TaxTMI 
TaxTMI 
2021 (11) TMI 567
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.... reliance on 'reports of investigation wing' etc. did not constitute 'material' relevant for the purpose of assessment in this case, as the 'appellant' had never been confronted with the same in right perspective and as such the addition made on the basis of such an ex-parte information and reports etc. is wholly vitiated. 4. BECAUSE the computation of income was not even relevant for the purpose of assessment and the same is vitiated, as during the course of search (even in pursuance of joint warrant of Authorisation), no incriminating material was found which could impinge upon the genuineness of the unsecured loan. 5. Because the Learned CIT(A) has erred in law and on facts in confirming the following additions:- S.No. Name of lenders Amount of interest Total addition 1. M/s Neil Industries Ltd. 2,96,160.00 2,96,160.00 without appreciating the supporting documentary evidences & explanation of the appellant placed on record and ignoring the information obtained u/s 133(6) of the Act from the loan creditor. 6. BECAUSE the learned CIT(A) failed to appreciate that the assessee had duly discharged the....
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.... filed returns u/s 153A of the Act. It was submitted that undisputedly no incriminating material was found during the search and the Assessing Officer has made the addition on account of interest paid by the assessee on unsecured loans from Neil Industries Pvt. Ltd. which were raised during earlier years on the basis that the loan creditor, to whom interest was paid, was held to be bogus being carrying on the activity of providing accommodation entries only. It was submitted that the Assessing Officer has arrived at this conclusion on the basis of statements of certain persons who had admitted that such companies were providing accommodation entries only. Learned counsel for the assessee submitted that during the assessment proceedings the assessee had filed all the relevant documents including confirmed copy of account of Neil Industries Pvt. Ltd., copy of bank statement of Neil Industries Pvt. Ltd., copy of ITR-V of Neil Industries Pvt. Ltd. Learned counsel for the assessee further submitted that even the Assessing Officer, by issuing notice u/s 133(6) of the Act to the above loan creditor, had obtained the information directly from such loan creditor and no discrepancy was found....
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.... the loan creditor, to whom interest was paid, was involved in providing accommodation entries. The assessee had filed complete information regarding the creditworthiness, genuineness and identity of the loan creditor and had also deducted tax at source from such interest payments. We further find that the Assessing Officer had issued notices u/s 133(6) of the Act and had also obtained information directly from this loan creditor and this loan creditor has filed the information and documents directly with the Assessing Officer and Assessing Officer did not find any discrepancy in the documents submitted by the assessee as well as in the documents submitted by the loan creditor directly. A copy of notice issued u/s 133(6) is placed in paper book page 18 and the reply of the unsecured loan creditor is placed in paper book pages 80 to 177. We further find that in the assessment order in the case of Neil Industries Pvt. Ltd., interest paid by the assessee has been accepted to be its income. A copy of assessment order passed u/s 143(3) in the case of Neil Industries (P) Ltd. for assessment year 2014-15 is placed in the paper book pages 45 to 73. 4.1 We find that the only reason for d....
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....equested. It is the duty of the department to allow cross examination of the persons - suo moto - before taking any adverse view of the statements against the assessee. That from the above provisions of the Act and the evidences furnished your good self will appreciate that the unsecured loans are genuine and the provisions of section 68 are not attracted in the case of the applicant. The notice issued may therefore, kindly be vacated and no addition as purposed be made in the assessment. In case any further clarification is required, kindly let me know." As per the contents of the above reply filed by assessee, we observe that though the Assessing Officer did issue summons to the witnesses to provide the assessee opportunity to cross examine the witnesses but witnesses did not appear whereas the counsel of the assessee was present for cross examination. The Assessing Officer without making further efforts and without ensuring the presence of witnesses, proceeded to disallow the interest ignoring all documentary evidences filed by assessee as well as by loan creditor directly. When this issue was taken before learned CIT(A), he held that there was no need to pr....
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....vour of assessee by holding as under: "4. We have heard the rival parties and have gone through the material placed on record. We find that due to a search conducted on the assessee and its group on 31/08/2015, the cases of the assessee were reopened and returns were filed u/s 153A of the Act. Admittedly, there was no incriminating material on the basis of which the Assessing Officer has made the additions. The Assessing Officer has made the additions on the basis of entries in the books of account of the assessee. In these cases, the interest paid by the assessee during these years, has been disallowed on the basis that the loan creditors, to whom interest was paid, were involved in providing accommodation entries only. The assessee had filed complete information regarding the creditworthiness, genuineness and identity of the loan creditor and had also deducted tax at source from such interest payments. We further find that the Assessing Officer had issued notices u/s 133(6) of the Act and had also obtained information directly from these loan creditors and these loan creditors have filed the information and documents directly with the Assessing Officer and Assessing Offi....
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....tter dated 22.12.2017 served on 24.12.2017 , the assessee applicant may submit that in response to your earlier letters the assessee applicant has already filed detailed replies from time to time. In the said reply the assessee applicant had requested your good self to provide various details and information as well as the Cross examination of the related persons. In compliance to the opportunity provided by your Good Self for Cross Examination of the aforesaid persons the assessee applicant attended your Office with his Counsel on the appointed date to avail the Cross examination but surprisingly enough, no body turned up on the said date. From your show cause notice it is seen that heavy reliance is being placed on the statements of such persons , who had violated the summons / direction of your Good self by not coming to your office . The Penal provisions as provided under the Act are applicable and the department must have taken serious action against them. The reasons - as to why they have not come, may kindly be provided. Apart from this various details and information as required vide our earlier letters are also awaited for our further submissions." The Assessing O....
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....r-mined. It is well established that mere bald retraction cannot take away the importance and evidentiary value of the original confession, specially in view of the fact that in this case, the deponent of the statement had provided the minute details relating to the transactions. It appears that the retraction statement was made purely to avoid clutches of law which had caught up with him and laid bare his nefarious activities. " Further, jurisdictional Hon'ble Allahabad High Court in the case of Motilal Padampat Udyog Ltd. Vs. CTT 293 ITR 656 has laid down the correct preposition of law of cross examination and held as follows; "Right of cross-examination of persons from whom the Assessing Officer has collected the evidence is not required by law. The requirement of the statute for a valid assessment would be met if all the evidence collected which is to be used against the assesses while framing the assessment order is placed before the assessee and he is given opportunity to rebut the evidence." Further, in a recent judgment of Hon'ble High Court, Delhi published on 04.04.2019 in itatonline.com in the case of Udit Kalra vs. ITO, it was held tha....
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....r dated 14/09/2021, under similar facts and circumstances, relying on the order of Hon'ble Supreme Court in the case of Andman Timber Industries (supra) has decided the issue in favour of the assessee by holding as under: "5. We have heard the rival parties and have gone through the material placed on record. We find that a search was conducted on the group on 27/11/2015 and in view of that search various assessees were required to file returns u/s 153A of the Act and Assessing Officer completed the assessments u/s 153A of the Act except in the year of search where the assessment order has been passed u/s 143(3) of the Act. It is undisputed fact that additions in these cases are not based upon any incriminating material found during the search and rather have been made on the basis of transactions which were already recorded in the books of account of assessees. The facts in brief are that assessees had obtained certain unsecured loans from two loan creditors namely Success Vyapar Limited and Neil Industries Ltd. The Assessing Officer added back such unsecured loans holding them to be accommodation entries and disallowed the interest paid on these loans and also made a....
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....t paid on such unsecured loans, has relied only on the statements of Directors of such companies which were recorded by the Investigation Wing. While making such additions, the Assessing Officer himself did not carry out any enquiry and straightforward relying on the statements recorded by some different officer, has made the additions. While making the additions he has also ignored the documentary evidences filed by the assessees and has also ignored a vital evidence that a substantial part of unsecured loans was already repaid even before the date of search. This fact of having repaid a part of unsecured loans before the date of search is apparent from the year-wise copy of account of such lenders, which for the sake of completeness has been made part of this order and is reproduced below: 5.1 While making the additions on the basis of statements of such persons, the Assessing Officer also noted in the assessment order that notices u/s 131 of the Act were issued to the persons who had given the statements for cross examination by the assessees but the fact of having issued notices u/s 131 of the Act is not coming out from the copy of order sheets placed at page....
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.... Morning Glory Infra Ltd. vs. DCIT, IT(SS)A No.72/Lkw/2018 has also held that additions, on the basis of statements of certain persons, cannot be sustained in the absence of cross examination by the assessee. Similar findings have been made by Lucknow Bench of the Tribunal in the case of Sigma Castings Ltd. vs. DCIT & other appeals in I.T.A. No.510/Lkw/2019 and others. 5.4 The findings in the case of Morning Glory incorporating the findings of Hon'ble Supreme Court in the case of Andman Timber Industries are reproduced below: 2. The brief facts of the case are that a search and seizure operation under section 132(1) of the Income-tax Act, 1961 was carried out at the residential and business premises of Dolphin Developers/Anand/Rotomac Group of cases on 25/6/2014 at Kanpur. Simultaneously, a survey under section 133A of the Act was also conducted at the registered office and the office of M/s Morning Glory Infra Ltd., situated at plot No.2, Block-I, Gotaiya Scheme No.VII, 7/102, Swaroop Nagar, Kanpur and 17/K/13, Sarvodaya Nagar, Kanpur. Shri Anoop Asthana, Prop. M/s Anoop Asthana Properties, main broker for Anand/Dolphin Group and Morning glory Infra Ltd. was ....
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.... "It is, at the outset, emphatically submitted that the aforesaid huge addition of Rs. 64 crores made by the Assessing Officer is patently illegal and bad in law since the same has been made merely on the basis of presumptions, conjectures and surmises, without any credible material/corroborative evidence to establish receipt of any income/cash, outside the books of account, as explained hereunder: The Assessing Officer, as stated above, has simply primarily relied upon the contents of a diary purportedly impounded from the premises of one property broker, Mr. Anoop Ashthana, and his exparte statement recorded during the course of survey at his premises. Re: diary impounded from premises of Mr. Anoop Asthana It is respectfully submitted that the contents of the aforesaid diary found during survey in the case of Mr. Anoop Asthana marked as Annexure A-14, pages 163-165 whereof have been relied upon by the Assessing Officer, could not have been the basis for making such huge addition in the hands of the appellant for the following reasons: ................................................................................. ........................
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....e appellant company. Page No.163 of the Annexure A-4 mentions certain figures which establishes that the money was receiving sale consideration in white and black for example for a 3 BHK flats 2080 square feet, the quantum of while and black mentioned are Rs. 1,20,57,600/- and Rs. 42,12,000/- respectively. Further, another entry is made for the 3 BHK flat admeasuring 2325 sq. ft. area, wherein amount of white and black mentioned is 1,34,81,400/- and Rs. 47,08,125/- respectively. Thus, Assessing Officer has calculated the quantum of black amount at 25% of the total consideration. During survey proceedings the statement of Shri Anoop Asthana, proprietor of AAP was recorded. For answer to question No.22, in the statement recorded on 25/6/2014 Shri Anoop Asthana has categorically stated that page 163 of the annexure A-4 are the entries relating to Emerald Garden and the amount of white and black represents the amount of cheque and cash. It is also stated that the black amount which is invariably in cash is directly paid to the appellant company by the investor to the Director of the appellant company. Shri Anoop Asthana also states that he only gets the commission income at the time of....
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....oker. The incriminating document found from premises of AAP establishes the fact that appellant company is engaged in receiving 25% of the sale consideration in cash, which is unaccounted in the books of the appellant. Assessing Officer has correctly extrapolated the modus operandi for calculating unaccounted income of appellant. 5.11. The contention of the ld. AR that no opportunity of cross examination to Shri Anoop Asthana was ever accorded to the appellant is far away from truth and reality of the case. The incriminating document found and impounded in the business premises of the Anoop Asthana and the incriminating statements of Shri Anoop Asthana was specifically confronted to the Managing Director of the appellant company Shri Sanjeev Kumar Jhunjhunwala on 27/1/2014. This statement is part and parcel fo the assessment order page 6 to 9, therefore, the plethora of the case laws cited by the ld. AR of the appellant does not apply to the facts and circumstances of the present case." 9. Thus, the assessee specifically contended before the ld. CIT(A), that any cross-examination of Shri Anoop Asthana was not allowed to it. The ld. CIT(A) has held that the stateme....
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....ents to the assessee. 11. First and foremost, the subject diary/pages were found and impounded from the premises of Shri Anoop Asthana, a third party, and not from the appellant. Further, Shri Anoop Asthana, in his statement, had stated that entries in the said diary were made by staff member of Shri Anoop Asthana, without providing details of the so-called staff member. Thus, the author of the so-called diary in question is not even known till date. Shri Anoop Asthana nowhere stated that the diary was written by someone on his behalf and/or on his instructions. Therefore, the entire case is fundamentally based on a mere inference drawn about the nature of the contents of the diary written by someone unknown, more particularly, only on the statement of Shri Anoop Asthana about the contents of the diary written by someone else. Since the diary was undisputedly found from the possession of Shri Anoop Asthana and not from the appellant, the contents of the said diary, simplicitor, without any corroborative material/evidence could not have been, in the absence of any corroborative material / evidence, made the basis of drawing any adverse inference against the appellant, much ....
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....dual parties appearing in the diary alongside the amounts are, statedly, completely alien to the appellant. The appellant had not sold any flat in the Emerald Garden project to the persons named in the said diary. Therefore, the very contents of the diary are suspect and are totally unreliable/unauthentic. No adverse inference can be drawn from the payment receipts (3 in number) in respect of flats in Emerald Garden project found from the premises of Shri. Anoop Asthana, particularly when nothing adverse has been stated by Shri. Asthana in this regard. 12. These facts, as specifically contended by the assessee before the ld. CIT(A) have not been rebutted and the ld. CIT(A) has gone merely by the uncorroborated unilateral statement of Shri Anoop Asthana, qua which, no opportunity of cross-examination of the deponent, Shri Anoop Asthana, was afforded to the assessee at any stage whatsoever. It is not sufficient to observe, as has been done by the ld. CIT(A), that ".........the incriminating document found and impounded in the business premises of Shri Anoop Asthana and the incriminating statements of Shri Anoop Asthana was specifically confronted to the Managing Director of ....
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....ed at the back of the assessee has to be excluded, as the same was relied on without giving any opportunity to cross-examine the person giving statement; and that the assessment based on such a statement is a statement rendered as based on no evidence and, accordingly, liable to be annulled. 16. In 'Amarjit Singh Bakshi (HUF) vs. ACIT' (supra), it has been held that opportunity to cross-examine the person giving a statement of culpable nature has to be given; and that in the absence of such an opportunity being given to the affected person, the statement ceases to be material for the purposes of assessment. 17. In CIT vs. SMC Share Brokers Ltd. (supra), it was held that a statement given by a broker at the back of the assessee could not be used to the detriment of an assessee and dismissal of Revenue's appeal was held to be justified. 18. In the case of 'Andaman Timber Industries vs. Commissioner of Central Excise', 281 CTR 241(SC), it has been held that "the assessee was manufacturing plywoods and related products in its factory. Some of those products were sold from factory premises only to certain buyers. However, major portion of products manufactured....
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....AT was set aside. Appeal allowed." 19. Evidently, the three documents found during survey from the possession of Shri Anoop Asthana, in the absence of the statement of Shri Anoop Asthana, do not have any value, particularly in the face of the fact that they are not corroborated by any independent evidence. Page No. 163: This is un-dated, but name of the project 'Emerald Garden' launched by the appellant was mentioned there. With reference to this, Shri Anoop Aathana who had been examined by the Authorised Officers, stated categorically that he had been working as a broker for last 30 years and all the prominent Developers of Kanpur were his clients. In his subsequent statement which appears at page 31 to 36 of the synopsis dated 10.12.2018, and in response to question no.7, he stated that 'cash money' as mentioned there was subject to negotiation between the Customer and the Developer. He further stated in his reply that he was not concerned with the 'incoming' and 'out-going' 'lenden' payments. Page Nos. 164 and 165: These were dated 18.01.2014 and 13.01.2013, falling in the assessment years 2014-15 & 2013-14 respectiv....
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....income declared and income tax, wealth tax payments made by him on such income/wealth. In response to Question No.23, he gave complete information, name-wise, of the booking receipts as had been impounded during the course of survey at the office premises of Shri Anoop Asthana, and in the end, he categorically stated that it would not be proper to draw adverse inference in relation to income from commodity trading. 16. Thus, one cannot but come to the inexorable conclusion that the order under appeal suffers from the vice of not taking into consideration the assessee's contention, which contention also does not stand rebutted, that it was not provided with any opportunity of cross-examining Shri Anoop Asthana. 17. In view of the above, we hold that: (i) the case of the assessee has been prejudiced for want of providing him opportunity of cross-examination of Shri Anoop Asthana, whose unilateral statement recorded exparte qua the assessee has been made the sole basis of the addition, thereby violating the principles of natural justice; and (ii) the other material, i.e., three pages of the diary found in the search do not establish any case for add....
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.... 02/11/2021) ============= Document 1 1920 पीठBe Before the Income Tax Appellate Tribunal, Bench 'B', Lucknow Fixed for 22/06/2021 Summarized chart containing reference to evidences in respect of unsecured loans [Date of Search 31.08.2015] S. No. ITA No. Assessment Year 1 IT(SS)A-523/1/2019 2014-15 2015-16 2 IT(SS)A-524/L/2019 Name of assessee M/s. Accumen Poly Pack Private Limited Appeals relating to assessment made u/s 153A/143(3) involving addition of unsecured loan/disallowance of interest on unsecured loan. D S ITA NO AY No. Notice u/s 133(6) Page issued to Reply filed by loan Page no Reply filed by the assessee Page no. of no. of creditor in response of during respec to notice u/s 133(6) respective Proceedings assessment respective PB loan tive PB creditor. PB 1. 523/Lkw/ 2014-15 Notice u/s Reply dt. 20.12.2017 1. Replies dt. 08.07.2017 2019 & dt. 27.09.2017 133(6) dated filed on 26.12.2017 27.11.2017 45 before the assessing issued to officer as under Success 1.Copy of reply 236 i. Copy of reply 26-27 & ....
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....2 on 31.03.2013 on 31.03.2013 A.Y. 2015-16 Particulars Amount (in Rs.) Reference PB Page No. Referenc Particulars. Amount (in Rs.) e PB Page No. Opening balance as 5,56,21,464 on 01.04.2014 Opening balance as on 01.04.2014 1,33,05,265 Loan taken Interest Credited TDS debited loan repaid 40,00,000 68,83,343 6,88,334 6,00,00,000 Loan taken Part-I, NIL Part-II, Interest Credited 16,25,708 Page- Page- TDS debited NIL 199 344 loan repaid NIL Closing balance as Closing balance as 58,16,473 1,49,30,973 on 31.03.2015 on 31.03.2015 A.Y. 2016-17 Particulars Amount (in Rs.) Reference PB Page No. Particulars Amount: (in Rs.) Referenc e PB Page No. Opening balance as on 01.04.2015 58,16,473 Opening balance as on 01.04.2015 1,49,30,973 Loan taken NIL Part-I, Loan taken 10,00,000 Part-II, Interest Credited NIL Page- Interest Credited 15,97,115 Page- TDS debited NIL 214 Amount Debited 1,88,739 334 loan repaid 58,16,473 loan repaid NIL ....
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.... Amount (in Rs.) Referenc e PB Page No. Opening balance as Opening balance as 64,80,713 79,15,160 on 01.04.2015 on 01.04.2015 Supplem Loan taken NIL Loan taken NIL entary Interest Credited PB Interest Credited 4,97,781 8,57,179 (952421) Conslidat 45 TDS debited ed A.Y. TDS debited 49,778 NIL (95242) 2013-14 loan repaid 69,28,716 loan repaid Closing balance as on 31.03.2016 NIL Closing balance as on 31.03.2016 NIL of Page- 232 87,72,339 M/s. Ghata Mehndipur Balaji Agri Extractions (P) Ltd. Details of loan taken and repaid by the assessee company M/s. Neil Industries Limited M/s. Success Vyapar Limited A.Y. 2014-15 Reference Particulars Amount (in Rs.) PB Page No. Particulars Amount (in Rs.) Referenc e PB Page No. Opening balance as on 01.04.2013 Loan taken Interest Credited Opening balance as 37,54,762 29,04,120 on 01.04.2013 42,00,000 Loan taken NIL 8,07,019 Interest Credited 3,48,490 19 TDS debited 80,702 TDS debited 34,849 23 23 loan repaid ....
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....08.12.2017 filed on 19.12.2017 in response to notice u/s 133(6) issued by Ld. AO alongwith confirmed copies of accounts, bank statement. copy of acknowledgement of ITR & copy of audited balance sheet with annexure. A.Y. 2015-16 [ITA No.-IT(SS)A-116/LKW/2019] S.N. Particulars of Documents Page No. of respective Paper Book 74 75 101-127 164 & 272 275 285. 286. 295. 315-331 70 71 72-73 128-157 366-367 372, 375, 377, 378, 383-404 Page No. e No. of respective M/s. Success Vyapar Limited Confirmed copy of account 1. 2. Copy of acknowledgement of ITR 3. Copy of relevant page of Bank Statements showing the entry of payment made to assessee Cupy of assessment order u/s 143(3) of the 1. T. ALL, 1961 fui A.Y. 2013-14, A.Y. 2012-13 & A.Y. 2014-15 5. 7. Notice u/s 133(6) dated 04.12.2017 Reply dated 08.12.2017 filed on 26.12.2017 in response to notice u/s 133(6) issued by Ld. AO alongwith confirmed copies of accounts, bank statement, copy of acknowledgement of ITR & copy of audited balance sheet with annexure. M/s. Neil Industries Limited Confirmed copy of....
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....014-15 9. Notice u/s 133(6) dated 21.11.2017 128-157 230 10. Reply dated 08.12.2017 filed on 19.12.2017 in response to notice u/s 133(6) issued by Ld. alongwith confirmed copies of accounts, bank statement, copy of acknowledgement of ITR & copy of audited balance sheet with annexure. 235, 236, 237, 246-257 A.Y. 2014-15 [ITA No. - IT(SS)A-106/LKW/2019] S.N. 1. Particulars of Documents M/s. Success Vyapar Limited Confirmed copy of account 2. Copy of acknowledgement of ITR 3. Copy of relevant page of Bank Statements showing the entry of payment made to assessee Page No. of respective Paper Book 45, 63-64 46 & 65 47-53 4. Copy of assessment order u/s 143(3) of the I. T. Act, 1961 for A.Y. 2013-14, A.Y. 2012-13 & A.Y. 2014-15 89-115 Confirmed copy of account 5. M/s. Neil Industries Limited 6. Copy of acknowledgement of ITR 54 & 61 7. Copy of assessment order u/s 143(3) of the I. T. Act, 1961 for A.Y. 2014-15 55 & 62 116-145 8. Notice u/s 133(6) dated 21.11.2017 9. Reply dated 08.12.2017 filed on 19.12.2017 in response to notice u/s 133(6) issued by Ld. AO alongwith confir....
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....3(3) of the I. T. Act, 1961 for A.Y. 2013-14, 50-76 A.Y. 2012-13 & A.Y. 2014-15 5. Reply dated 15.12.2017 filed on 26.12.2017 in response to notice u/s 161,165,166, 133(6) issued by Ld. AO alongwith confirmed copies of accounts, bank statement, copy of acknowledgement of ITR & copy of audited balance sheet 168, 187-198 with annexure. M/s. Neil Industries Limited 6. Confirmed copy of account 7. Copy of acknowledgement of ITR 8. Copy of assessment order u/s 143(3) of the I. T. Act, 1961 for A.Y. 2014-15 9. Notice u/s 133(6) dated 21.11.2017 10. Reply dated 15.12.2017 filed on 26.12.2017 in response to notice u/st 133(6) issued by Ld. AO alongwith confirmed copies of accounts, bank statement, copy of acknowledgement of ITR & copy of audited balance sheet with annexure. A.Y. 2015-16 [ITA No. - IT(SS)A-111/LKW/2019] S.N. Particulars of Documents M/s. Success Vyapar Limited 23 24 77-106 12 115, 120-128 Page No. of respective Paper Book 1. Confirmed copy of account 2. Copy of acknowledgement of ITR A.Y. 2012-13 & A.Y. 2014-15 3. Copy of assessment order u/s 143(3) of the I. T. Act, 1961 f....