TaxTMI 
TaxTMI 
2023 (11) TMI 1327
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....dertaken by revenue authorities upon all of them, described together as "Greater Kailash Hospital Group" and the most prominent issue involved in all appeals is same; therefore these appeals were heard together and are being disposed of by this consolidated order for the sake of brevity and convenience. It is agreed by both sides that the assessee "M/s Greater Kailash Hospital Private Limited" can be treated as a lead-case and its appeal must be decided first and thereafter other appeals. We proceed as requested by parties. IT(SS)A No. 6/Ind/2022 - M/s Greater Kailash Hospital Private Limited: 3. Brief facts are such that a search u/s 132 was conducted on 06.12.2016, pursuant to which assessments of AY 2011-12 to 2016-17 were framed u/s 153A and AY 2017-18 was framed u/s 143(3). The present appeal relates to AY 2017-18 for which the assessee filed return declaring a total income of (-) Rs. 2,57,91,917/- including undisclosed income of Rs. 2,29,00,000/- admitted/surrendered by assessee during search u/s 132(4). While framing assessment, the AO made two adjustments, namely (i) he assessed the undisclosed income of Rs. 2,29,00,000/- u/s 68 read with section 115BBE instead of 'no....
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....that the assessee requested to withdraw the surrender amount after a prolonged period of search stating that surrender was made under undue stress and pressure. Whereas the assessee filed its return of income after 10 months of search showing this undisclosed income and during the assessment proceedings, the assessee never requested to withdraw the surrendered amount shown in return of income filed in response to notice under section 153A of IT oct 6. Whether on the facts and in the circumstances of the case, the Ld. CIT(A) has erred in holding that the surrendered amount of cash of Rs 229,00,000/- was deposited in bank account out of cash in hand available with the assessee, especially when such contention was never made by the Assessee before the AO. Asst. Commissioner of Income Tax (Central) Ujjain (Stationed at Indore) 7. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in ignoring the fact that during the search proceedings as well as assessment proceedings, the assessee failed to explain the source of cash deposit in its bank account with evidences. The Ld. CIT(A) has completely overlooked the fact that....
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.... 14. The appellant craves right to add, amend or alter the grounds of appeal during or before the date of hearing of appeal. 4. Ld. DR for revenue submitted that the last Ground No. 14 is general in nature and no adjudication is required. Out of remaining 13 grounds, Ground No. 1 to 10 involve 1st issue of undisclosed income of Rs. 2,29,00,000/- and Ground No. 11 to 13 involve 2nd issue of addition of Rs. 10,00,000/-. Accordingly, the grounds can be grouped and adjudicated. Ground No. 1 to 10: 5. In these grounds, the revenue precisely claims that the CIT(A) has erred in excluding the income of Rs. 2,29,00,000/- from total income which was rightly assessed by AO in terms of section 68 r/w section 115BBE. 6. Ld. DR for revenue explained the facts of this issue in precise terms. He submitted that the assessee-company and its directors (Dr. Anil Bandi and Dr. Radhika Bandhi) are engaged in medical business/profession. After declaration of demonetization by Govt. of India, the assessee-company and directors made a total cash-deposit of Rs. 6,11,56,500/- in demonetized currency notes of Rs. 500 and Rs. 1,000 on a single day of 15.11.2016 in their respective bank accoun....
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....be initiated for the amount of disclosure made u/s 132(4) of the Act. Hence, penalty proceedings u/s 271AAB are hereby initiated for assessment year 2017-18." 7. Thus, the AO assessed the income of Rs. 2,29,00,000/- as declared by assessee in its return but, however, with a limited modification i.e. while the assessee declared impugned income as "Income from medical business/ profession", the AO characterized it as income u/s 68 read with section 115BBE because the assessee was unable to put forth any evidence in support of income from medical business/profession. However, during first- appeal before CIT(A), the assessee made an altogether different claim that the impugned income was not assessable at all and the same must be excluded from total income. The CIT(A) allowed assessee's claim by passing following order: 4.4.2 I have considered the facts of the case, plea raised by the appellant and findings of the AO. As a matter of fact the appellant has filed return of income u/s 139(1) under protest with a note that the income surrendered during the course of search was under undue stress and pressure and the same is to be withdrawn for total income. Similar plea was mad....
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....officers should: (a) draw their attention to any refunds or relief to which they appear to be clearly entitled but which they have omitted to claim for some reason or other; (b) freely advise them when approached by them as to their rights and liabilities and as to the procedure to be adopted for claiming refunds and reliefs." (ii). The decision of Hon'ble ITAT Kolkata Bench in the case of Sushil Kumar Das Vs Income Tax Officer as reported in [2011] 15 taxmann.com 52 wherein it has been held that: "9. We have heard the rival submissions and perused the materials available on record. The moot question arising out of this appeal is whether the income determined by the Assessing Officer on the basis of the return filed by the assessee can be a figure lower than the income returned by the assessee. It is a well settled that the principle for determining the taxable income of the assessee under the Income-tax Act should be within the purview of the law in force. If the taxable income determined by the Assessing Officer is not in accordance with such principle it is open to the assessee to contend the same before the higher authorities to follow th....
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....t question which arises here is that whether the appellant can withdraw income surrender/declared in return of income. Hon'ble Apex court in the case of CIT vs Shelly Products 129 taxmann 271 by passing a landmark judgment has held that any assessee by any way deposited abundant advance tax or self assessment tax which is in excess of liabilities can claim refund after making claim before AO and the AO after being satisfied shall grant relief as governed by section 240 of the Act. The relevant extract of judgment is reproduced as under:- "31. We cannot lose sight of the fact that the failure or inability of the revenue to frame a fresh assessment should not place the assessee in a more disadvantageous position than in what he would have been if a fresh assessment was made. In a case where an assessee chooses to deposit by way of abundant caution advance tax or self-assessment tax which is in excess of his liability on the basis of return furnished or there is any arithmetical error or inaccuracy, it is open to him to claim refund of the excess tax paid in the course of assessment proceeding. He can certainly make such a claim also before the concerned authority calcula....
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....ded that the surrender was made without any iota of incriminating document on record. I find strong force in the contentions raised by the appellant as there is no reference of any incriminating document in the body of assessment order by the ld AO. The ld AO has placed complete reliance on statement of director of the appellant recorded u/s 132(4), during the course of search and without making any reference of any seized material in support of his allegation. Hon'ble Supreme Court in the case of Pullangode Rubber Produce Co. Ltd vs State of Kerala (1973) 91 ITR 18 (SC) has categorically held that an admission in statement recorded on oath is an extremely important piece of evidence but it cannot be said that it is conclusive and it is always open to the person who made the admission to show that it is incorrect. In the instant case, the surrender was not supported by any incriminating document seized during the course of search and seizure proceedings and the appellant thereafter, while filing return of income u/s 139(1) and even during assessment proceedings with supportive evidences has made it ample clear that the admission made was under stress and the cash deposit is ful....
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....lief given by CIT(A) to assessee by upsetting the entire case. Ld. DR strongly supported the order of AO and opposed the order of CIT(A). He requested to uphold AO's order on following contentions: (i) Referring to revenue's plea in Ground No. 3 and 4, Ld. DR submitted that in the statements recorded by authorities u/s 132(4), the assessee himself admitted undisclosed income of Rs. 2,29,00,000/-. Thereafter, the assessee himself declared the said income in its return of income filed in response to notice u/s 153A. Thereafter, the AO assessed what was already declared by assessee in return of income. The AO only made a limited modification that he re-characterized the impugned income as income u/s 68 against assessee's claim of business income and that too for the reason that the assessee could not submit any evidence to establish as having earned from medical business/profession. Ld. DR submitted that the AO has not made any addition or not assessed any newer income from his side; he assessed only that income which was already there in the return of income. Ld. AR submitted that the controversy between AO and Assessee could at best be for re-characterisation of income but ....
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....is and the same was also submitted to CIT(A) which is noted on Page No. 43 of order of CIT(A). He drew us to Page 53 of Paper-Book and submitted that in the "Computation of Total Income" filed to AO, the assessee has given a "note" to the effect that the deposit of Rs. 2.65 crore was made out of cash in hand available in assessee's regular books on 08.11.2016 but due to high handedness and great pressure by search officials, the directors were forced to surrender at least 90% of the amount deposited in Bank A/c. It is further mentioned in the said note "To avoid litigation and penal proceedings, income surrendered during search (though explained from regular books of accounts), is being offered to tax in the computation of income." He also drew us to Page 114-115 of Paper-Book to show that in the letter dated 22.11.2018 filed during assessment-proceeding, the assessee re-iterated those very submissions to AO. Thus, Ld. AR submitted, the assessee included impugned income in the 'return of income' on the basis of surrender and to avoid litigation, although there was no actual/additional income with assessee and for that reason the assessee has not passed any entry of undisclosed inco....
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....Rs. 2,65,00,000/- in bank a/c. He drew us to Q.No. 7, where the assessee stated to have made withdrawal of Rs. 36,00,000/- from Bank A/c. It is after such statements that the assessee accepted to have earned the 'undisclosed income' of Rs. 2,29,00,000/- not recorded in books of account and agreed to disclose the same in return and pay tax. Yet again in Q.No. 11, the assessee admitted undisclosed income of Rs. 2,29,00,000/-. Ld. DR submitted that the undisclosed income of Rs. 2,29,00,000/- is exactly and correctly admitted by assessee based on difference of Rs. 2,65,00,000/- (the amount deposited in bank) and Rs. 36,00,000/- (the source of deposit). Therefore, the very claim of assessee is that there was a force to surrender at least '90% of the amount deposited in Bank A/c' and that is why assessee made surrender of Rs. 2,29,00,000/-, is an after-thought, totally wrong and far from truth. Ld. DR submitted that the assessee was very pretty sure that he is able to explain only part-amount and that is why admitted the remaining amount and declared in return. 11. In counter-reply to Ld. DR's rejoinder, Ld. AR submitted that the withdrawal of Rs. 36,00,000/- explained by assessee in ....
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....) then the assessee himself declared exactly same amount of admitted income in return of income filed in response to notice u/s 153A; (iv) during assessment- proceeding before AO, the assessee nowhere retracted/objected to assessment of income; the assessee only tried to explain the nature of income as coming from medical business/profession which the AO did not accept; (v) therefore, the AO assessed the same income as declared by assessee in return and the only modification done by AO was re- characterisation of nature of income. Thus, right from search-action till completion of assessment, the assessee had no objection, rather the assessee himself admitted, acknowledged and declared the impugned income in the statutory return filed u/s 153A. It is only in first-appeal that the assessee sought exclusion of income and the CIT(A) accepted assessee's claim. Now, the question is whether the relief given by CIT(A) is in order or not? 13. At first, we look into the decision of Hon'ble apex court in Banna Lal Jat Construction (P) Ltd. Vs. DCIT (2019) 106 taxmann.com 128 (SC). A passage from the decision is re-produced below: 20. .... We may in this connection refer to earlies....
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....luded thus "Subsequent retraction from the surrender without having evidence or proof of retraction is not permissible in the eyes of law. The statement recorded during the course of search action which was in presence of independent witnesses has overriding effect over the subsequent retraction". Thus, the Hon'ble Supreme Court is pretty hard in accepting retraction even. In the present appeal, the assessee has admitted undisclosed income in the statements recorded in presence of two witnesses u/s 132(4) with a clear acceptance that no force was exercised upon it. Even after completion of search, the assessee did not make any retraction/complaint to authorities. The matter does not stop here. Even in the return of income filed to tax department, the assessee himself included the impugned income. Even during assessment-proceeding undertaken by AO u/s 143(3), the assessee neither objected to inclusion of income nor made any claim for exclusion of impugned income before AO; the assessee only claimed that the impugned income was income from medical business/profession. Thus, the AO assessed only that income which was already admitted, offered and included by assessee in return of inco....
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....f this very assessee playing the same strategy, dealt by Co-ordinate Bench of ITAT, Indore in ITA No. 628/Ind/2019, order dated 10.02.2023 for AY 2013-14. In that case, a survey was conducted in past upon this very assessee wherein the assessee surrendered income of Rs. 5,83,25,000/-. Thereafter, in the return of income, the assessee included such income. The AO completed assessment after making some more additions/disallowances apart from assessing the undisclosed income already offered by assessee. The assessee allowed the AO to complete assessment. Then, the assessee went in first- appeal to contest only newer additions/disallowances made by AO but the assessee did not have any objection qua the undisclosed income. After finalisation of first-appeal, the assessee came to ITAT in a belated-appeal and requested to allow withdrawal of 'undisclosed income' by filing additional grounds. The ITAT dismissed assessee's appeal; the order of ITAT is re-produced below: "3. The ld. Representative of the assessee (ld. AR), drawing our attention towards the affidavit of Dr. Anil Bandi sworn on 23.05.2019, submitted that the assessee company had filed its return of income for AY 2013-....
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....eplying to the above, the ld. Sr. DR strongly opposed the condonation of delay and admission of new/additional grounds of appeal for AY 2013-14. 7. Drawing our attention to the relevant assessment order for AY 2013-14 dated 15.02.2016 u/s 143(3) of the Act, the ld. Sr. DR submitted that the assessee himself filed the return of income on 30.03.2013 declaring the taxable income at Rs. 5,83,25,000/- and the case was selected for scrutiny u/s 143(3) of the Act. The ld. DR further submitted that as per concluding para 8 of the said assessment order, it is clear that the AO accepted the return of income and made two additions only viz., addition of Rs. 6,22,252/- u/s 36(1)(iii) of the Act and Rs. 7,00,852/- u/s 36(1)(va) r.w.s 43B of the Act. The ld. Sr. DR further drew our attention towards Form No.35 filed by the assessee before the ld. CIT(A) dated 31.03.2016 and submitted that the assessee has raised the sole ground challenging the addition made by the AO of Rs. 7,00,852/- and no other ground has been agitated or raised before the ld. CIT(A). Further drawing our attention towards the impugned first appellate order of the ld. CIT(A)-1, Indore, dated 24.09.2018, the ld. Sr. DR....
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....e ld.CIT(A) and the ld.CIT(A) allowed the sole ground of the assessee deleting the said addition and, thus, there was no issue or ground for the assessee left unadjudicated to agitate before this Tribunal against order of CIT(A) dated 24.09.2018 for AY 2013-14. 9. The ld. Counsel of the assessee has prayed that the additional grounds of the assessee were not agitated before the ld. CIT(A), but, subsequently as advised by the tax consultant thus the same are being raised first time before the Tribunal. Therefore, the same may kindly be admitted for adjudication and the matter be restored to the file of the AO for examination and verification. 10. Now, we proceed to adjudicate the issue of condonation of delay of 156 days in filing the present appeal by the assessee. In this regard, in para 2.6 of the application/affidavit it has been mentioned as under:- "2.6. However, during the course of appeal as filed against the order passed under section 153A r.w.s. 143(3) of the Act, it was explained that additional income to the tune of Rs. 5,83,25,000/- was offered for tax in the return of total income for the Assessment Year 2013-14 even though no corresponding e....
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....isallowances made by the AO in the assessment order and, in the present case, the assessee availed this opportunity and filed the appeal before the ld. CIT(A) raising the sole ground of disallowance of Rs. 7,00,852/- which was allowed by the ld.CIT(A) vide order dated 24.09.2018 and no grievance of the assessee was left unaddressed after the order of the ld. CIT(A)-1, Indore dated 24.09.2018. 13. In the case of National Thermal Power Corporation Ltd. (supra), the Hon'ble Supreme Court held that: 'the power of the Tribunal in dealing with appeals is, thus, expressed in the widest possible terms. The purpose of assessment proceedings before taxing authorities is to assess correctly tax liability of as assessee in accordance with the law........ Then, the additional ground which goes to the root of the matter can be adjudicated without any extraneous material on the basis of the material already available on record and the same may be admitted for adjudication as additional ground.' But, in the present case, the assessee is seeking admission of additional ground and restoration of the same to the file of the AO for examination, verification and adjudication. Therefore, as per....
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.... Act and first appellate order dated 24.09.2018, it is clearly discernible that there was no such issue either before the AO or before the ld. CIT(A) for their consideration and adjudication. 15. Therefore, the application of the assessee for condonation of delay of 156 days and admission of new/additional grounds No.1 to 4 are dismissed. 16. In the result, the appeal filed by the assessee, being not maintainable is dismissed in limine." Apparently, one may say that the ITAT did not condone the delay and dismissed appeal on belated-filing ground. That is true but a careful reading of Para No. 14 of order clearly demonstrates that the ITAT also observed that the grievance of the assessee pertaining to the grounds was neither discernible from assessment-order (nor from order of first appellate authority because of specific situation of that case). The Co-ordinate Bench of ITAT noted that in assessment-order, the AO has accepted the returned income of Rs. 5,83,25,000/- and has made only two additions, totalling to Rs. 13,23,104/-. Therefore, the assessee, by way of raising new/additional ground cannot be allowed to retract or revise its returned income without fil....
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....sessment-order, it is found that the AO has made this addition for notional/hypothetical income of interest. The CIT(A) has, however, deleted addition, in Para No. 4.2.6 of appeal-order, by observing that the AO is not justified in bringing notional/hypothetical income to tax which was never earned by assessee. We agree with the view taken by Ld. CIT(A). Therefore, these grounds are dismissed. IT(SS)A No. 4/Ind/2022 - Dr. Anil Bandi: 21. The grounds raised in this appeal are as under: 1. Whether on the facts and in the circumstances of the case and in law, the ld. CIT(A) has erred in law in accepting fresh evidence/grounds about withdrawal of income disclosed in return amounting to Rs 1,01,50,000/- in complete disregard to rule 46(A) as condition prescribed under clause (a)-(d) of rule 46A(1) of IT rules 1964 were not satisfied 2. Whether on the facts and in the circumstances of the case and in law, the ld. CIT(A) has erred in accepting the plea of assessee regarding claim of withdrawal of income disclosed in the return of income amounting to Rs 1,01,50,000/- keeping in view that this claim was never made before th....
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.... justified his claim that undisclosed income was earned from medical profession, However, Ld. CIT(A) accepted the same ignoring that the retraction of assessee is neither reasonable nor supported by evidences 8. Whether on the facts and in the circumstances of the case, the Ld. CIT(A) has erred in accepting the plea of assessee so as to explain the nature and source of investment in excess jewellery found as seized during search as well as admitted undisclosed income by the assessee as no such explanation was given by the assessee during the search operation. The contention made by the assessee after search is merely an afterthought. 9. Whether on the facts and in the circumstances of the case, the Ld. CIT(A) has erred in ignoring the decision of Honble SC in the case of Bannalal Jat Construction (P) Ltd vs DCIT[2019] 106 Taxmann.com 128(SC) wherein hon'ble supreme court has held that since the assessee has itself declared the undisclosed income on the basis of evidence found during search, the mere fact that the director of assessee company retracted from statement at later point of time, could not make su....
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....the AO inferred that the assessee had made a cash loan of Rs. 3,00,000/- to M/s SPS Jewellers. When the AO show- caused assessee to explain source, the assessee replied that these papers did not belong to him or any family member. The assessee further submitted that these papers were left by some patient in hospital and they were kept by assessee in safe custody for return to owner on demand. However, the AO was not satisfied with submission of assessee and made addition. Ld. DR supported AO's action and prayed to uphold the addition. 27. Per contra, Ld. AR for assessee carried us to the copies of seized documents placed in Paper-Book at Page No. 85 and 86 and successfully demonstrated that both of the documents are blank and do not contain any detail as to the name in whose favour they were issued by M/s SPS Jewellers. The AO has wrongly and on presumption basis, attributed those documents to assessee. Ld. AR submitted that the AO has disbelieved assessee's factual submission that those documents were left by some patient in hospital and made addition. Ld. AR submitted that the CIT(A) has rightly given credence to assessee's submission and deleted addition; his order must be up....
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....Girdharilal vs. CIT (1954) 26 ITR 736 (SC). 4.4.3 In view of the above discussion, the AO was not justified in making addition of presumption basis and therefore, addition made by the AO amounting to Rs. 3,00,000/- is deleted. Therefore, appeal on this ground is allowed." On perusal of seized papers, we find that the CIT(A) has passed a well- reasoned order on this issue. Therefore, his order does not warrant any interference from us. We, therefore, uphold his order and these grounds of revenue are dismissed. IT(SS)A No. 5/Ind/2022 - Dr. Radhika Bandi: 29. The grounds raised in this appeal are as under: 1. Whether on the facts and in the circumstances of the case and in law, the Id. CIT(A) has erred in law in accepting fresh evidence/grounds about withdrawal of income disclosed in return amounting to Rs 1,61,50,000/- in complete disregard to rule 46(A) as condition prescribed under clause (a)-(d) of rule 46A(1) of IT rules 1964 were not satisfied. 2. Whether on the facts and in the circumstances of the case and in law, the Id. CIT(A) has erred in accepting the plea of assessee regarding claim of withdra....
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....fact that the assessee has not justified he claim that undisclosed income was earned from medica profession, However, Ld. CIT(A) accepted the same ignoring that the retraction of assessee is neither reasonable nor supported by evidences. 8. Whether on the facts and in the circumstances of the case the Ld. CIT(A) has erred in deleting the addition of Ra 36,27,731/- out of Rs 51,71,824/- made u/s 69A on account of unexplained investment in Jewellery which was initially disclosed by the assessee during the search proceedings u/s 132(4) of IT Act in her statements. 9. Whether on the facts and in the circumstances of the case the Ld. CIT(A) has erred in accepting the plea of assessee as to explain the nature and source of investment in excess jewellery found as seized during search as well as admitted undisclosed income by the assessee as no such explanation was given by the assessee during the search operation. The contention made by the assessee after search is merely are afterthought 10. Whether on the facts and in the circumstances of the case the Ld. CIT(A) has erred in ignor....
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....th-tax return of assessee supported by Valuation-Report dated 27.07.2007 1,399.95 355.75 1,755.70 32.10 Accepted by AO - for family members of assessee 753.72 112.11 865.83 7.71 Excess 1,092.13 372.95 1,465.08 36.41 Ld. DR submitted that the excess quantities are worked out on the basis of Board Circular and such excess quantities were only seized by search- authorities and assessed by AO at Rs. 51,71,824/-. Ld. DR submitted that due credit has already been given as per Board Circular and the assessee did not deserve any more credit. But, however, the CIT(A) has wrongly allowed more credit to assessee and given relief to assessee, which is not justified. Therefore, the revenue is against the order of CIT(A). 34. Per contra, Ld. AR for assessee relied heavily upon the order of CIT(A). He submitted that the search was conducted on 06.12.2016 and immediately thereafter the assessee filed an affidavit dated 15.12.2016 to Investigation Wing with supporting evidences (Page 110-113 of Paper-Book), explaining correct and complete details of sources of jewellery and the same explanation was again submitted to AO vide letter dated 14.12.2018 du....
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....n Cts.] Amount [in Rs.] 1 SBG/PD/MAR/13/2011-12 dated 16-03-2012 Shree Bhairav Gems NIL 1.09 2,54,000 2 86 dated 31-03-2013 Harshvardhan Ishipal [A HI Diamonds Pvt Ltd] NIL 1.070 2,95,000 3 90 dated 06-07-2014 Harshvardhan Ishipal [A HI Diamonds Pvt Ltd] NIL 1.010 3,60,000 4 Harshvardhan Ishipal [A HI Diamonds Pvt Ltd] NIL 1.010 3,60,000 5 TID/CM/2109 dated 05-07-2015 Tanishq [Titan Company Limited] 6.700 0.696 61,262 5 38 dated 07-07-2016 Harshvardhan Ishipal [A HI Diamonds Pvt Ltd] NIL 0.920 53,000 Total 6.700 5.796 13,86,262 The appellant has also filed details of gift received by her from her mother Dr Kusum J Singh on her birthday on 24.10.2016 which has been purchased by cheque. The details of purchase bills is summarized as under:- S.No Bill No./ Date Name of Supplier Gold Quantity [in Gms.] Diamond Quantity [in Cts.] Amount [in Rs.] 1 94 dated 11-07-2014 Harshvardhan Ishipal [A HI Diamonds Pvt Ltd] 9.114 2.180 1,17,414 2 105 dated 20 10 2016 Harshvardhan Ishipal [A HI Diamo....