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2011 (7) TMI 1180
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....yrs. 2002-03 to 2008-09 vide his orders dt. 31st Dec., 2009. 2. The first common issue in Revenue's appeal in IT(SS)A Nos. 19 to 21/Kol/2011 is as regards to orders of CIT(A) deleting additions made on account of alleged on-money receipts for on-going projects amounting to Rs. 2,58,64,762, Rs. 1,73,16,880 and Rs. 64,83,07,492 for the asst. yrs. 2006-07, 2007-08 and 2008-09 respectively, relying on project completion method of accounting followed by assessee company. For this, Revenue has raised common and identically worded grounds, except amount. Following three grounds raised in asst. yr. 2008-09 are being reproduced, as it is and will take facts and figures from this year only and will be decided far all three years on that basis. "1. That, on the facts and circumstances of the case, learned CIT(A) has erred in both law and facts in deleting the addition of Rs. 64,83,07,492 on account of undisclosed income arising out of receipt of on-money from various projects. 2. That, in doing so, learned CIT(A) erred in putting emphasis on the project completion method of accounting ignoring the fact that books of account of the assessee company were rejected. ....
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....office premises of assessee and in course of which the following books/documents were impounded: Premises Books/documents found and impounded Office premises of M/s Fort Projects (P) Ltd. at 7/1A Hazra Road, Kolkata-26 PC/1 to PC/3 Office premises of M/s Fort Projects (P) Ltd. and M/s Fort Builders at 38/1 Panditya Road, Kolkata-29 FP/1 to FP/11,FP/CD-1.FP/CPU/1 Office premises of M/s Fort Projects (P) Ltd. at 59C Chowringhee Road, Kolkata and 297/1A Hazra Road, Kolkata-26 GB/1 to GB/17, GB/CPU/1 During search at the residential premises of Sri Vivek Kumar Kathotia, director of company, documents, computer printouts etc. marked RM/1 to RM/4 were found and seized and papers marked RM 5 containing details of on-money receipts of assessee company in respect of flats in three projects namely (i) 20 Lee Road, Kolkata (ii) 22 Lee Road, Kolkata and (iii) 68 Hindustan Park, Kolkata were also found and seized. On the basis of seized document RM-5 a disclosure of Rs. 9.02 crores was made by assessee, whereas the allegation of assessee was that said seized documents were forcibly manufactured by Department at the time of search and seizure action in case of Sri Vive....
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....he seized document RM/5 are seen together, it is found that the assessee received the highest rate per square foot for the flat No. 4D Sri/Smt. A. Das- the total amount is Rs. 1,18,87,000 for 1,798 sq. ft. of flat. The rate works out to Rs. 6,611 per sq. ft. When the assessee admittedly received such rate from this flat, including on-money, in the project, there is no reason why the same rate was not received in respect of the other flats in the same project. The assessee has not disclosed any on-money in respect of most of the flats. The rates accounted for are different in most of the cases. There is no reason for variation of square foot rate in the same project. As per the details in pp. 56 and 57, the total amount of flat Nos. 2A, 2B, 3A, 3B, 3C, 3D, 4C, 4D, 5A, 5B, 5C and 5D, which were allocated to the buyers as well as from which on-money receipts are evidenced by RM/5 is Rs. 284.18 lakhs. The total amount @ 6,611 per sq. ft. works out to Rs. 14,41,99,132. The assessee has accounted for Rs. 6,20,16,500 on account of those flats. Besides, the assessee has disclosed on-money receipt totalling Rs. 2,87,18,000 from some flats as per RM/5. The balance amount, therefore,....
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....as undisclosed on on-money receipts in asst. yr. 2008-09. 24, Lee Road Project: When both the relevant documents, viz. impounded document GB/17 (pp. 51 and 52) and the pp. 7, 9 and 10 of the seized document RMJ/are seen together, it is found that the assessee received the highest rate per square foot for the flat No. 6B the total amount is Rs. 2,18,32,000 for total 2,729.ft. of flat. The rate works out to Rs. 8,000 per sq. ft. When the assessee admittedly received such rate from the flat, including on-money, in the project, there is no reason why the same rate was not received in respect of the other flats in the same project. The assessee has not disclosed any on-money in respect of most of the flats. The rates accounted for are different in most of the cases. There is no reason for variation of square foot rate in the same project. As per the details in pp. 51 and 52, the total area of flats is 86,987 sq. ft. The total 'area allocated to landlord is 19,684 sq. ft. Therefore, the assessee's share is 67,303 sq. ft. The total amount @ 8,000 per sq. ft. works out to Rs. 53,84,24,000. The assessee has accounted for Rs,4,39,84,900 as evident from p. 52 of GB/1....
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....at the time of search and entire alleged on-money receipt of Rs. 9.02 crores mentioned in RM/5 in respect of few flats in these three projects was however offered in entirety by assessee as its income for asst. yr. 2008-09 solely to buy peace and avoid unnecessary dispute. According to assessee, no other evidence, whether documentary or circumstantial, pertaining to receipt of on-money for other flats in these three projects or other projects were found in course of search or survey operation and AO was thus completely unjustified in extrapolating on-money to the balance flats in these three projects merely on the basis of disputed seized loose papers and making an exorbitant addition of Rs. 64.83 crores on the basis of surmises and conjectures. However, assessee contended that CIT(A) was correct to the extent of holding that assessee was regularly following project completion method of accounting and these three projects were incomplete till asst. yr. 2008-09, no receipt, whether in cheque or cash was taxable for asst. yr. 2008-09. 5. We have heard rival contentions and gone through facts and circumstances of the case. First of all we have gone through the seized document RM/1,....
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....'s plea that seized papers were forcibly manufactured by search party at the time of search on the pretext that the said issue had been raised after 22 months from the date of search and furthermore there was no evidence that Sri Vivek Kathotia was forced to write said papers by search party. The AO observed that assessee had suo motu offered sums mentioned in RM/5 as its income for asst. yr. 2008-09 and even CIT(A) also rejected assessee's stand on similar grounds. We find that said seized papers were not manufactured by search party at the time of the search but were found from the possession and control of assessee in the course of search. As such, the presumption under s. 292C regarding the correctness of the contents of seized documents applies to RM/5 also. Further, it is assumed that the presumption regarding the correctness of contents of seized documents under s. 292C is applicable to KM/5, the said presumption is rebuttable and assessee unsuccessfully tried to rebut the presumption under s. 292C by pointing out defects/mistakes in RM/5, but unable to do the same by any cogent evidence. Accordingly, we have to accept the seized document RM/5 as correct and true. ....
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....having accepted the project completion method of accounting consistently followed by assessee, there was no justification for estimating assessee's profits for these years by estimating undisclosed income earned from projects. We find that the AO had not disputed that on-money receipts were trading receipts received as advance from the prospective buyers of flats and only net profit could be brought to tax and not gross receipts. The CIT(A) has rightly held that only the profit embedded in trading receipt could be taxed which could be determined only on completion of projects/The conduct of search and seizure operation in a particular year did not lead to an inference that undisclosed income detected as a consequence thereof had to be taxed in the assessment year relevant to previous year in which the search was conducted but accounting profits have yet to be made on the basis of method of accounting followed by assessee. Therefore, we agree with the findings of CIT(A) that assessee was following project completion method of accounting, therefore all the amounts whether allegedly received in cash or by cheque were taxable in the years in which the projects were completed. In re....
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....reciated by the AO in its proper context. Thirdly, it may also be mentioned that although under Chapter XIV-B, the AO is entitled to take into account the estimate, particularly when documentary evidence was not forthcoming, an arbitrary method cannot be applied. There is no material to indicate that the GP rate of 15 per cent was the basis for the entire period 1984-1995. In the circumstances, an excessive rate of gross profit was applied to arrive at the conclusion that the closing stock was suppressed. Lastly, as pointed out by the Tribunal, in the matter of the second addition, the AO has worked out the said addition on the basis of excess of stock which finding is contrary to the finding of the AO while computing the closing stock. Under the above circumstances, the Tribunal was right in allowing the appeal. 7. Further, Hon'ble Rajasthan High Court in the case of CIT vs. Rajendra Prasad Gupta (2001) 166 CTR (Raj) 83: (2001) 248 ITR 350 (Raj) wherein Hon'ble High Court observed that under the scheme of provisions for block assessment it is apparent that it related to assessment of "undisclosed income" of assessee excluding incomes subjected to regular assessment in p....
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....cords the turnover of the assessee as found by the Tribunal and yet on the wrong basis of the incoming and outgoing cash transactions, the AO has arrived at the turnover. Moreover, the peak investment was Rs. 40,14,806 for three months. However, there is no material seized to justify any figure to be included for a period earlier to the said period of three months. In the circumstances, the Tribunal has recorded a finding of fact and has held that the addition of Rs. 3.40 crores was totally unjustified. The entire finding of the Tribunal is based on the facts. No substantial question of law arises. Hence, the appeal is dismissed." 9. We find that even Hon'ble apex Court in Dhakeswari Cotton Mills Ltd. vs. CIT (1954) 26 ITR 775 (SC) laid down principle regarding estimation that while making assessment under s. 23(3) of the IT Act 1922, the ITO is not fettered by technical rules of evidence and pleadings, and he is entitled to act on material which may not be accepted as evidence in a Court of law, but he is not entitled to make a pure guess and make an assessment without reference to any evidence or any material at all. There must be something more than bare suspicion to supp....
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....and circumstanced. Not only did the Tribunal not show the information given by the elsewhere, and whether these mills were similarly situated and refused even to look at the trunk load of books and papers which Mr. Banerjee produced before the AM in his Chamber. No harm would have been done if after notice to the Department the trunk had been opened and some time devoted to see what it contained. The assessment in this case and in the connected appeal, we are told, was above the figure of Rs. 55 lakhs and it was meet and proper when dealing with a matter of this magnitude not to employ unnecessary haste and show impatience, particularly when it was known to the Department that the books of the assessee were in the custody of the Sub-Divisional Officer, Narayanganj. We think that both the ITO and the Tribunal in estimating the GP rate on sales did not act on any material but acted on pure guess and suspicion. It is thus a fit case for the exercise of our power under Art. 136." 10. In the present case before us, we find that assessee was following project completion method of accounting and these projects were incomplete during the year under consideration. Even if it is assumed t....
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.... cash as well as amounts received by cheques were taxable in the year in which project was completed or substantially completed." We find that Kolkata Tribunal in the case of South Calcutta Promoters (P) Ltd. vs. ITO in ITA Nos. 2216 and 2217/Kol/2003, concerned assessee was engaged in the business of civil construction and development. The assessee booked income as and when flats were sold. Pursuant to search and seizure operation in the said assessee's case, it was found to have received amount in cash in the nature of advance over and above the advances reflected in books of account. The AO taxed the same as' income in the year of receipt ignoring the method of accounting followed by the assessee. Tribunal observed as under: The amount received by cheque by the assessee was shown in the liability side of the audited balance sheet filed by the assessee. The AO himself has observed in the assessment order for the relevant asst. yr. 1992-93 that the amount of Rs. 37,79,234 as per the audited balance sheet was shown as "advance from parties' and no adverse action on this amount has been taken by the AO. We find that although the assessee has not accounted for....
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.... CIT(A) has rightly held that only profit element of on-money receipts, if any, will be assessed in the year when project is completed, we confirm the same. As regards to rejection of books of accounts challenged by assessee, we are of the view that in view of seized documents RM/1 to RM/5, the books of account are to be rejected, but the books of account reframed after incorporating the entries of these seized documents, the assessment is to be framed on this and CIT(A) has rightly held so. Even otherwise we have accepted the seized documents RM/1 to RM/5 as correct in the case of Vivek Kumar Kathotia in IT(SS)A Nos. 4 to 7/Kol/2011 of assessee's appeals, wherein vide para 15 to 17, we have held under: "15. We find that the term 'used' in the provision of s. 292C of the Act 'may be presumed' is discussed, but in the context of s. 132(4) of the Act, by Hon'ble apex Court in the case of P.R. Metrani (supra) and said term implies that the presumption is rebuttable. The term 'rebut' means to disprove. In other words, unless contrary is proved, what is stated in the seized documents has to be presumed to be true and thus, the provisions of s. 29....
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....tion would render the deeming provisions of s. 292C otiose and presumption as to the correctness of seized documents is automatic under s. 292C of the Act unless the contrary is proved and as such, the assessee was not legally required to substantiate the seized documents with supporting evidence. Where the statute provides a deeming provision, what is prescribed is to be deemed without seeking corroborative evidence. We find from a bare perusal of RM/1 and RM/2, which would reveal that seized documents have been maintained in considerable details such as exact caratage of diamonds, the weight of gold and the rates of purchase and sales, the dates of purchase and sales have been mentioned. Further, in respect of paintings, minute details such as the exact size of the paintings and the names of the artists have also been mentioned in the seized documents. Thus, these are speaking documents and not dumb documents. A dumb document is a document which doesn't speak for itself and not a self-explanatory and detailed document like present one. Further, going through these documents it is revealed that these documents also record several regular transactions of the assessee which stan....
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....rsonal information of the assessee and as such, could not have been untrue of fabricated. Therefore, it was highly illogical on the part of the Department to assume that the said papers had been purposely prepared by the assessee to defraud the Department. As regards CIT(A)'s contention that no stocks of gold, diamonds or paintings were found in the course of search at the residential premises we are of the view that most of the gold, diamonds and paintings were sold prior to search action and as such considerable stocks of aforesaid items were not remaining at the time of search. Even during the course of search the assessee in reply to question No. 8 of his statement recorded on oath under s. 132(4) on 14th March, 2008, pp. 101 to 102 of assessee's paper book referred by learned counsel, wherein he stated that the gold after purchase was kept at various locations and this explains the reason why the remaining 2 kgs. of gold was not found in course of search at the residential premises of the assessee. Even during the course of search, in regards paintings, assessee admitted vide question No. 15 on the date of search that the same were on display at his residence and the s....
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.... documents inventorised RM-1 to RM-4 are dumb documents and for this Revenue has no basis whatsoever. To give a finding that the documents are dumb and such a finding can be reviewed on the ground that there is no evidence to support it or it is perverse. Further, when a conclusion has been reached on an appreciation of a number of facts, whether that is sound or not must be determined, not by considering the weight to be attached to each single fact in isolation, but by assessing the cumulative effect of all the facts in their setting as a whole. When a Court of facts acts on material partly relevant and partly irrelevant, it is impossible to say to what extent the mind of the Court was affected by the irrelevant material used by it in arriving at its finding. Such a finding is vitiated because of use of inadmissible material and hence decision in such situation is based on conjectures, surmises and suspicion. Hence, we consider documents found from the possession of the assessee during the course of search were real and declaration made by assessee on the basis of entry recorded in these documents of long-term capital gain on account of sale of gold and diamonds and also receipts....
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....of the same (reproduced at p. 4 of the assessment order), it is seen that the total disclosed consideration in respect of such flats was Rs. 7,63,42,000 and not Rs. 6,20,16,500. Thus, the alleged additional on-money estimated by the AO at Rs. 5,34,64,632 (i.e. Rs. 14,41,99,132 minus Rs. 6,20,16,500 minus Rs. 2,87,18,000) will actually come to Rs. 3,91,39,132 (i.e. Rs. 14,41,99,132 minus Rs. 7,63,42,000 minus Rs. 2,87,18,000) if the calculation error committed by the AO is rectified. Thus, the aforesaid error on part of the AO has resulted in surplus addition of Rs. 1,43,25,500. 20 Lee Road 'While estimating the on-money receipts in respect of project at 20, Lee Road, on pp. 7 and 8 of the assessment order under s. 144/153C for asst. yr. 2008-09, the AO committed the following errors: The AO has taken the total area of fiats sold at 54,008 sq. ft. (78,290 sq. ft. minus 24,282 sq. ft. (allocated to landlords). However, the area of flats allocated to the landlords was only 19,246 sq. ft. Further, the AO failed to appreciate that the flat mentioned against Mr. Vivek Agarwal (5,036 sq. ft.) was not sold to him. Mr. Vivek Agarwal was just a tenant ....
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....r flat Nos. 3B, 4A, 4C, 4D, 5A). Further, the assessee has already made a disclosure of Rs. 3,56,66,000 for the impugned project on the basis of RM/5. Accordingly, the alleged additional on-money works out to Rs. 4,23,44,100 (i.e. Rs. 1,13,80,8,000 minus Rs. 3,57,97,900 minus Rs. 3,56,66,000) as against Rs. 45,87,73,100 erroneously computed by the AO." The assessee himself contended that these are mistakes apparent from record and it will reduce the addition made by AO on account of additional on-money in respect of these projects by Rs. 41,64,29,000. Since assessee itself contended that these are mistakes apparent from record and we have decided the issue on the basis that the receipts cannot be added, since project has not been completed arid assessee is following project completion method, therefore, only the calculation errors (supra) committed by AO in respect of all the aforesaid three projects can be rectified by AO. For these years this exercise will be academic only, because we have already upheld the order of CIT(A) deleting addition. 12. The next common issue in these appeals of Revenue in IT(SS)A Nos. 15 to 20/Kol/2011 is in regard to deletion of addition on accou....
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....ire life span of the project and factors affecting the rates of booking have already been submitted vide submissions dt. 28th Dec., 2009 before AO. The assessee explained various factors affecting rates of bookings and reasons why uniform rates could not be assumed in case of all flats in a particular project but ignored submissions of assessee and made addition aggregating to Rs. 5,63,32,175 for the asst. yr. 2002-03 to asst. yr. 2007-08 as on-money receipt on pure estimation basis in respect of following projects: Name of the projects A.Y. Amount of addition Total addition Fort Royal 2003-04, 2006-07 13,61,250 38,45,142 52,06,392 Ramani Projects 2002-03, 2004-05, 2005-06, 2006-07 11,70,600 30,23,412 13,19,248 9,38,000 64,51,260 Fort Point 2005-06 14,57,000 14,57,000 Tower- 1 2006-07 19,61,520 19,61,520 Tower-2 2006-07 1,52,63,360 1,52,63,360 Block- 1 2006-07 2007-08 22,06,000 76,97,354 99,03,354 Block-2 2006-07 7,08,240 7,08,240 Oasis Block-4 2006-07 2007-08 9,42,500 27,57,810 37,00,310 Oasis Block-5 2005-06 2007-08 8,13,780 97,00,069 1,05,13,849 Oasis Block-....
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....ich flats in the said project had been sold over a period of time. The CIT(A) observed that "in the case under consideration the first flat in the said project No. 3B having area of 1100 sq. ft has been booked on 24th Aug., 2001 @ 1,475 per sq. ft. whereas flat No. 6B in same project having same square foot area is booked @ Rs. 900 per sq. ft. on 20th March, 2003. Further the fiat No. 8A having area of 1,550 s. ft. has been booked on 19th Jan., 2005 @ Rs. 1,600 per sq. ft. whereas flat Nos. 9A and 9B having area of 1100 sq. ft. area each is booked @ Rs. 1,000 per sq. ft. on 26th April, 2005 and flat No. 9C/D having area of 2650 sq. ft. area is booked @ 919 per sq. ft. on 11th May, 2005." With these observations CIT(A) held that flat sold by assessee in the same project could be taken as comparable case. But assessee contended that there could be difference on account . of different variables like location, time of booking, mode of payment, market fluctuations, extra fittings etc, hence, he held that AO was not justified in charging highest rate as base rate for making estimation and rejected books of account and arbitrarily estimated profit of the project @ 6 per cent of the total ....
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....t No. Agreement date Area Rate per (sq.ft.) sq.ft.(Rs.) Consideration (Rs.) Remarks Ahana Roy 8A 19-1-2005 1,550 1,600 26,80,000 Flat Nos. 9A and 9B were raw/bare flats as mentioned in the agreements. Uma Devi Dhandhania 9A 26-4-2005 1,550 1,000 16,00,000 Bishnu Kr. Dhandhania 9B 26-4-2005 20-3-2005 1,100 1,000 1,100 11,00,000 The fifth schedule work was done by the buyers and not by the appellant company due to which lower prices were offered to them Comparison-3 Party's name Flat No. Agreement date Area (sq.ft.) Rate per sq.ft. (Rs.) Consideration (Rs.) Remarks Mualidhar VC 9C/D 11-4-2005 2650 918 24,35,000 The said flat was sold at lower rate since the buyer was high ranking police officer and in terms of benefits arising on account of security etc. of the project, the appellant deemed It fit to sell flat at lower rates. In view of the above explanation, we are of the view that decision to sell a particular flat at a particular price was taken out of commercial expediency and on valid grounds and cannot be randomly doubted by Department in the ab....
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....ails of additions made by the AO are as under; Particulars of addition A.Y. 2002-03 A.Y. 2003-04 A.Y. 2004-05 A.Y. 2005-06 A.Y. 2006-07 A.Y. 2007-08 A.Y. 2008-09 Total Disallowance of interest paid 461,882 793,619 736,559 - 1992060 Expenditure disallowed 174,249 187,841 234,450 180,728 342,548 434,417 1400,743 2954976 The assessee contended that it is following completed project method of accounting, wherein profits on sale of residential and commercial units is recognized only when the work in respect of project is completed. The cost incurred and payments received while project is in progress are accumulated and carried forward as work-in-progress (WIP) under inventories and as advances received from customers under current liabilities, respectively. It has valued its WIP as per accounting policy specified under AS-7. Costs that are (i) directly relatable to specific project, and (ii) attributable to the project activity in general and can be allocated to specific projects are included in WIP. However, costs that relate to the activities generally, or that relate to project ac....
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....be added back in assessments framed under s. 153C of the Act. Thus, entire assessment orders framed under s. 144/153C for the said years making exorbitant additions in the hands of the assessee company on these issues is without any basis. Further, as discussed above, in the instant case, no search was conducted, proceedings under s. 153C were initiated against the assessee on the basis of one set of documents marked RM/5 seized from the premises of one of its directors. However, no incriminating material or documents were found in course of the search or survey action with respect to the allowability or otherwise of the expenditure or interest expenses for any of the years under consideration. In the original assessments framed under s. 143(3) of the Act for asst. yrs. 2002-03 to 2005-06, the AO after application of mind and detailed scrutiny of accounts had consciously allowed said expenses and interest On loan. Further, said expenses had also been allowed in summary assessment under s. 143(1) for asst. yr. 2006-07. However, later on while framing assessments under s. 144/153C for the said years, under identical circumstances vis-a-vis past, the AO opined that a part of such expe....
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....ich was not sustainable in the absence of any material on record to the said extent. The assessee had duly proved the nature and source of loan by documentary evidences and AO had held it unsatisfactory without bringing on record any contrary material. As such no addition could be made under s. 68. Aggrieved against findings of CIT(A), now Revenue is in appeal before us. 20. We have heard rival submissions and gone through facts and circumstances of the case. We find that assessee company had in fact received a loan of Rs. 10,00,000 from Toplight Vinimay (P) Ltd. which is duly assessed to tax under PAN AABCT 2411L. In support of the aforesaid, assessee submitted following evidences in its paper book: (i) Acknowledgement of filing return of income for asst. yr. 2006-07 of M/s Toplight Vinimay (P) Ltd. - p. 217 of the paper book. (ii) Audited balance sheet as at 31st March, 2006 of Toplight Vinimay (P) Ltd. showing balance of loans advanced to M/s Fort Projects IP) Ltd. of Rs. 10,07,076 as on 31st March, 2006 -p. 218 of the paper book. (iii) Audited P and L a/c of M/s Toplight Vinimay (P) Ltd. for the year ending 31st March, 2006-pp. 219-222 of the paper....