← All Phrases

“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)

Ajay Bakliwal, Kota vs. ACIT, Central Cirle, Kota

In the result, the appeal of the assessee is partly allowed

ITA 1277/JPR/2024[2015-16]Status: DisposedITAT Jaipur11 Apr 2025AY 2015-16
For Appellant: Shri Rajendra SisodiaFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 132Section 132(1)Section 132(4)Section 139Section 143(3)Section 153ASection 250

judgment of Pullangode Rubber Produce Co. Ltd. v. State of Kerala [1973] 91 ITR 0018, the legal position in relation to a statement under section 132(4) of the Income-tax Act, 1961 was set out as under: - a. An admission is an extremely important piece of evidence though

Ajay Bakliwal, Kota vs. ACIT, Central Circle, Kota

ITA 1276/JPR/2024[2014-15]Status: DisposedITAT Jaipur11 Apr 2025AY 2014-15
For Appellant: Shri Rajendra SisodiaFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 132Section 132(1)Section 132(4)Section 139Section 143(3)Section 153ASection 250

judgment of Pullangode Rubber Produce Co. Ltd. v. State of Kerala [1973] 91 ITR 0018, the legal position in relation to a statement under section 132(4) of the Income-tax Act, 1961 was set out as under: a. An admission is an extremely important piece of evidence though

Subhash Chander Gupta, H.No. 16528 Vishnu Colony, Raliway Road, Kurukshetra, Haryana vs. Joint Commissioner of Income Tax, Kurukshetra

In the result, both appeals of the assessee are

ITA 768/CHANDI/2024[2011-2012]Status: DisposedITAT Chandigarh07 Apr 2025AY 2011-2012

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Abhinav Gupta, AdvocateFor Respondent: Smt. Kusum Bansal, CIT, DR
Section 143(2)Section 148Section 153C

statement recorded under Section 132(4) and such presumption could bind the deponent who has made such declaration. In a statement under Section 132(4), it cannot bind a third person. The assessee has repeatedly requested for an opportunity to cross examine the alleged witness Shri Sushil Kumar

Subhash Chander Gupta, H.No. 1652 8 Vishnu Colony, Railway Road, Kurukshetra, Haryana vs. ITO Ward-3, Kurukshetra, Haryana

In the result, both appeals of the assessee are

ITA 765/CHANDI/2024[2011-2012]Status: DisposedITAT Chandigarh07 Apr 2025AY 2011-2012

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Abhinav Gupta, AdvocateFor Respondent: Smt. Kusum Bansal, CIT, DR
Section 143(2)Section 148Section 153C

statement recorded under Section 132(4) and such presumption could bind the deponent who has made such declaration. In a statement under Section 132(4), it cannot bind a third person. The assessee has repeatedly requested for an opportunity to cross examine the alleged witness Shri Sushil Kumar

Smt. Jasmine Shah Srivastava, Bengaluru vs. Assistant Commissioner of Income-Tax, (International Taxation), Circle-2(2), Bengaluru

In the result, appeal filed by the assessee is allowed

ITA 615/BANG/2023[2011-12]Status: DisposedITAT Bangalore28 Mar 2025AY 2011-12

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2011-12

For Appellant: Shri. V. Chandrashekar, AdvocateFor Respondent: Shri. Subramanian S, Addl. CIT(DR)(ITAT), Bangalore
Section 131Section 132Section 132(4)Section 143(3)Section 147Section 148Section 153C

contained the details of the daily activity of Smt. MamtaAjila. On the day of search, Smt. Mamta was not in station and statement under section 132(4) of the Act from Shri. Ashwin Ajila, the husband of Smt. Mamta Ajila on the day of search and seizure and confirmed that

Jaipal Singh, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

Appeal of the assessee are disposed off

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

attempt should be made to obtain confession as to any disclosed income. Circumstances in which the assessee had to give the statements under Section 132(4) and/or under Section 131 of the Act have been explained in the affidavit filed on 20.05.2013. The very fact that the search continued ... assessee whereby cash, jewellery, books of account and certain documents were found and seized Assessee on same day had given a statement under section 132(4) where under admissions with regard to unaccounted income of Rs.6.20 lakhs were made - Said unaccounted income consisted of marriage expenditure, unexplained household expenditure

Jaipal Singh, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

Appeal of the assessee are disposed off

ITA 119/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Mar 2025AY 2017-18
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

attempt should be made to obtain confession as to any disclosed income. Circumstances in which the assessee had to give the statements under Section 132(4) and/or under Section 131 of the Act have been explained in the affidavit filed on 20.05.2013. The very fact that the search continued ... assessee whereby cash, jewellery, books of account and certain documents were found and seized Assessee on same day had given a statement under section 132(4) where under admissions with regard to unaccounted income of Rs.6.20 lakhs were made - Said unaccounted income consisted of marriage expenditure, unexplained household expenditure

Jaipal Singh, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

Appeal of the assessee are disposed off

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

attempt should be made to obtain confession as to any disclosed income. Circumstances in which the assessee had to give the statements under Section 132(4) and/or under Section 131 of the Act have been explained in the affidavit filed on 20.05.2013. The very fact that the search continued ... assessee whereby cash, jewellery, books of account and certain documents were found and seized Assessee on same day had given a statement under section 132(4) where under admissions with regard to unaccounted income of Rs.6.20 lakhs were made - Said unaccounted income consisted of marriage expenditure, unexplained household expenditure

Jaipal Singh, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

Appeal of the assessee are disposed off

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

attempt should be made to obtain confession as to any disclosed income. Circumstances in which the assessee had to give the statements under Section 132(4) and/or under Section 131 of the Act have been explained in the affidavit filed on 20.05.2013. The very fact that the search continued ... assessee whereby cash, jewellery, books of account and certain documents were found and seized Assessee on same day had given a statement under section 132(4) where under admissions with regard to unaccounted income of Rs.6.20 lakhs were made - Said unaccounted income consisted of marriage expenditure, unexplained household expenditure

Jaipal Singh, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

Appeal of the assessee are disposed off

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

attempt should be made to obtain confession as to any disclosed income. Circumstances in which the assessee had to give the statements under Section 132(4) and/or under Section 131 of the Act have been explained in the affidavit filed on 20.05.2013. The very fact that the search continued ... assessee whereby cash, jewellery, books of account and certain documents were found and seized Assessee on same day had given a statement under section 132(4) where under admissions with regard to unaccounted income of Rs.6.20 lakhs were made - Said unaccounted income consisted of marriage expenditure, unexplained household expenditure

ACIT CC -6(1), Mumbai, Bkc vs. Sanjay Dagadu Deshpute, Nasik

In the result, appeal of the Revenue is dismissed

ITA 5680/MUM/2024[2021-22]Status: DisposedITAT Mumbai11 Mar 2025AY 2021-22

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri Rashmikant Modi / KetkiFor Respondent: Shri Dr. Kishor Dhule, CIT-DR
Section 132Section 132(4)Section 148Section 69C

statements of Shri Shailendra Rathi recorded during the course of search. Shri Ravi Wadepalle an employee of Rucha Group in his statement under section 132(4) of the Act stated that some of the documents belonging to 3 ITA No.5680/Mum/2024 - Sanjay Dagadu Deshpute Rucha Group were kept at the premises

Raj Kumar Golecha, Pali vs. Assistant Commissioner of Income Tax, Central Circle-2, Jodhpur, Aaykar Bhawan

Appeal of the assessee is allowed

ITA 515/JODH/2023[2014-15]Status: DisposedITAT Jodhpur10 Mar 2025AY 2014-15
Section 10(38)Section 132Section 132(4)Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 250

premises of the Group searched. Some loose papers were seized from the residence of Shri LabhchandGolecha (father of the assesseed) and his statement under section 132(4) of the IT Act was also recorded. Notice under section 153A of the IT Act was issued on 04.07.2016 for filing the return

Vasireddy Vidya Sagar, Guntur vs. The Deputy Commissioner of Income Tax, Central Circle -1, Guntur

ITA 526/VIZ/2024[2020-21]Status: DisposedITAT Visakhapatnam07 Mar 2025AY 2020-21

Bench: Shri K. Narasimha Chary, Hon'Ble & Shri S Balakrishnan, Hon'Bleआयकर अपीलसं./I.Τ.Α.Nos.524, 525 & 526/Viz/2024 (निर्धारण वर्ष/ Assessment Years: 2014-15, 2019-20 & 2020-21) Vasireddy Vidya Sagar D.No. 5-37-44/2, Kalangi Complex 4/7, Brodipet, Guntur - 522002 [Pan: Agzps2420F] V. Dcit – Central Circle – 1 Income Tax Office Lakshmipuram Main Road Guntur - 522006 Andhra Pradesh (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By Shri Mv Prasad, Ca Dr. Aparna Villuri, Sr.Ar सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/Date Of Pronouncement 19.02.2025 07.03.2025 आदेश /Order Per Shri S Balakrishnan: 1. These Appeals Are Filed By The Assessee Against Different Orders Of Learned Commissioner Of Income Tax (Appeals), Visakhapatnam – 3 [Hereinafter In Short "Ld.Cit(A)"] Vide Respective Din & Order No. As Stated Below:-

Section 115BSection 132(4)Section 142(1)Section 153C

payment of Rs. 11,17,507/- on 29.03.2014 to M/s.Polisetty Somasundaram. Ld. AO found that in the sworn statement under section 132(4) of the Act, Managing Partner of M/s. Polisetty Somasundaram has stated that cash payments made to the assessee are cash loans and the amount received with interest

Vasireddy Vidya Sagar, Guntur vs. The Deputy Commissioner of Income Tax, Central Circle-1, Guntur

ITA 525/VIZ/2024[2019-20]Status: DisposedITAT Visakhapatnam07 Mar 2025AY 2019-20

Bench: Shri K. Narasimha Chary, Hon'Ble & Shri S Balakrishnan, Hon'Bleआयकर अपीलसं./I.Τ.Α.Nos.524, 525 & 526/Viz/2024 (निर्धारण वर्ष/ Assessment Years: 2014-15, 2019-20 & 2020-21) Vasireddy Vidya Sagar D.No. 5-37-44/2, Kalangi Complex 4/7, Brodipet, Guntur - 522002 [Pan: Agzps2420F] (अपीलार्थी/ Appellant) V. Dcit – Central Circle – 1 Income Tax Office Lakshmipuram Main Road Guntur - 522006 Andhra Pradesh (प्रत्यर्थी/ Respondent) करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/Date Of Pronouncement : Shri Mv Prasad, Ca : Dr. Aparna Villuri, Sr.Ar 19.02.2025 07.03.2025 आदेश /Order Per Shri S Balakrishnan: 1. These Appeals Are Filed By The Assessee Against Different Orders Of Learned Commissioner Of Income Tax (Appeals), Visakhapatnam – 3 [Hereinafter In Short "Ld.Cit(A)"] Vide Respective Din & Order No. As Stated Below:-

Section 115BSection 132(4)Section 142(1)Section 153C

payment of Rs. 11,17,507/- on 29.03.2014 to M/s.Polisetty Somasundaram. Ld. AO found that in the sworn statement under section 132(4) of the Act, Managing Partner of M/s. Polisetty Somasundaram has stated that cash payments made to the assessee are cash loans and the amount received with interest

Vasireddy Vidya Sagar, Guntur vs. The Deputy Commissioner of Income Tax, Central Circle-1, Guntur

ITA 524/VIZ/2024[2014-15]Status: DisposedITAT Visakhapatnam07 Mar 2025AY 2014-15

Bench: Shri K. Narasimha Chary, Hon'Ble & Shri S Balakrishnan, Hon'Bleआयकर अपीलसं./I.Τ.Α.Nos.524, 525 & 526/Viz/2024 (निर्धारण वर्ष/ Assessment Years: 2014-15, 2019-20 & 2020-21) Vasireddy Vidya Sagar V. Dcit – Central Circle – 1 D.No. 5-37-44/2, Kalangi Complex 4/7, Brodipet, Guntur - 522002 [Pan: Agzps2420F] (अपीलार्थी/ Appellant) Income Tax Office Lakshmipuram Main Road Guntur - 522006 Andhra Pradesh (प्रत्यर्थी/ Respondent) करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By Shri Mv Prasad, Ca Dr. Aparna Villuri, Sr.Ar सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing 19.02.2025 घोषणा की तारीख/Date Of Pronouncement 07.03.2025 आदेश /Order Per Shri S Balakrishnan: 1. These Appeals Are Filed By The Assessee Against Different Orders Of Learned Commissioner Of Income Tax (Appeals), Visakhapatnam – 3 [Hereinafter In Short "Ld.Cit(A)"] Vide Respective Din & Order No. As Stated Below:-

Section 115BSection 132(4)Section 142(1)Section 153CSection 65B

payment of Rs. 11,17,507/- on 29.03.2014 to M/s.Polisetty Somasundaram. Ld. AO found that in the sworn statement under section 132(4) of the Act, Managing Partner of M/s. Polisetty Somasundaram has stated that cash payments made to the assessee are cash loans and the amount received with interest

Vemuluri Naga Bhushanam, Hyderabad vs. The Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result appeal of the assessee is allowed

ITA 500/VIZ/2024[2020-21]Status: DisposedITAT Visakhapatnam27 Feb 2025AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.496, 497, 498, 499 & 500/Viz/2024 (निर्धारण वर्ा/ Assessment Years: 2016-17, 2017-18, 2018-19, 2019-20 & 2020-21) Vemuluri Naga Bhushanam V. Dcit – Central Circle – 1(1) D.No.8-2-293/82/A/1149 Income Tax Office Road No. 36 Lakshmipuram Main Road Jubilee Hills, Hyderabad – 500033 Guntur – 522006 Telangana Andhra Pradesh [Pan: Abipv2941A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 115BSection 132(4)Section 142(1)Section 153C

payment of Rs. 1,66,47,945/- to M/s.Polisetty Somasundaram. Ld. AO found that in the sworn statement under section 132(4) Mr. P. Shyam Sundhar, Managing Partner of M/s. Polisetty Somasundaram has stated that cash payments made to the assessee are cash loans and the amount received with interest

Vemuluri Naga Bhushanam, Hyderabad vs. The Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result appeal of the assessee is allowed

ITA 499/VIZ/2024[2019-20]Status: DisposedITAT Visakhapatnam27 Feb 2025AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.496, 497, 498, 499 & 500/Viz/2024 (निर्धारण वर्ा/ Assessment Years: 2016-17, 2017-18, 2018-19, 2019-20 & 2020-21) Vemuluri Naga Bhushanam V. Dcit – Central Circle – 1(1) D.No.8-2-293/82/A/1149 Income Tax Office Road No. 36 Lakshmipuram Main Road Jubilee Hills, Hyderabad – 500033 Guntur – 522006 Telangana Andhra Pradesh [Pan: Abipv2941A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 115BSection 132(4)Section 142(1)Section 153C

payment of Rs. 1,66,47,945/- to M/s.Polisetty Somasundaram. Ld. AO found that in the sworn statement under section 132(4) Mr. P. Shyam Sundhar, Managing Partner of M/s. Polisetty Somasundaram has stated that cash payments made to the assessee are cash loans and the amount received with interest

Vemuluri Naga Bhushanam, Hyderabad vs. The Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result appeal of the assessee is allowed

ITA 498/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam27 Feb 2025AY 2018-19

Bench: Shri Laliet Kumar, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.496, 497, 498, 499 & 500/Viz/2024 (निर्धारण वर्ा/ Assessment Years: 2016-17, 2017-18, 2018-19, 2019-20 & 2020-21) Vemuluri Naga Bhushanam V. Dcit – Central Circle – 1(1) D.No.8-2-293/82/A/1149 Income Tax Office Road No. 36 Lakshmipuram Main Road Jubilee Hills, Hyderabad – 500033 Guntur – 522006 Telangana Andhra Pradesh [Pan: Abipv2941A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 115BSection 132(4)Section 142(1)Section 153C

payment of Rs. 1,66,47,945/- to M/s.Polisetty Somasundaram. Ld. AO found that in the sworn statement under section 132(4) Mr. P. Shyam Sundhar, Managing Partner of M/s. Polisetty Somasundaram has stated that cash payments made to the assessee are cash loans and the amount received with interest

Vemuluri Naga Bhushanam, Hyderabad vs. The Deputy Commissioner of Income Tax, Central Circle-1(1), Guntur

In the result appeal of the assessee is allowed

ITA 497/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam27 Feb 2025AY 2017-18

Bench: Shri Laliet Kumar, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.496, 497, 498, 499 & 500/Viz/2024 (निर्धारण वर्ा/ Assessment Years: 2016-17, 2017-18, 2018-19, 2019-20 & 2020-21) Vemuluri Naga Bhushanam V. Dcit – Central Circle – 1(1) D.No.8-2-293/82/A/1149 Income Tax Office Road No. 36 Lakshmipuram Main Road Jubilee Hills, Hyderabad – 500033 Guntur – 522006 Telangana Andhra Pradesh [Pan: Abipv2941A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 115BSection 132(4)Section 142(1)Section 153C

payment of Rs. 1,66,47,945/- to M/s.Polisetty Somasundaram. Ld. AO found that in the sworn statement under section 132(4) Mr. P. Shyam Sundhar, Managing Partner of M/s. Polisetty Somasundaram has stated that cash payments made to the assessee are cash loans and the amount received with interest

Vemuluri Naga Bhushanam, Hyderabad vs. The Deputy Commissioner of Income Tax, Central Circle-1(1), Guntur

In the result appeal of the assessee is allowed

ITA 496/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam27 Feb 2025AY 2016-17

Bench: Shri Laliet Kumar, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.496, 497, 498, 499 & 500/Viz/2024 (निर्धारण वर्ा/ Assessment Years: 2016-17, 2017-18, 2018-19, 2019-20 & 2020-21) Vemuluri Naga Bhushanam V. Dcit – Central Circle – 1(1) D.No.8-2-293/82/A/1149 Income Tax Office Road No. 36 Lakshmipuram Main Road Jubilee Hills, Hyderabad – 500033 Guntur – 522006 Telangana Andhra Pradesh [Pan: Abipv2941A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 115BSection 132(4)Section 142(1)Section 153C

payment of Rs. 1,66,47,945/- to M/s.Polisetty Somasundaram. Ld. AO found that in the sworn statement under section 132(4) Mr. P. Shyam Sundhar, Managing Partner of M/s. Polisetty Somasundaram has stated that cash payments made to the assessee are cash loans and the amount received with interest