KEMOX CORPORATION,BHIWANDI vs. DCIT-CC-3, THANE, THANE

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ITSSA 223/MUM/2025Status: DisposedITAT Mumbai24 October 2025AY 2016-1713 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the addition made by the AO, as affirmed by the Ld. Commissioner (Appeals), was unsustainable. The Tribunal noted that the assessment proceedings for the AYs under consideration were unabated. It observed that the AO's assessment order did not mention any specific incriminating material for making the addition but relied on the search and seizure operation and post-enquiry. The Tribunal referred to the Delhi High Court judgments in Commissioner of Income Tax v. Harjeev Aggarwal and Smt. Dayawanti Gupta v. CIT, which held that statements recorded under Section 132(4) of the Act do not by themselves constitute incriminating material unless corroborated by other incriminating material found during the search. The Tribunal further noted that the statement made by Mr. Dodhia was subsequently retracted and not supported by any incriminating material found during the search. Crucially, the Tribunal relied on the Apex Court's decision in Abhishar Buildwell Pvt. Ltd., which clearly laid down that in cases of completed/unabated assessments, no addition can be made by the AO in the absence of any incriminating material found during the search under Section 132 or requisition under Section 132A of the Act. Since the addition in the present case was not based on any incriminating material found during the search and seizure operation, the Tribunal deleted the addition. Consequently, the legal ground raised by the Assessee was allowed, and the appeals were allowed on this legal aspect, making it unnecessary to delve into other issues.

What were the facts?

The Assessee, M/s. Kemox Corporation, filed appeals against the orders of the Commissioner of Income Tax (Appeals) for Assessment Years (AY) 2014-15 to 2018-19. The appeals involved identical facts and issues. The Assessing Officer (AO) made an addition of Rs. 50,00,000/- on account of unexplained cash credit under Section 68 read with Section 115BBE of the Income Tax Act, 1961, for AY 2014-15, treating a loan from M/s. Bridhi Marketing Pvt. Ltd. as bogus. The AO's action was based on post-search inquiries which suggested the company was a shell entity. The Assessee contended that the addition was made without any incriminating material found during the search and seizure operation, and that the assessments were unabated. The Ld. Commissioner (Appeals) dismissed the Assessee's legal grounds.

What were the issues?

1. Whether the addition of Rs. 50,00,000/- as unexplained cash credit under Section 68 read with Section 115BBE of the Income Tax Act, 1961, is sustainable when no incriminating material was found during the search and seizure operation, and the assessment for AY 2014-15 was unabated? Assessee's contentions: - The addition made by the AO and affirmed by the Ld. Commissioner (Appeals) is unsustainable as it is not based on any incriminating material found and seized during the search operation. - The assessments for the relevant AYs were unabated. - Relied on judgments in Abhishar Buildwell Pvt. Ltd. (454 ITR 212 SC) and A One Sizing Works Vs. the ACIT. Revenue's contentions: - The additions were made on account of bogus unsecured loans based on search and seizure operations under Section 132 of the Act. - Incriminating material, specifically pages 37 & 38 of bundle number MN 5, seized from the premises of Shri Divyesh Dhanani, detailed various loans and interest paid by group entities, including the Assessee. - These seized pages showed the name of M/s. Bridhi Marketing Pvt. Ltd. and the amount received back. - The statement of Shri Badhresh Dhodhia recorded during the search could not explain these pages. - Post-search investigations suggested that loan creditors were not existing at the given addresses, indicating accommodation entries. - The Ld. Commissioner (Appeals) rightly held that incriminating material was found during the search and seizure operation.

Which sections of the Income-tax Act were involved?

Section 68,Section 115BBE,Section 132,Section 132(4),Section 153A,Section 250,Section 131(1)(d),Section 147,Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCH “E”, MUMBAI

Before: SHRI NARENDER KUMAR CHOUDHRY & SHRI PRABHASH SHANKAR

For Appellant: Ms. Simran Dhawan, Ld. A.R, Shri Ravi Gantra, Ld. A.R
For Respondent: Shri Ritesh Misra, Ld. D.R
Hearing: 28.07.2025Pronounced: 24.10.2025

IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “E”, MUMBAI

BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER AND SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER

ITA Nos.220, 222, 223, 224, 225/M/2025 Assessment Years: 2014-15, 2015-16, 2016-17, 2017-18 & 2018-19

M/s. Kemox Corporation, DCIT-CC-3, House No.69/100, Room No.12, A Wing, New Mavji Compound, Vs. 16th Floor, Ashar IT Park, Narpoli, Thane West, Maharashtra – 421 302 Maharashtra - 400604 PAN: AAFFK4685A (Appellant) (Respondent) Present for: Assessee by : Ms. Simran Dhawan, Ld. A.R. a/w Shri Ravi Gantra, Ld. A.R. Revenue by : Shri Ritesh Misra, Ld. D.R. Date of Hearing : 28.07.2025 Date of Pronouncement : 24.10.2025 O R D E R Per : Narender Kumar Choudhry, Judicial Member: These appeals have been preferred by the Assessee against the orders even dated 13.12.2024 impugned herein, passed by the Ld. Commissioner of Income Tax (Appeals) (in short Ld. Commissioner) u/s 250 of the Income Tax Act, 1961 (in short ‘the Act’) for the 2014-15, 2015-16, 2016-17, 2017-18 and 2018- 19.

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2.

All the appeals under consideration are having almost identical facts and issues and therefore for the sake of brevity, the same were heard together and disposed of by this composite order.

3.

The Assessee has raised legal issue in the following cases:

ITA nos. A.Y. Assessment Time Limit Whether any The case order for issuance scrutiny was passed u/s of notice u/s proceedings abated or 143(2) of the were pending unabated Act for the A.Y. under consideration 2014-15 153A 30.09.2015 No Unabated 220/M/2025 222/M/2025 2015-16 153A 30.09.2016 No Unabated 223/M/2025 2016-17 153A 30.09.2017 No Unabated 224/M/2025 2017-18 153A 30.09.2018 No Unabated 225/M/2025 2018-19 153A 30.09.2019 No Unabated

And therefore for the sake of brevity, we deem it appropriate to decide these appeals simultaneously by this common order, taking into consideration legal aspect/ground raised by the Assessee, first and the facts and circumstances involved in ITA no. 222/Mum/2025 as a lead case and result of the same would be applicable mutatis mutandis to all appeals under consideration.

4.

In the A.Y. 2014-15 case, it is observed from the assessment order that the AO has mentioned the fact that during the search action it was seen that the Assessee has taken unsecured loans from various parties and most of the loans from family members and some of the loans taken from Kolkata based company during the AY under consideration, are as follows:

F.Y. Loan taken by Loan taken from Amount of loan Amount of received interest 2013-14 Kemox Bridhi Marketing Rs.50,00,000/- Rs.1,07,671/- Corporation Pvt. Ltd.

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4.1 The AO further mentioned the fact that a post search enquiry was conducted by the investigation wing, Thane, in the case of Bridhi Marketing Pvt. Ltd., which is Kolkata based company and commission u/s 131(1)(d) of the Act was also sent in the case of said company, to the investigation wing, Kolkata, for further verification of the address and its genuineness. In the letter dated 10.01.2020 received from DDIT (Inv.) Unit 4(2), Kolkata, it has been reported that Inspector of unit was deputed to verify the existence of this company, who though was found at the given address but their Directors did not appear to give evidence personally, at the office of DDIT. This company only sent the replies through mail/speed post to DDIT (Inv.) 4(2), Kolkata. In the report further reported that M/s. Bridihi Marketing Pvt. Ltd. is reflected as shell company in the data base of entry operators maintained by the Directorate. Hence, the identity, genuineness of the transactions and creditworthiness of the above company could not be ascertained.

4.2 The AO further observed that the Assessee has taken almost all loans from local parties from Bhiwandi and Mumbai regions. The AO further observed that large loans which are taken by the Assessee are from Kolkata based companies, which on enquiry found non-existent or managed by accommodation entry provider. Hence, it is concluded that the Assessee has failed to satisfactorily explain the loan taken from the above mentioned company and to substantiate the genuineness of the loan based on enquiries conducted by the Department.

4.3 The AO therefore on the aforesaid reasons, ultimately treated the loan of Rs.50,00,000/- taken by the Assessee from M/s. Bridhi Marketing Pvt. Ltd. as unexplained cash credit, within the meaning

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of section 68 of the Act and added the same to the total income of the Assessee u/s 68 r.w.s. 115BBE of the Act.

5.

The Assessee being aggrieved though challenged the said addition on legal aspect as well, in the appeal filed before the Ld. Commissioner, however, the Ld. Commissioner dismissed the legal ground raised by the Assessee on various reasons, which we will deal in finding part of this judgment.

6.

The Assessee thus has also raised the said legal ground before us and has claimed that addition in the aforesaid case relevant to the A.Y 2014-15 which is under consideration, is not based on any incriminating material found and seized in the search and seizure operation and the assessments in the aforesaid year were unabated and therefore in view of various judgments including by the Hon’ble Apex Court in the case of Abhishar Buildwell Pvt. Ltd. 454 ITR 212 (SC) and in the group cases of the Assessee titled as A One Sizing Works Vs. the ACIT {ITA No.6458/M/20254 and Ors. decided on 10.07.2025}, the additions made by the AO, as affirmed by the Ld. Commissioner, vide impugned order passed in this case, are unsustainable and thus liable to be deleted.

7.

On the contrary, the Ld. CIT DR refuted the claim of the Assessee and submitted that the additions have been made by the AO on account of bogus unsecured loan, on the basis of search and seizure operations carried out u/s 132 of the Act at the business as well as residential premises of Dodhia Group of cases, including the Assessee herein on dated 27.11.2019. The Ld. Commissioner has also endorsed the specific fact, while adjudicating the similar ground raised by the Assessee in the A.Y. 2014-15 as a lead case, to the effect that two pages (page no.37 & 38 of bundle number MN 5) were seized from the premises of Shri Divyesh Dhanani having

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details of various loans raised and interest paid by entities of Dodhia group, including the Assessee herein. As per seized pages, the amount of interest paid was received back by the group entities after deducting a commission of 3% and the figure of amount received back from the loan creditors, is mentioned under the column “return”. The name of the Assessee is also appearing at seized pages nos. 37 & 38 and the name of M/s. Bridhi Marketing Pvt. Ltd. is mentioned on the pages along with details of amount received back. The said pages were confronted with Shri Badhresh Dhodhia in the statement recorded during the search in question No.60 of the statement and he could not explain the same. It is seen from the statement of Shri Badhresh Dhodida that he could not give satisfactory explanation. The name of said company is appearing in question no.48 of the statement. Further, Mr. Dhodhia admitted in reply to question no.70 & 72 that the cash available with the Dodhia was routed in the form of accommodation entries through M/s. Vinam Finance Pvt. Ltd. In this backdrop, during the post search investigation, the DDIT (Inv.), got conducted independent investigation regarding the existence of various loan creditors of Dodhia group at Kolkata as well as Mumbai and the enquiries suggested that so called loan creditors were not existing on the given addresses and therefore the above discussion clearly suggest that incriminating material qua accommodation entries was found during the search, as well as collected during the post search enquires and therefore the Ld. Commissioner has rightly held that the contention of the Assessee that no incriminating material was found during the search, is incorrect. And thus on the aforesaid facts as analyzed by the Ld. Commissioner, the additions are liable to be affirmed as the same are based on incriminating material found during the search and seizure operation u/s 132 of the Act.

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8.

Having heard the parties and perusing the material available on record and giving thoughtful consideration to the peculiar facts and circumstances of the case and the rival contentions raised by the Assessee qua legal issue about the additions dehors incriminating material found during the search and seizure operation made vide order u/s 153A of the Act, it is observed that admittedly, in the assessment order, the AO has not mentioned any incriminating material for making the addition under consideration but in fact simply relied on search and seizure operation and post enquiry conducted by the Investigation Wing, Kolkata in the premises of M/s. Bridhi Marketing Pvt. Ltd., who was admittedly found at the given address.

8.1 From the findings of the Ld. Commissioner as well, it appears that he has mentioned the fact that during the search operation, two pages nos.37 & 38 (bundle No.MN 5) were found from Shri Divyesh Dhanani, which were having details of various loans raised and interest paid by entities of Dhodhia Group and received back after deducting a commission @ 3% and the figure of amount received back from the loan creditors is mentioned under the column “return”.

8.2 The Ld. Commissioner also relied on the statement of Shri Badhresh Dhodhia, who was confronted with said pages and could not explain the same by giving satisfactory explanation. Further, Mr. Dodhia has admitted that the cash available with Dodhia group was routed in the form of accommodation entries through M/s. Vinam Finance Pvt. Ltd. In this background, during the post search investigation, the DDIT (Inv.) got conducted independent investigation regarding the existence of various loans creditors of Dodhia group at Kolkata and Mumbai and the enquiry suggested that so called loan creditors were not existing on the given address.

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The above discussion clearly suggests that incriminating material regarding the accommodation entries was found during the search as well as post search enquiries.

9.

We observe from the findings of the Ld. Commissioner that though he has specified page nos.37 & 38 but it is a fact as recorded by the Ld. Commissioner himself that the aforesaid documents were seized from the premises of Shri Divyesh Dhanani but not from the Assessee. Further, the Ld. Commissioner also relied on the statement of Shri Badhresh Dodhia recorded during the search, which was admittedly subsequently retreated on dated 08-03-2020 though notarized affidavits and even otherwise having no independent value, dehors the substantive corroborative material recovered from the search and seizure operation in the case of the Assessee for attracting the provisions of section 153A of the Act. Even if any incriminating material has been recovered from third party, then the same can be used according to the procedure established by law, as enshrined in section 153C of the Act but not u/s 153A of the Act. Further, statement of third parties recorded during pre-search and post search cannot entail making the addition u/s 153A of the Act dehors incriminating material found during the course of search and seizure operation, in the unabated assessment.

10.

We further observe that in the cases of group entities namely A One Sizing Works (supra), the Hon’ble Co-ordinate Bench of the Tribunal also dealt with the same search and seizure operation as involved in the instant case, documents seized from Shri Divyesh Dhanani, as well as the statement of Shri Badhresh Dodhia, who was confronted with the seized material and the Hon’ble Co- ordinate Bench by considering the identical facts “that statement of Mr. Dodhia u/s 132(4) of the Act, was not recorded at the searched premises but

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in fact the same was recorded at A-402, Padmavati Residency, Oswal Park, Bhiwandi and therefore the said statement cannot be treated as incriminating material found and seized from the Assessee”, ultimately held that in the absence of incriminating material, no addition could have been made in the case of the Assessee from A.Ys 2014-15 to A.Y. 2018- 19, by observing and holding as under:

“4.11 We find that the Assessing Officer has nowhere referred to any of the incriminating material found from the premises of the assessee in respect of AYs 2014-15 to 2018-19. In fact, the AO's show cause notices themselves refer to seized materials from other premises and persons. The materials relied upon including pages 36-38 of Bundle No. 3 were found from the residence of a third party and not from the assessee. Therefore, such documents, in the absence of invocation of Section 153C of the Act, cannot be utilized to make additions in the hands of the assessee under Section 153A. As far as statements of Shri Bhadresh Dodhia and other persons are concerned, not a single statement has been recorded from the premises of the assessee and therefore, same cannot be treated as incriminating material seized or found from the premises of the assessee. We also found that Hon'ble Delhi High Court in the case of CIT vs. Harjeev Aggarwal reported in 290 CTR 263 held that statement recorded u/s 132(4) of the Act do not constitute incriminating material found from the premises of the assessee. Further, even the Ld. CIT(A) in his appellate order admitted that pages 37 and 38 of Bundle No. 3 were seized from a third party and confronted to Shri Bhadresh Dodhia, who could not explain the same. However, such confrontation cannot substitute for the statutory requirement that incriminating material must be found from the premises of the assessee, not third parties, in order to sustain additions in unabated assessments. 4.12 In view of the above analysis, we hold that: For the unabated assessment years viz. AYs 2014-15 to 2018-19, no addition could have been made under Section 153A of the Act in the absence of any incriminating material found during the course of search from the premises of the assessee. Statements of third parties, or material found from other premises, not being relatable to the assessee's premises, cannot form the basis for additions in a 153A proceeding in respect of completed assessments, unless proceedings under other

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provisions are separately initiated-which has not been done in this case. Consequently, all additions made in respect of unsecured loans and disallowances of interest for the above assessment years are unsustainable in law. 4.13 For the reasons stated above and in view of the settled position of law laid down by this Court in Abhisar Buildwell (supra), we are of the considered opinion that the additions made in assessment years 2014-15 to 2018-19 under Section 153A of the Act are without jurisdiction and liable to be deleted. Accordingly, the ground of appeals related to existence of incriminating material raised in AYs 2014-15 to AY 2018-19 is allowed. Since we have held that in absence of incriminating material, no addition could have been made in the case of the assessee from AYs 2014-15 to AY 2018-19 therefore, all other ground raised by the assessee are rendered academic and hence, we are not adjudicating upon the same”.

10.1 We further observe that the Hon'ble Delhi High Court in the case of CIT vs. Harjeev Aggarwal reported in 290 CTR 263 has also dealt with a situation, wherein statement u/s 132(4) of the Act was used as incriminating material by the AO and the Hon’ble High Court ultimately held that statements recorded u/s 132(4) of the I.T. Act cannot constitute incriminating material, unless corroborated by other material found during the search and cannot be the sole basis for making the a block assessment, by observing and holding as under: -

"23. It is also necessary to mention that the aforesaid interpretation of Section 132(4) of the Act must be read with the explanation to Section 132(4) of the Act which expressly provides that the scope of examination under Section 132(4) of the Act is not limited only to the books of accounts or other assets or material found during the search. However, in the context of Section 158BB(1) of the Act which expressly restricts the computation of undisclosed income to the evidence found during search, the statement recorded under Section 132(4) of the Act can form a basis for a block assessment only, if such statement relates to any incriminating evidence of undisclosed income unearthed during search and cannot be the sole basis for making a block assessment.

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24.

If the Revenue's contention that the block assessment can be framed only on the basis of a statement recorded under Section 132(4) is accepted, it would result in ignoring an important check on the power of the AO and would expose Assessees to arbitrary assessments based only on the statements, which we are conscious are sometimes extracted by exerting undue influence or by coercion. Sometimes statements are recorded by officers in circumstances which can most charitably be described as oppressive and in most such cases, are subsequently retracted. Therefore, it is necessary to ensure that such statements, which are retracted subsequently, do not form the sole basis for computing undisclosed income of an Assessee."

10.2 We further observe that the Hon'ble Delhi High Court in the case of CIT Vs. Best Infrastructure (India) (P) Ltd. reported in 397 ITR 82 has also dealt with an identical issue and situation, wherein statement u/s 132(4) of the Act was used as incriminating material by the AO and the Hon’ble High Court ultimately held “that statements recorded u/s 132(4) of the I.T. Act do not by themselves constitute incriminating material”, by observing and holding as under: -

"38. Fifthly, statements recorded under Section 132 (4) of the Act of the Act do not by themselves constitute incriminating material as has been explained by this Court in Commissioner of Income Tax v. Harjeev Aggarwal (supra). Lastly, as already pointed out hereinbefore, the facts in the present case are different from the facts ITA No.7374/Del/2017 ITA No.7567/Del/2017 in Smt. Dayawanti Gupta v. CIT (supra) where the admission by the Assessees themselves on critical aspects, of failure to maintain accounts and admission that the seized documents reflected transactions of unaccounted sales and purchases, is non- existent in the present case. In the said case, there was a factual finding to the effect that the Assessees were habitual offenders, indulging in clandestine operations whereas there is nothing in the present case, whatsoever, to suggest that any statement made by Mr. Anu Aggarwal or Mr. Harjeet Singh contained any such admission. 39. For all the aforementioned reasons, the Court is of the view that the ITAT was fully justified in concluding that the assumption of jurisdiction under Section 153A of the Act qua the Assessees herein was not justified in law."

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11.

From the aforesaid judgments of Delhi High Court, it has become clear that statements recorded u/s 132(4) of the I.T. Act cannot constitute incriminating material unless corroborated by any incriminating material found during the search and it is necessary to ensure that such statements, which are retracted subsequently, do not form the sole basis for computing undisclosed income of an Assessee. Further statements recorded u/s 132(4) of the I.T. Act do not by themselves constitute incriminating material.

11.1 As in this case, statement made by Mr. Dodhia is neither supported with any incriminating material found during the course of search in his case and even otherwise the statement was subsequently retracted vide notarized affidavit dated 08-03-2020 and thus has lost it sanctity and therefore in view of aforesaid judgments of Delhi High Court, cannot be treated as incriminating material for making the addition.

12.

We addressing the next question “whether addition on the basis of no incriminating material found during the search and seizure operation in the unabated assessment is sustainable or not,” observe that said question in now not res-integra, as the same has ultimately been settled by the Hon’ble Apex Court in the case of Abhisar Buildwell Pvt. Ltd. (supra), by laying down the following dictum.

“14. In view of the above and for the reasons stated above, it is concluded as under: i)………………………………………………………………………… ………………………………………………………………………… ………………………………………………………………………… …………………………………………………………………………. iv) In case no incriminating material is unearthed during the search, the AO cannot assess or reassess

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taking into consideration the other material in respect of completed assessments/unabated 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 fulfillment of the conditions as envisaged/mentioned under sections 147/148 of the Act and those powers are saved."

12.1 The Hon’ble Apex Court in the said case, has laid down clearly that in case no incriminating material is unearthed during the search or seizure operation, then the AO cannot assess or re-assess taking into consideration the other material qua completed/unabated assessment. Meaning thereby, in respect of completed/unabated assessment, no addition can be made dehors any incriminating material found during the course of search u/s 132 or requisition u/s 132A of the Act. However, the Hon’ble Apex Court has carved out an exception that completed/unabated assessment can be reopened by the AO in exercise of powers u/s 147/148 of the Act but subject to fulfilment of the conditions, as envisaged/mentioned u/s 147/148 of the Act and those powers are saved.

13.

Coming to the instant case, as we have held above that the assessment proceedings for the AYs under consideration were completed/unabated and the addition made by the AO, as affirmed by the Ld. Commissioner is not based on any incriminating material found during the search and seizure operation in the case of the Assessee and therefore in our considered view, the addition under consideration is unsustainable and thus the same is deleted.

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Resultantly, the legal ground raised by the Assessee is allowed.

14.

As we have deleted the addition on the aforesaid legal point/issue, thus are inclined not to delve into other issues including on merit of the case, as adjudication of the same would prove to be futile exercise. However, the other issues would be remained open to agitate, in case of need arises. Thus, the appeal under consideration i.e. ITA No.220/M/2025 is allowed on the legal aspect/ground.

15.

In view of our judgment in ITA No.220/M/2025, remaining appeals under consideration pertaining to AYs 2015-16 to 2018- 19 as having involved legal issue qua additions made dehors the incriminating material found during the course of search and seizure operation, are also allowed on the subjected legal aspect/ground.

16.

In the result, all appeals filed by the Assessee are allowed subject to exception/liberty mentioned above. Order pronounced in the open court on 24.10.2025.

Sd/- Sd/- (PRABHASH SHANKAR) (NARENDER KUMAR CHOUDHRY) ACCOUNTANT MEMBER JUDICIAL MEMBER * Kishore, Sr. P.S. Copy to: The Appellant The Respondent The CIT, Concerned, Mumbai The DR Concerned Bench //True Copy// By Order Dy/Asstt. Registrar, ITAT, Mumbai.

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