TaxTMI 
TaxTMI 
2019 (10) TMI 438
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.... of order passed by A.O. by C1T(A) is erroneous and bad in law. 3. That the A.O. is not justifying in disallowing the sundry debtors of Rs. 8,58,44,005/- and added in the total income of the assessee and confirmation of the order passed by A.O. by Ld. CIT(A) s erroneous and bad in law. 4. That the total assessment made by Ld. A.O. of Rs. 25,94,15,964/- is arbitrary, unjust and illegal on the various legal facts and circumstances and action of Ld. A.O. cannot be said justified and he has not reject the books of account, which was duly audited as required U/s 44AB. Ld. CIT(A) ignored the fact that trading result are accepted by the trade tax authority and Police authority however, he took action against Radhey Shyam Mittal therefore, the assessment framed by Ld. A.O. and confirmed by CIT(A) is erroneous and against the facts and law. 5. That without prejudice to ground no. 1, 2, 3 & 4 the assessment completed u/s 143(3) for the A.Y. 2009-10 on the similar facts and circumstances @ 1% so called bogus receipt of Sh. Radhey Shyam Mittal. AO assessed income @ 1% and Ld. CIT(A) totally ignored this fact hence order passed by Ld. CIT(A) without considering the as....
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..... The Assessing Officer was convinced that the credit entries appearing in the name of Mittal Paper Mart amounting to Rs. 1,73,12,52,389/- is bogus and, accordingly, made addition of Rs. 17.31 crores as unexplained credit. 9. While making the addition, the Assessing Officer drew support from: 10. Proceeding further, the Assessing Officer noticed that the assessee has shown total sundry debtors of Rs. 17,41,65,793/-. Notices u/s 133(6) were issued to the debtors and the status of the notices is as under: 1. M/s Arshia Enterprises. 514, Kamla nagar, Meeru Rs. 7,91,545 Not known 6.5.10 2. M/s Gyan Industries T.P. Nagar, Meerut Rs. 70,000 Not known 6.5.10 3. M/s Shree Adinath Enterprises Mahaveer Ji Nagar, Baghpat Road, Meerut Rs. 2,65,000 5.5.10 4. M/s AARU Enterprises Bhopa Road, Muzaflar Nagar Rs. 28,54,908 5.5.10 5. M/s Adinath Enterpeises 16, Dwarikapuri, MZF Rs. 5,84,900 5.5.10 6. M/s S.S. Marketing Nandan Garden W.K. Road, Meerut Rs. 73,02.781 5.5.10 7. M/s Gokul Enterprises 160/51 Mark Ganj, Lucknow Rs. 6,95,87,579 5.5.10 8. M/s Sincere Marketing Co. Sect. 8, Noida Rs. 5,55,580 5 ....
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....ed to Sh. Puneet Jain on 19.03.2010 requiring to furnish cash book, ledger and all the bills and vouchers/copy of bank account in this office on 25.03.2010. No compliance was made of this summon and again summon u/s 131 was issued and served upon Sh. Puneet Jain to furnish all the details as asked in earlier summons. But the assessee did not comply to these summons also. However, During the course of hearing, in response to summons u/s 131, the sundry creditor Sh. Radhy Shyam Mittal Prop. M/s Mittal Paper Mart attended on along with his son Sh. Rajnish Mittal and got his statement on oath recorded. Statement on oath and affidavit of Sh. Radhey Shyam Mittal is part of assessment order. On the basis of statement given, the Assessing Officer treated the sundry creditor of Rs. 17,31,25,389/- as bogus. The Trade Tax Department and Police Department have confirmed that the purchases made by Shri Radhey Shyam Mittal M/s Mittal Paper Mart from M/s Saifali Paper Mart were bogus as the said company had closed and stopped manufacturing and from 1999-2000 is not manufacturing, purchasing and sales, which stands confirmed also by Trade Tax Authorities. As the addition was made....
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.... for carrying the goods. He was again required to produce the sale bills in original and evidence of transportation of the goods from his premises to the parties to whom goods were sold. He was again reminded that you and your father have not attended in person for examination. He was also informed that in the month of December on 21.12.2007, you have purchased goods 42 times in a day, on 24.12.2007- 22 times, on 25.12.2007- 44 times, on 26.12.2007- 42 times, on 27.12.2007 -13 times, on 28.12.2007 - 15 times and on 29.12.2007- 14 times and after that no purchases were made. He was required to furnish the name and complete addresses of the parties to whom corresponding sales were made by him on these dates. The counsel of the assessee vide letter dated 09.12.2011 received in this office on 16.12.2011 stated that Punit Jain was seriously injured in an accident between car and tractor-trolly on 02.12.2011 at Nawab Ganj Disttl. Gaunda, Faizabad and he has multiple fractures in his both arms and have an injury in his head. He is on complete rest. So he is unable to attend the office. As regards the purchases made from M/s Mittal Paper Mart, the counsel stated that the purchases were mad....
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....s given to Hand Writing Expert. Sh. Sanjeev Tomar, 77-Old Prempuri, Railway Road, Meerut who confirmed that these cheques have been written in the handwriting of Shri Praveen Kumar Jain. A copy of hand writing expert's report is being enclosed herewith. The handwriting of Shri Praveen Kumar Jain, father of the assessee on the available 54 bearer cheques of Shri Radhey Shyam Mittal from which the cash withdrawals were made, confirms the statement of Shri Radhey Shyam Mittal bank account was got opened and introduced by the assessee and cash withdrawals from his bank account were made by Sh. Puneet Jain and his father Shri Praveen Kumar Jain. Handwriting of Shri Puneet Jain could not be verified as he has not been produced for examination. The handwriting on the sale bills of M/s Mittal Paper Mart issued to M/s Paras Paper Centre could not be verified in absence of the examination of Shri Praveen Kumar, Prop. M/s Paras Paper Centre. Further, as regards addition of Rs. 8,58,55,005/- on account of unexplained debtors, vide letter dated 08.11.2011, the assessee was required as under: "In the written submission before the CIT(Appeals) you have taken a ground th....
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....her debited the account of M/s Mittal Paper Mart by Rs. 15,87,579/- and credited the account of M/s Gokul Enterprises by transfer entries. In support of its contention, in the paper book filed by Sh. Puneet Jain Prop. M/s Paras Paper Centre has taken the following grounds: a) The he is registered under both UP. VAT Act as well as Central Sales Tax Act and M/s Mittal Paper Mart is duly registered under UPTT-MF0055531 dated 01.10.2005 CST No. MF 5044141 dated 28.10.2006 from whom he has made purchases of Rs. 41,76,22,254/- b) That because of the reason that FIR was made by Commercial Tax Department, the assessee suffered shock and mental agony and he was unable to give any reply to the notices, issued by the A.O. c) That the statement of Sh. Radhey Shyam Mittal and affidavit is contradictory to the fact that the return filed by him after auditing his books of accounts by a C.A. voluntary and if any wrong committed by Radhey Shyam Mittal then he should be punished if his statement is found true but assessee cannot be penalized until the assessee cross examine the witness. d) That the assessee was not allowed sufficient opportunity even the ....
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....d with rejection of books of accounts as the creditor was not found genuine. Since, the creditor had not shown debit balance of the assessee in its books of account, the credit balance remained unverifiable and the A.O. made the addition accordingly. The assessee has challenged the service of notice under section 143(2) which was made on the mother of the assessee as the assessee in the records had given his residential address. But, since the assessee had complied the said notice, it cannot be challenged at this stage and the service of this notice is held to be proper service. In view of the above facts and circumstances, it is proved that fake/bogus purchases and sales through fake bills were made by M/s Mittal Paper Mart and M/s Paras Paper centre in connivance with each other through the firm M/s Mittal Paper Mart. In view of my above comments, the appeal proceedings may kindly be decided on merits." 14. After considering the facts and remand report of the Assessing Officer, the ld. CIT(A) confirmed the additions made by the Assessing Officer. 15. Before us, the ld. counsel for the assessee reiterated what has been stated before the lower authorities. I....
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....mination, the ld. DR stated that technical rules of evidence do not apply to the Income tax proceedings and Income tax authorities are not bound by technical rules of evidence though the general principles of Evidence Act do apply. 21. The ld. DR referred to various judicial decisions in support of her submissions in her written submissions and for the sake of convenience, the same is extracted hereunder: "Hon'ble Supreme Court in the case of Indian & Eastern Newspaper Society v. CIT 119 ITR 996 has held that the proceedings for assessment before the Assessing Officer have been described as quasi-judicial in character. The Hon'ble Supreme Court in S.S. Gadgil v. Lal & Co. 53 ITR 231 has held that a proceeding for assessment is not a suit for adjudication of a civil dispute. That an income-tax proceeding is in the nature of a judicial proceeding between contesting parties, is a matter which is not capable of even a plausible argument. The income-tax authorities who have power to assess and recover tax are not acting as judges deciding a litigation between the citizen and the State: they are administrative authorities whose proceedings are regulated by statute, b....
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....tained therein. The Hon'ble Supreme Court in the case of Chuharmal v. CIT [1988] 172 ITR 250 has held that What is meant by saying that the Evidence Act does not apply to proceedings under the Income-tax Act is that the rigor of the rules of evidence contained in the Evidence Act are not applicable, but that does not mean that when the taxing authorities are desirous of invoking the principles of the Act in proceedings before them, they are prevented from doing so. All that is required is that if they want to use any material collected by them which is adverse to the assessee, then the assessee must be given a chance to make his submissions thereon. The principles of natural justice are violated if an adverse order is made on an assessee on the basis of the material not brought to his notice. Surrounding circumstances must be considered while scrutinizing the documents - as Hon'ble Supreme Court has said in the case of Durga Prasad and that the taxing authorities are not required to put on blinkers while looking at the documents produced before them. They are entitled to look into the surrounding circumstances to find out the reality of the recitals made ....
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....lities of the assessees to payment of income-tax. Under section 142(2), the ITO may make such enquiry as he considers necessary for the purpose of obtaining full information in respect of the income or loss of an assessee. Under section 143(3), the ITO does not only hear such evidence as the assessee may produce or as he may require to be produced, but also takes into consideration "all relevant material which he has gathered" for the purpose of making an assessment. While the word "evidence" may recall the oral and documentary evidence as may be admissible under the Indian Evidence Act, the use of the word "material" shows that the ITO not being a court can rely upon material which may not be strictly evidence admissible under the Indian Evidence Act for the purpose of making an order of assessment. The courts often take judicial notice of certain facts which need not be proved, while administrative and quasi-judicial authorities can take "official notice" of wider varieties of facts which need not be proved before them. Thus, not only in respect of the relevancy but also in respect of proof the material which can be taken into consideration by the ITO and other authorities under ....
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....re it, in all events, the correct perspective of things and what is helpful or valuable in that direction is 'evidence' in the larger context or in the generic sense. As is well known, strict rules of evidence, as are known to the Indian Evidence Act, are not applicable to income-tax proceedings and thus the word 'evidence' in the income-tax proceedings has to be understood in the generic sense. In the case of Nokia India (P.) Ltd. v. DDIT 59 taxmann.com 212 Hon'ble ITAT DELHI BENCH has relied upon the decision of Hon'ble Calcutta High Court in the case of Kisanlal Agarwalla v. Collector of Land Customs AIR 1967 & Cal. 80 where the Hon'ble Court has held the following in para 28 - "28. There is a good deal of misconception on this question of the right of cross- examination as part of natural justice Natural justice is fast becoming the most unnatural and artificial justice and for that confusion the Courts are no less responsible than the litigants. Ordinarily the principle of natural justice is that no man shall be a judge in his own cause and that no man should be condemned unheard. This latter doctrine is known as audi alteram parlem. It is on ....
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.... cross-examine the witness who made adverse report is not an invariable attribute of the requirement of the said dictum. The principles of natural justice do not require formal cross- examination. Formal cross-examination is a part of procedural justice. It is governed by the rules of evidence, and is the creation of Court. It is part of legal and statutory justice, and not a part of natural justice, therefore, it cannot be laid down as a general proposition of law that the revenue could not rely on any evidence which had not been subjected to cross39 examination. However, if a witness has given directly incriminating statement and the addition in the assessment is based solely or mainly on such statement, in that eventuality it is incumbent on the Assessing Officer to allow crossexamination. Adverse evidence and material, relied upon in the order, to reach the finality, should be disclosed to the assessee. But this rule is not applicable where the material or evidence used is of collateral nature. " In the case of Smt. Kusum Lata Thakral v. CIT 150 ITR 714 Hon'ble Punjab & Haryana High Court has held that it was clear from the findings recorded by the Tribunal that there ....
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....w that any evidence upon which the department might rely should have been subjected to cross examination. The procedure for assessment is indicated in section 23(3) of the Act. The ITO is not a Court. Having regard to the nature of the proceedings, he occupies the position of a quasi-judicial Tribunal. He is not bound by the rules of evidence in the Indian Evidence Act. The limit of the enquiry and the kind of materials or evidence which he can act upon cannot be specified and the statute has not attempted it. Wide though his powers be, he must act in consonance with rules of natural justice. One such rule is that he shall not use any material against the assessee without giving him an opportunity to meet it. In the case of ITO v. M. Pirai Choodi 334 ITR 261 Hon'ble Supreme Court of India has held that in this case, the High Court has set aside the order of assessment on the ground that no opportunity to cross-examine was granted, as sought by the assessee. We are of the view that the High Court should not have set aside the entire assessment order. At the highest, the High Court should have directed the Assessing Officer to grant an opportunity to the assessee to crossexa....
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....rtment on the basis of which it could justify its action, as the statement of the aforesaid two witnesses who were unknown to the appellant was the only basis of issuing the Show Cause Notice. Hence, this judgment will not apply where there is sufficient material on record of the Revenue against the appellant apart from the statement of the witnesses. Further this case will also not apply where the appellant is asking to cross examine its/his own witnesses who are known to them and not regarded as third party as under rule of evidence the right to cross examine is given for the witness of the opposite party. For example, if the assessee makes a claim of purchase/investment/transaction in the return of income and filed the necessary details of the parties in support of the claim as witness and if the Revenue has collected the material to rebut such claim which may be in the form of the statement recorded, the appellant has to discharge the onus which was casted upon him and in such condition cannot take the plea of cross examination of his own witnesses unless he claims / proves in the proceedings that the witnesses on which he relied upon turned hostile. Fur....
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.... the price which is mentioned in the price list itself could be the subject matter of cross-examination. Therefore, it was not for the Adjudicating Authority to presuppose as to what could be the subject matter of the cross-examination and make the remarks as mentioned above. We may also point out that on an earlier occasion when the matter came before this Court in Civil Appeal No. 2216 of 2000, order dated 17.03.2005 was passed remitting the case back to the Tribunal with the directions to decide the appeal on merits giving its reasons for accepting or rejecting the submissions. We are of the opinion that if the testimony of these two witnesses is discredited, there was no material with the Department on the basis of which it could justify its action, as the statement of the aforesaid two witnesses was the only basis of issuing the Show Cause Notice. " 22. Replying to the written submissions of the ld. DR, the ld. counsel for the assessee in his rejoinder has stated as under: "Summons u/s 131 of the Act were not served on Sri R.S. Mittal. This is acknowledged by the Assessing Officer in the assessment order itself; 2. Suddenly Sri R.S. Miftal is stated to hav....
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....lating the dictum are - 8. a) C. Vasant Lai & Co., Vs. CIT (1962) 45 ITR 206 (SC) b) Kishan Chand Cheiia Ram vs. CIT (1980) 125 ITR 713 (SC) c) Chuharmal vs. CIT (1988) 172 ITR 250 d) CIT vs. SMC Share Brokers Ltd. (2007) 288 ITR 345 e) CIT vs. Sunil Aggarwai (2015) 379 ITR 367 (Del) f) CIT vs. Ansal Properties & Industries (order annexed) g) CIT vs. Trans Asia Securities Pvt. Ltd. (order annexed) h) CIT vs. Andaman Timber Inds Ltd. (2015) 281 CTR 241 (SC) Relevant portions in the cited judgement are highlighted and submitted. 9. The Ld. CIT(DR) submitted that Sri R.S. Mittal was not the department's witness and that, therefore, Department was not under any obligation to produce him for the Appellant for cross examining him. This averment is blatantly wrong. It is the statement of Sri R.S. Mittal and his affidavit which have been relied upon entirely by the Assessing Officer to propose the addition in the Appellant's case. Having relied upon such material which emanated from Sri R.S. Mittal and utilized as evidence against the Appellant by the Department, it cannot now be pleaded by the De....
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.... the later observations contextually different in CIT vs. Durga Prasad More (1971) 82 ITR 540 (SC), Sumati Dayal vs. CIT (1995) 214 ITR 801 (SC), Me Dowell & Co. Ltd (1985) 154 ITR 148 (SC). In the given case the Assessing Officer has himself identified the party. All payments were admittedly through account payee cheques. There is no evidence of any abstraction or repayment of those in cheques, in cash or otherwise by the assessee. In such circumstances the invocation of Section 68 of the Act is ab initio fallacious and untenable. None of the cases as cited by the Ld. CIT(DR) are relevant to the issue in hand. In particular Para of the judgement and order of the Delhi High Court in Nova Promoters (2012) 342 ITR 169 (Del) case is of cardinal importance and only goes to endorse the assessee's plea regarding shifting or onus u/s 68 of the Act. 13. On the aspect of natural justice and cross examination cases cited as Nokia India Pvt. Ltd. vs. DDIT (2015) 59 Taxman.com 212 (Delhi.Trib), CIT vs. Kuber Fibers Pvt. Ltd. (2017) 77 Taxman.com 345 (Delhi) and GTC Industries Ltd. vs. ACIT (1998) 65 ITD 380 (Bom) are all decided on the basis of the facts appertaining to those cases. E....
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....al in character. All proceedings, whether judicial or quasi-judicial are to be based on evidence. Being so the cited authority only endorses the Appellant's contention for the order to be oocceci QKV MCATA. cisxck . 14.3 S. S. Gadqil Vs. Lai & Co. (19641 53 ITR 231 (SC): As stated by the apex court in the cited judgement, the assessment proceedings are not in the nature of a les between the parties; yet they are in the nature of judicial proceedings. Being judicial proceedings any finding or inference is essentially to be based on cogent evidence. The contest in the case at hand of the Appellant is that the evidence as used in assessment is untested and unverified. The cited judgement fortifies the assessee's stance. That principles of natural justice are contravened if evidence used by the Assessing Officer is not confronted to the assessee for rebuttal. This citation as pressed by the Id. CIT(DR) only goes to fortify assessee's submissions. 14.4 Dhakeswari Cotton Mills Ltd. Vs. Vs. CIT (1954) 26 ITR 775 (SC): This decision as cited by the Id. CIT(DR) is clearly in favour of the assessee's contention that the evidence as utilized in assessme....
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....ng Works Ltd. (1978) 113 ITR 389 (Del.): This judgement is mitigative in character, in as much as, in a case where the books of accounts by the assessee had been destroyed by fire the Assessing Officer was directed to compute the income in terms of the audited account and audit report. In the cited case, the court attempted to define what is 'material'? This citation, therefore, cannot be an authority for the proposition erroneously advanced by the Id. CIT(DR) that the cross examination of Shri R. K. Mittal was in-essential in the facts and circumstances of the case in appeal. 14.9 Hersh Win Chadha vs. DCIT (2011) 135 TTJ 513: (sic) GTC Industries Ltd. Vs. ACIT (1998) 65 ITD 380: & Nokia India (P.) Ltd. Vs. DDIT 59 taxmann.com 212: The principle of law as propounded by the Hon'ble High Courts and the apex court have been adopted by the Hon'ble Tribunal in the cited orders. Being so, they do not require any separate comment. 15.1 CIT Vs. Metal Products of India (1984) 150 ITR 714 (P &H): The High Court has only gone by the principle. The Id. CIT(DR) has missed to notice and quote the more relevant part of the judgeme....
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....l.): In this case what the court has advised is that cross-examination should be sought at an appropriate time and not belatedly. Obviously the ratio is based on its own facts and would have no relevance or application to the Appellant's case at hand where the crossexamination was sought at an appropriate time. 15.5 T. Deasahaya Nadar Vs. CIT 51 ITR 20 (Mad.): After the later decisions of the apex court as cited supra (Chuharmal Vs. CIT) this old decision of the Madras High Court loses its significance and authority. 16. ITO Vs. M. Pirai Choodi (2011) 334 ITR 261 (SC): The correct citation is 334 ITR 262. This order emanates out of a writ filed before the High Court against the assessment order. It is in that context that the quoted advise has been tendered by the apex court to the High Court. It is a well established principle of law that a decision in a writ does not create a precedent. Dr. Gauri Shankar Prasad Vs. iTQ f2017) 393 ITR 635 (Pat.): In the cited case request for cross-examine was never expressed by the litigant. In the subject case cross-examination has been sought at the first available opportunity durin....
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....nate benches would not apply on the plethora of facts considered in the year under consideration which remain unrebutted by the assessee. 26. The statement of Shri Radhey Shyam Mittal has been exhibited elsewhere. A perusal of the same reveals that the bank account of M/s Mittal Paper Mart was, in fact, operated by Shri Puneet Jain. Shri Radhey Shyam Mittal has categorically stated that it was Shri Puneet Jain who was depositing the money in the account of Mittal Paper Mart and was withdrawing the money from the same account as the cheque book of Shri Radhey Shyam Mittal was already with him or with Shri Praveen Kumar Jain, father of Shri Puneet Jain, bearing the signatures of Shri Radhey Shyam Mittal. 27. Another glaring fact coming out of the statement of Shri Radhey Shyam Mittal is that even the pay-in slips of the bank were prepared by Shri Puneet Jain or Shri Praveen Kumar Jain. 28. The Bank Manager, where Mittal Paper Mart had its bank account, was summoned by the Assessing Officer alongwith the pay in slips prepared by Shri Puneet Jain/Shri Praveen Kumar Jain. Those pay in slips were referred to a forensic expert, report is exhibited at pages 58 to 63 of the p....
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.... in the name of Mittal Paper Mart P/o Shri Radhey Shyam Mittal amounting to Rs. 17,31,25,389/- is unexplained credit which is supported by evidences on record. On this count, reliance placed on the decision of the Hon'ble High Court of Calcutta in the case of Shankar Industries 114 ITR 689 is misplaced in as much as the assessee has failed to establish the genuineness of the transaction. Merely because the transactions have been done by account payee cheques would not suffice when the forensic expert's report clearly proves that the account was operated in the handwriting of Shri Puneet Jain, and all deposits and withdrawals were made in the handwriting of Shri Puneet Jain. 33. Reliance placed on the decision of the Hon'ble Supreme Court in the case of Andaman Timber Industries [supra] is clearly distinguishable on facts as it cannot be stated that no opportunity of cross examination was given. From the assessment order itself, it can be seen that several notices were served upon the assessee during the assessment proceedings itself but the assessee chose not to respond and capture the opportunity to cross examine Shri Radhey Shyam Mittal. 34. Moreover, the stat....
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....ind any merit in this addition of debit entry and the same is directed to be deleted. 39. In the result, the appeal of the assessee in ITA No. 1569/DEL/2013 is partly allowed The order is pronounced in the open court on 27.09.2019. ============= Document 1 उचित न मानते हà¥à¤¯à¥‡ उपरोकà¥à¤¤ संडà¥à¤°à¥€ कà¥à¤°à¥‡à¤¡à¤¿à¤Ÿà¤°à¥à¤¸ मै० मितà¥à¤¤à¤² पेपर मारà¥à¤Ÿ के पà¥à¤°à¥‹à¥¦ शà¥à¤°à¥€ राधेशà¥à¤¯à¤¾à¤® मितà¥à¤¤à¤² को इस कारà¥à¤¯à¤¾à¤²à¤¯ से दिनांक 08-03-2010 को धारा 131 का समà¥à¤®à¤¨ जारी करते हà¥à¤¯à¥‡ दिनांक 15-03-2010 को निरà¥à....
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....•à¥‡à¤¸ की सà¥à¤¨à¤µà¤¾à¤ˆ के दौरान करदाता के संडà¥à¤°à¥€ कà¥à¤°à¥‡à¤¡à¤¿à¤Ÿà¤°à¥à¤¸ शà¥à¤°à¥€ राधेशà¥à¤¯à¤¾à¤® मितà¥à¤¤à¤² पà¥à¤°à¥‹à¥¦ मै० मितà¥à¤¤à¤² पेपर मारà¥à¤Ÿ दिनांक 16-04-2010 को अपने पà¥à¤¤à¥à¤° शà¥à¤°à¥€ रजनीश मितà¥à¤¤à¤² के साथ इस कारà¥à¤¯à¤¾à¤²à¤¯ में उपसà¥à¤¥à¤¿à¤¤ हà¥à¤¯à¥‡ । तथा साथ ही उनà¥à¤¹à¥‹à¤¨à¥‡ मै० पारस पेपर सैनà¥à¤Ÿà¤° पà¥à¤°à¥‹à¥¦ à¤....
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....पनी आय का सà¥à¤°à¥‹à¤¤ à¤à¥€ बतायें। उतà¥à¤¤à¤° शà¥à¤°à¥€ मानजी मै नि0 वरà¥à¤· 1997-98 तक अपनी आयकर विवरणी मेरठआयकर कारà¥à¤¯à¤¾à¤²à¤¯ में दाखिल करता था। उसके उपरानà¥à¤¤ मेरे पास कोई रोजगार नही था । इसलिये मैने बीच में अपनी कोई आयकर विवरणी दाखिल नही की। उसके उपरानà¥à¤¤ à¤....
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....ने कहा वही हà¥à¤†à¥¤ फरà¥à¤® का पà¥à¤°à¤¯à¥‹à¤— खाली बिल काटने के लिये किया गया। उपरोकà¥à¤¤ बà¥à¤¯à¤¾à¤¨ के समà¥à¤¬à¤¨à¥à¤§ में शà¥à¤°à¥€ राधेशà¥à¤¯à¤¾à¤® पà¥à¤°à¥‹à¥¦ मै० मितà¥à¤¤à¤² पेपर मारà¥à¤Ÿ 59 आरà¥à¤¯ नगर à¤à¤¸à¥¦ के० रोड मेरठसे मै० पारस पेपर सैनà¥à¤Ÿà¤° के संडà¥à¤°à¥€ कà¥à¤°à¥‡à¤¡à¤¿à¤Ÿà¤°à¥à¤¸ रूपया 17,31,25,389 के समà¥à¤¬à¤¨à¥à¤§....
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....स कारà¥à¤¯à¤¾à¤²à¤¯ में दिये गये बयान व दिये गये शपथ पतà¥à¤° के समà¥à¤¬à¤¨à¥à¤§ में करदाता को इस कारà¥à¤¯à¤¾à¤²à¤¯ से दिनांक 19. 03.2010, 08.04.2010, 24.05.2010 व दिनांक 31.05.2010 को धारा 131(1)/142(1) का नोटिस जारी करते हà¥à¤¯à¥‡ उकà¥à¤¤ समà¥à¤¬à¤¨à¥à¤§ में अपना पकà¥à¤· व साकà¥à¤·à¥à¤¯ दिनांक 25.03.2010, 14.04.2010, 28.05.2010 व दिनांक 03.06.2010 को करने हेतू दिनà....
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....रा जाना । करदाता के संडà¥à¤°à¥€ कà¥à¤°à¥‡à¤¡à¤¿à¤Ÿà¤°à¥à¤¸ शà¥à¤°à¥€ राधेशà¥à¤¯à¤¾à¤® मितà¥à¤¤à¤² पà¥à¤°à¥‹à¥¦ मै० मितà¥à¤¤à¤² पेपर मारà¥à¤Ÿ दà¥à¤µà¤¾à¤°à¤¾ अपनी आयकर कारà¥à¤¯à¤¾à¤²à¤¯ वारà¥à¤¡ 2 (2) मेरठमें दिनांक 30-09-2008 आर० आर० नं० 1502008194 निरà¥à¤§à¤¾à¤°à¤£ वरà¥à¤· 2008-09 की दाखिल अपनी आयकर विवरणी में उकà¥à¤¤ संडà¥à¤°à¥€ डेटरà¥à¤¸ / कà¥à¤°à¥‡....