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.

How many judgments cite Sumati Dayal v. CIT?

1,967 judgments on BharatTax cite Sumati Dayal v. CIT (214 ITR 801), spanning 2010 to 2026.

Which sections of the Income Tax Act does Sumati Dayal v. CIT come up under?

It is most often cited in judgments turning on Section 68, Section 143(3), Section 147, Section 148, Section 142(1), Section 115BBE.

Sumati Dayal v. CIT (214 ITR 801)

DCIT, CC-2, Jaipur vs. Shri Nath Corporation, Jaipur

In the result, appeal of the assessee and that of the revenue stands

ITA 182/JPR/2020[2017-18]Status: DisposedITAT Jaipur07 Jun 2023AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &

Section 132Section 143Section 145(3)

…gle day by issuing total 85 invoices which is 97% of total sales of the year and does not pass the test of human probability as held by the Hon'ble Supreme Court in the cases of Shrinath Corporation vs. DCIT, Central Circle-02, Jaipur SumatiDayalVs CIT (1995) 214 ITR 801 (SC) and CIT VSDurga Prasad More (1971) 82 ITR 540 (SC)" 3. On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition of Rs. 1,56,63,325/-in spite of the fact that the cash sales pattern of the preceding 2 year with current year cash sales pattern is also surprising. Viz. in the month of November as…

M/S. Shri Nath Corporation, Jaipur vs. DCIT, C.C.-2, Jaipur

In the result, appeal of the assessee and that of the revenue stands

ITA 117/JPR/2020[2017-18]Status: DisposedITAT Jaipur07 Jun 2023AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &

Section 132Section 143Section 145(3)

…gle day by issuing total 85 invoices which is 97% of total sales of the year and does not pass the test of human probability as held by the Hon'ble Supreme Court in the cases of Shrinath Corporation vs. DCIT, Central Circle-02, Jaipur SumatiDayalVs CIT (1995) 214 ITR 801 (SC) and CIT VSDurga Prasad More (1971) 82 ITR 540 (SC)" 3. On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition of Rs. 1,56,63,325/-in spite of the fact that the cash sales pattern of the preceding 2 year with current year cash sales pattern is also surprising. Viz. in the month of November as…

Rekha Chawla, Salem vs. The Assistant Commissioner of Income Tax, Central Circle, Salem

In the result, appeals filed by both assessees in ITA Nos

ITA 375/CHNY/2022[2012-13]Status: DisposedITAT Chennai31 May 2023AY 2012-13

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Bleआयकर अपील सं./Ita Nos.392 & 393/Chny/2021 &

For Respondent: Mr.S.R.Karuppusamy, CIT

Section 143(3)Section 263

…to put on blinkers -while looking at the documents produced before them. They were entitled to look into the surrounding circumstances to find out the reality of the recitals made in those documents'. 9.5.2. The Hon'ble Apex Court in the case Sumathy Dayal [214 ITR 801(SC)] came across a similar improbable result that was shown by the assessee. These entire edifices through which the assessee claimed to have earned huge tax exempt gains within a very short span of time fails the test of both genuineness and human probabilities. In the case cited supra, the Hon'ble SC propounded their principles of human probabi…

Rekha Chawla, Salem vs. The Assistant Commissioner of Income Tax, Central Circle, Salem

In the result, appeals filed by both assessees in ITA Nos

ITA 374/CHNY/2022[2011-12]Status: DisposedITAT Chennai31 May 2023AY 2011-12

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Bleआयकर अपील सं./Ita Nos.392 & 393/Chny/2021 &

For Respondent: Mr.S.R.Karuppusamy, CIT

Section 143(3)Section 263

…to put on blinkers -while looking at the documents produced before them. They were entitled to look into the surrounding circumstances to find out the reality of the recitals made in those documents'. 9.5.2. The Hon'ble Apex Court in the case Sumathy Dayal [214 ITR 801(SC)] came across a similar improbable result that was shown by the assessee. These entire edifices through which the assessee claimed to have earned huge tax exempt gains within a very short span of time fails the test of both genuineness and human probabilities. In the case cited supra, the Hon'ble SC propounded their principles of human probabi…

Sanjay Chawla, Salem vs. The ACIT, Central Cirlce, Salem

In the result, appeals filed by both assessees in ITA Nos

ITA 373/CHNY/2022[2012-13]Status: DisposedITAT Chennai31 May 2023AY 2012-13

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Bleआयकर अपील सं./Ita Nos.392 & 393/Chny/2021 &

For Respondent: Mr.S.R.Karuppusamy, CIT

Section 143(3)Section 263

…to put on blinkers -while looking at the documents produced before them. They were entitled to look into the surrounding circumstances to find out the reality of the recitals made in those documents'. 9.5.2. The Hon'ble Apex Court in the case Sumathy Dayal [214 ITR 801(SC)] came across a similar improbable result that was shown by the assessee. These entire edifices through which the assessee claimed to have earned huge tax exempt gains within a very short span of time fails the test of both genuineness and human probabilities. In the case cited supra, the Hon'ble SC propounded their principles of human probabi…

Sanjay Chawla, Salem vs. The ACIT, Central Cirlce, Salem

In the result, appeals filed by both assessees in ITA Nos

ITA 372/CHNY/2022[2011-12]Status: DisposedITAT Chennai31 May 2023AY 2011-12

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Bleआयकर अपील सं./Ita Nos.392 & 393/Chny/2021 &

For Respondent: Mr.S.R.Karuppusamy, CIT

Section 143(3)Section 263

…to put on blinkers -while looking at the documents produced before them. They were entitled to look into the surrounding circumstances to find out the reality of the recitals made in those documents'. 9.5.2. The Hon'ble Apex Court in the case Sumathy Dayal [214 ITR 801(SC)] came across a similar improbable result that was shown by the assessee. These entire edifices through which the assessee claimed to have earned huge tax exempt gains within a very short span of time fails the test of both genuineness and human probabilities. In the case cited supra, the Hon'ble SC propounded their principles of human probabi…

Sanjay Chawla, Salem vs. The ACIT, Central Cirlce, Salem

In the result, appeals filed by both assessees in ITA Nos

ITA 371/CHNY/2022[2010-11]Status: DisposedITAT Chennai31 May 2023AY 2010-11

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Bleआयकर अपील सं./Ita Nos.392 & 393/Chny/2021 &

For Respondent: Mr.S.R.Karuppusamy, CIT

Section 143(3)Section 263

…to put on blinkers -while looking at the documents produced before them. They were entitled to look into the surrounding circumstances to find out the reality of the recitals made in those documents'. 9.5.2. The Hon'ble Apex Court in the case Sumathy Dayal [214 ITR 801(SC)] came across a similar improbable result that was shown by the assessee. These entire edifices through which the assessee claimed to have earned huge tax exempt gains within a very short span of time fails the test of both genuineness and human probabilities. In the case cited supra, the Hon'ble SC propounded their principles of human probabi…

Sanjay Chawla, Salem vs. The Assistant Commissioner of Income-Tax, Central Circle, Salem.

In the result, appeals filed by both assessees in ITA Nos

ITA 396/CHNY/2021[2012-13]Status: DisposedITAT Chennai31 May 2023AY 2012-13

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Bleआयकर अपील सं./Ita Nos.392 & 393/Chny/2021 &

For Respondent: Mr.S.R.Karuppusamy, CIT

Section 143(3)Section 263

…to put on blinkers -while looking at the documents produced before them. They were entitled to look into the surrounding circumstances to find out the reality of the recitals made in those documents'. 9.5.2. The Hon'ble Apex Court in the case Sumathy Dayal [214 ITR 801(SC)] came across a similar improbable result that was shown by the assessee. These entire edifices through which the assessee claimed to have earned huge tax exempt gains within a very short span of time fails the test of both genuineness and human probabilities. In the case cited supra, the Hon'ble SC propounded their principles of human probabi…

Sanjay Chawla, Salem vs. The Assistant Commissioner of Income-Tax, Central Circle, Salem.

In the result, appeals filed by both assessees in ITA Nos

ITA 395/CHNY/2021[2011-12]Status: DisposedITAT Chennai31 May 2023AY 2011-12

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Bleआयकर अपील सं./Ita Nos.392 & 393/Chny/2021 &

For Respondent: Mr.S.R.Karuppusamy, CIT

Section 143(3)Section 263

…to put on blinkers -while looking at the documents produced before them. They were entitled to look into the surrounding circumstances to find out the reality of the recitals made in those documents'. 9.5.2. The Hon'ble Apex Court in the case Sumathy Dayal [214 ITR 801(SC)] came across a similar improbable result that was shown by the assessee. These entire edifices through which the assessee claimed to have earned huge tax exempt gains within a very short span of time fails the test of both genuineness and human probabilities. In the case cited supra, the Hon'ble SC propounded their principles of human probabi…

Sanjay Chawla, Salem vs. The Assistant Commissioner of Income-Tax, Central Circle, Salem.

In the result, appeals filed by both assessees in ITA Nos

ITA 394/CHNY/2021[2010-11]Status: DisposedITAT Chennai31 May 2023AY 2010-11

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Bleआयकर अपील सं./Ita Nos.392 & 393/Chny/2021 &

For Respondent: Mr.S.R.Karuppusamy, CIT

Section 143(3)Section 263

…to put on blinkers -while looking at the documents produced before them. They were entitled to look into the surrounding circumstances to find out the reality of the recitals made in those documents'. 9.5.2. The Hon'ble Apex Court in the case Sumathy Dayal [214 ITR 801(SC)] came across a similar improbable result that was shown by the assessee. These entire edifices through which the assessee claimed to have earned huge tax exempt gains within a very short span of time fails the test of both genuineness and human probabilities. In the case cited supra, the Hon'ble SC propounded their principles of human probabi…

Rekha Chawla, Salem vs. The Assistant Commissioner of Income-Tax, Central Circle, Salem.

In the result, appeals filed by both assessees in ITA Nos

ITA 393/CHNY/2021[2012-13]Status: DisposedITAT Chennai31 May 2023AY 2012-13

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Bleआयकर अपील सं./Ita Nos.392 & 393/Chny/2021 &

For Respondent: Mr.S.R.Karuppusamy, CIT

Section 143(3)Section 263

…to put on blinkers -while looking at the documents produced before them. They were entitled to look into the surrounding circumstances to find out the reality of the recitals made in those documents'. 9.5.2. The Hon'ble Apex Court in the case Sumathy Dayal [214 ITR 801(SC)] came across a similar improbable result that was shown by the assessee. These entire edifices through which the assessee claimed to have earned huge tax exempt gains within a very short span of time fails the test of both genuineness and human probabilities. In the case cited supra, the Hon'ble SC propounded their principles of human probabi…

Rekha Chawla, Salem vs. The Assistant Commissioner of Income Tax, Central Circle, Salem

In the result, appeals filed by both assessees in ITA Nos

ITA 392/CHNY/2021[2011-12]Status: DisposedITAT Chennai31 May 2023AY 2011-12

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Bleआयकर अपील सं./Ita Nos.392 & 393/Chny/2021 &

For Respondent: Mr.S.R.Karuppusamy, CIT

Section 143(3)Section 263

…to put on blinkers -while looking at the documents produced before them. They were entitled to look into the surrounding circumstances to find out the reality of the recitals made in those documents'. 9.5.2. The Hon'ble Apex Court in the case Sumathy Dayal [214 ITR 801(SC)] came across a similar improbable result that was shown by the assessee. These entire edifices through which the assessee claimed to have earned huge tax exempt gains within a very short span of time fails the test of both genuineness and human probabilities. In the case cited supra, the Hon'ble SC propounded their principles of human probabi…

ITO, Ward-14(1)(1), Mumbai vs. M/S. Bansal Separators and Spares Pvt. Ltd., Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 3173/MUM/2022[2014-15]Status: DisposedITAT Mumbai31 May 2023AY 2014-15

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleito – Ward – 14(1)(1) V. M/S. Bansal Separators & Spares Pvt. Ltd., Room No. 431, 4Th Floor 6, Laxminarayan Shopping Centre Aayakar Bhavan, M.K. Road Sion Trombay Road, Chembur Mumbai - 400020 Mumbai - 400071 Pan: Aabcb8468M (Appellant) (Respondent)

Section 133(6)Section 143(1)Section 143(2)Section 68

…elevant information specified in notices issued to them. Therefore, he came to the conclusion that the assessee has not established the identity, creditworthiness and genuineness of the transactions. Accordingly, by relying on case law of Sumati Dayal v. CIT [214 ITR 801] and Jalan timbers v. CIT [213 ITR 11] he held that the unsecured loans received by the assessee are treated as unexplained cash credits u/s. 68 of the Act. Accordingly, he added to the total income of the assessee. Similarly, he also disallowed Page No. | 3 M/s. Bansal Separators and Spares Pvt. Ltd., interest expenses incurred by the assessee o…

Vishan Raj Jain (HUF), Hyderabad vs. ACIT Central Circle-1 (2), Hyderabad

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

ITA 193/HYD/2022[2016-17]Status: DisposedITAT Hyderabad25 May 2023AY 2016-17

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2016-17 Vishan Raj Jain (Huf) Vs. Acit, Central Circle-1(2) 6-3-650, G7 6-3-650, G7, Aaykar Bhawan Maheswari Chambers Opp:L.B.Stadium Somajiguda Basheer Bagh Telangana-500 082 Hyderabad-500 004

For Appellant: Shri K.C.Devdas, CAFor Respondent: Shri K.P.R.R.Murthy, Sr.AR

Section 10Section 10(38)Section 115BSection 142(1)Section 143(2)Section 147Section 148Section 250

…ne and it is manipulated transaction in collusion with the brokers to paint creditworthiness to the transaction and claim exemption u/s. 10(38). This is in accordance with the ratio laid by the Hon'ble Apex Court in Sumati Dayal Vs Commissioner Of Income-Tax, 214 ITR 801(SC), that " the apparent must be considered the real until it is shown that there are reasons to believe that the apparent is not the real and that the taxing authorities are entitled to look into the surrounding circumstances to find out the reality and the matter has to be considered by applying the test of human probabilities. (See : CIT v. Du…

Shri Komal Kumbhat, Guwahati vs. Income Tax Officer, Ward-2(1), Guwahati

ITA 136/GTY/2020[2014-15]Status: DisposedITAT Guwahati25 May 2023AY 2014-15

Bench: Shri Sanjay Gargi.T.A No.136/Gty/2020 Assessment Year: 2014-15 Shri Komal Kumbhat…………...................................................……Appellant 234, G.N.B Road, 2Nd Floor, Opposite Gauhati Club Bus Stand-Above Sarita Restaurant, Guwahati-781003. [Pan: Aedpk8036P] Vs. Ito, Ward-2(1), Guwahati...…...................……........……...…..…..Respondent Appearances By: Shri H. S. Kumbhat, Ar, Appeared On Behalf Of The Appellant. Shri N. T. Sherpa, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 14, 2023 Date Of Pronouncing The Order : May 25, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 02.03.2020 Of The Commissioner Of Income Tax (Appeals)- Guwahati-1, Guwahati (Hereinafter Referred To As The ‘Cit(A)’) Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Through Various Grounds Of Appeal Has Agitated Two Issues I.E. (I) Addition Made/Confirmed By The Lower Authorities On Long-Term Capital Gains Claimed By The Assessee Of Rs.21,80,417/- Treating The Same As Bogus & Thereby Adding The Same

Section 131Section 250

…u/s 10(38) and his claim of Long Term Capital Gains cannot be accepted when the modus operandi of the entire transaction from investment to LTCG is supported otherwise by surrounding evidences. Reliance is placed on the judgement of Sumati Dayal v. CIT (1995) 214 ITR 801 (SC), where the Apex Court has held that the matter has to be considered in the light of human probabilities and the surrounding circumstances, and the Court had occasion to consider the principle "what is apparent is real" and held that this principle is not sacrosanct and may be overlooked if surrounding circumstances so suggest. In view of the…

Chetan Dinesh Sheth, Thane vs. ITO, Ward, Thane

Appeal is allowed

ITA 439/MUM/2023[2014-15]Status: DisposedITAT Mumbai24 May 2023AY 2014-15

For Appellant: Shri Haridas BhatFor Respondent: Shri Sridhar Govind Menon

Section 10(38)Section 143(3)Section 68

…the Assessing Officer. Before parting we would like to observe that the Assessing Officer 9. and the CITA) had placed reliance affirmed the judgment of the Hon’ble Supreme Court in the case of Durga Prasad More 82 ITR 540 (SC) and Sumati Dayal V. CIT (1995) 214 ITR 801 (SC). However, as observed by the Hon’ble Delhi High Court in the case of Principal Commissioner of Income Tax-12 v. Smt. Krishna Devi: [2021] 431 ITR 361 (Delhi)[15-01-2021], the theory of human behavior and preponderance of probabilities cannot be cited as a basis to turn a blind eye to the evidence produced by an assessee. Further, in the case…

Kshitij Marine Services Pvt. Ltd., Surat vs. Assistant Commissioner of Income Tax, Cir.1(1)(2), Surat

In the result, appeal filed by the assessee is allowed

ITA 125/SRT/2021[2013-14]Status: DisposedITAT Surat23 May 2023AY 2013-14

Bench: SHRI PAWAN SINGH (Judicial Member), DR. A. L. SAINI (Accountant Member)

For Appellant: Shri Rasesh Shah, CAFor Respondent: Shri Vinod Kumar, Sr- DR

Section 133(6)Section 143(3)Section 69C

…IN THE INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI PAWAN SINGH, JM & DR. A. L. SAINI, AM आयकर अपील सं./ITA No.125/SRT/2021 ("नधा"रणवष" / Assessment Years: (2013-14) (Physical Court Hearing) Kshitij Marine Services Pvt. Assistant Commissioner of Ltd., O-2, Office Floor, Income-tax, Circle-1(1)(2), Vs. Madhulka Apartments, Bhatar Surat, Aaykar Bhavan, Majura Road, Surat-393001 Gate, Surat-395001 "थायीलेखासं./जीआइआरसं./PAN/GIR No.: AAACK 9924 E (अपीलाथ" /Assessee) (""थ" /Respondent) िनधा"रती की ओर से /Assessee by : Shri Rasesh Shah, CA राज" की ओर से/Revenue by : Shri Vinod Kumar, Sr- DR सुनवाई क" त…

Robert Holding Pvt. Ltd., Kolkata vs. I.T.O., Ward-4(1), Kolkata

The appeal of the assessee is treated as allowed for statistical purposes

ITA 368/KOL/2020[2012-13]Status: DisposedITAT Kolkata22 May 2023AY 2012-13

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A No.368/Kol/2020 Assessment Year: 2012-13 Robert Holding Pvt. Ltd..................................................................……Appellant 121, Netaji Subhas Road, 4Th Floor, Room No.47, Kolkata-1. [Pan: Aabcr4839G] Vs. Ito, Ward-4(1), Kolkata...............................……........……...…..…..Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri P. P Barman, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 23, 2023 Date Of Pronouncing The Order : May 22, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 29.11.2019 Of The Commissioner Of Income Tax (Appeals)-10, Kolkata (Hereinafter Referred To As The ‘Cit(A)’) Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Contested The Addition Of Rs.13680000/- Constituting Share Capital Of Rs.2280000/- & Share Premium Of Rs.11400000/- Treating The Same As Unexplained Income Of The Assessee U/S 68 Of The Act. The Another Issue Raised By The Assessee Through Grounds Of Appeal Is That The Assessee Had Returned Income At A

Section 131Section 142(1)Section 143(2)Section 250Section 68

…M/s Star Griha Pvt. Ltd vs CIT and M/s. Bisakha Sales Pvt. Ltd., Kolkata (PAN:AADCB0527F) .. (Appellant)-Vs- CIT(Kol.-II), Kolkata ..(Respondent). The Hon'ble Apex Court in the case of CIT vs Durga Prasad More 82 ITR 540 and in the case of Sumati Dayal vs CIT 214 ITR 801 has expounded that revenue authorities are also supposed to consider the surrounding circumstances and apply the test of human probability. In these cases the transactions though apparent were held to be not real ones. In the light of the above discussion, the entire amount of money received on account of issue of shares along with the quantum of…

Sangeeta Devi Jhunjhunwala, New Delhi vs. ITO, Ward-70(1), New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 747/DEL/2022[2015-16]Status: DisposedITAT Delhi18 May 2023AY 2015-16

Bench: Dr. Brr Kumar & Ms. Astha Chandraasstt. Year: 2015-16

For Appellant: Shri Rajiv SaxenaFor Respondent: Shri Amit Shukla, Sr. DR

Section 10(38)Section 131Section 142(1)Section 143(1)Section 69C

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G”: NEW DELHI BEFORE DR. BRR KUMAR, ACCOUNTANT MEMBER AND MS. ASTHA CHANDRA, JUDICIAL MEMBER Asstt. Year: 2015-16 Sangeeta Devi Jhunjhunwala, Vs. ITO, Ward-70(1) IPSO Legal H-35, 1st Floor, New Delhi. Jangpura Extension, New Delhi – 110 014 PAN AAAPJ3918J (Appellant) (Respondent) Assessee by: Shri Rajiv Saxena, Ms. Sumangla Saxena, Shri Shayam Sunder, Shri Dishant Seth, Advocates Department by : Shri Amit Shukla, Sr. DR Date of Hearing: 05.04.2023 Date of 18.05.2023 pronouncement: O R D E R PER ASTHA CHANDRA, JM The appeal filed by the assessee is directed against…

Rajesh Kumar Damani, Kolkata vs. I.T.O., Ward-50(4), Kolkata

In the result, the appeal of the assessee is hereby allowed

ITA 2187/KOL/2019[2011-12]Status: DisposedITAT Kolkata04 May 2023AY 2011-12

Bench: Dr. Manish Borad & Shri Sonjoy Sarma]

Section 10(38)Section 133ASection 148Section 151Section 234Section 68Section 69C

…ement of income, however needs further probe) and thereafter the AO observes that the matter is to be considered by applying the test of human probabilities. Thereafter referring to the Hon’ble Supreme Court decision in the case of Sumati Dayal Vs. CIT (1995) 214 ITR 801 (SC) and in the case of CIT Vs. P. Mohankala 291 ITR 278, he concludes that in view of the above facts and after analysing the information available on record, the AO says that he has reason to believe that the assessee has suppressed his income by using LTCG treating it as exempt to the tune of Rs.2,38,54,750/- which is/are reported as bogus by…

Sumati Dayal v. CIT

What is Sumati Dayal v. CIT authority for?

Also referred to as

Also reported as

Sections most often in play

Issues it is cited on

Judgments citing Sumati Dayal v. CIT

DCIT, CC-2, Jaipur vs. Shri Nath Corporation, Jaipur

M/S. Shri Nath Corporation, Jaipur vs. DCIT, C.C.-2, Jaipur

Rekha Chawla, Salem vs. The Assistant Commissioner of Income Tax, Central Circle, Salem

Rekha Chawla, Salem vs. The Assistant Commissioner of Income Tax, Central Circle, Salem

Sanjay Chawla, Salem vs. The ACIT, Central Cirlce, Salem

Sanjay Chawla, Salem vs. The ACIT, Central Cirlce, Salem

Sanjay Chawla, Salem vs. The ACIT, Central Cirlce, Salem

Sanjay Chawla, Salem vs. The Assistant Commissioner of Income-Tax, Central Circle, Salem.

Sanjay Chawla, Salem vs. The Assistant Commissioner of Income-Tax, Central Circle, Salem.

Sanjay Chawla, Salem vs. The Assistant Commissioner of Income-Tax, Central Circle, Salem.

Rekha Chawla, Salem vs. The Assistant Commissioner of Income-Tax, Central Circle, Salem.

Rekha Chawla, Salem vs. The Assistant Commissioner of Income Tax, Central Circle, Salem

ITO, Ward-14(1)(1), Mumbai vs. M/S. Bansal Separators and Spares Pvt. Ltd., Mumbai

Vishan Raj Jain (HUF), Hyderabad vs. ACIT Central Circle-1 (2), Hyderabad

Shri Komal Kumbhat, Guwahati vs. Income Tax Officer, Ward-2(1), Guwahati

Chetan Dinesh Sheth, Thane vs. ITO, Ward, Thane

Kshitij Marine Services Pvt. Ltd., Surat vs. Assistant Commissioner of Income Tax, Cir.1(1)(2), Surat

Robert Holding Pvt. Ltd., Kolkata vs. I.T.O., Ward-4(1), Kolkata

Sangeeta Devi Jhunjhunwala, New Delhi vs. ITO, Ward-70(1), New Delhi

Rajesh Kumar Damani, Kolkata vs. I.T.O., Ward-50(4), Kolkata