Sumati Dayal v. CIT

214 ITR 801Supreme Court of India1995#12 most cited

What is Sumati Dayal v. CIT authority for?

The Revenue is entitled to look behind the apparent form of a transaction to discover its true nature, applying the test of human probabilities and surrounding circumstances. If transactions defy logic or are unnatural, they can be treated as bogus, even if supported by some documentation, especially in cases of cash credits or unexplained investments.

1,967

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2010 to 2026.

Also referred to as

Sumati Dayal v CIT · Section 68 · human probabilities · genuineness of transaction · true nature of transaction · accommodation entry · bogus capital gains · penny stock · look behind apparent form · preponderance of probability · colourable device · unexplained loans

Also reported as

80 Taxmann 89125 CTR 124

Sections most often in play

Section 68Section 143(3)Section 147Section 148Section 142(1)Section 115BBESection 69CSection 69A
Read the full judgment

Issues it is cited on

price riggingcolourable devicepreponderance of probabilitybogus ltcgpenny stocksection 10(38)entry operatoraddition under section 68addition u/s 68genuineness of the transactionaccommodation entryshare application money

Judgments citing Sumati Dayal v. CIT

Ns Healthcare Services Private Limited, Vijayawada vs. Assistant Commissioner of Income Tax, Central Circle, Vijayawada

In the results, appeals filed by the revenue in ITA Nos

ITA 147/VIZ/2025[2021-22]Status: DisposedITAT Visakhapatnam18 Jun 2025AY 2021-22

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

Section 133Section 142(1)Section 148Section 148A

…different from the present case and is not applicable to the facts of the present case. 23. The Ld. CIT(A) is not justified in allowing relief to the assessee company without applying the decision of Hon'ble Apex Court in the case of Sumati Dayal v CIT (1995) 214 ITR 801 (SC), wherein it was held that Surrounding circumstances and test of applying human probabilities "Though an apparent must be considered real until it was shown that there were reasons to believe that the apparent was not real in the case where a party relied on self-serving recitals in document, it was for that party to establish the truth of th…

Ns Healthcare Services Private Limited, Vijayawada vs. Assistant Commissioner of Income Tax, Central Circle, Vijayawada

In the results, appeals filed by the revenue in ITA Nos

ITA 146/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam18 Jun 2025AY 2020-21

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

Section 133Section 142(1)Section 148Section 148A

…different from the present case and is not applicable to the facts of the present case. 23. The Ld. CIT(A) is not justified in allowing relief to the assessee company without applying the decision of Hon'ble Apex Court in the case of Sumati Dayal v CIT (1995) 214 ITR 801 (SC), wherein it was held that Surrounding circumstances and test of applying human probabilities "Though an apparent must be considered real until it was shown that there were reasons to believe that the apparent was not real in the case where a party relied on self-serving recitals in document, it was for that party to establish the truth of th…

Ns Healthcare Services Private Limited, Vijayawada vs. Assistant Commissioner of Income Tax, Central Circle, Vijayawada

In the results, appeals filed by the revenue in ITA Nos

ITA 145/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam18 Jun 2025AY 2019-20

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

Section 133Section 142(1)Section 148Section 148A

…different from the present case and is not applicable to the facts of the present case. 23. The Ld. CIT(A) is not justified in allowing relief to the assessee company without applying the decision of Hon'ble Apex Court in the case of Sumati Dayal v CIT (1995) 214 ITR 801 (SC), wherein it was held that Surrounding circumstances and test of applying human probabilities "Though an apparent must be considered real until it was shown that there were reasons to believe that the apparent was not real in the case where a party relied on self-serving recitals in document, it was for that party to establish the truth of th…

ITO, Ward-5(1), Kolkata vs. M/S. Shivrashi Infraprojects Private Limited, Kolkata

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

ITA 2328/KOL/2024[2012-13]Status: DisposedITAT Kolkata18 Jun 2025AY 2012-13

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 250Section 68

…s. BST Infratech Ltd. in 161 taxmann.com 668 (Cal). iii) Pr.CIT (Central)-1, Kolkata vs NRA Iron & Steel Pvt. Ltd. (412 ITR 161) [2020] 117 taxmann.com 752 (SC). iv) Pr. CIT Vs. Swati Bajaj reported in 2022 SCC Online 1572 (Cal). v) Sumati Dayal v. CIT [1995] 214 ITR 801 (SC). vi) CIT Vs. Durga Prasad More 1973 CTR (SC) 500: [1971] 82 ITR 540 (SC). vii) CIT vs. Independent Media (P) Ltd. [2012] 25 taxmann.com 276 (Delhi). 5. The Ld. DR requested that the order of the Ld. CIT(A) may be set aside as no opportunity was provided to the Ld. AO and before the Ld. AO the assessee could not justify the receipt of high pr…

Assistant Commissioner of Income Tax- 4(1)(1), Mumbai vs. Ankur Agrawal, Mumbai

In the result, both the appeals filed by the Assessee are allowed

ITA 5179/MUM/2024[2012-13]Status: DisposedITAT Mumbai16 Jun 2025AY 2012-13

Bench: Shri Sandeep Gosain, () & Shri Prabhash Shankar, ()

Section 10(38)Section 250Section 68

…. At this juncture, it is submitted by ld Counsel that prices of shares are determined by the market forces and not solely on the basis of financial statements. 24. We also note that Assessing officer and CIT(A) has relied on the case of Sumati Dayal vs. CIT (214 ITR 801) (SC). We are of the view that said decision is not applicable to the assessee under consideration, as the assessee has successfully demonstrated with help of evidences on record to have made the transaction of purchase and sale of alleged shares. No single material was brought on record indicating name of any of the entry provider taking assesse…

Principal Commissioner of Income Tax 5 Kolkata vs. M/S B L Tak and Sons HUF

The appeal is allowed and the order passed by the learned Tribunal is set aside and the

ITAT/243/2024HC Calcutta09 Jun 2025

Bench: : The Hon'Ble The Chief Justice T.S Sivagnanam -A N D- Hon'Ble Justice Chaitali Chatterjee (Das) Date : 9Th June, 2025.

Section 143(3)Section 260ASection 69C

…by group of entry operators and shell entities. Thereafter the assessing officer has taken note of the various decisions, namely, CIT Vs. Durga Prasad More reported in (1971) 82 ITR 540(SC), Sumati Dayal Vs. Commissioner of Income Tax reported in (1995) 214 ITR 801 (SC), applied the test of human probabilities as propounded in the said decisions and then completed the assessment and has pointed out that before finalizing the assessment a final show cause notice was issued on 18.09.2021 for which the assessee submitted reply on 22.09.2021 and the said reply was also considered and the assessing officer h…

Gajendra Mohanty, Malkangiri vs. Income Tax Officer, Jeypore Ward, Jeypore

In the result, the appeal filed for AY 2017-18 is partly allowed and the appeal filed for AY 2018-19 is dismissed

ITA 161/CTK/2025[2018-19]Status: DisposedITAT Cuttack04 Jun 2025AY 2018-19

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 144Section 250Section 3Section 69A

…-remains unexplained. Therefore, the contention of the appellant that Ld. AO has erred in making above addition does not have any merit. 11.0 It is a well settled principle of law as declared by the Hon'ble Supreme Court in the case of Sumati Dayal Vs. CIT, (214 ITR 801) (SC) that the true nature of transaction have to be ascertained in the light of surrounding circumstances. It needs to be emphasized that a standard of proof beyond reasonable doubt has no applicability in the determination of matters under taxing statutes. In the present case, it is clear that apparent is not the real as evidenced from the obse…

Gajendra Mohanty, Malkangiri vs. Income Tax Officer, Jeypore Ward, Jeypore

In the result, the appeal filed for AY 2017-18 is partly allowed and the appeal filed for AY 2018-19 is dismissed

ITA 160/CTK/2025[2017-18]Status: DisposedITAT Cuttack04 Jun 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 144Section 250Section 3Section 69A

…-remains unexplained. Therefore, the contention of the appellant that Ld. AO has erred in making above addition does not have any merit. 11.0 It is a well settled principle of law as declared by the Hon'ble Supreme Court in the case of Sumati Dayal Vs. CIT, (214 ITR 801) (SC) that the true nature of transaction have to be ascertained in the light of surrounding circumstances. It needs to be emphasized that a standard of proof beyond reasonable doubt has no applicability in the determination of matters under taxing statutes. In the present case, it is clear that apparent is not the real as evidenced from the obse…

Shri Sanjaybhai Ramjibhai Patel, Bhavnagar vs. ITO, Ward-1(5), Bhavnagar

ITA 454/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad03 Jun 2025AY 2014-15

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita No. 452/Ahd/2018 "नधा"रण वष"/Asstt. Year: 2014-2015

For Appellant: Shri TusharHemani, Sr. Advocate with Shri Parimalsinh B ParmarFor Respondent: Shri B.P Srivastava, Sr. DR
Section 10(38)Section 143(1)Section 143(2)Section 271(1)Section 68

…आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण, अहमदाबाद "यायपीठ आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण अहमदाबाद "यायपीठ अहमदाबाद "यायपीठ , अहमदाबाद। अहमदाबाद "यायपीठ अहमदाबाद। अहमदाबाद। अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “ A ” BENCH, AHMEDABAD ] BEFORE MS SUCHITRA KAMBLE, JUDICIAL MEMBER And SHRI NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No. 452/AHD/2018 "नधा"रण वष"/Asstt. Year: 2014-2015 Shri JigneshRamjibhai Patel, The Income Tax Officer, Plot no.1182/A/1, बनामVs Ward 1(2), . Sir Pattani Road, Ahmedabad. Opp. State Bank of India, Ghogha Circle, Bhavnagar-364001. PAN: AJTPP4619C आयकर अपील स…

Smt. Shital Sanjaybhai Patel, Bhavnagar vs. ITO, Ward-1(5), Bhavnagar

ITA 453/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad03 Jun 2025AY 2014-15

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita No. 452/Ahd/2018 "नधा"रण वष"/Asstt. Year: 2014-2015

For Appellant: Shri TusharHemani, Sr. Advocate with Shri Parimalsinh B ParmarFor Respondent: Shri B.P Srivastava, Sr. DR
Section 10(38)Section 143(1)Section 143(2)Section 271(1)Section 68

…आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण, अहमदाबाद "यायपीठ आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण अहमदाबाद "यायपीठ अहमदाबाद "यायपीठ , अहमदाबाद। अहमदाबाद "यायपीठ अहमदाबाद। अहमदाबाद। अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “ A ” BENCH, AHMEDABAD ] BEFORE MS SUCHITRA KAMBLE, JUDICIAL MEMBER And SHRI NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No. 452/AHD/2018 "नधा"रण वष"/Asstt. Year: 2014-2015 Shri JigneshRamjibhai Patel, The Income Tax Officer, Plot no.1182/A/1, बनामVs Ward 1(2), . Sir Pattani Road, Ahmedabad. Opp. State Bank of India, Ghogha Circle, Bhavnagar-364001. PAN: AJTPP4619C आयकर अपील स…

Shri Jignesh Ramjibhai Patel, Bhavnagar vs. ITO, Ward-1(2), Bhavnagar

ITA 452/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad03 Jun 2025AY 2014-15

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita No. 452/Ahd/2018 "नधा"रण वष"/Asstt. Year: 2014-2015

For Appellant: Shri TusharHemani, Sr. Advocate with Shri Parimalsinh B ParmarFor Respondent: Shri B.P Srivastava, Sr. DR
Section 10(38)Section 143(1)Section 143(2)Section 271(1)Section 68

…आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण, अहमदाबाद "यायपीठ आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण अहमदाबाद "यायपीठ अहमदाबाद "यायपीठ , अहमदाबाद। अहमदाबाद "यायपीठ अहमदाबाद। अहमदाबाद। अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “ A ” BENCH, AHMEDABAD ] BEFORE MS SUCHITRA KAMBLE, JUDICIAL MEMBER And SHRI NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No. 452/AHD/2018 "नधा"रण वष"/Asstt. Year: 2014-2015 Shri JigneshRamjibhai Patel, The Income Tax Officer, Plot no.1182/A/1, बनामVs Ward 1(2), . Sir Pattani Road, Ahmedabad. Opp. State Bank of India, Ghogha Circle, Bhavnagar-364001. PAN: AJTPP4619C आयकर अपील स…

Navansh Vinimay Pvt. Ltd., Kolkata vs. I.T.O., Ward - 8(2), Kolkata

In the result, the appeal of the assessee is dismissed

ITA 724/KOL/2022[2012-2013]Status: DisposedITAT Kolkata30 May 2025AY 2012-2013

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 142(1)Section 143Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250

…e reliability of the evidence placed before a court or tribunal. Therefore, the courts and Tribunals have to judge the evidence before them by applying the test of human probabilities". Similarly, in a later decision in the case of Sumati Dayal v. CIT [(1995) 214 ITR 801 (SC)], Hon'ble Supreme Court rejected the theory that it is for alleger to prove that the apparent and not real, and observed that, "This, in our opinion, is a superficial approach to the problem. The matter has to be considered in the light of human probabilities..... Similarly the observation that if it is alleged that these tickets. were obtai…

Income Tax Officer Ward Hingoli, Ward Hingoli (Camp at Parbhani) vs. Vishwas Agro Product Pvt Ltd, Parbhani

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

ITA 1566/PUN/2024[2017-18]Status: DisposedITAT Pune29 May 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

For Appellant: Shri Govind PrasadFor Respondent: Shri Milind Debaje – JCIT (Virtual)
Section 143(2)

…ed funds in the disguise of trade advances. Rejecting the various explanations given by the assessee and relying on the decisions of the Hon'ble Supreme Court in the case of CIT vs. Durga Prasad More reported in 82 ITR 540 (SC) and Sumati Dayal vs. CIT (1995) 214 ITR 801 (SC), the Assessing Officer made addition of Rs.1,62,84,153/- to the total income of the assessee by observing as under: “9….. The explanation of the assessee has been considered but the same is found not acceptable. The assessee-company is trying to state that Pranav International Ltd., Dubai advanced to the assessee-company at Rs.2,12,03,549/-…

Income Tax Office Ward-7(1), Delhi vs. Durga Agencies Pvt. Ltd, Delhi

In the result, appeal of the Revenue is partly allowed

ITA 5423/DEL/2024[2017-18]Status: DisposedITAT Delhi27 May 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2017-18] Ito, Vs Durga Agencies Pvt.Ltd., Ward-7(1), 27/94 B Ground Floor, Tikona Delhi Park, Jwala Nagar, Shahdara, East Delhi-110032. Pan-Aaacd4709 Appellant Respondent Revenue By Shri Rajesh Kumar Dhanesta, Sr.Dr Assessee By Ms. Vaishnavi Yadav, Adv. Date Of Hearing 27.05.2025 Date Of Pronouncement 27.05.2025

Section 142(1)Section 143(3)Section 250Section 271ASection 68

…ITA No.5423/Del/2024 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “B” BENCH: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER [Assessment Year : 2017-18] ITO, vs Durga Agencies Pvt.Ltd., Ward-7(1), 27/94 B Ground Floor, Tikona Delhi Park, Jwala Nagar, Shahdara, East Delhi-110032. PAN-AAACD4709 APPELLANT RESPONDENT Revenue by Shri Rajesh Kumar Dhanesta, Sr.DR Assessee by Ms. Vaishnavi Yadav, Adv. Date of Hearing 27.05.2025 Date of Pronouncement 27.05.2025 ORDER PER MANISH AGARWAL, AM : The present appeal has been filed by the Revenue against the order dated 27…

Deputy Commissioner of Income Tax, Central Circle-16, Delhi vs. Bharat Bhushan Suri, Delhi

In the result, the appeal of Revenue is allowed for statistical purposes

ITA 2957/DEL/2023[2017-18]Status: DisposedITAT Delhi23 May 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishraita No.2957/Del/2023, A.Y. 2017-18 Dy. Commissioner Of Income Bharat Bhushan Suri Tax, Central Circle-16, E-248, Greater Kailash I, E-2, Jhandewalan Extn. New Delhi Ara Centre, Delhi Pan: Ahnpp6394A New Delhi (Appellant) (Respondent) Appellant By Mr. Javed Akhtar, Cit(Dr) Respondent By Sh. Deepanshu Mehta, Advocate Date Of Hearing 27/02/2025 Date Of Pronouncement 23/05/2025 Order Per Avdhesh Kumar Mishra, Am This Appeal If The Revenue For The Assessment Year (Hereinafter, The ‘Ay’) 2017-18 Filed Is Directed Against The Order Dated 02.08.2023 Passed By The Commissioner Of Income Tax (Appeals)-28, New Delhi [Hereinafter, The ‘Cit(A)’].

Section 132Section 153CSection 69A

…ned in the registered sale deed and as well as in the agreement to sell as consideration received through the banking channel. The AO, placing reliance on the decisions of the Hon’ble Supreme Court in the cases of Durga Prasad More 82 ITR 540 and Sumati Dayal 214 ITR 801 to emphasize on the circumstantial evidence and human probability. Accordingly, the AO held that the assessee along with his brother has received Rs.23,08,26,446/- (Rs.27,08,26,446/- minus Rs.4,00,00,000/-) in cash as on-money over and above the registered sale consideration and taxed the proportionate on-money receipt in the hands of the sellers…

Deputy Commissioner of Income Tax, Central Circle-16, Delhi vs. Vinod Kumar Suri, Delhi

In the result, the appeal of Revenue is allowed for statistical purposes

ITA 2958/DEL/2023[2017-18]Status: DisposedITAT Delhi21 May 2025AY 2017-18

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 132Section 153CSection 69A

…ned in the registered sale deed and as well as in the agreement to sell as consideration received through the banking channel. The AO, placing reliance on the decisions of the Hon’ble Supreme Court in the cases of Durga Prasad More 82 ITR 540 and Sumati Dayal 214 ITR 801 to emphasize on the circumstantial evidence and human probability. Accordingly, the AO held that the assessee along with his brother has received Rs.23,08,26,446/- (Rs.27,08,26,446/- minus Rs.4,00,00,000/-) in cash as on-money over and above the registered sale consideration and taxed the proportionate on-money receipt in the hands of the sellers…

Ajeet Kumar Rampuria, Tonk vs. ITO Ward 7(2), Tonk

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

ITA 44/JPR/2025[2013-14]Status: DisposedITAT Jaipur20 May 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Sandeep Jhanwar, C.AFor Respondent: Sh. Anup Singh, Addl. CIT
Section 147Section 148Section 250

…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. 44/JP/2025 fu/kZkj.k o"kZ@Assessment Year : 2013-14 cuke Ajeet Kumar Rampuria ITO, Vs. Prop. M/s Ajay Arts, Ward 7(2), Mahaveer Chock, Tonk Tonk LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: ABGPR 3327 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Sandeep Jhanwar, C.A jktLo dh vksj ls@ Revenue by : Sh. An…

Kailash Chand Maheshwari, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

ITA 1465/JPR/2024[2017-18]Status: DisposedITAT Jaipur20 May 2025AY 2017-18
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 127Section 132Section 133ASection 144Section 153ASection 57Section 68Section 69C

…being swayed by the not so convincing, but apparently in order, statements and letters and examining them, in a pedantic manner, with the blinkers on. The same has been the approach adopted by Hon'ble Supreme Court, in the case of Sumati Dayal Vs CIT [(1995) 214 ITR 801 (SC)]. wherein Their Lordships have, inter alia, disapproved acceptance of a claim of winning the appellant claims to have won in horse races a total amount of Rs.3,11,831 on 13 occasions out of which 10 winnings were from Jackpots and 3 were from Treble events by Chairman of the Income Tax Settlement Commission, and observed that "This, in our o…

Kailash Chand Maheshwari, Jaipur vs. Deputy Commissioner of Income Tax, Centralcircle-2, Jaipur

ITA 1464/JPR/2024[2016-17]Status: DisposedITAT Jaipur20 May 2025AY 2016-17
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 127Section 132Section 133ASection 144Section 153ASection 57Section 68Section 69C

…being swayed by the not so convincing, but apparently in order, statements and letters and examining them, in a pedantic manner, with the blinkers on. The same has been the approach adopted by Hon'ble Supreme Court, in the case of Sumati Dayal Vs CIT [(1995) 214 ITR 801 (SC)]. wherein Their Lordships have, inter alia, disapproved acceptance of a claim of winning the appellant claims to have won in horse races a total amount of Rs.3,11,831 on 13 occasions out of which 10 winnings were from Jackpots and 3 were from Treble events by Chairman of the Income Tax Settlement Commission, and observed that "This, in our o…

Kailash Chand Maheshwari, Jaipur vs. Deputy Commissioner of Income Tax, Jaipur

ITA 1463/JPR/2024[2015-16]Status: DisposedITAT Jaipur20 May 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri S. L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 127Section 132Section 133ASection 144Section 153ASection 57Section 68Section 69C

…being swayed by the not so convincing, but apparently in order, statements and letters and examining them, in a pedantic manner, with the blinkers on. The same has been the approach adopted by Hon'ble Supreme Court, in the case of Sumati Dayal Vs CIT [(1995) 214 ITR 801 (SC)]. wherein Their Lordships have, inter alia, disapproved acceptance of a claim of winning the appellant claims to have won in horse races a total amount of Rs. 3,11,831 on 13 occasions out of which 10 winnings were from Jackpots and 3 were from Treble Kailash Chand Maheshwari vs. DCIT events by Chairman of the Income Tax Settlement Commissio…