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

bogus expenditure collapses. IV. Section 65B Compliance IV. Section 65B Compliance – Electro IV. Section 65B Compliance IV. Section 65B Compliance Electro Electronic Evidence Electro nic Evidence nic Evidence nic Evidence • No chain-of-custody documentation has been placed to establish reliability of alleged seized digital extracts relied upon by the Assessing Officer. V. Comparative Position – Sunil Aggarwal V. Comparative Position

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

bogus expenditure collapses. IV. Section 65B Compliance IV. Section 65B Compliance – Electro IV. Section 65B Compliance IV. Section 65B Compliance Electro Electronic Evidence Electro nic Evidence nic Evidence nic Evidence • No chain-of-custody documentation has been placed to establish reliability of alleged seized digital extracts relied upon by the Assessing Officer. V. Comparative Position – Sunil Aggarwal V. Comparative Position

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

bogus expenditure collapses. IV. Section 65B Compliance – Electronic Evidence • No chain-of-custody documentation has been placed to establish reliability of alleged seized digital extracts relied upon by the Assessing Officer. V. Comparative Position – Sunil Aggarwal vs Present Case Issue Sunil Aggarwal (Delhi HC) Present Case Statement u/s 132(4) Recorded and later retracted Recorded and retracted before AO Timing

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

bogus expenditure collapses. IV. Section 65B Compliance – Electronic Evidence No chain-of-custody documentation has been placed to establish reliability of alleged seized digital extracts relied upon by the Assessing Officer. V. Comparative Position – Sunil Aggarwal vs Present Case Issue Statement u/s 132(4) Timing of Retraction Requirement Sunil Aggarwal (Delhi HC) Recorded and later retracted Not immediate AO must

SAMEER MUTREJA,GURGAON vs. JCIT (OSD), NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri Mahavir Singh & Shri M. Balaganesh

purchase of shares in the said company or in any other entity. He further stated that Mr. Sushil Mutreja informed him that shares worth Rs. 30,000 were allotted in his name, but the payment would be made by someone else. ITA Nos. 5098 to 5104/Del/2025 Sameer Mutreja ITA Nos. 4951 to 4957/Del/2025 Sachin Mutreja ii. The said statement, even

SACHIN MUTREJA,GURGOAN vs. JOINT COMMISSIONER OF INCOME TAX, NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri Mahavir Singh & Shri M. Balaganesh

purchase of shares in the said company or in any other entity. He further stated that Mr. Sushil Mutreja informed him that shares worth Rs. 30,000 were allotted in his name, but the payment would be made by someone else. ITA Nos. 5098 to 5104/Del/2025 Sameer Mutreja ITA Nos. 4951 to 4957/Del/2025 Sachin Mutreja ii. The said statement, even

SACHIN MUTREJA,HARYANA vs. JCIT (OSD), DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri Mahavir Singh & Shri M. Balaganesh

purchase of shares in the said company or in any other entity. He further stated that Mr. Sushil Mutreja informed him that shares worth Rs. 30,000 were allotted in his name, but the payment would be made by someone else. ITA Nos. 5098 to 5104/Del/2025 Sameer Mutreja ITA Nos. 4951 to 4957/Del/2025 Sachin Mutreja ii. The said statement, even

SAMEER MUTREJA,GURGAON vs. JCIT(OSD), NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri Mahavir Singh & Shri M. Balaganesh

purchase of shares in the said company or in any other entity. He further stated that Mr. Sushil Mutreja informed him that shares worth Rs. 30,000 were allotted in his name, but the payment would be made by someone else. ITA Nos. 5098 to 5104/Del/2025 Sameer Mutreja ITA Nos. 4951 to 4957/Del/2025 Sachin Mutreja ii. The said statement, even

SACHIN MUTREJA,GURGOAN vs. JOINT COMMISSIONER OF INCOME TAX (OSD), NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri Mahavir Singh & Shri M. Balaganesh

purchase of shares in the said company or in any other entity. He further stated that Mr. Sushil Mutreja informed him that shares worth Rs. 30,000 were allotted in his name, but the payment would be made by someone else. ITA Nos. 5098 to 5104/Del/2025 Sameer Mutreja ITA Nos. 4951 to 4957/Del/2025 Sachin Mutreja ii. The said statement, even

SACHIN MUTREJA,GURGOAN vs. JOINT COMMISSIONER OF INCOME TAX, NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri Mahavir Singh & Shri M. Balaganesh

purchase of shares in the said company or in any other entity. He further stated that Mr. Sushil Mutreja informed him that shares worth Rs. 30,000 were allotted in his name, but the payment would be made by someone else. ITA Nos. 5098 to 5104/Del/2025 Sameer Mutreja ITA Nos. 4951 to 4957/Del/2025 Sachin Mutreja ii. The said statement, even

SACHIN MUTREJA,GURGOAN vs. JOINT COMMISSIONER OF INCOME TAX (OSD), NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri Mahavir Singh & Shri M. Balaganesh

purchase of shares in the said company or in any other entity. He further stated that Mr. Sushil Mutreja informed him that shares worth Rs. 30,000 were allotted in his name, but the payment would be made by someone else. ITA Nos. 5098 to 5104/Del/2025 Sameer Mutreja ITA Nos. 4951 to 4957/Del/2025 Sachin Mutreja ii. The said statement, even

SAMEER MUTREJA,GURGAON vs. JCIT (OSD), NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri Mahavir Singh & Shri M. Balaganesh

purchase of shares in the said company or in any other entity. He further stated that Mr. Sushil Mutreja informed him that shares worth Rs. 30,000 were allotted in his name, but the payment would be made by someone else. ITA Nos. 5098 to 5104/Del/2025 Sameer Mutreja ITA Nos. 4951 to 4957/Del/2025 Sachin Mutreja ii. The said statement, even

SAMEER MUTREJA,GURGAON vs. JCIT(OSD), NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri Mahavir Singh & Shri M. Balaganesh

purchase of shares in the said company or in any other entity. He further stated that Mr. Sushil Mutreja informed him that shares worth Rs. 30,000 were allotted in his name, but the payment would be made by someone else. ITA Nos. 5098 to 5104/Del/2025 Sameer Mutreja ITA Nos. 4951 to 4957/Del/2025 Sachin Mutreja ii. The said statement, even

SAMEER MUTREJA,GURGAON vs. JCIT(OSD), NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri Mahavir Singh & Shri M. Balaganesh

purchase of shares in the said company or in any other entity. He further stated that Mr. Sushil Mutreja informed him that shares worth Rs. 30,000 were allotted in his name, but the payment would be made by someone else. ITA Nos. 5098 to 5104/Del/2025 Sameer Mutreja ITA Nos. 4951 to 4957/Del/2025 Sachin Mutreja ii. The said statement, even

SACHIN MUTREJA,HARYANA vs. JCIT(OSD), DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri Mahavir Singh & Shri M. Balaganesh

purchase of shares in the said company or in any other entity. He further stated that Mr. Sushil Mutreja informed him that shares worth Rs. 30,000 were allotted in his name, but the payment would be made by someone else. ITA Nos. 5098 to 5104/Del/2025 Sameer Mutreja ITA Nos. 4951 to 4957/Del/2025 Sachin Mutreja ii. The said statement, even

SAMEER MUTREJA,GURGAON vs. JCIT(OSD), NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri Mahavir Singh & Shri M. Balaganesh

purchase of shares in the said company or in any other entity. He further stated that Mr. Sushil Mutreja informed him that shares worth Rs. 30,000 were allotted in his name, but the payment would be made by someone else. ITA Nos. 5098 to 5104/Del/2025 Sameer Mutreja ITA Nos. 4951 to 4957/Del/2025 Sachin Mutreja ii. The said statement, even

SACHIN MUTREJA,GURGOAN vs. JOINT COMMISSIONER OF INCOME TAX (OSD), DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri Mahavir Singh & Shri M. Balaganesh

purchase of shares in the said company or in any other entity. He further stated that Mr. Sushil Mutreja informed him that shares worth Rs. 30,000 were allotted in his name, but the payment would be made by someone else. ITA Nos. 5098 to 5104/Del/2025 Sameer Mutreja ITA Nos. 4951 to 4957/Del/2025 Sachin Mutreja ii. The said statement, even

SAMEER MUTREJA,GURGAON vs. JCIT(OSD), NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri Mahavir Singh & Shri M. Balaganesh

purchase of shares in the said company or in any other entity. He further stated that Mr. Sushil Mutreja informed him that shares worth Rs. 30,000 were allotted in his name, but the payment would be made by someone else. ITA Nos. 5098 to 5104/Del/2025 Sameer Mutreja ITA Nos. 4951 to 4957/Del/2025 Sachin Mutreja ii. The said statement, even

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

bogus expenditure collapses. IV. Section 65B Compliance – Electronic Evidence • No chain-of-custody documentation has been placed to establish reliability of alleged seized digital extracts relied upon by the Assessing Officer. V. Comparative Position – Sunil Aggarwal vs Present Case Issue Sunil Aggarwal (Delhi HC) Present Case Statement u/s 132(4) Recorded and later retracted Recorded and retracted before AO Timing