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

Issues it is cited on

Judgments citing Society v. UOI

Vishwas Sudhakar Chaknalwar, Nagpur vs. Assistant Commissioner of Income Tax, Centra Circle 2(1), Nagpur

In the result, appeal filed by the Revenue is dismissed

ITA 238/NAG/2022[2020-21]Status: DisposedITAT Nagpur09 Jun 2025AY 2020-21

Bench: Shri V. Durga Rao, Hon’Ble & Shri K.M. Roy, Hon’Ble Accountant, Member Vishwas Sudhakar Chaknalwar V. Acit – Central Circle – 2(1) 801,8Th Floor & 800 Sq.Ft Space On 8Th Floor Room No. 312, 3Rd Floor Royal Park, Ramdaspeth Aayakar Bhavan Nagpur - 440012 Telangkhedi Road, Civil Lines Nagpur – 440002 Pan – Abdpc0828J (Appellant) (Respondent) Acit – Central Circle – 2(1) V. Vishwas Sudhakar Chaknalwar 801,8Th Floor & 800 Sq.Ft Space On 8Th Floor Room No. 312, 3Rd Floor Royal Park, Ramdaspeth Aayakar Bhavan Nagpur – 440012 Telangkhedi Road, Civil Lines Nagpur – 440001 Pan – Abdpc0828J (Appellant) (Respondent)

Section 132Section 133ASection 139(4)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 69A

…R 71/91) and the two spiral pads (MR 69/91 and MR 70/91) are "books" within the meaning of section 34, but not the loose sheets of papers contained in the two files (Mrs 72/91 and 73/91).' 9.7. Also, Hon'ble Supreme Court in case of Common Cause v. UOI [2017] 394 ITR 220 (SC), wherein searches were conducted on the Birla and Sahara Group of Companies and incriminating material in form of random sheets and loose papers, computer prints, hard disk, pen drives etc. were found, held that noting on loose sheet/diary does carry any evidentiary value under the provision of section 34 of the Evidence Act. Relevant extrac…

Income-Tax Officer, Ward-1(2)(3), Ahmedabad vs. K. Mart, Prem Darwaja

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

ITA 1323/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad01 Apr 2025AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/Ita No.1323/Ahd/2024 निर्धारण वर्ष / Assessment Year : 2017-18 Income Tax Officer Ward-1(2)(3) Ahmedabad K. Mart 38, Teliya Mill Compound O/S. Prem Darwaja Ahmedabad – 380 002 बनाम / V/S. स्थायी लेखा सं./Pan: Aakfk 2520 R अपीलार्थी/ (Appellant) प्रत्यर्थी / (Respondent) Assessee By: Shri Mehul K. Patel, Ar Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख / Date Of Hearing : 26/03/2025 घोषणा की तारीख / Date Of Pronouncement: 01/04/2025 आदेश/Order Per Makarand V. Mahadeokar, Am: This Appeal Filed By The Revenue Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (Hereinafter Referred To As “Cit(A)"] Dated 27.05.2024 Passed For

For Appellant: Shri Mehul K. Patel, ARFor Respondent: Shri Rignesh Das, Sr.DR
Section 133ASection 142(1)Section 144Section 147Section 148Section 44ASection 69A

…see would need or receive a 3 ITA No.1323/Ahd/2024 The Income Tax Officer vs. K.Mart Asst. Year: 2017-18 cash loan of Rs.2.65 crores. The assessee further relied upon decisions of the Hon'ble Supreme Court in the case of Common Cause v. Union of India [(2017) 394 ITR 220 (SC)] and CBI v. V.C. Shukla [(1998) 3 SCC 410], to contend that documents found in possession of a third party are not admissible as evidence unless corroborated and unless opportunity of rebuttal or cross-examination is provided. In the appellate proceedings, the CIT(A) examined the submissions and the assessment order in detail. It was observe…

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Coimbatore

In the result, all the five appeals filed by the assessee are allowed

ITA 552/CHNY/2024[2018-19]Status: DisposedITAT Chennai11 Mar 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

…/17-18/A & iii)CBE/132/OA/17-18/A 1-6, cannot be regarded as ‘books of accounts’ or ‘documents’ seized in the course of search. We also refer to the judgement of the Hon’ble Supreme Court in the case of Common Cause (A Registered Society) Vs. Union of India (394 ITR 220) (SC), wherein the Hon’ble Apex Court reiterated the principles laid down by its earlier judgement in the case of CBI vs. V.C.Shukla & Ors. (supra). The relevant finding of the Hon’ble Supreme Court reads as follows:- ITA Nos.548 to 552//CHNY/2024 "278. With respect to the kind of materials which have been placed on record, this Court in V.C. Shu…

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Coimbatore

In the result, all the five appeals filed by the assessee are allowed

ITA 551/CHNY/2024[2017-18]Status: DisposedITAT Chennai11 Mar 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

…/17-18/A & iii)CBE/132/OA/17-18/A 1-6, cannot be regarded as ‘books of accounts’ or ‘documents’ seized in the course of search. We also refer to the judgement of the Hon’ble Supreme Court in the case of Common Cause (A Registered Society) Vs. Union of India (394 ITR 220) (SC), wherein the Hon’ble Apex Court reiterated the principles laid down by its earlier judgement in the case of CBI vs. V.C.Shukla & Ors. (supra). The relevant finding of the Hon’ble Supreme Court reads as follows:- ITA Nos.548 to 552//CHNY/2024 "278. With respect to the kind of materials which have been placed on record, this Court in V.C. Shu…

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Chennai

In the result, all the five appeals filed by the assessee are allowed

ITA 549/CHNY/2024[2015-16]Status: DisposedITAT Chennai11 Mar 2025AY 2015-16

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

…/17-18/A & iii)CBE/132/OA/17-18/A 1-6, cannot be regarded as ‘books of accounts’ or ‘documents’ seized in the course of search. We also refer to the judgement of the Hon’ble Supreme Court in the case of Common Cause (A Registered Society) Vs. Union of India (394 ITR 220) (SC), wherein the Hon’ble Apex Court reiterated the principles laid down by its earlier judgement in the case of CBI vs. V.C.Shukla & Ors. (supra). The relevant finding of the Hon’ble Supreme Court reads as follows:- ITA Nos.548 to 552//CHNY/2024 "278. With respect to the kind of materials which have been placed on record, this Court in V.C. Shu…

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Coimbatore

In the result, all the five appeals filed by the assessee are allowed

ITA 548/CHNY/2024[2014-15]Status: DisposedITAT Chennai11 Mar 2025AY 2014-15

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

…/17-18/A & iii)CBE/132/OA/17-18/A 1-6, cannot be regarded as ‘books of accounts’ or ‘documents’ seized in the course of search. We also refer to the judgement of the Hon’ble Supreme Court in the case of Common Cause (A Registered Society) Vs. Union of India (394 ITR 220) (SC), wherein the Hon’ble Apex Court reiterated the principles laid down by its earlier judgement in the case of CBI vs. V.C.Shukla & Ors. (supra). The relevant finding of the Hon’ble Supreme Court reads as follows:- ITA Nos.548 to 552//CHNY/2024 "278. With respect to the kind of materials which have been placed on record, this Court in V.C. Shu…