TaxTMI 
TaxTMI 
2025 (3) TMI 2244
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.... is a delay of 131 days in filing both of these appeals. The revenue/appellant has filed applications for condonation of delays supported by affidavits. In these documents, Ld. DR for revenue explained, the revenue has submitted following reason for delay: "I, Sanjeev Kumar, presently posted as Income Tax Officer-5(1), Indore do solemnly affirm as under:- 1. I am assessing officer having jurisdiction over the case of M/s. Umang Developers, Indore, PAN: AACFU7969E, Appeal no. ITA No. CIT(A), Indore2/10840/2019-20 dated 30/05/2023 for A.Y. 2017-18. 2. The order of Ld. CIT(A) was received in the office on 31/05/2023 as per ITBA appeal register but the same was not reflected in the list generated on 01/06/2023. Due to which it do not come to the notice of the undersigned that this order has been passed by the CIT(A) against the revenue. Thereafter, Scrutiny report was submitted before the Pr.CIT-1, Indore which was sent back with the observation of the Pr.CIT-1, Indore. Again scrutiny report was submitted and letter of authorization were issued by the Pr.CIT-1, Indore on 06/12/2023. Accordingly, this appeal has been filed on 08/12/2023 delayed by 130 days. ....
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....he grounds raised in this appeal are as under: "1. On the facts and circumstances of the case, Ld. CIT(A) erred in deleting the addition of Rs. 35,00,000/- w.r.t. transactions with M/s. KCL Infra Project merely on the basis that the AO had not given any rebuttal, ignoring the fact that M/s. KCL Infra Project is a well-known penny stock company and involved in providing entries to its beneficiaries. 2. On the facts and circumstances of the case, Ld. CIT(A) erred in deleting the addition of Rs. 1,81,33,897/- u/s 68 as bogus sundry creditors on the basis of remand report submitted by the AO. Ld. CIT(A) ignored that the issue required proper verification and AO in his report clearly mentioned that authenticity of bills submitted by the assessee cannot be verified at that time due to Covid-19 Pandemic and lockdown due to second wave of Covid-19. 3. On the facts and circumstances of the case, Ld. CIT(A) erred in deleting the addition of Rs. 57,50,000/- merely on the basis that the AO had not given any rebuttal, ignoring the fact that AO had not accepted the contention of the assessee and object that the same cannot be entertained in his remand report. ....
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.... AO in his Remand Report has categorically stated that 'in respect of the amount received in the year through, the assessee has submitted relevant documents during the course of remand proceedings'. It is clear that when given chance of rebuttal, the AO has not given any adverse finding. However, the AO has taken a legal stand that additional evidences cannot be entertained as they do not fulfil the conditions laid down in rule 46 of the IT Rules. Thus, one thing is clear that the AO has not faulted with merits of arguments / additional evidences submitted by the appellant rather admitted that relevant documents have been submitted by the appellant. But the AO is not willing to entertain them under the technicality of Rule 46A. Rule 46A of the IT Rules, 1962 is reproduced as under: "46A. (1) The appellant shall not be entitled to produce before the Deputy Commissioner (Appeals) or, as the case may be, the Commissioner (Appeals), any evidence, whether oral or documentary, other than the evidence produced by him during the course of proceedings before the Assessing Officer, except in the following circumstances, namely :- (a) where the Assessing Officer has refused to ....
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....(3)]. In this case the appellant has provided reasons which prevented him to present these evidences before the AO, including that of mistake of his Counsel, because of which certain documents could not be submitted before the AO in time. These have been found sufficient enough reasons and hence additional evidences are admitted. Most importantly purpose of the Income Tax Act is to collect rightful tax from assesses and therefore in situations where AO is convinced on merits of the matter, he cannot say that the additional evidences submitted by assessee cannot be entertained on account of technicalities of Rule 46A. As the appellant has submitted all the relevant documents before the AO (which he could not at the time of assessment) in respect of credits received during the year and the AO has not given any rebuttal, no addition is called for with respect to the fresh credit of Rs. 57,50,000/- received by the appellant from the above named four lenders during the previous year relevant to AY-201718. It is to be appreciated that various Courts of Law have ruled that once an appellant has discharged the primary onus of giving evidences in respect of identity, creditworthiness and ge....
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....y AO himself in last column of the aforesaid list of 17 loans. Further, the assessee filed A/c Confirmation, ITR and Bank Statement of KCL to CIT(A) as additional evidences which the CIT(A) forwarded to AO for conducting remand-proceeding. Thereafter, the AO filed remand-report to CIT(A) as under: 9. KCL Infra Project 35,00,000/- Assessee has submitted copy of confirmation, copy of ITR and relevant part of Bank statement. Though in respect of this lender, to substantiate the claim, the assessee has submitted copy of confirmation, copy of ITR and relevant part of the bank statements. But it is worth mentioning that time to time the information has been passed on by Investigation Wing considering this entity as entry provider. The company is found to be involved in providing Penny stock and bogus accommodation entries. The name of the company also appeared in the list of Penny stock companies appearing in list forwarded by the CBDT upon reference from PMO. Even in some cases relying upon information, proceedings of re-assessment is initiated. Therefore, it is requested to decide the issue of loan taken from KCL Infra Project on merit because relevant transaction may be du....
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....he Hon'ble Jurisdictional Tribunal held otherwise on perusal of the audited accounts of the lender - demonstrating enough reserves and surplus. Facts on record, appellant's submission and case laws have been perused. The addition was made first by the AO in assessment order u/s 143(3) dated 29.12.2019 for want of documents other than loan confirmation. The appellant then submitted additional evidences viz., ITR, bank statement, etc, to evidence identity, genuinity and credit worthiness of the lender. The evidences being additional were remanded to the AO for rebuttal. The AO examined the evidences and the appellant in remand proceeding and then in the remand report did not rebut these evidences but commented that this loan may be dubious as the lender was named as entry provider in Investigation Department report and as a penny stock in CBDT list. However, the AO never gave a copy of the relevant extract to the appellant for cross-examination or comment. Thus Report, if any, indicating the lender has been used by the AO without affording any opportunity to the appellant and against the appellant at the time of concluding the remand report. It is also noteworthy tha....
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....n taken from "Mr. Manan Jhawar" is at parity with the impugned loan taken from KCL in the sense the AO, in remand-report, raised the very same doubt as raised for loan from KCL. The AO noted that Mr. Manan Jhanwar was a relative of director of KCL and KCL was a penny stock company. The CIT(A), after considering this reporting made by AO in remand-report, deleted the addition qua the loan taken from Mr. Manan Jhanwar; the order passed by CIT(A) is re-produced below for an immediate reference: "Sr. No. 10: Manan Jhawar: As regards receipt of credit of Rs. 47,50,000/- from Mr. Manan Jhawar, is concerned the AO in his assessment-order made this addition for the reason that copy of ITR, bank statement and lender's capital account to show his credit worthiness were not furnished. These additional evidences submitted in appellate proceedings were remanded to the AO for rebuttal. In the Remand Report, the AO has recorded that the appellant has submitted copy of loan confirmation, relevant part of bank statement and copy of ITR. Thus, identity, creditworthiness and genuinity of the transactions is demonstrated by the appellant. The AO has neither challenged no....
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....addition qua the loan of Rs. 35,00,000/- taken from KCL. We uphold the order of CIT(A) and the Ground raised by revenue is dismissed. Ground No. 2: 21. In this ground, the revenue claims that the CIT(A) has erred in deleting the addition of Rs. 1,81,33,897/- made by AO u/s 68 qua sundry creditors. 22. The AO has made this addition in Para 7 of assessment-order. During assessment-proceeding, the AO observed that the assessee has shown current liability of sundry creditors at Rs. 1,81,33,897/- in its Balance Sheet. When the AO asked assessee to justify the claim of sundry creditors, the assessee filed its reply giving a complete list of creditors and seeking more time for submission of A/c Confirmations. The list filed by assessee is placed at Page 169 of Paper-Book, the same is re-produced here for an immediate reference: The AO, however, rejected assessee's submission and treated the impugned creditors as unexplained and made addition by following order: "7.......The assessee is totally unjustified in making above claim. Along with its submission the assessee has submitted a list in which merely of name of such creditors totaling to Rs. 1,81,33,897/- is mention....
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....n, it was found that the assessee has shown Current Liability i.e. 'Sundry Creditors' to the tune of Rs. 1,81,33,897/-. Vide a query the assessee was requested to furnish the requisite documentary evidences so as to justify this claim. Later, the assessee submitted a list of 'Sundry Creditors' exceeding Rs. 2 lakh. No other details were furnished so as to justify this claim and other documentary evidences giving details of transactions carried out which resulted into raising of 'Sundry Creditors'. It was very surprising that assessee's books of account are audited within the meaning section 44AB of the Income Tax Act. The assessee itself has claimed in its submission that these creditors are actually trade creditors. But even after availing so many opportunities the assessee was totally unable in furnishing copy of ledgers of such creditors maintained in assessee's books of accounts or other relevant details too. Now the additional evidences submitted by the assessee at appellate stage, are duly perused, in which the assessee has contended that out of total addition of Rs. 1,81,33,897/-, addition of Rs. 1,63,21,564/- pertains to the opening ....
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....very same contention that the assessee is at fault for not submitting evidences to AO when the AO called the same. 26. Per contra, Ld. AR for assessee relied very strongly upon the order of CIT(A). He re-iterated the vehement findings made by CIT(A). He submitted that the AO has not made any objection in remand-report against the evidences filed by assessee and that the assessee cannot be penalised for AO's inability to verity the evidences due to Covid-19 pandemic. 27. We have considered rival submissions of both sides and perused the case record including the orders of lower-authorities. The addition of Rs. 1,81,33,987/- made by AO in respect of sundry creditors shown in assessee's Balance-Sheet is an issue of controversy in this ground. Admittedly, the assessee filed a list of 25 creditors, re-produced above, to AO and sought time for filing A/c Confirmations of creditors. The AO, however, rejected assessee's request and treated the entire amount of outstanding liability appearing in Balance-Sheet as unexplained and made addition. During first-appeal proceedings the assessee filed the very same list to CIT(A) with A/c Confirmations and Invoices of creditors in terms of Rul....
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....ded by AO, the assessee took new loans of Rs. 57,50,000/- only during current year from 4 creditors and the rest was opening balance brought forward from earlier year. The details of new loans as noted by CIT(A) in a tabular format on Pages 6-8 of impugned order, are re-produced below: Sr. No. Name of lender Amount (in Rs. ) AO's remarks in remand Report on additional evidence 1 Chandra R. Bakhru 3,50,000/- As per ledger, received during the year. Submitted copy of confirmation PAN, relevant part of Bank statement showing amount transferred through bank. 2 Heaven construction P. Ld. 45,00,000/- As per ledger, received during the year. Submitted copy of confirmation, copy of ITR A.Y. 2017-18. 3 Poonam Udhav Rajani 6,00,000/- As per confirmation, received during the year. Submitted copy of confirmation, copy of ITR A.Y. 2017-18. 4 Udhavdas Rupchand Rajani 3,00,000/- As per confirmation, received during the year. Submitted copy of confirmation, copy of ITR A.Y. 2017-18. Total 57,50,000/- Now, the revenue is aggrieved by deletion of addition of Rs. 57,50,000/- qua these new loans taken during the y....
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....m producing before the Assessing Officer any evidence which is relevant to any ground of appeal ; or (d) where the Assessing Officer has made the order appealed against without giving sufficient opportunity to the appellant to adduce evidence relevant to any ground of appeal. (2) No evidence shall be admitted under sub-rule (1) unless the Deputy Commission (Appeals) or, as the case may be, the Commissioner (Appeals) records in writing the reasons for its admission. (3) The Deputy Commissioner (Appeals) or, as the case may be, the Commissioner (Appeals) shall not take into account any evidence produced under sub-rule (1) unless the Assessing Officer has been allowed a reasonable opportunity- (a) to examine the evidence or document or to cross-examine the witness produced by the appellant, or (b) to produce any evidence or document or any witness in rebuttal of the additional evidence produced by the appellant. (4) Nothing contained in this rule shall affect the power of the Deputy Commissioner (Appeals) or, as the case may be, the Commissioner (Appeals) to direct the production of any document, or the examination of any witness, to enable....
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....itional evidences were not filed to AO without any valid reason. He submitted that the CIT(A) is wrong in accepting additional evidences over-ruling the objection raised by AO. 35. Per contra, Ld. AR for assessee relied very strongly upon the order of CIT(A). He re-iterated the order of CIT(A) and submitted that the CIT(A) has given vehement observations and conclusions; his order must be preserved. 36. We have considered rival submissions of both sides and perused the case record including the orders of lower-authorities. After a careful consideration, we find that the assessee filed evidences of impugned loans to CIT(A) during first-appellate proceeding invoking Rule 46A and acting upon assessee's request the CIT(A) forwarded those evidences to AO. The AO filed remand-report wherein he has not expressed anything adverse against the evidences but raised only a limited objection that the additional evidences cannot be entertained. But the CIT(A) has taken in account the verdict of Rule 46A which permits admission of additional evidences in sufficient situations. Further, the CIT(A) has not only accepted assessee's explanation as sufficient to invoke Rule 46A but also accepted....
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....5, the revenue is assailing the CIT(A)'s action of admitting additional evidences during first-appellate proceedings. 39. We have already decided identical ground in appeal of AY 2017-18 in earlier part of this order. Since the underlying facts and issue remain same, our adjudication therein would apply mutatis mutandis. Carrying the same, this ground of revenue is dismissed. Ground No. 1: 40. In this ground, the revenue claims that the CIT(A) has erred in deleting the addition of Rs. 5,03,68,443/- made by AO qua unexplained loans taken by assessee, ignoring the adverse reporting made by AO in remand-report. 41. The AO has made this addition vide Para 4 of assessment-order. During assessment-proceeding, the AO observed that the assessee has shown liabilities of unsecured loans. The AO has noted that when he asked assessee to explain the same, the assessee initially filed reply on 21.04.2021 showing that he has taken loans and paid interest amounting to Rs. 5,03,68,443/- (Rs. 4,40,37,039/- of principal loans + Interest of Rs. 63,31,404/-). When the AO asked assessee to submit documentary evidences, the assessee filed another reply on 24.05.2021 with certain documentary e....
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....erring the huge amounts, the same amount has been credited to KCL bank Accounts, thereafter the KCL transfer the same to Umang Developers. Total Rs. 4,02,92,500/- For which show cause dated 07/06/2021 has been issued to the assessee for which the assessee replied on 01/07/2021, but the assessee submitted only the Bank Statements of KCL Infra Projects And Rohit Creations. After verification of the lenders bank accounts, it is found that on each transaction date a lump sum amount has been transferred to the lenders account one or two days before. Assessee has also failed to provide creditworthiness of lenders as their income in the ITR is substantially less compared to loan amount given by them. The source of lenders income is not proven from given submission. It is also found that the assessee has paid Interest @ Rs. 13,76,982/- out of total interest paid claim to the tune of Rs. 63,31,404/-, for the loan taken during F.Y 2017-18 i.e. A.Y 2018-19, Rest amount of Interest has been paid for the Loan amount which has been taken before the F.Y 2017-18 and as per Assessment-Order for A.Y 2017-18, the assessing Office has disallowed the total lo....
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....cannot be accepted. In view of these findings, the AO disallowed an amount of (Rs. 4,40,37,039/- loan amount + Interest Rs. 63,31,404/-) = Rs. 5,03,68,443/-. The AO added this to the total income of the appellant as unexplained cash credit u/s 68 of the Act. In course of appellate proceedings, additional evidences were filed by appellant. The matter was remanded to the AO for examination and rebuttal. In the remand report, the AO reproduced verbatim para 4 of assessment order and then commented as under: "The assessee has submitted relevant documents during the course of remand proceedings, the same cannot be entertained as it does not fulfill the conditions laid down in Rules 46A of the IT Rules. However, the case may be decided on merit." Thus, the AO has not given any rebuttal to the additional evidences submitted by the appellant and taken recourse to technicalities of Rule 46A. For the sake of easy reference, AO's remarks on these lenders is reproduced hereunder: XXX (already re-produced in foregoing para in a Tabular Format. Hence not being re-produced to avoid duplication) Facts on record, appellant's submission a....
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.... not have net worth to lend or that there was complicity between lender and the appellant and therefore the transaction was ingenuine. No such thing has been brought on record by the AO. Neither was this attempted during remand proceedings. This addition therefore cannot be sustained in absence of clinching evidence. Manisha W/o Mohan This lender has lend Rs. 1,52,67,500/- to the appellant. It is seen that this lender has filed ITR for A.Y. 2018-19, declaring income of Rs. 13,62,510/- with exempt income of Rs. 38,95,070/-. The AO in assessment order noted that bank statement were not complete and did not tally with bank book. Further, it's pointed out that before every credit given by the lender to the appellant, there was credit to lenders account by Mr. Mohan Jhawar. However, during appeal, the appellant submitted complete bank statement and the same were remanded to the AO. The AO did not offer any rebuttal. It is to be noted that the lender is a bonafide income tax payer, filing regular tax return and for the A.Y. 2018-19, has declared income of Rs. 13,62,510/-, with exempt income of Rs. 38,95,070/-. Thus, the lender is flush with ample income dur....
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.... has been established. By submitting loan conformation, bank statement and ITR of the lender, the appellant has discharged the initial onus upon it. Thereafter it was incumbent upon the AO to prove its point through necessary enquiry. In absence of any findings with respect to complicity between lender and appellant and inadequacy of net worth of the lender, no adverse view can be taken on this loan. KCL Infra Project Ltd. This person has advanced Rs. 1,82,25,000/- to the appellant. Bank Statement and ITR of the lender, declaring income of Rs. 39,75,580/- for A.Y. 2018-19 has been submitted by the appellant. The AO has given findings that before advancement of loan to the appellant the lender has received money, which has been used to lend money to the appellant. However, the AO has not found out as to which person has credited money to lender's account and has not linked the person crediting money to lender's account with the appellant and thus establishing complicity. Also, it is seen that the lender has ample income of Rs. 39,75,580/- during the relevant assessment year and that no net worth analysis of the lender has been done by the appellant. The app....
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....efore." This, according to Ld. AR, shows that the AO has accepted 'source' of loans taken by assessee but was expecting the assessee to explain 'source of source' which is not permissible in the provision of section 68 before introduction of first proviso to section 68 through Finance Act, 2022. So far as the 2nd component of interest on loans is concerned, Ld. AR submitted that after adjudication by CIT(A) and ITAT, there survives no addition of principal loans either in current AY 2018-19 or preceding AY 2017-18. Therefore, when the loans have been accepted as genuine, the disallowance of interest has not legs to stand. With these submissions, Ld. AR prayed that the entire addition of Rs. 5,03,68,443/- consisting of principal loans and interest thereon, made by AO is rightly deleted by CIT(A) and hence the impugned order of CIT(A) must be upheld. 46. We have given a careful consideration to rival submissions of both sides and carefully perused the documents held on record including the orders of lower-authorities. The issue in this ground relates to the addition of principal loans and interest thereon. So far as addition of principal amounts is concerned, we firstly agree that....
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....g entries to its beneficiaries." 48. After deliberations during hearing, we agree with the submission of Ld. AR for assessee that nowhere in the assessment-order as well as remand-report, the AO has mentioned that KCL was a penny stock company and involved in providing entries to beneficiaries as being claimed in the ground raised by revenue. Although such an allegation was made by AO in the remand-report of preceding AY 2017-18 but there is no such allegation in current AY 2018-19. It appears that the revenue has copied this ground from preceding AY 2017-18. Therefore, in the first place, the ground raised by revenue is baseless. Even otherwise, the merit of identical ground raised by revenue in preceding AY 2017-18 (Ground No. 1) has already been adjudicated by us in earlier part of this order wherein we have dismissed revenue's ground after due examination. We adopt the same reasoning and conclusion mutatis mutandis and accordingly this ground raised by revenue in AY 2018-19 is also dismissed. 49. Before closing, we would like to mention one more point of this issue although it was not submitted by either side during hearing but it is necessary for the sake of completeness....
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....idences filed by assessee and deleted addition by passing following order: "Ground No. 4: The AO found out that the appellant has shown sundry creditors to the tune of Rs. 2,03,22,536/-. The AO asked for requisite documentary evidences to justify this claim. The appellant furnished copy of ledgers of such creditors maintained in its books of account but did not furnish all bills/vouchers, copy of bank statement highlighting the transactions. The AO also noted that some of the confirmations were not legible. The AO computed that out of the total sundry creditors of 2,03,22,536/-, an amount of Rs. 1,47,16,146/- shown by the appellant as purchase during the year was unexplained credit and added the same to the income of the appellant u/s 68 of the Act. During the appellate proceeding, the appellant submitted additional documents which were remanded to the AO for examination and rebuttal. The appellant has submitted details of creditors including Name/PAN/Address & amount, copy of ledger account of creditors, confirmation by creditors and copies of bills. The appellant has explained that due to second wave of Covid-19, confirmation of accounts and bills of so....
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....ocedure. The AO filed remand-report which is re-produced above. In remand-report, the AO has not reported any objection against the evidences filed by assessee, he has merely mentioned his own inability to verify documents due to Covid Pandemic but even while mentioning so, the AO reported the CIT(A) to take a decision on merit. The CIT(A) has considered the points raised by AO as well as the documents filed by assessee and thereafter deleted the addition on merit. In our considered view, the order passed by CIT(A) is very correct and does not suffer from any error or perversity. Hence, we have no reason to interfere with the order of CIT(A), the same is hereby upheld and this ground is dismissed. Ground No. 4: 56. In this ground, the revenue claims that the CIT(A) has erred in deleting the addition of Rs. 4,05,38,902/-. For the sake of immediate reference, we re-produce the ground raised by revenue: "4. On the facts and circumstances of the case, Ld. CIT(A) erred in deleting the addition of Rs. 4,05,38,902/- ignoring the fact that the adverse finding of AO submitted in Remand report where it is specifically concluded that an amount of Rs. 2,85,64,210/- (Rs. 1,56,25,....
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....r concluded that Rs. 1,56,25,000 + Rs. 1,29,39,210/- = Rs. 2,85,64,210/- should be considered from undisclosed sources and may be added as unexplained credit within the meaning of section 68 of the Act. The appellant has submitted that fresh capital received from the partners is only Rs. 1,56,25,000/- and remaining increase to partners' capital is attributed to interest credited to the partners by the appellant. Thus, on the quantum of fresh capital introduced during the year, there is no dispute between the appellant and the AO in Remand Report. The appellant further submitted that it has furnished ITRS/PAN/Copies of Bank Statement and Confirmation from the partners to prove the bonafide of introduction of partner capital. Analysis of partner's capital is therefore summarised as under: 1. Amit Parikh: He has introduced capital of Rs. 64 lakh and his returned income as per ITR for A.Y. 2018-19 is Rs. 12,40,150/- with other exempt income of Rs. 56,899/-. The AO has not giving any findings on net worth of Mr. Parikh. Even during the remand stage, net worth of this person has not been demonstrated to be inadequate. Therefore, conclusion of the A....
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....ned due to server error and that the said amount was returned to the appellant and thus the effect was nullified and this fact can be verified from bank statement of the appellant attached at Page No. 540 of the paper book. This submission has not been controverted by the AO in remand report. Therefore, no adverse view can be taken against the appellant. However, as far as introduction of money into account of Mr. Pawan Vachani by Shri Sarichand Vachani and Smt. Kamini Vachani is concerned, no link has been established for these persons with the appellant and therefore, complicity is not established. Hence, the entire introduction of capital of Rs. 17,50,000/- by Mr. Pawan Vachani into the appellant cannot be faulted. 5. Rajesh Nareshchand Chelawat: He has introduced capital of Rs. 7,50,000/-. As per his ITR for A.Y. 2018-19 he has returned income of Rs. 1,44,55,580/-. The AO disallowed this amount because bank statement was not furnished to him. Subsequently the appellant has submitted additional evidences and they were remanded to AO for examination and rebuttal. The AO has not given any comment either in favour of or against this transaction. No net worth analy....
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....sh Naresh Chand Chelawat. The CIT(A) has vehemently considered the facts of all partners in his order and taken a concious decision to delete the addition made by AO. He prayed that the order of CIT(A) must be upheld. 62. We have considered rival submissions of both sides and carefully perused the case record including the orders of lower-authorities. At first, we find that the AO has made an addition of Rs. 4,05,38,902/- on mere arithmetical calculation. He has firstly taken a figure of Rs. 2,38,02,032/- on the basis of difference in closing balances and opening balances in Partners' Capital A/cs and secondly taken a figure of Rs. 1,67,36,870/- returned to partners; aggregated the two figures at Rs. 4,05,38,902/- and made addition by treating the same as unexplained credit during the year. The assessee has, however, filed a summarised chart showing movements in Partners' Capital A/c demonstrating therein that there was fresh capital introduction of Rs. 1,56,25,000/- only and then there was a credit of interest on capital to partners amounting to Rs. 1,29,39,210/-. Therefore, the addition of Rs. 4,05,38,902/- made by AO is patently wrong. In so far as the fresh capital of Rs. 1,....