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Ashish P Patel,Ahmedabad vs The Acit, Central Circle-1(3), ... on 1 August, 2025

13. Lastly comes the crucial issue as to whether the impugned seized material / 'Excel' sheet (not mentioning the assessees' names) forms a dumb document or not. We make it clear that the department has failed to corroborate the impugned seized document indicating assessee's alleged on money payment over and above the sale price itself. All it has done is to rely on their father's name only. It is nowhere clear as to whether it is an alleged document forming part of the books of account maintained in the regular course of business either by the vendor or vendee side. All it contains therefore is rough notings and jottings only. This tribunal co-ordinate bench's decision Nishan Constructions Vs. ACIT ITA No.1502/Ahd/2015; after considering the hon'ble apex court's landmark decision ITSSA No. 429, 460, 431, 472, 462 of 2019 & CO No. 5, 7, 193 of 2020 Shri Ashish P. Patel 74 in Common Cause, Vs. Union of India (2017) 77 taxmann.com 245 (SC) and CBI Vs. V.C. Shukla (1998) 3 SCC 410 (SC) holds that such loose sheets deserves to be treated as a dumb documents only since not revealing full details about the dates containing lack of further particular s and therefore, ought not to be made basis of an addition.
Income Tax Appellate Tribunal - Ahmedabad Cites 61 - Cited by 0 - Full Document

The Acit, Central Circle-1(3), ... vs Ashish P Patel, Ahmedabad on 1 August, 2025

13. Lastly comes the crucial issue as to whether the impugned seized material / 'Excel' sheet (not mentioning the assessees' names) forms a dumb document or not. We make it clear that the department has failed to corroborate the impugned seized document indicating assessee's alleged on money payment over and above the sale price itself. All it has done is to rely on their father's name only. It is nowhere clear as to whether it is an alleged document forming part of the books of account maintained in the regular course of business either by the vendor or vendee side. All it contains therefore is rough notings and jottings only. This tribunal co-ordinate bench's decision Nishan Constructions Vs. ACIT ITA No.1502/Ahd/2015; after considering the hon'ble apex court's landmark decision ITSSA No. 429, 460, 431, 472, 462 of 2019 & CO No. 5, 7, 193 of 2020 Shri Ashish P. Patel 74 in Common Cause, Vs. Union of India (2017) 77 taxmann.com 245 (SC) and CBI Vs. V.C. Shukla (1998) 3 SCC 410 (SC) holds that such loose sheets deserves to be treated as a dumb documents only since not revealing full details about the dates containing lack of further particular s and therefore, ought not to be made basis of an addition.
Income Tax Appellate Tribunal - Ahmedabad Cites 61 - Cited by 0 - Full Document

The Acit, Central Circle-1(3), ... vs Ashish P Patel, Ahmedabad on 1 August, 2025

13. Lastly comes the crucial issue as to whether the impugned seized material / 'Excel' sheet (not mentioning the assessees' names) forms a dumb document or not. We make it clear that the department has failed to corroborate the impugned seized document indicating assessee's alleged on money payment over and above the sale price itself. All it has done is to rely on their father's name only. It is nowhere clear as to whether it is an alleged document forming part of the books of account maintained in the regular course of business either by the vendor or vendee side. All it contains therefore is rough notings and jottings only. This tribunal co-ordinate bench's decision Nishan Constructions Vs. ACIT ITA No.1502/Ahd/2015; after considering the hon'ble apex court's landmark decision ITSSA No. 429, 460, 431, 472, 462 of 2019 & CO No. 5, 7, 193 of 2020 Shri Ashish P. Patel 74 in Common Cause, Vs. Union of India (2017) 77 taxmann.com 245 (SC) and CBI Vs. V.C. Shukla (1998) 3 SCC 410 (SC) holds that such loose sheets deserves to be treated as a dumb documents only since not revealing full details about the dates containing lack of further particular s and therefore, ought not to be made basis of an addition.
Income Tax Appellate Tribunal - Ahmedabad Cites 61 - Cited by 0 - Full Document

The Acit, Central Circle-1(3), ... vs Ashish P Patel, Ahmedabad on 1 August, 2025

13. Lastly comes the crucial issue as to whether the impugned seized material / 'Excel' sheet (not mentioning the assessees' names) forms a dumb document or not. We make it clear that the department has failed to corroborate the impugned seized document indicating assessee's alleged on money payment over and above the sale price itself. All it has done is to rely on their father's name only. It is nowhere clear as to whether it is an alleged document forming part of the books of account maintained in the regular course of business either by the vendor or vendee side. All it contains therefore is rough notings and jottings only. This tribunal co-ordinate bench's decision Nishan Constructions Vs. ACIT ITA No.1502/Ahd/2015; after considering the hon'ble apex court's landmark decision ITSSA No. 429, 460, 431, 472, 462 of 2019 & CO No. 5, 7, 193 of 2020 Shri Ashish P. Patel 74 in Common Cause, Vs. Union of India (2017) 77 taxmann.com 245 (SC) and CBI Vs. V.C. Shukla (1998) 3 SCC 410 (SC) holds that such loose sheets deserves to be treated as a dumb documents only since not revealing full details about the dates containing lack of further particular s and therefore, ought not to be made basis of an addition.
Income Tax Appellate Tribunal - Ahmedabad Cites 61 - Cited by 0 - Full Document

Ashish P Patel,Ahmedabad vs The Acit, Central Circle-1(3), ... on 1 August, 2025

13. Lastly comes the crucial issue as to whether the impugned seized material / 'Excel' sheet (not mentioning the assessees' names) forms a dumb document or not. We make it clear that the department has failed to corroborate the impugned seized document indicating assessee's alleged on money payment over and above the sale price itself. All it has done is to rely on their father's name only. It is nowhere clear as to whether it is an alleged document forming part of the books of account maintained in the regular course of business either by the vendor or vendee side. All it contains therefore is rough notings and jottings only. This tribunal co-ordinate bench's decision Nishan Constructions Vs. ACIT ITA No.1502/Ahd/2015; after considering the hon'ble apex court's landmark decision ITSSA No. 429, 460, 431, 472, 462 of 2019 & CO No. 5, 7, 193 of 2020 Shri Ashish P. Patel 74 in Common Cause, Vs. Union of India (2017) 77 taxmann.com 245 (SC) and CBI Vs. V.C. Shukla (1998) 3 SCC 410 (SC) holds that such loose sheets deserves to be treated as a dumb documents only since not revealing full details about the dates containing lack of further particular s and therefore, ought not to be made basis of an addition.
Income Tax Appellate Tribunal - Ahmedabad Cites 61 - Cited by 0 - Full Document

Shri Ashish Prafulbhai ... vs The Dcit. Central Circle-1(3),, ... on 1 August, 2025

13. Lastly comes the crucial issue as to whether the impugned seized material / 'Excel' sheet (not mentioning the assessees' names) forms a dumb document or not. We make it clear that the department has failed to corroborate the impugned seized document indicating assessee's alleged on money payment over and above the sale price itself. All it has done is to rely on their father's name only. It is nowhere clear as to whether it is an alleged document forming part of the books of account maintained in the regular course of business either by the vendor or vendee side. All it contains therefore is rough notings and jottings only. This tribunal co-ordinate bench's decision Nishan Constructions Vs. ACIT ITA No.1502/Ahd/2015; after considering the hon'ble apex court's landmark decision ITSSA No. 429, 460, 431, 472, 462 of 2019 & CO No. 5, 7, 193 of 2020 Shri Ashish P. Patel 74 in Common Cause, Vs. Union of India (2017) 77 taxmann.com 245 (SC) and CBI Vs. V.C. Shukla (1998) 3 SCC 410 (SC) holds that such loose sheets deserves to be treated as a dumb documents only since not revealing full details about the dates containing lack of further particular s and therefore, ought not to be made basis of an addition.
Income Tax Appellate Tribunal - Ahmedabad Cites 61 - Cited by 0 - Full Document

Shri Ashish Prafulbhai ... vs The Dcit. Central Circle-1(3),, ... on 1 August, 2025

13. Lastly comes the crucial issue as to whether the impugned seized material / 'Excel' sheet (not mentioning the assessees' names) forms a dumb document or not. We make it clear that the department has failed to corroborate the impugned seized document indicating assessee's alleged on money payment over and above the sale price itself. All it has done is to rely on their father's name only. It is nowhere clear as to whether it is an alleged document forming part of the books of account maintained in the regular course of business either by the vendor or vendee side. All it contains therefore is rough notings and jottings only. This tribunal co-ordinate bench's decision Nishan Constructions Vs. ACIT ITA No.1502/Ahd/2015; after considering the hon'ble apex court's landmark decision ITSSA No. 429, 460, 431, 472, 462 of 2019 & CO No. 5, 7, 193 of 2020 Shri Ashish P. Patel 74 in Common Cause, Vs. Union of India (2017) 77 taxmann.com 245 (SC) and CBI Vs. V.C. Shukla (1998) 3 SCC 410 (SC) holds that such loose sheets deserves to be treated as a dumb documents only since not revealing full details about the dates containing lack of further particular s and therefore, ought not to be made basis of an addition.
Income Tax Appellate Tribunal - Ahmedabad Cites 61 - Cited by 0 - Full Document

Ashish P Patel,Ahmedabad vs The Acit, Central Circle-1(3), ... on 1 August, 2025

13. Lastly comes the crucial issue as to whether the impugned seized material / 'Excel' sheet (not mentioning the assessees' names) forms a dumb document or not. We make it clear that the department has failed to corroborate the impugned seized document indicating assessee's alleged on money payment over and above the sale price itself. All it has done is to rely on their father's name only. It is nowhere clear as to whether it is an alleged document forming part of the books of account maintained in the regular course of business either by the vendor or vendee side. All it contains therefore is rough notings and jottings only. This tribunal co-ordinate bench's decision Nishan Constructions Vs. ACIT ITA No.1502/Ahd/2015; after considering the hon'ble apex court's landmark decision ITSSA No. 429, 460, 431, 472, 462 of 2019 & CO No. 5, 7, 193 of 2020 Shri Ashish P. Patel 74 in Common Cause, Vs. Union of India (2017) 77 taxmann.com 245 (SC) and CBI Vs. V.C. Shukla (1998) 3 SCC 410 (SC) holds that such loose sheets deserves to be treated as a dumb documents only since not revealing full details about the dates containing lack of further particular s and therefore, ought not to be made basis of an addition.
Income Tax Appellate Tribunal - Ahmedabad Cites 61 - Cited by 0 - Full Document
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