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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

Bysani Srinath Mamatha, Bengaluru vs. Joint Commissioner of Income Tax (OSD), Central Circle-1(3), Bengaluru

ITA 406/BANG/2025[2014-15]Status: DisposedITAT Bangalore09 Oct 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

over 14 months and was not supported by any corroborative evidence. The AO found that statements recorded under section 132(4) carry strong evidentiary value, and retractions must be immediate and supported by proof of coercion or mistake. In this case, the assessee has not discharged his burden of proof ... sufficient cause for not producing it earlier. 4.1 The AO emphasizes that the statement recorded under section 132(4) of the Act has full evidentiary value. Once given voluntarily, it cannot be lightly retracted. The Hon'ble Courts and Tribunals have repeatedly held that the burden lies on the assessee

Bysani Srinath Mamatha, Bengaluru vs. Joint Commissioner of Income Tax, (OSD) Central Circle-1(3), Bengaluru

ITA 405/BANG/2025[2013-14]Status: DisposedITAT Bangalore09 Oct 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

over 14 months and was not supported by any corroborative evidence. The AO found that statements recorded under section 132(4) carry strong evidentiary value, and retractions must be immediate and supported by proof of coercion or mistake. In this case, the assessee has not discharged his burden of proof ... sufficient cause for not producing it earlier. 4.1 The AO emphasizes that the statement recorded under section 132(4) of the Act has full evidentiary value. Once given voluntarily, it cannot be lightly retracted. The Hon'ble Courts and Tribunals have repeatedly held that the burden lies on the assessee

Bysani Adinarayagupatha Srinath, Bengaluru vs. Joint Commissioner of Income Tax (OSD), Central Circle-1(3), Bengaluru

ITA 404/BANG/2025[2018-19]Status: DisposedITAT Bangalore09 Oct 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

over 14 months and was not supported by any corroborative evidence. The AO found that statements recorded under section 132(4) carry strong evidentiary value, and retractions must be immediate and supported by proof of coercion or mistake. In this case, the assessee has not discharged his burden of proof ... sufficient cause for not producing it earlier. 4.1 The AO emphasizes that the statement recorded under section 132(4) of the Act has full evidentiary value. Once given voluntarily, it cannot be lightly retracted. The Hon'ble Courts and Tribunals have repeatedly held that the burden lies on the assessee

Bysani Adinarayaguptha Srinath, Bengaluru vs. Joint Commissioner of Income Tax (OSD), Central Circle-1(3), Bengaluru

In the result, the appeals of the assessee for Assessment Years

ITA 402/BANG/2025[2016-17]Status: DisposedITAT Bangalore09 Oct 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

over 14 months and was not supported by any corroborative evidence. The AO found that statements recorded under section 132(4) carry strong evidentiary value, and retractions must be immediate and supported by proof of coercion or mistake. In this case, the assessee has not discharged his burden of proof ... sufficient cause for not producing it earlier. 4.1 The AO emphasizes that the statement recorded under section 132(4) of the Act has full evidentiary value. Once given voluntarily, it cannot be lightly retracted. The Hon’ble Courts and Tribunals have repeatedly held that the burden lies on the assessee

Bysani Adinarayaguptha Srinath, Bengaluru vs. Joint Commissioner of Income Tax (OSD), Central Circle-1(3), Bengaluru

ITA 401/BANG/2025[2015-16]Status: DisposedITAT Bangalore09 Oct 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 131Section 132Section 132(4)Section 153A

over 14 months and was not supported by any corroborative evidence. The AO found that statements recorded under section 132(4) carry strong evidentiary value, and retractions must be immediate and supported by proof of coercion or mistake. In this case, the assessee has not discharged his burden of proof ... sufficient cause for not producing it earlier. 4.1 The AO emphasizes that the statement recorded under section 132(4) of the Act has full evidentiary value. Once given voluntarily, it cannot be lightly retracted. The Hon'ble Courts and Tribunals have repeatedly held that the burden lies on the assessee

Bysani Adinarayaguptha Srinath, Bengaluru vs. Joint Commissioner of Income Tax(OSD), Central Circle 1(3), Bengaluru

ITA 400/BANG/2025[2014-15]Status: DisposedITAT Bangalore09 Oct 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

over 14 months and was not supported by any corroborative evidence. The AO found that statements recorded under section 132(4) carry strong evidentiary value, and retractions must be immediate and supported by proof of coercion or mistake. In this case, the assessee has not discharged his burden of proof ... sufficient cause for not producing it earlier. 4.1 The AO emphasizes that the statement recorded under section 132(4) of the Act has full evidentiary value. Once given voluntarily, it cannot be lightly retracted. The Hon'ble Courts and Tribunals have repeatedly held that the burden lies on the assessee

Bysani Adinarayaguptha Srinath, Bengaluru vs. Joint Commissioner of Income Tax(OSD), Central Circle-1(3), Bengaluru

ITA 399/BANG/2025[2013-14]Status: DisposedITAT Bangalore09 Oct 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

over 14 months and was not supported by any corroborative evidence. The AO found that statements recorded under section 132(4) carry strong evidentiary value, and retractions must be immediate and supported by proof of coercion or mistake. In this case, the assessee has not discharged his burden of proof ... sufficient cause for not producing it earlier. 4.1 The AO emphasizes that the statement recorded under section 132(4) of the Act has full evidentiary value. Once given voluntarily, it cannot be lightly retracted. The Hon'ble Courts and Tribunals have repeatedly held that the burden lies on the assessee

Amit Banthia, Bangalore vs. DCIT, Central Circle-1(1), Bangalore

In the result, the appeal of the assessee is allowed

ITA 2325/BANG/2024[2018-19]Status: DisposedITAT Bangalore09 Oct 2025AY 2018-19

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri K.R Pradeep, AdvocateFor Respondent: Shri Ballusamy N, JCIT (DR)
Section 132Section 143(3)Section 153CSection 153DSection 292CSection 69

through banking channels and fully reflected in the registered sale deed. It was argued that the sale deed, being a registered document, has high evidentiary value and cannot be brushed aside on the basis of uncorroborated oral statements. The ld. AR pointed out that there was no evidence ... locker close to the date of registration was also a strong circumstance. He contended that statements recorded under section 132(4) have evidentiary value and can be relied upon for making additions. The fact that the vendor company offered the cash as part of its own capital gains also supported

Chandulal Banthia, Bangalore vs. DCIT, Central Circle-1(1), Bangalore

In the result, the appeal of the assessee is allowed

ITA 2324/BANG/2024[2018-19]Status: DisposedITAT Bangalore09 Oct 2025AY 2018-19

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri K.R Pradeep, AdvocateFor Respondent: Shri Ballusamy N, JCIT (DR)
Section 132Section 143(3)Section 153CSection 153DSection 292CSection 69

through banking channels and fully reflected in the registered sale deed. It was argued that the sale deed, being a registered document, has high evidentiary value and cannot be brushed aside on the basis of uncorroborated oral statements. The ld. AR pointed out that there was no evidence ... locker close to the date of registration was also a strong circumstance. He contended that statements recorded under section 132(4) have evidentiary value and can be relied upon for making additions. The fact that the vendor company offered the cash as part of its own capital gains also supported

DCIT, Central Circle 8(4), Mumbai vs. Akshat Vinimay Private Limited, Kolkata

In the result, the appeal of the revenue in ITA No

ITA 1949/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Oct 2025AY 2014-15

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Dhaval ShahFor Respondent: Shri Rajesh Kumar Yadav (CIT-DR)
Section 132Section 143Section 143(3)Section 153ASection 250

statements and subsequent enquiries. 4 On facts and circumstances of the case and in law, the Id. CITIA) erred in not considering the corroborative evidentiary value of statements. 3 ITA No.1949 /Mum/2025 & c.o. 94/Mum/2025 Akshat Vinimay Private Limited 5. On the facts and in the circumstances of the case ... statements and subsequent enquiries. On facts and circumstances of the case and in law, the Id. CIT (A) erred in not considering the corroborative evidentiary value of statements. A. During the course of investigation under Project Falcon, statements under oath of various brokers were recorded. In particular, Shri Sanjay Kumar

Rapolu Kavitha, Hyderabad vs. DCIT., Central Circle-2(1), Hyderabad

In the result, the appeal of the assessee in ITA\nNo

ITA 775/HYD/2025[2019-20]Status: DisposedITAT Hyderabad08 Oct 2025AY 2019-20
For Respondent: Dr. Sachin Kumar, SR-DR
Section 143(2)Section 153CSection 69

held that “books" ordinarily mean bound\nmaterial; loose sheets or scraps of paper cannot be treated as books\nof account, and have weak evidentiary value as they are easily\ndetachable and unverifiable. It was thus argued that no addition can\nbe sustained merely on such loose papers, particularly when

Sunil Kumar Mukka, Warangal vs. DCIT., Central Circle-2(1), Hyderabad

In the result, the appeal of the assessee in ITA\nNo

ITA 772/HYD/2025[2019-20]Status: DisposedITAT Hyderabad08 Oct 2025AY 2019-20
For Respondent: Dr. Sachin Kumar, SR-DR
Section 143(2)Section 153CSection 69

held that “books\" ordinarily mean bound\nmaterial; loose sheets or scraps of paper cannot be treated as books\nof account, and have weak evidentiary value as they are easily\ndetachable and unverifiable. It was thus argued that no addition can\nbe sustained merely on such loose papers, particularly when

Deputy Commissioner of Income Tax, Central Circle - 3(2), Kolkata vs. Eskag Sanjeevani Pvt. Ltd., Kolkata

In the result, both the appeals of the Revenue are dismissed

ITA 1638/KOL/2024[2019-20]Status: DisposedITAT Kolkata08 Oct 2025AY 2019-20

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri Rajeeva Kumar, ARFor Respondent: Shri P.N. Barnwal, DR
Section 133(6)Section 139(1)Section 153ASection 68

filing evidences before the ld. Assessing Officer and ld. Assessing Officer has acted on the basis of statements of three persons, which lacks evidentiary value in absence of any substantive and corroborative evidences being brought on records. The ld. AR stated that where the AO has any doubt about

Arvindbhai Ratilal Shah T L/H Kokilaben Arvindbhai Shah, Surat vs. ITO, Ward 2(3) (6), Surat

In the result, the appeal of the assessee is dismissed

ITA 878/SRT/2025[2017-18]Status: HeardITAT Surat07 Oct 2025AY 2017-18

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2017-2018 Arvindbhai Ratilal Shah, T L/H Ito Ward 2(3)(6), Kokilaben Arvindbhai Shah, Income Tax Office, Room 405, C/O Sun Gems, 203 Syndicate Vs. Anavil Business Centre, Pal- House, Gujjar Falia Haripura, Hazira Road, Adajan, Surat-395003. Surat-394270. Pan No. Actps 6533 K Appellant Respondent

For Appellant: Mr. Suresh K Kabra, CAFor Respondent: Mr. J.K. Chandnani, Sr. DR
Section 143(1)Section 69A

after Assessment Year 2013-14, the assessee continued to file returns of income from other sources and maintained certain books of account. However, the evidentiary value of such books remains uncorroborated, as the same were not subjected to audit and the copies filed before us are unsigned, even

DCIT, Central Circle-2, Jaipur vs. Pradeep Jain, Jaipur

Appeals are hereby dismissed

ITA 955/JPR/2025[2018]Status: DisposedITAT Jaipur07 Oct 2025

Bench: SHRIGAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Avinash Khandelwal, C.AFor Respondent: Smt. Alka Gautam, CIT
Section 132Section 133ASection 143(2)

seized record is analysed in the light of search statement of the appellant, which in absence of any contrary material always have the evidentiary value, then it explicitly reveals that the transactions, which considered by AO as unexplained cash credits are noting regarding the mock transactions of option trading

Pradeep Jain, Jaipur vs. DCIT, Central Circle-2, Jaipur

Appeals are hereby dismissed

ITA 938/JPR/2025[2018-19]Status: DisposedITAT Jaipur07 Oct 2025AY 2018-19

Bench: SHRIGAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Avinash Khandelwal, C.AFor Respondent: Smt. Alka Gautam, CIT
Section 132Section 133ASection 143(2)

seized record is analysed in the light of search statement of the appellant, which in absence of any contrary material always have the evidentiary value, then it explicitly reveals that the transactions, which considered by AO as unexplained cash credits are noting regarding the mock transactions of option trading

Saroj Gupta, Nalagarh, Himachal Pradesh vs. ACIT (Central Circle), Shimla, Himachal Pradesh

The appeal stands partly allowed

ITA 367/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh07 Oct 2025AY 2019-20

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.367/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2019-20) Smt. Saroj Gupta Acit (Central Circle) M/S Aakash Hospital & Diagnostic बनाम/ Vs. Railway Board Building Main Bazar, Nalagarh (Hp) -174101 The Mall, Shimla (Hp) 171003 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Ahvpg-9358-F (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl.Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 25-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 07/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2019-20 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 27-01-2025 In The Matter Of An Assessment Framed By Ld. Assessingofficer [Ao] U/S. 143(3) Of The Act On 26-09-2021. The Sole Grievance Of The Assessee Is Confirmation Of Twin Additions Of Rs.41.94 Lacs & Addition Of Rs.50 Lacs. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed-Off As Under.

For Appellant: Shri Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Dr. Ranjit Kaur (Addl.CIT) – Ld. Sr. DR
Section 133A(1)Section 139(1)Section 143(3)Section 37(1)

During appellate proceedings, the assessee relied on judicial precedents to contend that statement during survey would not hold any evidentiary value. The Ld. CIT(A) concurred that there was no incriminating material for AYs 2013-14 to 2018-19 and therefore, deleted similar additions as made ... confirmed by Hon'ble Apex Court (reported as 352 ITR 480), such statements u/s 133A would not carry much evidentiary value. If the recorded statements are ignored then in such a case, except for incriminating material for only a small part of the year, there is no evidence of sales

DCIT, CC-I, Chandigarh vs. M/S Manohar Infrastructure & Construction Pvt. Ltd., Chandigarh

Appeal stands partly allowed

ITA 1306/CHANDI/2017[2012-13]Status: DisposedITAT Chandigarh07 Oct 2025AY 2012-13

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.1285/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2011-12) & 2. आयकर अपील सं. / Ita No.1286/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Manohar Infrastructure & Dcit Constructions Pvt. Ltd. Central Circle-1 बनाम/ Vs. Sco No 139-141 Sector 17-C Chandigarh. Chandigarh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecm-8616-P (अपीलाथ"/Appellant) : (""थ" / Respondent) & 3. आयकर अपील सं. / Ita No.1306/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit M/S Manohar Infrastructure & बनाम/ Central Circle-1 Constructions Pvt. Ltd. Chandigarh. Sco No 139-141 Sector 17-C Vs. Chandigarh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecm-8616-P (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Harry Rikhy (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Shri Sarabjeet Singh (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 09-07-2025 घोषणाकीतारीख /Date Of Pronouncement : 01/10/2025

For Appellant: Shri Harry Rikhy (Advocate) – Ld. ARFor Respondent: Shri Sarabjeet Singh (CIT) – Ld. DR
Section 131Section 132(1)Section 132(4)Section 153ASection 153A(1)(b)

assessee to the sellers over and above the registered amount. Therefore, this document is liable to be held as mere dumb document having no evidentiary value without corroboration thereof. 6. It could be seen that the whole basis of addition is enquiry made by Ld. AO by issuing notices

Manohar Infrastructure and Constructions Pvt. Ltd., Chandigarh vs. DCIT, CC-1, Chandigarh

Appeal stands partly allowed

ITA 1286/CHANDI/2017[2012-13]Status: DisposedITAT Chandigarh07 Oct 2025AY 2012-13

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.1285/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2011-12) & 2. आयकर अपील सं. / Ita No.1286/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Manohar Infrastructure & Dcit Constructions Pvt. Ltd. Central Circle-1 बनाम/ Vs. Sco No 139-141 Sector 17-C Chandigarh. Chandigarh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecm-8616-P (अपीलाथ"/Appellant) : (""थ" / Respondent) & 3. आयकर अपील सं. / Ita No.1306/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit M/S Manohar Infrastructure & बनाम/ Central Circle-1 Constructions Pvt. Ltd. Chandigarh. Sco No 139-141 Sector 17-C Vs. Chandigarh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecm-8616-P (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Harry Rikhy (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Shri Sarabjeet Singh (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 09-07-2025 घोषणाकीतारीख /Date Of Pronouncement : 01/10/2025

For Appellant: Shri Harry Rikhy (Advocate) – Ld. ARFor Respondent: Shri Sarabjeet Singh (CIT) – Ld. DR
Section 131Section 132(1)Section 132(4)Section 153ASection 153A(1)(b)

assessee to the sellers over and above the registered amount. Therefore, this document is liable to be held as mere dumb document having no evidentiary value without corroboration thereof. 6. It could be seen that the whole basis of addition is enquiry made by Ld. AO by issuing notices

Manohar Infrastructure and Constructions Pvt. Ltd., Chandigarh vs. DCIT, CC-1, Chandigarh

Appeal stands partly allowed

ITA 1285/CHANDI/2017[2011-12]Status: DisposedITAT Chandigarh07 Oct 2025AY 2011-12

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.1285/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2011-12) & 2. आयकर अपील सं. / Ita No.1286/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Manohar Infrastructure & Dcit Constructions Pvt. Ltd. Central Circle-1 बनाम/ Vs. Sco No 139-141 Sector 17-C Chandigarh. Chandigarh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecm-8616-P (अपीलाथ"/Appellant) : (""थ" / Respondent) & 3. आयकर अपील सं. / Ita No.1306/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit M/S Manohar Infrastructure & बनाम/ Central Circle-1 Constructions Pvt. Ltd. Chandigarh. Sco No 139-141 Sector 17-C Vs. Chandigarh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecm-8616-P (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Harry Rikhy (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Shri Sarabjeet Singh (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 09-07-2025 घोषणाकीतारीख /Date Of Pronouncement : 01/10/2025

For Appellant: Shri Harry Rikhy (Advocate) – Ld. ARFor Respondent: Shri Sarabjeet Singh (CIT) – Ld. DR
Section 131Section 132(1)Section 132(4)Section 153ASection 153A(1)(b)

assessee to the sellers over and above the registered amount. Therefore, this document is liable to be held as mere dumb document having no evidentiary value without corroboration thereof. 6. It could be seen that the whole basis of addition is enquiry made by Ld. AO by issuing notices