T.S. Kumarasamy v. Asstt.CIT

65 ITD 188Income Tax Appellate Tribunal1998#5163 most cited

What is T.S. Kumarasamy v. Asstt.CIT authority for?

Statements, admissions, and confessions made during income tax proceedings are binding and cannot be retracted unless proven to be involuntary or under coercion, as Income Tax Officers do not use unfair means.

23

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2019 to 2024.

Also referred to as

T.S. Kumarasamy v. Asstt.CIT · retracted statement · binding admissions · involuntary statement · coercion · duress · oath statements · search operations · ITAT

Issues it is cited on

section 271aabstatement under section 132(4)retracted statementdumb documentssection 271aaon-moneysection 271asection 40a(3)tnmmsection 40aconcealment of incomerevenue expenditure

Judgments citing T.S. Kumarasamy v. Asstt.CIT

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD vs. VARSHA VISWANATH PROPERTIES PRIVATE LIMITED, HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2050/HYD/2018[2016-17]Status: DisposedITAT Hyderabad09 Jan 2024AY 2016-17

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

…ind this is, a person making a statement stops the opposite party from making further investigation." It would also be useful to refer to the decision of the Madras Bench of the Income-tax Appellate Tribunal in the case of T.S. Kumarasamy Vs. Asstt.CIT [1998] 65 ITD 188 where, taking note of the fact that ITOs are not Police Officers and, as such, they do not use or resort to, unfair means in recording oath statements during the search operations or during the course of any proceedings before them, it was held that such statements, admissions and confessions are binding and cannot be retracted, unless and until i…

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD vs. VARSHA VISWANATH PROPERTIES PRIVATE LIMITED, HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2049/HYD/2018[2015-16]Status: DisposedITAT Hyderabad09 Jan 2024AY 2015-16

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

…ind this is, a person making a statement stops the opposite party from making further investigation." It would also be useful to refer to the decision of the Madras Bench of the Income-tax Appellate Tribunal in the case of T.S. Kumarasamy Vs. Asstt.CIT [1998] 65 ITD 188 where, taking note of the fact that ITOs are not Police Officers and, as such, they do not use or resort to, unfair means in recording oath statements during the search operations or during the course of any proceedings before them, it was held that such statements, admissions and confessions are binding and cannot be retracted, unless and until i…

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD vs. VARSHA VISWANATH PROPERTIES PRIVATE LIMITED, HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2048/HYD/2018[2014-15]Status: DisposedITAT Hyderabad09 Jan 2024AY 2014-15

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

…ind this is, a person making a statement stops the opposite party from making further investigation." It would also be useful to refer to the decision of the Madras Bench of the Income-tax Appellate Tribunal in the case of T.S. Kumarasamy Vs. Asstt.CIT [1998] 65 ITD 188 where, taking note of the fact that ITOs are not Police Officers and, as such, they do not use or resort to, unfair means in recording oath statements during the search operations or during the course of any proceedings before them, it was held that such statements, admissions and confessions are binding and cannot be retracted, unless and until i…

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD vs. VARSHA VISWANATH PROPERTIES PRIVATE LIMITED , HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2047/HYD/2018[2013-14]Status: DisposedITAT Hyderabad09 Jan 2024AY 2013-14

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

…ind this is, a person making a statement stops the opposite party from making further investigation." It would also be useful to refer to the decision of the Madras Bench of the Income-tax Appellate Tribunal in the case of T.S. Kumarasamy Vs. Asstt.CIT [1998] 65 ITD 188 where, taking note of the fact that ITOs are not Police Officers and, as such, they do not use or resort to, unfair means in recording oath statements during the search operations or during the course of any proceedings before them, it was held that such statements, admissions and confessions are binding and cannot be retracted, unless and until i…

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD vs. VARSHA VISWANATH PROPERTIES PRIVATE LIMITED , HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2046/HYD/2018[2012-13]Status: DisposedITAT Hyderabad09 Jan 2024AY 2012-13

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

…ind this is, a person making a statement stops the opposite party from making further investigation." It would also be useful to refer to the decision of the Madras Bench of the Income-tax Appellate Tribunal in the case of T.S. Kumarasamy Vs. Asstt.CIT [1998] 65 ITD 188 where, taking note of the fact that ITOs are not Police Officers and, as such, they do not use or resort to, unfair means in recording oath statements during the search operations or during the course of any proceedings before them, it was held that such statements, admissions and confessions are binding and cannot be retracted, unless and until i…

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 1910/HYD/2018[2016-17]Status: DisposedITAT Hyderabad09 Jan 2024AY 2016-17

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

…ind this is, a person making a statement stops the opposite party from making further investigation." It would also be useful to refer to the decision of the Madras Bench of the Income-tax Appellate Tribunal in the case of T.S. Kumarasamy Vs. Asstt.CIT [1998] 65 ITD 188 where, taking note of the fact that ITOs are not Police Officers and, as such, they do not use or resort to, unfair means in recording oath statements during the search operations or during the course of any proceedings before them, it was held that such statements, admissions and confessions are binding and cannot be retracted, unless and until i…

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 1909/HYD/2018[2015-16]Status: DisposedITAT Hyderabad09 Jan 2024AY 2015-16

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

…ind this is, a person making a statement stops the opposite party from making further investigation." It would also be useful to refer to the decision of the Madras Bench of the Income-tax Appellate Tribunal in the case of T.S. Kumarasamy Vs. Asstt.CIT [1998] 65 ITD 188 where, taking note of the fact that ITOs are not Police Officers and, as such, they do not use or resort to, unfair means in recording oath statements during the search operations or during the course of any proceedings before them, it was held that such statements, admissions and confessions are binding and cannot be retracted, unless and until i…

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 1908/HYD/2018[2014-15]Status: DisposedITAT Hyderabad09 Jan 2024AY 2014-15

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

…ind this is, a person making a statement stops the opposite party from making further investigation." It would also be useful to refer to the decision of the Madras Bench of the Income-tax Appellate Tribunal in the case of T.S. Kumarasamy Vs. Asstt.CIT [1998] 65 ITD 188 where, taking note of the fact that ITOs are not Police Officers and, as such, they do not use or resort to, unfair means in recording oath statements during the search operations or during the course of any proceedings before them, it was held that such statements, admissions and confessions are binding and cannot be retracted, unless and until i…

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 1907/HYD/2018[2013-14]Status: DisposedITAT Hyderabad09 Jan 2024AY 2013-14

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

…ind this is, a person making a statement stops the opposite party from making further investigation." It would also be useful to refer to the decision of the Madras Bench of the Income-tax Appellate Tribunal in the case of T.S. Kumarasamy Vs. Asstt.CIT [1998] 65 ITD 188 where, taking note of the fact that ITOs are not Police Officers and, as such, they do not use or resort to, unfair means in recording oath statements during the search operations or during the course of any proceedings before them, it was held that such statements, admissions and confessions are binding and cannot be retracted, unless and until i…

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 1906/HYD/2018[2012-13]Status: DisposedITAT Hyderabad09 Jan 2024AY 2012-13

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

…ind this is, a person making a statement stops the opposite party from making further investigation." It would also be useful to refer to the decision of the Madras Bench of the Income-tax Appellate Tribunal in the case of T.S. Kumarasamy Vs. Asstt.CIT [1998] 65 ITD 188 where, taking note of the fact that ITOs are not Police Officers and, as such, they do not use or resort to, unfair means in recording oath statements during the search operations or during the course of any proceedings before them, it was held that such statements, admissions and confessions are binding and cannot be retracted, unless and until i…

DY. COMMISSIONER OF INCOME TAX, CEN-CIRCLE 4(1), MUMBAI vs. MR RASHMIN GIRDHARILAL RUGHANI, MUMBAI

In the result, both the appeal of the Revenue and cross

ITA 2143/MUM/2023[2017-2018]Status: DisposedITAT Mumbai29 Nov 2023AY 2017-2018

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Appellant: Mr. Gaurav KabraFor Respondent: Smt. Sanyogita Nagpal, CIT-DR

…binds the petitioner." In this case, the retraction filed within and binds the petitioner." In this case, the retraction filed within 6 days was rejected by the Hon'ble Apex C 6 days was rejected by the Hon'ble Apex Court. b. As held in T S Kumarasmy vs ACIT, 65 ITD 188, by the b. As held in T S Kumarasmy vs ACIT, 65 ITD 188, by the b. As held in T S Kumarasmy vs ACIT, 65 ITD 188, by the Hon'ble Madras ITAT, "It is well known that the Income Hon'ble Madras ITAT, "It is well known that the Income Hon'ble Madras ITAT, "It is well known that the Income-tax Officers are not Police Officers and they do not use or reso…

DY. COMMISSIONER OF INCOME TAX, CEN-CIRCLE 4(1), MUMBAI vs. MR RASHMIN GIRDHARILAL RUGHANI, MUMBAI

In the result, both the appeal of the Revenue and cross

ITA 2142/MUM/2023[2018-2019]Status: DisposedITAT Mumbai29 Nov 2023AY 2018-2019

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Appellant: Mr. Gaurav KabraFor Respondent: Smt. Sanyogita Nagpal, CIT-DR

…binds the petitioner." In this case, the retraction filed within and binds the petitioner." In this case, the retraction filed within 6 days was rejected by the Hon'ble Apex C 6 days was rejected by the Hon'ble Apex Court. b. As held in T S Kumarasmy vs ACIT, 65 ITD 188, by the b. As held in T S Kumarasmy vs ACIT, 65 ITD 188, by the b. As held in T S Kumarasmy vs ACIT, 65 ITD 188, by the Hon'ble Madras ITAT, "It is well known that the Income Hon'ble Madras ITAT, "It is well known that the Income Hon'ble Madras ITAT, "It is well known that the Income-tax Officers are not Police Officers and they do not use or reso…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE AJMER vs. MUKESH KUMAR SOMANI , KISHANGARH

In the result appeals of the revenue in ITA Nos

ITA 336/JPR/2022[2019-20]Status: DisposedITAT Jaipur08 Dec 2022AY 2019-20
For Appellant: Shri C. M Agarwal (C.A.)For Respondent: Shri Shailendra Sharma (CIT)
Section 143(3)Section 69

…is so, the fact that the initials of the lenders are mentioned in the accounts of the borrowers, they are to be considered as genuine-Chander Mohan Mehta us Asstt. CIT (1999) 65 TTJ (Pune) 327: (1999) 71 ITD 245 (Pune) and T.S Kumarasamu vs Asstt. CIT (1998) 65 ITD 188 (Mad) relied on. (Para 12) 6. BIREN V. SAVLA vs. ASSISTANT COMMISSIONER OF INCOME TAX, ITAT, MUMBAI BENCH, reported in (2005) 24 CCH 0634 MumTrib.. (2006) 100 TTJ 1006 Held: If presumption under s. 132(4) is raised in respect of A-2 and A-4 then same should be equally and in identical proportion be raised in respect of A-3 and A-5. The principle…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE AJMER vs. ALOK MALPANI, KISHANGARH

In the result appeals of the revenue in ITA Nos

ITA 334/JPR/2022[2019-20]Status: DisposedITAT Jaipur08 Dec 2022AY 2019-20
For Appellant: Shri C. M Agarwal (C.A.)For Respondent: Shri Shailendra Sharma (CIT)
Section 143(3)Section 69

…is so, the fact that the initials of the lenders are mentioned in the accounts of the borrowers, they are to be considered as genuine-Chander Mohan Mehta us Asstt. CIT (1999) 65 TTJ (Pune) 327: (1999) 71 ITD 245 (Pune) and T.S Kumarasamu vs Asstt. CIT (1998) 65 ITD 188 (Mad) relied on. (Para 12) 6. BIREN V. SAVLA vs. ASSISTANT COMMISSIONER OF INCOME TAX, ITAT, MUMBAI BENCH, reported in (2005) 24 CCH 0634 MumTrib.. (2006) 100 TTJ 1006 Held: If presumption under s. 132(4) is raised in respect of A-2 and A-4 then same should be equally and in identical proportion be raised in respect of A-3 and A-5. The principle…

AMIT BHASKARRAO SANAP,,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE -3, , AURANGABAD

In the result, appeal of the Assessee is Dismissed

ITA 78/PUN/2019[2015-16]Status: DisposedITAT Pune19 Oct 2022AY 2015-16

Bench: Shri Partha Sarathi Chaudhury & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.78/Pun/2019 िनधा"रण वष" / Assessment Year : 2015-16 Amit Bhaskarrao Sanap, The Assistant A-2, N-4, Cidco, Aurangabad, Vs Commissioner Of Income Maharashtra – 431001. Tax, Circle-3, Aurangabad. Pan: Auips 4177 L Appellant/ Assessee Respondent /Revenue Assessee By None. Revenue By Shri S P Walimbe & Shri Arvind Desai – Dr Date Of Hearing 25/07/2022 Date Of Pronouncement 19/10/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)-2, Aurangabad, Dated 13.11.2018 For The A.Y. 2015-16. The Assessee Has Raised The Following Grounds Of Appeal: “1. The Order Of The Learned Commissioner (A), Aurangabad Confirming The Addition Of Rs.1,93.17.241/- Made By The A.O. In Computing The Income U/S 56 Instead Of Exempt U S. 10(38) Of The Act Of The Appellant Is Contrary To Law & Facts Of The Case.

Section 10(38)Section 56

…law. However, such a retraction has been made by the appellant after a ITA No.78/PUN/2019 for A.Y. 2015-16 Amit Bhaskarrao Sanap Vs. ACIT, Circle-3, (A) lapse of almost three years. Reliance is placed on the decision in the case of T.S. Kumarasamy Vs. ACIT (65 ITD 188) (Madras ITAT), wherein the Honourable Tribunal held that ITOs are not police officers, they do not use unfair means or third-degree methods in recording statement on oath. Therefore, such statements and oaths cannot be retracted unless it is proved by legally acceptable evidence that such admission/confession or oath was not voluntarily tendered…

M/S. SIMTOOLS PVT. LTD.,MUMBAI vs. DCIT , CENTRAL CIRCLE-7(3) ( EARSTWHILE DCIT- CENT. CIR-42), MUMBAI

In the result, this appeal by the assessee stands allowed as above

ITA 1574/MUM/2020[2011-12]Status: DisposedITAT Mumbai09 Feb 2022AY 2011-12

Bench: Shri Shamim Yahya & Shri Amarjit Singh

For Appellant: Shri Anuj KisnadwalaFor Respondent: Shri Vinay Sinha
Section 132(4)Section 153CSection 32(1)Section 79

…me contained on money collection. He again referred to statement of other employees of Lodha group and thereafter that of Shri Abhinandhan Lodha. He referred to following case laws i) Surjeet Singh chhabra v. Union of India (SC) ii) TS Kumarasami v. ACIT , 65 ITD 188 (Mad.) iii) MK Mohammad Kunhi v. CIT 92 ITR 341 (ker.) iv) V Kunhikannan v CIT 219 ITR 235 (Ker.) v) Hotel Kiran v ACIT, 82 ITD 453 (Pune.Trib) vi) Dr.SC Gupta v. CIT, 248 ITR 782(Alld) 13. He concluded as under:- “Respectfully following the above judicial authorities on the subject, I hold as under:- (i) Statements in the nature of declarations…

DCIT CC 3(4) CEN RG 3, MUMBAI vs. MARS REALTORS P. LTD, MUMBAI

Appeals of the Revenue are dismissed

ITA 7180/MUM/2016[2013-14]Status: DisposedITAT Mumbai05 Apr 2019AY 2013-14

Bench: Shri G.S. Pannu & Shri Amarjit Singh

For Appellant: Shri T. Kipgen, CIT-DRFor Respondent: Shri Vijay Mehta
Section 132(1)Section 132(4)Section 143(3)Section 68

…ing Officer cannot accept one part of the seized material and ignore the other part of the same material. He relied on the decisions in the case of Pepsico India Holdings Pvt. Ltd. 349 ITR 85 (Del.); Indeo Airways Pvt. Ltd. 349 ITR 85 (Del.); T.S. Kumaraswamy 65 ITD 188 (Mad); Vatika Greenfield Ltd. 121 TTJ 208 and held that Assessing Officer cannot accept the impounded material on selective basis and consider some part of evidence as true while rejecting the evidence which is in favour of assessee, without bringing anything on record. 19. With respect to conclusion of the Assessing Officer that no reasonable pe…

DCIT CC 3(4) CEN RG 3, MUMBAI vs. DEV LAND AND HOUSING P.LTD, MUMBAI

Appeals of the Revenue are dismissed

ITA 7179/MUM/2016[2013-14]Status: DisposedITAT Mumbai05 Apr 2019AY 2013-14

Bench: Shri G.S. Pannu & Shri Amarjit Singh

For Appellant: Shri T. Kipgen, CIT-DRFor Respondent: Shri Vijay Mehta
Section 132(1)Section 132(4)Section 143(3)Section 68

…ing Officer cannot accept one part of the seized material and ignore the other part of the same material. He relied on the decisions in the case of Pepsico India Holdings Pvt. Ltd. 349 ITR 85 (Del.); Indeo Airways Pvt. Ltd. 349 ITR 85 (Del.); T.S. Kumaraswamy 65 ITD 188 (Mad); Vatika Greenfield Ltd. 121 TTJ 208 and held that Assessing Officer cannot accept the impounded material on selective basis and consider some part of evidence as true while rejecting the evidence which is in favour of assessee, without bringing anything on record. 19. With respect to conclusion of the Assessing Officer that no reasonable pe…

DCIT CC 3(4) CEN RG 3, MUMBAI vs. DEV LAND AND HOUSING P.LTD, MUMBAI

Appeals of the Revenue are dismissed

ITA 7178/MUM/2016[2010-11]Status: DisposedITAT Mumbai05 Apr 2019AY 2010-11

Bench: Shri G.S. Pannu & Shri Amarjit Singh

For Appellant: Shri T. Kipgen, CIT-DRFor Respondent: Shri Vijay Mehta
Section 132(1)Section 132(4)Section 143(3)Section 68

…ing Officer cannot accept one part of the seized material and ignore the other part of the same material. He relied on the decisions in the case of Pepsico India Holdings Pvt. Ltd. 349 ITR 85 (Del.); Indeo Airways Pvt. Ltd. 349 ITR 85 (Del.); T.S. Kumaraswamy 65 ITD 188 (Mad); Vatika Greenfield Ltd. 121 TTJ 208 and held that Assessing Officer cannot accept the impounded material on selective basis and consider some part of evidence as true while rejecting the evidence which is in favour of assessee, without bringing anything on record. 19. With respect to conclusion of the Assessing Officer that no reasonable pe…

DCIT CC 3(4) CEN RG 3, MUMBAI vs. DEV LAND AND HOUSING P.LTD, MUMBAI

Appeals of the Revenue are dismissed

ITA 7177/MUM/2016[2009-10]Status: DisposedITAT Mumbai05 Apr 2019AY 2009-10

Bench: Shri G.S. Pannu & Shri Amarjit Singh

For Appellant: Shri T. Kipgen, CIT-DRFor Respondent: Shri Vijay Mehta
Section 132(1)Section 132(4)Section 143(3)Section 68

…ing Officer cannot accept one part of the seized material and ignore the other part of the same material. He relied on the decisions in the case of Pepsico India Holdings Pvt. Ltd. 349 ITR 85 (Del.); Indeo Airways Pvt. Ltd. 349 ITR 85 (Del.); T.S. Kumaraswamy 65 ITD 188 (Mad); Vatika Greenfield Ltd. 121 TTJ 208 and held that Assessing Officer cannot accept the impounded material on selective basis and consider some part of evidence as true while rejecting the evidence which is in favour of assessee, without bringing anything on record. 19. With respect to conclusion of the Assessing Officer that no reasonable pe…

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