“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

Shailesh Goyal, Tonk vs. ACIT, Centre Circle Jaipur, Jaipur

In the result, appeal of the assessee is allowed in above terms

ITA 496/JPR/2024[2016-17]Status: DisposedITAT Jaipur29 Jul 2025AY 2016-17

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Respondent byFor Respondent: Date of hearing

Section 132(1)Section 133ASection 143(3)Section 250Section 271(1)(c)Section 69C

More-over addition made on the basis of deaf and dumb papers in absence of any supporting and corroborative details and evidence carried no evidentiary value as per Evidence Act. Thus, the addition so made deserves to be deleted summarily. 1.1 The Id. CIT(A) has grossly erred in upholding ... view of the scope and ambit of the materials collected during the course of survey action under section 133A shall not have any evidentiary value, as rightly held by the Commissioner and the Tribunal since such statement was not attached to the provisions of section 133A

Minesh Bipinbhai Patel, Vadodara vs. The Dy.CIT, Central Circle-1, Vadodara

In the result the appeal of the assessee for A

ITA 650/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad29 Jul 2025AY 2016-17

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarit(Ss)A No.23/Ahd/2024 Asstt.Year : 2015-16 & Asstt.Year 2016-17 Minesh Bipinbhai Patel The Dcit, Cent.Cir.1 10, Shantivan Society Vs. Race Course Sussen Tarsali Road Vadodara. Makarpura Vadodara 390 010. Pan : Acqpp 7756 G (Appellant) (Respondent) Assessee By : Shri Tushar Hemani, Sr.Advocate Revenue By : Shri Sher Singh, Cit-Dr & Shri Hargovind Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 24/07/2025 घोषणा की तारीख /Date Of Pronouncement: 29/07/2025 आदेश/O R D E R आदेश आदेश आदेश

For Appellant: Shri Tushar Hemani, Sr.AdvocateFor Respondent: Shri Sher Singh, CIT-DR and Shri Hargovind Singh, Sr.DR

Section 132Section 139(1)Section 143(3)Section 153ASection 250

order of CIT(A) and contended that such a report was an afterthought, obtained much later during the assessment proceedings and lacks evidentiary value in light of the contemporaneous and spontaneous nature of the seized diary entries. The DR emphasized that the valuation report is inherently subjective and cannot displace ... were merely speculative jottings. He noted that mere denials by the assessee or confirmations filed without adequate verification were not sufficient to displace the evidentiary value of seized materials. 7.6 Based on the above considerations, the CIT(A) proceeded to adopt an estimation. The AO had made a substantive addition

Jayachandraraju Gangaraju, Nellore vs. ITO., Ward-2, Nellore

In the result, the appeal of the assessee is allowed

ITA 125/HYD/2025[2017-18]Status: DisposedITAT Hyderabad25 Jul 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri VVSC Muralidhar RaoFor Respondent: Dr. Sachin Kumar, SR-DR

Section 143Section 153Section 69

withdrawn. He also argued that even if there were some contradictions in the oral statements regarding the date or place of loan disbursement, the evidentiary value of the documentary records and the lender’s admission of giving the loan remain unimpeached. He submitted that the assessee had discharged the onus

Rameshwar Lal Vyas, Beawar, Ajmer vs. DCIT, Central Circle, Ajmer

In the result, appeal of the assessee is allowed

ITA 1257/JPR/2024[2017-18]Status: DisposedITAT Jaipur24 Jul 2025AY 2017-18

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Respondent: Shri Vinod Gupta CA, Ld. AR

Section 133ASection 139Section 143(3)Section 250Section 271ASection 69

party and submitted confirmation and affidavit of such parties. With respect to statement, he stated that statement u/s.133A of the Act has no evidentiary value. The CIT (A) did not accept the submissions of the assessee and confirmed the addition made by the AO. 7. We have gone through ... statement is concerned, we note that the statement recorded u/s.133A of the Act has no evidentiary value and any admission made during the survey cannot be allowed to be the basis of addition. It is a settled legal position that statement recorded u/s.133A of the Act does not have

O.C Tanner India Private Limited, Mumbai vs. DCIT, Circle -2(3)(1), Mumbai

In the result the appeal is, accordingly, he appeal is, accordingly, allowed for statistical allowed for statistical purposes

ITA 5785/MUM/2024[2021-22]Status: DisposedITAT Mumbai24 Jul 2025AY 2021-22

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2021-22 O.C. Tanner India Pvt. Ltd., Dy. Cit, Circle-2(3)(1), No. 2, Lave 7 Tower 2, Phase Ii, 552, 5Th Floor, Aayakar Bhavan, Raiaskaran Techpark Andheri Vs. Maharishi Karve Road, Kurla Road, Andheri East, Mumbai-400020. Sakinaka S.O. Mumbai, Mumbai-400072. Pan No. Aabco 1031 F Appellant Respondent

For Appellant: Mr. Vijay Mehta, CA

Section 144C(13)Section 144C(5)

always be available in documentary form, and hence, the cumulative evidentiary documentary form, and hence, the cumulative evidentiary documentary form, and hence, the cumulative evidentiary value of regular, topic value of regular, topic-specific email trails becomes crucial. specific email trails becomes crucial. The Appellant subm The Appellant submits that

Professional Automotives Private Limited, Jammu vs. Assistant Commissioner of Income Tax, Central Circle-1, Jaipur

ITA 813/JPR/2025[2017-18]Status: DisposedITAT Jaipur23 Jul 2025AY 2017-18

For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)

Section 132(4)Section 143(3)Section 37(1)

arise. Therefore, the statement of the managing director of the assessee, recorded patently under Section 132(4) of the Act, does not have any evidentiary value. This provision embedded in sub-section (4) is obviously based on the well-established rule of evidence that mere confessional statement without there being

Professional Automotives Private Limited, Jammu vs. Assistant Commissioner of Income Tax, Central Circle-1, Jaipur

In the result the appeal of the assessee in ITA no

ITA 812/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)

Section 143(3)Section 37(1)

present case, after considering catena of previous decisions, held that the statements recorded under section 132(4) of the IT Act have great evidentiary value and they cannot be discarded summarily and cryptic manner, by simply observing that the assessee retracted from his statement. One has to come ... reproduce para 15 of the said judgment, which reads thus, "15. In our view, the statements recorded under section 132(4) have great evidentiary value and it cannot be discarded as in the instant case ITA No. 720/JP/2017 M/s BannalalJat Construction Pvt. Ltd., Bhilwara v. ACIT, Central Circle-Ajmer

M/S Banna Lal Jat Constructions Pvt. Ltd., Bhilwara vs. DCIT, Central Circle, Ajmer

Appeal is partly allowed by reducing the penalty to the

ITA 1569/JPR/2024[2015-16]Status: DisposedITAT Jaipur23 Jul 2025AY 2015-16

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

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR

Section 132Section 250Section 271ASection 274

decision of Hon'ble Rajasthan High Court in case of Ravi Mathur & Ors. held that statement recorded u/s 132(4) has a great evidentiary value and thus confirmed the addition made by AO. (g) From the above facts it can be noted that assessee has proved that cash found during ... statement about the source of cash recorded in survey has been bypassed. Hence even though addition is confirmed on the technical ground regarding the evidentiary value of statement recorded u/s 132(4), it would not automatically lead to a conclusion that by not disclosing such amount in the return

L.M. Fabrication, Distt. Solan, Himachal Pradesh vs. DCIT (Central Circle ), Shimla, Himachal Pradesh

In the result, appeal of the Assessee is partly allowed

ITA 366/CHANDI/2025[2019-2020]Status: DisposedITAT Chandigarh23 Jul 2025AY 2019-2020

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 366/Chd/2025 "नधा"रण वष" / Assessment Year : 2019-20 L.M Fabrication, Dcit, बनाम Village Nalka, Central Circle, Opp Raj Industry Shimla Vs. Vilalge Nalka Bagbania Po Manpura, Tehsil Baddi Solan H.P. 174101 "थायी लेखा सं./ Pan No: Aaefl3340C अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 21.07.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 23.07.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 18.10.2021 Passed By The Ld. Commissioner Of Income Tax(Apepals)-3, Gurgaon For The Assessment Year 2019-20. 2. Grounds Of Appeal Are As Under:

For Appellant: Sh. Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 115Section 115BSection 133ASection 69C

failed to appreciate that the whole of the additions is based on the statement recorded during survey which has no evidentiary value at all and as such the entire addition of 366-Chd-2025 L.M. Fabrication, Distt. Solan 6 Rs. 15 lacs are not justified and only the appropriate addition ... with decisions of the other High Courts, wherein, it has been held that the statement recorded during the course of survey proceedings have no evidentiary value and cannot be relied on. It is further been contended that the noting recovered during survey are rough noting and no addition

Dy. Commissioner of Income Tax, Central Circle 5(1), Mumbai. vs. Sarvapriya Leasing Pvt. Ltd., Mumbai

In the result, the appeal filed by the revenue bearing ITA No 3108/Mum/2023 is dismissed

ITA 3109/MUM/2023[2018-19]Status: DisposedITAT Mumbai23 Jul 2025AY 2018-19

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjee

Section 132Section 153CSection 250Section 69A

absence of any corroborative evidence—does not constitute admissible or credible material. Consequently, the action initiated by the revenue against the assessee company lacks evidentiary value, is contrary to law, and the impugned notices issued under Section 153C of the Act are liable to be quashed as being void, illegal ... irrelevant as evidence being not admissible under Section 34 so as to constitute evidence with respect to the transactions mentioned therein being of no evidentiary value. The entire prosecution based upon such entries which led to the investigation was quashed by this Court. 21. We are constrained to observe that

Dy. Commissioner of Income Tax, Central Circle 5(1), Mumbai. vs. Sarvapriya Leasing Pvt. Ltd., Mumbai

In the result, the appeal filed by the revenue bearing ITA No 3108/Mum/2023 is dismissed

ITA 3108/MUM/2023[2019-20]Status: DisposedITAT Mumbai23 Jul 2025AY 2019-20

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeedeputy Commissioner Of Vs Saarrthi Reality & Infra Llp, 2Nd Floor, Geetai Sankul, Paud Road, Income-Tax, Central Circle 5(1), Mumbai Kothrud, Pune, Pin-411037 Room No. 1928, 19Th Floor, Air India Building, Nariman Point, Pan: Acmfs8187L Mumbai-400021 Appellant Respondent - A.Y. 2019-20 - A.Y. 2018-19

For Appellant: Shri Jaiprakash Bairagra & Ms. Rupa NandaFor Respondent: Shri Dr. Kishore Dhule – CIT DR

Section 132Section 153CSection 250Section 69A

Infra LLP & Others evidence—does not constitute admissible or credible material. Consequently, the action initiated by the revenue against the assessee company lacks evidentiary value, is contrary to law, and the impugned notices issued under Section 153C of the Act are liable to be quashed as being void, illegal ... irrelevant as evidence being not admissible under Section 34 so as to constitute evidence with respect to the transactions mentioned therein being of no evidentiary value. The entire prosecution based upon such entries which led to the investigation was quashed by this Court. 21. We are constrained to observe that

Dy. Commissioner of Income-Tax, Central Circle-5(1), Mumbai. vs. Saarrthi Realty and Infra Limited Liability Partnership, Mumbai

In the result, the appeal filed by the revenue bearing ITA No 3108/Mum/2023 is dismissed

ITA 3106/MUM/2023[2019-20]Status: DisposedITAT Mumbai23 Jul 2025AY 2019-20

For Appellant: Shri Jaiprakash Bairagra & Ms. Rupa NandaFor Respondent: Shri Dr. Kishore Dhule – CIT DR

Section 132Section 153CSection 250Section 69A

Brij Kumar, New Delhi vs. DCIT Central Circle 15, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2011/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Jul 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri S. Rifaur Rahmanbrij Kumar, Vs. Dcit, Central Circle 15, M – 117, Guru Harkishan Nagar, New Delhi. Paschim Vihar, West Sunder Vihar, New Delhi – 110 087. (Pan : Aanpk3701B) (Appellant) (Respondent) Assessee By : Shri Rajat Jain, Ca Shri Akshat Jain, Ca Revenue By : Shri Jitender Singh, Cit Dr Date Of Hearing : 26.05.2025 Date Of Order : 23.07.2025 O R D E R

For Appellant: Shri Rajat Jain, CAFor Respondent: Shri Jitender Singh, CIT DR

Section 153CSection 260ASection 69A

case of Moosa S. Madha & Azam S. Madha v. CIT [(1973) 4 SCC 128] was of the opinion that photostat copies have very little evidentiary value. 17. Admittedly, the entire foundation is laid on the basis of the photocopy of the alleged agreement to sell dated 5 March

Jeevan Javerchand Rathod, Mumbai vs. Income Tax Officer 31(2)(1), Mumbai

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

ITA 3592/MUM/2025[2013-14]Status: DisposedITAT Mumbai22 Jul 2025AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Respondent: Mr. Haridas Bhat

Section 133(6)Section 250

confirm that the appellant was authorized to collect cash on behalf of customers. As such, the confirmation letter does not hold sufficient evidentiary value to counter the AO's findings. e) The 5% Addition Was Reasonable and Based on Facts The appellant argued that the addition of 5% as unexplained

DCIT, CC-3, Ludhiana, Kitchlu Nagar vs. Sh. Aman Batra, Civil Lines

Appeal stands dismissed

ITA 1041/CHANDI/2024[2022-23]Status: DisposedITAT Chandigarh21 Jul 2025AY 2022-23

Bench: or at the time of hearing of the appeal.

For Appellant: Shri Pankaj Bhalla, C.AFor Respondent: Shri Manav Bansal, CIT, DR

Section 143(2)Section 144BSection 28Section 69Section 69ASection 69C

reliance on the ‘whataspp chat’ without complying with the provisions of section 65B of the Evidence Act and considering that there is no evidentiary value of 'Whatsapp chat' as per the judgment of 'Hon'ble Apex Court' is against the facts and circumstances of the case and other judgements ... placed reliance on the 'Whatsapp chat' without complying with the provisions of section 65B of the Evidence Act and considering that there is no evidentiary value of 'Whatsapp chat' as per the judgment of 'Hon'ble Apex Court' is against the facts and circumstances of the case and other judgements

DCIT(CC)-8(3), Mumbai vs. Mehta Emporium Jewellers, Mumbai

In the result, appeal of the revenue is partly allowed for statistical purposes

ITA 2830/MUM/2025[2019-20]Status: DisposedITAT Mumbai21 Jul 2025AY 2019-20

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No.2830/Mum/2025 (निर्धारण वर्ा/Assessment Year :2019-20) Deputy Commissioner V/S. Mehta Emporium Of Income Tax- Central बिधम Jewellers Circle 8(3), Mumbai 101, Mehta Arch, S.V. Road, Room No. 656, 6Th Floor, Opp. Natraj Market, Malad Aayakar Bhavan, M.K. (West), Mumbai 400064 Road, Mumbai 400020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aalfm2962N Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी निर्ााररती की ओर से /Assessee By: Shri. Devendra Jain रधजस्व की ओर से /Revenue By: Shri. R.A. Dhyani, Cit Dr

For Appellant: Shri. Devendra JainFor Respondent: Shri. R.A. Dhyani, CIT DR

Section 132Section 143(3)Section 250Section 292CSection 69A

2830/Mum/2025 AY 2019-20 Mehta Emporium Jewellers the search. Therefore, in my considered view this document lacks the evidentiary value. 18. It is also worthwhile to note that the Courts have time and again examined the authenticity of such documents and have also examined whether addition could be made ... view that the loose papers found and seized from the business premises of the appellant is nothing but a dumb document without having any evidentiary value which can be used against the appellant for making an addition u/s 69A of the I.T Act. The addition made

Mallya Real Estates P.Ltd, Delhi vs. ITO, Ward-16(2), New Delhi

ITA 6158/DEL/2017[2013-14]Status: DisposedITAT Delhi18 Jul 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Amit Katoch, Sr. DR

Section 131Section 68

Companies Act, 1956 has to comply with statutory formalities. That these companies were complying with such formalities does not add any credibility or evidentiary value. In any case, it does not ipso facto prove that the transactions are genuine....... Compliance with statutory norms and requirements is only one aspect

Homelife Buildcon Private Limited, Sunview Enclave, Ayali Kalan, Ludhiana, Punjab vs. Smt. Samandeep Kaur DCIT-Central Circle-1, Ludhiana, Punjab

In the result, Revenue appeal is dismissed and appeal filed by the assessee is allowed

ITA 880/CHANDI/2024[2021-2022]Status: DisposedITAT Chandigarh17 Jul 2025AY 2021-2022

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 880/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Ludhiana, Punjab-142027 स्थायी लेखा सं./PAN NO: AABCH5690M अपीलार्थी/Appellant बनाम The DCIT Central Circle-1 Ludhiana, Punjab प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 1036/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 बनाम Homelife Buildcon Private Limited Sunview Enclave, Ayali

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rohit Kapoor, C.AFor Respondent: Shri Manav Bansal, CIT, DR

Section 115BSection 153D

denied by both the ladies in their statements before the department. The assessee relied upon a number of judgments for the preposition that no evidentiary value can be attached to the statement of ‘third party’ or any of the parties during search or post search. It relied upon the judgments ... Banda and Surbhi Banda the purchaser of plots had been recorded during search or later on during the course of assessment proceedings. Since the evidentiary value of registered document cannot be ignored and brushed aside merely on the basis of certain digital data from third party, which has not been

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Homelife Buildcon Pvt. Ltd., Ludhiana

In the result, Revenue appeal is dismissed and appeal filed by the assessee is allowed

ITA 1036/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh17 Jul 2025AY 2021-22

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 880/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Ludhiana, Punjab-142027 स्थायी लेखा सं./PAN NO: AABCH5690M अपीलार्थी/Appellant The DCIT Central Circle-1 Ludhiana, Punjab प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 1036/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Lu

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rohit Kapoor, C.AFor Respondent: Shri Manav Bansal, CIT, DR

Section 115BSection 153D

Rangamani Krishnan, Chennai vs. ACIT, Central Circle-1(2), Chennai

In the result all the five appeals filed by the assessee for the A

ITA 457/CHNY/2025[2019-20]Status: DisposedITAT Chennai17 Jul 2025AY 2019-20

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

For Appellant: Shri D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT

Section 131Section 142Section 142(1)Section 250Section 69

foundational elements required u/s.153C of the Act. The ld.AR therefore contends that satisfaction recorded on the basis of such loose sheets, which have no evidentiary value in the eyes of law, constitutes nothing more than a speculative assertion. It cannot, therefore, form the jurisdictional basis for the assumption of proceedings ... neither admitted by the assessee nor confirmed by its alleged author, and in the absence of any independent corroborative material, such document has no evidentiary value in the eyes of law. The Hon’ble Supreme Court has, in unequivocal terms, held that entries in loose papers or unverified records seized