TaxTMI 
TaxTMI 
2019 (7) TMI 1262
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....mon order for the sake of convenience as under: 2. Brief facts of the case are that a search u/s 132 was carried out in the residence of the assessee who is engaged in the business of civil contract works. The case was taken up for scrutiny, notices u/s 153A, 143(2) and 142(1) were issued and the assessments were completed u/s 143(3) r. w. s. 153A of the Act. During the search conducted in the residential premises of the assessee, incriminating material was found and the assessments were completed u/s 153A r. w. s. 143(3) by an order dated 31. 03. 2014. The year wise breakup of the returns filed in response to the Notice u/s 153A for the A. Y. 2008-09 to 2011-12 are as under: Asst. Year Date of Filing Total income admitted Agricultural income 2008-09 24. 05. 2013 23,35,550/- 7,50,000/- 2009-10 47,40,700/- 8,50,000/- 2010-11 23. 05. 2013 99,43,060/- 8,50,000/- 2011-12 89,12,370/- 9,00,000/- 2. 1. Similarly the details of the additions made to the returned income u/s 143(3) r. w. s. 153A of the Act for the A. Y. 2008-09 to 2011-12 are as under: Nature of addition 2008-09 2009-10 2010-11 201....
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....id in cash to the seller for purchase of a residential house. However, subsequently, the assessee stated to have decided to purchase the house in shell form and to do the interior work themselves, hence the seller returned the entire sum of Rs. 1. 95 crores in cash to the assessee. The assessee further stated that he had decided to register the property in the name of his wife Smt. R. Sulochana Devi, hence paid Rs. 1. 10 crores by way of cheque from his wife. The assessee further stated that interior work was done by themselves and the entire transaction was recorded in the books of his wife. During the post search enquiries, the assessee did not produce any documentary evidence to support the argument put forth by the assessee. Further the assessee even failed to produce the books of accounts showing the relevant entries made in the books of accounts and nor produced any other proof. Therefore, the AO issued show the cause notice to the assessee as to why the said amount of Rs. 1. 95 crores should not be treated as undisclosed investment in his individual hands. In response to the show cause notice, the assessee filed explanation reiterating the submissions made earlier and furthe....
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..... Murali Krishna after expiry of 9 years, i. e. after expiry of time limit for taking any action in the case of Sri L. Murali Krishna is unjustified and the Ld. CIT(A) should not have entertained the additional evidence produced by the assessee at the appellate stage. Apart from the above, the Ld. DR argued that the Addl. CIT has given a clear observation while forwarding the remand report stating that the report of the AO should not be considered, since, the AO simply stated that the explanation of the assessee is selfserving statement without bringing any facts or evidence on record. The Ld. CIT(A) ought to have endorsed the observations of the Addl. CIT also while deciding the appeal. The Ld. DR further argued that the AO in his remand report requested the Ld. CIT(A) to consider the issue on merits. It is further argued by the Ld. DR that the AO did not make proper enquiries with regard to the genuineness of the sources while submitting the remand report. Therefore, argued that the order of the Ld. CIT(A) be set aside and the addition made by the AO to be confirmed. 5. On the other hand, the Ld. AR argued that the assessee had advanced a sum of Rs. 195 lakhs for purchase of h....
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....o Sri Srisaila Babu, GPA holder in cash and Rs. 15 lakhs in cash and Rs. 10 lakhs by DD to Sri Murali Krishna. During the course of search and post search enquiries, the assessee has not furnished any explanation, explaining the sources of amount paid. The assessee neither produced the books of accounts showing relevant entries nor produced any proof explaining the sources. The assessee filed explanation stating that he intended to purchase the residential house for which he had paid Rs. 195 lakhs to Sri L. Murali Krishna and later on he changed his mind and planned to purchase a house from Sri L. Murali Krishna in a shell form and wanted to do the interior works himself. Hence Sri L. Murali Krishna returned the entire amount of Rs. 195. 00 lakhs in cash to the assessee and Rs. 1. 10 crores was paid by his wife. From the assessment order, it is seen that the assessee did not furnish any evidence with regard to the sources for payment and return of the amount paid to Murali Krishna. Hence, the AO made the addition. Subsequently, at the appellate stage, the assessee filed additional evidence, evidencing the receipt of money back from Sri L. Murali Krishna and on the basis of which th....
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....by Smt. R. Sulochana Devi as per the receipts found during the course of search. Hence, it is not necessary to return the amounts paid to builder and make the payment again to register the house in the name of Smt. Sulochana Devi. The amounts already paid during 14. 01. 2008 to 04. 04. 2008 can as well be treated as consideration for purchase of house. The reply submitted by the assessee neither sounds logical nor convincing. The AO should have examined the source of books of accounts which were not produced at the time of search / post search as well as assessment proceedings but produced later on. Apart from the above, as per the assessment order, Rs. 15 lakhs was paid to Sri L. Murali Krishna in cash and Rs. 180 lakhs was paid to Sri Srisaila Babu, GPA holder. When the amount was paid to Sri Srisaila Babu, why Sri L. Murali Krishna returned the amount, who is Sri Sailababu was also not explained. The AO neither examined Sri Murali Krishna nor examined Sri Srisaila Babu and the reasons for not producing the evidence at the time of search or post search and the assessment proceedings. Therefore, we are of the considered opinion that the issue was not properly verified by the lower....
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....ract relevant questions and answers of the statement recorded by the AO from question No. 3 to 6 which reads as under : "Q. No. 3 : Now I am showing you the seized books of account seized at your residence at Nellore marked as Annexure A/RV/PO/3, A/RV/PO/4, A/RV/PO/6, A/RV/PO/7, A/RV/PO/12, A/RV/PO/13, A/RV/PO/14 and also the impounded material marked as A/RVR/3, A/RVR/4 impounded from your Hyderabad office. Please go through these books of account and explain the contents? Ans : These books are seized /impounded from my residence at Nellore and my office in Hyderabad. These books are pertaining to my business receipts and payments. Q. No. 4. : In the above books, it was noticed that there were some amounts mentioned against some names. Please go through them and explain how did you account for those receipts /payments? Please explain the nature of those expenditure? Ans : An A/RV/PO/3 at page No. 50 contains brokerage expenses, page 300 to 304 contains 'Work related Expenses'; in A/RV/PO/6, page 35 to 40 and 73 to 74 contains 'Work related Expenditure', page 207 to 209 contains 'General Expenses; in A/RV/PO/7, page 14 contains 'Work Related Expenditure';....
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.... 8.2. General Expenses. As per the seized material marked as annexure A/RV/PO/3 pages serially numbered from page No. 122 to 129, A/RV/PO/4 pages serially numbered from 124 to 127, 266, 267, 268 to 271, 424 to 425, 392, 393, 395, 397 & 59, A/RV/PO/06 page number 207 to 209, A/RV/PO/07 page No. 192, the assessee has claimed deduction towards General Expenses to the extent of Rs. 63,04,108/- and the year wise breakup is as under : F. Y. A. Y. Amount (Rs. ) 2006-07 2007-08 29,74,800 2007-08 2008-09 7,63,308 2008-09 2009-10 11,71,000 2009-10 2010-11 13,95,000 Total 63,04,108 In the statement recorded on 10. 04. 2012, in question No. 6, the assessee accepted to come forward for admission of expenditure as disallowable. The AO issued show cause notice as to why the amount of Rs. 63,04,108/- should not be disallowed in the respective assessment years for want of proper evidence. The assessee submitted that the expenditure was incurred in the site and produced relevant ledger extracts, but no supportive material was filed before the AO at the time of search or post search proceedings and during the assessment proceedings....
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....he Ld. CIT(A) observed the complexity in the accounts and owing to complexity of the work the Ld. CIT(A) restricted the disallowance of expenses to the extent of 50%. For the sake of clarity and convenience, we extract relevant part of the order of the Ld. CIT(A) which reads as under for the A. Y. 2008-09 to 2011-12: "I have considered the arguments of appellant and findings of the Assessing Officer with reference to each addition, it is a fact that the appellant has filed the Returns of Income much before the search action. The financial results are arrived only after statutory audit. In this context, the main issue before the Assessing Officer is to see or examine whether the evidence gathered in search is in accordance with the books of account or not? The Assessing Officer has accorded reasonable opportunity by issuing show-cause notices with reference to each head of account namely departmental expenses/brokerage/general expenses and EPL expenditure for all the assessment years The Authorized Representative of the appellant have produced comparative summary of expenditure as per the seized material and as per the books of account as a sample to ascertain the ext....
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.... of expenses whether allowable or Otherwise. This could be probable reason why the appellant was not able to identify the persons and their association with the business of the appellant. Apparently, that could be the reason why such expenditure was not supported with bills and vouchers. At the same, the Assessing Officer has not given a categorical finding regarding the nature of payment except stating that in the absence of explanation to the show-cause notice, the expenditure is treated as 'unaccounted investment' It is not a case where the appellant has not incurred the expenditure without affecting the withdrawals from the bank. It is clear that these expenses have been loaded into the books under two heads as appearing in the P&L. account In this scenario, it is not possible to segregate as to what is allowable or otherwise in this case. If one indulges in this exercise, it may lead to recasting the books of account with reference to the expenses alone which is not possible at this state. Owing to these complex situations, a reasonable conclusion can be arrived with a reasonable nexus to the seized material and books of account. Keeping these aspects in mind; I procee....
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....ppellant would have dovetailed such amount into the books of account. The modus operandi adopted by the appellant when such expenses are debited in the books is also not forth-coming in the assessment order. At the best, the appellant could have inflated such expenditure. It is also not known under which head the expenditure was debited in Direct Expenditure. Be it as it may, it is not possible to figure out what is the extent of allowable expenditure or otherwise. In such complex situation, I am of the opinion that it serves both the parties if a reasonable percentage of such expenditure is considered for disallowance. After careful consideration of submissions and material on record, the Assessing Officer is directed to disallow 50% of expenditure in each Asst. Year. iii) Illegal payments / general expenses (A. Yrs 2008-09 to 2010-11) : (iiia) The Assessing Officer is of the view that the seized material A/RV/PO/3 (Page Nos. 122 to 129), A/RV/PO/4 (Page Nos. 124 to 127, 266, 267 & 268 to 275, 424 to 425, 392, 393, 395, 397 & 59, A/RV/P0/6 (Page Nos 207 to 220, A/RV/PO/7 (Page No. 192) represent expenditure incurred under the head 'general expenses'. The ....
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....appellant had made a claim of expenses without being incurring the same It is noticed that the monies have been withdrawn and they have gone out of the books. The appellant had equally failed in substantiating his case as to what is allowable or otherwise. Except making a claim, no leads have been provided though the entire seized material is in the possession of appellant. The Authorized Representative of the appellant had fairly conceded that bills and vouchers cannot be produced with certainty. It is not certain whether such expenses are truly meant for business or otherwise The Assessing Officer has also not given such categorical finding In this factual matrix, it would render justice If the expenditure is disallowed at 50% The Assessing Officer is accordingly directed to adopt 50% of expenditure as not allowable being unexplained expenditure. The total expenditure claimed for the Asst Year 2008-09 to 2010-11 is Rs. 63,04,108/- Accordingly, 50% of it would be Rs. 31,52,054. iv) EPL Expenditure/ Illegal payments: (iva) It is the case of the Assessing Officer that there are certain expenditure which is termed as work related such as EPC expenses (Engineer....
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....he ends of Justice. A. Y. Amount (Rs. ) 2007-08 5,26,250 2008-09 3,44,000 2009-10 3,12,500 2010-11 1,00,000 Total 12,82,750 9.1. The assessee also filed cross appeals agitating disallowance confirmed by the CIT(A) and cross objection supporting the order of the Ld. CIT(A) for confirming 50% of the addition for all the assessment years. During the appeal hearing, the Ld. DR argued that during the course of search, seized material was found indicating the payments, which was grouped under general expenses, direct expenses and EPC expenses. During the course of search, the assessee accepted that the payments were not supported by proper evidence and also agreed to come forward with disallowance. No evidences were filed with regard to the name and address of the persons to whom the amounts were paid, nature of expenses, purpose of payment etc. During the appeal proceedings also, the assessee did not produce such details, which is evident from the remand report also. No evidence whatsoever was filed by the assessee to prove the genuineness of the payment. The assessee failed to establish that the payment was made for the purpose of business. In res....
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....Direct Expenditure', general expenses and EPI expenses. The assessee failed to produce any evidence to support the payments made in respect of the various payments. The Ld. AR during the appeal hearing accepted that the entire expenditure was made out of the self contained vouchers and there were no proper vouchers available with the assessee to support the genuineness of the expenditure. In the statement recorded u/s 132, the assessee had agreed that the payments were made to the persons who promised to get the things done in an expeditious manner. Names of the persons to whom the payments were made, what was the work done by the person, nature of service rendered by the said persons was not explained by the assessee. Whether the payments were made in regular course of business or for illegal payments was also not furnished by the assessee. Though in response to question No. 5, the assessee stated that the payments were made to technically qualified people, who assisted in execution of the EPC contracts, the assessee neither furnished the names and address of the persons, nature of the payments and the nature of services rendered etc. Prima facie, from the statement of the assesse....
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....59,306. 40 2. Mess Maintenance Account 3,00,602. 22 91 to 93 3,00,602. 00 62,3071. 00 3,22,469. 00 3. Travelling Expenses Account 83,923. 00 180, 189 83,923. 00 3,57,265. 00 2,73,342. 00 4. Tippers Maintenance 24,91,176. 00 121 to 124 24,91,176. 00 53,38,493. 00 28,47,317. 00 5. Machinery Maintenance Account 25,72,303. 00 133 to 137 25,72,303. 00 48,19,851. 00 22,47,548. 00 6. Blasting Materials Account 3,59,328. 00 227 3,59,328. 00 14,90,800. 00 11,31,472. 00 7. Salaries Account 19,73,096. 00 291 to 304 19,73,096. 00 60,75,000. 00 41,01,904. 00 The above differences show the scale of inflation of expenditure made by the assessee for which there was no explanation. In the normal course these excess expenses also required to be explained with relevant evidences and the reasons. It appears that assessee neither explained before the AO nor before the Ld. CIT(A). Though glaring differences were found by the Ld. CIT(A), the Ld. CIT(A) considered the trade practices and the explanation offered by the assessee and reasonably allowed 50% of expenditure. Consideri....
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....transactions. He has confirmed that he has taken Rs. 25 lakhs each on 07. 10. 2011 and 20. 10. 2011 from Sri R. Venkatramaiah and they were outstanding as on the date. The assessee as well as the executant of pronotes submitted that they have no documentary proof to support the submission made by them in the statements. The extract of the statement recorded from Sri Muthaiah is reproduced vide page no. 3 and 4 of the assessment order which reads as under : Sri Muthaah was also summoned and his statement was recorded on 19/04/2012, relevant portion of the statement Is extracted below "Q. No. 8 : I am showing you copies of pro-notes signed by you S. No, 195, 196, 198 & 199 of the seized folder marked as A/R VR/2 found and seized froth the residence of Sri Ravulpalli Venkatraniaiah during the course of search operations conducted. As per which you have taken amount of Ps. 1. 5 crores from Sri Ravulapalli Venkatrainaiah, Please explain these transactions and clarify whether these are reflected in your books of account, if so please produce the evidences there of? Ans : I confirm that,I have signed and executed the following pro-notes asmentioned at pages seri....
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....he work performance on behalf of others or to join together in the form of joint ventures and execute bigger works which otherwise could not be executed by them individually. The assessee and Sri Muthaiah are jointly exploring various works including HSNL work and Delhi-Agra road work. As a part of performance guarantee Sri R. Muthaiah has deposited two promissory notes of Rs. 50 lakhs each in the name of the assessee and his wife Smt. R. Sulochana Devi. Therefore, stated that the pro-notes of Rs. 50. 00 lakhs do not represent any advance given by the assessee and it is only paper transaction and does not deserve to be treated as unexplained investment in the hands of the assessee, therefore requested to delete the addition. However, the AO did not find the explanation offered by the assessee as convincing, hence, treated the sum of Rs. 50. 00 lakhs as unexplained investment and taxed the same in the hands of the assessee. 14. Aggrieved by the order of the AO, the assessee went on appeal before the CIT(A) and the Ld. CIT(A) confirmed the addition made by the AO. However, allowed the sum of Rs. 50 lakhs as telescopic benefit for the additional income offered by the assessee in th....
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....y the argument that there is no financial transaction in the instrument The affidavit though filed will not vitiate or erase the facts recorded on the pro-notes. A fact recorded cannot be disproved by an affidavit though valid in the eyes of Law. The affidavit filed must demonstrate with material to the hilt that what was recorded in the pro-notes is not real. The affidavit does not bring such facts. It remains a mere isolated statement. (e) Further, I have also perused the statement recorded from Sri R. Muttaiah on 19/04/2012 wherein he stated that the pro-notes were not torn since they have no value. I have examined this aspect. I am of the opinion that the Executant has no legal remedy if the lender pressed for legal action in any Court of Law owing to the signature appended by the Executant. The burden of proof shifts on Sri R. Muttaiah to prove that money was not received against the acknowledgement. Thus, the probability of ignoring the instruments is remote and unconvincing. The assertion of executants of pro-note is definitely an afterthought engaged in order to orchestrate the view of the appellant. Further, the material evidence as to Executant's role in Delh....
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....ipt of cash of Rs. 25,00,000/- each on different dates. The pro-notes were executed by Sri Muttaiah. The rate of interest is 36%. The pronotes are duly signed by the Executant. I have gone through the statement recorded from Sri Muttaiah on 19/04/2012 wherein he confirmed that a loan of Rs. 50,00,000/- was borrowed from Sri Ravulapalli Venkatramaiah and it is still outstanding. This fact was also confirmed by Sri Ravulapalli Venkatramaiah in his statement recorded on 11/01/2012 Thus, the pro-notes are considered as explained (f) Alternatively, the appellant had pleaded for telescoping of additional income ofRs. 50,00,000/- offered by the appellant for the Assessment Year 201112. The appellant had relied on the ratios of following cases in support of his claim : CIT vs. Venkateswara Timber DepOt ( 222 ITR 768, AP HC] CIT vs. K. S. M. Guruswamy Nadar & Sons [149 ITR 127, Mad HC] Gopal S Pandith vs DCIT [186 TTJ 64, Bang Tribunal]J M. M. Sulatman vs. ACIT [159 TTJ 746, Cochin Tribunal ] (j) I have considered the alternative plea and found that the appellant had offered Rs. 50,00,000/- as additional income for the A. Y. . 2011-12 wh....
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....fidavits, the assessee cannot get away from taxing the unexplained investment. Therefore, argued that the Ld. CIT(A) rightly directed the AO to tax the sum of Rs. 50 lakhs in the hands of the assessee and the remaining Rs. 50 lakhs in the hands of Smt. R. Sulocahna Devi. However, the Ld. CIT(A) allowed the addition of Rs. 50 lakhs in the hands of the assessee to be set off against the additional income offered by the assessee for the A. Y. 2011-12 which is incorrect. The Ld. DR further submitted that though the assessee had offered the additional income for the A. Y. 2011-12, that was offered for the excess expenditure which was already spent by the assessee and there were no funds available for the assessee for advancing the amounts to Sri Muthaiah. Further, the Ld. DR argued that the assessee's contention is contradictory. One way, the assessee contended that there was no advance and alternatively pleaded for telescopic benefit which is contradictory to each other and once the assessee asks for telescopic benefit, it goes against the assessee. In any case, since the assessee has already spent the amount for the A. Y. 2011-12, there is no case for allowing telescopic benefit, henc....
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.... pro-notes drawn in favour of Smt. R. Sulochana Devi on 01. 07. 2011 for Rs. 50 lakhs bearing interest @24% and Sri R. Venkatramaiah on 01. 07. 2011 for Rs. 50 lakhs @24% and Sri R. Venktramaiah on 07. 10. 2011 and 20. 10. 2011 for Rs. 25 lakhs @36% were found and seized from the residential premises of the assessee. In the statement recorded on 11. 01. 2012, the assessee explained that the pro-notes were taken for the purpose of security in the tender process of HSNL work, with regard to pro-notes for Rs. 25 lakhs each on 07. 10. 2011 and 20. 10. 2011 was accepted by the assessee as well as the executant of the pro-notes, therefore, there is no dispute. A statement u/s 131 was recorded from Sri R. Muthaiah, executant of the pro-notes who has stated that the pro-notes were given as performance guarantee to Sri Venkatramaiah for allotment of work at Delhi-Agra road work from JP Associates. There is no dispute that Sri R. Muthaiah has agreed that all the pro-notes were signed by Sri Muthaiah and there is no dispute with regard to the correctness of the pro-notes. The contention of the assessee was that it was obtained for the security for tender work of HSNL, whereas as per the conte....
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....t the recipient has received a sum of Rs. 50. 00 lakhs each on 01. 07. 2011 from R. Sulochana Devi and Sri R. Venkatramaiah and as per the contents of the pro-notes, they are genuine transactions with complete details on the pro-notes. It was also mentioned the rate of interest, date of receipt, sum of receipt and acknowledged having received the money. The pro-notes were not cancelled and there was no evidence to show that the pro-notes were given as security. The Ld. AR argued that the pro-notes does not contain signature of the witnesses. As per the Negotiable Instruments Act, the witness's signature is not mandatory to hold that the promissory note as valid. As per section 4 of the Negotiable Instruments Act, the requirement is, drawer should sign the promissory note in writing, promising to make the payment on demand. That's why it is called demand promissory note. Since the valid pro-notes are available with the assessee, during the course of search, as per section 292C of the Act, it is presumed that the assessee had given loans to Sri R. Muthaiah. Since the assessee failed to prove that the pro-notes were obtained only for the purpose of security, we have no hesitation to h....
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....odus operandi of inflation of expenditure under each head and also explain the generation of cash for advancing the amount out of sums saved from the inflation of expenditure. In the absence of such details, it is not correct to allow telescopic benefit, hence, we set aside the order of the Ld. CIT(A) and restore the order of the AO. Accordingly, appeal of the revenue is allowed and CO of the assessee is dismissed. 22. The next issue in this appeal is confirmation of addition on account of illegal payments under the head Direct Expenses, General Expenses and EPC expenses. The AO disallowed the sum of Rs. 34,06,750/- for not producing the relevant evidences. The Ld. CIT(A) restricted the disallowance to 50% of the expenses debited to the Profit & Loss account. 23. Against the order of the CIT(A), the assessee filed cross appeal challenging the confirmation of the addition made by the AO and filed cross objections supporting the order of the Ld. CIT(A) for restricting the disallowance to 50%. The issue is involved on identical facts in the assessee's case for the A. Y. 2008-09 to 2011-12 discussed in para No. 8 to 11 of this order. Taking consistent view, we uphold the order of....
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....o. 566/Viz/2018 for the A. Y. 2008-09 to 2012-13 are dismissed. Order pronounced in the open court on 26th June 2019. ============= Document 1 SRI R.VENKATRAMAIH-AY 2008-09 Annexure 1 COMPARITIVE SUMMARY OF EXPENDITURE AS PER SEIZED MATERIAL AND REGULAR BOOKS OF ACCOUNTS Amount as per Seized material Sl.No. Name of the Ledger A/RV/PO/6 Page Nos Amount as per regular books of accounts Income Tax Return Diffrence 1 General Expenses Account 279.014.00 23 to 26 279,014.00 279.014.00 2 Bank Charges Account 1,131,778.00 41 1.131,778.00 556,418.15 3 Printing & Stationery Account 51,681.00 55 $1,681.00 4 Sheds Account 254,371.00 61,52 254,371.00 325,971.00 5 Phone Bills Account 9.223.00 65 6 Diesel Account 2,213,128.00 75 to 78 9,223.00 2,213,128.00 125.658.00 773,339 84 51,681.00 (71,600.00) (116,435 00) 2,213,128.00 7 Mess Maintalance Account 300,602.00 91 to 93 300,602.00 623,071.00 B Oils Account 178.410.00 99 178,410.00 16,037,716.40 (322,469.00 (15,859,306.40) 9 Traveiling Expen....