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“retraction of statement”

Search & SeizureSection 132(4)Section 132(4)316 judgments

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

nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material.\nI. Retraction of Statement – Legal Position\nThe statement recorded during search was retracted during\nassessment proceedings. Though the retraction was not immediate,\nthe delay occurred due to continuous ... carries more weight\nthan a statement made during a survey under Section 133A.\nHe further submitted that the Assessee had not chosen to retract\nhis statement till ten months after the date of the search and\ntherefore the retraction itself was not genuine. According to him,\nthe said retraction

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

nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material.\nI. Retraction of Statement – Legal Position\nThe statement recorded during search was retracted during\nassessment proceedings. Though the retraction was not immediate,\nthe delay occurred due to continuous ... carries more weight\nthan a statement made during a survey under Section 133A.\nHe further submitted that the Assessee had not chosen to retract\nhis statement till ten months after the date of the search and\ntherefore the retraction itself was not genuine. According to him,\nthe said retraction

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

before the Assessing Officer;  The retraction was supported by documentary evidence;  The addition is unsupported by corroborative material. I . Retraction of State I . Retraction of Statement I . Retraction of State I . Retraction of State ment ment – Legal Position ment Legal Position Legal Position Legal Position The statement recorded during search ... carries more weight than a statement made during a survey under Section 133A. ---- He further submitted that the Assessee had not chosen to retract his statement till ten months after the date of the search and therefore the retraction itself was not genuine. According to him, the said retraction

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

nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material.\nI. Retraction of Statement – Legal Position\nThe statement recorded during search was retracted during\nassessment proceedings. Though the retraction was not immediate,\nthe delay occurred due to continuous ... carries more weight\nthan a statement made during a survey under Section 133A.\nHe further submitted that the Assessee had not chosen to retract\nhis statement till ten months after the date of the search and\ntherefore the retraction itself was not genuine. According to him,\nthe said retraction

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

before the Assessing Officer;  The retraction was supported by documentary evidence;  The addition is unsupported by corroborative material. I . Retraction of State I . Retraction of Statement I . Retraction of State I . Retraction of State ment ment – Legal Position ment Legal Position Legal Position Legal Position The statement recorded during search ... carries more weight than a statement made during a survey under Section 133A. ---- He further submitted that the Assessee had not chosen to retract his statement till ten months after the date of the search and therefore the retraction itself was not genuine. According to him, the said retraction

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

nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material.\nI. Retraction of Statement – Legal Position\nThe statement recorded during search was retracted during\nassessment proceedings. Though the retraction was not immediate,\nthe delay occurred due to continuous ... carries more weight\nthan a statement made during a survey under Section 133A.\nHe further submitted that the Assessee had not chosen to retract\nhis statement till ten months after the date of the search and\ntherefore the retraction itself was not genuine. According to him,\nthe said retraction

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
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

nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material.\nI. Retraction of Statement – Legal Position\nThe statement recorded during search was retracted during\nassessment proceedings. Though the retraction was not immediate,\nthe delay occurred due to continuous ... carries more weight\nthan a statement made during a survey under Section 133A.\nHe further submitted that the Assessee had not chosen to retract\nhis statement till ten months after the date of the search and\ntherefore the retraction itself was not genuine. According to him,\nthe said retraction

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

before the Assessing Officer;  The retraction was supported by documentary evidence;  The addition is unsupported by corroborative material. I . Retraction of State I . Retraction of Statement I . Retraction of State I . Retraction of State ment ment – Legal Position ment Legal Position Legal Position Legal Position The statement recorded during search ... carries more weight than a statement made during a survey under Section 133A. ---- He further submitted that the Assessee had not chosen to retract his statement till ten months after the date of the search and therefore the retraction itself was not genuine. According to him, the said retraction

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE-05, DELHI

ITA 5520/DEL/2025[2023-24]Status: DisposedITAT Delhi20 Mar 2026AY 2023-24
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

retracted before the Assessing Officer;\n➤ The retraction was supported by documentary evidence;\n➤ The addition is unsupported by corroborative material.\nI. Retraction of Statement – Legal Position\nThe statement recorded during search was retracted during\nassessment proceedings. Though the retraction was not immediate,\nthe delay occurred due to continuous fear ... carries more weight\nthan a statement made during a survey under Section 133A.\nHe further submitted that the Assessee had not chosen to retract\nhis statement till ten months after the date of the search and\ntherefore the retraction itself was not genuine. According to him,\nthe said retraction

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT CENTRAL CIRCLE-05, DELHI

ITA 5519/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material.\nI. Retraction of Statement – Legal Position\nThe statement recorded during search was retracted during\nassessment proceedings. Though the retraction was not immediate,\nthe delay occurred due to continuous ... carries more weight\nthan a statement made during a survey under Section 133A.\nHe further submitted that the Assessee had not chosen to retract\nhis statement till ten months after the date of the search and\ntherefore the retraction itself was not genuine. According to him,\nthe said retraction

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE- 05, DELHI

ITA 5518/DEL/2025[2021-22]Status: DisposedITAT Delhi20 Mar 2026AY 2021-22
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material.\nI. Retraction of Statement – Legal Position\nThe statement recorded during search was retracted during\nassessment proceedings. Though the retraction was not immediate,\nthe delay occurred due to continuous ... carries more weight\nthan a statement made during a survey under Section 133A.\nHe further submitted that the Assessee had not chosen to retract\nhis statement till ten months after the date of the search and\ntherefore the retraction itself was not genuine. According to him,\nthe said retraction

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE-05, DELHI

ITA 5517/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

retracted before the Assessing Officer;\n➤ The retraction was supported by documentary evidence;\n➤ The addition is unsupported by corroborative material.\nI. Retraction of Statement – Legal Position\nThe statement recorded during search was retracted during\nassessment proceedings. Though the retraction was not immediate,\nthe delay occurred due to continuous fear ... carries more weight\nthan a statement made during a survey under Section 133A.\nHe further submitted that the Assessee had not chosen to retract\nhis statement till ten months after the date of the search and\ntherefore the retraction itself was not genuine. According to him,\nthe said retraction

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

nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material.\nI. Retraction of Statement – Legal Position\nThe statement recorded during search was retracted during\nassessment proceedings. Though the retraction was not immediate,\nthe delay occurred due to continuous ... carries more weight\nthan a statement made during a survey under Section 133A.\nHe further submitted that the Assessee had not chosen to retract\nhis statement till ten months after the date of the search and\ntherefore the retraction itself was not genuine. According to him,\nthe said retraction

VESTIGE MARKETING PVT. LTD.,DELHI vs. DCIT, CENTRAL CIRCLE- 05, DELHI

ITA 5515/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Mar 2026AY 2018-19
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

nThe statement was retracted before the Assessing Officer;\nThe retraction was supported by documentary evidence;\nThe addition is unsupported by corroborative material.\nI. Retraction of Statement – Legal Position\nThe statement recorded during search was retracted during\nassessment proceedings. Though the retraction was not immediate,\nthe delay occurred due to continuous ... carries more weight\nthan a statement made during a survey under Section 133A.\nHe further submitted that the Assessee had not chosen to retract\nhis statement till ten months after the date of the search and\ntherefore the retraction itself was not genuine. According to him,\nthe said retraction

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 4321/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Feb 2026AY 2016-17

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

recorded on oath during the course of search without considering the letter of retraction of statement which were filed, clarifying the correct factual position. Additions have been made merely on the basis of excel sheets/loose papers found during the course of search. No corroborative evidence has been brought on record ... section 69C. Ld. Assessing Officer has relied on these statements recorded during the course of search without considering that a letter of retraction of statement with clarification as to error in the statement so recorded earlier was filed before the investigation wing by the deponents. 11.9. Case of the assessee

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 4320/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

recorded on oath during the course of search without considering the letter of retraction of statement which were filed, clarifying the correct factual position. Additions have been made merely on the basis of excel sheets/loose papers found during the course of search. No corroborative evidence has been brought on record ... section 69C. Ld. Assessing Officer has relied on these statements recorded during the course of search without considering that a letter of retraction of statement with clarification as to error in the statement so recorded earlier was filed before the investigation wing by the deponents. 11.9. Case of the assessee

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 4319/MUM/2025[2019-20]Status: DisposedITAT Mumbai20 Feb 2026AY 2019-20

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

recorded on oath during the course of search without considering the letter of retraction of statement which were filed, clarifying the correct factual position. Additions have been made merely on the basis of excel sheets/loose papers found during the course of search. No corroborative evidence has been brought on record ... section 69C. Ld. Assessing Officer has relied on these statements recorded during the course of search without considering that a letter of retraction of statement with clarification as to error in the statement so recorded earlier was filed before the investigation wing by the deponents. 11.9. Case of the assessee

ACIT, CC-6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 4318/MUM/2025[2022-23]Status: DisposedITAT Mumbai20 Feb 2026AY 2022-23

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

recorded on oath during the course of search without considering the letter of retraction of statement which were filed, clarifying the correct factual position. Additions have been made merely on the basis of excel sheets/loose papers found during the course of search. No corroborative evidence has been brought on record ... section 69C. Ld. Assessing Officer has relied on these statements recorded during the course of search without considering that a letter of retraction of statement with clarification as to error in the statement so recorded earlier was filed before the investigation wing by the deponents. 11.9. Case of the assessee

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

ITA 4090/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Feb 2026AY 2016-17

nsubmitted that authorities below have relied solely upon the statements\nrecorded on oath during the course of search without considering the\nletter of retraction of statement which were filed, clarifying the correct\nfactual position. Additions have been made merely on the basis of excel\nsheets/loose papers found during the course ... section 69C. Ld. Assessing Officer has relied on these\nstatements recorded during the course of search without considering\nthat a letter of retraction of statement with clarification as to error in\nthe statement so recorded earlier was filed before the investigation wing\nby the deponents.\n11.9. Case of the assessee

OVERSEAS INFRASTRUCTURE ALLIANCE(INDIA) PRIVATE LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6(2), MUMBAI

ITA 4064/MUM/2025[2022-23]Status: DisposedITAT Mumbai20 Feb 2026AY 2022-23

nsubmitted that authorities below have relied solely upon the statements\nrecorded on oath during the course of search without considering the\nletter of retraction of statement which were filed, clarifying the correct\nfactual position. Additions have been made merely on the basis of excel\nsheets/loose papers found during the course ... section 69C. Ld. Assessing Officer has relied on these\nstatements recorded during the course of search without considering\nthat a letter of retraction of statement with clarification as to error in\nthe statement so recorded earlier was filed before the investigation wing\nby the deponents.\n11.9. Case of the assessee

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