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2018 (3) TMI 1958
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....s of manufacturing and trading of marble/granite slabs and tiles. A survey U/s 133A of the Income Tax Act, 1961 (in short the Act) was carried out on 12/09/2013 and 13/09/2013 alongwith other group concerns of the partners namely Shri Arihant Choudhary, Shri Tilak Choudhary, Kusum Choudhary and Smt. Shweta Choudhary. The return of income was filed declaring NIL income in the case of M/s Asmi Stonex after adjusting unabsorbed depreciation on 30/09/2014, return of income declaring total income of Rs. 5,90,940/- was filed in the case of Arihant Choudhary and return of income declaring total income of Rs. 5,25,530/- was filed in the case of Tilak Choudhary. The Assessing Officer made addition on account of excess stock and short cash noted during the survey proceedings. 4. A common issue involved in all these appeals, is sustaining the addition of Rs. 1,99,37,946/- in the case of M/s Asmi Stonex, Rs. 37,73,000/- in the case of Arihant Choudhary and Rs. 31,43,000/- in the case of Tilak Choudhary on account of excess stock. 5. The assessee claimed that the ld. CIT(A) has not considered the submissions of the assessee and confirmed the addition without any basis. The brief facts in ....
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....hich disclosed that the blocks were purchased weight wise. This submission of the assessee has remained untroverted which points out to a serious blunder in the valuation of marble blocks. It was also pointed out that the stock of marble blocks of Rs. 4,21,68,000/- is 90% of the total stock found during the course of survey of Rs. 4,73,04,946/-. The major discrepancy in the valuation of marble blocks has rendered the entire valuation of stock as a farce. Therefore no addition could have been made on the basis of such valuation. This submission of the assessee has remained uncontroverted by the Learned CIT(A). They have simply reiterated again and again statement of Shri Pradeep Choudhary on the basis of which valuation was done. The submission of the assessee is that in the face of documentary evidence oral statement cannot prevail. (iii) It was submitted before the Learned CIT(A) that as per books of accounts of the assessee the stock in hand as on the date of survey 12.09.2013 was of Rs. 1,88,820 of Marble Blocks and of Rs. 18,79,542/- of marble slabs and tiles. In support of this book position of stock necessary papers are available on paper book page number on....
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....de before the Learned Assessing Officer but the same were ignored and not taken into consideration. The discrepancies raised by the assessee have also remained uncontroverted. It is the submission of the assessee that the entire survey was a farce. The figures of stock valuation are fake and it was just to obtain forced surrender from the assessee. It is settled principle of accountancy that valuation of stock cannot be made on the basis of statement of the assessee. The same has to be worked with reference to purchase and sale vouchers. But in this case the survey team did not carry out any verification with reference to purchase and sale vouchers but tried its best to force Shri Pradeep Choudhary to make surrender. Thus the thrust of the survey team was not on carrying out a genuine survey but was in recording statement of the assessee under duress. It is submitted that mere statement cannot be basis of any addition unless the same is substantiated. In the remand report as well as in the appellate order the Learned Assessing Officer and the Learned CIT(A) have taken shelter of the statement of Shri Pradeep Choudhary for making and sustaining the addition. In fact the revenue has ....
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....osed total disregard to documentary evidences and arbitrary attitude of the Learned Assessing Officer. The Learned CIT(A) has also ignored to consider the submissions made by the assessee. The assessee considers it relevant to quote the following para from the above case law:- Assistant Commissioner of Income Tax vs. M/s. AL Quresh Export, ITA No.6733/Mum/2008 (Assessment Year: 2005-06) dated 15th February 2011. Thus it is obvious that the additional income disclosed by the appellant was not based on any documentary evidence. No material is found or impounded in the survey to corroborate the confession of concealed income nor investigated and declared later in post survey or assessment proceeding which followed. A statement so made cannot be the end of the matter and the AO was expected to dig out fresh facts and corroborate its findings. A statement recorded during the course of survey can be made the basis of assessment u/s.143(3) only it if it is linked to evidences. The reply to Q. No.11 in which the so called declaration has been made is premature and appears dumb to say the least. The transaction or manner in which such additional income was earned and the d....
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....en to the person who made the admission to show that it is incorrect. In the present case apart from answer given by the partner Shakir Qureshi to question at S. no.11 on survey day that since "I am not able to reconcile the discrepancy on purchase for which bills were yet to be received, as such I offer an income of Rs. 1.91 Crores", no clinching evidence or material based on valid inquiry is placed on record by the AO which could persuade the appellate authority to confirm the addition so made. In CIT vs. Ramdas Motor Transport {(1994)(238 ITR 177) (183) (A)} and Jaikisan R. Agarwal vs. ACIT {(2000) 66 TTJ 704} it has been held that if the admission in the statement is not supported by any asset or document, the retraction may be genuine. The Allahabad High Court in the case of Abdul Qayinne vs. CIT {(1990) 184 ITR 404 (All.)} made the categorical observation to the effect that an admission or an acquiescence cannot be foundation for an assessment when the income is returned under an erroneous impression or misconception of law. It was always open to ITA 6733/M/2008 M/s. AL Quresh Export assessee to demonstrate any satisfy the authority concerned that a particular income wa....
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....r worked out stock of Rs. 4,73,04,946/- allegedly found at the business premises of the assessee whereas virtually there was no such stock at the business premises of the assessee. The survey team on the paper first allegedly worked out the stock at Rs. 4,73,04,946/- and later-on on presumption and assumption divided the same in all the five sister concerns and a sum of Rs. 3,20,73,946/- was held as belonging to the assessee. There are no details as how this stock was held to belong to the assessee. The entire exercise of survey does not give any details of the manner in which the working was done either of the stock as per books or of the stock found physically. There are no details of purchases and sales before working out the stock as per books. There is no reference to the cost of purchases before valuing the stock found physically. The stock as per books as well as the stock found physically has been worked out and valued on the basis of statement of Shri Pradeep Kumar Choudhary which was recorded under threat, duress and stress. Such statement recorded u/s 133A does not carry any evidentiary value. It is only on presumption that the stock found at the premises of M/s....
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.... a hypothetical manner without taking into consideration the actual facts. It was concerned mainly obtaining surrender of income. Therefore all manipulations were done in making a false valuation report whereas no such stock was actually existed. Further apportionment of stock was made in the hands of various concerns just to give it a color of genuineness. In these circumstances it is submitted that addition made by the Learned Assessing Officer has no legs and deserves to be deleted. It is further submitted that as per trading account the total sales disclosed by the assessee are only of Rs. 1,37,45,932/- of marble slabs and tiles. For conduct of such sales existence of stock to the extent of Rs. 3,20,73,946/- is a distant cry. The Learned Assessing Officer has not disturbed the sale of the assessee. The sales as per books of accounts stand accepted. Hence it is established that the stock valuation report is false and flimsy. No additions can be made on the basis of such an unrealistic report. The figure of stock of Rs. 3,20,73,946/- indicate that some exact working would have been under taken otherwise how could one reach to a figure so exact upto 00003946. But no details are....
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....is not only defective but invalid. It appears that during the survey the authorized officers were in a hurry to obtain surrender of income by hook or by crook. The defect of valuing marble blocks without quantifying their weight is a major defect. This invalidates the entire valuation. The assessee has purchased marble blocks with reference to weight. Copies of vouchers of purchases of marble blocks from R.K. Marbles Pvt Ltd are available on paper book page number cited supra. It is submitted that out of the total stock valued by the survey team at Rs. 4,73,04,940/-, more than 90% of it pertain to marble blocks and granite blocks which has been valued purely on estimate basis. The Marble blocks were purchased weight vise but the valuation has been done by counting the marble blocks as big and small which is not correct. During the year under consideration upto the date of survey the assessee purchased 43 marble blocks weighing 436.64 tons for a sum of Rs. 7,39,513/- which gives average cost of 1 block at Rs. 17,198/- tons whereas in the survey valuation report the marble blocks have been valued bigger size at Rs. 40,000/- per block and smaller size at Rs. 26,000/- Per block. In ....
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....eight of marble blocks so as to treat them big or small. Details of purchases of marble blocks along with relevant purchase vouchers, ledger account are available on paper book cited supra. It is iterated that assessee has no stock of marble blocks as on the date of survey and hence it was wrong on the part of the Learned Assessing Officer to have considered the stock of Rs. 3,20,73,946/- in the hands of the assessee without any base and without any ground. 6. Stock of granite wrongly considered in the hands of the assessee: - The valuation of granite has also been done in very routine and slipshod manner without taking into consideration the size, the quality and the color. The same has been valued at Rs. 24,80,170/-. It is submitted that so far as the assessee is concerned as on the date of survey it had purchased 61 granite blocks weighting 625.25 tons of the value of 4,45,000/-. The average cost of per blocks works out of Rs. 7295/- whereas in the valuation report the granite blocks have been valued bigger size @ 26000/- per block and smaller size at Rs. 26000/- per block. The valuation made by the survey team is totally wrong. The assessee had purchased granite blocks wi....
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....Kamlesh Rathore. (Answer to question no. 7). Thus the assessee had no say in the valuation of the stock found. The stocks required to be valued with reference to vouchers of purchase and not on the basis of statement. Therefore the entire valuation stock is defective, wrong, incorrect and overvalued and therefore deserves to be disregarded. (c) The stock was bifurcated in the hands of five concerns at the instance of Shri Pradeep Choudhary at his oral instruction. The statement does not give any basis of bifurcating of stock in the hands of five sister concerns. (Answer to question no. 8) This has been done purely on guess work. Such bifurcation is not acceptable and not reliable being not correct. (d) The stock as per books of all the five concerns have been taken at Rs. 1,42,17,000/- on the basis of alleged computer sheets whereas stock as per books should have been worked out with reference to individual books of accounts of each of the five concerns. There is no reference of any stock register, trading A/c etc. while working out the stock as per books on the date of survey. Thus the stock as per books taken by the revenue is invalid and deserves to be ignored.....
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....issued by the Board quoted below. The addition made on the basis of such confessional statement deserves to be deleted. Board circulars dated 10.03.2003 and 18.12.2014 are quoted below- (i) F. No. 286/2/2003-IT (Inv) dated 10.03.2003 No confessional statement in the course of search, seizure and survey. March 10th, 2003 Confession of additional Income during the course of search &seizure and survey operation GOVERNMENT OF INDIA MINISTRY OF FINANCE &COMPANY AFFAIRS DEPARTMENT OF Revenue CENTRAL BOARD OF DIRECT TAXES Room No. 254/North Block, New Delhi, the 10th March, 2003 To All Chief Commissioners of Income Tax, (Cadre Contra) & All Directors General of Income Tax Inv. Sir Subject : Confession of additional Income during the course of search &seizure and survey operation -regarding Instances have come to the notice of the Board where assessees have claimed that they have been forced to confess the undisclosed income during the course of the search &seizure and survey operations. Such confessions, if not based upon credible evidence, are later retracted by the concerned assessees whil....
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.... your attention to the Instructions/Guidelines issued by CBDT from time to time, as referred above, through which the Board has emphasized upon the need to focus on gathering evidences during Search/Survey and to strictly avoid obtaining admission of undisclosed income under coercion/undue influence. 3. In view of the above, while reiterating the aforesaid guidelines of the Board, I am directed to convey that any instance of undue influence/coercion in the recording of the statement during Search/Survey/Other proceeding under the I.T.Act,1961 and/or recording a disclosure of undisclosed income under undue pressure/ coercion shall be viewed by the Board adversely. 4. These guidelines may be brought to the notice of all concerned in your Region for strict compliance. 5. I have been further directed to request you to closely observe/oversee the actions of the officers functioning under you in this regard. 6. This issues with approval of the Chairperson, CBDT (K. Ravi Ramchandran) Director (Inv.)-II, CBDT - It is submitted that the action of the i.e. authorities in obtaining surrender of income that too under duress is against the circulars of the CBDT which are binding upon t....
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....f stock has been taken purely on guess work. Further not only that the cost of stock was not worked out with reference to purchase vouchers but a blunder has also been committed in working out the cost of marble blocks. The Marble block was purchased weight vise but the valuation has been done by counting the marble blocks as big and small which is not correct. During the year under consideration the assessee purchased 43 marble blocks weighing 436.64 tons for a sum of Rs. 7,39,513/- which gives average cost of 1 block at Rs. 17,198/- whereas in the survey valuation report the marble blocks have been valued bigger size at Rs. 40,000/- per block and smaller size at Rs. 26,000/- Per block. In any case both the sizes stand overvalued. Further it is not known as what was the criteria of treating a marble block big or small. So far as the assessee is concern the blocks have ranged around 10 tons each. There is no big difference in the weight of marble blocks so as to treat them big or small. Details of purchases of marble blocks along with relevant purchase vouchers, ledger account are available on paper book page number cited supra. The facts of purchases of marble bl....
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.... which is more than double to the total sales of the year. Thus apparently the stock determined by the survey team/the excess stock worked out do not match the sales of the assessee which stand accepted by the Learned Assessing Officer. Not only this even during the course of survey not a single paper was found showing unaccounted purchase or sale. In these circumstances the addition made by the Learned Assessing Officer was totally unjustified on the basis of alleged excess stock. The addition made by the Learned Assessing Officer deserves to be deleted. The following case is quoted in support: - Shekhawati Art Palace Vs. CIT (2008) 116 TTJ (JP) 552 Mere rejection of account would not mean that it must lead to addition. 13. Surrender u/s 133A was under duress - From the aforesaid facts it is clear that the survey authorities had not worked out the valuation of stock in a truthful manner. The position of physical stock has been taken purely on estimate basis and it has no relation with the ground reality. The survey team was obsessed for obtaining surrender. Hence confessional statement has been recorded which is in clear cut violation of the cir....
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.... (f) Kailashhen Manharlal Chokshi Vs CIT (2008) 14 DTR 257 (Guj) It is also to be seen as to whether an addition made is merely based on the statement recorded by the AO under s. 132(4) and whether any cognizance may be taken of the retracted statement. So far as case on hand is concerned, the glaring fact required to be noted is that the statement of the assessee was recorded under s. 132(4) at midnight. In normal circumstances, it is too much to give any credit to the statement recorded at such odd hours. The person may not be in a position to make any correct or conscious disclosure in statement if such statement is recorded at such odd hours. Moreover, this statement was retracted after two months. The main grievance of the AO was that the statement was not retracted immediately and it was done after two months. It was an afterthought and made under legal advise. However, if such retraction is to be viewed in light of the evidence furnished along with the affidavit, it would immediately be clear that the assessee has given proper explanation for all the items under which disclosure was sought to be obtained from the assessee. (g) Pullanguegode ....
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....yer: - It is submitted that the aforesaid facts and discussion clearly establish that it is a case where surrender of income was obtained under the garb of survey. In fact no genuine survey was conducted verifying the books of accounts or the position of stock. It is because of this that the marble blocks have been valued without taking into consideration there weight and the purchase cost. The stock of five concerns has been inventorized at one place and then fictionally bifurcated in the respected hands of the five concerns without any basis. The assessee does not know on what basis the stock allegedly held belonging to it has been apportioned at Rs. 3,20,73,946/- particularly the marble slabs and tiles costedRs. 12.21 per square feet as against Rs. 30/- adopted by the survey team while valuing the stock. In fact the entire exercise of valuation of stock is full of blunders and is not actionable. No addition could be made on the basis of such valuation report. Therefore it is prayed and requested to delete the addition made by the Learned Assessing Officer and allow the appeal of the assessee on this issue." Similar identical submissions have also been taken by the ld....
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.... of both marble and granite and also to consider the quality of marble and granite of each block as there is wide variation in price due to various reasons like colour, design, patterns etc.. It is a well known fact that all the blocks cannot be categorized of the same quality and cannot be valued at the same rate. Thus, the valuation prepared by the survey team does not carry weight and quantification of the value of the stock on the date of survey. Thus, such major discrepancies in the valuation of marble and granite blocks has rendered the entire valuation done by survey team as a farce. No addition can be sustained on the basis of such casual valuation of stock. As per books of account, the stock inventory was filed, which is placed at page No. 13 to 124 of the paper book and this fact has not been controverted by the revenue. Further the bifurcation of the stock among various entities is also not based on any concrete evidence. The stock statement as per books taken by the survey team is also not based on any positive evidence. It is also a fact that the cost of the granite block in the hands of the assessee was Rs. 7295/- while the survey has adopted at Rs. 26,000/- per bo....
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....4 wherein it has been clearly stated that instances/complaints of undue influence/coercion have come to notice of the CBDT that some assessees were coerced to admit undisclosed income during the searches/surveys conducted by the department. The CBDT is also aware about the fact that such admissions are retracted in the subsequent proceedings since the same are not backed by credible evidence. The CBDT is also aware about the fact that such actions defeat the purpose of search/survey operations as they fail to bring the undisclosed income to tax is a sustainable manner leave alone levy of penalty or launching of prosecution. Thus, such confessional statements not supported by credible evidence cannot be made basis to make and sustain the addition. Such view also gets support from the following case laws: (a) Jain Trading Co. Vs ITO (2007) 17 SOT 574 (Mum) An assessee who makes an offer of additional income during course of an enquiry by income-tax authorities is not bound by his offer of additional income for all time to come. But at the same time, the burden cast upon an assessee, who chooses to retract his earlier statement, is very heavy. In the instant case, during the cou....
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.... any statement made by such person during such examination can also be used in evidence under the Income-tax Act. On the other hand, whatever statement is recorded under section 133A is not given an evidentiary value. The statement obtained under section 133A would not automatically bind upon the assessee. Therefore, admission made during such statement cannot be made the basis of any admission. (c) Paul Mathews & Sons Vs CIT 263 ITR 101 (Ker) Section 133A enables the income-tax authority only to record any statement of any person which may be useful but does not authorise for taking any sworn in statement. On the other hand, such power to examine a person on oath is specifically conferred on the authorised officer only under section 132(4) in the course of any search or seizure. Thus, the Act whenever it thought fit and necessary to confer such power to examine a person on oath, the same has been expressly provided whereas section 133A does not empower any ITO to examine any person on oath. In contradistinction to the power under section 133A, section 132(4) enables the authorised officer to examine a person on oath and any statement made by such person during such examin....
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....me was accepted by the said officer. [Para 18] The view taken by the ITO could not be said to be unsustainable in law, so as to call it an order passed erroneously. The ITO had seized books of account and elicited certain answers which had no evidentiary value. There were certain omissions and commissions on the part of the assessee and the assessee had voluntarily offered certain amounts to be treated as additional income for the assessment year in question. But the same had been explained by the assessee, which explanation was accepted after referring to the records and the assessment order passed. The ITO was satisfied about the actual amount received towards advances and only an amount of Rs. 6 lakhs out of the balance was to be further explained and they were telescoped. The entire sum of Rs. 19 lakhs was considered for the block assessment completed in the case of the creditor much before the survey. In those circumstances, the statement of the assessee that the amount of Rs. 13 lakhs offered by him in the statement during the course of survey was only a mistake of fact, could not be brushed aside. Further, in the light of the voluntary disclosure in the letter given in wr....
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....…धिक थाठगठstock जिसकी cast रà¥. 3.30,87,946 /- आती है, के बारे में सà¥à¤ªà¤·à¥à¤Ÿà¥€à¤•à¤°à¤£ कà¥à¤· उतà¥à¤¤à¤°-8 मैने Mok की सूची Annerwse- '5' है पृषà¥à¤ 1 से 12. देख बà¥à¤°à¤¹ लिठहै à¤à¤µà¤‚ tok Takig à¤à¤µà¤‚ Valuation सं सहमत हूà¤à¥¤ इस अधिक पाà¤à¤ stork के बारे में, मैं कोई सà¥à¤ªà¤·à¥à¤Ÿà¥€à¤•à¤°à¤£ नहीं दे सकता हूठà¤à¤µà¤‚ इसका मेरा लेखा - पà¥à¤¸à¥à¤¤à¤•à¥‹ ....
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....े अरà¥à¤œà¤¿à¤¤ मानकर आयकर के लिठसमरà¥à¤ªà¤¿à¤¤ करता हूà¤à¥¤ 5\/13- /12/9/13 than A -0. Wanith , वन Entities दà¥à¤µà¤¾à¤°à¤¾ funwitz 2213 Document 3 (16) वरना आपके इस. वà¥à¤¯à¤¾à¤µà¤¸à¤¾à¤¯à¤¿à¤• सà¥à¤¥à¤² मैं Hotel Arjau hilace पर सरà¥à¤µà¥‡à¤•à¥à¤·à¤£ की कारà¥à¤¯à¤µà¤¾à¤¹à¥€ के दौरान आपके Arcerentant शà¥à¤°à¥€ पà¥à¤°à¤•à¤¾à¤¶ चनà¥à¤¦à¥à¤° जैन ने विà¤à¤¿à¤¨à¥à¤¨ फरà¥à¤®à¥‹à¤‚ के Qorh Balainul के बारे में हà¥à¤ˆ कि cash जो कि ....
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....¤…पने बयानों में कहा है कि उनà¥k की tिion के बारे में à¤à¤µà¤‚ 87ok की अधिकता à¤à¤µà¤‚ कमी के बारे में अनà¥à¤¯ ही बयान देगें । कृपया सà¥à¤ªà¤·à¥à¤Ÿ करे। उतà¥à¤¤à¤°à¤² मैने अपने पà¥à¤¤à¥à¤° के बमान पढ़ लिठहै à¤à¤µà¤‚ मैं इससे सहमत हूठकि चूंकि वह कà¤à¥€ नà¤à¤¨à¥‡ tिness संà¤à¤¾à¤²à¤¨à¥‡ लगा है, अत: उसà¤....
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....परिसर में उकà¥à¤¤ फरà¥à¤® के अलावा मैं Anilonst storuse, Shweta stomap, Tilak smusk à¤à¤µà¤‚ Kutum stoves का माल à¤à¥€ रखा हà¥à¤† है। इसी तरह इस वà¥à¤¯à¤µà¤¸à¤¾à¤¯à¤¿à¤• परिसर के सामने सà¥à¤¥à¤¿à¤¤ stock Yard में à¤à¥€ कसà¥à¤¤à¥‡ पाà¤à¤šà¥‹ सरà¥à¤®à¥‹à¤‚ का stock समà¥à¤®à¤¿à¤²à¤¿à¤¤ संप से रखा हà¥à¤† है। मैने सà¥à¤µà¤¯à¤‚ इस वà¥à¤¯à¤µà¤¸à¤¾à¤¯à¤¿à¤• परिसर पर जाकर यह check किया है। Slan पà¥à¤°à¤¶à....
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....‡ अनà¥à¤¸à¤¾à¤° किया गया है। मैने सà¥à¤µà¤¯à¤‚ à¤à¥€ इस परिसर में धूà¤à¤•à¤° व सामने सà¥à¤¥à¤¿à¤¤ stock Yosed में जाकर stork का आकलन à¤à¤²à¥€-à¤à¤¾à¤à¤¤à¥€ कर लिया है à¤à¤µà¤‚ | stork Taking षं Brock की codt Valuation से पूरà¥à¤£à¤¤à¤ƒ संतà¥à¤·à¥à¤Ÿ हूà¤à¥¤ पà¥à¤°à¤¶à¥à¤¨-8 मैं आपको आपके दà¥à¤µà¤¾à¤°à¤¾ कमà¥à¤ªà¥à¤¯à¥‚टर में दरà¥à¤œ Record के हिसाब से पाà¤à¤šà¥‹ फरà¥à¤®à¥‹à¤‚ का à¤....
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....ीं है। मैं इस Excess stock को उकà¥à¤¤ फाà¤à¤šà¥‹ फरà¥à¤®à¥‹à¤‚ की अघोषित आय से अरà¥à¤œà¤¿à¤¤ मानकर निमà¥à¤¨ पà¥à¤°à¤•à¤¾à¤° से आयकर के लिठसमरà¥à¤ªà¤¿à¤¤ करता हूठ: - S.N Name of the Firm Prop. | As Pe's Books Physically Differance found 1. Asmi Stangn P/F 1,21,36,000/- 3,20,73,340/- 1,99,37,990/ ! Arrit haunt stamera : Arihant 2,27,000/- 40, 08, à¦mf 37,73, à¦à¦•f Choudhary 3. Shesita stories Shurta 10,30,000/-, 40, 00,000/- 29,70,000/- Chynahary 4. Talak stones Tilak 3,50,000/- 35,00,000/- 31,43,000f Choudhary 5. Kuestion Stmend Known 4.67,000 34,21,000Rs. 32,64,000/ Chaudhary 3,30,87,944- 13/3/13 1,42, 17,000/- 4,73,04,946 à....