TaxTMI 
TaxTMI 
2025 (11) TMI 1890
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....,40,00,000/- from Sachin Nahar in cash and an amount of Rs. 15,22,200/- was paid in cash towards interest payment. It was informed that Shri Sachin Nahar is working as finance broker and is working as middleman who provides a platform for those investors who are having surplus funds and the borrowers who are in need of funds. Therefore, after recording due satisfaction and reason to believe with respect to escapement of income and after obtaining the necessary statutory prior approval through ITBA system from Addl. Commissioner of Income Tax, Range-2, Pune, a notice u/s 148 of the Act was issued to the assessee on 31.03.2021 for reopening the assessment u/s 147 of the Act for assessment year 2017-18. The issues for reopening the case as mentioned by the Assessing Officer in the online service of order dated 13.12.2021 read as under: "Issues as per reasons recorded for reopening:- The assessee has borrowed cash loan from Sachin Nahar whose creditworthiness is doubtful. Therefore, cash loan of Rs. 1,40,00,000/- taken by the assessee is unexplained cash credit in the books of accounts of the assessee. Further the repayment of interest in cash was not disclosed by the....
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....therefore, issued a show cause notice asking the assessee to explain as to why the proceedings u/s 263 of the Act should not be initiated. The said notice reads as under: 6. Rejecting the various explanations given by the assessee, he set aside the order dated 13.12.2021 passed by the Assessing Officer disposing of the objections of the assessee to the notice dated 31.03.2021 issued u/s 148 of the Act for proper verification of fact and to re-examine the issues. The relevant findings of the Ld. PCIT read as under: "4. I have considered the entire written submission carefully. So far as the judgements cited by the assessee, these are not applicable in assessee's case because the facts are clearly distinguishable. Further, the contentions of the assessee are not acceptable considering facts of the case discussed below. 4.1 A letter No.Pn/DCIT.Cen.Cir.1(1)/Sharing of Info./2020-21, dated 27/03/2021 issued by the Asstt. Commissioner of Income Tax, Central Circle 1(1), Pune to the Assessing Officer is available on record whereby a reference was invited to his office's earlier letter No.Pn/DCIT/CC 1(1)/Info/2019-20 dated 10/06/2019 vide which information abou....
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....tion were also shared with the Assessing Officer along with the copy of statement of Shri. Sachin Nahar. 4.2 After considering the information and documents received, the Assessing Officer initiated proceedings under section 147 of the Act by issue of notice under section 148 of the Act on 31/03/2021 after recording the reasons for the same. During the course of assessment proceedings, the assessee raised objections to reopening of his case. The main contention of the assessee was that the Assessing Officer jumped to the conclusion that the cash credit (borrowing of Rs. 1,40,00,000/-) is duly entered in the books of accounts of the assessee without any basis or supporting material. However, it is seen from the reasons recorded by the Assessing Officer that while recording the reasons, the Assessing Officer has duly categorized the same viz. brief details of the assessee, brief details of information collection / received, analysis of information collection/received, enquiries made by the AO, findings of the AO, basis of forming reason to believe and details of escapement of income, applicability of provisions of section 147/151 to the facts of the case etc. Under the headi....
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....D. Chordia. He stated to have gone through the papers and confirms that the seized papers do not contain any entry relating to Ashok D. Chordia and he further confirmed that he has not lent any cash to the assessee and has not received any interest, as stated in the reasons recorded for issue of notice under section 148. It is pertinent to note here that the notings made by Shri. Sachin Nahar as per the seized documents were in coded format. Shri. Sachin Nahar was time and again confronted upon to decode the entries therein while recording his statement under section 131 of the Act on 17/11/2017 and in his answer to question No.6, states that he has tried all the efforts to recall coded names to decode into full name and to provide their other details and still not able to provide details of certain codes and he is not able to recall them. Vide answer to question No.9, he again states that he is concerned only with his commission, did not maintain regular books of accounts and will try to provide the remaining details as and when recollect the same. Vide answer to question No.14 and 15, he stated that in such line of business, the depositor contacts him on phone and does necessary ....
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....ve at a conclusion that there were no entries related to the assessee is found to be incorrect and without any proper verification of facts. It seems that the Assessing Officer has solely relied upon the affidavit of Shri. Sachin Nahar, however, considering the facts discussed in para (4.2) in this regard, further inquiries were required before coming to any such conclusion. 4.4 Without prejudice to the above, it is also seen that the Assessing Officer while disposing the objections, has mentioned that they are found to be prima facie acceptable. Use of the words 'prima facie' while giving his findings by the Assessing Officer shows that he was not sure about his findings but still proceeded to accept the objections of the assessee. 4.5 Without prejudice to the above, it also seems that the complete details of information which was received from the Asstt./Dy.CIT, Central Circle-1(1), Pune was not available before the Assessing Officer while disposing of the objections of the assessee vide order dated 13/12/2021. The letter dated 27/03/2021 of the Asstt.CIT, Central Circle-1(1), Pune specifies following enclosures as reproduced below: "1) Document sei....
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....ave been present in the documents supplied but might have misplaced while transferring the case to another Assessing Officer. Therefore, the completeness of relevant documents while disposing of the objections of the assessee was very important, however, the Assessing Officer did not verify this fact while passing the order dated 13/12/2021. 4.6 The provisions of Section 263 are very clear that Commissioner of Income-tax can exercise power under the said section when he forms an opinion on the basis of records that an order passed by the Assessing Officer is both erroneous and prejudicial to the interests of the revenue. Further, Explanation 2 to section 263, which was inserted vide Finance Act 2015 with effect from 1 June 2015, provides that an order passed without making inquiries or verification which should have been made, should be deemed to be erroneous insofar as it is prejudicial to the interests of the Revenue. This has also been validated by various judicial pronouncements including Apex Court decision in the case of Malabar Industrial Company Ltd. vs. CIT (243 ITR 83 (SC)] wherein it has been held that, whether, where assessing officer had accepted entry in stat....
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....of the objections of the assessee to the notice dated 31/03/2021 under section 148 of the Act, is hereby partly set aside to the file of the Assessing Officer for proper verification of fact and to re-examine the issues considering the aspects discussed in the foregoing paragraphs and decide the issues afresh. However, before arriving at any conclusion, the Assessing Officer shall give reasonable opportunity to the assessee to adduce the evidence and information with regard to the issues involved. The Assessing Officer shall, accordingly, dispose of the objections of the assessee afresh by forming his independent opinion after due verification of the relevant documents, seized material, statements recorded by the Investigation Wing etc. He shall obtain the relevant material from the concerned Authorities, which are not available at present as per discussion in para (4.5) above. Consequent to setting aside the order dated 13/12/2021, the proceedings under section 147 of the Act are hereby revived and the same shall be completed as per law. It is hereby clarified that the Assessing Officer (JAO) cannot travel beyond this while adjudicating and investigating the issue discussed herein....
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....etting aside the proceedings u/s 147 for "proper verification" is incorrect, considering the decisions of - a) Honorable Pune ITAT, dated 19-8-2024, in case of Narendra Bafna v. ITO, Ward-1, Ahmadnagar, and b) Honorable Jurisdictional High Court, dated 18-2-2025 in case of Sejal Jewellers v. Union of India - Writ Petition No. 3057 of 2019 Appellant further contends that, rightful section for present subject proceedings, ought to have been section 153C (and not section 147). Appellant thus contends that, learned PCIT-1's decision of setting aside the 147 related proceedings leads to nullity and hence, is infructuous. 7. Learned PCIT-1, Pune erred in law and on facts in merely setting aside order passed by learned ACIT, Central Circle-1, Pune dated 13-12-2021 for accepting Appellant's objections to 147 proceedings. Learned PCIT-1, Pune erred in not setting aside the order passed by FAO dated 3-2-2022 for dropping the 147 proceedings, thus, leading to infructuous subsequent proceedings. 9. The Learned Counsel for the assessee referring to the above additional grounds submitted that the above additional grounds raised are purely legal in n....
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....ECD IN INTEREST PAID IN SR NO AMOUNT (As per seized record) FY 2016-17 FY 2017-18 BORROWER NAME OF THE BORROWER F.Y. 2016-17 F.Y. 2017-18 1 1500 1500000 ASHOK C ASHOK D CHORDIYA 1,71,000 - 2 1500 1500000 ASHOK C ASHOK D CHORDIYA 1,64,650 45,000 3 1000 1000000 ASHOK C ASHOK D CHORDIYA 1,16,650 30,000 4 2500 2500000 ASHOK C ASHOK D CHORDIYA 2,60,000 64,975 5 1000 1000000 ASHOK C ASHOK D CHORDIYA 95,300 30,000 6 1500 1500000 ASHOK C ASHOK D CHORDIYA 1,47,000 90,000 7 1500 1500000 ASHOK C ASHOK D CHORDIYA 1,47,000 90,000 8 2000 2000000 ASHOK C ASHOK D CHORDIYA 2,45,000 60,000 9 1500 1500000 ASHOK C ASHOK D CHORDIYA 1,75,500 45,000 14. Referring to the papers enclosed with the chart submitted by the ACIT, Central Circle 1(1), Pune, the details of which are placed at pages 8 to 13 of the paper book, the Ld. Counsel for the assessee drew the attention of the Bench t....
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....for the present proceedings should have been initiated u/s 153C and not 147, therefore, the Ld. PCIT's decision of setting aside the 147 related proceedings leads to nullity and has to be treated as infructuous. 17. Referring to the decision of the Hon'ble Bombay High Court in the case of Sejal Jewellery & Anr. Vs. Union of India & Ors. vide Writ Petition No.3057 of 2019 and batch of other appeals order dated 18.02.2025, he submitted that under identical circumstances the Hon'ble Bombay High Court has held that the correct provision should be under section 153C and not 147. 18. Referring to the decision of the Co-ordinate Bench of the Tribunal in the case of ITO vs. Narendra Sampatlal Bafna vide ITA No.688/PUN/2024 for assessment year 2017-18 and CO No.25/PUN/2024 order dated 19.08.2024, he submitted that in that case also reopening was made on the basis of information received from the Investigation wing that the assessee has taken cash loan of Rs. 6,20,00,000/- from various parties through Mr. Sachin Nahar. The amount was added by the Assessing Officer in the assessment proceedings and on appeal the Ld. CIT(A) deleted the addition by quashing the re-assessment proceedings o....
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....nd transmitted the relevant material containing information regarding the Assessee to the AO. There is also no material that the AO had on receipt of the said information issued a notice under Section 153C of the Act. Thus, in fact the AO did not assume jurisdiction under Section 153C of the Act. Absent assumption of any jurisdiction, the question of Sections 147, 148 and 149 of the Act being overridden by virtue of the non obstante clause of Section 153C of the Act, does not arise. The said clause would be operative only if the AO had in fact assumed jurisdiction under Section 153C of the Act. In that eventuality, recourse to the provisions as named in the opening sentence of Sections 139, 147, 149, 151 and 153 of the Act would be ousted. 66. In the present case, the re-assessment proceedings are initiated under Section 147 of the Act not only on the basis of the material containing information that was found during the search conducted in respect of Jain Brothers, but is also founded on the basis of other information as obtained by the Investigation Wing, namely, that the Assessee had purchased units of a penny scrip named SVC Resource Ltd. This being the case, the decis....
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....h materials were seized and such materials were further explored and enquired. Such enquiry revealed significant information in regard to M/s. Green Valley Gems Pvt. Ltd. which according to the Revenue had provided accommodation entries to the petitioner, in which it was also revealed that M/s. Green Valley Gems Pvt. Ltd. was a shell company. Accordingly reopening proceedings u/s 147 were initiated and notice u/s 148 of the Act was issued. When the petitioner challenged such reopening of assessment on the ground that the assessment could have been only made u/s 153C and not u/s 147 of the Act, the Hon'ble Bombay High Court accepted the contention of the petitioner and quashed the re-assessment proceedings by observing as under: "12. We have heard learned counsel for the parties and with their assistance, we have perused the record. At the outset, we may observe that the (2023) 149 taxmann.com 399 (SC) (1993) 69 Taxman 627 (SC) 18 February, 2025 WP3057_2019.DOC jurisdiction of the Assessing Officer to issue the impugned notice would be required to be considered on the basis of the departmental record and on such basis, the relevant provisions of law which would govern the f....
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....reen Valley Gems Pvt. Ltd. from whom the petitioners had alleged to have taken accommodation entries. It is on the basis of such information, which was certainly not the information borne out or gathered from the return of income, which was filed and/or any material thereunder, the Assessing Officer reached to a conclusion to reopen the assessment, on the ground that the assessee had not explained such loan receipt 18 February, 2025 WP3057_2019.DOC transactions. Such opinion was formed by the Assessing Officer on the basis that M/s. Green Valley Gems Pvt. Ltd. was a shell/paper company. It is on such premise that the Assessing Officer was of the view that income had escaped assessment within the purview of Clause (c) of Explanation 2 of Section 147 of the I.T. Act and such escapement had occurred due to the assessee's failure to disclose true, proper and complete facts in the return of income, filed for the subject assessment year. Accordingly, notice under Section 148 was issued. 14. Thus, on the perusal of such reasons, it is quite clear that the provisions of Section 153A providing for "Assessment in case of search or requisition" and the provisions of Section 153C,....
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....her evidence from which material evidence could with due diligence have been discovered by the Assessing Officer will not necessarily amount to disclosure within the meaning of the foregoing proviso. Explanation 2.--For the purposes of this section, the following shall also be deemed to be cases where income chargeable to tax has escaped assessment, namely:-- (a) where no return of income has been furnished by the assessee although his total income or the total income of any other person in respect of which he is assessable under this Act during the previous year exceeded the maximum amount which is not chargeable to income-tax; (b) where a return of income has been furnished by the assessee but no assessment has been made and it is noticed by the Assessing Officer that the assessee has understated the income or has claimed excessive loss, deduction, allowance or relief in the return; (ba) where the assessee has failed to furnish a report in respect of any international transaction which he was so required under section 92E;] (c) where an assessment has been made, but-- (i) income chargeable to tax has been underassessed; or (ii....
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....form and verified in the prescribed manner and setting forth such other particulars as may be prescribed and the provisions of this Act shall, so far as may be, apply accordingly as if such return were a return required to be furnished under section 139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made and for the relevant assessment year or years : Provided that the Assessing Officer shall assess or reassess the total income in respect of each assessment year falling within such six assessment years and for the relevant assessment year or years : Provided further that assessment or reassessment, if any, relating to any assessment year falling within the period of six assessment years and for the relevant assessment year or years referred to in this sub- section pending on the date of initiation of the search under section 132 or making of requisition under section 132A, as the case may be, shall abate : Provided also that the Central Government may by rules made by it and published in the Official Gazette (except....
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....shall cease to have effect, if such order of annulment is set aside. Explanation.--For the removal of doubts, it is hereby declared that, i) save as otherwise provided in this section, section 153B and section 153C, all other provisions of this Act shall apply to the assessment made under this section; (ii) in an assessment or reassessment made in respect of an assessment year under this section, the tax shall be chargeable at the rate or rates as applicable to such assessment year." 153C. Assessment of income of any other person. (1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,-- (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or 18 February, 2025 WP3057_2019.DOC (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than the person referred to in section 153A, then, the books of account or documents or assets, seized or requisitioned shall be ha....
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....ch other person but no notice under sub-section (2) of section 143 has been served and limitation of serving the notice under sub-section (2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue the notice and assess or reassess total income of such other person of such assessment year in the manner provided in section 153A. (3) Nothing contained in this section shall apply in relation to a search initiated under section 132 or books of account, other documents or any assets requisitioned under section 132A on or after the 1st day of April, 2021. 16. On a plain reading of Section 153A, it is clear that it begins with a 'non- obstante' clause, when it provides that notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under sec....
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....case, the Revenue's contention was to the effect that the Assessing Officer was competent to consider all the materials which were available on record, including the materials found during search so as to make an assessment of the total income. Some of the High Courts had accepted such propositions. However, the assessee had contended that there were also decisions of the High Courts to the effect that if assessment proceedings were not pending on the date of initiation of the search, the Assessing Officer needs to consider only the incriminating material found during the search, and was precluded from considering any other material derived from any other source. It is in such context, the Supreme Court considering the purport of the provisions of Section 153A of the I.T. Act, vis a vis its applicability qua the provisions of Section 147, and the applicability of Section 132, 132A and notably the 18 February, 2025 WP3057_2019.DOC decision of the Delhi High Court in Commissioner of Income Tax, Central-III vs. Kabul Chawla6 inter alia held that the provisions of Section 153A(1) need to be mandatorily resorted once a search takes place. The Supreme Court held as under: "7....
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....t under Section 153A merges into one. Only one assessment shall be made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record of the AO. vii. Completed assessments can be interfered with by the AO while making the assessment under Section 153 A only on the basis of some incriminating material unearthed during the course of search or requisition of documents or undisclosed income or property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment." 18. The Supreme Court held that it was in complete agreement with the view taken by the Delhi High Court in Kabul Chawla (supra) and of the Gujarat High Court in Principal Commissioner of Income Tax-4 vs. Saumya Construction7 taking the view that no addition can be made in respect of the completed assessments in absence of any incriminating material. 19. Insofar as the present proceedings are concerned, the following observations made by the Supreme Court in the context of Section 147 and 148 of the I.T. Act need to be noted: "11. As per the provisions of Se....
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....e reassessment proceedings under Sections 147/148 of the Act, subject to fulfillment of the conditions mentioned in sections 147/148, as in such a situation, the Revenue cannot be left with no remedy. Therefore, even in case of block assessment under section 153A and in case of unabated/completed assessment and in case no incriminating material is found during the search, the power of the Revenue to have the reassessment under Sections 147/148 of the Act has to be saved, otherwise the Revenue would be left without remedy. 12. If the submission on behalf of the Revenue that in case of search even where no incriminating material is found during the course of search, even in case of unabated/completed assessment, the AO can assess or reassess the income/total income taking into consideration the other material is accepted, in that case, there will be two assessment orders, which shall not be permissible under the law. At the cost of repetition, it is observed that the assessment under Section 153A of the Act is linked with the search and requisition under Sections 132 and 132A of the Act. The object of Section 153A is to bring under tax the undisclosed income which is found d....
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....ed assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under Section 132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened by the AO in exercise of powers under Sections 147/148 of the Act, subject to fulfilment of the conditions as envisaged/mentioned under Sections 147/148 of the Act and those powers are saved. The question involved in the present set of appeals and review petition is answered accordingly in terms of the above and the appeals and review petition preferred by the Revenue are hereby dismissed. No costs." 21. The Rajasthan High Court in Shyam Sunder Khandelwal s/o. Late Damodar Lal Khandelwal vs. Assistant Commissioner of Income Tax, Central Circle-2, Jaipur8 (supra) also had taken a similar view when the issue which had arisen before the Court was in regard to the notice issued under Section 148 of the I. T. Act, the basis of issuance of such notice was the material seized during search. The contention of the assessee was to the effect that in the said ci....
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....in cases of search and requisition. There cannot be a quibble with the proposition that the special provision shall prevail over the general provision. To say it differently the provisions of Section 153A to 153D have prevalence over the regular provisions for assessment or reassessment under Section 143 & 147/148. 27. Section 153A and 153C starts with non- obstante clause. The procedure for assessment/reassessment in Section 153A, 153C in cases of search or requisition has an overriding effect to the regular provisions for assessment or reassessment under Sections 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin to Section 153A and Section 153C. Corollary being that after seizing of operational 18 February, 2025 WP3057_2019.DOC period of Section 153A to 153D, the cases being dealt thereunder were circumscribed in the scope of newly substituted Section 148." We are in complete agreement with the view taken by the Division Bench of Rajasthan High Court in the aforesaid decision. 22. Applying the principles of law as discussed hereinabove, we are of the clear opinion that the foundation of the present case....
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....he Act read as under: "153C. (1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,- (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than the person referred to in section 153A, then, the books of account or documents or assets, seized or requisitioned shall be handed over to the Assessing Officer having jurisdiction over such other person and that Assessing Officer shall proceed against each such other person and issue notice and assess or reassess the income of the other person in accordance with the provisions of section 153A, if, that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous year in which search is c....
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....ge. The copy of statement recorded u/s. 132(4) of the IT Act, 1961 on 04.08.2017 of Shri Sachin Nahar as well as related documents regarding cash loan taken by the party along with the related pages of Shri Sachin Nahar's submission containing name of the above mentioned person and the Assessment Years in which the transactions were made are enclosed herewith for reference and necessary action at your end." 20. We find the Assessing Officer at para 2 of the reasons recorded has mentioned as under: "During search at his residence, various notebooks, notepad and loose papers were found and seized as Bundle No 1 to 28. In his statement recorded u/s. 132(4) of the Act at his residence on 02.08.2017, Shri Sachin Nahar stated that this seized material contain details of his money lending business in Cash and the Notings therein are related to Principal amount lent by lenders & borrowed by borrowers, names of lenders & borrowers, interest component etc. In the said seized registers, there are two types of notings, one which contains the accounts of borrowers and other registers contain notings of names of investors (depositors) in coded words. Here it is important to....
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....ngly allowed. 26. In the result, the appeal filed by the assessee is allowed. Order pronounced in the open Court on 30th July, 2025. ============= Document 1 GOVERNMENT OF INDIA MINISTRY OF FINANCE INCOME TAX DEPARTMENT OFFICE OF THE PRINCIPAL COMMISSIONER OF INCOME TAX PCIT, Pune-1 To. ASHOK DHANRAJ CHORDIA SOLITAIRE WORLD SOLITAIRE WORLD , 8TH FLOOR CTS NO. 36/1/1 OPP. REGENCY CLASSIC MUMBAI BANGLORE HIGHWAY 411045, Maharashtra India DIN & Notice No : PAN/TAN: AY ITBA/REV/F/REV1/2023- Dated: AAMPC9919J 2017-18 24/1063250846(1) 23/03/2024 NOTICE FOR THE HEARING M/s/Mr/Ms Subject: Notice for Hearing in respect of Revision proceedings u/s 263 of the THE INCOME TAX ACT, 1961 - Assessment Year 2017-18. In this regard, a hearing in the matter is fixed on 28/03/2024 at 04:00 PM. You are requested to attend in person or through an authorized representative to submit your representation, if any alongwith supporting documents/information in support of the issues involved (as mentioned below). If you wish that the Revision proceeding be concluded on the basis of your written submissions/representations filed in this o....
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....ply is not received by the given date, it shall be presumed that you have nothing to say in this regard and the proceedings shall be completed on the basis of information available on record. 6. Please note that this is the first and last opportunity to submit compliance. In the event of failure to comply, the matter will be decided on the basis of material available on record. 7. The attedance as mentioned in Para 1 is not insisted. Your may furnish your response through e portal on or before 28/03/2024. SANTOSH KUMAR Document 3 6 OFFICE OF THE Anett Commissioner Of Income Tax. Central Circle 1(1), Pane Pine 411037 Thanc & C0 24263617 Email Id- pune.delt.cen1.le incometax.gov.in Date:27/03/2021 Ne.Pa/DCIT.Cen.Cir.1(1)/Sharing of Info./2020-21/ Te The Deputy Commissioner of Income Tax, Circle 2. Pune. Sir/Madam. Sub: Sharing of Information in the case of Shri Sachin Nahar- reg. Ref: This office letter No. Pa/DCIT/CC 1(1)/Info./2019-20 dated 10.06.2019 Reference may kindly be made to this office letter No. Pn/DCIT/CC 1(1)/Info./2019-20 dated 10/06/2019 vide which information about the cash loan was provided to you. In the case of Shri Sachin N....