.22 To 26/Chny/2025 निर्धारणवर्ष/Assessment Years: 2015-16, 2016-17, 2017-18, 2019-20 & 2020-21 The Acit, Central Circle-2(2), Chennai. V. (अपीलार्थी/Appellant) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement : Mrs. Sheila Parthasarthy, Cit : Mr. N. Arjun Raj, Advocate : 28.04.2025 : 30.06.2025 Kasthoori Raja Dhanush, Old No.16/5, New No.33/5, Rajamannar Street, Thyagaraya Nagar, Chennai-600 017. [Pan: Actpv 0618 E] (प्रत्यर्थी/Respondent/Cross- Objector) आदेश / Order Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals) - 19, Chennai (Hereinafter Referred To As `Ld.Cit(A) `) All Dated 17.10.2024 For The

Section 132Section 153ASection 15ASection 271D

…is of the above, the decision relied on by the assessee in the case cited above is not applicable to the facts and circumstances of his case. (vi) The decision of the Hon'ble Supreme Court in the case of Common Cause (A Registered Society) Vs. Union of India (394 ITR 220) is distinguishable in the case of the assessee, for the simple reason that the evidences found were not simple loose sheets or arbitrary notings. The entries found in the seized materials were in the form of proper accounts, maintained systematically, on daily basis. The entries have been logically explained by the author of the entries, during…

Assistant Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Kasthoori Raja Dhanush, Chennai

In the result, all the appeals of the Revenue and In the result, all the appeals of the Revenue and Cross

ITA 3190/CHNY/2024[2017-18]Status: DisposedITAT Chennai30 Jun 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Mrs. Sheila Parthasarthy, CIT
Section 132Section 15A

…e. (vi) The decision of the Hon'ble Supreme Court in the case of Common (vi) The decision of the Hon'ble Supreme Court in the case of Common (vi) The decision of the Hon'ble Supreme Court in the case of Common Cause (A Registered Society) Vs. Union of India (394 ITR 220) is (A Registered Society) Vs. Union of India (394 ITR 220) is (A Registered Society) Vs. Union of India (394 ITR 220) is distinguishable in the case of the assessee, for the simple reason that distinguishable in the case of the assessee, for the simple reason that distinguishable in the case of the assessee, for the simple reason that the eviden…

Assistant Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Kasthoori Raja Dhanush, Chennai

In the result, all the appeals of the Revenue and In the result, all the appeals of the Revenue and Cross

ITA 3189/CHNY/2024[2016-17]Status: DisposedITAT Chennai30 Jun 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Mrs. Sheila Parthasarthy, CIT
Section 132Section 15A

…e. (vi) The decision of the Hon'ble Supreme Court in the case of Common (vi) The decision of the Hon'ble Supreme Court in the case of Common (vi) The decision of the Hon'ble Supreme Court in the case of Common Cause (A Registered Society) Vs. Union of India (394 ITR 220) is (A Registered Society) Vs. Union of India (394 ITR 220) is (A Registered Society) Vs. Union of India (394 ITR 220) is distinguishable in the case of the assessee, for the simple reason that distinguishable in the case of the assessee, for the simple reason that distinguishable in the case of the assessee, for the simple reason that the eviden…

Assistant Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Kasthoori Raja Dhanush, Chennai

In the result, all the appeals of the Revenue and In the result, all the appeals of the Revenue and Cross

ITA 3188/CHNY/2024[2015-16]Status: DisposedITAT Chennai30 Jun 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Mrs. Sheila Parthasarthy, CIT
Section 132Section 15A

…e. (vi) The decision of the Hon'ble Supreme Court in the case of Common (vi) The decision of the Hon'ble Supreme Court in the case of Common (vi) The decision of the Hon'ble Supreme Court in the case of Common Cause (A Registered Society) Vs. Union of India (394 ITR 220) is (A Registered Society) Vs. Union of India (394 ITR 220) is (A Registered Society) Vs. Union of India (394 ITR 220) is distinguishable in the case of the assessee, for the simple reason that distinguishable in the case of the assessee, for the simple reason that distinguishable in the case of the assessee, for the simple reason that the eviden…

Rishi Agarwal, Guwahati vs. ITO, Ward-2(2), Guwahati

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 266/GTY/2024[2021-22]Status: DisposedITAT Guwahati24 Jun 2025AY 2021-22

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 143(3)Section 250Section 69C

…teral entry in the books of account in the name of other person will not fasten liability against such other person unless the truthfulness of such entry is established. The Hon'ble Supreme Court in Common Cause (A Registered Society) v. Union of India (2017) 394 ITR 220 (SC) has quoted at page no. 226 from its own decision in the case of CBI v. V. C. Shukla (1998) 3 SCC 410 (SC) as under:- “It has further been laid down in V. C. Shukla (supra) as the value of entries in the books of account, that such statement shall not alone be sufficient evidence to charge any person with liability, even if they are relevant…