TaxTMI 
TaxTMI 
2024 (3) TMI 301
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....ssessee came into being, share capital and share premium of Rs. 27,63,46,000/- with equivalent paper investments were routed through bank account of the assessee on various dates between 16.03.2011 to 31.03.2011.The directors of the said assessee company were Mr. Premnath Mali and Mr. Sandeep Mukherjee who were appointed by Shri Bajrang Lal Agarwal who was the controlling person of BCPL. Thereafter BCPL was purchased by three persons namely Shri Suresh Kumar Agarwal, Shri Yogendra Kumar Agarwal and Shri Deepak Kumar Sanwaria during financial year 2012-13 from Shri Bajrang Lal Agarwal in order to purchase a piece of land measuring 85.51 acres at Renguni Mouza, Dhanbad which was in joint ownership of Shri Rabindra Nath Paul, Sri Binoy Krishna Paul, Sri Amiya Kumar Paul, Sri Bani Brata Paul and Sri Uday Shankar Paul( hereinafter referred to as Paul Brothers).Paul Brothers were represented by their power of attorney holder Shri Tarun Kanti Ghoshal. After acquisition of the said company, the old directors resigned and new directors were inducted namely Mr. Triloki Singh representing Shri Suresh Kumar Agarwal and Mr. Manik Kumar Tiwari representing Shri Deepak Kumar Sanwaria. A search ac....
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....mar Agarwal gave one more address on which the notice was duly served on the assessee and in compliance ,the assessee filed necessary documents comprising audit report, bank statement of Dhan Laxmi Bank, Kolkata along with computation of income besides memorandum and article of association. The AO, on perusal of the said evidences observed that the company was incorporated on 22.02.2011 with directors namely Sri Sandeep Mukherjee, Shri Premnath Mali and Ashok Thakur and the said company was controlled by Shri Bajrang Lal Agarwal. The AO observed that Shri Sandeep Mukherjee and Premnath Mali have held 50,000 equity shares each. During the year the assessee company has received share capital including share premium of Rs. 27,63,46,000/- which was inclusive of Rs. 20,00,000/- each received from M/s Erwin Trading Pvt. Ltd. and M/s Tanika Commercial Pvt. Ltd. the two companies which were also controlled by Shri Bajrang Lal Agarwal. The AO noted that the assessee did not charge any premium from these two companies. Whereas the other subscribers the details whereof were given on page 2 and 3 of the assessment order, were charged huge premium of Rs. 499/- per share with face value of 1/- e....
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....ned cash credit by recording a finding that the money was belonging to the directors and as such added the same u/s 68 of the Act unexplained cash credit in the assessment framed u/s 153A/143(3) of the Act dated 28.03.2016. 5. The said order was challenged before the Ld. CIT(A) and Ld. CIT(A) also affirmed the addition as made by the AO on the same reasoning. 6. The Ld. A.R vehemently submitted before us that there was no dispute as to the business of Shri Bajrang Lal Agarwal who was controlling various shell companies which were constituted and managed by the said person for providing accommodation entries and thus working as conduit and pass through entity. The Ld. A.R referred to the assessment order in which the AO has extracted the replies given by Shri Bajrang Lal Agarwal to various queries during the course of recording of statement u/s 132(4) of the Act and also referred to the answers given by Shri Bajrang Lal Agarwal that all these entities including assessee were providing accommodation entries to various entities/beneficiaries in lieu of commission in the form of share capital and unsecured loans and charging commission in lieu of that ranging from 10 paisa to 25 ....
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.... purpose of routing the funds into the bank of the ultimate beneficiary companies. In defense of argument the Ld. A.R. relied on the decision of Co-ordinate Bench of Delhi in the case of ITO vs. M/s Angel Cement Pvt. Ltd. &Ors. In ITA NO. 4691/Del/2016 dated 18.03.2021 and the decision of Hon'ble Allahabad High Court in the case of Prem Castings Pvt. Ltd. vs. CIT [2017] 88 taxmann.com 189. Finally the Ld. A.R prayed before the Bench that the addition as confirmed by the Ld. CIT(A) may kindly be directed to be deleted in view of these factthat the assessee is a merely a conduit and not the final beneficiary. 7. The Ld. D.R, on the other hand, stated that the Ld. CIT(A) has rightly upheld the order of AO as the assessee has failed to explain the source of share capital/share premium collected from 16 share subscribers . The Ld. D.R submitted that though the assessee was conduit engaged in providing accommodation entries to various either intermediaries or final beneficiaries and also the fact that the money received by the assessee was immediately passed on to other intermediary or final beneficiaries ,but the onus of the assessee is not discharged as the assessee has to prove eac....
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....rther corroborated by the fact that the very first day during the course of recording statement u/s 132(4) of the Act Shri Bajrang Lal Agarwal have stated that he is engaged in providing accommodation entries in lieu of commission through the assessee meaning thereby that money did not belong to him as it is only pass through entity. The case of the assessee finds support from the decision of Coordinate Bench of Delhi in the case of ITO vs. M/s Angel Cement Pvt. Ltd. &Ors.(supra) wherein the Co-ordinate Bench has held as under: "61. The ld. CIT-DR relying upon the order of the Assessing Officer had contended that the assessees herein has availed accommodation entries wherein they have introduced the unaccounted/undisclosed fund into their books of account in the garb of share capital and or loan and advances. However, there is not an iota of material by way of any inquiry or information from Investigation Wing that, firstly, above named assessee companies have been found to be beneficiary of accommodation entry in any search or survey in the case of entry operator; and secondly, any inquiry has been made in the case of the assessee companies wherein it has been found that ....
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....ited company at the very beginning i.e., at a time when it may not have conducted any business so as to give rise to any income or money to make such an investment. In that case, addition may be warranted in the hands of the directors etc. However, that is not the case here. No other fact has been pleaded or found to exist as may save the assessee in this case from the addition made under section 68." 8.2. Since Shri Bajrang Lal Aggarwal was providing accommodation entries to either intermediaries or the ultimate beneficiaries through paper companies including the assessee and the assessee is only a conduit for channelizing the unaccounted funds of beneficiary companies, therefore, in our opinion, the order passed by the Ld. CIT(A) appears to be incorrect and cannot be sustained. Accordingly we set aside the order of ld. CIT(A) and direct the AO to delete the addition. However the AO is directed to assess the commission income on accommodation entries @ 20 paisa on Rs. 27,63,46,000/- which comes to Rs. 6,90,865/-. Consequently the Appeal of the assessee is party allowed. 9. Now we shall adjudicate in IT(SS)A NO. 16/Ran/2018 for AY 2012-13 and the revised grounds raised by the....
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.... 6,000/- 04/05/2011 Cash 15,000/- 21,000/- 16/05/2011 110.33 20,889.67 20.05.2011 220.66 20,669.01 03/12/2011 Majestic/172228 1,10,000/- 1,30,669.01 05/12/2011 Khushi/010910 1,04,500/- 26,169.01 The AO called upon the assessee to explain along with corroborative evidences all the credit entries however but no satisfactory reply was given. As such, the total amount of Rs. 1,57,81,000/- was added to the total income of the assessee company M/s BCPL u/s 68 of the Act in the assessment framed u/s 153A/143(3) of the Act dated 28.03.2016. . 11. We find that the issue raised in ground no. 1 is similar to one as decided by us in IT(SS)A No. 15/Ran/2018 for AY 2011-12 in favour of the assessee. Therefore our finding in the above IT(SS)A No. 15/Ran/2018 would, mutatis mutandis, apply to ground no. 1 as well. Consequently, we set aside the order of Ld. CIT(A) and direct the AO to delete the addition made. However AO is directed to assess the commission income @ 20 paisa per hundred of Rs. 1,57,81,000/-. Consequently ground no. 1 is partly allowed. 12....
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....,000/- per katha and thus the aggregate of consideration worked out to Rs. 15,90,48,600/-. Since the Paul brothers could not hand over the possession of the impugned land to the assessee due to on going legal disputes and therefore the assessee made payment of Rs. 1,01,000/- only as advance on the date of signing of MOU on 31.03.2012. We note that Rs. 1,01,000/- was paid by Shri Suresh Kumar Agarwal and Sri Yogendra Kumar Agarwal out of their personal sources and the same was covered in the disclosure of additional income made by them in the course of search proceedings as it is evident from table Nos. A & B which has extracted in Para 27. Therefore in view of these facts, we are not in a position to concur with the findings of the Ld. CIT(A) on the upholding the assessment order on this issue as Rs. 1,01,000/- was assessed as stated hereinabove. Consequently we set aside the order of Ld. CIT(A) on these cases and direct the AO to delete the addition. Ground no. 2 is allowed. 16. Now we shall take in IT(SS)A No. 17/Ran/2018 for AY 2013-14. The revised grounds are reproduced as under: 1. That on the facts and in the circumstances of the case, the Ld. CIT(A) erred in conf....
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....0,000/- to the P.O.A holder, Sri Tarun Kanti Ghosal as per bank statement although the facts and materials on record clearly demonstrate that only part payment of the sale . consideration was made which was duly covered by the additional income disclosed and/or assessed in the hands of the actual investors/buyers of land in course of their search/reassessment proceedings u/s 153A/147 of the Act. 6. That the Appellant craves leave to add, modify, alter any or all the grounds during the course of hearing and/or pendency of appeal. 17. Issue raised in ground no.1 is against the confirmation of addition of Rs. 1,24,00,000/- by Ld. CIT(A) as made by the AO in respect of credit entries in bank account of the assessee in IDBI Bank, Howrah. 18. Brief facts in brief are that as stated above, a search action was conducted on the assessee, a group entities and its key persons on 19.02.2014 and subsequent dates and during the course of search it was revealed that 85.51 acres of land at Renguni Mouza Dhanbad was registered in the name of assessee by power of attorney holder Shri Tarun Kanti Ghoshal . The document seized during the course of search is placed at page 57 of bunch of loose....
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....r of the land to pursue all the pending litigations relating to the said land. The Ld. A.R submitted that total financial investment including stamp fee, registration charges part payment towards sale consideration were approximately to the tune of Rs. 3.00crores. The Ld. A.R also stated that the above three persons were advised by their CA Vivek Agarwal to purchase a paper company to acquire a land in the name of said company. Accordingly the assessee was acquired by these three individuals through their C.A VivekAgarwal and entry provider Shri Bajrang Lal Agarwal. Thereafter Shri Trilokee Singh and Mr. Manik Kumar Tiwari were inducted as directors on 3.4.2012. The Ld. A.R stated that prior to that MOU dated 31.03.2012 was entered into between the assessee represented by Shri Triloki Singh and Tarun Kanti Ghoshal on behalf of Paul brothers stating therein the terms of transfer and payments in connection with the said land. The Ld. A.R also argued that the new bank account was opened in the name of the assessee on 18.04.2012 with IDBI Bank, Howrah and the amounts given by three persons namely Shri Suresh Kumar Agarwal, Shri Yogendra Kumar Agarwal and Shri Deepak Kumar Sanwaria out ....
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....d that the required funds was provided by the three persons namely Sri Suresh Kumar Agarwal, Sri Yogendra Kumar Agarwal and Sri Deepak Kumar Sanwaria out of their personal sources and after depositing the cash in the various shell companies , the cheques were received and credited in the account of the assessee company out of which the assessee company paid Rs. 1,22,44,500/- towards stamp duty and part payment of sale consideration of Rs. 79 Lakh to Shri Tarun Kanti Ghoshal. The Ld. A.R ,while referring to the statement recorded u/s 131 dated 10.06.2014 of Shri Vivek Aggarwal in his answer to question no 2, submitted that the said person admitted that that out of deposits of total credits of Rs. 4.57 Crores in the bank account of the assessee through accommodation entries, Rs. 1.32 Crore was given to Krishna Coke Pvt. Ltd. with Sri Deepak Kumar Sanwaria as director in the form of unsecured loan. The copy of the statement dated 10.06.2014 of Sri Vivek Agarwal is placed at page 461-466 of PB. The Ld. A.R submitted that Rs. 1.32 crores was admitted by Sri Deepak Kumar Sanwaria as his undisclosed income for AY 2013-14 in the course of statement recorded u/s 131 of the Act on 18.03.2016....
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....t during the year the assessee has deposited through RTGS/cheque a sum of Rs. 4,41,90,000/- in its bank account out of which Rs. 1,24,00,000/- were deposited up to 6.6.2012 which was utilized for payment of stamp duty of Rs. 1,22,44,500/-. The AO added the same as unexplained cash credit in the hands of the assessee company in the assessment framed whereas on the basis of statements recorded of Sri Suresh Kumar Agarwal, Sri Yogendra Kumar Agarwal, Sri Deepak Kumar Sanwaria and Sri Vivek Agarwal, we note that the deposit of money in the bank account of the assessee has been advanced by these individuals out of their personal sources and have been admitted as additional income and offered to tax in their respective returns of income filed in various assessment years as is evident from table A & B infra. We note that the said amount was assessed in various years in the hands of these individuals and therefore the action of Ld. CIT(A) in confirming this addition on account of unexplained cash credit cannot be sustained as the same stood offered to tax in their individual assessments and if confirmed, would result in taxing the same amount twice. Accordingly we set aside the order of Ld....
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....page 109 and added the sum of Rs. 1,83,90,000/- to the income of the assessee. 26. In the appellate proceedings, the Ld. CIT(A) partly allowed the appeal of the assessee by sustaining the addition of Rs. 1,81,45,000/- in terms of table as reproduced above thereby allowing relief to the tune of Rs. 2,45,000/- on the ground that there was a prima facie mistake in the assessment order. As is evident from the seized document AR-1 page 109 and various debit entries appearing up to 28.08.2012 in bank account maintained with IDBI Bank, the total of expenditure /investments works out to Rs. 1,81,45,000/- . The ld. CIT noted that the assessee could not rebut the findings given by the ld AO with documentary evidences and therefore addition is confirmed as there is no reason to interfere or disturb the finding of AO. 27. We have heard rival submissions and perused the material on record. We note that these expenses were incurred out of total funds deposited in the bank above three persons namely Sri Suresh Kumar Agarwal, Sri Yogendra Kumar Agarwal and Sri Deepak Kumar Sanwaria. We also note that these funds as credited in the bank account of the assessee have been assessed in the hands ....
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....ny can made payment to the previous owner on behalf of the new owners and on this score alone, the addition cannot be sustained. Besides we note that actual commission paid by these three individuals for acquisition of the assessee was duly covered in the additional income disclosed/assessed in their respective search/assessment proceedings as is evident from table no. A and B above. We have also perused the statement of Sri Suresh Kumar Agarwal recorded on 19.02.2014 u/s 132(4) of the Act, a copy of which is placed at page 405-418 of PB in which he has stated that Rs. 30,00,000/- was decided to be paid as commission to Sri Bajrang Lal Agarwal in response to quarry no. 19 and no where stated that the said amount was actually paid. The said commission was to be made for total paper investments ofRs. 27.64 crores and same was not paid in full during the year. We further note that the total investments of Rs. 27.64 Cr in the books of account/balance sheet as on the date of acquisition out of which investments to the tune of Rs. 4,41,90,000/- were liquidated during A.Y. 2012-13 and therefore only a part of the total agreed commission i.e. Rs. 22,55,500/- was actually paid by these thre....
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....rchasing draft and paying the power of attorney holder Shri Tarun Kanti GhoshalRs 60,00,000/-. For his services he was paid Rs 22,55,500/- till 3/8/2012. Sri Vivek Agarwal signed the document on 3/08/2012. The AO also noted that Page 10 of AR-5 found from the residential premises of Sri Suresh Kumar Agarwal during the course of search on 19/02/2014 that for purchasing the company M/s BCPL with paper investments worth Rs 27,64,44,668/- , commission of Rs 1,10,57,786/- was agreed to by the parties involved. As stated hereinabove , Rs 1,22,44,500/- approx.. was paid as stamp duty, Rs 60,00,000/- was to paid to Shri Tarun Kanti Ghosal as per MoU dated 31/03/2012 and if Rs 22,55,500/- was paid as commission to Vivek Agarwal , the amount comes to Rs 2,05,00,000/-. Shri Dabbu Babu further paid Rs 20.0 lakh two tunes, so total fund comes to 62,55,500/- that the accounts for up to that day. It was prepared as on 03/08/2012 which was also signed by Vivek Agarwal after receiving Rs 62,55,500/-. So commission received till 03/08/20 12 was Rs 22,55,500/- . According to the AO since the source of fund is not explained, Rs 22,55,500/- is added as undisclosed investment u/s 69B in tine hands of th....
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....ew of the above facts, we are inclined to set aside the order of Ld. CIT(A) on this issue and direct the AO to delete the addition. Consequently ground no. 4 is allowed. 36. Issue raised in ground no. 5 is against the confirmation of addition of Rs. 21,31,26,000/- by Ld. CIT(A) as made by the AO on account of undisclosed investments u/s 69B of the Act. 37. Facts in brief are that as per memorandum of understanding found from the residential premises of Sri Varan Kanti Ghoshal during the course of search, the sale consideration in respect of the land was to be paid by account payee cheque/DD. The AO observed that the assessee company has shown the land in its balance sheet as asset with corresponding outstanding amount also shown as liability. The AO procured the details sale deeds from the Stamp Valuation Office the details whereof are extracted below for ready reference: It is seen that the total consideration is shown at Rs. 22,10,26,000/ whereas the bank account showed payments of only Rs60,00,000/- and Rs 19,00,000/- aggregating to Rs 79,00,000/- have changed hands. So the AO treated the balance Rs 21,31,26,000/- (Rs 22,10,26,000/- Rs 79,00,000/-) as undisclosed invest....
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....nd Acknowledge as having been received." and in the same deeds the fact of physical transfer has been reduced in writing as "The Vendors have put this day the Purchasers in physical and peaceful possession of the said land." Thus the two ingredients of receipt of consideration and also possession of property for a sale to become absolute have been fulfilled. Further the sale deeds were registered under the Indian Registration Act 1908 before the District Sub Registrar who is an authority authorised to register the sale deeds which has been witnessed by two witnesses who are respectable citizens of that area. The claim of the assessee company that the actual terms of payment of consideration is as per the MOU is not tenable in view of the fact that the MOU is only a preliminary discussion which was reduced in writing. Thereafter, as the appellant paid full value of consideration than only the sale deed was executed. Therefore after taking into consideration the totality of facts and circumstances and the conduct of the appellant addition made of Rs. 21,31,26,000/- is hereby upheld." 39. After hearing the rival contentions and perusing the material on record, we find that the AO h....
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.... 31.03.2011, 31.03.2012, 31.03.2013, 31.03.2014 and 31.03.2015 which are placed at page 27-77 of PB that the impugned land has been accounted for the books of the assessee company at the value stated in registered sale deed on the asset side of the Balance sheet. We note that in FY 2012-13 and 2013-14 the impugned land was wrongly overstated by Rs. 1,13,80,000/- however the same was rectified and correct value of land was shown at the value as per sale deed in FY 2014-15. The consideration payable to Sri Tarun Kanti Ghoshal was shown as outstanding and was duly shown in the liability side under the head current liabilities and therefore we are not in a position to approve the conclusion drawn by the authorities that the consideration was understated by the assessee whereas as a matter of fact there was no understatement of value of impugned land. Moreover the authorities below have not brought on record any evidence substantiating the fact that the consideration was paid outside the books of accounts. In the instant case the consideration for which the impugned land was purchased was fully accounted for in the books as asset and the outstanding part of the sales consideration was s....
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....e Act. 5. That the Appellant craves leave to add, modify, alter any or all the grounds during the course of hearing and/or pendency of appeal. 42. The issue raised in ground no 1 is against the order of ld. CIT(A) upholding the addition of Rs. 5,00,000/- as made by the AO u/s 69B/69C as unexplained expenses. 43. Issue raised in ground no. 1 has already been adjudicated by us in IT(SS)A No. 17/Ran/2018 (Supra). The facts in brief are that Sri Vivek Agarwal was paid Rs. 5,00,000/ - on 09/08/2013 by Mohan Babu alias Yogendra Kumar Agarwal. The AO upon examination of page 109 and 110 of AR-1 which contained details of investment by different stake holders and expenses/ investment in the impugned land. It showed that Vivek Agarwal was paid 5.00 Lakh (decoded) by Mohan Babu. Since the source of fund was not explained, Rs. 5,00,000/- was added as undisclosed investment u/s 69B of the Act in the hands of the company M/s BCPL while the same was also added in the hands of Sri Yogendra Kumar Agarwal protectively. 44. In the appellate proceedings, the Ld. CIT(A) has upheld the above addition made by the AO u/s 69B of the Act (as undisclosed investment) as unexplained expendit....
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....l income made by Sri Yogendra Kumar Agarwal fully covers the said payment and therefore cannot be treated as unexplained expenditure u/s 69C of the Act. Accordingly we set aside the order of Ld. CIT(A) and direct the AO to delete the addition. The ground no. 1 is allowed. 47. Issue raised in ground no. 2 to 4 is against the confirmation of addition of Rs. 2,29,800/- paid to K. D. Singh, Rs. 3,00,000/- paid to Sri Tushar Kanti Ghoshal and Rs. 3,00,000/- paid to Sri Bani Brata Paul which were sustained by Ld. CIT(A). 48. Facts in brief are that during the course of search at the residential premises of Sri Suresh Kumar Agarwal MITA note book with ID mark AR-1 was found. Page 68 of the note book shows that Rs.2,29,800/ - was paid to Sri K D Singh during the financial year. The assessee also agreed that it was in connection with the land at Renguni mouza, Dhanbad. Since the source is not explained, the same is added u/s 69B in the hands of the company. The AO also noted that AR-1/page 68 shows that Rs.3,00,000/- was paid, to Sri Tushar Kanti Ghosal, Advocate during the financial year 2013-14. Since the source of cash is not explained, the amount of Rs.3,00,000/- is added as....
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....inent to mention that the addition qua these amounts were made in the hands of M/s BCPL in various assessment years as discussed above on substantive basis which was affirmed by the Ld. CIT(A) and as discussed above, whereas the additions made on protective basis in the case of instant assessee was deleted on the ground that the substantive addition was sustained as stated above. 53. After hearing the rival contentions and perusing the material on record, we find that various additions were made in the hands of the assessee were on protective basis. We have already decided the appeals in the case of M/s BCPL wherein the substantive addition has been deleted on merit on the ground that the addition made were not sustainable for the reason that the money deposited in the bank account of the M/s BCPL, and payment of commission to Vivek Agarwal and various other persons and also the incidental expenses incurred in connection with the purchase and registration of Renguni Land were duly offered to tax in the hands of Shri Suresh Kumar Agarwal, Shri Yogendra Kumar Agrawal and Sri Deepak Kumar Sanwaria as is apparent from Table A & B above. The necessary details qua these expenses incur....
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....hri Shantanu for registry and Rs. 2,00,000/- was spent for registry fee. Thus the total amount comes to Rs. 1,02,45,000/- as per the seized documents. Accordingly the AO added Rs. 1,26,90,000/- in the hands of assessee on protective basis. Similarly other additions were made. We have perused Table A extracted in para 27 on which the total expenses incurred and the impugned land was shown in different years comprised of the amounts added in the hands of the assessee by AO and Table Bin para 27 expenses, contains the details of and the source out of which these expenses/payment were incurred/made. In our view, since the sources of these cheques or investments have been offered to tax by way of additional income in the hands of various persons as stated in Table B on the basis of which we have deleted the addition in case of M/s BCPL Therefore the addition made on protective basis in the hands of Suresh Kumar Agarwal cannot be sustained and the AO is directed to delete the addition . Consequently the appeals of the revenue is dismissed. 55. In the result, all the appeals of the assessee are allowed and the appeal of the revenue is dismissed. Order is pronounced in the open court....
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....on with land 13 Padio Tushar Kanti Ghosal, Advocate 14 Cash deposited in bank for payment to Bani Brata Paul towards Renguni Land TOTAL UND SCLOSED INVESTMENT/EXPENSES ON RENGUN LAND 500,000 AR-1, page 109 229 800 AR-1, page 68 300,000 AR-1, page 68 300,000 Indusind Bank Account of BCPL for FY 2013-14 35,710,700 Document 3 Table No. B 5 No 1534 Rs R$ Suresh Kumar Aganva SKA 2008-09 280.179 2009-10 AY. 2010-11 3,877,474 293,070 2011-12 2012-13 2013-14 2014-15 Yogendra Kumar Agarwal (YKA 2012-13 900,000 2013-14 Rs 70 asto vards Rengun land 10,407,003 11.307.003 1.175.988 4,400,000 9,750,000 2,000,000 21.776,711 21,776,711 elace 300 Return of incomeus 153A Revised Computation of income 2645 for As 2008-09 to 2014-15 get 571-655 of the B Disclosure Petition of WA-per-510 of the PB Assessment Order u/s153A of KA for A. 2013-14 assessing 7,000,000 undisclosed investment of Rs. 10407 000/- which includes Rs. 70 akhs on Renguni Land-roges 358-339 (Deepak Kuma: Sanwaria A. 2013-14) addition made us 147 in the case of DKS for AY 2013-14- no appealed before ....