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“statement under section 132(4)”

Search & SeizureSection 132(4)Section 132(4)692 judgments

The decision most relied on for statement under section 132(4) is Andaman Timber Industries v. CCE (281 CTR 241), cited in 1,335 judgments on BharatTax.

Leading authorities on statement under section 132(4)

Andaman Timber Industries v. CCE
281 CTR 241 · 2015 · Supreme Court
1,335
citing judgments

An assessee must be given an opportunity to cross-examine third parties whose statements are relied upon for adverse findings. Failure to provide this opportunity is a serious flaw rendering the order a nullity.

Pr. CIT v. Meeta Gutgutia
395 ITR 526 · 2017 · High Court
1,226
citing judgments

In search assessments under Section 153A, additions to income are permissible only if incriminating material is found during the search; in the absence of such material, completed assessments cannot be disturbed. A statement recorded under Section 132(4) and later retracted may not, on its own, constitute sufficient incriminating evidence for making additions.

PCIT v. Best Infrastructure (India) (P.) Ltd.
397 ITR 82 · 2017 · High Court
786
citing judgments

A statement recorded under Section 132(4) of the Income Tax Act, 1961, does not by itself constitute incriminating material for making additions to income.

Pullangode Rubber Produce Co. Ltd. v. State of Kerala
91 ITR 18 · 1973 · Supreme Court
666
citing judgments

Admissions, whether made through entries in account books or statements, are important pieces of evidence but are not conclusive. An assessee has the right to demonstrate that an admission made by them is incorrect or can be retracted.

Commissioner of Income Tax v. Harjeev Aggarwal
290 CTR 263 · 2016 · High Court
583
citing judgments

Assessment based solely on a statement recorded under Section 132(4) of the Income Tax Act requires the statement to be relatable to incriminating material or evidence found during the search, especially when considering Section 158BB(1) which restricts computation of undisclosed income to evidence found during search.

CIT v. S. Khader Khan Son
352 ITR 480 · 2013 · Supreme Court
581
citing judgments

Statements recorded during a survey under Section 133A do not have evidentiary value as Section 133A does not empower examination on oath. Consequently, additions to income cannot be made solely based on such uncorroborated statements without other credible evidence.

Umacharan Shaw & Bros. v. CIT
37 ITR 271 · 1959 · Supreme Court
567
citing judgments

An income tax assessment or addition cannot be sustained solely on the basis of suspicion, surmises, or conjectures, as strong suspicion does not amount to proof. The revenue authorities must rely on concrete evidence and material to frame an assessment.

Society v. UOI
394 ITR 220 · 2017 · Supreme Court
493
citing judgments

Uncorroborated loose papers or documents found during a search operation have no evidentiary value and cannot be the sole basis for determining undisclosed income. Additions based on such material require independent evidence to establish trustworthiness and a direct link to the assessee.

Judgments citing statement under section 132(4)

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7844/DEL/2025[2024-25]Status: DisposedITAT Delhi20 Mar 2026AY 2024-25

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

According to him, the said retraction did not dilute the evidentiary value of the categorical admission made by the Assessee in his statement under Section 132(4) of the Act. He submitted that the addition of Rs.86 lakhs solely on the basis of the said retracted statement as, therefore, permissible ... books of accounts produced before him. 14. Therefore, although the counsel for the Revenue may be right in his submission that a statement under Section 132(4) of the Act carries much greater weight than the statement made under Section 133A of the Act,_a_retracted statement_under Section 132

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7843/DEL/2025[2023-24]Status: DisposedITAT Delhi20 Mar 2026AY 2023-24

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 201Section 37Section 37(1)Section 69A

also in view of: The Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003, dated 02.11.2015) held: A statement under Section 132(4) may have evidentiary value; However, once retracted, it cannot be relied upon in isolation; The Assessing Officer must examine the explanation with reference

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7842/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

also in view of: The Hon’ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003, dated 02.11.2015) held:  A statement under Section 132(4) may have evidentiary value; 6 ITA-5515/Del/2025 & 13 others  However, once retracted, it cannot be relied upon in isolation;  The Assessing Officer must ... According to him, the said retraction did not dilute the evidentiary value of the categorical admission made by the Assessee in his statement under Section 132(4) of the Act. He submitted that the addition of Rs.86 lakhs solely on the basis of the said retracted statement as, therefore, permissible

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7841/DEL/2025[2021-22]Status: DisposedITAT Delhi20 Mar 2026AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

also in view of: The Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003, dated 02.11.2015) held: ➤ A statement under Section 132(4) may have evidentiary value; However, once retracted, it cannot be relied upon in isolation; The Assessing Officer must examine the explanation with reference ... According to him, the said retraction did not dilute the evidentiary value of the categorical admission made by the Assessee in his statement under Section 132(4) of the Act. He submitted that the addition of Rs.86 lakhs solely on the basis of the said retracted statement as, therefore, permissible

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7840/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

also in view of: The Hon’ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003, dated 02.11.2015) held:  A statement under Section 132(4) may have evidentiary value; 6 ITA-5515/Del/2025 & 13 others  However, once retracted, it cannot be relied upon in isolation;  The Assessing Officer must ... According to him, the said retraction did not dilute the evidentiary value of the categorical admission made by the Assessee in his statement under Section 132(4) of the Act. He submitted that the addition of Rs.86 lakhs solely on the basis of the said retracted statement as, therefore, permissible

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7839/DEL/2025[2019-20]Status: DisposedITAT Delhi20 Mar 2026AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

According to him, the said retraction did not dilute the evidentiary value of the categorical admission made by the Assessee in his statement under Section 132(4) of the Act. He submitted that the addition of Rs.86 lakhs solely on the basis of the said retracted statement as, therefore, permissible ... books of accounts produced before him. 14. Therefore, although the counsel for the Revenue may be right in his submission that a statement under Section 132(4) of the Act carries much greater weight than the statement made under Section 133A of the Act,_a_retracted statement_under Section 132

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7838/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Mar 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

also in view of: The Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003, dated 02.11.2015) held: A statement under Section 132(4) may have evidentiary value; However, once retracted, it cannot be relied upon in isolation; The Assessing Officer must examine the explanation with reference ... According to him, the said retraction did not dilute the evidentiary value of the categorical admission made by the Assessee in his statement under Section 132(4) of the Act. He submitted that the addition of Rs.86 lakhs solely on the basis of the said retracted statement as, therefore, permissible

Vestige Marketing Pvt Ltd, Delhi vs. DCIT Central Circle -05, Delhi

ITA 5521/DEL/2025[2024-25]Status: DisposedITAT Delhi20 Mar 2026AY 2024-25

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

also in view of: The Hon’ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003, dated 02.11.2015) held:  A statement under Section 132(4) may have evidentiary value; 6 ITA-5515/Del/2025 & 13 others  However, once retracted, it cannot be relied upon in isolation;  The Assessing Officer must ... According to him, the said retraction did not dilute the evidentiary value of the categorical admission made by the Assessee in his statement under Section 132(4) of the Act. He submitted that the addition of Rs.86 lakhs solely on the basis of the said retracted statement as, therefore, permissible

Vestige Marketing Pvt Ltd, Delhi vs. DCIT, Central Circle-05, Delhi

ITA 5520/DEL/2025[2023-24]Status: DisposedITAT Delhi20 Mar 2026AY 2023-24

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

also in view of: The Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003, dated 02.11.2015) held: ➤ A statement under Section 132(4) may have evidentiary value; However, once retracted, it cannot be relied upon in isolation; The Assessing Officer must examine the explanation with reference ... According to him, the said retraction did not dilute the evidentiary value of the categorical admission made by the Assessee in his statement under Section 132(4) of the Act. He submitted that the addition of Rs.86 lakhs solely on the basis of the said retracted statement as, therefore, permissible

Vestige Marketing Pvt Ltd, Delhi vs. DCIT Central Circle-05, Delhi

ITA 5519/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

According to him, the said retraction did not dilute the evidentiary value of the categorical admission made by the Assessee in his statement under Section 132(4) of the Act. He submitted that the addition of Rs.86 lakhs solely on the basis of the said retracted statement as, therefore, permissible ... books of accounts produced before him. 14. Therefore, although the counsel for the Revenue may be right in his submission that a statement under Section 132(4) of the Act carries much greater weight than the statement made under Section 133A of the Act,_a_retracted statement_under Section 132

Vestige Marketing Pvt Ltd, Delhi vs. DCIT, Central Circle- 05, Delhi

ITA 5518/DEL/2025[2021-22]Status: DisposedITAT Delhi20 Mar 2026AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

According to him, the said retraction did not dilute the evidentiary value of the categorical admission made by the Assessee in his statement under Section 132(4) of the Act. He submitted that the addition of Rs.86 lakhs solely on the basis of the said retracted statement as, therefore, permissible ... books of accounts produced before him. 14. Therefore, although the counsel for the Revenue may be right in his submission that a statement under Section 132(4) of the Act carries much greater weight than the statement made under Section 133A of the Act,_a_retracted statement_under Section 132

Vestige Marketing Pvt Ltd, Delhi vs. DCIT, Central Circle-05, Delhi

ITA 5517/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

also in view of: The Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003, dated 02.11.2015) held: ➤ A statement under Section 132(4) may have evidentiary value; However, once retracted, it cannot be relied upon in isolation; The Assessing Officer must examine the explanation with reference ... According to him, the said retraction did not dilute the evidentiary value of the categorical admission made by the Assessee in his statement under Section 132(4) of the Act. He submitted that the addition of Rs.86 lakhs solely on the basis of the said retracted statement as, therefore, permissible

Vestige Marketing Pvt Ltd, New Delhi vs. DCIT, Central Circle- 05, Delhi

ITA 5516/DEL/2025[2019-20]Status: DisposedITAT Delhi20 Mar 2026AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

also in view of: The Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003, dated 02.11.2015) held: A statement under Section 132(4) may have evidentiary value; However, once retracted, it cannot be relied upon in isolation; The Assessing Officer must examine the explanation with reference ... According to him, the said retraction did not dilute the evidentiary value of the categorical admission made by the Assessee in his statement under Section 132(4) of the Act. He submitted that the addition of Rs.86 lakhs solely on the basis of the said retracted statement as, therefore, permissible

Vestige Marketing Pvt. Ltd., Delhi vs. DCIT, Central Circle- 05, Delhi

ITA 5515/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Mar 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

also in view of: The Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003, dated 02.11.2015) held: A statement under Section 132(4) may have evidentiary value; However, once retracted, it cannot be relied upon in isolation; The Assessing Officer must examine the explanation with reference ... According to him, the said retraction did not dilute the evidentiary value of the categorical admission made by the Assessee in his statement under Section 132(4) of the Act. He submitted that the addition of Rs.86 lakhs solely on the basis of the said retracted statement as, therefore, permissible

DCIT, Central Circle-4(3), Kolkata vs. Brgd Sponge & Iron Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed and the appeal

ITA 1966/KOL/2025[2016-17]Status: DisposedITAT Kolkata26 Feb 2026AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

Section 115JSection 132(1)Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 148ASection 68

from examining the explanation offered by the assessee with reference to the books of account produced before him. Although, a statement under section 132(4) of the Act carries much greater weight than the statement made under section 133A of the Act, but a retracted statement even under section 132

Brgd Sponge & Iron Pvt. Ltd., Kolkata vs. DCIT, Central Circle 4(3), Kolkata

ITA 1403/KOL/2025[2016-2017]Status: DisposedITAT Kolkata26 Feb 2026AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

Section 115JSection 132(1)Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 148ASection 68

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRIPRADIP KUMAR CHOUBEY, JM ITA

Msn Laboratories Private Limited, Hyderabad vs. ACIT, Central Circle-2(4), Hyderabad

ITA 2304/HYD/2025[2018-19]Status: DisposedITAT Hyderabad25 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 132(4)Section 270ASection 40A(3)

books of account. The evidences found during the course of search in the case of the assessee were confronted and a statement under section 132(4) of the Act was recorded from Sri B Buchi Reddy. The statement recorded from the Cashier was put before the M.D. of the assessee

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1884/HYD/2025[2021-22]Status: DisposedITAT Hyderabad18 Feb 2026AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 132(4)Section 143(1)Section 143(3)Section 148

years. The incriminating material found during the course of search were confronted to Shri Ramesh Kumar Sanaka, Sr. Accounts Manager and a statement under section 132(4) of the Act has been recorded. In his statement, of Shri Ramesh Kumar Sanaka, Sr. Accounts Manager explained that the transactions recorded

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1876/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 132(4)Section 143(1)Section 143(3)Section 148

years. The incriminating material found during the course of search were confronted to Shri Ramesh Kumar Sanaka, Sr. Accounts Manager and a statement under section 132(4) of the Act has been recorded. In his statement, of Shri Ramesh Kumar Sanaka, Sr. Accounts Manager explained that the transactions recorded

Assistant Commissioner of Income Tax, Central Circle, Bareilly vs. Ankur Anand, Bareilly

Appeals of the Department stand dismissed

ITA 337/LKW/2025[2015-16]Status: DisposedITAT Lucknow13 Feb 2026AY 2015-16

Bench: Shri Sudhanshu Srivastava & Shri Nikhil Choudharyit(Ss) A Nos.336 & 337/Lkw/2025 Assessment Years: 2014-15 & 2015-16 Acit, Central Circle, Bareilly Vs. Ankur Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Agppa4219C (Appellant) (Respondent) It(Ss)A No.334/Lkw/2025 Assessment Year:2015-16 Acit, Central Circle, Bareilly Vs. Mohit Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Abupa3002H (Appellant) (Respondent)

For Appellant: Shri Neeraj Kumar, CIT (DR)For Respondent: Shri Rakesh Garg, Advocate
Section 10(38)Section 132Section 143(3)Section 153ASection 68

search I.T(SS).A. Nos. 336 & 337/LKW/2025 IT(SS).A. No.334/LKW/2025 6 proceedings in the case of the assessee. and assessee’s statement under section 132(4) of the Act was also recorded on this issue. 4. Whether on the facts and circumstances of the case ... found in digital form were found and seized during the search proceedings in the case of the assessee, and assessees statement under section 132(4) of the Act was also recorded on this issue. 4. Whether on facts and circumstances of the case