“Section 132(4)”

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

were retracted.\nThe Assessing Officer has made additions treating certain purchases as\ngenuine. The disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement ... also in view of:\nThe Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003,\ndated 02.11.2015) held:\nA statement under Section 132(4) may have evidentiary value;\nHowever, once retracted, it cannot be relied upon in isolation;\nThe Assessing Officer must examine the explanation with\nreference

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

were retracted.\nThe Assessing Officer has made additions treating certain purchases as\nbogus. The disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement ... also in view of:\nThe Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003,\ndated 02.11.2015) held:\nA statement under Section 132(4) may have evidentiary value;\nHowever, once retracted, it cannot be relied upon in isolation;\nThe Assessing Officer must examine the explanation with\nreference

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

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

etracted. etracted. The Assessing Officer has made additions treating certain purchases as genuine. The disallowance is primarily based on:  A statement recorded under Section 132(4) during search; and  An inference that payments made through banking channels were allegedly returned in cash. The Assessee respectfully submits that:  The statement ... 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

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

retracted.\nThe Assessing Officer has made additions treating certain purchases as\nbogus. The disallowance is primarily based on:\n➤ A statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement ... view of:\nThe Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003,\ndated 02.11.2015) held:\n➤ A statement under Section 132(4) may have evidentiary value;\nHowever, once retracted, it cannot be relied upon in isolation;\nThe Assessing Officer must examine the explanation with\nreference to books

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

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

etracted. etracted. The Assessing Officer has made additions treating certain purchases as genuine. The disallowance is primarily based on:  A statement recorded under Section 132(4) during search; and  An inference that payments made through banking channels were allegedly returned in cash. The Assessee respectfully submits that:  The statement ... 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

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

were retracted.\nThe Assessing Officer has made additions treating certain purchases as\ngenuine. The disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement ... also in view of:\nThe Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003,\ndated 02.11.2015) held:\nA statement under Section 132(4) may have evidentiary value;\nHowever, once retracted, it cannot be relied upon in isolation;\nThe Assessing Officer must examine the explanation with\nreference

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

were retracted.\nThe Assessing Officer has made additions treating certain purchases as\ngenuine. The disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement ... also in view of:\nThe Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003,\ndated 02.11.2015) held:\nA statement under Section 132(4) may have evidentiary value;\nHowever, once retracted, it cannot be relied upon in isolation;\nThe Assessing Officer must examine the explanation with\nreference

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

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

etracted. etracted. The Assessing Officer has made additions treating certain purchases as genuine. The disallowance is primarily based on:  A statement recorded under Section 132(4) during search; and  An inference that payments made through banking channels were allegedly returned in cash. The Assessee respectfully submits that:  The statement ... 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

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

retracted.\nThe Assessing Officer has made additions treating certain purchases as\ngenuine. The disallowance is primarily based on:\n➤ A statement recorded under Section 132(4) during search; and\n➤ An inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that ... view of:\nThe Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003,\ndated 02.11.2015) held:\n➤ A statement under Section 132(4) may have evidentiary value;\nHowever, once retracted, it cannot be relied upon in isolation;\nThe Assessing Officer must examine the explanation with\nreference to books

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

were retracted.\nThe Assessing Officer has made additions treating certain purchases as\ngenuine. The disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement ... also in view of:\nThe Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003,\ndated 02.11.2015) held:\nA statement under Section 132(4) may have evidentiary value;\nHowever, once retracted, it cannot be relied upon in isolation;\nThe Assessing Officer must examine the explanation with\nreference

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

were retracted.\nThe Assessing Officer has made additions treating certain purchases as\ngenuine. The disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement ... also in view of:\nThe Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003,\ndated 02.11.2015) held:\nA statement under Section 132(4) may have evidentiary value;\nHowever, once retracted, it cannot be relied upon in isolation;\nThe Assessing Officer must examine the explanation with\nreference

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

retracted.\nThe Assessing Officer has made additions treating certain purchases as\nbogus. The disallowance is primarily based on:\n➤ A statement recorded under Section 132(4) during search; and\n➤ An inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that ... view of:\nThe Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003,\ndated 02.11.2015) held:\n➤ A statement under Section 132(4) may have evidentiary value;\nHowever, once retracted, it cannot be relied upon in isolation;\nThe Assessing Officer must examine the explanation with\nreference to books

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

were retracted.\nThe Assessing Officer has made additions treating certain purchases as\ngenuine. The disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement ... also in view of:\nThe Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003,\ndated 02.11.2015) held:\nA statement under Section 132(4) may have evidentiary value;\nHowever, once retracted, it cannot be relied upon in isolation;\nThe Assessing Officer must examine the explanation with\nreference

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

retracted.\nThe Assessing Officer has made additions treating certain purchases as\ngenuine. The disallowance is primarily based on:\n➤ A statement recorded under Section 132(4) during search; and\nAn inference that payments made through banking channels\nwere allegedly returned in cash.\nThe Assessee respectfully submits that:\nThe statement ... also in view of:\nThe Hon'ble Delhi High Court in CIT v. Sunil Aggarwal (ITA 224/2003,\ndated 02.11.2015) held:\nA statement under Section 132(4) may have evidentiary value;\nHowever, once retracted, it cannot be relied upon in isolation;\nThe Assessing Officer must examine the explanation with\nreference

GAURAV VERMA,DELHI vs. DCIT, CENTRAL CIRCLE-8, DELHI

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI Before Sh. S. Rifaur Rahman, Accountant Member & Sh. Sudhir

GAURAV VERMA,DELHI vs. DCIT, CENTRAL CIRCLE-8, DELHI

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI Before Sh. S. Rifaur Rahman, Accountant Member & Sh. Sudhir

GAURAV VERMA,DELHI vs. DCIT, CENTRAL CIRCLE-8 DELHI, DELHI

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI Before Sh. S. Rifaur Rahman, Accountant Member & Sh. Sudhir

GLOBAL STAINLESS,DELHI vs. ACIT,CIRCLE-34(1), DELHI

In the result, the captioned appeals of the assessee are dismissed

Bench: Ms. Madhumita Roy & Shri Naveen Chandraassessment Year : 2018-19 Global Stainless, Vs. Acit, 17, Meera Tower, Ground Floor, Circle-34(1), Wazirpur Industrial Area, Delhi. New Delhi – 110 052. Pan: Aajfg7209G (Appellant) (Respondent) Assessee By : Shri Amol Sinha, Advocate & Shri Ankit Kumar, Advocate Revenue By : Shri Manish Gupta, Sr.Dr Date Of Hearing : 13.01.2026 Date Of Pronouncement : 20.03.2026 Order Per Madhumita Roy:

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : G : NEW DELHI BEFORE MS. MADHUMITA ROY, JUDICIAL MEMBER AND SHRI NAVEEN

DCIT CENTRAL CIRCLE -28, NEW DELHI, NEW DELHI vs. MANOJ KUMAR SINGH, NEW DELHI

In the result, appeal filed by the assessee is allowed in above terms and the appeal of the Revenue is dismissed

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F’: NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI

MANOJ KUMAR SINGH,DELHI vs. DCIT(A) CENTRAL CIRCLE-28, DELHI

In the result, appeal filed by the assessee is allowed in above terms and the appeal of the Revenue is dismissed

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F’: NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI