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“tangible material”

ReassessmentSection 147Section 1472,812 judgments

The decision most relied on for tangible material is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on tangible material

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.
291 ITR 500 · 2007 · Supreme Court
1,030
citing judgments

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

CIT v. Kelvinator of India Ltd.
256 ITR 1 · 2002 · High Court
439
citing judgments

An Assessing Officer cannot reopen an assessment under Section 147 based on a mere change of opinion regarding the same material available during the original assessment. Reopening requires fresh, tangible material or information that leads to a reason to believe income has escaped assessment.

CIT v. Orient Craft Ltd.
354 ITR 536 · 2013 · High Court
366
citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

PCIT v. RMG Polyvinyl (I) Ltd.
396 ITR 5 · 2017 · High Court
272
citing judgments

Reassessment based solely on information from the Investigation Wing, without the Assessing Officer conducting further inquiry or demonstrating an independent application of mind, is unjustified and invalid.

CIT v. Foramer France
264 ITR 566 · 2003 · Supreme Court
253
citing judgments

Reassessment proceedings initiated under Section 147 beyond four years from the end of the relevant assessment year are invalid unless the assessee failed to disclose fully and truly all material facts necessary for assessment. Without such failure, the notice issued under Section 148 is time-barred and without jurisdiction.

Haryana Acrylic Manufacturing Company v. CIT
308 ITR 38 · 2009 · High Court
248
citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

Judgments citing tangible material

Smt. Satyawati Marwaha Through Legal Heir Sh, Chander Sheikhar Marwaha, Jalandhar vs. Assistant Commissioner of Income Tax, Jalandhar

In the result, the appeal for Asstt

ITA 347/ASR/2024[2015-16]Status: DisposedITAT Amritsar30 Oct 2025AY 2015-16

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashray Sarna, C. A
Section 10(38)Section 132Section 144Section 144rSection 147Section 148Section 151Section 250(6)Section 68

basis of the "reason" recorded is vitiated. Thus, the reasons recorded are incorrect and vague and not based on any tangible material and merely based on borrowed satisfaction from investigation wing, it does not have live nexus with the formation of belief. It was at best a suspicion and therefore

Smt. Satyawati Marwaha Through Legal Heir Sh. Chander Sheikhar Marwaha, Jalandhar vs. Assistant Commissioner of Income Tax, Jalandhar

In the result, the appeal for Asstt

ITA 346/ASR/2024[2014-15]Status: DisposedITAT Amritsar30 Oct 2025AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashray Sarna, C. A
Section 10(38)Section 132Section 144Section 144rSection 147Section 148Section 151Section 250(6)Section 68

basis of the "reason" recorded is vitiated. Thus, the reasons recorded are incorrect and vague and not based on any tangible material and merely based on borrowed satisfaction from investigation wing, it does not have live nexus with the formation of belief. It was at best a suspicion and therefore

Jitendrakumar Ambelal Patel, Na vs. Arivs.ITO, Ward-3, Navsari

In the result, the appeal of the assessee is partly allowed for e appeal of the assessee is partly allowed for statistical purposes

ITA 660/SRT/2025[2009-10]Status: DisposedITAT Surat30 Oct 2025AY 2009-10

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2009-2010 Jitendrakumarambelal Patel Ito, Ward-3, 52, Kanbiwad. At & Po-Pananj, Room No. 108, Swapnalok Soc., Tal-Chikhli, Navsari-396521 Vs. Near Kaliawadi Bridge, Navsari - 396521 Pan No. Bncpp 7509 R Appellant Respondent

For Appellant: Shri J. K. Chandnani, Sr. DRFor Respondent: Shri P M Jagasheth, CA
Section 147Section 148Section 271(1)(c)

Officer has duly recorded cogent and specific reasons, has duly recorded cogent and specific reasons, has duly recorded cogent and specific reasons, founded upon tangible material that came to his possession, founded upon tangible material that came to his possession, founded upon tangible material that came to his possession, thereby ... information, in our considered by the Investigation Wing. Such information, in our considered by the Investigation Wing. Such information, in our considered opinion, constitutes tangible material sufficient to trigger the opinion, constitutes tangible material sufficient to trigger the opinion, constitutes tangible material sufficient to trigger the jurisdictional satisfaction envisaged under

Sanjay Sivabhagwan Keyal, Surat vs. ITO, Ward-2(3)(4), Surat

In the result, the appeal of the assessee is dismissed

ITA 636/SRT/2025[2009-10]Status: DisposedITAT Surat30 Oct 2025AY 2009-10

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2009-2010 Sanjay Sivabhagwan Keyal Ito, Ward – 2(3)(4), Flat No.304, 3Rd Floor, Room No.613, Vatika Township, Near Model, Vs. Aaaykar Bhavan, Township, Parvat Patia Majura Gate, Surat - 395010. Surat - 395002. Pan No. Adspk 6097N Appellant Respondent

For Appellant: Shri J.K. Chandnani, Sr. DRFor Respondent: Mr. Rasesh, CA
Section 144Section 148Section 69A

contra, supported the orders supported the orders of the lower authorities, contending that the of the lower authorities, contending that the Assessing Officer had tangible material, namely AIR information, Assessing Officer had tangible material, namely AIR information, Assessing Officer had tangible material, namely AIR information, duly verified with the return

Bachraj Chhotelal Mehta, Surat vs. Income Tax Officer, Ward-2(3)(8), Surat

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

ITA 529/SRT/2025[2008-09]Status: DisposedITAT Surat30 Oct 2025AY 2008-09

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2008-2009 Bachraj Chhotelal Mehta, Ito Ward-2(3)(8), C-3, 3Rd Floor, Antwerp Park, 619, Aayakar Bhavan, Majura Apartment, Kansara Sheri, Vs. Gate, Mahidharpura, Surat-395001. Surat-395003. Pan No. Afrpm 7809 R Appellant Respondent

For Respondent: Mr. Jay Thakkar, CA
Section 144Section 147Section 148Section 156

u/s.148 in absence of AO erred in issuing the notice u/s.148 in absence of AO erred in issuing the notice u/s.148 in absence of tangible material and reason to believe that income tangible material and reason to believe that income tangible material and reason to believe that income chargeable

Ranjana Jatwani, Faridabad vs. Ward 2(1), Fbd, Faridabad

Appeal is allowed

ITA 6051/DEL/2025[2014-15 ]Status: DisposedITAT Delhi30 Oct 2025

Bench: Sh. Satbeer Singh Godaraita No. 6051/Del/2025 : Asstt. Year : 2014-15 Ranjana Jatwani, Vs Income Tax Officer, H. No. 1497, Sector-14, Ward-2(1), Faridabad, Haryana-121001 Faridabad-121001 (Appellant) (Respondent) Pan No. Aaopj9934A Assessee By: Sh. Charitra Gupta, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 30.10.2025 Date Of Pronouncement: 30.10.2025 Order

For Appellant: Sh. Charitra Gupta, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 148

authorities have erred in law and on facts in setting into motion the impugned reopening u/s 148/147 of the Act without there being any tangible material indicating her to have made investments in question amounting to Rs.24,08,000/- with M/s Piyus Group. The Revenue could hardly dispute that ... tribunal hereby concludes that both the lower authorities have erred in law and on facts in initiating the impugned reopening for want of any tangible material in light of PCIT Vs. K.R. Pulp and Papers Ltd. (2025) 175 taxmann.com 278 (Del.) which stands quashed in very terms therefore

Uday Punj, Delhi vs. DCIT, Circle-19(1), Delhi

In the result, the reassessment proceedings initiated in this case is bad in law

ITA 3087/DEL/2025[2013-14]Status: DisposedITAT Delhi30 Oct 2025AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Uday Punj, Vs. Dcit, Circle 19 (1), Chimes, New Delhi. 55, Sultanpur Farms, New Delhi – 110 030. (Pan : Aaapp1309F) (Appellant) (Respondent) Assessee By : Shri Rahul Khare, Advocate Revenue By : Shri Om Prakash, Sr. Dr Date Of Hearing : 17.09.2025 Date Of Order : 30.10.2025 Order Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income-Tax (Appeals)-29, New Delhi [For Short ‘Ld. Cit (A)] Dated 18.03.2025 For Assessment Year 2013-14 Raising Following Grounds Of Appeal :- “1. That Learned Cit-A Erred In Fact & In Law In Confirming The Reopening Of The Case U/S 147/148 Without Appreciating The Facts Which Is Not Only Bad In Law But Also Against The Facts & Circumstances Of The Case.

For Appellant: Shri Rahul Khare, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 143Section 143(3)Section 147Section 148Section 73

income chargeable to tax had escaped assessment for such an AY. Further, there ought to be a live link / rational nexus between the tangible material in the possession of the AO and formation of belief that the income chargeable to tax of the Assessee had escaped taxation for the relevant ... losses ,which was duly responded by the Assessee vide its submission dated 15.10.2015 (please refer page no.10/11/15 of the paper book). Further, no new / tangible material was brought on record by the AO evidencing that on such concluded issues, the income chargeable to tax of the Appellant had escaped assessment

Kajal Batra, Delhi vs. ACIT, Circle-52(1), Delhi

In the result, the appeal of the assessee stands dismissed as above

ITA 2419/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 147Section 148Section 151Section 68Section 69A

bank account and there was no rationale for inferring the entire bank deposits/credits as income. It was contended that there was no tangible material in the Ld. AO’s possession except the information available on ITD/ITBA/Insight Portal of the Income Tax Department as the Ld. AO had failed to demonstrate

Naranji Rajaram Dave, Porbandar vs. Income-Tax Officer, Ward-2(3), Porbandar, Gujarat

In the result, the appeal of the assessee is allowed

ITA 822/RJT/2024[2017-18]Status: DisposedITAT Rajkot29 Oct 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 822/Rjt/2024 ("नधा"रणवष"/Assessment Year: (2017-18) Naranji Rajaram Dave, Income Tax Officer, Wd -2(3), Vs. Porbandar-360575 17, 17 Naranji Rajaram Dave, Suttar Vada, Porbandar, Suttar Vada, Porbandar-360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acjpd8823B (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Sagar Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 133(6)Section 139Section 143(2)Section 143(3)Section 250Section 60

documents submitted during the course of assessment proceedings. Further, ld.Counsel stated that the addition made by the assessing officer was without bringing any tangible material on record and based on assumptions and presumptions. The ld.Counsel has stated that the assessing officer 4 Naranji R. Dave had failed to consider

Unimed Technologies Limited, Halol vs. The Asstt. Commissioner of Income Tax, Circle-2(1)(1), Vadodara

In the result, the Departmental appeal is dismissed for AY 2017-18

ITA 1425/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad29 Oct 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Sher Singh, CIT-DR &
Section 115JSection 143(3)Section 250Section 263

remains unchanged, a different view should not ordinarily be taken. The learned Departmental Representative, despite raising general objections, could not bring on record any tangible material or fact to controvert the above position. No evidence has been placed before us to show that the expenditure led to acquisition

Assistant Commissioner of Incometax, Race Course, Vadodara vs. Unimed Technologies Limited, Halol Panchmahal

In the result, the Departmental appeal is dismissed for AY 2017-18

ITA 1423/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad29 Oct 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Sher Singh, CIT-DR &
Section 115JSection 143(3)Section 250Section 263

remains unchanged, a different view should not ordinarily be taken. The learned Departmental Representative, despite raising general objections, could not bring on record any tangible material or fact to controvert the above position. No evidence has been placed before us to show that the expenditure led to acquisition

Audumbar Sadguru Niwas Foundation, Parbhani vs. CIT (Exemption), Pune

In the result, both the appeals in ITA Nos

ITA 1035/PUN/2025[2026-27]Status: DisposedITAT Pune29 Oct 2025AY 2026-27

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Shubham N. RathiFor Respondent: Shri Amol Khairnar
Section 12ASection 12A(1)(ac)Section 80G

bills/invoices of expenditure on each activity, photographs, cuttings etc has been furnished to prove the genuineness of activities. In absence of any such tangible material in respect of proof of activities being carried out it is not possible to arrive at any conclusion about the genuineness of activities and also

Audumbar Sadguru Niwas Foundation, Pune vs. CIT (Exemption), Pune

In the result, both the appeals in ITA Nos

ITA 1034/PUN/2025[2026-27]Status: DisposedITAT Pune29 Oct 2025AY 2026-27

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Shubham N. RathiFor Respondent: Shri Amol Khairnar
Section 12ASection 12A(1)(ac)Section 80G

bills/invoices of expenditure on each activity, photographs, cuttings etc has been furnished to prove the genuineness of activities. In absence of any such tangible material in respect of proof of activities being carried out it is not possible to arrive at any conclusion about the genuineness of activities and also

Satish Vishnu Thombare, Income Tax Officer, Ward-1, Ahmednagar vs. Varsha Prafulla Zende, Ahmednagar

In the result, the appeal of the Revenue is dismissed

ITA 1656/PUN/2024[2010-11]Status: DisposedITAT Pune29 Oct 2025AY 2010-11

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1656/Pun/2024 धििाारण वर्ा / Assessment Year : 2010-11 Satish Vishnu Thombare, Varsha Prafulla Zende, Income Tax Officer, Prop Of Bleach Chem Enterprises, Ward-1, Ahmednagar Vs. Industrial Estate, Shrirampur, Maharashtra-413709 Pan : Aabpz2541C अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Miss Shivani Shah (Virtual) Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order

For Appellant: Miss Shivani Shah (Virtual)For Respondent: Shri Akhilesh Srivastva
Section 132(1)Section 147Section 148Section 151Section 68

reopening of assessment, stating that the notice issued under Section 148 was issued merely based on a change of opinion without any fresh or tangible material on record. It is also stated that the notice under Section 148 had been issued without prior sanction under Section ... been disposed of. On 29/11/2019, Respondent No.1 passed the order of disposing of objections holding that notice under Section 147 is based on tangible material. 8. Petitioner has filed the present petition for the reliefs stated above. This Court, on 18/12/2019, granted time to Respondents to file a reply. However

Anoop Jain HUF, Delhi vs. Joint Commissioner of Income Tax (OSD), Central Circle - 1, Noida

In the result, appeal of the assessee is allowed

ITA 4043/DEL/2025[2013-14]Status: DisposedITAT Delhi29 Oct 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2013-14] Ritu Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1 Market, New Delhi-110001 Noida Pan-Aampj9586C Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aadpj2136K Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Huf Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aaaha6321A Appellant Respondent Appellant By Shri S.K.Tulsian, Adv. & Shri Bhoomija Verma, Adv. Respondent By Shri Mahes Kumar, Cit Dr Date Of Hearing 03.09.2025 Date Of Pronouncement 29.10.2025 Order

Section 115BSection 127Section 132Section 139Section 142Section 142(1)Section 142(2)Section 142(3)Section 143(2)Section 153A

ITA No.4038/Del/2018 & Others THE INCOME TAX APPELLATE TRIBUNAL DELHI “G” BENCH: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER

Anoop Jain, Delhi vs. Joint Commissioner of Income Tax (OSD), Central Circle - 1, Noida

In the result, appeal of the assessee is allowed

ITA 4042/DEL/2025[2013-14]Status: DisposedITAT Delhi29 Oct 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2013-14] Ritu Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1 Market, New Delhi-110001 Noida Pan-Aampj9586C Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aadpj2136K Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Huf Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aaaha6321A Appellant Respondent Appellant By Shri S.K.Tulsian, Adv. & Shri Bhoomija Verma, Adv. Respondent By Shri Mahes Kumar, Cit Dr Date Of Hearing 03.09.2025 Date Of Pronouncement 29.10.2025 Order

Section 115BSection 127Section 132Section 139Section 142Section 142(1)Section 142(2)Section 142(3)Section 143(2)Section 153A

ITA No.4038/Del/2018 & Others THE INCOME TAX APPELLATE TRIBUNAL DELHI “G” BENCH: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER

Ritu Jain, Delhi vs. Joint Commissioner of Income Tax (OSD), CC - 1, Noida

In the result, appeal of the assessee is allowed

ITA 4038/DEL/2025[2013-14]Status: DisposedITAT Delhi29 Oct 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2013-14] Ritu Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1 Market, New Delhi-110001 Noida Pan-Aampj9586C Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aadpj2136K Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Huf Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aaaha6321A Appellant Respondent Appellant By Shri S.K.Tulsian, Adv. & Shri Bhoomija Verma, Adv. Respondent By Shri Mahes Kumar, Cit Dr Date Of Hearing 03.09.2025 Date Of Pronouncement 29.10.2025 Order

Section 115BSection 127Section 132Section 139Section 142Section 142(1)Section 142(2)Section 142(3)Section 143(2)Section 153A

ITA No.4038/Del/2018 & Others THE INCOME TAX APPELLATE TRIBUNAL DELHI “G” BENCH: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER

Mali Ram Yadav, Therkyo Ki Dhani vs. ITO, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1110/JPR/2025[2017-18]Status: DisposedITAT Jaipur28 Oct 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं. / ITA No. 1110/JPR/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Shri Mali Ram Yadav Thekryo Ki Dhani, Village & Post: Jahota, Tehsil: Amer Distt: Jaipur 303 701 बनाम Vs. The ITO Ward - 7(2) Jaipur प्रत्यर्थी / Respondent स्थायी लेखा सं. / जीआईआर सं. / PAN/GIR No.: ABJPY 6715A अपीलार्थी / Appellant निर्धारिती की ओर से / Assesseeby : Shri Rakesh Kumar Kabra, CA Mrs. Prachela Kabra, CA राजस्व की ओर से /

For Appellant: Shri Rakesh Kumar Kabra, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 144Section 147Section 148Section 148ASection 234ASection 69

Rajesh Jhaveri Stock Brokers (P) Ltd. [(2007) 291 ITR 500 (SC)] held that the AO is empowered to reopen an assessment if there is tangible material to form a belief that income has escaped assessment. In the present case, the AO had tangible material regarding the purchase of immovable property

DCIT, Central Circle-8(1), Mumbai vs. Ei Resorts & Clubs Pvt Ltd, Mumbai

3213/Mum/2025

ITA 3926/MUM/2025[2020-21]Status: DisposedITAT Mumbai28 Oct 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

placed reliance on an array of judicial precedents to fortify his argument that a retracted statement, standing alone and unsupported by any tangible material, lacks evidentiary sanctity and cannot form the sole basis of addition. 22. The AR pointed out that the AO did not bother to analyze and evaluate

DCIT, Central Circle-8(1), Mumbai vs. E I Resorts and Clubs Pvt Ltd, Mumbai

3213/Mum/2025

ITA 3886/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Oct 2025AY 2012-13

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

placed reliance on an array of judicial precedents to fortify his argument that a retracted statement, standing alone and unsupported by any tangible material, lacks evidentiary sanctity and cannot form the sole basis of addition. 22. The AR pointed out that the AO did not bother to analyze and evaluate