TaxTMI 
TaxTMI 
2020 (9) TMI 915
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....on 145(3) of the I.T. Act, 1961 and in further sustaining addition of Rs. 10.00 lacs in the hands of the assessee on this count. 2. That on the facts and in the circumstances of the case, the ld. CIT(A) is wrong, unjust and has erred in law in upholding finding recorded by the AO that the assessee has allegedly made investment of capital for alleged unrecorded transactions of Rs. 91,53,55,592/- and in fu9rther sustaining addition to the extent of Rs. 15,74,496/- on this count which was worked out on the basis of proportion of actual capital of Rs. 34,96,965/- for declared turnover of Rs. 203,30,09,914/-. ITA No.1257/JP/2019 - A.Y. 2016-17- Assessee ''1. That on the facts and in the circumstances of the case, the ld. CIT(A) is wrong, unjust and has erred in law in upholding rejection of books of account of the assessee by the AO by invoking the provisions of Section 145(3) of the I.T. Act, 1961 and in further sustaining addition of Rs. 10.00 lacs in the hands of the assessee on this count. 2. That on the facts and in the circumstances of the case, the ld. CIT(A) is further wrong and has erred in law in holding that loss of Rs. 17,45,527/- suffered....
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.... was right in deleting the addition of Rs. 1,58,31,290/- made by the AO on account of undisclosed transaction recorded in the seized documents (software in the name of Johari Hajir) on the basis of assessee himself admitted that the transaction recorded in this software are unaccounted transactions but this fact was ignored by the ld. CIT(A). 2. Whether on the facts and in the circumstances of the case & in law the ld. CIT(A) was right in deleting the addition of Rs. 10.00 lacs made by the AO on account of undisclosed profit from unaccounted transactions with detected during the search. 3. Whether on the facts and in the circumstances of the case & in law the ld. CIT(A) was justified in allowing the appeal of the assessee holding that the addition related to MCX transactions was without any reason however the same were appearing in Johari Software but was not disclosed in regular books of accounts. 4. Whether on the facts and in the circumstances of the case & in law the ld. CIT(A) was right in deleting the addition of Rs. 2,57,00,000/- made by the AO on account of unexplained investment in purchase of gold.'' 2. The hearing of the appeals was conclude....
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....n of income. The A.O. issued notice u/s 143 (2) and 142 (1) of the Act which assessee also complied. The A.O. completed assessment u/s 153C r.w.s. 143 (3) at an income of Rs. 6,47,89,430/- making: (i) an addition of Rs. 5,69,79,862/- as unexplained investment as per discussion in para - 5 of assessment order and (ii) an addition of Rs. 59,17,397/- as unexplained expenditure as per discussion in para - 6 of assessment order. The assessee, thereafter moved an application u/s 154 to A.O. for rectification of apparent mistake(s) in assessment order passed by A.O. The A.O. accepted the application u/s 154 filed by assessee and vide rectification order 08-03-2019 determined total income at Rs. 3,08,47,230/- by reducing addition of Rs. 5,69,79,862/- to Rs. 2,30,37,862/- addition so made in assessment order. 6. The Ld CIT(A) partly allowed the appeal of assessee and deleted the following addition. (i) Addition of Rs. 2,20,37,862/- on account of alleged unrecorded transactions in Hazir software (ii) Addition of Rs. 43,42,901/- on account of alleged investment of capital The department is in appeal against the above said additions deleted by CI....
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.... not be applied for all sales for which complete details including quantitative details are available. In respect to transaction of purchase and sale recorded in regular books of accounts the return of income computing total income from accounts audited u/s 44AB was filed declaring an income of Rs. 18,42,170/-. The return was processed u/s 143 (1) and no notice u/s 143 (2) was received within allowed time. The present assessment has been completed u/s 143 (3) r.w.s. 153C. The A.O. found no defect or deficiency in books of accounts maintained and declared op. stock, purchases, sales & closing stock including quantitative details thereof have been accepted as such by the A.O. and, therefore declared gross profit was completely verifiable and the AO should have accepted as per law. The A.O. however accepted all the transaction of sales, purchases and stock for the period 24-11-2014 to 31-3-2015 as declared by the assessee and applied 1% G.P. rate on sale of said period while accepted the declared profit for remaining period of the year which is grossly incorrect in law. The accounts of the year have to be accepted as such for the whole year and, in law there cannot be that declared re....
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....bmissions made. I am of the view learned AO is not correct in apply in uniform GP rate of 1% to accounted and unaccounted sale. The portion of statement relied upon by the Ld. AO in is on page 9 same is reproduced below:- 9. The Ld. AO is directed to accept the books result of regular books of accounts which are duly audited and a returned income of Rs. 1892170 is filed. For the unaccounted transaction in silver and gold ('Hazir' software) the Ld. AR has filed a detailed P & L account. The same is reproduced by the Ld. AO onwards of the order. The Ld. A/R has taken a plea that the content of 'Hazir' software are to be taken as true and correct unless proven otherwise. Section 292C reads as under; ........ ......................................... 9.2 There is force in the argument of the Ld. A/R 'Hazir' software and its complete printout from the same have been filed and seen by me. These unaccounted transactions are very systematically written and a Profit & Loss Account out of these are filed by the Ld. A/R before the Ld. AO and me too. There is nothing on records to suggest that these accounts and gross profit eviden....
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....n MCX portal in said Hazir software as is evident from assessment order itself. The A.O. also accepted the purchases, sales, op. stock & closing stock resulted from the transactions recorded therein as such in 'Hazir' software without pointing out any defect or deficiency therein and so also in law even those accounts cannot be rejected by invoking section 145 (3). The A.O. while accepting all transaction in 'Hazir' software in toto is just not accepting the profit resulted from said details which is not correct in law and so cannot be a ground for invoking section 145 (3). In view of above facts of the case the A.O. is wrong and has erred in law in rejecting books of accounts of assessee by invoking section 145 (3) of the Act. In case of Paradise Holidays 325 ITR 13 it has been held that the accounts which are regularly maintained in the course of business and are duly audited, free from any qualification by the auditors, should normally be taken as correct unless there are adequate reasons to indicate that they are incorrect or unreliable. The Hon'ble Rajasthan High Court in the case of Malani Ramjivan Jagan Nath (2009) 316 ITR 120 (2007) 163 Taxman 731 has ....
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....ition of Rs. 10,00,000/- is purely based on surmises and conjectures and accordingly the Ld. CIT(A) is correctly deleted the same. 13. Ground No. 3 of the departmental appeal and ground No. 2 of the assessee's appeal are interlinked. In this regard, we observe that the assessing officer in the assessment order wrongly held that assessee has made investment of capital for alleged unrecorded transactions and in further working out such investment on the basis of actual investment for recorded turnover of the business. The assessing officer is thus wrong and has erred in law in working out total investment for business at Rs. 9414362/- on the basis of alleged total turnover of Rs. 5,47,31,72,177/- which is worked out by him in proportion to actual capital of Rs. 3496965/- for declared turnover of Rs. 2,03,30,09,914/-. The addition of Rs. 59,17,397/- made to the income of the assessee by the assessing officer as alleged unexplained expenditure/capital investment on this count is unwarranted and is without any material on record. The ld. CIT(A) has dealt with this issue in para 22 of his appeal order, which is as under: 22. I have perused the written submissions submitted by....
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....17 (Assessee & Revenue). With reference to the facts narrated above for the A.Y. 2016-17. The A.O. issued notice u/s 153C of the Act on 24-09-2018 (on the basis of documents seized from Shri Ram Kumar Soni) to assessee and in compliance thereto assessee filed return of income declaring income of Rs. 17,82,540/- as was declared in original return of income. The A.O. issued notice u/s 143 (2) and 142 (1) of the Act which assessee also complied. The A.O. completed assessment u/s 153C r.w.s. 143 (3) at an income of Rs. 11,27,44,750/- making: (i) an addition of Rs. 11,09,62,214/- as unexplained investment as per discussion in para - 5 of assessment order and The assessee, thereafter moved an application u/s 154 to A.O. for rectification of apparent mistake(s) in assessment order passed by A.O. The A.O. accepted the application u/s 154 filed by assessee and vide rectification order 08-03-2019 determined total income at Rs. 4,75,71,820/- by reducing certain additions so made in assessment order. 17. By the impugned order, the Ld CIT(A) partly allowed the appeal of assessee and deleted the following addition. (i) Addition of Rs. 2,76,61,034/- on account of ....
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....d time. The present assessment has been completed u/s 143 (3) r.w.s. 153C. The A.O. found no defect or deficiency in books of accounts maintained and declared op. stock, purchases, sales & closing stock including quantitative details thereof have been accepted as such by A.O. and, therefore declared gross profit was completely verifiable and the AO should have accepted as per law. The A.O. however taken the transaction of sales for the year and applied 1% G.P. rate on sale of the year. We observe that the assessment u/s 153C has to be completed in accordance with provisions of section 153A. It is now settled law that no addition in assessment u/s 153A/153C can be made unless there is some incriminating material therefor. In view of this also application of G.P. rate of 1% on sales transaction accounted in regular books of accounts for the year is not in accordance with law and declared results are to be accepted. In respect to transaction of purchase and sales not recorded in regular books of accounts but found in 'Hajir' Software, we observe that the record found in Hajir software is correct and complete. The complete details of all transactions alongwith quantitative detail....
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....e and correct unless proven otherwise. Section 292C reads as under; ........ ......................................... 9.2 There is force in the argument of the Ld. A/R 'Hazir' software and its complete printout from the same have been filed and seen by me. These unaccounted transactions are very systematically written and a Profit & Loss Account out of these are filed by the Ld. A/R before the Ld. AO and me too. There is nothing on records to suggest that these accounts and gross profit evident from it not to be accepted. 9.3 Accordingly, for this A.Y. following profits as computed and filed before the Ld. AO from 'Hazir' Software shall be added: 1. For silver trading (period 24-11-2014 to 31-03-2015) Rs. 562647 2. For gold trading (period 24-11-2014 to 31-3-2015) Rs. 1617752 The aforesaid two additions shall be made by the Ld. AO 9.4 Since the books of accounts are rejected I am of the view a nominal addition of Rs. 10 lacs is made in the income the appellant as a fair estimation of income as envisaged in the section 145 of the Act. " Accordingly, the Ld. CIT(A) deleted the addition of Rs. 2,76,61,03....
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....of assessee by invoking Sec. 145 (3) of the Act. 20. In view of the above facts and submissions made herein above the G.P. rate of 1% applied by the A.O. on the sales found recorded in 'Hajir' software is thus unwarranted and uncalled for. Further the ld. CIT(A) has sustained a lump sum addition of Rs. 10,00,000/- in the hands of assessee as against the addition of 2,30,37,862/- made by the Assessing officer. 21. In ground No. 2 of the appeal, the revenue has alleged ld. CIT(A)'s action in deleting addition of Rs. 10.00 lacs, which was made by the A.O. on account of profit from undisclosed transactions from MCX. In this regard, we observe that the AO in the assessment order made lump sum addition of Rs. 1000000/- to the income of the assessee on account of alleged profit on unaccounted transactions at MCX. That the profit from transaction with MCX is computable from record found in 'Hazir' software and assessee submitted before A.O. the resultant profit from MCX transaction being to (-) Rs. 9,52,665/- which A.O. verified the same and found it correct and accepted it and added the same in income of assessee assessed by A.O. Besides that, the A.O. further made a lump sum additi....
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....se (a), The income-tax payable shall be the aggregate of- (i) the amount of income-tax calculated on the income referred to in clause (a) and clause (b), at the rate of sixty per cent; and (ii) the amount of income-tax with which the assessee would have been chargeable had his total income been reduced by the amount of income referred to in clause (i). (2) Notwithstanding anything contained in this Act, no deduction in respect of any expenditure or allowance or set off of any loss shall be allowed to the assessee under any provision of this Act in computing his income referred to in clause (a) and clause (b) of sub-section (1). We observe that Section 115BBE (2) only bars (prior to 1-4-17 before its amendment made by Finance Act, 2016) that no deduction in respect of any expenditure or allowance shall be allowed to the assessee under any provision of this Act in computing his income referred to in clause (a) of Sub-Section (1) of Section 158BBE. However, the said section does not bar set off of loss in other head of income allowable under section 71 of I. T. Act from the income referred to in section 115BBE. It is from A.Y. 2017-18 by virtue o....
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....s wrong and has erred in law in not allowing the set off of net unaccounted loss from the accounted income of assessee. 25. In the result, appeal of the revenue is dismissed whereas appeal of the assessee is allowed. 26. Now we take appeals for the A.Y. 2017-18 (Assessee & Revenue) For the A.Y. 2017-18, the A.O. issued notice u/s 153C of the Act on 24-09-2018 (on the basis of documents seized from Shri Ram Kumar Soni) to assessee and in compliance thereto assessee filed return of income declaring income of Rs. 35,16,090/-. The A.O. issued notice u/s 143 (2) and 142 (1) of the Act which assessee also complied. The A.O. completed assessment u/s 153C r.w.s. 143(3) at an income of Rs. 6,41,70,460/- making: a) an addition of Rs. 3,02,00,000/- as unexplained investment as per discussion in para - 4 of assessment order and b) an addition of Rs. 3,04,54,368/- as undisclosed income/unexplained expenditure as per discussion in para - 5 of assessment order. The assessee, thereafter moved an application u/s 154 to A.O. for rectification of apparent mistake(s) in assessment order passed by A.O. The A.O. accepted the application u/s 154 filed by assessee and vide....
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....d an application of GP rate of 1% on short stock of Rs. 8347544 The text of statement can be seen on page 9 of the Ld. AO order. 8.2 I have closely perused the Ld. AO order and the submissions made. I am of the view learned AO is not correct in apply in uniform GP rate of 1% to accounted and unaccounted sale. The portion of statement relied upon by the Ld. AO in is on page 9 same is reproduced below:- 9. The Ld. AO is directed to accept the books result of regular books of accounts which are duly audited and a returned income of Rs. 1892170 is filed. For the unaccounted transaction in silver and gold ('Hazir' software) the Ld. AR has filed a detailed P & L account. The same is reproduced by the Ld. AO onwards of the order. The Ld. A/R has taken a plea that the content of 'Hazir' software are to be taken as true and correct unless proven otherwise. Section 292C reads as under; ........ ......................................... 9.2 There is force in the argument of the Ld. A/R 'Hazir' software and its complete printout from the same have been filed and seen by me. These unaccounted transactions are very systematically wri....
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....rchase & sale of 9 kg gold from Ram Kumar Soni and the said undisclosed income was declared by assessee in accordance with section 199C of Taxation Laws (Second Amendment) Act 2016 in PMGKY (Pradhan Mantri Garib Kalyan Yojna) in which assessee declared income of Rs. 1,05,50,000/-as per details thereof given in affidavit filed which includes said undisclosed income of Rs. 45,00,000/- also. The Pr. Commissioner of Income Tax also issued prescribed certificate in respect to declaration under PMGKY (copies of all documents submitted). In annexure AS, Exhibit - 12 i.e. cash book found and seized from Ram Kumar Soni, Sikar following transaction of receipt of amount in the name of Babu Lal Lawat i.e. assessee were found Date (Amount in Rs.) Narration Page No. of Ex-12 19.11.16 5500000 Sh. Babu Lal ji Lawat 221 22.11.16 12500000 Sh. Babu Lal ji Lawat 224 02.12.16 2000000 Sh. Babu Lal ji Lawat 236 03.12.16 1550000 Sh. Babu Lal ji Lawat 237 08.12.16 800000 Sh. Babu Lal ji Lawat 243 08.12.16 1400000 Sh. Babu Lal ji Lawat 243 11.12.16 800000 Sh. Babu Lal ji Lawat (7450/- लेना &#....
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....owever in this regard it is submitted that except a cash payment of Rs. 200000 on 02-12-2016 balance payment was made in instalments from the sale proceeds of the said gold sold. In this connection it is also submitted that the payment of Rs. 200000 on 02-12-2016 was also made from the advance amount against sales received from customers. D. In view of the above said facts, as evident and verifiable from the seized record itself that the total amount of transactions was Rs. 1,80,00,000 + 66,00,000 = 2,46,00,000/- and not Rs. 3,57,95,000/-. It appears that the working by the department has been done by adding debit and credit both the side of transactions in the account i.e. the purchase of gold of Rs. 1,80,00,000 and payment thereof of said amount has been considered/taken twice at Rs. 3,57,95,000/- i.e. aggregate amount of debit and credit of transactions with Mr. Ram Kumar Soni. It is further submitted as the cash payment transaction of (Rs. 55,00,000 + 1,25,00,000) = Rs. 1,80,00,000/- is verifiable from the impounded Johari Software and accordingly the source of payment of said amount is explained and as such no further addition by adding both the side i.e. Dr.....
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....Soni was for 7 kg gold for Rs. 2,47,95,000/-. As the assessee admitted purchase and sale of 9 kg gold for Rs. 3,02,00,000/- and also admitted the profit earned thereon amounting to Rs. 45,00,000/- and so same is not being disputed. 35. It is evident from entries found in cash book of Ram Kumar Soni and from statement recorded from assessee in course of survey that assessee purchased gold in period of demonetization which was obviously for sale to persons on receiving cash from them as the same is normal practice of gold trade. The gold purchased in period of demonetization was towards agreed sale to persons on receiving amount therefor from those persons. Thus the source of payment to Ram Kumar Soni for purchase of gold is out of amount received from its sales and so it is to be treated as properly explained. It is only profit on sale of said purchased gold which is income of assessee which was undisclosed income of assessee and the same could only be subjected to tax. It is settled law that in case of unaccounted sales only profit therefrom could only be taxed as income of assessee. The assessee relies on the judgement of ITAT, Ahmedabad Bench in case of DCIT Vs. Brijvasi Devel....
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.... of gold in period post demonetization. These transactions were for purchase/sale of 7 Kg gold. However appellant in his statement dated 24-12-2016 u/s 131 admitted sale/purchase of 9 kg gold for Rs. 3,02,20,000/- and stated that gold was purchased by him from Ram Kumar Soni and directly sold to people of nearest place(s) who themselves made direct payment to Ram Kumar Soni and he only earned profit on such transaction of sale of 9 kg gold which he admitted to be @ Rs. 5,00,000/- per kg total Rs. 45 Lakhs. This income was later on disclosed under the provisions of PMGKY Scheme, 2016. The Ld. AO in assessment order on the basis of statement of appellant that he purchased 9 kg gold for Rs. 3,02,00,000/- from Ram Kumar Soni which was sold by him took into consideration the amount of Rs. 3,02,00,000/-. The AO held that these transactions were through old demonetization currency which was barred transaction under demonetization scheme. The AO therefore required appellant to furnish details related to parties to whom gold was so sold and on failure of appellant to provide such details the AO made addition of Rs. 3,02,00,000/- in income of appellant u/s 68 r.w.s. 115BBE of the Ac....
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.... from total income as so the addition on this account is restricted to Rs. 45,00,000/- and balance is deleted. The appellant thus gets relief of Rs. 3,02,00,000-45,00,000 = Rs. 2,57,00,000/-." In view of the above facts and submissions made herein above the Ld. CIT(A) is correct in deleting the addition of Rs. 2,57,00,000/- made by the AO on account of alleged undisclosed investment in purchase of Gold. 37. In the result, all the appeals of the revenue are dismissed whereas all the appeals of the assessee are allowed. Order pronounced in the open court on 15/09/2020. ============= Document 1 पà¥à¤°. 63 आपके इस वà¥à¤¯à¤¾à¤µà¤¸à¤¿à¤• परिसर में कम पाये गये 83,47,544 /- रूपठउ. 8.3 के कम सà¥à¤Ÿà¥‰à¤• का कारण सà¥à¤ªà¤·à¥à¤Ÿ करने में आप असमरà¥à¤¥ रहे है, तो फà....
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....¸à¤¾à¤° कà¥à¤¯à¥‹à¤‚ नही इस unaccounted sale पर 1% का Gross Profit मारà¥à¤œà¤¿à¤¨ लगा कर कà¥à¤² 33,475 /- रूपठको आपकी अघोषित आय मान लिया जावे ?..." Document 2 पà¥à¤°. 63 आपके इस वà¥à¤¯à¤¾à¤µà¤¸à¤¿à¤• परिसर में कम पाये गये 83,47,544 /- रूपठके कम सà¥à¤Ÿà¥‰à¤• का कारण सà¥à¤ªà¤·à¥à¤Ÿ करने में आप असमरà¥à¤¥ रहे है, तो फिर कà¥à¤¯à¥‹à¤‚ नहीं यह माना जावे कि इस ....
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....¤®à¤¾à¤°à¥à¤œà¤¿à¤¨ लगा कर कà¥à¤² 33,475/- रूपठको आपकी अघोषित आय मान लिया जावे ?†Document 3 पà¥à¤°. 63 आपके इस वà¥à¤¯à¤¾à¤µà¤¸à¤¿à¤• परिसर में कम पाये गये 83,47,544 /- रूपठउ. 8.3 के कम सà¥à¤Ÿà¥‰à¤• का कारण सà¥à¤ªà¤·à¥à¤Ÿ करने में आप असमरà¥à¤¥ रहे है, तो फिर कà¥à¤¯à¥‹à¤‚ नहीं यह माना जावे कि इस 83,47,544 /- रूपठसà¥à¤Ÿà¥‰à¤• को आपने out of boo....
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....¤†à¤ªà¤•à¥€ अघोषित आय मान लिया जावे ?........†" The appellant agreed that on this short stock a GP rate of 1% can be applied. Document 4 पà¥à¤°. 69 अब जबकि आपने सà¥à¤µà¤¯à¤‚ ने यह सà¥à¤µà¥€à¤•à¤¾à¤° कर लिया है कि शà¥à¤°à¥€ रामकà¥à¤®à¤¾à¤° सोनी, सीकर को नगद à¤à¥à¤—तान करने के बारे में आपने à¤à¥‚ठे बयान दिये थे, तो कृपया अब आप सà¥à¤µà¤¯à¤‚ ही यह बताने का कषà¥à¤Ÿ करें कि à....
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....गवाया तथा यहां पर अनà¥à¤¯ पारà¥à¤Ÿà¤¿à¤¯à¥‹à¤‚ को मà¥à¤¨à¤¾à¤«à¥‡ के साथ बेच दिया । बाकी 6 Kg सोना मैंने शेखवाटी बेलà¥à¤Ÿ (सीकर, à¤à¥à¤à¥à¤¨à¥‚ व चूरू जिले) की पारà¥à¤Ÿà¤¿à¤¯à¥‹à¤‚ को वहीं से direct ही बिकवा दिया अरà¥à¤¥à¤¾à¤¤à¥ डिलेवरी सीधे सीकर से ही करवा दी। इसके लिठउन पारà¥à¤Ÿà¤¿à¤¯à¥‹à¤‚ ने direct ही र....
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....ना) बताया है, उन लोगों का नाम, पता, विवरण उपलबà¥à¤§ करवाने में मैं असमरà¥à¤¥ हूठ। आपके इस सवाल का मेरे पास कोई उतà¥à¤¤à¤° नहीं है । पà¥à¤°. 71 आपने शà¥à¤°à¥€ रामकà¥à¤®à¤¾à¤° सोनी से यह 9 ाह सोना नये नोटों में खरीदा या पà¥à¤°à¤¾à¤¨à¥‡ नोटों में खरीदा ? उ. मैंने शà¥à¤°à¥€ रामकà¥à¤®à¤....
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.... मà¥à¤à¥‡ मेरा मà¥à¤¨à¤¾à¤«à¤¾ à¤à¤¿à¤œà¤µà¤¾ दिया था । पà¥à¤°. 73 आपके बताई बात पर अगर विशà¥à¤µà¤¾à¤¸ किया जावे तो आपने उस सोने का बेचने पर कमाये मà¥à¤¨à¤¾à¤«à¥‡ का फिर कà¥à¤¯à¤¾ किया ? उ. मैंने मेरे अघोषित मà¥à¤¨à¤¾à¤«à¥‡ को मेरे मालवीय अरबन को ओपरेटिव बैंक, जौहरी बाजार मं लोन अकाउंट मेà....