Surinder Kumar v. Commissioner of Income Tax

282 ITR 78High Court2006#7539 most cited
15

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2026.

Sections most often in play

Section 133ASection 145Section 147Section 148(2)Section 40A(3)Section 250Section 115BBESection 131

Issues it is cited on

retraction of statementsection 148(2)mlisection 158bbstatement under section 132(4)survey under section 133ablock periodon-moneysection 40a(3)short term capital gainsection 145loose papers

Judgments citing Surinder Kumar v. Commissioner of Income Tax

SAMA NARASIMHA REDDY AND SAMA SARASWATHI REDDY GARDENS,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1335/HYD/2025[2014-15]Status: DisposedITAT Hyderabad20 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

…Hon’ble Delhi High Court in the case of Ajay Gupta vs. Commissioner of Income Tax in ITA 360/2015 & 361/2015, dated 27/10/2016 and also the decision of the Hon’ble Punjab & Haryana High Court in the case of Surinder Kumar vs. Commissioner of Income Tax (2006) 282 ITR 78 (P&H). 11. We have heard both the parties, perused the material available on record and the orders of the authorities below. We have also carefully considered the judicial pronouncements and the case laws relied upon by the Larned Counsel for the assessee and the Ld. Sr. AR present for the Revenue. There is no dispute with regard to the fact that…

SAMA NARASIMHA REDDY AND SAMA SARASWATHI REDDY GARDENS,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1334/HYD/2025[2013-14]Status: DisposedITAT Hyderabad20 Feb 2026AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

…Hon’ble Delhi High Court in the case of Ajay Gupta vs. Commissioner of Income Tax in ITA 360/2015 & 361/2015, dated 27/10/2016 and also the decision of the Hon’ble Punjab & Haryana High Court in the case of Surinder Kumar vs. Commissioner of Income Tax (2006) 282 ITR 78 (P&H). 11. We have heard both the parties, perused the material available on record and the orders of the authorities below. We have also carefully considered the judicial pronouncements and the case laws relied upon by the Larned Counsel for the assessee and the Ld. Sr. AR present for the Revenue. There is no dispute with regard to the fact that…

SAMA NARASIMHA REDDY AND SAMA SARASWATHI REDDY GARDENS,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1333/HYD/2025[2012-13]Status: DisposedITAT Hyderabad20 Feb 2026AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

…Hon’ble Delhi High Court in the case of Ajay Gupta vs. Commissioner of Income Tax in ITA 360/2015 & 361/2015, dated 27/10/2016 and also the decision of the Hon’ble Punjab & Haryana High Court in the case of Surinder Kumar vs. Commissioner of Income Tax (2006) 282 ITR 78 (P&H). 11. We have heard both the parties, perused the material available on record and the orders of the authorities below. We have also carefully considered the judicial pronouncements and the case laws relied upon by the Larned Counsel for the assessee and the Ld. Sr. AR present for the Revenue. There is no dispute with regard to the fact that…

SAMA NARASIMHA REDDY AND SAMA SARASWATHI REDDY GARDENS,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1332/HYD/2025[2011-12]Status: DisposedITAT Hyderabad20 Feb 2026AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

…Hon’ble Delhi High Court in the case of Ajay Gupta vs. Commissioner of Income Tax in ITA 360/2015 & 361/2015, dated 27/10/2016 and also the decision of the Hon’ble Punjab & Haryana High Court in the case of Surinder Kumar vs. Commissioner of Income Tax (2006) 282 ITR 78 (P&H). 11. We have heard both the parties, perused the material available on record and the orders of the authorities below. We have also carefully considered the judicial pronouncements and the case laws relied upon by the Larned Counsel for the assessee and the Ld. Sr. AR present for the Revenue. There is no dispute with regard to the fact that…

JAIPAL SINGH,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR

ITA 120/JPR/2024[2018-19]Status: DisposedITAT Jaipur11 Mar 2025AY 2018-19
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

…ed out of consideration in\ntotality of facts, particularly in the absence of regular books of account. The\nTribunal rightly followed the observations of the Allahabad High Court in Dr. SC.\nGupta [2001] 248 ITR 782 and of this court in Surinder Kumar [2006] 282 ITR 78\n(P&H). Thus, having regard to the facts and circumstances of the case, the view\ntaken by the Tribunal cannot be held to be perverse or illegal.\"\n(Emphasis supplied)\n(In the above case the statement was recorded during survey. The above\njudgement is in the context of evidentiary value of statement recorded during\nsurvey).\nCommissioner of In…

JAIPAL SINGH,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR

ITA 118/JPR/2024[2016-17]Status: DisposedITAT Jaipur11 Mar 2025AY 2016-17
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

…ed out of consideration in\ntotality of facts, particularly in the absence of regular books of account. The\nTribunal rightly followed the observations of the Allahabad High Court in Dr. SC.\nGupta [2001] 248 ITR 782 and of this court in Surinder Kumar [2006] 282 ITR 78\n(P&H). Thus, having regard to the facts and circumstances of the case, the view\ntaken by the Tribunal cannot be held to be perverse or illegal.\"\n(Emphasis supplied)\n(In the above case the statement was recorded during survey. The above\njudgement is in the context of evidentiary value of statement recorded during\nsurvey).\nCommissioner of In…

JAIPAL SINGH,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR

ITA 116/JPR/2024[2014-15]Status: DisposedITAT Jaipur11 Mar 2025AY 2014-15
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

…ed out of consideration in\ntotality of facts, particularly in the absence of regular books of account. The\nTribunal rightly followed the observations of the Allahabad High Court in Dr. SC.\nGupta [2001] 248 ITR 782 and of this court in Surinder Kumar [2006] 282 ITR 78\n(P&H). Thus, having regard to the facts and circumstances of the case, the view\ntaken by the Tribunal cannot be held to be perverse or illegal.\"\n(Emphasis supplied)\n(In the above case the statement was recorded during survey. The above\njudgement is in the context of evidentiary value of statement recorded during\nsurvey).\nCommissioner of In…

JAIPAL SINGH,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR

ITA 115/JPR/2024[2013-14]Status: DisposedITAT Jaipur11 Mar 2025AY 2013-14
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

…ed out of consideration in\ntotality of facts, particularly in the absence of regular books of account. The\nTribunal rightly followed the observations of the Allahabad High Court in Dr. SC.\nGupta [2001] 248 ITR 782 and of this court in Surinder Kumar [2006] 282 ITR 78\n(P&H). Thus, having regard to the facts and circumstances of the case, the view\ntaken by the Tribunal cannot be held to be perverse or illegal.\"\n(Emphasis supplied)\n(In the above case the statement was recorded during survey. The above\njudgement is in the context of evidentiary value of statement recorded during\nsurvey).\nCommissioner of In…

RAJESH PRODUCTS,TONK ,RAJASTHAN vs. ACIT, JAIPUR

Appeal is dismissed

ITA 626/JPR/2023[2016-17]Status: DisposedITAT Jaipur18 Jul 2024AY 2016-17
For Appellant: Shri Mahesh Jain, CA (Th. V.C)For Respondent: Shri Bhanwar Singh Ratnu, (CIT-DR)
Section 132(1)Section 132(4)Section 142(1)Section 143(2)Section 143(3)

…be ruled out of consideration in totality of facts, particularly in the absence of regular books of account. The Tribunal rightly followed the observations of the Allahabad High Court in Dr. SC Gupta 2001 248 ITR 782 and of this court in Surinder Kumar (2006) 282 ITR 78 (P&H). Thus, having regard to the facts and circumstances of the case, the view taken by the Tribunal cannot be held to be perverse or illegal (Emphasis supplied) (In the above case the statement was recorded during survey. The above judgement in this in the context of evidentiary value of statement recorded during survey) Commissioner of Income-t…

DCIT, ALLAHABAD vs. M/S MAHESH CHANDRA VISHNU CHANDRA SARRAF, ALLAHABAD

In the result, the appeal of the revenue ITA No

ITA 216/ALLD/2016[2012-13]Status: DisposedITAT Allahabad03 Jul 2023AY 2012-13

Bench: Sh. Ramit Kochar & Sh. Anikesh Banerjeei.T.A. No.199/Alld/2016 Assessment Year: 2012-13 M/S Mahesh Chandra Vishnu Vs. Acit-Circle-1, Chandra Sarraf, Allahabad. 37/164, Meerganj, Chowk Allahabad. (Respondent) [Pan:-[Aaqfm2701G] (Appellant) I.T.A. No. 216/Alld/2016 Assessment Year: 2012-13 Dy. Cit-Circle-1, Vs. M/S Mahesh Chandra Allahabad. Vishnu Chandra Sarraf, 37/164, Meerganj, Chowk Allahabad. [Pan:-[Aaqfm2701G] (Appellant) (Respondent) C.O. No.34/Alld/2016 (In I.T.A. No. 216/Alld/2016) Assessment Year: 2012-13 M/S Mahesh Chandra Vishnu Vs. Dcit-Circle-3, Chandra Sarraf, Allahabad. 37/164, Meerganj, Chowk Allahabad. [Pan:-[Aaqfm2701G] (Respondent) (Appellant) Appellant By None. Respondent By Sh. A.K. Singh, Sr. Dr

Section 143(3)Section 145(3)Section 250(6)

…ruled out of consideration in totality of facts, particularly in the absence of regular books of account. The Tribunal rightly followed the observations of the Allahabad High Court in Dr. S.C. Gupta[2001] 248 ITR 782 and of this court in Surinder Kumar [2006] 282 ITR 78 (P&H). Thus, having regard to the facts and circumstances of the case, the view taken by the Tribunal cannot be held to be perverse or illegal.” 7.6.4. Hiralal Maganlal& Co. v. Deputy Commissioner of Income-tax, SR- 52, [2005] 96ITD113 (ITAT-MUM.) “Whether further since retraction was not supported by any independent or reliable evidence to prov…

M/S MAHESH CHANDRA VISHNU CHANDRA SARRAF,ALLAHABAD vs. ACCT, ALLAHABAD

In the result, the appeal of the revenue ITA No

ITA 199/ALLD/2016[2012-13]Status: DisposedITAT Allahabad03 Jul 2023AY 2012-13

Bench: Sh. Ramit Kochar & Sh. Anikesh Banerjeei.T.A. No.199/Alld/2016 Assessment Year: 2012-13 M/S Mahesh Chandra Vishnu Vs. Acit-Circle-1, Chandra Sarraf, Allahabad. 37/164, Meerganj, Chowk Allahabad. (Respondent) [Pan:-[Aaqfm2701G] (Appellant) I.T.A. No. 216/Alld/2016 Assessment Year: 2012-13 Dy. Cit-Circle-1, Vs. M/S Mahesh Chandra Allahabad. Vishnu Chandra Sarraf, 37/164, Meerganj, Chowk Allahabad. [Pan:-[Aaqfm2701G] (Appellant) (Respondent) C.O. No.34/Alld/2016 (In I.T.A. No. 216/Alld/2016) Assessment Year: 2012-13 M/S Mahesh Chandra Vishnu Vs. Dcit-Circle-3, Chandra Sarraf, Allahabad. 37/164, Meerganj, Chowk Allahabad. [Pan:-[Aaqfm2701G] (Respondent) (Appellant) Appellant By None. Respondent By Sh. A.K. Singh, Sr. Dr

Section 143(3)Section 145(3)Section 250(6)

…ruled out of consideration in totality of facts, particularly in the absence of regular books of account. The Tribunal rightly followed the observations of the Allahabad High Court in Dr. S.C. Gupta[2001] 248 ITR 782 and of this court in Surinder Kumar [2006] 282 ITR 78 (P&H). Thus, having regard to the facts and circumstances of the case, the view taken by the Tribunal cannot be held to be perverse or illegal.” 7.6.4. Hiralal Maganlal& Co. v. Deputy Commissioner of Income-tax, SR- 52, [2005] 96ITD113 (ITAT-MUM.) “Whether further since retraction was not supported by any independent or reliable evidence to prov…

VISHNU AGGARWAL,FARIDABAD vs. ITO, FARIDABAD

In the result, the appeal of the assessee is allowed

ITA 358/DEL/2017[2013-14]Status: DisposedITAT Delhi06 Apr 2023AY 2013-14

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year : 2013-14

For Appellant: Shri K.C. Singhal, AdvocateFor Respondent: Shri Umesh Takyar, Sr. DR
Section 145(3)Section 2(22)(e)

…hat payments were also made through banks. 6.1 Also it is settled law that section 145(3) cannot be invoked on the mere ground that GP rate is low as compared to earlier year, as held in the decision of Hon'ble P&H High Court in Surinder Kumar Charanjit Kumar 282 ITR 78 PH, wherein it has been held that “a low GP rate may not per se lead to an inference that accounts are false, but coupled with other relevant circumstances, it does afford a sufficient ground for rejection of the accounts and estimation of profits.” 6.2 Keeping in view of the facts and circumstances of the case and respectfully following the prece…

M/S. MARSHAL MULTITRADE PVT. LTD,MUMBAI vs. THE ITO WD 9(2)-3, MUMBAI

In the result, the appeal by the assessee is dismissed

ITA 1914/MUM/2008[2004-2005]Status: DisposedITAT Mumbai13 Dec 2022AY 2004-2005

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Rajiv KhandelwalFor Respondent: Shri Chetan M. Kacha
Section 144Section 145(3)Section 145ASection 250Section 254(1)

…g the books of accounts since without the appropriate details the correct income could not be determined. In this regard it would be apt to refer to the observations of Punjab and Haryana high court in case of Surinder Kumar Charanjit Kumar V CIT rep order in 282 ITR 78; “We are unable to agree with learned counsel. It is true that the accounts regularly maintained by an assessee in the course of business are normally taken as correct unless there are cogent reasons to indicate that they are not reliable, yet it is not possible to lay down the exact circumstances in which these may be rejected as incorrect or unr…

VISHNU AGGARWAL,FARIDABAD vs. ITO, FARIDABAD

In the result, the Appeal of the Assessee is partly allowed

ITA 357/DEL/2017[2012-13]Status: DisposedITAT Delhi26 Apr 2019AY 2012-13

Bench: Shri H.S. Sidhu

Section 143(1)Section 144Section 145(3)Section 2(22)(e)

…bmitted that section 145(3) of the Act cannot be invoked on the mere ground GP rate is low as compared to earlier year and in this regard he relied upon the decision of the Hon’ble Punjab and Haryana High Court in the case of 4 Surinder Kumar Charanjit Kumar 282 ITR 78. In view of the above, he requested that the appeal of the assessee may be allowed. 5. On the other hand, Ld. DR relied upon the orders of the Ld. CIT(A) on the issue in dispute and stated that the GP rate declared by the assessee was much lower than declared in the preceding year. He further submitted that the appellant neither maintained sto…

PARVATIBEN DAMJI SHAH,MUMBAI vs. ITO 21(1)(4), MUMBAI

In the result, the appeal filed by the assessee company in ITA N0

ITA 3181/MUM/2014[2009-10]Status: DisposedITAT Mumbai05 Jul 2016AY 2009-10

Bench: Shri Sanjay Garg & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.3181/Mum/2014 ("नधा"रण वष" / Assessment Year : 2009-10) Smt. Parvatiben Damji Shah, The Income Tax Officer – बनाम/ 602, Aashish Apartment, 21(1)(4), V. Tilak Mandir Road, C-10, 6 Th Floor, Vile Parle(East), Pratyaksha Kar Bhavan, Mumbai – 400 057. Bandra-Kurla Complex, Bandra East, Mumbai – 400 050. "थायी लेखा सं./Pan : Aaqps2114K (अपीलाथ" /Appellant) .. (""यथ" / Respondent)

For Respondent: Dr. S. Pandian
Section 143(3)Section 253(3)Section 69A

…(SC). 3. CIT v. Uttamchand Jain (Bom) IT Appeal No. 634 of 2009. 4. Abdul Qaymme v. CIT (1990) 184 ITR 404 5. ITAT Bangalore Bench decision in the case of Carpenters Classics (Exim) (p) Ltd. v. DCIT 108 ITD 142. 6. Surendra Kumar Charanjeet Kumar Singh v. CIT 282 ITR 78 (P&H HC) 7. Bacchitarsingh v. CIT 328 ITR 400(P&H HC). The learned CIT(A) observed that the contention of the assessee that statement recorded during the course of survey was not voluntary and is not supported by any documentary evidence, the learned CIT(A) observed that the assessee failed to demonstrate and satisfy the A.O. with corroborative e…