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

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 examine the explanation with reference to books of account;  Addition based solely on a retracted statement without corroboration is not tenable. The Court specifically observed that even where retraction is delayed

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132(4) may have evidentiary value; However, once retracted, it cannot be relied upon in isolation; The Assessing Officer must examine the explanation with reference to books of account; Addition based solely on a retracted statement without corroboration is not tenable. The Court specifically observed that even where retraction is delayed, the AO is not absolved from examining

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132(4) may have evidentiary value; However, once retracted, it cannot be relied upon in isolation; The Assessing Officer must examine the explanation with reference to books of account; ➤ Addition based solely on a retracted statement without corroboration is not tenable. The Court specifically observed that even where retraction is delayed, the AO is not absolved from examining

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132(4) may have evidentiary value; However, once retracted, it cannot be relied upon in isolation; The Assessing Officer must examine the explanation with reference to books of account; Addition based solely on a retracted statement without corroboration is not tenable. The Court specifically observed that even where retraction is delayed, the AO is not absolved from examining

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132(4) may have evidentiary value; However, once retracted, it cannot be relied upon in isolation; The Assessing Officer must examine the explanation with reference to books of account; Addition based solely on a retracted statement without corroboration is not tenable. The Court specifically observed that even where retraction is delayed, the AO is not absolved from examining

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132(4) may have evidentiary value; However, once retracted, it cannot be relied upon in isolation; The Assessing Officer must examine the explanation with reference to books of account; Addition based solely on a retracted statement without corroboration is not tenable. The Court specifically observed that even where retraction is delayed, the AO is not absolved from examining

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132(4) may have evidentiary value; However, once retracted, it cannot be relied upon in isolation; The Assessing Officer must examine the explanation with reference to books of account; Addition based solely on a retracted statement without corroboration is not tenable. The Court specifically observed that even where retraction is delayed, the AO is not absolved from examining

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-20, DELHI vs. M. B. POWER (MADHAYA PRADESH) LTD, DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

132(4) of the Act. Basis the statement, not only his case was transferred to New Delhi u/s 127 of the Act but notices u/s 153C were issued to the assessee. On these fact, Hon’ble Karnataka High Court referring to V.C. Shukla (supra) and Common Cause (supra) quashed the notices ITA No.3850/Del/2023 & Others u/s 153C, issued on the basis

MB POWER (MADHYA PRADESH) LIMITED ,SOUTH EAST DELHI vs. DCIT, CENTRAL CIRCLE-20, DELHI, DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

132(4) of the Act. Basis the statement, not only his case was transferred to New Delhi u/s 127 of the Act but notices u/s 153C were issued to the assessee. On these fact, Hon’ble Karnataka High Court referring to V.C. Shukla (supra) and Common Cause (supra) quashed the notices ITA No.3850/Del/2023 & Others u/s 153C, issued on the basis

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 20, DELHI vs. M.B. POWER (MADHAYA PRADESH) LTD, DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

132(4) of the Act. Basis the statement, not only his case was transferred to New Delhi u/s 127 of the Act but notices u/s 153C were issued to the assessee. On these fact, Hon’ble Karnataka High Court referring to V.C. Shukla (supra) and Common Cause (supra) quashed the notices ITA No.3850/Del/2023 & Others u/s 153C, issued on the basis

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-20, DELHI vs. MB POWER (MADHYA PRADESH) LIMITED, DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

132(4) of the Act. Basis the statement, not only his case was transferred to New Delhi u/s 127 of the Act but notices u/s 153C were issued to the assessee. On these fact, Hon’ble Karnataka High Court referring to V.C. Shukla (supra) and Common Cause (supra) quashed the notices ITA No.3850/Del/2023 & Others u/s 153C, issued on the basis

MB POWER (MADHYA PRADESH) LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE-20, DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

132(4) of the Act. Basis the statement, not only his case was transferred to New Delhi u/s 127 of the Act but notices u/s 153C were issued to the assessee. On these fact, Hon’ble Karnataka High Court referring to V.C. Shukla (supra) and Common Cause (supra) quashed the notices ITA No.3850/Del/2023 & Others u/s 153C, issued on the basis

JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-20, DELHI vs. M B POWER (MADHYA PRADESH) LTD., DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

132(4) of the Act. Basis the statement, not only his case was transferred to New Delhi u/s 127 of the Act but notices u/s 153C were issued to the assessee. On these fact, Hon’ble Karnataka High Court referring to V.C. Shukla (supra) and Common Cause (supra) quashed the notices ITA No.3850/Del/2023 & Others u/s 153C, issued on the basis

DCIT, GHAZIABAD vs. M/S. DEVIDAYAL ALUMINIUM INDUSTRIES PVT. LTD., GHAZIABAD

In the result, appeal of the Revenue is dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

132(4) of the Act. Basis the statement, not only his case was transferred to New Delhi u/s 127 of the Act but notices u/s 153C were issued to the assessee. On these fact, Hon’ble Karnataka High Court referring to V.C. Shukla (supra) and Common Cause (supra) quashed the notices ITA No.3850/Del/2023 & Others u/s 153C, issued on the basis

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. M/S ACE MEGA STRUCTURE PRIVATE LIMITED, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

132(4) which was not corroborated by any material evidence, neither such statement would be a conclusive evidence, nor any addition could be made. Further, the judgment of Hon'ble HIGH COURT OF GUJARAT in the case of Principal Commissioner of Income-tax (Central) vs. Naresh Nemchand Shah reported at 2023] 156 taxmann.com 346 (Gujarat) has held as under: "Where

ACE MEGA STRUCTURES PRIVATE LIMITED,UTTAR PRADESH vs. DCIT/ACIT CEN CIR, NOIDA, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

132(4) which was not corroborated by any material evidence, neither such statement would be a conclusive evidence, nor any addition could be made. Further, the judgment of Hon'ble HIGH COURT OF GUJARAT in the case of Principal Commissioner of Income-tax (Central) vs. Naresh Nemchand Shah reported at 2023] 156 taxmann.com 346 (Gujarat) has held as under: "Where

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CC- 30,, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

Section 153 C of the Act but in relation to Section 153A of the Act as well.Consequently, this Court does not find any error having been committed by the ITAT in accepting the plea of the Assessee that there is no 64 I.T.As. No.4039, 4040, 4041, 4042, 4043, 4064, 4065, 4066, 4067, 4068, 4069, 4070/DEL/2017 incriminating document which was seized

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PARKASH INDUSTRIES LTD, HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

Section 153 C of the Act but in relation to Section 153A of the Act as well.Consequently, this Court does not find any error having been committed by the ITAT in accepting the plea of the Assessee that there is no 64 I.T.As. No.4039, 4040, 4041, 4042, 4043, 4064, 4065, 4066, 4067, 4068, 4069, 4070/DEL/2017 incriminating document which was seized