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“evidentiary value”

Natural JusticeEvidenceEvidence5,387 judgments

The decision most relied on for evidentiary value is Kishanchand Chellaram v. CIT (125 ITR 713), cited in 962 judgments on BharatTax.

Leading authorities on evidentiary value

Kishanchand Chellaram v. CIT
125 ITR 713 · 1980 · Supreme Court
962
citing judgments

Adverse material or evidence collected by the Assessing Officer behind the assessee's back, without providing it to the assessee or affording an opportunity for cross-examination, has no evidentiary value and cannot be relied upon to make additions.

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.

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.

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.

CIT v. S. Khader Khan Son
300 ITR 157 · 2008 · High Court
452
citing judgments

A statement recorded under duress during a survey, if subsequently retracted, has no evidentiary value and cannot be the sole basis for an income-tax assessment; the assessment should instead rely on audited accounts.

CBI v. V.C. Shukla
3 SCC 410 · 1998 · Supreme Court
442
citing judgments

Loose sheets of paper, excel sheets, or diaries, often referred to as 'dumb documents,' are wholly irrelevant as evidence and not admissible under Section 34 of the Evidence Act if they lack evidentiary value. Additions to income cannot be made solely based on such documents without corroborating, reliable, and admissible evidence supported by other circumstances.

Omar Salay Mohamed Sait v. CIT
37 ITR 151 · 1959 · Supreme Court
372
citing judgments

An income tax assessment or addition cannot be made based solely on suspicion, surmises, or conjectures. The income tax department requires evidence or material to justify an addition, as suspicion, however strong, does not constitute proof.

CIT v. R. Nalini Devi ITTA 232 of 2013 (A. P)
294 ITR 49 · 2007 · Supreme Court
299
citing judgments

Additions to income cannot be made solely based on uncorroborated third-party statements, documents, or loose sheets seized during a search, and such evidence requires the assessee to be provided with an opportunity for cross-examination.

Judgments citing evidentiary value

Assisstant Commissioner of Income Tax, Jhandewalan Extn vs. Om Prakash Arora, Connaught Place

In the result, appeal of the Revenue vide ITA No

ITA 5029/DEL/2024[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2015-16] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue Cross Objection No.42/Del/2025 (Arising Out Of Ita No.5031/Del/2024) [Assessment Year: 2015-16] Om Prakash Arora, Assistant Commissioner Of Income M-3, Flat No.103, Avg Tax, Central Circle-01, Bhawan The Variety Books Vs E-2, Jhandewalan Extn. Depot. Connaught Place, New Delhi-110055 New Delhi-110001 Pan-Accpa9774F Assessee Revenue [Assessment Year: 2016-17] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue

Section 139(1)Section 143(3)Section 147Section 148Section 151

absence of part payment towards sale consideration of Rs. 75 Cr. which could have been effected through cheques having evidentiary value, the genuineness of this Mo cannot be relied upon. This signifies that this agreement is an afterthought between the two parties just to link the deals and to make

DCIT, Delhi vs. Jmk Jewels Private Limited, Delhi

ITA 4282/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 M/S. Jmk Jewels Pvt. Ltd., Vs. Acit, Shop No. 302, Building New Delhi No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi Pan: Aabch6018F (Appellant) (Respondent) With Assessment Year: 2017-18 Dcit, Vs. M/S. Jmk Jewels Pvt. Ltd., New Delhi Shop No. 302, Building No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi Pan: Aabch6018F (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Sh. Rahul Bhardwaj, Adv. Department By Sh. Mahesh Kumar, Cit(Dr), Sh. Rajesh Tiwari, Sr. Dr

Section 115BSection 143(3)Section 44ASection 68

unexplained cash credit u/s 68 of the Income Tax Act, 1961 in view of the following reasons: i. No documents of evidentiary value in support of the above queries has been provided by the assessee in respect of show cause notice dated 17.12.2019 issued to the assessee ... provided by you why an adverse view should not be taken by the department in this matter Neither tenable justification nor documents of evidentiary value has been given by the assessee in respect of show cause notice regarding revising VAT returns. Hence, in the absence of any information available

Jmk Jewels Private Limited, Delhi vs. Assistant Commissioner of Income Tax, Delhi

ITA 3609/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 M/S. Jmk Jewels Pvt. Ltd., Vs. Acit, Shop No. 302, Building New Delhi No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi Pan: Aabch6018F (Appellant) (Respondent) With Assessment Year: 2017-18 Dcit, Vs. M/S. Jmk Jewels Pvt. Ltd., New Delhi Shop No. 302, Building No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi Pan: Aabch6018F (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Sh. Rahul Bhardwaj, Adv. Department By Sh. Mahesh Kumar, Cit(Dr), Sh. Rajesh Tiwari, Sr. Dr

Section 115BSection 143(3)Section 44ASection 68

unexplained cash credit u/s 68 of the Income Tax Act, 1961 in view of the following reasons: i. No documents of evidentiary value in support of the above queries has been provided by the assessee in respect of show cause notice dated 17.12.2019 issued to the assessee ... provided by you why an adverse view should not be taken by the department in this matter Neither tenable justification nor documents of evidentiary value has been given by the assessee in respect of show cause notice regarding revising VAT returns. Hence, in the absence of any information available

Jag Mohan, Delhi vs. DCIT, Central Circle- 18, New Delhi

In the result, appeal of the assessee is partly allowed in the terms aforesaid

ITA 7055/DEL/2017[2014-15]Status: DisposedITAT Delhi07 Jan 2026AY 2014-15

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं.7055/धिल्ली/2017(नि.व. 2014-15) Jag Mohan, 354, Tarun Enclave, Pitampura, ...... अपीलार्थी/Appellant Delhi 110034 Pan Ahdpm-3671-M बिाम Vs. Deputy Commissioner Of Income Tax, ..... प्रनिवादी/Respondent Circle-18, New Delhi अपीलार्थी द्वारा/ Appellant By : S/Shri Raghav Sharma, Mohit Gupta, Chartered Accountants & Ms. Chandrima Choudhary, Advocate प्रधिवािीद्वारा/Respondent By : Ms. Namita Khurana Cit-Dr & Shri Om Prakash, Sr.Dr सुिवाई की निथर्थ/ Date Of Hearing : 10/10/2025 घोषणा की निथर्थ/ Date Of Pronouncement: 07/01/2026 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-28, New Delhi [In Short ‘The Cit(A)’] Dated 18/09/2017, For Assessment Year 2014-15. 2. A Search & Seizure Operation U/S.132 Of The Income Was Conducted On 26.08.2013 In The Case Of Mohan India Group. The Assessee Is One Of The Directors Of Mohan India Group & The Assessee Was Also Covered Under Said Search. During

For Appellant: S/Shri Raghav Sharma, Mohit Gupta, CharteredFor Respondent: Ms. Namita Khurana CIT-DR &
Section 132Section 143(3)Section 153A

contested by the assessee either before the CIT(A) nor has been challenged the same before the Tribunal. Therefore, books of account losses their evidentiary value, hence, cannot be relied upon by the assessee at this stage. Therefore, reference to the balance sheet by the assessee at this stage

Deepak Kakubhai Mehta, Mumbai vs. DCIT, Central Circle 4(1), Mumbai

In the result, all the appeals filed by the assessee are allowed

ITA 6511/MUM/2025[2018-19]Status: DisposedITAT Mumbai06 Jan 2026AY 2018-19

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

Section 1Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 30Section 56

statements recorded under section 132(4) of the Act. It therefore becomes necessary to examine, with some degree of doctrinal clarity, the evidentiary value of such statements in the context of search assessments. 39.1. There can be no quarrel with the proposition that a statement recorded under section ... evidentiary value and may be used in proceedings under the Act. However, it is equally well settled that a statement, by itself and in the absence of corroborative incriminating material, cannot constitute incriminating material for the purposes of section 153A. 40. Courts have repeatedly cautioned against placing blind or mechanical

Deepak Kakubhai Mehta, Mumbai vs. DCIT, Central Circle 4(1), Mumbai

ITA 6510/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Jan 2026AY 2017-18
Section 1Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 30Section 56

statements recorded under section 132(4) of the Act. It therefore becomes necessary to examine, with some degree of doctrinal clarity, the evidentiary value of such statements in the context of search assessments. 39.1. There can be no quarrel with the proposition that a statement recorded under section ... evidentiary value and may be used in proceedings under the Act. However, it is equally well settled that a statement, by itself and in the absence of corroborative incriminating material, cannot constitute incriminating material for the purposes of section 153A. 40. Courts have repeatedly cautioned against placing blind or mechanical

Deepak Kakubhai Mehta, Mumbai vs. DCIT, Central Circle 4(1), Mumbai

ITA 6509/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Jan 2026AY 2016-17
Section 1Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 30Section 56

statements recorded under section 132(4) of the Act. It therefore becomes necessary to examine, with some degree of doctrinal clarity, the evidentiary value of such statements in the context of search assessments. 39.1. There can be no quarrel with the proposition that a statement recorded under section ... evidentiary value and may be used in proceedings under the Act. However, it is equally well settled that a statement, by itself and in the absence of corroborative incriminating material, cannot constitute incriminating material for the purposes of section 153A. 40. Courts have repeatedly cautioned against placing blind or mechanical

Deepak Kakubhai Mehta, Mumbai vs. DCIT, Central Circle 4(1), Mumbai

In the result, all the appeals filed by the assessee are allowed

ITA 6508/MUM/2025[2015-16]Status: DisposedITAT Mumbai06 Jan 2026AY 2015-16

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

Section 1Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 30Section 56

statements recorded under section 132(4) of the Act. It therefore becomes necessary to examine, with some degree of doctrinal clarity, the evidentiary value of such statements in the context of search assessments. 39.1. There can be no quarrel with the proposition that a statement recorded under section ... evidentiary value and may be used in proceedings under the Act. However, it is equally well settled that a statement, by itself and in the absence of corroborative incriminating material, cannot constitute incriminating material for the purposes of section 153A. 40. Courts have repeatedly cautioned against placing blind or mechanical

Deepak Kakubhai Mehta, Mumbai vs. DCIT, Central Circle 4(1), Mumbai

ITA 6507/MUM/2025[2014-15]Status: DisposedITAT Mumbai06 Jan 2026AY 2014-15
Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 56Section 69Section 69A

statements recorded under section 132(4) of the Act. It\ntherefore becomes necessary to examine, with some degree of\ndoctrinal clarity, the evidentiary value of such statements in\nthe context of search assessments.\n39.1. There can be no quarrel with the proposition that a\nstatement recorded under section ... also do not record the discovery of any\ncorroborative material from the assessee's possession\nevidencing the alleged advancement of cash loans.\n51.1. The evidentiary value of loose papers and\nuncorroborated notings is, at best, weak. Courts have\nconsistently held that such documents, unless supported by\nindependent and reliable evidence

Deepak Kakubhai Mehta, Mumbai vs. DCIT, Central Circle 4(1), Mumbai

ITA 6506/MUM/2025[2013-14]Status: DisposedITAT Mumbai06 Jan 2026AY 2013-14
Section 1Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 4Section 56

statements recorded under section 132(4) of the Act. It therefore becomes necessary to examine, with some degree of doctrinal clarity, the evidentiary value of such statements in the context of search assessments. 39.1. There can be no quarrel with the proposition that a statement recorded under section ... evidentiary value and may be used in proceedings under the Act. However, it is equally well settled that a statement, by itself and in the absence of corroborative incriminating material, cannot constitute incriminating material for the purposes of section 153A. 40. Courts have repeatedly cautioned against placing blind or mechanical

Deepak Kakubhai Mehta, Mumbai vs. DCIT Central Circle - 4(1), Mumbai

ITA 6505/MUM/2025[2012-13]Status: DisposedITAT Mumbai06 Jan 2026AY 2012-13
Section 1Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 56Section 69

statements recorded under section 132(4) of the Act. It therefore becomes necessary to examine, with some degree of doctrinal clarity, the evidentiary value of such statements in the context of search assessments. 39.1. There can be no quarrel with the proposition that a statement recorded under section ... evidentiary value and may be used in proceedings under the Act. However, it is equally well settled that a statement, by itself and in the absence of corroborative incriminating material, cannot constitute incriminating material for the purposes of section 153A. 40. Courts have repeatedly cautioned against placing blind or mechanical

S Chandra Prakash, Chennai vs. ITO, Central Circle-3(2), Chennai

ITA 2815/CHNY/2025[2021-22]Status: DisposedITAT Chennai05 Jan 2026AY 2021-22

Bench: Shri Aby T Varkey & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:2815/Chny/2025 & Sa No.105/Chny/2025 निर्धारण वर्ष / Assessment Year: 2021-22 S.Chandra Prakash, No.13/5, Vritti Apartment, 2A, Ormes Road, 3Rd Cross Street, Kilpauk S.O, Kilpauk, Chennai – 600 010. Ito, Vs. Central Circle – 3(2), Chennai. [Pan: Aaapc-4541-Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Mr. Y. Sridhar, F.C.A. प्रत्यर्थी की ओर से/Respondent By : Ms. R. Anitha, Addl. Cit. सुनवाई की तारीख/Date Of Hearing : 04.12.2025 घोषणा की तारीख/Date Of Pronouncement : 05.01.2026 आदेश /Order Per S. R. Raghunatha, Ам: This Appeal & Stay Application Filed By The Assessee Is Against The Order Of The Learned Commissioner Of Income-Tax (Appeals), Chennai - 20 (In Short "Cit(A)") Passed U/S.250 Of The Income-Tax Act, 1961 (In Short "The Act") Dated 08.08.2025 Pertaining To Assessment Year (Ay) 2021-22 Against The Order Passed By The Acit, Central Circle-3(2), Chennai, U/S.143(3) Of The Act Dated 30.12.2022. :-2-:

For Appellant: Mr. Y. Sridhar, F.C.AFor Respondent: Ms. R. Anitha, Addl. CIT
Section 131Section 132ASection 143(3)Section 250Section 69

That the Ld.CIT(A) erred in failing to appreciate that a confession obtained during the period of detention by the police cannot possess evidentiary value, more particularly when it is proven that the same was obtained under excessive coercion. 5. That the Ld.CIT(A) erred in upholding the order ... attempt or postscript to explain the source of jewellery found and seized. e. That the statement deposed u/s.131(1A) can still possess evidentiary value when obtained by way of threat and physical assault. f. That either the AO or the CIT(A) could counter the claims of the appellant

Mr. Thirumani, Chennai vs. ACIT, Ncc-6(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 3351/CHNY/2024[2016-17]Status: DisposedITAT Chennai05 Jan 2026AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:3351/Chny/2024 िनधा$रण वष$ / Assessment Year: 2016-17 Thirumani, Acit, 260/1, Mint Street, Park Town, Vs. Non-Corporate Circle 6(1), Chennai – 600 003. Chennai – 600 034. [Pan: Aagpt-7541-K] (अपीलाथ&/Appellant) ('(थ&/Respondent)

For Appellant: Shri. B. Ramakrishnan, F.C.AFor Respondent: Ms. Gouthami Manivasagam, J.C.I.T
Section 142(1)Section 143(2)Section 143(3)Section 54Section 54FSection 56(2)(vii)

assessee and does not link exemption to cost of construction. The test is capability of habitation but not the magnitude. 10. Coming to the evidentiary value of the documents produced by both the parties. In the present case, the assessee has produced: 1. Panchayat house-tax receipt classifying the structure

Income Tax Officer, Mumbai vs. Ndw Development Corporation LLP, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 3817/MUM/2025[2022]Status: DisposedITAT Mumbai01 Jan 2026

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2022-23 Income Tax Officer-20(2)(1), Ndw Development Corporation 304, Piramal Chambers, Llp, Parel, Vs. B 201-202, Doodh Wala Complex, Mumbai-400012. Chsl, Belashis Road, Mumbai Central, Mumbai-400008. Pan : Aapfn4779C (Appellant) (Respondent) Assessee By : Shri Madhur Agarwal Revenue By : Shri Inder Solanki, Cit-Dr

For Appellant: Shri Madhur AgarwalFor Respondent: Shri Inder Solanki, CIT-DR
Section 143(2)Section 143(3)Section 694Section 69A

respect of three loan transactions amounting to Rs 53,15,000/-, the same by default leads to raising a question mark on evidentiary value of documentation submitted and accepted by the ld CIT(A) in respect of rest all loan transactions amounting ... have not been accepted by the ld CIT(A) and addition has been confirmed cannot by any stretch of imagination leads to challenging the evidentiary value of documentation submitted and accepted by the Ld.CIT(A) in respect of rest all loan transactions as it is an accepted principle that each

DCIT, Kolkata vs. Sujit Arya, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 751/KOL/2025[2014-15]Status: DisposedITAT Kolkata31 Dec 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Sujit Arya Dcit P-3, Paramathesh Barun Sarani, 3, Govt Place West, Kolkata- New Cit Road, Central Metro, Vs. 700001, West Bengal Kolkata-700073, West Bengal (Appellant) (Respondent) Pan No. Actpa8796J Assessee By : Shri Sunil Surana, Ar Revenue By : Shri S.B. Chakraborthy, Dr Date Of Hearing: 02.12.2025 Date Of Pronouncement: 31.12.2025

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 133A

case of Bansal Strips (p) Ltd. v. Asst. CIT (2006) 99 33 of bunch SA-5 and be aa guiding case to decide the evidentiary value of the page no. of unaccounted to examine the merit in the decision of AO in making addition Tribunal, while income solely relying ... said piece of paper. The Hon'ble making addition in elaborating assessment upon the evidentiary value of a dumb document for has held as under: - made "The on their impugned basis in seized the papers are dumb documents and no addition can be absence of corroborative materials. No circumstantial evidence

New Track Exim Private Limited, Delhi vs. Income Tax Officer, Ward 18(3), Delhi

In the result, appeal of the assessee is partly allowed

ITA 2765/DEL/2024[2012-13]Status: DisposedITAT Delhi31 Dec 2025AY 2012-13

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 151Section 250Section 68

sent by the assessee himself. The papers arranged by the assessee and filed by its Counsel are nothing but paper trails which have no evidentiary value." 13. From the above, it is clear that despite the request of the assessee for cross- examination of Shri S.K. Gupta, whose statement

Integrated Service Point Ltd., Chennai vs. ACIT, CC-2(4), Chennai

ITA 1883/CHNY/2025[2022-23]Status: DisposedITAT Chennai30 Dec 2025AY 2022-23

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Pvt. Ltd.,) Vs. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing घोषण की तारीख / Date Of Pronouncement : 13.10.2025 : 30.12.2025 :- 2 -:

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

arranged manner of convenience. 4. The Ld. LD.CIT(A) erred in holding that seized document is only secondary evidence and did not have any evidentiary value in respect of entries found therein without any corroborative evidence, without appreciating that the entries found in the seized materials were in the form ... 1883/Chny/2025 ITA Nos.1874, 1876 & 1879/Chny/2025 Integrated Service Point Ltd. recorded under section 132(4). It was further contended that the seized electronic records lacked evidentiary value, as they did not comply with the mandatory requirements of section 65B of the Evidence Act, 1872. 57. The Id. CIT(A), after considering

Integrated Service Point Ltd., Chennai vs. ACIT, Central Circle-2(4), Chennai

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

ITA 1882/CHNY/2025[2019-20]Status: DisposedITAT Chennai30 Dec 2025AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

arranged manner of convenience. 4. The Ld. LD.CIT(A) erred in holding that seized document is only secondary evidence and did not have any evidentiary value in respect of entries found therein without any corroborative evidence, without appreciating that the entries found in the seized materials were in the form ... 1883/Chny/2025 ITA Nos.1874, 1876 & 1879/Chny/2025 Integrated Service Point Ltd. recorded under section 132(4). It was further contended that the seized electronic records lacked evidentiary value, as they did not comply with the mandatory requirements of section 65B of the Evidence Act, 1872. 57. The ld. CIT(A), after considering

Integrated Service Point Ltd., Chennai vs. ACIT, Central Circle-2(4), Chennai

ITA 1881/CHNY/2025[2016-17]Status: DisposedITAT Chennai30 Dec 2025AY 2016-17

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Income Tax, Pvt. Ltd.,) The Dy./Asst. Commissioner Of Central Circle-2(4), 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Chennai. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 13.10.2025 घोषण की तारीख / Date Of Pronouncement : 30.12.2025 :- 2 -:

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

arranged manner of convenience. 4. The Ld. LD.CIT(A) erred in holding that seized document is only secondary evidence and did not have any evidentiary value in respect of entries found therein without any corroborative evidence, without appreciating that the entries found in the seized materials were in the form ... pointed out the discrepancies in the original deposition :- 13 -: recorded under Section 132(4). It was further contended that the seized electronic records lacked evidentiary value, as they did not comply with the mandatory requirements of Section 65B of the Evidence Act, 1872. 57. The Id. CIT(A), after considering

ACIT, Chennai vs. Integrated Service Point Limited, Anna Nagar

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

ITA 1879/CHNY/2025[2022-23]Status: DisposedITAT Chennai30 Dec 2025AY 2022-23

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

arranged manner of convenience. 4. The Ld. LD.CIT(A) erred in holding that seized document is only secondary evidence and did not have any evidentiary value in respect of entries found therein without any corroborative evidence, without appreciating that the entries found in the seized materials were in the form ... 1883/Chny/2025 ITA Nos.1874, 1876 & 1879/Chny/2025 Integrated Service Point Ltd. recorded under section 132(4). It was further contended that the seized electronic records lacked evidentiary value, as they did not comply with the mandatory requirements of section 65B of the Evidence Act, 1872. 57. The ld. CIT(A), after considering