The Revenue challenged the Tribunal's order but failed to produce original seized documents despite multiple opportunities. The Court dismissed the appeal due to non-production of evidence and held that the lower authorities' finding of fact was not perverse.
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PRINCIPAL COMMISSIONER OF INCOME TAX-4 DELHI .....Appellant Through: Mr Abhishek Maratha, SSC with Mr.Apoorv Aggarwal, Mr Viplav Acharya, JSCs, Ms Nupur Sharma, Mr. Siddhartha Kumar & Mr.Himanshu Gaur, Advs. versus
KRBL FOODS LTD .....Respondent Through: Mr. Sachit Jolly, Sr. Adv. with Mrs.Mansha Anand, Mr. Abhyudaya Shankar Bajpai, Mr. Sohum Dua, Ms.Saloni Ray, Mr. Ghunaim Siddiqui & Ms. Manvi, Advs.
CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE RAJNEESH KUMAR GUPTA O R D E R % 23.07.2026
This is a digitally signed order.
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28.01.2019 passed by the Commissioner of Income Tax (Appeals) was upheld.
“1. Mr. Abhishek Maratha, learned Senior Standing Counsel for the appellant-Income Tax Department informs the Court that the relevant record as directed, has been brought and is ready for perusal of the Court. 2. We had called not the entire record on 09.04.2026. It may be noticed that we have ordered thus:
“1. Mr. Abhishek Maratha, learned Senior Standing Counsel appearing for the appellant in presence of the Assessing Officer (AO) prays for last opportunity of four weeks to trace the record and produce the original seized document mentioned at page no. 52 of paper book.
2. Request acceded to.
3. Since a number of opportunities have been granted, we make it clear that in case the Department fails to produce the original document and record, we shall be constrained to dismiss the appeal for want of
This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 25/07/2026 at 11:45:31
prosecution”
3. Accordingly, we only proposed to examine the original document, scanned copy whereof has been pasted on page No. 52 of the paper-book.
4. List this case on 25.05.2026.
5. The appellant shall flag the above referred original documents from the seized record and show to the court”
“Sir/Madam,
Kindly refer to the trail mail.
Kindly refer to the ongoing proceedings in the case of KRBL Foods Ltd. pending before the Hon'ble Delhi High Court and the communications exchanged regarding tracing and production of the alleged incriminating image/data recovered during the course of search proceedings in the case of ISRPL Group. In continuation of the earlier communication from this office, it is submitted that the matter was immediately taken up with Circle-10(1), Delhi, where the present jurisdiction over the PAN of Ms. Chanchal Taneja and M/s Index Securities & Research Pvt. Ltd. lies.
In response thereto, the ACIT, Circle-10(1), Delhi vide mail dated has informed that:
"one sealed hard disk along with one working copy and certain records pertaining to the said search proceedings has now been traced from the old records. However, during the process of examination/extraction of the working copy of hard disc, it has been observed that the said hard disk is approximately 10 years old and certain files/data contained therein appear to have become corrupted and are presently not readily accessible/retrievable.
This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 25/07/2026 at 11:45:31
The ACIT, Circle-10(1), Delhi has further informed that efforts are presently being undertaken on priority basis through all possible technical means to retrieve and recover the available data from the said hard disk in view of the urgency involved and the directions of the Hon'ble High Court"
Accordingly, it is requested that the aforesaid factual position may kindly be brought to the notice of the Hon'ble Court.
This is for your kind information and further necessary action.”
DINESH MEHTA, J.
RAJNEESH KUMAR GUPTA, J.
JULY 23, 2026 kk
This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 25/07/2026 at 11:45:31
1 issue framed by the court
Whether the Revenue could substantiate its claim regarding seized documents to challenge the Tribunal's order?
1 provisions across 1 enactments
PRINCIPAL COMMISSIONER OF INCOME TAX-4 DELHI
KRBL FOODS LTD
DINESH MEHTA
RAJNEESH KUMAR GUPTA
As recorded by the court registry
Judgements on the same questions, provisions and authorities, from every court
