TaxTMI 
TaxTMI 
2026 (4) TMI 1376
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.... 111,61,80,000/- from seven parties in the relevant previous year, as unexplained cash credits liable to be added under section 68 of the Act; in assessment order dated 27.12.2011 and upheld in the lower appellate discussion. 3. That being the case, the assessee vehemently submits that the impugned addition is not sustainable in law as the assessee had filed the respective confirmations, ITRs, computations etc. to prove the three ingredients of identity, genuineness and creditworthiness of the parties concerned. The Revenue on the other hand draws support from both the learned lower authorities' respective findings making the impugned addition. Our attention is further invited to the CIT(A)'s detailed discussion upholding the impugned addition as under: "5.20.1 Coming to the present case, I find that the appellant is trying to establish the identity mainly from the following: i) PAN, ii) Incorporation Certificate, iii) Affidavit filed by the Director during course of assessment proceedings, iv) reply tendered in response to notice u/s. 133(6) issued by the AO v) and statement of the Director recorded during remand proceedings. 5.20.2 The sanctity of th....
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....is position should not be accepted. v) In spite of specific opportunities, mentioned as under, the appellant did not produce (the then) Directors of the above said seven (share subscriber) companies from whom share application/share premium money has been received: a) Vide letter dated 30.11.2017, the appellant was asked to produce these persons on 06.12.2017. b) Vide hearing dated 12.06.2017, the appellant was asked to produce these persons on 15.12.2017. During the said hearing (on 06.12.2007), the AR of the appellant assured that these persons would be produced on the next dated of hearing i.e. 15.12.2017. c) Vide letter dated 15.06.2017, the appellant was asked to produce these persons on 19.12.2017. This date of hearing, incidentally was same as asked by the appellant's letter dated 15.12.2017. vi) The confirmations of account filed during assessment proceedings and/ vide replies filed u/s. 133(6), are not having original signatures (these are photocopies) except in case of M/s S.R. Cable Pvt. Ltd. The confirmations in form of certificate filed during assessment proceedings and/ vide replies filed u/s. 133(6), are not having origina....
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....s, and iii) name of the applicant company has been written in bold letters, to list a few}. The photocopies of the resolutions accompanying share application forms show that all the resolutions are having the same style {e.g. i) name of the Director who ¡s authorized to purchase/sale shares has been written in bold letters, and ii) the Director is empowered to execute power of attorney in respect of said shares as he thinks fit.}. In case of M/s Aasheesh Capital Services Pvt. Ltd. and M/s Aquiss Pvt. Ltd., although, the authorized Director is male, however, the resolution empowers him to execute, power of attorney in respect of said shares as she thinks fit. xi) Neither,' any activities were found to have been actually carried out at the official addresses of these companies, nor any employee of these companies was found present at these addresses, nor any books of accounts or vouchers were found at these addresses. On the contrary, cheque books and pass books were found and seized from the residential premise of Jain Brothers {at 22/1, New Rajender Nagar, New Delhi}. Further, Acknowledgement of filing of Returns of these companies, User Ids and password of all compa....
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....nts related to beneficiaries in the form of papers and Hard Discs were also found, establishing the fact that they were engaged in the business of providing accommodation entries at a large scale. ii) The fact that Jain brother were found in possession of cheque books and other vital documents, including their passwords to file ITRs belies the theory of proving identity by documents like PAN, Certificate of Incorporation, Status at ROC or filing of Rol or even having an assessment order (which does not directly makes AO to deal with the question of identity of such company). iii) The specific references mentioned above, show that all the above said seven (share subscriber) companies from whom this purported share capital has been received by the appellant have been used as conduits for providing accommodation entries. iv) In fact as discussed above, during the appellate proceedings before the Hon'ble ITAT, Delhi in ITA Nos.6991 to 6997/Del/2014 for A.Y.s 2005-06 to 2011-12 (Shri Virender Kumar Jain) and ITA Nos.6998 to 7004/Del/2014 for A.Y.s 2005-06 to 2011-12 (Shri Surender Kumar Jain), the Authorised Representative (of S/Sh Virendra Kumar Jain and ....
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....otocopies of the ITR-VZ the annual accounts of these companies, as follows. ix) All the seven affidavits of the Directors of these companies filed before AO, were of the same style and are identically worded. Two of these affidavits (in case of M/s Karishma Industries Pvt. Ltd. and M/s Nandal Finance and Leasing Ltd.) were unsigned but notarized. Regarding affidavit dated 09.12.2011 is of Sh. Chhagan Lal Sharma (in case of Nandal Finance & Leasing Pvt. Ltd.), as stated earlier, this affidavit is not signed but notarized. Moreover, the affidavit claims that Sh. Chhagan Lal Sharma was Director on 09.12.2011, however, as per details filed during appellate proceedings in October, 2012, there were three Directors namely, Savesh Pal Singh (from 07.04.2012), ii) Mamta (from 07.04.2012), and iii) Jyoti Jain (from 01.05.2010). Regarding affidavit dated 09.12.2011 of Sh. Prem Kumar Mahato (in case of S.R. Cables Pvt. Ltd), as per details filed during appellate proceedings in October, 2012, there were four Directors namely, Yogesh Mittal, ii) Veena Devi Mittal, iii) Ritesh Mittal, and iv) Sweta Mittal. All of these four Directors have been appointed on 30.09.2011. This means that Sh.....
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....ess of these companies to extend the kind money under consideration. S No. Name of the purported share holder Amount. received (Rs.) Income as per ITR (A.Y. 09-10) Income as per P&L A/c (A.Y. 08-09) Income as per P&L A/c (A.Y. 07-08) 1. S.R. Cables Pvt. Ltd. 3,00,00,000 17,627 -16,715 28,591 2. Aasheesh capital Services Pvt. Ltd. 28,95,00,000 86,346 86,346 76,703 3. Aquiss Pvt. Ltd. 19,20,00,000 77,596 77,596 -1,600 4. Sunny cast and forge Pvt. Ltd. 12,39,00,000 89,698 89,742 (8218) 5. Karishma Inds. Itd. 20,10,00,000 2,52,386 2,49,694 (7332) 6. Vrindavan Capital Services Pvt. Ltd. 5,97,00,000. 7,54,615 7,54,615 7. M/s Nandal Finance & Leasing Pvt. Ltd. 21,99,00,000 21,836 21,835 5,865 xiii) The 'Directors' salary paid in these seven companies (who have been claimed to have subscribed to shares of the appellant company) are tabulated as under. It may be seen that this meager expense on Directors' salary does not justify the Creditworthiness of these companies to extend the kind money under consideration. S. No. ....
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.... Vrindavan Capital Services Pvt. Ltd. 5,97.00,000 750 the company was not in existence. 7 M/s Nandal Finance & Leasing Pvt. Ltd. 21,99,00,000 NII Nit xvi) It can be seen from the above table that these companies do not have any capacity to pay the purported amounts. xvii) A perusal of the bank statements produced shows that these are typical statements of accommodation entry providers. The amount comes from somewhere and immediately or in an interval of day or two, it goes out. The material seized. From the residence of Jain Brothers also indicate that these balances are created in order to provide accommodation entries. In any case, creditworthiness is much more than the papers like balance sheet. It is the trust of a third party to extend credit to a party in the market. The investigation made by the revenue has gathered ample evidences to show that no person in the market would extend any credit to these seven (share subscriber) companies. 5.25 The statement recorded during remand proceedings will have to be discarded because, as stated earlier, the same have been recorded without any reference of vital findings (mentioned abov....
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....he specific references, mentioned above, show that all the above said seven (share subscriber) companies from whom this purported share capital has been received by the appellant have been used as conduits for providing accommodation entries. iv) in fact, as discussed above, during the appellate proceedings before the Hon'ble ITAT, Delhi in ITA Nos.6991 to 6997/Del/2014 for A.Y.s 2005-06 to 2011-12 (Shri Virender Kumar Jain) and ITA Nos.6998 to 7004/Del/2014 for A.Y.s 2005-06 to 2011-12 (Shri Surender Kumar Jain), the Authorised Representative (of S/Sh Virendra Kumar Jain and Surendra Kumar Jain) has taken a stand that their cases are to be treated at par with the cases of accommodation entry operators-Sh S K Gupta and Sh Tarun Goyal. The Hon'ble ITAT also accepted this stand. In spite of specific show cause notice vide letter dated 15.12.2017, Appellant did not show any cause as to why this position should not be accepted. v) In spite of specific opportunities, mentioned as under, the appellant did not produce (the then) Directors of the above said seven (share subscriber) companies from whom share application/share premium money has been received: a....
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....owever, as per details filed during appellate proceedings in October, 2012, there were three Directors namely, Savesh Pal Singh (from 07.04.2012), ii) Mamta (from 07.04.2012), and iii) Jyoti Jain(from. 01.05.2010). Regarding affidavit dated 09.12.2011 of Sh. Prem Kumar Mahato (in case of S.R. Cables Pvt. Ltd), as per details filed during appellate proceedings in October, 2012, there were four Directors namely, Yogesh Mittal, ii) Veena Devi Mittal, iii) Ritesh Mittal, and iv) Sweta Mittal. All of these four Directors have been appointed on 30.09.2011. This means that Sh. Prem Kumar Mahato was not a Director on the date of giving affidavit However, he has clearly stated (in the affidavit) that he is a Director of M/s S.R. Cables Pvt. Ltd. on the said date. x) Original of the share application forms and the accompanying resolutions were not produced. However, the photocopies of the share application forms show that all the share application forms are having same style (e.g. i) name of the appellant company has been written in bold letters, ii) after the address of the appellant company, there is a line made by. = signs, and iii) name of the applicant company has been written ....
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....2.49,694 (7332) Capital Vrindavan Services Pvt.,Ltd. 5,97,00,000 7,64,615 7.54,615 7. M/s Nandal Finance & Leasing Pvt. Ltd. 21,99,00,000 21,836 21,835 5,865 xiv) The Staff's salary paid in these seven companies (who have been claimed to have subscribed to shares of the appellant company) are tabulated as under. It may be seen that this meager expense on Staff's salary does not justify the creditworthiness of these companies to extend the kind money under consideration. S. No. Name of the purported share holder Amount received (Rs.) Staff's Salary (p.m.). (in Rs. ) (A.Y. 09- 10) 08- (A.Y. OD) 1. S.R. Cables Pvt. Ltd. 3.00,00,000 17,604 14,625 2 Aasheesh capital Services Pvt. Ltd. 28,95,00,000 13,417 6,615 3. Aquiss Pvt. Ltd. 19,20,00,000 10,000 NII 4. Sunny cast and forge Pvt Ltd 12,39,00,000 29,290 16,334 5. Karishma Inds. Itd. 20,10,00,000 28,3341 16,334 6. Vrindavan Capital Services Pvt. Ltd. 5,97,00,000 6042 The company was not in existence 7. M/s Nandal Finance & Leasing Pvt. Ltd. 21,99,00,000....
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....ntly, these persons were not produced before undersigned in spite of sufficient opportunities afforded during the present appellate proceedings. 5.30 In view of the above discussion, I have no hesitation to hold that the appellant failed to discharge the onus ¡to prove genuineness of the transactions under consideration. 6.1 Ground No. 1 is general in nature, which need no specific adjudication. 7.1.1 Vide ground no. 2, the appellant has contested the addition of Rs. 111.60 crores made by the AO u/s. 68 on account of share application as well as share premium amount. It is the argument of the appellant that it has discharged the onus of proving identity and creditworthiness of the investors and genuineness of the transactions. 7.1.2 I have perused the documentation relied upon by the appellant to explain the identity, genuineness and creditworthiness of the above stated seven (share subscribing) companies. As discussed earlier, the confirmations of accounts and confirmation in form of certificate are not with original signatures and even photocopy of signatures are of someone else other than a director. The bank account/as-usual records dep....
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....rofits and loss account is looked into it seems complete dry as interest against investment running in crores the income shown is few. thousand and so is the total turnover. Adding mope -to this in the statement given by one of the directors of Suraj Corporate Services Pvt, Ltd. it has been clearly accepted that Suraj Corporate Services Pvt. Ltd. is an accommodation entry provider. and just a paper company. This modus operandi of accommodation entry provider cannot get itself covered under the shadow of PAN, income-tax return, audited financial statement and proof of transactions by account payee cheques. One has to go ahead to rethink why such company is incorporated. In normal course a business entity ¡is incorporated to earn profits and capital is contributed for doing the same but when the capital investment or reserve and surplus created is just used to invest in other companies without having any return and the gross turnover of the company is not having any direct connection with the voluminous bank transaction then such companies end up into a paper company. 19. From going through all the above judgments and decision, we find that along with evidences, surrou....
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....just as to facilitate the Revenue to keep track of transactions and thus PAN cannot be blindly and without consideration of surrounding circumstances treated as sufficient disclosing the identity of individual". 21. We further observe that Hon. Delhi High Court in the case of CIT V Empire Builtech P Ltd 361 ITR 258 (Del), has he Id that when assessee does not produce evidence or tries to avoid the appearance before the Assessing authority it necessarily creates difficulties and prevents ascertainment of the truth and correct facts as the Assessing Officer is denied the advantage of the attendance or factual assertion by the assessee before him. If an assessee deliberately and intentionally fails to produce evidence before the Assessing Officer with the desire to prevent enquiry or investigation an adverse opinion should be drawn. The assessee had not discharged the initial onus to establish the identity, creditworthiness of the share applicants and the genuineness of the transactions. The additions made by the Assessing Officer were justified and sustainable. 22. We are, therefore, of the view that in the given facts and circumstances of the case and respectfully ....
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....r and; a) restrict the addition u/s. 68 to only the peak unexplained credit in each case after elimination circular transaction. b) To eliminate taxation of the same amount multiple times, due 'to the chain transactions which resulted due to layering indulged by the assessee. c) Consider the material on record and the precedence available on the issue and determine the percentage of commission, which the assessees would hâve earned and bring the same to tax. 24. Before parting we make it dear that the burden of proof lay on the assessee. It is for the assessee to demonstrate the chain of transaction, the layering indulged by him, the calculation of peak unexplained credit etc. and to prove each credit in the books of each assessee. In the result ad these appeals are set aside to the file of the AO for fresh adjudication in accordance with law. " 11. The Delhi Bench of the ITA T in the case of M/s Vijay Conductors India Pvt. Ltd., ITA No.3484/De//2O13, Assessment year 2008-09, order dated 28.1.2015 at para 17 held as follows:- "17. Thus, there is an order of the Settlement Commission as well as the Additional Commission....
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....uit entities". The said orders of the Settlement Commission or of the Additional CIT were binding on the AO. It is not in dispute that the Respondent Assessees are the conduit entities and not the beneficiaries. Consequently, the order of the ITA T deleting the addition under Section 68 of the Act in their hands does not suffer from any legal infirmity." 13. The A O is directed to follow the propositions laid down in these case laws." 7.3.2. The above stated cases are related to known and accommodation entry provider Sh. Tarun Goyal and S.K. Gupta. In these cases providing accommodation entry is admitted fact. Since, the cases of Sh. Surendra Kumar Jain and Sh. Virendra Kumar Jain have been equated with the cases of Sh. Tarun Goyal and S.K. Gupta by the advocate representing Sh. Surendra Kumar Jain and Sh. Virendra Kumar Jain as well as by the Hon'ble ITAT, therefore, it becomes admitted position by Sh. Surendra Kumar Jain and Sh. Virendra Kumar Jain as well as finding returned by the ITAT. 7.4. It is therefore, evident that the Jain brothers admitted before the Hon'ble ITAT that they alongwith their group companies were engaged in the business of pro....
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....placement and as already stated above, the Delhi High Court in several cases such as NR Portfolio Pvt. Ltd., N. Tarika Property Invest. (P) Ltd. (221 Taxman 14) and Navodaya Castle Pvt. Ltd.(226 Taxman 190), on identical facts of the case wherein it was found that there were corresponding deposits in the bank accounts before issue of share application cheques, has held that the certificate of incorporation, PAN etc. were not sufficient for purposes of identification of the subscriber company. The Supreme Court of India has upheld the Delhi High Court's orders in N. Tarika Property Invest. (P) Ltd and Navodaya Castle Pvt. Ltd. (51 taxmann.com 387 and 56 taxmann.com 18) by dismissing the assessee's SLP. 7.6. The Hon'ble Delhi High Court in CIT vs. Focus Exports Pvt. Ltd. (228 Taxman 88) while examining the provisions of section 68 has ruled that where the assessee. failed to offer a reasonable and acceptable explanation regarding the source and nature of credit, the AO is entitled to draw inference that the. receipt are that of an assessable nature. The High Court observed as under: "9. A bare reading of Section 63 of the. Act suggests that there has to be credit of....
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....ers in order to ascertain whether they are financially sound and are able to purchase shares for substantial amounts and if they have borrowed money for making the investment, whether they were capable of repaying them having regard to the nature of their business, volume of the business etc. it is for this purpose that it is necessary for the assessee, in appropriate cases, where the facts and surrounding circumstances justified, to seek the assistance of the principal officer of the subscribing companies and present them before the AO so that he will be in a position to explain in detail the source from which the thus shares were subscribed. A curious aspect of the matter which cannot be lost sight of is that the record reveals the assessee's ability to procure the share applicants bank statement. This speaks volume about its conduct and belies the arguments about its inability to ensure the presence of such company's Principal Officers." 7.8. The Hon'ble High Court in the case of N.R Portfolio observed as under: "29. In CIT v. Nipun Builders & Developers (P.) Ltd. [2013] 350 ITR 407 (Delhi), this principle has been reiterated holding that the assess....
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....ork or documentation but genuineness, creditworthiness, identity are deeper and obtrusive. Companies no doubt are artificial er juristic persons but they are soulless and are dependent upon the individuals behind them who run and manage the said companies. It is the persons behind the company who take the decisions, controls and manage them." 7.9 The Hon'ble jurisdictional High Court in the case of CIT II vs. MAF Academy (P) Ltd. held as under: 23. The contention that the Revenue must have evidence to show circulation of money from the assessee to the third party is fallacious and has been repeatedly rejected, even when Section 68 of the Act was not in the statute. In A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807, Supreme Court observed that it was not the duty of the Revenue to adduce evidence to show from what source, income was derived and why it should be treated as concealed income. The assessee must prove satisfactorily the source and nature of cash received during the accounting year. Similarly observations were made in CIT vs. M. Ganapathi Mudaliar [1964] 53 ITR 623 (SC), inter alia helding that it was not necessary for the Revenue to locate the e....
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....ompanies, investigation made by the Revenue unearthed the material which overwhelmingly demonstrated that neither in respect of identity nor (in respect of) the creditworthiness of the seven (share subscribing) companies, nor (in respect of) genuineness of transactions, the onus of which rested on the appellant has been discharged. The explanation offered regarding the amounts credited in the books of accounts of the appellant has correctly been found to be unsatisfactory by the AO. As far as, amount of Rs. 80,000/- each received from Sh. Surendra Kumar Jain and his wife Smt. Priti Jain is concerned, the main dispute is about genuineness. Undisputedly, this amount has been received in cash and not through the banking channel. Nothing has been produced in support of genuineness except Xerox copy of share application forms. It is not the case that Sh. Surendra Kumar Jain or his wife were not having bank accounts. In spite of specific requisition made through letter dated 30.11.2017 and pursued vide order sheet entry dated 06.12.2017 and letter dated 15.12.2017, the appellant refrained from producing original share application forms, shareholder register, register of minutes of the me....
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.... AR chose not to attend the hearing, it cannot take shelter that it was not confronted with the material used in this appellate order. 7.13 In view of the above discussion, this ground (no. 2) is dismissed and the addition made by the AO with regard to unexplained credit of Rs. 111.60 crore is upheld. 8.1 Vide ground no. 3, the appellant has stated that the AO has grossly erred in alleging that notices u/s. 133(6) and summons u/s. 131 were received back which is otherwise duly served and complied by shareholders. 8.2 The relevant portion of the assessment order is reproduced as under: "3. During the year the assessee has received money on account of allotment of shares to the tune of Rs. 18,60,30,000/- and share premium money of Rs. 93,01,50,000/-totaling Rs. 111,61,80,000/-where asked to submit names and addresses of persons from whom this money was received. It was submitted vide letter dated 04/11/2011 that a sum of Rs. 111.60 crores was received from the following seven parties. The rest of Rs. 1.80 lacs was received from the two Directors Sh. S.K.Jain and Smt. Priti Jain. 1. M/s S. R. Cables Pvt. Ltd 3,00,00,000 2. M/s Aashish....
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..... of the assessee was required to produce the Directors of the corporate share holder (to whom shares were allotted during the year and from whom share premium was allegedly received) for examination on oath so that the genuineness of these transactions could be verified. The case was adjourned to 23.12.2011. 7. On this date, Sh. S. K. Jain, Director of the assessee company appeared and filed written submissions which have been kept on record. The Directors of the shareholders companies were a Non-Banking Financial Corporation. It has shown a sum of Rs. 99,11,93,336/- under the head loans and advances. Out of these a sum of Rs. 60 crores have been paid to two companies as Share Application money. The purpose of examining the Directors of three Corporate Shares holder was to locate as to what was the big purpose in investing this huge amount without any return on such investment. No normal and prudent person shall invest its hard-earned money in a non-earning proposition. Those directors were also to be asked as to why and for what purpose, they agreed to pay premium of Rs. 50/-per share, as there were hardly investment of the assessee company and as per the Accountancy Pri....
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....nding on the term of loan, tenure, creditworthiness of debtors etc. The AR further contested that the Books of Account of the appellant was produced before the Assessing Officer during the assessment proceedings it was test checked and found to be maintained in normal course of business. 9.5 I have perused the assessment order as well as order sheet in the assessment folder(a copy enclosed as Annexure-2 to this order), there is no mention of production or checking of books of accounts. It is noticed that the order sheet entry dated 20.12.2011 says as under: "20.12.2011 Sh. S.K. Jain, Director appeared and filed the requisite details. Asked to explain why the share application money of Rs. 111,61,80,000/- raised during the year be not treated as unexplained u/s. 68 of the I. T. Act 1961 as the summons remained unserved in most of the cases. Moreover, directors could not beproduced u/s. 131 of I. T. Act 1961 for statement. 2) Please explain why the interest @ 12% (Twelve Percent) should not be charged on the loans granted in absence of loan agreement. Case adjourned to 23/12/2011." 9.6 The entry on order sheet dated 23.12.2011 says, "Sh. S....
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....lso, the AR did not make any oral arguments regarding this issue. The assessment order contains satisfaction of the AO regarding initiation of penalty which is a preliminary stage. The penalty proceedings are separate proceedings and the appellant would get full opportunity to represent its case. At this stage the ground is besides the points and also premature. Therefore, this ground (no. 6) is dismissed." 4. We have given our thoughtful consideration to the assessee's and the Revenue's vehement submission reiterating their respective stands. We find no merit in the assessee's case so far as correctness of the impugned addition is concerned. We make it clear that various landmark judicial precedents in Sumati Dayal Vs. CIT (1995) 214 ITR 801 (SC), CIT Vs. Durga Prasad More (1971) 82 ITR 540 (SC) and PCIT Vs. NRA Iron & Steel Co. (2019) 412 ITR 161 (SC) have settled the issue in the department's favour that any explanation tendered in income tax proceedings ought to be appreciated in light of human probability(ies) after removing all blinkers. And that mere submission of documentary evidence itself does not absolve the assessee from discharging its onus to prove genuineness of s....
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....e as per the ITR-V Remarks Sunny Cast Forge Ltd. Correcta ONNY CA Signature per the ITR-V Director (Prem Kumar Mahato). 6 R Cables Pvt. Ltet. Signature per the ITR-V of Director( Prem Kumar Mahato) Nandal Finacne & Leasing Pvt. Ltd. Chhaft Authorised Signatory/D 07 Signature 86 per the ITR-V in ofDirector(Anil Kumar Bansal). However. per annual account signature of another Director Sh. Chhagna Lai are as under: Chhave Karishma Industries Ltd. IXTA INDIAN Signature as per the ITR-V is of m Signatory'E Director(Naresh Kumar Gupta). Aquiss Pvt. Ltd. Signature as per Badap the ITR-V is of Director(Pradeep Kumar Sharma). Aashoosh Capital Services Pvt. Ltd. jeesh Capre Brin Signature as per the ITR-V is of Director(Brijesh : Stand Sienato Singhal). jeesh Capre Brin Signature as per the ITR-V is of Director(Brijesh : Stand Sienato Singhal). Document 2 Name of the Company Signature as por ITR-V Signature as per confirmation of account Sunny Cast & Forge Ltd UNNY CAIN 4 8' S R Cables Pvt. Ltd. Prahato Yours TalkFut .R. CABLEB PVT. Nandal Finacne & Leasing Ltd. re Props C Karishma Industries Ltd. Krimbaker Aquiss Pvt. Ltd. Badoo IQTES PR....
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....nt. signature of another Director Sh. Chhagna Lal are as under: Chhave Karishma Industrias Ltd. Signature por the ITR-V Is of Director(Naresh Kumar Gupta). Aquiss Pvt. Ltd. Signature as per Badap the ITR-V is of Director (Pradeep Kumar Sharma). ONNY C on No. Of THE 5 R Cables Pvt. Ltd. Aasheesh Capital Services Pvt. Ltd. Bem Signature as - per the ITR-V is of Director (Brijesh Singhal) wetend Sienato Document 6 RUPEE TERM LOAN AGREEMENT THIS RUPEE TERM LOAN AGREEMENT ("This Agreement") is made at New Delhi on this 31" day of July 2009 by the among I. Transnational Growth Fund Limited (TGFL) h RBI Regd. NBFC Co. Registered under the Companies Act, 1956, and having its Regd. Office at C-73, 7th floor, Himalaya House, 23, KG Marg, New Delhi through its Director Mr. Surender Kumar Jain, Resident of 555, Double Storey, New Rajinder Nagar, New Delhi-110060 "Lender(s)" 2. Pooja Finlease Limited a company Regd. Under the Companies Act, 1956 and having its Regd. Office J-398, New Rajinder Nagar, New Delhi-110060 through its Director Sh. Lun Karan Mehta and Authorised Representative Mr. Jeth Mal Mehta Residence of J-398, New Rajinder Nagar, New Delhi....