RAKESH KUMAR BANSAL,GUJRAT vs. DCIT, CENTRAL CERCLE , GHAZIABAD

In the result, both the appeals of the assessees are partly allowed

Bench: Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.2515/Del/2022 िनधा"रणवष"/Assessment Year: 2015-16 बनाम Geeta Bansal Dcit Ch. No. 206-207, Vs. Central Circle Ansal Satyam Rdc, Ghaziabad. Rajnagar, Ghaziabad, Uttar Pradesh 201002 Pan No. Aispb9075G अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.2516/Del/2022 िनधा"रणवष"/Assessment Year: 2015-16 बनाम Rakesh Kumar Bansal Dcit Ch. No. 206-207, Vs. Central Circle Ansal Satyam Rdc, Ghaziabad. Rajnagar, Ghaziabad, Uttar Pradesh 201002 Pan No. Abwpb1370M अपीलाथ" Appellant ""यथ"/Respondent

TDS on property from Axis Bank Ltd. Assessee furnished copy of loan sanctioned letters before the Assessing Officer. Assessee denied any payment of cash against purchase of property However, the Assessing Officer relying on the digital/tally data found and seized in the premises of V.K. Patel and his statement recorded u/s 132(4) of the Act came to the conclusion

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

TDS Deduction → ITR Disclosure. The following records are placed on record:  GST-compliant invoices;  e-Way Bills evidencing physical movement of goods;  Goods Receipt Notes confirming inward entries;  Ledger accounts in audited books;  Bank statements showing RTGS/NEFT payments;  Form 16A evidencing deduction of tax under Section 194Q;  Vendor’s Income Tax Return acknowledgements. Books of account have not been rejected

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

TDS Deduction → ITR Disclosure. The following records are placed on record:  GST-compliant invoices;  e-Way Bills evidencing physical movement of goods;  Goods Receipt Notes confirming inward entries;  Ledger accounts in audited books;  Bank statements showing RTGS/NEFT payments;  Form 16A evidencing deduction of tax under Section 194Q;  Vendor’s Income Tax Return acknowledgements. Books of account have not been rejected

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

TDS Deduction → ITR Disclosure. The following records are placed on record:  GST-compliant invoices;  e-Way Bills evidencing physical movement of goods;  Goods Receipt Notes confirming inward entries;  Ledger accounts in audited books;  Bank statements showing RTGS/NEFT payments;  Form 16A evidencing deduction of tax under Section 194Q;  Vendor’s Income Tax Return acknowledgements. Books of account have not been rejected

M/S. BAIN & COMPANY INDIA PVT. LTD.,GURGAON vs. ITO (TDS) (INTERNATIONAL TAXATION), NEW DELHI

TDS under section 195 of the Income Tax Act can be held liable to deduct such sums at a time when explanation 4 was factually not on the statute book, all deductions liable to be made and the assessment years in question being prior to the year 2012. 81. This question is answered by two latin maxims, lex non cogit

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE - 13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

65B of the Indian Evidence Act, 1872. Hence, addition made of Rs. 11,13,114/- merely on the basis of alleged un-substantiated soft data/ excel sheets, is bad in law and is liable to be quashed. Addition u/s 37(1) of the Income Tax Act, 1961 not attracted 8. That on the facts and in the circumstances

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE - 13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

65B of the Indian Evidence Act, 1872. Hence, addition made of Rs. 11,13,114/- merely on the basis of alleged un-substantiated soft data/ excel sheets, is bad in law and is liable to be quashed. Addition u/s 37(1) of the Income Tax Act, 1961 not attracted 8. That on the facts and in the circumstances

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE -13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

65B of the Indian Evidence Act, 1872. Hence, addition made of Rs. 11,13,114/- merely on the basis of alleged un-substantiated soft data/ excel sheets, is bad in law and is liable to be quashed. Addition u/s 37(1) of the Income Tax Act, 1961 not attracted 8. That on the facts and in the circumstances

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE - 13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

65B of the Indian Evidence Act, 1872. Hence, addition made of Rs. 11,13,114/- merely on the basis of alleged un-substantiated soft data/ excel sheets, is bad in law and is liable to be quashed. Addition u/s 37(1) of the Income Tax Act, 1961 not attracted 8. That on the facts and in the circumstances

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE - 13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

65B of the Indian Evidence Act, 1872. Hence, addition made of Rs. 11,13,114/- merely on the basis of alleged un-substantiated soft data/ excel sheets, is bad in law and is liable to be quashed. Addition u/s 37(1) of the Income Tax Act, 1961 not attracted 8. That on the facts and in the circumstances

DCIT, CENTRAL CIRCLE-6, INCOME TAX DEPARTMENT vs. PMK IMPEX PRIVATE LIMITED , ATMA RAM HOUSE

TDS on such purchase was\nalso deducted and deposited. The evidences as found and seized during\nthe course of search corroborate the veracity of our version in this\nregard. The contents of the impugned conversations/chats may be\nanalysed in the light of the above said version which will clarify the\nentire gamut of facts and circumstances pursuant to which

MODI RUBBER LTD. vs. ASSISTANT COMMISSIONER OF INCOME-TAX

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE CHANDER SHEKHAR

Section 65B of the Indian Evidence Act, 1872. Further, the same was very much in existence even before the prosecution was contemplated. The present petitions pertain to deduction of TDS

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

section 65B(4) of the\nIndian Evidence Act, 1872 is a condition precedent to the\nadmissibility of evidence by way of electronic record as\nsection 65B(4) of the Indian Evidence Act, 1872 is a\nmandatory. In view of the same, it was submitted that the\npen drive (an electronic record), being relied upon by the\ndepartment, is not admissible

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

section 65B(4) of the\nIndian Evidence Act, 1872 is a condition precedent to the\nadmissibility of evidence by way of electronic record as\nsection 65B(4) of the Indian Evidence Act, 1872 is a\nmandatory. In view of the same, it was submitted that the\npen drive (an electronic record), being relied upon by the\ndepartment, is not admissible

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

section 65B(4) of the\nIndian Evidence Act, 1872 is a condition precedent to the\nadmissibility of evidence by way of electronic record as\nsection 65B(4) of the Indian Evidence Act, 1872 is a\nmandatory. In view of the same, it was submitted that the\npen drive (an electronic record), being relied upon by the\ndepartment, is not admissible

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

section 65B(4) of the\nIndian Evidence Act, 1872 is a condition precedent to the\nadmissibility of evidence by way of electronic record as\nsection 65B(4) of the Indian Evidence Act, 1872 is a\nmandatory. In view of the same, it was submitted that the\npen drive (an electronic record), being relied upon by the\ndepartment, is not admissible

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

section 65B(4) of the\nIndian Evidence Act, 1872 is a condition precedent to the\nadmissibility of evidence by way of electronic record as\nsection 65B(4) of the Indian Evidence Act, 1872 is a\nmandatory. In view of the same, it was submitted that the\npen drive (an electronic record), being relied upon by the\ndepartment, is not admissible

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

section 65B(4) of the\nIndian Evidence Act, 1872 is a condition precedent to the\nadmissibility of evidence by way of electronic record as\nsection 65B(4) of the Indian Evidence Act, 1872 is a\nmandatory. In view of the same, it was submitted that the\npen drive (an electronic record), being relied upon by the\ndepartment, is not admissible

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

section 65B(4) of the\nIndian Evidence Act, 1872 is a condition precedent to the\nadmissibility of evidence by way of electronic record as\nsection 65B(4) of the Indian Evidence Act, 1872 is a\nmandatory. In view of the same, it was submitted that the\npen drive (an electronic record), being relied upon by the\ndepartment, is not admissible