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The Dcit, Central Circle-1 Rajkot, ... vs Prafulbhai Narendrabhai Gangdev, ... on 13 March, 2026 cites

A.R.R. Trust vs Acit on 3 June, 2005

17. in the light of the above facts, the persons from whose possession the incriminating material was found, i.e. the pendrive, are admittedly closely linked with the assessee, in relation especially to maintenance of accounts. They are surely not alien to the transactions. And cannot be said to be outsiders/third parties. In fact considering the fact that they were admittedly maintaining data of the group, the possession of pendrive, also containing data of the group, with them in fact is to be attributed to the group, of which the assessee is a part. The possession of the pendrive, though physically found from other persons, the constructive possession is to be treated as that of the assessee. The Hon'ble Madras High Court in the case of S.R. Trust Vs. ACIT, in its order in Writ Petition No.22213 of 2018, dated 12.3.2021, dealt with an identical plea of the assessee, and rejected the same applying the principle of constructive possession. The Hon'ble High court made a very pertinent observation in this respect stating that if such an approach, as canvassed by the assessee is adopted, then it would be very easy for any assessee to evade the provisions of the Act by utilizing services of the third-
Income Tax Appellate Tribunal - Chennai Cites 12 - Cited by 10 - Full Document
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