Vasantlal & Co. v. CIT

45 ITR 206Supreme Court of India1962#487 most cited

What is Vasantlal & Co. v. CIT authority for?

The Income Tax Officer (ITO) can gather material for assessment through private enquiries but must disclose such material to the assessee and provide an opportunity to explain it to uphold the principles of natural justice. The ITO is not bound by strict rules of evidence and can use material collected privately, provided disclosure and explanation are afforded.

193

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2015 to 2026.

Also referred to as

Vasantlal & Co. v. CIT · 45 ITR 206 · SC · private enquiry · disclosure of material · opportunity to explain · natural justice · cross-examination

Sections most often in play

Section 147Section 148Section 153CSection 68Section 143(3)Section 144BSection 250Section 132

Issues it is cited on

buyback of sharesretention moneyonus of proofsection 269tsection 158bbsection 269sthird party informationsection 271eicdsdumb documentssection 132(4a)section 292c

Judgments citing Vasantlal & Co. v. CIT

Income Tax Officer-Khargone, Aayakar Bhawan Khargone vs. Ibrahim Abbasali Bohra, Barwaha

The appeal of the Revenue is dismissed

ITA 120/IND/2025[2014-15]Status: DisposedITAT Indore27 Mar 2026AY 2014-15

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 147Section 246ASection 250Section 253Section 68

…sआयकरअपीलीयअिधकरण, इंदौर"ायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND SHRI PARESH M JOSHI, JUDICIAL MEMBER ITA No.119&120/Ind/2025 (AY: 2013-14 & 2014-15) INCOME TAX IBRAHIM ABBASALI बनाम/ OFFICER BOHRA Vs. 15 Tilak Marg, Barwaha Khargone -451115 (PAN:AHLPB7848M) (Appellant) (Respondent) Assessee by Sh. Soumya Bumb, CA Revenue by Shri Ashish Porwal, Sr.DR Date of Hearing 23.03.2026 Date of 27.03.2026 Pronouncement आदेश/ O R D E R Per Paresh M Joshi, J.M.: (I)ITA No:-119/Ind/2025 AY-2013-14 This is an Appeal filed by the Revenue under sect…

Income Tax Officer, Aayakar Bhawan Khargone vs. Ibrahim Abbasali Bohra, Barwaha

The appeal of the Revenue is dismissed

ITA 119/IND/2025[2013-14]Status: DisposedITAT Indore27 Mar 2026AY 2013-14

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 147Section 246ASection 250Section 253Section 68

…sआयकरअपीलीयअिधकरण, इंदौर"ायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND SHRI PARESH M JOSHI, JUDICIAL MEMBER ITA No.119&120/Ind/2025 (AY: 2013-14 & 2014-15) INCOME TAX IBRAHIM ABBASALI बनाम/ OFFICER BOHRA Vs. 15 Tilak Marg, Barwaha Khargone -451115 (PAN:AHLPB7848M) (Appellant) (Respondent) Assessee by Sh. Soumya Bumb, CA Revenue by Shri Ashish Porwal, Sr.DR Date of Hearing 23.03.2026 Date of 27.03.2026 Pronouncement आदेश/ O R D E R Per Paresh M Joshi, J.M.: (I)ITA No:-119/Ind/2025 AY-2013-14 This is an Appeal filed by the Revenue under sect…

Bhagawati M Jain, Dombivali vs. Ward 3(1), Kalyan

In the result, appeal of the assessee is allowed

ITA 2408/MUM/2025[2018-2019]Status: DisposedITAT Mumbai10 Mar 2026AY 2018-2019

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2018-19 Bhagawati M Jain Income Tax Officer C-22, Bhanu Chs, Ward 3(1), Bhanu Nagar, Dombivali East, 2Nd Floor, Rani Mansion, Vs. Kalyan - 421201 Kalyan-Murbad Rd, Maharashtra Kalyan-Dombivali, Maharashtra, 421301 (Pan: Aatpj1123G) (Appellant) (Respondent) Present For: Assessee : Shri Viraj Mehta, Ca Revenue : Shri Aditya Rai, Sr. Dr Date Of Hearing : 22.12.2025 Date Of Pronouncement : 10.03.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2024-25/1073449956(1), Dated 19.02.2025, Passed Against The Assessment Order By Assessing Officer, National Faceless Assessment Centre, Delhi, U/S. 147 R.W.S.144B Of The Income- Tax Act (Hereinafter Referred To As The “Act”), Dated 26.02.2024, For Assessment Year 2018-19. 2. Grounds Taken By Assessee Are Reproduced As Under:

For Appellant: Shri Viraj Mehta, CAFor Respondent: Shri Aditya Rai, Sr. DR
Section 132Section 139(1)Section 147Section 148Section 148ASection 151Section 153CSection 69B

…of cash payment by me to the builder, but still today no evidence was produce or furnished to me. And even not allowing me for the cross examination of the said builders. I am referring to following decision as held for similar issue. i. C Vasantalal and Co. 45 ITR 206(SC) ii. Kishan Chand Chellaram VSCIT (125 ITR 713) iii. CIT Central Jaipur Vs. Smt. Sunita Dhadda iv. M/s Andaman Timber Industries Vs. Commissioner of Central Excise 92015 (281 CTR 241(SC)." 5.1 On the contrary, ld. Sr. DR placed reliance on the orders of authorities below and submitted that addition made is based on material passed on by search…

Nandkishore Telefilms & Media Private Limited, Mumbai vs. Circle 7(2)(2), Mumbai

In the result appeal of the revenue is dismissed

ITA 2563/MUM/2025[2013-14]Status: DisposedITAT Mumbai05 Dec 2025AY 2013-14

Bench: Ms. Padmavathy S & Shri. Raj Kumar Chauhan

Section 132(4)Section 133(6)Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 250Section 68

…parties whose statement AO is relying on particularly the judgment of Hon'ble Supreme Court in the case of Andaman Timber Industries V. CIT, 281 CTR 241 along with following decisions. 1. H.R. Metha Vs. ACIT, 387 ITR 561 (Bom HC) 2. C Vasantlal& co. Vs. CIT, 45 ITR 206 (SC) 3. KishinchandChellaram Vs. CIT, 125 ITR 713 (SC) 4. CIT Vs. Ashish International, ITA No. 4299 of 2009. 5. CIT Vs. Ashwani Gupta, 322 ITR 396 (Bom) 6.3 It was contented by Ld. AR that in the statement of Shri Vipul Vidur Bhatt, he has replied regarding unsecured loans to only one party M/s Moraj Building concepts Pvt Ltd., and he has nowhere…

Income Tax Officer-3(1), Raipur vs. Rahul Kathuria, Raipur

In the result, appeal of the Revenue in ITA No

ITA 152/RPR/2025[2019-20]Status: DisposedITAT Raipur26 Nov 2025AY 2019-20

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.151 & 152/Rpr/2025 "नधा"रण वष" / Assessment Years : 2018-19 & 2019-20 The Income Tax Officer/Income Tax Officer-3(1) Raipur (C.G.)

For Appellant: Shri V.K. Jindal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 148

…ct of figures taken as per BSE data Rs.2,04,23,038/- vide reply doted 02.11.2022 (refer Page No. 1-2) However, the same was also not made available to us." The appellant has cited the decision of Hon'ble Supreme Court in the case of C. Vasantlal & Co. vs. CIT 45 ITR 206 (SC) and has assailed the addition under discussion as "tantamount to breach of Principle of Natural Justice". 5.5.10. The appellant also contends that "the assessee has earned short term capital gain of Rs.602532/-, short term capital loss of Rs.556736/- and intraday profit of Rs.46804/-. thus, in total the assessee has earned only 92600/- on whi…

Income Tax Officer, Raipur vs. Rahul Kathuria, Raipur

In the result, appeal of the Revenue in ITA No

ITA 151/RPR/2025[2018-19]Status: DisposedITAT Raipur26 Nov 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.151 & 152/Rpr/2025 "नधा"रण वष" / Assessment Years : 2018-19 & 2019-20 The Income Tax Officer/Income Tax Officer-3(1) Raipur (C.G.)

For Appellant: Shri V.K. Jindal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 148

…ct of figures taken as per BSE data Rs.2,04,23,038/- vide reply doted 02.11.2022 (refer Page No. 1-2) However, the same was also not made available to us." The appellant has cited the decision of Hon'ble Supreme Court in the case of C. Vasantlal & Co. vs. CIT 45 ITR 206 (SC) and has assailed the addition under discussion as "tantamount to breach of Principle of Natural Justice". 5.5.10. The appellant also contends that "the assessee has earned short term capital gain of Rs.602532/-, short term capital loss of Rs.556736/- and intraday profit of Rs.46804/-. thus, in total the assessee has earned only 92600/- on whi…

DCIT, Circle-7(1), Delhi vs. Dlf Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 715/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Oct 2025AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…which the charge was going to be imposed and given an opportunity to rebut the effect of the materials, if he can. Similar view has been expressed by the Hon’ble Supreme Court in Dhakeshwari Cotton Mills Ltd Vs CIT 26 ITR 775 and in C. Vasantlal & Co. Vs CIT 45 ITR 206. j) M/s Green Power Realtors (P) Ltd. v. DCIT, Circle 11(2) (2013)34 taxmann.com 27 (Madras), Hon’ble High Court stated that “It requires under law that the assessee should be heard in the matter before concluding the proceedings and, therefore, the revenue authority is bound to offer an opportunity of being heard with law, before proceeding to pa…

DCIT, Circle-7(1), Delhi vs. Dlf Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 714/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…which the charge was going to be imposed and given an opportunity to rebut the effect of the materials, if he can. Similar view has been expressed by the Hon’ble Supreme Court in Dhakeshwari Cotton Mills Ltd Vs CIT 26 ITR 775 and in C. Vasantlal & Co. Vs CIT 45 ITR 206. j) M/s Green Power Realtors (P) Ltd. v. DCIT, Circle 11(2) (2013)34 taxmann.com 27 (Madras), Hon’ble High Court stated that “It requires under law that the assessee should be heard in the matter before concluding the proceedings and, therefore, the revenue authority is bound to offer an opportunity of being heard with law, before proceeding to pa…

DCIT, Circle-7(1), Delhi vs. Dlf Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 713/DEL/2024[2019-20]Status: DisposedITAT Delhi30 Oct 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…which the charge was going to be imposed and given an opportunity to rebut the effect of the materials, if he can. Similar view has been expressed by the Hon’ble Supreme Court in Dhakeshwari Cotton Mills Ltd Vs CIT 26 ITR 775 and in C. Vasantlal & Co. Vs CIT 45 ITR 206. j) M/s Green Power Realtors (P) Ltd. v. DCIT, Circle 11(2) (2013)34 taxmann.com 27 (Madras), Hon’ble High Court stated that “It requires under law that the assessee should be heard in the matter before concluding the proceedings and, therefore, the revenue authority is bound to offer an opportunity of being heard with law, before proceeding to pa…

Dlf Limited, Delhi vs. National Faceless Assessment Centre, Delhi

In the result, appeal of the Revenue is dismissed

ITA 677/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Oct 2025AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…which the charge was going to be imposed and given an opportunity to rebut the effect of the materials, if he can. Similar view has been expressed by the Hon’ble Supreme Court in Dhakeshwari Cotton Mills Ltd Vs CIT 26 ITR 775 and in C. Vasantlal & Co. Vs CIT 45 ITR 206. j) M/s Green Power Realtors (P) Ltd. v. DCIT, Circle 11(2) (2013)34 taxmann.com 27 (Madras), Hon’ble High Court stated that “It requires under law that the assessee should be heard in the matter before concluding the proceedings and, therefore, the revenue authority is bound to offer an opportunity of being heard with law, before proceeding to pa…

Dlf Limited, Delhi vs. National Faceless Assessment Centre, Delhi

In the result, appeal of the Revenue is dismissed

ITA 676/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…which the charge was going to be imposed and given an opportunity to rebut the effect of the materials, if he can. Similar view has been expressed by the Hon’ble Supreme Court in Dhakeshwari Cotton Mills Ltd Vs CIT 26 ITR 775 and in C. Vasantlal & Co. Vs CIT 45 ITR 206. j) M/s Green Power Realtors (P) Ltd. v. DCIT, Circle 11(2) (2013)34 taxmann.com 27 (Madras), Hon’ble High Court stated that “It requires under law that the assessee should be heard in the matter before concluding the proceedings and, therefore, the revenue authority is bound to offer an opportunity of being heard with law, before proceeding to pa…

Income Tax Officer, Delhi vs. Mohd Rizwan, Delhi

ITA 3535/DEL/2025[2021-22]Status: DisposedITAT Delhi15 Oct 2025AY 2021-22

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Income Tax Officer, Delhi. (Appellant)

For Appellant: NoneFor Respondent: Shri Abhijeet Kumar, Sr. DR
Section 144Section 80C

…VISP (P) Ltd 186 CTR 717 (MP), 3. Precision Finance 208 ITR 465 (Cal), 4. Golcha Prop. Pvt Ltd 227 ITR 391 (Raj), 5. Chaturbhuj Pandey AIR 1969 (SC) 255, 6. Sumati Dayal 214 ITR 801 (SC), and 7. Sanjay Oil Cakes 316 ITR 274 (Gujarat), and 8. C VasantLal& Co. 45 ITR 206 (SC) In the case of India Woolen Carpet factory supra, the assesse failed to provide addresses of the suppliers as well as evidence to prove genuineness of the transactions. But in the present case, copies of invoices were provided and payments were made through banking channel. Relevant part of this judgement is reproduced below “4. The Assessing…

Sunil Kumar Agarwal, Jaipur vs. ACIT, Cen. Cir-2, Jaipur

In the result the appeal of the assessee in ITA no

ITA 513/JPR/2025[2016-17]Status: DisposedITAT Jaipur14 Oct 2025AY 2016-17
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Anita Rinesh, JCIT, Sr-DR
Section 132Section 139Section 153ASection 234B

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” 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 Nos. 513 & 519 to 521/JP/2025 fu/kZkj.k o"kZ@Assessment Years : 2016-17 & 2018-19 to 2020-21 cuke Sunil Kumar Agarwal ACIT, Vs. 395, Narnoli Mansion, Outside Central Circle-2, Sanganeri Gate, Jaipur Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: ABRPA9601M vihykFkhZ@Appellant izR;FkhZ@Respondent vk;dj vihy la-@ITSS No. 03/JP/2025 fu/kZkj.k…

Income Tax Officer, Jaipur vs. Pooja Kedia, Jaipuir

In the result, the appeal of the revenue is dismissed

ITA 1321/JPR/2024[2019-20]Status: DisposedITAT Jaipur07 Aug 2025AY 2019-20
For Appellant: Sh. Siddharth Ranka, Adv. &For Respondent: Sh. Gaurav Awasthi, JCIT, Sr. DR
Section 142(1)Section 147Section 148ASection 68

…f cross examination and natural justice the following decisions were relied upon by the appellant: a. Andaman Timber Industries v. CCE [2015] 62 taxmann.com 3 (SC) b. JHR. Mehta v. Asstt. CIT [2016] 72 taxmann.com 110(Bom.). C. C. Vasantial& Co. v. CIT 11962) 45 ITR 206 (SC) KishinchandChellaram v. CIT [1980] 4 Taxman 29/125 ITR 713 (SC), CIT v. Ashish International IT Appeal No. 4299 of 2009, dated 22-2-2011] d. CIT v. Ashwani Gupta [2010] 191 Taxman 51/322 ITR 396 (Bom.), State of M.P. v. Chintaman Sadashiva Vaishampayan AIR 1961 SC 1623 ix) On this issue the appellant has raised the legal issue of denial of na…

ITO 41(3)(1), Mumbai vs. Deepika Anil Agarwal, Mumbai

In the result the appeal filed by the revenue stands

ITA 1885/MUM/2025[2011-12]Status: DisposedITAT Mumbai06 Aug 2025AY 2011-12

Bench: Hon’Ble Shri Sandeep Gosain& Shri Girish Agrawal

Section 10(38)Section 132Section 132(4)Section 143Section 147Section 148Section 263Section 68

…letters from bank manager, not shown to assesse, treated amount so remitted as income from undisclosed sources—Tribunal, relying on letters of bank manager, upheld ITO's action—Whether tribunal justified-Held, on facts, no. 8. C Vasantlal& Co. vs. CIT [1962] 45 ITR 206 (SC) It was open to an income tax officer to collect materials to facilitate assessment even by private enquiry. But if he desires to use materials so collected, the assesse must be informed of the materials and must be given an adequate opportunity of explaining it. Suspicious cannot take place the evidence 1. DCIT v. Shri Rajeev G. Kalathil, (Mu…

Rajendra Kumar Mundra (HUF), Mumbai vs. National Faceless Assessment Centre (NFAC), Delhi

In the result the appeal filed by the assessee stands allowed

ITA 1000/MUM/2024[2016-17]Status: DisposedITAT Mumbai06 Aug 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain& Shri Girish Agrawalrajendra Kumar Mundra Vs. Ito, Ward 24(3)(1) (Huf) Piramal Chamber C-28, Ameya Bldg, Behind Lalbaug, Mumbai – Ymca Dn Nagar Andheri (W) 400012. 400053. Pan/Gir No.Aadh6828J (Applicant) (Respondent)

Section 147Section 148Section 2Section 263Section 68Section 69A

…29 (SC)- amount so remitted as income from undisclosed sources—Tribunal, relying on letters of bank manager, upheld ITO's action— Whether tribunal justified—Held, on facts, no. 8. C Vasantlal& Co. vs. It was open to an income tax officer to collect CIT [1962] 45 ITR 206 materials to facilitate assessment even by (SC) private enquiry. But if he desires to use materials so collected, the assesse must be informed of the materials and must be given an adequate opportunity of explaining it. Suspicious cannot take place the evidence 1. DCIT v. Shri Rajeev G. Kalathil, (Mum) (Trib) (ITA No. 6727/M/2012 dt.20/8/2014 29…

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 820/JPR/2025[2019-20]Status: DisposedITAT Jaipur25 Jul 2025AY 2019-20
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

…the statements of Sh. MukeshChoksi, which were neither supplied to assessee nor was opportunity of cross examination was provided. Ld.AO and Id.CIT(A) have denied the opportunity of cross examination relying upon following case laws: C. Vasantlal& Co. Vs. CIT 45 ITR 206: On perusal of the Hon'ble Supreme Court order, it is seen that nowhere the Hon'ble Supreme Court has held in this order that opportunity of cross examination need not be provided to the assessee even though the statement of third party has been recorded by some other officer (or even by assessing officer) that too behind the back of the assessee.…

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 819/JPR/2025[2018-19]Status: DisposedITAT Jaipur25 Jul 2025AY 2018-19
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

…the statements of Sh. MukeshChoksi, which were neither supplied to assessee nor was opportunity of cross examination was provided. Ld.AO and Id.CIT(A) have denied the opportunity of cross examination relying upon following case laws: C. Vasantlal& Co. Vs. CIT 45 ITR 206: On perusal of the Hon'ble Supreme Court order, it is seen that nowhere the Hon'ble Supreme Court has held in this order that opportunity of cross examination need not be provided to the assessee even though the statement of third party has been recorded by some other officer (or even by assessing officer) that too behind the back of the assessee.…

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 818/JPR/2025[2017-18]Status: DisposedITAT Jaipur25 Jul 2025AY 2017-18
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

…the statements of Sh. MukeshChoksi, which were neither supplied to assessee nor was opportunity of cross examination was provided. Ld.AO and Id.CIT(A) have denied the opportunity of cross examination relying upon following case laws: C. Vasantlal& Co. Vs. CIT 45 ITR 206: On perusal of the Hon'ble Supreme Court order, it is seen that nowhere the Hon'ble Supreme Court has held in this order that opportunity of cross examination need not be provided to the assessee even though the statement of third party has been recorded by some other officer (or even by assessing officer) that too behind the back of the assessee.…

Ravinder Singh Thakkar, Jaipur vs. Assistant Commssioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 817/JPR/2025[2016-17]Status: DisposedITAT Jaipur25 Jul 2025AY 2016-17
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 143(3)Section 147

…the statements of Sh. MukeshChoksi, which were neither supplied to assessee nor was opportunity of cross examination was provided. Ld.AO and Id.CIT(A) have denied the opportunity of cross examination relying upon following case laws: C. Vasantlal& Co. Vs. CIT 45 ITR 206: On perusal of the Hon'ble Supreme Court order, it is seen that nowhere the Hon'ble Supreme Court has held in this order that opportunity of cross examination need not be provided to the assessee even though the statement of third party has been recorded by some other officer (or even by assessing officer) that too behind the back of the assessee.…