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Documents citing Assistant Commissioner Of Income Tax vs Sanjay Chhabra Son Of Late Shri Moti Lal ... on 27 January, 2022

Dcit, Central Circle-2(1), Chennai vs Shri Rajagopal Kamaraj, Thiruvarur on 10 April, 2024

432) wherein it was held that when a diary is seized in search of the premises of a third patty allegedly containing entries of hundi transactions on behalf of various parties including the assessee, no addition could be made based on the said entries since the diary was neither found from the premises of assessee nor was it in handwriting of assessee and revenue failed to produce any other cogent material to link the assessee to the diary. The ratio of the said decision was held to be squarely applicable to the case of the assessee since Ld. AO had not referred to any cogent material to corroborate the entries made in the material seized from a third-party which are purportedly the transactions made by the said third-party with the assessee. Similar analogous ration as laid down in various other decisions which have been enumerated in preceding paras 7.11 of this order. We concur with the same.
Income Tax Appellate Tribunal - Chennai Cites 27 - Cited by 0 - Full Document

Dcit, Central Circle-2(1), Chennai vs Shri Rajagopal Kamaraj, Thiruvarur on 10 April, 2024

432) wherein it was held that when a diary is seized in search of the premises of a third patty allegedly containing entries of hundi transactions on behalf of various parties including the assessee, no addition could be made based on the said entries since the diary was neither found from the premises of assessee nor was it in handwriting of assessee and revenue failed to produce any other cogent material to link the assessee to the diary. The ratio of the said decision was held to be squarely applicable to the case of the assessee since Ld. AO had not referred to any cogent material to corroborate the entries made in the material seized from a third-party which are purportedly the transactions made by the said third-party with the assessee. Similar analogous ration as laid down in various other decisions which have been enumerated in preceding paras 7.11 of this order. We concur with the same.
Income Tax Appellate Tribunal - Chennai Cites 27 - Cited by 0 - Full Document

Dcit, Central Circle-2(1), Chennai vs Shri Rajagopal Kamaraj, Thiruvarur on 10 April, 2024

432) wherein it was held that when a diary is seized in search of the premises of a third patty allegedly containing entries of hundi transactions on behalf of various parties including the assessee, no addition could be made based on the said entries since the diary was neither found from the premises of assessee nor was it in handwriting of assessee and revenue failed to produce any other cogent material to link the assessee to the diary. The ratio of the said decision was held to be squarely applicable to the case of the assessee since Ld. AO had not referred to any cogent material to corroborate the entries made in the material seized from a third-party which are purportedly the transactions made by the said third-party with the assessee. Similar analogous ration as laid down in various other decisions which have been enumerated in preceding paras 7.11 of this order. We concur with the same.
Income Tax Appellate Tribunal - Chennai Cites 27 - Cited by 0 - Full Document

Shri Rajagopal Kamaraj, Thiruvarur vs Dcit, Central Circle-2(1), Chennai on 10 April, 2024

432) wherein it was held that when a diary is seized in search of the premises of a third patty allegedly containing entries of hundi transactions on behalf of various parties including the assessee, no addition could be made based on the said entries since the diary was neither found from the premises of assessee nor was it in handwriting of assessee and revenue failed to produce any other cogent material to link the assessee to the diary. The ratio of the said decision was held to be squarely applicable to the case of the assessee since Ld. AO had not referred to any cogent material to corroborate the entries made in the material seized from a third-party which are purportedly the transactions made by the said third-party with the assessee. Similar analogous ration as laid down in various other decisions which have been enumerated in preceding paras 7.11 of this order. We concur with the same.
Income Tax Appellate Tribunal - Chennai Cites 27 - Cited by 0 - Full Document

Shri Rajagopal Kamaraj, Thiruvarur vs Dcit, Central Circle-2(1), Chennai on 10 April, 2024

432) wherein it was held that when a diary is seized in search of the premises of a third patty allegedly containing entries of hundi transactions on behalf of various parties including the assessee, no addition could be made based on the said entries since the diary was neither found from the premises of assessee nor was it in handwriting of assessee and revenue failed to produce any other cogent material to link the assessee to the diary. The ratio of the said decision was held to be squarely applicable to the case of the assessee since Ld. AO had not referred to any cogent material to corroborate the entries made in the material seized from a third-party which are purportedly the transactions made by the said third-party with the assessee. Similar analogous ration as laid down in various other decisions which have been enumerated in preceding paras 7.11 of this order. We concur with the same.
Income Tax Appellate Tribunal - Chennai Cites 27 - Cited by 0 - Full Document

Shri Rajagopal Kamaraj, Thiruvarur vs Dcit, Central Circle-2(1), Chennai on 10 April, 2024

432) wherein it was held that when a diary is seized in search of the premises of a third patty allegedly containing entries of hundi transactions on behalf of various parties including the assessee, no addition could be made based on the said entries since the diary was neither found from the premises of assessee nor was it in handwriting of assessee and revenue failed to produce any other cogent material to link the assessee to the diary. The ratio of the said decision was held to be squarely applicable to the case of the assessee since Ld. AO had not referred to any cogent material to corroborate the entries made in the material seized from a third-party which are purportedly the transactions made by the said third-party with the assessee. Similar analogous ration as laid down in various other decisions which have been enumerated in preceding paras 7.11 of this order. We concur with the same.
Income Tax Appellate Tribunal - Chennai Cites 27 - Cited by 0 - Full Document

Shri O. Panneerselvam, Chennai vs Dcit Central Circle2(4), Chennai on 5 April, 2024

15. Proceeding further, it could also be seen that the impugned additions have been made in the hands of the assessee merely on the basis of vague entries found in the material seized from a third-party premise. The said material was seized from the premises of a third-party during the course of search conducted in the case of the said third-party. The said material was neither seized from the premises of the assessee nor was the same found to be in the handwriting of the assessee. Therefore, such material, unless backed by corroborative evidence, would not constitute adequate evidence to draw any adverse inference against the assessee as held by Hon'ble Delhi High Court in the case of CIT vs. Sant Lal [2020] 118 Taxmann.com 432 (Del). The Hon'ble Court, in similar situation, held no addition could be made merely on the basis of such entries. The ratio of the said decision was squarely applicable to the case of the assessee as the Ld. AO has not referred to any cogent material to corroborate the entries made in the material seized from a third-party which are purportedly the transactions made by the said third-party with the assessee.
Income Tax Appellate Tribunal - Chennai Cites 26 - Cited by 0 - Full Document

Shri O. Panneerselvam, Chennai vs Dcit Central Circle2(4), Chennai on 5 April, 2024

15. Proceeding further, it could also be seen that the impugned additions have been made in the hands of the assessee merely on the basis of vague entries found in the material seized from a third-party premise. The said material was seized from the premises of a third-party during the course of search conducted in the case of the said third-party. The said material was neither seized from the premises of the assessee nor was the same found to be in the handwriting of the assessee. Therefore, such material, unless backed by corroborative evidence, would not constitute adequate evidence to draw any adverse inference against the assessee as held by Hon'ble Delhi High Court in the case of CIT vs. Sant Lal [2020] 118 Taxmann.com 432 (Del). The Hon'ble Court, in similar situation, held no addition could be made merely on the basis of such entries. The ratio of the said decision was squarely applicable to the case of the assessee as the Ld. AO has not referred to any cogent material to corroborate the entries made in the material seized from a third-party which are purportedly the transactions made by the said third-party with the assessee.
Income Tax Appellate Tribunal - Chennai Cites 26 - Cited by 0 - Full Document

Dcit Central Circle2(4), Chennai vs Shri O. Panneerselvam, Chennai on 5 April, 2024

15. Proceeding further, it could also be seen that the impugned additions have been made in the hands of the assessee merely on the basis of vague entries found in the material seized from a third-party premise. The said material was seized from the premises of a third-party during the course of search conducted in the case of the said third-party. The said material was neither seized from the premises of the assessee nor was the same found to be in the handwriting of the assessee. Therefore, such material, unless backed by corroborative evidence, would not constitute adequate evidence to draw any adverse inference against the assessee as held by Hon'ble Delhi High Court in the case of CIT vs. Sant Lal [2020] 118 Taxmann.com 432 (Del). The Hon'ble Court, in similar situation, held no addition could be made merely on the basis of such entries. The ratio of the said decision was squarely applicable to the case of the assessee as the Ld. AO has not referred to any cogent material to corroborate the entries made in the material seized from a third-party which are purportedly the transactions made by the said third-party with the assessee.
Income Tax Appellate Tribunal - Chennai Cites 26 - Cited by 0 - Full Document
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