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TaxTMI 
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2018 (10) TMI 1746
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....iled and necessary steps were taken thereafter. After realizing that the appeal was not filed, he took immediate step to file the appeal, resulting in delay of 93 days. The assessee submitted that he had no intention to jeopardize the interests of the revenue by delaying the filing of the appeal and prayed to condone the delay for which the Ld. DR has not opposed it. In our opinion, there is good and sufficient reason for condoning the short delay of 93 days. Accordingly, we condone the delay and the appeal in ITA No. 372/Coch/2016 is taken up for adjudication. ITA No. 372/Coch/2016: Assessee This appeal by the assessee is directed against the order of the CIT(A)-IV, Kochi dated 31/03/2016 for the assessment year 2008-09. 2. The first ground raised by the assessee is with regard to sustenance of addition made towards estimation of G.P. at Rs. 40,88,636/-. 3. The facts of the issue are that on the basis of documents/books of account found and seized and information gathered during the course of search at its business premises on 21/08/2007, a notice u/s. 142(1) of the Act was issued to the assessee on 28/04/2009. In response to the above notice, the return of income for the ....
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....ove. 3.4 On checking the log-in time of the computer maintained in M/s. Sunny Jacob 916 Jewellery showroom, Trivandrum, it was found that the entries in the computer show that all the sales for a day are recorded in the computer within a short time of 2 to 3 minutes which gives more credence to the view that sale bills generated in the computer are made up for accounting purposes only and they do not reflect the actual sales. 3.5 Further many discrepancies were noticed in the books of accounts found and seized during the course of search regarding the amount withdrawn and debited. The assessee could not offer any satisfactory explanation for the discrepancies. But during the course of hearing at the time of original assessment, the assessee produced computer printed cash book and ledger where the above discrepancies were removed The cash book and the ledger produced on 28/12/2009 were impounded u/s. 131(3) of the Act. As the account books based on which the assessee had made up the accounts, were held to be not reliable and income was estimated on estimated turnover, the above discrepancies did not affect the computation of income. 3.6 During the shop inspection by the Commer....
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....selection was handed over to Shri Mathew Eapen, former Floor Supervisor of M/s. Sunny Jacob 916 Jewellery, Trivandrum who was issuing the sale bills to the customer. Hence, according to him no estimate slips, where final selection was made could go out of the shop and it is only in the cases where there were possibilities of an immediate exchange, estimate slips were given after affixing cash received seal. Shri Mathew Eapen in his statement dated 21/08/2007 had stated that his shop was not issuing sale bills for all sales and purchase bills for all purchases but on re-examination, he stated that his shop was issuing sale bills for all sales and purchases bills for all purchase. Similarly, Shri Bejimon S., erstwhile Manager of M/s. Sunny Jacob Jewellers and Wedding Centre, Kottarakkara tried to explain that the shop at Kottarakkara was not using computer but on re-examination he stated that the computer was used at least sparingly. The statement given by Shri Pintu T. Jacob, Computer Operator, M/s. Sunny Jacob 916 Jewellery, was a clarification to the effect that he was only printing estimate slips and not sale bills and he was only entrusted with the work of printing estimate slip....
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....d the average G.P. adopted for the AYs 2002-03 to 2008-08 was 18.23%. The assessee requested to adopt G.P. of 10%, however, the AO did not find any merit in this claim of the assessee. Since the average profit adopted by the assessee voluntarily was 18.23%, the AO adopted the gross profit at 19% of the turnover estimated as the total income of the assessee. 4. On appeal, the CIT(A) held that the AO's order, to the extent of the profit on suppression of sales, was upheld by his Predecessor where he had distinguished the estimates of profit based on seized incriminating materials found in respect of the period relevant to AY 2008-09 vis-à-vis applying the same principle for estimating the suppression of sales during the AY 2002-03 to 2007-08 without having any specific materials seized in respect of these assessment years. Since the previous CIT(A) had made threadbare analysis of the suppressed income for the AY 2008-09, to which the present CIT(A) fully concurred with, following the findings such suppression was upheld in principle. As regards, the estimation of the quantum of G.P. by applying a rate of 19% instead of 22% in the original assessment order by the AO, the same....
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....Apex Court against the order of the High Court vide SLP 14765-14767 of 2015 along with other connected cases. The Hon'ble Apex Court restored back the issues to be examined by the CIT(A) who passed the present impugned appellate order. The CIT(A) has given a tabulation showing the income returned and assessed for the Assessment Years 2002-03 to 2008-09 and Para 7 deals with the Statement of Facts. The ld. AR relied on the CIT(A) 's observations and findings wherein it was found that the order passed by his learned predecessor covered the entire span of facts of the case and at the same time the Assessing Officer had not brought on record any new fact on record. It was held that the addition based on estimate of GP rate on the estimated suppressed turnover had no basis. The additions were accordingly deleted. Having regard to the fact that there were no seized materials covering the earlier years, except for the Assessment Year 2008-09, the CIT(A) found that there was no evidence that the assessee had suppressed its turnover for prior years. No incriminating material was found concerning the prior years. The order of the CIT (A) in deleting addition of prior years cannot be fa....
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....ls obtained during the course of search is bad in law. 5.6 The Ld. AR further submitted that the original assessment order that has been set aside by the ITAT, Cochin Bench and the same additions that have been deleted by the CIT(A) have been fully reproduced except for a small reduction in the Gross Profit percentage from 22% to 19%. No fresh evidences from the seized documents nor any fresh findings/reasons to support the addition as directed by the ITAT, Cochin Bench while setting aside the said assessment order have been put forth by the assessing authorities while completing the assessment. The reasons for the additions are the same which has already been considered by the CIT(A) and hence, it is a covered matter. 6. On the other hand, the Ld. DR relied on the orders of the lower authorities. 7. We have heard the rival submissions and perused the record. There was a search in the business premises of the firm on 20/08/2007. During the course of search, it was found that the assessee was maintaining its accounts in computerized form. The CPUs used for the purpose at Kottayam and Kottarakkara were seized during the course of search. From the Pazhavangadi, Trivandrum shop o....
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....ns of M/s. Sunny Jacob Group of Jewelleries are printing estimate slips on computer when a customer comes and selects a gold ornament for purchase. As a customer may change his selection more than once, more than one estimate slips are likely to be issued in such cases. But, the estimate slips handed over to the sales man for preparation of final bill, which according to the assessee, is written manually, is the final estimate slip where the purchases of the customer is recorded. If there is no likelihood of return or exchange of the ornaments immediately, a customer is issued a sale bill. He is not given estimate slip. But in case there is a possibility of exchange or return immediately instead of sale bill, the estimate slip with the seal of "cash received" is handed over to the customer with the jewellery. All the estimate slips other than those which are handed over to the customers are destroyed/thrown into the waste basket. Hence, a customer can have an estimate slip with him only if that purchase is one where the immediate exchange or return is expected. Though the assessee is printing estimate slips in the computer, the assessee is not saving the data in the computer. Also,....
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.....2007 to 07.08.2007. The AO has also pointed-out that at the showroom of M/s. Sunny Jacob Jewellers 916 Kerala Showroom, Pazhavangadi, Trivandrum all the sales of the day are recorded in the computer within 2 to 5 minutes. The period referred to by the AO is between 07.05.2007 to 11.05.2007. He has observed that it is very anomalous and gives more credence to the view that sale bill generated in the computer are made up for accounting purposes only and they do not reflect the actual sales. In Para 13 (a), (b) and (c) some other discrepancies pointed-out for the Kollam shop, Kottayam shop and Kottarakkara Shop. Based on these discrepancies the AO has finally rejected the books of accounts invoking provisions of sec. 145(3) r.w.s. 144. 6. As regards assessee's ground relating to the invocation of sec. 144 r.w.s. 145(3) is concerned I do not agree with the appellant because the AO has first pointed-out various discrepancies and anomalies in the books of accounts maintained by the appellant and then only invoked provisions of sec. 145(3) r.w.s. 144. The appellant has submitted that the provisions of sec. 145(3) are not fully complied with, because no opportunity of being heard w....
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.... that there is suppression for whole of the search year. Similar view has been taken in the case of Rajendrakumar Lahoti vs. DCIT (266 ITR 621), In the earlier years the additions could not stand the test of appeal because there was no material available with the Department to show that there was suppression of income for those years and, therefore, there could not have been any additions. But for the year under consideration a pattern of suppression has emerged though restricted to only a small period, but it proves that there was suppression for this period and once there was suppression for a period of the year the estimate is possible for whole of the year as pronounced by various judicial forums. Hence for the assessment year 2008-09 I do not have any hesitation in holding that the appellant has concealed income to the tune of Rs. 47,34,209/- as per working given in the order for assessment year 2008-09. I therefore sustain the same. 7.3. In the revised assessment order, the Assessing Officer held as under: "The order giving effect to the order n/s.263 of the I.T. Act by the Commissioner of Income-tax (Central), Kochi was passed on 20.03.2013 by making an addition of Rs. ....
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....eriya (332 ITR 537) wherein it was held as under: "(ii) That the partner of the assessee had in unambiguous terms stated that 20 per cent of the sales outturn was suppressed and only 80 per cent was recorded in the account books and it was the practice from the very beginning. So, it was just and appropriate to presume that there was uniform concealment of income in all the assessment years during the block period. Hence the assessee was liable to be assessed during the block period at a uniform rate." In view of the above judgments of the Jurisdictional High Court, we are inclined to dismiss this ground of the assessee. The appeal of the assessee is dismissed. 8. The next ground is with regard to sustenance of addition of Rs. 23,14,809/- towards valuation of closing stock. 9. The facts of the case are that the issue considered U/s. 263 by the CIT cannot and was also not subject matter of appeals before CIT(A) and ITAT. The issue set aside and restored to the file of Assessing Officer by the ITAT was regarding the issue of suppressed sales turnover and profit whereas the issue set aside by the CIT in her order dated 16/03/2012 was the valuation of correct closing stock. Gi....
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.... in the books. Once this principle is applied and the stock-in-trade is valued at market price, the surplus if any, has to get reflected as profits of the firm and has to be charged to tax. The assessee relied on various judicial decisions in the same line. For example, G.R. Ramachari & Co. vs. CIT 1961) 41 ITR 142 (Mad) : Popular Workshops vs. CIT (1986) 54 CTR 323 (Ker): (1987) 166 ITR 348(Ker). Popular Automobiles vs. CFT (1990)89 CTR 248(Ker) : (1989) 179 ITR 632 (Ker) etc. 9.2 The Assessing Officer noted that the firm's business was totally discontinued and the assets were in fact distributed. The only difference was that the entire assets were assigned to one of the partners in satisfaction of his accepting the entire liabilities. After taking over the entire assets and liabilities of the firm the partner continued the business of the firm as part of his proprietary concern, Dona Gold. This would mean that the firm stood dissolved. 9.3 In view of the above, the contentions raised by the assessee that the firm is not "dissolved" but only its assets and liabilities were sold to another concern "as business as a whole" and that there being no closing stock, the Assessing....
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....4,809/-. 11. Against this, the assessee is in appeal before us. The ld. AR submitted that the addition of Rs. 23,14,809/- being difference in valuation of closing stock was wrong. The lower authorities failed to distinguish the facts of the assessee's case with the facts in the case of A.L.A. Firms vs. CIT (189 ITR 285). 12. On the other hand, the Ld. DR relied on the orders of the lower authorities. 13. We have heard the rival submissions and perused the record. In this case, te closing stock was estimated by applying GP rate at 22% in the assessment year under consideration. Since we have confirmed the estimation of income by applying GP rate at 22%, the closing stock determined by the Assessing Officer is to be confirmed. Accordingly, we find no infirmity in the order of the lower authorities and the same is confirmed. Thus, this ground of appeal of the assessee is dismissed. The appeal of the assessee is dismissed. ITA Nos. 314 to 319/Coch/2016: Revenue: AY 2002-03 to 2008-09 14. These appeals filed by the Revenue are directed against the common order of the CIT(A)-IV, Kochi dated 31/03/2016 for the assessment years 2002-03 to 2008-09. 15. The only ground raised by ....
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....asons, it was prayed that the order of the CIT(A) may be set aside and that of the AO restored. 17.2 On the other hand, the Ld. AR relied on the order of the CIT(A). 17.3 We have heard the rival submissions and perused the record. Since we have confirmed the estimation of income for the assessment year 2008-09 in ITA No. 372/Coch/2016 by placing reliance on the judgment of the Travancore Logistics cited supra and Meriya Hotel cited supra, estimation of income for these assessment years on the basis of the seized records found during the search in the year relevant to the AY 2008-09 is justified as the assessee has followed uniform system of suppression of sales. This ground of appeal of the Revenue is allowed for all the assessment years 17.4 In the result, the appeals of the Revenue in ITA Nos. 314 to 319/Coch/2016 are allowed. ITA No. 371/Coch/2016 : Assessee: AY 2007-08 18. This appeal filed by the assessee is directed against the common order of the CIT(A)-IV, Kochi dated 31-03-2016 for the assessment year 2007-08. 18.1. There is a delay of 93 days in filing the appeal before the Tribunal. The reason advanced by the assessee for filing the appeal belatedly is same a....
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....of the appellate order in the office of Pr. Commissioner of Income-tax, Trivandrum on transfer of jurisdiction from the office of Commissioner of Income-tax, Central Circle, Trivandrum. As the delay was due to sufficient causes beyond the control of the Revenue, it was prayed that the delay of 22 days may be condoned and admit the appeals for adjudication. In our opinion, there is good and sufficient reason for condoning the short delay of 93 days. Accordingly, we condone the delay and the appeals in ITA Nos. 341 to 344/Coch/2016 are taken up for adjudication. 19.2 The only ground in ITA Nos. 341-344/Coch/2016 is with regard to estimation of G.P. towards unaccounted sales on the basis of material found during the search for the assessment year 2008-09. 19.3 The facts of the case are similar to that considered by us in Ground No. 1 in 19.4 The addition made by the Assessing Officer was deleted by the CIT(A) for the reason that no material was found during the course of search for the assessment year 2008-09 . 19.5 Against this, the Revenue is in appeal before us. The Ld. DR submitted that the AO had established that assessee had affected sales by issue of estimate slips inst....
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....A)-IV, Kochi dated 31/03/2016 for the assessment years 2006- 07 and 2007-08. 21.2 The issue raised in these appeals is whether the CIT(A) was justified in deleting the additions of Rs. 1,31,55,837/- and Rs. 1,68,39,970/- for the assessment year 2006-07 and 2007-08, being unexplained investment made by the assessee in the purchase of property. 21.3. The facts of the case are the assessee is a partner in several firms. He is also a Director in two private limited companies. There was a search u/s. 132 of the I.T. Act in the business and residential premises of the assessee on 21/08/2007. A notice u/s. 153A of the Act was issued to the assessee on 30/06/2009. In response to the notice, the assessee filed his returns of income for the assessment years 2006-07 and 2007-08, declaring total income of Rs. 1,09,062/- and Rs. 95.799/- respectively. The original assessment was completed u/s. 153A r.w.s. 143(3) of the I.T. Act, determining a total income of Rs. 1,36,74,900/-and Rs. 1,74,05,770/- for the assessment years 2006-07 and 2007-08 respectively. The assessee filed appeals against the original assessments before the first appellate authority. The CIT(A) vide order dated 22/09/2010 d....
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.... are different from income-tax proceedings while computing the total income the modus operandi adopted by the taxpayer can be taken into account in the income-tax proceedings also. The income-tax authority has to reappreciate the materials found by the Commercial Tax Authorities. Moreover, one Mr. Pintu Jacob claimed that he was issuing only estimate slip. Moreover several investment in the landed properties were found from assessment year 2002-03 to assessment year 2008- 09. The agreement for sale -was found and the assessing officer claims that the profit on suppressed sales was invested in landed properties. Therefore, it may not be correct to say that there was no material for the assessment years 2002-03 to 2007-08. In those circumstances, this Tribunal is of the considered opinion that Commissioner of Incometax( A) is not justified in deleting the addition for the assessment years 2002-03 to 2007-08. However, the statement recorded from the cashier and other persons and the material collected by the Commercial Tax Department needs to be examined after giving an opportunity to the taxpayer. The taxpayer had no occasion to respond to the material collected by the sales-tax depa....
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....lusion in the appeals. " 21.6 Pursuant to the ITAT order dated 16/11/2012, the fresh assessment was completed by making the additions of Rs. 1,31,55,837/- and Rs. 1,68,39,970/- for the assessment years 2006-07 and 2007-08 respectively, being the on-money payments made by the assessee for purchase of lands. In other words, the assessment orders passed in consequent to the order of the ITAT had reiterated the additions made in the original assessment order. 21.7 Aggrieved by the additions made by the Assessing Officer in the second assessment order, the assessee had preferred appeals to the first appellate authority. The CIT(A) following his predecessor's order, held that the additions are purely on estimate basis without any documentary proof and therefore they cannot be sustained. The CIT(A) after reproducing his predecessor's order held as follows: "11. As a matter of fact, my ld. Predecessor has already discussed the issue on facts as well as on the judicial pronouncement on identical facts and has held that "additions made on this count are not justified and accordingly cannot be sustained", I do not find anything new brought out by the AO during the re-assessment proceed....
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.... Hotel Anjali Park, Kottayam on 13-2-2007. For these and other grounds that may be advanced at the time of hearing, the order of the learned Commissioner of Income tax (Appeals) on the above points may be set aside and that of the Assessing Officer restored." 21.9 The Ld. DR relied on the grounds raised and also has filed written submission. The relevant portion of the written submission reads as follows: "1(a) The Respondent Shri Sunny Jacob is a Partner in the firm mentioned below: - M/s.. Sunny Jacob Jewellers, Kottayam. M/s. Sunny Jacob Gold Hyper Market, Kollarn. M/s. Sunny Jacob Jewellers & Wedding Centre, Kottarakkara. M/s. Sunny Jacob 916 Jewellers Show Room, Fort Manor, Trivandrum. Shri Sunny Jacob is also a director of M/s. Sunny Jacob Builders and Developers P. Ltd, Kottayam and M/s. Kalathil Builders & Developers. 1 (b) A Search u/s 132 was conducted on 21-08-2007 in the Residential premises and business premises at Kottayam, Kollam, Kottarakkara & Trivandrum. Sworn statement was recorded from Sri Sunny Jacob during search proceedings on 24/08/2007. Incriminating documents were seized. Incriminating documents revealed for the immovable properti....
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....ident in the following findings:- "Valuation at 200% of the declared cost was proposed after taking into account the above factors and the fact that these properties were in the hands of the tenant at the time of transfer. Hence, considering the circumstances of the case, the properties are valued as proposed and the extra amount paid is treated as unexplained investment u/s 69 of the Income Tax Act. The additional payment for investment in property so made, works out to Rs. 50 lakhs for the Assessment Year 2006-07. Rs. 1,00,82,700/-for 2007-08 and Rs. 1,60,000/- for 2008-09'". The aggregate addition made for 2006-07 assessment is Rs. 1,31,55,837/-. 3. The CIT(A) after having considered the lack of evidence and the objections raised by the appellant before him, deleted the additions of Rs. 1,31,55,837/-for the Assessment Year 2006-07 and Rs. 1,68,39,970/- for the Assessment Year 2007-08. Before the CIT(A), the Counsel for the appellant submitted elaborate argument note, the relevant case law on the subject, which are discussed in detail and the issues were decided by holding that additions were arbitrary and purely on estimates and unsupported by any reliable material ....
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.... per the document. The Assessing Officer stated that the assessee had admitted that amounts have been paid as per the sale agreements seized and had offered to tax for AY 2008-09 the difference as per the sale agreement seized and the sale documents, in the statement recorded during the course of search. The A.O. noted that the properties purchased by the assessee for the assessment year 2006-2007 and 2007-2008 are in the same locality and in the same village of the properties purchased by the assessee for the assessment year 2008-2009. Therefore it was concluded by the A.O. that onmoney has been paid for the properties purchased during assessment year 2006-2007 and A.Y. 2007-2008 as well based on the seized documents and statement recorded from the assessee concerning AY 2008-09. The A.O. took the average value per cent for the purchase made by assessee in the A.Y. 2008- 2009 and adopted the same value for the purchase made in the assessment year 2006-2007 and 2007-2008 and worked out the on-money payment as regards the purchase of property at Kollam. 22.3 With regard to the purchase of property at Kottayam, it was noticed by the A.O., that the documented consideration was Rs. 5....
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....essee has a valid point that price which is smaller and strategically located plot would fetch more compared with bigger plot at the interior and the observation that all plots in the area would fetch similar price is illogical and unconvincing and same is evident from two purchases made by the assessee for the assessment year 2008-2009 itself. Apart from the documents seized for assessment year 2008-2009, no incriminating documents have been seized against the assessee with regard to the purchase made in assessment years 2006-2007 and 2007-2008. As mentioned earlier, the A.O. ought to have been referred the matter to the Valuation Officer to determine the actual market value of the property as provided u/s 142A of the Income-tax Act. The A.O. has also not mentioned the circle rate notified by the Revenue Authorities for the purpose of determining the market value of the said property. It is a generally acceptable principle that when a property is registered with the registering authority, the valuation cannot be challenged unless something incriminating is found by the Department. In the instant case, there is no incriminating documents found by the Department relating to assessme....
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....d was Rs. 18,00,000/- in place of Rs. 1,70,000/- and Rs. 44,48,000/- in place of Rs. 6,00,000 as per documents. In his statement the appellant had admitted that the amounts have been paid as per documents seized. The AO has inferred that since "these properties in the same locality and in the same Village and as they are of similar nature and contiguous all the properties would have fetched almost the same value during the transaction". Hence the AO inferred that the difference has been paid for the properties from the sources undisclosed to the Department and worked-out that since an amount of Rs. 18,00,000/- has been paid for a plot measuring 3.312 cents, the rate per cent is Rs. 540345 and for the plot measuring 11.61 cents the rate comes to Rs. 383118. Hence taking an average of Rs. 418710, the AO worked-out the difference at Rs. 100011 and Rs. 8055826 as difference for the bigger plot, hence for the plots purchased at Kollam the total extra money paid was worked-out at Rs. 8155837 which has been added to the returned income of the appellant . 18.1. Similarly, the AO also estimated the payment of on money in respect of properties purchased at Kottayam from one Shri T K Josep....
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....ion of the property the appellant submits he has to pay lot of compensation but for the serious financial hardship he could not pay and therefore possessing was not taken by him for a very long time. He submits that ''Adverse possession and tenancy rights were the criteria which determined the price when the property at TB Road, Kottayam was purchased. " 20. On a careful consideration of the facts it has been observed that even the AO who has estimated the value of Kottayam property @200% of the agreement value comparing it with that of property purchased by Hotel Anjali Park has also mentioned in Para 6(d) in agreeing with the appellant that a part of the property is still in the hands of the tenants and the assessee have to pay money for evicting some of the occupants. He adds that "also no direct evidence for payment of extra money has been seized by the Department." However, still he has not accepted the contention of the appellant and comparing it and comparing it with the property purchased by Hotel Anjali Park has taken the valuation @200% of the declared cost. While doing so he has not commented upon as to the point raised by the appellant that the property purch....
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....se, potential and all other characteristics." In Para 5.2.1.3 of this guidelines under the chapter Method of Valuation' it has been circulated that "Two properties cannot be identical. They may not posses similar advantage and disadvantage. All such factors of adjustment I influence affecting land rates are to be considered" and the main factors are (a) Location and situation (b) Size, (c) Side open, (d) Encumbrance, etc. Under the head 'Size' it has been written that "in general large plots fetch less unit price due to less number of buyers..... Sometimes it is not possible to have sale instances of larger size of plots and the sale instances available are of smaller size developed plots. In such a situation the price of small developed plot cannot be directly applied. " Similarly for 'Side open' it has been directed that the plots having more sides open fetch more rate. Similarly due and adequate importance should also be given for shape, encumbrance, etc. Unfortunately the AO has not applied any of the factors while determining the extra money payments for which additions have been made. 25. The valuation has been made by the AO himself instead of referring th....
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.... the assessee. This ground of appeal of the Revenue is dismissed for both the assessment years. ITA No. 322/Coch/2016 23. This appeal filed by the Revenue is directed against the common order of the CIT(A)-IV, Kochi dated 31/03/2016 for the assessment years 2006-07. 23.1 The main ground of the Revenue is with regard to deletion of addition of Rs. 1,42,86,087/- on account of unaccounted sales. 23.2 The facts of the case are similar to that considered by us in ITA No. 372/Coch/2016. 23.3 On appeal, the CIT(A) observed that his predecessor had already discussed the issue on facts as well as on the judicial pronouncements on identical facts and had held that additions made on this count are not justified and accordingly cannot be sustained. The CIT(A) did not find anything new brought out by the AO during the assessment proceedings which deserved to be analysed over and above what had been discussed and analysed by his predecessor. Accordingly, the addition made by the AO was held to be not sustainable and hence were deleted for 2006-07. 23.4 Against this, the Revenue is in appeal before us. The Ld. DR submitted that the evidences unearthed during the search u/s. 132 hold g....