TaxTMI 
TaxTMI 
2025 (1) TMI 1640
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....ils/document recovered during the search proceedings and the assessee has failed to explain the transactions in respect of papers/material found during the course of assessment proceedings and also during appellate proceedings. 2. On the facts and in the circumstances of the case and in law, the CIT(A) has erred in deleting the addition of Rs. 27,60,18,560/- made by the AO on account of unexplained investments in DKD Coins/lending DKD despite the facts that addition has been made on the basis of incriminating details/document recovered during the search proceedings and the assessee has failed to explain the transactions in respect of papers/material found during the course of assessment proceedings and also during appellate proceedings. 3. On the facts and in the circumstances of the case and in law, the CIT(A) has erred in restricting the addition to Rs. 33,51,040/- as against addition of Rs. 85,44,151/- made by the AO on account of unexplained investments in ATS Coins despite the facts that addition has been made on the basis of incriminating details/document recovered during the search proceedings and the assessee has failed to explain the transactions in respe....
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....ubject, the learned commissioner of the Income Tax (Appeals) has erred in referring for special audit u/sub. Section 142(2A) of the Income Tax Act, 1961 without any cogent reason. 2. On the facts and in the circumstances of the case as well as law on the subject, the learned commissioner of the Income Tax (Appeals) has erred in confirming the action of the Assessing Officer in initiating assessment proceedings and passing Assessment order u/s. 143(3) of the Act not in within time limit. It is contradictory to the limitation of the income Tax Act, 1961. 3. On the facts and in the circumstances of the case as well as law on the subject, the learned commissioner of the Income Tax (Appeals) has erred in confirming the action of the Assessing Officer in making addition of Rs. 3,69,68,256/- on account of alleged unexplained investments in Crypto-currency, Dekado, ATC and Bitconnect. 4. On the facts and in the circumstances of the case as well as law on the subject, the learned commissioner of the Income Tax (Appeals) has erred in confirming the action of the Assessing Officer in making addition of Rs. 50,12,212/- on account o: alleged unexplained expenditure fo....
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.... also recorded the modus operandi of transaction in Crypto Currency/virtual currency on page No. 5 to 16 of assessment order. On subsequent pages of assessment order, the AO noted about seized material vide Annexure-A-1 to A10, & PA-1 to PA-8, BF/1 and BF/2 and the reply of assessee in respect of all the annexures/seized materials. The AO undertaken the assessment proceedings through Income Tax Business Application (ITBA) Portal, despite the fact that it was a case of assessment by the Central Circle. The AO (AO) at different places on various pages recorded the response of assessee in respect of various seized material. 4. During assessment, the AO noted that during search action at assesses premises various incriminating evidence in physical as well as in digital devices were found and seized, specifically with regards to DKD, ATC and Bitconnect. The assessee created several user IDs in series and through such series of IDs invested in DKD, ATC and Bitconnect. DKD was operated through multilevel marketing strategy, wherein the investor would earn referral point received on adding new investor. DKD holder also had options of lending the coins for earning interest and gain on fl....
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.... response to the show cause notice the assessee denied of his investment in ATC. The AO held that all such evidence were found from the laptop of the assessee and are admissible evidences. The AO was of the view that total coin deposits in the account of assessee from ATC (Akash) was of 196,735.91 and bonus coins were of 41,975. Total coin of ATC (Jiyansh) was 1,50,213 and bonus coins were 39,794.84. The AO based on rate of ATC on website (http://www.coinbase.com/price/atc-coin) was of the view that rate of ATC as on 03/09/2017 was @ Rs. 34/- per coin, hence worked out the unexplained investment as table on page No. 147 of assessment order. The AO worked out investment in ATC coins at Rs. 85,44,151/- and treated the same as unexplained investment. However, the bonus coins value worked out at Rs. 19,18,616/- as unaccounted income. 6. The AO further noted that assessee also made investment in Bitconnect Coins (BCC), the details of which were found from the residence of assessee in file seized from HDD vide B1-PO/HDD/OAE/D Drive/Desktop/Personal acs-a excel file in the name Sanjay Fuwa Final Sheet-41. On show cause the assessee denied his investment in BCC. The AO held that digital....
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.... at C-605, Laurels, Bhartana, Vesu, Surat. The assessee was asked to explain the source of such expenditure. The assessee in response to the show cause notice explained the source of such expenditure and submitted that all the expenses are recorded in the books. The assessee submitted that expenses were incurred on furniture and fittings also filed ledger account of carpenter and fittings. The reply of the assessee was not accepted by AO by taking view that the assessee was required to match the details of expenditure with payments from bank. No such information is matching with payment through cheques or demand draft is furnished by assessee. The AO treated entire expenditure as unexplained and made addition under section 69C of Rs. 1,01,57,149/-. The AO passed assessment order under section 143(3) on 11.06.2021. The assessment order is running into 198 pages. The assessment order does not contain specific contents of various show cause notice nor the dates of summery of various reply filed by the assessee. 9. Aggrieved by the additions in the assessment order, the assessee filed appeal before ld CIT(A)-Central Circle Surat. Before ld CIT(A) the assessee filed detailed written ....
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....l. The assessee purchased DKD coins before launching in market. Thus, the costing of coins purchased by assessee cannot be compared with coins launched in market. The assessee received such coins under ESCROW account, the assessee utilized the same coins to make investment in regular income scheme of DKD with different IDs with intention to get referral coin with bonus coins and interest coins. The assessee made a numerous IDs in a series and invested coins through such various IDs. Locking period of 4 months was in the scheme. Excel sheets containing same details in different sheets. The DKD platform was closed down in the months of January 2018 and full investment of the assessee become nil. The assessee lost all his investment in DKD in the same year. The AO while making addition mentioned three excel sheets namely DKDFULL.xls, DKD FULL(l). xls, DKD FULL(2). xls in digital data and as per these sheets the assessee made investment in DKD in various occasions. The AO has not considered the sheets named "stake" from all excel sheets and added total coin in both sheets DKD Full and DKD FULL(1) and also added total sheets named "coins" from excel sheet DKD FULL(2). Xls. All three exc....
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....assessee has explained procedure of investment in DKD coins but the AO ignored all the procedure and made addition in all possible way of presumption in multiple way. The DKD platform was closed in the month of January, 2018 and entire investment of assessee had become NIL. The assessee lost all his investment in DKD in the same year. There is no question of making addition of unexplained investment in DKD in the same year. 11. Against the additions of investment in ATC coins, the assessee stated that he never made any investment in any other currency except DKD. In his without prejudice submission, the assessee stated that in the downloaded folder of assessee's laptop" Sanjay_hp_laptop_320_gb", the assessee explained that in case any document is downloaded from e-mail or WhatsApp web or online side then such document is stored in downloaded folder. Staff of the assessee, who was sitting in the office, operated such laptop. There could be possibility that such file was downloaded in the laptop of assessee. The excel sheet which is made the basis of addition contained details of ATC coins on two different dates which is the same format of two tables of two different dates. The AO....
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....asis of which the AO made addition, such sheet does not belong to assessee. The assessee provided name and address of such person but the AO not accepted such explanation and made addition on account of sales and undisclosed business income out of books aggregating of Rs. 85,50,954/-. The assessee further stated that neither the assessee nor his family member is engaged in the business of cashew. The assessee also given the name of Manish Patel and mobile number, who was the manager of Dipakbhai, who was in the business of cashew in the foreign country and all transactions are written in the diary as Annexure-A/3. Such diary/Annexure- A/3 is related to the business of Manish Patel. Despite informing the AO about all the details, she has not conducted any enquiry and made addition in the hands of assessee. In without prejudice submission, the assessee stated that that the diary contained turnover of 48,71,69,000/- of currency of Conakry, however, there is no transaction in this diary. Total transaction written in the diary is only 25,83,36,650/- in the currency of Conakry. The value of which in Indian rupees is only Rs. 17,90,803/-. So even it is assumption that the transaction rela....
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.... several investor IDs to get such benefit of scheme. The assessee also earned income on lending coins. The assessee dealt with this DKD coins for a period of five months, wherein he invested in the initial offering in the month of September,2017 and referral and lending scheme remained in force till January, 2018. However, the contention of the assessee is that he merely invested in 193123 DKD coin and that too in initial coin offering in September 2017, which is evident from Escrow account found in search action. The coin allotted were kept in escrow account till the lending scheme started in November, 2017. In November, 2017, the assessee started lending scheme wherein new investors were roped in by virtue of multi-level marketing. The AO relied upon three excel sheets of DKD FULL, DKD FULL1 and DKD FULL2. The Ld.CIT(A) on detailed verification of these sheets found that the coins acquired by assessee are found and different lots and can be identified with Escrow account of DKD coins. For instance, 19971 coins under name SAPI9801 found in the DKD FULL2.xls-coins find mention in DKD FULL-stake with same ID SAPI9801 and same number of coins of 19971. Similarly, the same coins are f....
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....taxed in the hands of the assessee. 16. On the quantum of investment in 193123 DKD Coins, the ld CIT(A) noted that the assessee acquired these coins in the ESCROW account in September, 2017. DKD Coins were launched in September, 2017 in Dubai, the appellant had invested in the ICO for the said coins. It is the case of assessee that he invested at the rate of USD 2. Such fact is also evident from the investigation done by Crime Investigation Department (CID), Surat which is available in public domain, copy of the First Information Report (FIR) lodged by one Girish Kumar Dhanjibhai Sheladiya on 10.01.2019 against Divesh Darji who claimed to be dealer in the DKD Coins in Surat. In such FIR, the investor who had lost his investment has complained against Divesh Darji that he had invested in DKD @ USD 1.00 per DKD Coin and lost it. The assessee made the investments in these coins in cash. No evidence of the actual investment was found during the course of Search. The AO has quantified the investment by the assessee on the basis of a sheet from the hard disk, of which is scanned by the AO in para 21.2.3.6 of the assessment order. The AO took the value of the DKD coins as on 01.12.2017....
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....estricted the addition on investment of 98,560 coins @ Rs. 34/- per coin. Thereby deleted the remaining addition of Rs. 71,11,727/- (1,04,62,767- 33,51,040) 18. On the second part of addition on the basis of excel sheet "Sanjay Fuwa final sheet-41-2", sheet two of Rs. 18,55,130/-. This addition is in respect of 1,50,213/- coins at level 1 to 9 @ Rs. 12.35 per coin. The ld CIT(A) noted that the AO has worked the total investment at Rs. 18,55,130/- (1,50,213 coins [x] Rs. 12.35). Before the AO, the assessee submitted that these coins do not belong to him but did not specify the person to whom these coins pertain to / belong to. However, the AO held that as the evidence of holding these coins was found in the premises of the assessee, the onus was on the assessee to furnish the details and as the assessee has failed to furnish the details, as per the provisions of Section 132(4A) of the Act it will be held that the investment is made by the assessee. The ld CIT(A) concurred with the finding of AO and accordingly, the unexplained investment quantified by the AO of Rs. 18,55,130/- was upheld. 19. With regards the bonus coins which were treated as sold by the AO and made an additio....
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....aterial which was inventorized as Annexure A-3, was found in the premises of the assessee. The assessee claimed that this sheet belongs to Manishkumar M. Patel. As per the said statement, the AO held that the assessee had done the business worth USD 52684.57 (as per Guinea Frank the currency of Conakry it was 48,71,69,0007-). As per this incriminating material, the AO held that the assessee had done the business worth Rs. 33,79,1887- (USD 52684.57 [x] Rs.64.10) Before the AO, the assessee contended that Annexure A-3 pertained to the Conakry (capital of West African country, Guine) undertaken by Dipalbhai, Nitinbhai and Manish Bhai who were known to the assessee and did the business in cashew. The seized materials indicate total sales/ receipts/turn-over of total income of GNF 48,71,69,0007- which the appellant had claimed to be not in Indian currency. The currency of Conakry is Guinea Franc (GNF). The assessee further contended that Manishkumar M. Patel has left (forgotten) such diary who was working for Deepalbhai. The assessee also furnished the copy of passport of Manishkumar M Patel before the AO as evidence that Manish Patel was working in the foreign country and assessee had ....
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....o M/s OTTIMO Agency dated 16.11.2017 is Rs. 2,72,000/-, which shows that Rs. 3,02,000/- is incurred outside the books of accounts. Similarly, the total payment to M/s Veneer Point is dated 08.10.2017 is Rs. 40,000/- but the invoices from the said vendor is Rs. 73,300/-, which shows that Rs. 23,300/- is outside the books of account. On the basis of such observation, the ld CIT(A) held the expenditure incurred as per the incriminating material is partly recorded in the books and partly not recorded in the books. The expenditure recorded in books which finds mention in the incriminating material needs to be given credit to in determining the unexplained expenditure on furnishing and renovation of the flat. The AO has made an addition of Rs. 1,01,57,149/- treating the entire expenditure as per the incriminating material to be unexplained expenditure. However, the total amounts debited in the impugned AY in the books of accounts of the assessee relating to renovation and furnishing is Rs. 51,44,937/-, which needs to be given credit to. Thus, the unexplained expenditure on renovation and furnishing comes to Rs. 50,12,212/- (1,01,57,149 minus 51,44,937/-). On the basis of above finding th....
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....rious cryptocurrencies, the AO proposed for making a reference to a Special Auditor. The AO while passing assessment order made addition on account of unexplained investment in various crypto-currencies like DKD, ATC coin and Bitconnect of Rs. 68.40 crore. All the additions were based on seized documents found during search action. It was also found that assessee was having undisclosed business in Conakry (Guinea) through Deepak Bhai, Nitin Bhai and Manishbhai. On the basis of seized materials, it was found that turnover of such business was at 48.71 crore in the local currency of that country. So, the value of transaction in Indian Rupee was worked out by AO at Rs. 33,79,188/-. On the basis of various incriminating evidence, addition of Rs. 85,50,954/- was made on account of income of undisclosed business. It was also noted that assessee has made renovation in its residential house and various incriminating evidences were found, which was not explained by assessee nor any satisfactory explanation of such details of expenses, to whom, such expenses were provided. So, AO made addition of such payment on account of house renovation of Rs. 1.01 crores. Thus, making total addition of R....
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....nd pseudonymous asset. So, the whole point is this that there are huge transaction and it required specialized mind to understand such transaction. The assessee was allegedly keeping the cryptocurrency in escrow account. Escrow is a third-party service that hold onto the crypto-currencies which means the crypto-currency is the seller of contemplated and proclaimed to sell to buyer; and buyer has made payment but has not yet received the virtual currency. Once the seller received payment, they can then release the virtual currency from escrow account and trade (transaction) is completed. These services secure transaction for both the buyers and the sellers, creating a safer trading environment for everyone. In such scenario, assessee made large purchases and investments of cryptocurrencies during financial year 2017-18. During the time of investment, the market of crypto-currencies has been completely unregulated. The assessee purchased and made investment in Dekado/ATC crypto-currencies from market on a peer-to-peer basis (P2P) basis cash transaction and made unexplained investment therein. The Ld.CIT-DR for the Revenue submits that assessee purchased were three types of crypto-cur....
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.... investment, bonus, lending and interest coin aggregating as of 541,129.71 as prevailing rate of DKD coins were of Rs. 734/- thereby the AO worked out total unexplained investment and undisclosed income of Rs. 67.32 crore. 28. Total unexplained investment in ATC coin was made at Rs. 85,44,151/-. Such investment consists of ATC Jiyansh at Rs. 18,44,130/- and ATC Akash at Rs. 66,89,020/- (18,44,130+ 66,89,020). Third addition relates to ATC coin which is based on excel sheet "B1 CPU/HDD desktop" which relates to total sales of bonus coins of 81,769.84 out of 39,794.84 @ Rs. 12.35/- and 41975 @ Rs. 34/- per coin, which was worked out at Rs. 19,18,616/-. Though the assessee claimed that such investment does not belong to him and belongs to someone else and no evidence produced by assessee. 29. The ld. CIT(A) in his order, restricted the addition of Dekado (DKD) by taking the value of investment as in September, 2017 @ 2.5 $ thereby restricted the addition to the extent of Rs. 3.13 crore and remaining addition on account of bonus as referral point and other income was deleted. The addition on account of undisclosed investment in ATC coins at Rs. 85.44 lacs were restricted to Rs. 3....
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....m receipt of report of special auditor. Thus, the assessment order is liable to be quashed being passed beyond the limitation period. Against the addition of various investment in different in different cryptocurrencies, the learned AR of the assessee submits that during assessment the assessee was asked to explained seized material. The assessee explained each of the document seized during the search action. The AO disregarded the explanation furnished by the assessee. Against the addition of unexplained investments in various crypto currencies, the ld. AR of the assessee submits that during the search action, certain physical and digital data was found and seized. The assessee was to explained such seized material. The assessee explained each and every excel sheets found in the search action. The AO made addition by disregarding the submission of assessee. The AO made addition of unexplained investment in DKD currency of Rs. 67.32 crores. The assessee explained before the AO that rate of DKD currency in September, 2017 was between 1 to 2 US dollar per coin. To support such contention, the assessee also furnished copy of FIR made against Divesh Darji, who was the main operator, wh....
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....estor as well as in his own statement, stated that rate of DKD coin was only 2.00 US Dollar per coin. Thus, the investment in DKD coin at the worst may be restricted to 2.00 US Dollar per DKD for total DKD coin of 193123 coins. As the investment was made from withdrawal of capital from Om Anand Export, thus, it cannot be treated unexamined. If such investment is treated as unaccounted, the assessee be allowed credit in the account of firm "Om Anand Export". 33. On the unexplained investment in ATC coin, the ld. AR of the assessee submits that the assessee has not made any investment except DKD coin. The AO made addition on account of investment in ATC coin on the basis of download folder "Sanjay_hp_laptop_320_gb". The ld. AR of the assessee submits that in case any document is downloaded either from e-mail or WhatsApp or on online, it stored in download folder automatically. Various staffs of assessee were also sitting in his office and was operating laptop of assessee, there is possibility that such downloaded file was downloaded by staff of assessee. Before the AO, the assessee explained that her staff Miss Renu Singh was using such computer and such detailed found in download....
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....s were provided to the AO. The assessee never visited such foreign country nor carried out any business. The assessee provided passport of Manish Kumar M Patel and other evidence that he was working in foreign company and assessee nothing to do with his business. The ld. CIT(A) after considering the submission of assessee, deleted the addition of unaccounted business receipt of Rs. 85,50,954/-. The ld. AR of the assessee submits that he supports the order of ld. CIT(A) on this issue. 35. Against the addition on account of unexplained expenditure in renovation of house. The ld. AR of the assessee submits that the AO made addition of Rs. 1.01 crore on account of unexplained expenditure in renovation of house. The ld. CIT(A) allowed part relief to the assessee. The ld. CIT(A) allowed relief of Rs. 51.44 lacs and remaining of Rs. 50.12 lacs were confirmed. The ld. AR of the assessee submits that he supports the order of ld. CIT(A) to the extent that the assessee was allowed relief even the remaining addition is not liable to be sustained as the assessee has furnished complete details of all the expenditure. The ld. CIT(A) also failed to appreciate the evidence furnished by the asses....
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...., part of seized material) * DKDFULL (1). XLS.XLS- "STAKE" (Digital Data, part of seized material) * DKDFULL (2). XLS- "STAKE" (Digital Data, part of seized material) * DKDFULL (2). XLS- "COINS" (Digital Data, part of seized material) * DKDFULL (2). XLS- "RECTIFIED NEW SHEET" (Digital Data, part of seized material) * Return of Income, Computation of Income, Capital Account, Balance sheet as on 31/03/2018, Ledger Account of assessee, Ledger Account of Om Anand Exports in the books of assessee, Ledger Account of assessee in the books of Om Anand Exports. * ATC-HAN PDF 03/09/2017 (Digital Data Part of seized material) * ATC Sanjay Fuwa Final Sheet-41- "Sheet2" (Digital Data, Part of seized material) * ATC Sanjay Fuwa Final Sheet-41-'1-7' (Digital Data, Part of seized material) * ATC Sanjay Fuwa Final Sheet-41- "8" (Digital Data, Part of seized material) * ATC Sanjay Fuwa Final Sheet-41- "9" (Digital Data, Part of seized material) * B1-PD/HDD/0AE/DESKTOP/Personal acs.xls, Sheet 2. (Investment Accounts in Bitconnect), * Sheet Prepared Data, page No. and amount (Annexure-a/3) (In C....
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....DKDFull(2).xls Total 67,32,01,161 37. We find that the ld. CIT(A) on considering the submission of assessee held that DKD coins details were found in DKD FULL-1 and FULL-2 are the same coin and all total investment by assessee is only 193123. There is no evidence that assessee acquired more than 193123 DKD coins. The AO has taken each excel sheet as a separate investment. Thus, the addition if any to be made only in respect of total investment of 193123 DKD coin. The benefit of bonus coin and interest on referral income was never realized as DKD coins were abruptly taken off from the website. Thus, the assessee never reaped by the assessee, so such income cannot be taxed in the hands of assessee. As recorded above, the AO valued the investment on the basis of rate of DKD coin on 01st December, 2017. We find that the ld. CIT(A) despite recording the fact that as per allegation in the FIR against Devesh Darji, the complainant made allegation of investment in DKD at 1.00 Dollar per coin and lost it. The ld. CIT(A) also noted that prevalent rate of DKD in September, 2017 was ranging from 1.00 USD to 2.00 USD. We find that assessee also accepted th....
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....ised by the assessee. No evidence was found during course of search action, to show existence of fact that assessee ever received any benefit from lending or referral scheme. The AO has nowhere mentioned in her assessment order that any investigation of fact was carried out during assessment or in post search period, which may strengthen her case. Therefore, we can safely conclude that this addition is based on mere presumption. Hence, we affirm the order of ld CIT(A) with our additional observation. 39. Being a search case, we independently examined the facts related with the issue of unaccounted investment in DKD and / or the benefits if any realised by assessee on these DKD coins. On independent examination of facts, we find that there is no evidence on record that the assessee made investment in more than 193124 DKD coins or any benefits either on referral or on account of interest or on lending was ever realised by the assessee. No evidence was brought by the AO on record to support huge additions. Thus, we do not find merit in the ground No. 1 & 2 of the appeal of revenue. 40. Ground No. 3 & 4 in revenues appeal relates to the addition of unexplained investment and unac....
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....y all investment has lost. We find that the ld CIT(A) after considering the submissions of the assessee accepted the contention of assessee and considered the investment in ATC coin as on 03.09.2017 at 98,560 coin and restricted addition of unexplained investment thereto only. The ld CIT(A) also worked out the figure of addition sustained by him at Rs. 33,51,040/- (98,560 X Rs. 34). Thus, the addition of unexplained investment in ATC Akash at Rs. 66,89,020/- was restricted to Rs. 33,51,040/-. We find that ld CIT(A) has right deleted the duplicate addition, which we affirm. 41. Second part of addition in ATC made by AO is based on excel sheet "Sanjay Fuwa Final sheet_41". The AO made this addition of 150,213 coins at Level 1 to 10. The AO worked out total investment at Rs. 18,55,130/- by taking rate of ATC @ Rs. 12.35/-( 150,213X 12.35). We find that before AO the assessee explained that this investment does not belongs to him rather belongs to third person. The AO disregarded the contention of the assessee and held that evidence of holding of these coins were found from the possession of the assessee. We find that even before ld CIT(A) the assessee took similar plea. The ld CIT(....
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....he details of expenses, sales, purchases of business of cashew and jute bags at Conakry and Buke. In the details the names of Deepalbhai, Manish Bhai, Vijaybhai and Nitin Bhai are mentioned / written. The name of assessee is nowhere mentioned. At the end, there are details that these four people, who had started some cashew and jute bags business which resulted in loss. The ld CIT(A) also held that even Annexure A-3 gives the details of the same cashew and jute business which is in Conakry currency. During such period Mr. Manish Patel stayed in Conakry as per the stampings in his passport (from 03.05.2017 to 03.06.2017). The entries in the diary are pertaining to the same period 03.05.2017 to 03.06.2017. In none of the incriminating material, there is any reference about the assessee or his investment and therefore, in absence of any adverse inference to the assessee in the seized material, the details found cannot be treated to be that of the assessee and addition cannot be made. 45. We find that there is no independent or corroborative evidence on record to prove that facts that the assessee carried out such undisclosed business or any income was ever accrued, aroused or credi....
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....l the evidences. We find that the ld CIT(A) on considering the explanation and evidences of assessee restricted the addition to the extent of Rs. 50.12 lacs by taking view that the ld CIT(A) noted that assessee has produced the partywise bifurcation of expenses. Ld CIT(A) also given certain instances that on examination of the party-wise ledgers, he found that the assessee has made the payments by cheques as well as cash to the said parties. All the payments made to the vendors which are recoded in the books and which is not recorded in the books are found in the incriminating material. While considering one invoice dated 29.03.2017 from M/s OTTIMO Agency, which is respect of purchase of white goods, shows total of value of Rs. 5,74,000/-. But the amount shown paid by cheque to M/s OTTIMO Agency dated 16.11.2017 is Rs. 2,72,000/-, which shows that Rs. 3,02,000/- is incurred outside the books of accounts. Similarly, the total payment to M/s Veneer Point is dated 08.10.2017 is Rs. 40,000/- but the invoices from the said vendor is Rs. 73,300/-, which shows that Rs. 23,300/- is outside the books of account. On the basis of such observation, the ld CIT(A) held the expenditure incurred a....