Sohan Lal Gupta v. CIT

33 ITR 786High Court1958#2035 most cited

What is Sohan Lal Gupta v. CIT authority for?

Tax authorities cannot reject an assessee's affidavit or a retraction of an admission of income without providing an opportunity to substantiate the claims or cross-examine the deponent. Simply lacking documentary evidence is not sufficient ground for outright rejection of such evidence.

56

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2026.

Also referred to as

Sohan Lal Gupta v. CIT · 33 ITR 786 · affidavit rejection · retracted statement section 132(4) · opportunity to substantiate · cross-examination · evidentiary value affidavit · natural justice assessment · Section 131 evidence · survey statement retraction · assessee's statement

Sections most often in play

Section 143(3)Section 133ASection 147Section 148Section 131Section 132(4)Section 142(1)Section 143(2)

Issues it is cited on

peak credit theorysection 140asection 271(l)surrender of incomesection 151(1)section 151(2)survey under section 133asection 282section 271(l)(c)section 271fsection 292cnon-speaking order

Judgments citing Sohan Lal Gupta v. CIT

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, PATIALA vs. SATGURU FOUNDATION(REGD), MUKTSAR

In the result, all the four appeals are dismissed

ITA 494/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh15 Jan 2026AY 2013-14

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 491, 493 & 494/Chd/2023 "नधा"रण वष" / A.Y. : 2010-11, 2012-13 & 2013-14 The Acit, M/S Satguru Foundation (Regd.), Central Circle, Vs Desh Bhagat College & Hospital, Patiala. Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 492/Chd/2023 "नधा"रण वष" / A.Y. : 2011-12 The Acit, M/S Satguru Foundation (Regd.), Patiala. Vs Desh Bhagat College & Hospital, Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Vineet Krishan, AdvocateFor Respondent: Shri Abhishekl Pal Garg, CIT DR
Section 147

…etter was filed before the investigation officer, however, the department has ignored retraction filed by the assessee. It is well established principle of law by the decision of the Hon’ble Allahabad High Court in the case of L. Sohan Lal Gupta Vs CIT (1958) 33 ITR 786 that an affidavit filed by the assessee cannot be discarded, unless an opportunity is given to the assessee to substantiate its case. In this case, the Assessing Officer as well as learned CIT(A) has discarded retraction letter filed by the assessee only on the basis of admission of undisclosed income recorded in the statement u/s.132(4) of the In…

ASSTT. COMMISSIONER OF INCOME TAX, PATIALA vs. SATGURU FOUNDATION(REGD.), MUKTSAR

In the result, all the four appeals are dismissed

ITA 493/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh15 Jan 2026AY 2012-13

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 491, 493 & 494/Chd/2023 "नधा"रण वष" / A.Y. : 2010-11, 2012-13 & 2013-14 The Acit, M/S Satguru Foundation (Regd.), Central Circle, Vs Desh Bhagat College & Hospital, Patiala. Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 492/Chd/2023 "नधा"रण वष" / A.Y. : 2011-12 The Acit, M/S Satguru Foundation (Regd.), Patiala. Vs Desh Bhagat College & Hospital, Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Vineet Krishan, AdvocateFor Respondent: Shri Abhishekl Pal Garg, CIT DR
Section 147

…etter was filed before the investigation officer, however, the department has ignored retraction filed by the assessee. It is well established principle of law by the decision of the Hon’ble Allahabad High Court in the case of L. Sohan Lal Gupta Vs CIT (1958) 33 ITR 786 that an affidavit filed by the assessee cannot be discarded, unless an opportunity is given to the assessee to substantiate its case. In this case, the Assessing Officer as well as learned CIT(A) has discarded retraction letter filed by the assessee only on the basis of admission of undisclosed income recorded in the statement u/s.132(4) of the In…

ASSISTANT COMMISSIONER OF INCOME TAX, PATIALA vs. SATGURU FOUNDATION(REGD), MUKTSAR

In the result, all the four appeals are dismissed

ITA 492/CHANDI/2023[2011-12]Status: DisposedITAT Chandigarh15 Jan 2026AY 2011-12

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 491, 493 & 494/Chd/2023 "नधा"रण वष" / A.Y. : 2010-11, 2012-13 & 2013-14 The Acit, M/S Satguru Foundation (Regd.), Central Circle, Vs Desh Bhagat College & Hospital, Patiala. Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 492/Chd/2023 "नधा"रण वष" / A.Y. : 2011-12 The Acit, M/S Satguru Foundation (Regd.), Patiala. Vs Desh Bhagat College & Hospital, Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Vineet Krishan, AdvocateFor Respondent: Shri Abhishekl Pal Garg, CIT DR
Section 147

…etter was filed before the investigation officer, however, the department has ignored retraction filed by the assessee. It is well established principle of law by the decision of the Hon’ble Allahabad High Court in the case of L. Sohan Lal Gupta Vs CIT (1958) 33 ITR 786 that an affidavit filed by the assessee cannot be discarded, unless an opportunity is given to the assessee to substantiate its case. In this case, the Assessing Officer as well as learned CIT(A) has discarded retraction letter filed by the assessee only on the basis of admission of undisclosed income recorded in the statement u/s.132(4) of the In…

ASSISSTANT COMMISSIONER OF INCOME TAX, PATIALA vs. SATGURU FOUNDATION(REGD)., MUKTSAR

In the result, all the four appeals are dismissed

ITA 491/CHANDI/2023[2010-11]Status: DisposedITAT Chandigarh15 Jan 2026AY 2010-11

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 491, 493 & 494/Chd/2023 "नधा"रण वष" / A.Y. : 2010-11, 2012-13 & 2013-14 The Acit, M/S Satguru Foundation (Regd.), Central Circle, Vs Desh Bhagat College & Hospital, Patiala. Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 492/Chd/2023 "नधा"रण वष" / A.Y. : 2011-12 The Acit, M/S Satguru Foundation (Regd.), Patiala. Vs Desh Bhagat College & Hospital, Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Vineet Krishan, AdvocateFor Respondent: Shri Abhishekl Pal Garg, CIT DR
Section 147

…etter was filed before the investigation officer, however, the department has ignored retraction filed by the assessee. It is well established principle of law by the decision of the Hon’ble Allahabad High Court in the case of L. Sohan Lal Gupta Vs CIT (1958) 33 ITR 786 that an affidavit filed by the assessee cannot be discarded, unless an opportunity is given to the assessee to substantiate its case. In this case, the Assessing Officer as well as learned CIT(A) has discarded retraction letter filed by the assessee only on the basis of admission of undisclosed income recorded in the statement u/s.132(4) of the In…

SALEK CHAND SAINI,MEERUT vs. ITO, WARD-2(3), MEERUT

In the result, appeal of assessee in ITA No

ITA 2545/DEL/2024[2014-15]Status: DisposedITAT Delhi09 Dec 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Rohit Aggarwal, CAFor Respondent: Shri Manish Gupta, Sr. DR
Section 143(2)Section 143(3)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘G’ BENCH, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 2545/DEL/2024 [A.Y 2014-15] Shri Salek Chand Saini Vs. The I.T.O. H. No. 198, Mohalla Raza Darwaza Ward - 2(3) Meerut Road, Parikshitgarh, Meerut Meerut PAN: PCECPS 3545 A (Appellant) (Respondent) Assessee By : Shri Rohit Aggarwal, CA Department By : Shri Manish Gupta, Sr. DR Date of Hearing : 04.11.2025 Date of Pronouncement : 04.11.2025 ORDER PER NAVEEN CHANDRA, AM :- This appeal by the assessee is directed against the order of the ld…

RAJESH KUMAR POONIA,JHUNJHUNU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- JHUNJHUNU, JHUNJHUNU, JHUNJHUNU

In the result, both the appeals of the assessee are allowed

ITA 623/JPR/2024[2016-17]Status: DisposedITAT Jaipur06 May 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Vedant Agrawal, Adv. (V.C)For Respondent: Sh. Anup Singh, Add. CIT-DR
Section 131Section 133ASection 142(1)Section 143(2)Section 143(3)Section 145(3)

…he statements made by them in their affidavits. Under these circumstances it was not open to the Revenue to challenge the correctness of the cash book entries or the statements made by those deponents in their affidavits". (ii) L. Sohanlal Gupta v. CIT [1958] 33 ITR 786 (All.) – The Tribunal was not entitled to reject the Affidavit filed by the assessee on the mere ground that he had produced no documentary evidence; if it was not accepted as sufficient proof, the assessee should have been called upon to produce documentary evidence or he should have been cross examined to find out how far his assertions in the a…

RAJESH KUMAR POONIA,JHUNJHUNU vs. ASSISTANT COMMISSIONER OF INCOME TAX, JHUNJHUNU

In the result, both the appeals of the assessee are allowed

ITA 611/JPR/2024[2017-18]Status: DisposedITAT Jaipur06 May 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Vedant Agrawal, Adv. (V.C)For Respondent: Sh. Anup Singh, Add. CIT-DR
Section 131Section 133ASection 142(1)Section 143(2)Section 143(3)Section 145(3)

…he statements made by them in their affidavits. Under these circumstances it was not open to the Revenue to challenge the correctness of the cash book entries or the statements made by those deponents in their affidavits". (ii) L. Sohanlal Gupta v. CIT [1958] 33 ITR 786 (All.) – The Tribunal was not entitled to reject the Affidavit filed by the assessee on the mere ground that he had produced no documentary evidence; if it was not accepted as sufficient proof, the assessee should have been called upon to produce documentary evidence or he should have been cross examined to find out how far his assertions in the a…

DCIT, JAIPUR vs. AMRAPALI JEWELS PVT. LTD. , JAIPUR

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

ITA 740/JPR/2024[2021]Status: DisposedITAT Jaipur19 Feb 2025

Bench: Him.

For Appellant: Sh. Sanjay Jhanwar, Sr. AdvFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 143(3)Section 145(3)Section 153DSection 251Section 69B

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, vk;dj vihy la-@ITA No. 750/JP/2024 fu/kZkj.k o"kZ@Assessment Year : 2021-22 cuke Amrapali Jewels Pvt. Ltd. ACIT, Vs. K-14B Ashok Marg, C-Scheme, Central Circle-01, Jaipur Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AABCA 3277 F vihykFkhZ@Appellant izR;FkhZ@Respondent vk;dj vihy la-@ITA No. 740/JP/2024 fu/kZkj.k o"kZ@Assessment Years : 2021-22 cuke DCIT A…

DCIT, CENTRAL CIRCLE -III, LUDHIANA vs. SH. PURAN CHAND, LUDHIANA

In the result, we upheld the findings of the ld CIT(A) and the grounds of appeal taken by the Revenue are dismissed

ITA 559/CHANDI/2022[2018-19]Status: DisposedITAT Chandigarh31 Jan 2024AY 2018-19

Bench: Or At The Time Of Hearing Of The Appeal.

For Appellant: Shri Pankaj Bhalla, C.AFor Respondent: Shri Dharam Vir, JCIT, Sr. DR
Section 292CSection 69A

…34 so as to constitute evidence with respect to the transactions mentioned therein being of no evidentiary value I he entire prosecution based upon such entries which led to the investigation was quashed by this Court [Para 20] Sohan Lai Gupta vs. CIT (1958) 33 ITR 786 at 1 791 (All) Shri G. S. Pathak contended rightly before us that the Tribunal was not entitled to reject the affidavit on this point on such a ground After the assessee had filed the affidavit, he was neither cross-examined on that point nor was he called upon to produce any documentary evidence Consequently, the assessee was entitled to assume…

RAM DEV CHANDELWAL,S/O SHRI HEERA LAL CHANDELWAL vs. INCOME TAX OFFICER, WARD - BUNDI

In the result, appeal of the assessee is allowed

ITA 585/JPR/2023[2017-18]Status: DisposedITAT Jaipur28 Nov 2023AY 2017-18

Bench: Or At The Time Of Hearing.”

For Appellant: Shri S.L. Poddar (Adv.)For Respondent: Smt. Monisha Choudhary (Addl.CIT) a
Section 143(3)Section 250Section 68

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR Mk0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. No. 585/JPR/2023 fu/kZkj.k o"kZ@Assessment Years : 2017-18 cuke Ram Dev Chandel Income Tax Officer, S/o Shri Neera Lal Chandel Vs. Ward, Bundi Village Karwar, Tehsil- Nainwan, Bundi. LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AGHPC 6443 Q vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Shri S.L. Poddar (Adv.…

SH. ARASHPREET SINGH. S/O.LATE.SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX .CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 64/ASR/2019[2014-15]Status: DisposedITAT Amritsar25 May 2023AY 2014-15

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

…etter was filed before the investigation officer, however, the department has ignored retraction filed by the assessee. It is well established principle of law by the decision of the Hon’ble Allahabad High Court in the case of L. Sohan Lal Gupta Vs CIT (1958) 33 ITR 786 that an affidavit filed by the assessee cannot be discarded, unless an opportunity is given to the assessee to substantiate its case. In this case, the Assessing Officer as well as learned CIT(A) has discarded retraction letter filed by the assessee only on the basis of admission of undisclosed income recorded in the statement u/s.132(4) of the In…

SH. ARASHPREET SINGH S/O. LATE SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 63/ASR/2019[2013-14]Status: DisposedITAT Amritsar25 May 2023AY 2013-14

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

…etter was filed before the investigation officer, however, the department has ignored retraction filed by the assessee. It is well established principle of law by the decision of the Hon’ble Allahabad High Court in the case of L. Sohan Lal Gupta Vs CIT (1958) 33 ITR 786 that an affidavit filed by the assessee cannot be discarded, unless an opportunity is given to the assessee to substantiate its case. In this case, the Assessing Officer as well as learned CIT(A) has discarded retraction letter filed by the assessee only on the basis of admission of undisclosed income recorded in the statement u/s.132(4) of the In…

SH. ARASHPREET SINGH S/O. LATE SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CERCLE- II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 62/ASR/2019[2012-13]Status: DisposedITAT Amritsar25 May 2023AY 2012-13

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

…etter was filed before the investigation officer, however, the department has ignored retraction filed by the assessee. It is well established principle of law by the decision of the Hon’ble Allahabad High Court in the case of L. Sohan Lal Gupta Vs CIT (1958) 33 ITR 786 that an affidavit filed by the assessee cannot be discarded, unless an opportunity is given to the assessee to substantiate its case. In this case, the Assessing Officer as well as learned CIT(A) has discarded retraction letter filed by the assessee only on the basis of admission of undisclosed income recorded in the statement u/s.132(4) of the In…

SH. ARSPREET SINGH . S/O. LATE. SH. GURMAIL SINGH ,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE .II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 61/ASR/2019[2011-12]Status: DisposedITAT Amritsar25 May 2023AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

…etter was filed before the investigation officer, however, the department has ignored retraction filed by the assessee. It is well established principle of law by the decision of the Hon’ble Allahabad High Court in the case of L. Sohan Lal Gupta Vs CIT (1958) 33 ITR 786 that an affidavit filed by the assessee cannot be discarded, unless an opportunity is given to the assessee to substantiate its case. In this case, the Assessing Officer as well as learned CIT(A) has discarded retraction letter filed by the assessee only on the basis of admission of undisclosed income recorded in the statement u/s.132(4) of the In…

SH. ARASHPREET SINGH S/O LATE SH. GURMAIL SINGH,SHRI MUKATSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 60/ASR/2019[2010-11]Status: DisposedITAT Amritsar25 May 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

…etter was filed before the investigation officer, however, the department has ignored retraction filed by the assessee. It is well established principle of law by the decision of the Hon’ble Allahabad High Court in the case of L. Sohan Lal Gupta Vs CIT (1958) 33 ITR 786 that an affidavit filed by the assessee cannot be discarded, unless an opportunity is given to the assessee to substantiate its case. In this case, the Assessing Officer as well as learned CIT(A) has discarded retraction letter filed by the assessee only on the basis of admission of undisclosed income recorded in the statement u/s.132(4) of the In…

LATE. SH. GURMAIL SINGH S/O. SH. LAL SINGH,SRI MUKATSAR vs. DY.COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 59/ASR/2019[2014-15]Status: DisposedITAT Amritsar25 May 2023AY 2014-15

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

…etter was filed before the investigation officer, however, the department has ignored retraction filed by the assessee. It is well established principle of law by the decision of the Hon’ble Allahabad High Court in the case of L. Sohan Lal Gupta Vs CIT (1958) 33 ITR 786 that an affidavit filed by the assessee cannot be discarded, unless an opportunity is given to the assessee to substantiate its case. In this case, the Assessing Officer as well as learned CIT(A) has discarded retraction letter filed by the assessee only on the basis of admission of undisclosed income recorded in the statement u/s.132(4) of the In…

LATE. SH. GURMAIL. SINGH. S/O. SH. LAL SINGH,SRI MUKATSAR vs. DY.COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 58/ASR/2019[2013-14]Status: DisposedITAT Amritsar25 May 2023AY 2013-14

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

…etter was filed before the investigation officer, however, the department has ignored retraction filed by the assessee. It is well established principle of law by the decision of the Hon’ble Allahabad High Court in the case of L. Sohan Lal Gupta Vs CIT (1958) 33 ITR 786 that an affidavit filed by the assessee cannot be discarded, unless an opportunity is given to the assessee to substantiate its case. In this case, the Assessing Officer as well as learned CIT(A) has discarded retraction letter filed by the assessee only on the basis of admission of undisclosed income recorded in the statement u/s.132(4) of the In…

LATE. SH. GURMAIL SINGH.S/O. LATE SH. LAL SINGH,SRI MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 57/ASR/2019[2012-13]Status: DisposedITAT Amritsar25 May 2023AY 2012-13

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

…etter was filed before the investigation officer, however, the department has ignored retraction filed by the assessee. It is well established principle of law by the decision of the Hon’ble Allahabad High Court in the case of L. Sohan Lal Gupta Vs CIT (1958) 33 ITR 786 that an affidavit filed by the assessee cannot be discarded, unless an opportunity is given to the assessee to substantiate its case. In this case, the Assessing Officer as well as learned CIT(A) has discarded retraction letter filed by the assessee only on the basis of admission of undisclosed income recorded in the statement u/s.132(4) of the In…

LATE. SH. GURMAIL. SINGH S/O. SH. LAL SINGH,SHRI MUKAT SAR vs. DY. COMMISSIONER OF 9INCOME TAX. CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 56/ASR/2019[2011-12]Status: DisposedITAT Amritsar25 May 2023AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

…etter was filed before the investigation officer, however, the department has ignored retraction filed by the assessee. It is well established principle of law by the decision of the Hon’ble Allahabad High Court in the case of L. Sohan Lal Gupta Vs CIT (1958) 33 ITR 786 that an affidavit filed by the assessee cannot be discarded, unless an opportunity is given to the assessee to substantiate its case. In this case, the Assessing Officer as well as learned CIT(A) has discarded retraction letter filed by the assessee only on the basis of admission of undisclosed income recorded in the statement u/s.132(4) of the In…

LATE. SH. GUMAIL SINGH . S/O. SH. LAL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

ITA 55/ASR/2019[2010-11]Status: DisposedITAT Amritsar25 May 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

…etter was filed before the investigation officer, however, the department has ignored retraction filed by the assessee. It is well established principle of law by the decision of the Hon’ble Allahabad High Court in the case of L. Sohan Lal Gupta Vs CIT (1958) 33 ITR 786 that an affidavit filed by the assessee cannot be discarded, unless an opportunity is given to the assessee to substantiate its case. In this case, the Assessing Officer as well as learned CIT(A) has discarded retraction letter filed by the assessee only on the basis of admission of undisclosed income recorded in the statement u/s.132(4) of the In…

Showing 1–20 of 56 · Page 1 of 3

Sohan Lal Gupta v. CIT (33 ITR 786) — Cited in 56 Judgments | BharatTax