KIRTIKUMAR L. MEHTA, HUF,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(3), AHMEDABAD

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ITSSA 131/AHD/2023Status: DisposedITAT Ahmedabad24 June 2025AY 2012-1314 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that while the evidence recovered during the search from the developer's premises was reliable, the assessee had consistently denied making on-money payments and repeatedly requested an opportunity to cross-examine the concerned person, Shri Paurav I Patel, who allegedly prepared the Excel sheet. This request was accepted by the ld. JCIT, who directed the AO to allow cross-examination. Although the witness did not appear on the stipulated date, the AO could have enforced his presence using powers under Section 131 of the Act, possibly with warrants. The Tribunal found that the principles of natural justice were violated by not providing the assessee with the opportunity to cross-examine the witness, despite directions from a competent authority. Therefore, the impugned order of the CIT(A) was set aside. The matter was restored to the file of the AO with directions to comply with the order of the ld. JCIT dated 12.12.2018, provide the assessee an opportunity to cross-examine the concerned witness(es), and thereafter pass a fresh assessment order in accordance with law. The AO was directed to exercise his powers to ensure the attendance of the witness(es).

What were the facts?

The appeals by various assessees, including Kiritkumar L. Mehta, HUF, and others, are against orders of the CIT(A) for Assessment Year 2012-13. The core issue stems from a search under Section 132 on the HN Safal Group, which led to the seizure of a hard disk containing an Excel sheet ('Mondeal2.xlsx'). This sheet allegedly detailed payments, including 'on-money' (cash component), for the purchase of units in the Mondeal Business Park scheme by the assessees from Adicorp Deal S G Project. The Assessing Officer (AO) made additions of Rs. 24,44,444/- on account of alleged undisclosed income, citing the data in the Excel sheet and the failure of the assessees to prove the source of the cash payment. The assessees contended that the hard disk was seized from the premises of Safal Group, not theirs, and that they had not accepted the documents or made such cash payments.

What were the issues?

1. Whether the order framed by the AO under Section 143(3) r.w.s. 153C is bad in law and void ab initio due to violation of principles of natural justice, specifically the denial of adequate opportunity to cross-examine the person who prepared the Excel sheet or made statements relied upon by the AO. (Assessee's contention: The AO failed to provide a reasonable opportunity for cross-examination, violating natural justice. The CIT(A) erred in upholding the AO's order. Revenue's contention: Not recorded. 2. Whether the addition of Rs. 24,44,444/- as undisclosed income is erroneous and unsustainable in law, as the assessees deny making any cash payment in excess of the recorded consideration and assert that no undisclosed income was derived. (Assessee's contention: The addition is based on documents seized from a third party (Safal Group) over which the assessee had no control, and the AO did not provide conclusive material to prove the alleged cash payment. The evidence found during the search of HN Safal Group cannot be used against the assessee. Revenue's contention: Not recorded.) 3. Whether the AO erred in not issuing notices under Section 143(2) and Section 142(1) in accordance with the law. (Assessee's contention: The order is bad in law due to non-compliance with statutory notice requirements. Revenue's contention: Not recorded.) 4. Whether the AO grossly failed to comply with the directions issued by the Joint CIT u/s 144A. (Assessee's contention: The AO did not follow the directions of the Joint CIT, making the order bad in law. Revenue's contention: Not recorded.)

Which sections of the Income-tax Act were involved?

Section 132,Section 143(3),Section 153C,Section 142(1),Section 143(2),Section 144A,Section 245D,Section 131,Section 271(1)(c),Section 234B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “ B ” BENCH, AHMEDABAD

Before: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Respondent: Shri V. Nandakumar, CIT-DR &, Shri Kavan Limbasiya, Sr.DR
Hearing: 26/03/2025Pronounced: 24/06/2025

आदेश/O R D E R

Per Sanjay Garg, Judicial Member: These appeals have been preferred by different assessees against the separate orders of the Commissioner of Income Tax (Appeals)-11 & 12, Ahmedabad (hereinafter referred to as "the CIT(A)") for the Assessment Year (AY) 2012-13.

2.

Although these appeals pertain to different assessees, the primary issues are identical. Therefore, all these appeals were heard together. For the sake of convenience, we proceed to dispose of all these appeals of the assessees by this consolidated order.

3.

First, we take up the Appeal of the assessee in IT(SS)A No.131/Ahd/2023 for AY 2012-13, in the case of Kiritkumar L. Mehta, HUF, as a lead case, wherein the assessee has raised the following grounds of appeal: “Your appellant being dissatisfied with the order passed by the Commissioner of Income tax (Appeals) presents this appeal against the same on the following amongst other grounds.

1.0 The CIT(A) erred in upholding the order framed by the assessing officer on 27th December, 2018 under section 143(3) r.w.s. 153C which is bad in law. The order has been framed without affording adequate and reasonable opportunity of being heard. The order being bad in law be quashed.

1.1 The observations made by the CIT(A) in paras 6.2.1 and 7.4 are incorrect and have been made at pleasure of the CIT(A) without any knowledge on part of the appellant. The appellant had never accepted document seized from hard disc. The hard disc was seized from premises of SAFAL GROUP and not appellant and the application under section 245D was made by SAFAL GROUP and not the appellant.

2.0 The CIT(A) ought to have held that The order framed by the assessing officer under section 143(3) r.w.s. 153C is void ab initio and not sustainable in the eyes of law. The order was framed by the assessing officer without affording any opportunity of being heard and it is in violation of principle of natural justice. The order be quashed.

2.1 The CIT(A) ought to have held that the order framed by the AO was bad in law because the assessing officer did not issue notice under section 143(2) and notice under section 142(1) in accordance with the provisions of law. The order framed by the AO without issuing notices in accordance with the provisions of law is bad in law. The order be quashed.

2.2 The CIT(A) ought to have held that the order framed by the assessing officer under section 143(3) r.w.s. 153C is bad in law and it be quashed because the order has been framed in violation of decisions of the Hon'ble Supreme Court including in the case of CIT Vs. Sunita Dhadda SLP 9432/2018. The assessing officer did not allow any genuine opportunity to cross examine the person on whose statements the assessing officer was relying. The order framed by the assessing officer be quashed.

2.3 The CIT(A) ought to have held that the order under section 143(3) r.w.s. 153C is bad in law because the assessing officer has grossly failed to comply with the directions Issued by the Joint CIT u/s 144A. The directions have not been followed by the assessing officer and therefore the order under section 143(3) r.w.s. 153C is bad in law.

3.0 The CIT(A) erred in upholding addition of Rs. 24,44,444/- alleging undisclosed income. The appellant it had not derived any undisclosed income and each and every income derived by the appellant was disclosed. The appellant submits that admittedly there was no undisclosed income of Rs. 24,44,444/- and therefore the addition be quashed.

3.1 The appellant submits that it did not make any payment in cash of Rs. 24,44,444/- in excess of the consideration which has been recorded and reflected in the books of account for purchase of premises situated at Mondeal Business Park from Safal Group, The addition of Rs. 24,44,444/- be therefore quashed.

3.2 The appellant submits that it did not make any payment in cash and further the assessing officer did not bring any material on record which conclusively prove the alleged cash payment and therefore addition of Rs, 24,44,444/- is erroneous. The addition of Rs. 24,44,444/- be deleted..

3.3. The CIT(A) erred in upholding an error of law and error of fact in relying upon the statements found from the premises of the Safal Group of Companies during the proceedings under section 132. The addition of Rs. 24,44,444/- merely on the basis of documents found at the premises of H.N Saffal group is erroneous and unsustainable in the eyes of law. The addition of Rs. 24,44,444/- be therefore quashed.

3.4 The appellant submits that hard disk excel sheet etc. referred to by the assessing officer in the assessment order were found from the premises of H.N.Saffal Group on which the appellant did not have any control and therefore not acceptable in the case of the appellant. The additions of Rs. 24,44,444/- be quashed.

3.5 The CIT(A) ought to have held that evidences found during the proceedings under section 132 in the case of H.N.Saffal Group can not be used against the appellant in its income tax proceedings. The addition being on basis of the unfounded allegations and without any evidence/materials acceptable in the eyes of law be quashed.

4.0 CIT(A) ought to have held that the notice of demand dated 27th December, 2018 issued by the assessing officer raising demand of Rs. 12,47,933/- is bad in law.

4.1 The appellant, under the facts, denies its liability in respect of interest under section 2348 charged by the AO is illegal and void ab initio. The AO be directed to delete interest charged u/s 2348.

Your appellant prays for leave to add, alter, amend and/or withdraw all or any of the grounds of appeal before the final hearing of the appeal.”

4.

The brief facts of the case, as extracted from the order of the Assessing Officer (in short “the AO”) are that a search under section 132 of the Income Tax Act (hereinafter referred to as “the Act”) was conducted on various premises of HN Safal Group of cases on 4th September 2013. During the course of search, Annexure-A-08 i.e. hard disk was seized from 7th Floor, Safal Profitaire. Corporate Road, Prahlad Nagar, Ahmedabad which contained various details of various residential and commercial project. In this hard disk, excel sheet namely Mondeal2.xlsx was found which contained soft data of Mondeal Park Scheme of Adicorp-Deal S G Project (PAN- AAKLFA8999F). It contained name of the Member/client/customer, unit/plot shop no., payment details through cheque and cash, details of outstanding etc. were mentioned.

5 5. The figures mentioned in the Column ‘Cq. Rece.' And 'D. Rece.’ Indicated the total consideration received through cheque and cash respectively till the date of the sheet. In the subsequent columns 'Total Q o/s.' and Total D o/s.' the outstanding value of the cheque component of the consideration and the cash component of the consideration, pending for collection, has been calculated. It was noted that as per Mondeal2.xlsx found, Dr. K L Mehta with co-owners had paid on money to Adicorp Deal S G Project(PAN-AAKLFA8999F) for the purposes of purchasing of shop/office, the details of which is detailed in the following format:

Sr. Block Name of the Ref Date of Cq. Rece. D. Rece. No. No. Party Booking

1 C Dr. K L Mehta RS 15-Sep-Ol 49,868,00 22,000,000 and Other 0

The AO observed from the above that payment of on money of Rs.2,20,00,000/- had been made by Dr. K L Mehta jointly with other co- owners on 15/09/2011 relevant to the F Y 2011-12 i.e A Y 2012-13 for purchase of shop/office in the Mondeal Business Park the scheme of M/s. Adicorp Deal S C Project(PAN-AAKLFA8999F).

6.

On perusal of the Sale deed registered vide Registered deed No. 11465/2011 dated 13/10/2011, it was noticed that Dr. K L Mehta alongwith 9 Co-owners having equal shares had purchased the said property at the consideration of Rs.4,98,68,000/-. The details of which was as under:

7.

From the above sale deed, it was clear that the assessee, Mehta Kirti kumar Laxmidas (HUF) was one of the equal co-owners of the property purchased at the Mondeal Business Park Scheme and had paid equal share of total on money paid of Rs.2,20,00,000/- for purchase of the property to M/s. Adicorp Deal S G Project.

8.

Considering the above facts, the Assessing Officer of M/s. H N Safal Croup was satisfied that the document found and seized from the H N Safal Group at 7th Floor, Safal Profitaire, Corporate Road, Prahladnagar, Ahmedabad pertained to Mehta Kiritkumar Laxmidas (HUF) and had bearing on the determination of total income of the assessee for A Y 2012-13 and the same was forwarded to the AO having jurisdiction over the assessee.

9.

Subsequently, notice u/s.153C of the Act dated 24/10/2017 was issued and served upon the assessee by the AO through speed post as well as notice server requiring the assessee to file the return of income for AY 2012-13 within 15 days of receipt of the said notice. In response to the above, vide letter dated 18/11/2017, the assessee furnished the copy of original return of income filed for A Y 2012-13 declaring total income at Rs.3,46,403/- and requested the AO to provide the photocopies of the documents on the basis of which allegation had been leveled against him. The assessee was provided the reasons as well as satisfaction note for reopening the assessment u/s.153C of the Act for AY 2012-13.

10.

The assessee, however, stressed that they have not made any on-money payment for the purchase of property except that was mentioned in the sale deed. The assessee reiterated that all the money was paid through cheque which was duly recorded in the sale deed and nothing more than that was paid in cash. It was further requested to the AO that since the AO was inclined to make adverse inference on the basis of excel sheet etc., therefore, the assessee requested to the AO to allow him the opportunity to cross- examine the persons who had made the alleged notings. The AO, however, did not grant the opportunity to cross-examine the persons, who had allegedly made the disputed notings.

11.

The assessee, thereafter, filed an application u/s.144A of the Act dated 18/12/2018 before the Jt.CIT requesting him to issue the directions to the A.O. to allow opportunity to the assessee to cross-examine the persons who allegedly made the disputed notings regarding receipt of on-money. The Jt.CIT accepted the request of the assessee and vide letter dated 12.12.2018 issued the following directions:

8 "Considering the application made by the assessee and following the principles of natural justice, the Assessing Officer is directed;

i To allow the cross examination of the persons who have prepared the document which was seized during the course of search action u/s.132 in M/s. H N Safal Croup on 04.09.2013 and implicated the name of the assessee.

ii) To comply the decision of the Hon'ble Supreme Court and also various High Courts;

iii) To pass a reasoned and speaking order after duly considering the provisions of law and principles of natural justice.

In view of the facts of the case as mentioned above, the application of the assessee u/s 144A of the I. T. Act, 1961 dated 18/12/2018 is hereby decided accordingly.\

12.

The AO, accordingly, issued the summons under section 131 of the Act to Shri Paurav I Patel, C/o. Adicorp Deal S G Project, Ahmedabad to attend his office for cross examination, with the details of the on money payments made of Rs.2,20,00,000/- by Mehta Kiritkumar Laxmidas HUF (Dr. K L Mehta alongwith 9 Co-owners having equal shares) for purchase of the property at Mondeal Business Park scheme of Adicorp Deal S C Project. Vide letter dated 24/12/2018 the assessee was also intimated and requested to remain present for cross examination of Shri Paurav I Patel of M/s. Adicorp Deal S G Project, Ahmedabad.

13.

On the stipulated date 26.12.2018, neither Paurav I Patel nor his Authorised Representative attended, however, the AR of the assessee alongwith his Accountants remained present in the office of the AO to conduct the cross-examination of Shri Paurav Patel, which could not be conducted due to non-attendance of Shri Paurav Patel of Adicorp Deal S G Project.

14.

The assessee, thereafter, stressed to the AO that since Shri Paurav I Patel was witness of the Department on whose statement addition had been proposed in his case, and since despite direction the said witness had not come present for cross-examination, therefore, no additions were warranted in this case. The ld.AO, however, did not agree with the aforesaid contentions of the assessee. He held that it was not a simple case wherein the addition were proposed on the bald statement of Shri Paurav I Patel. He observed that in this case, sufficient evidences were available in the shape of hard-disc seized from the searched person containing details of various residential and commercial projects, including the details of payment received in cash as well as cheque. That such details were comprehensive and that the data recorded in the excel-sheet was self-explanatory containing various details of the property, name of the purchaser, area of the unit, sold value and consideration received through cheque and cash respectively. He, therefore, held that there was sufficient evidence on the file which suggested that the assessee along with others had paid on-money for the purchase of the property in question. He, therefore, held that merely because the assessee could not-cross-examine Shri Paurav I Patel, that itself, did not bar the AO to complete the assessment on the basis of substantial evidence on the file. He, accordingly made the impugned addition, observing as under:

“The submissions made by the assessee have been carefully considered. However, the contention of the assessee is not acceptable that department does not have evidence or any material acceptable in the eyes of law for making addition, as in the reason for issuing the notice u/s.153C of the Act itself is mentioned regarding the Hard disk which was seized from 7th Floor, Safal Profitaire, Corporate Road, Prahlad Nagar, Ahmedabad containing various details of various residential and commercial project and in this hard disk, excel sheets namely Mondeal2.xlsx was found which contain soft data of Mondeal Business Park Scheme of Adicorp Deal S G Project and as per the sheet Mondeal.xlx, the assessee alongwith other 9 co-owners has paid total on- money of Rs.2,20,00,000/- on 15/09/2011 to M/s Adicorp Deal S G Project for the purpose of purchasing of shop/ office in Mondeal Business Park scheme. Out of Rs.2,20,00,000/- the portion of the assessee is 1/9th which come to Rs.24,44,444/- as per the Registered deed. The hard disc contains the data broadly of following nature:

a. Details of the saleable area of the units of the scheme. b. Names of the Brokers involved in the booking and sale of the units. c. Unit -wise details of the collection made from the customers. d. Details of the collection made through cheque, till the last modification date of the sheet and Date-wise details of the collection made through cash. e. Details of the expenditure made in cash and the details of the distribution of the cash receipts between the partners. f. Other miscellaneous details.

On perusal of details of sheet Mondeal.xlx it is found that the said excel sheet contains the comprehensive details of all the units booked till the date of last modification of the sheet i.e. 28.01.2012. The data as recorded in the excel sheet is self-explanatory and contains the full details such as Unit & it Block, Name of the purchaser, Area of the Unit, sold value and consideration received through cheque and consideration received through cash respectively.

7.1 On perusal of the excel sheet seized during the-search action as well as sale deed no. 11465/48 executed on 13.10.2011 by the assessee & other co-owners, it has been observed that the name of seller & purchaser, unit/block no!, area of unit, consideration amount (paid through cheque) etc are mentioned in sale deed have exactly tallied with the excel sheet. Therefore, there is no reason to believe that the cash amounting to Rs.24,44,444/-received from the assessee in terms of on money for the purchase of property have not been paid by him,. The said cash component is mentioned in Column 'D Rece' of excel sheet namely Mondeal.xlx seized during the search action. The contention that there is no proof regarding cash payment made by the assessee and received by seller is not tenable, particularly when the assessee accept the payment made by the cheque, confirmed the purchase made in respect of Block C in the Mondeal Business Park scheme floated by Adicorp Deal S G Project. The name of the buyer and seller as well as area sold found in the sheet is also reflected in the sale deed. The assessee cannot accept the part details and does not accept the details of cash payment towards the purchase of Unit. The assessee has submitted that he |as not paid any on money for the purchase of unit in Mondeal Business Park scheme developed by Adicorp Deal S G t. The above contention of the assessee is also found not to.be tenable. Further, of on money was found during the course of search is important evidence.

Further, it is also ascertained that Adicorp Deal S G Project is one of the sister concerned of HN Safal Croup who has developed the scheme of Mondeal Business Park scheme, have filed an application before Hon'ble Settlement Commission, Mumbai and it is also learnt that the above Croup had admitted the additional income for receipt of on money in respect of various scheme developed by HN Safal Group.

7.2 It is pertinent to mention here that, no prudent person will admit the undisclosed income and pay the relevant tax on it if he has not received the undisclosed income.

Test of Human possibilities and "preponderance of possibilities should be applied to decide the issue in absence of direct evidences. The reliance is placed, on the decision of Hon'ble Supreme Court in 82 ITR 340 (SC), 191 1TR 667(SC) & 214 ITR801 (SC) and in the case of Sumati DayalVs. CIT 214 ITR 80(SC) in which the Hon'ble Supreme Court has held as under;

"In the Income Tax cases the suit is that of Civil Case in which one I have to go by the preponderance of probability and not by evidence to prove it to the guilt. It has been observed by the tan Apex Court that the courts will not be obvious to the notorious fact of life..."

7.3 Further, it is not out of place to mention that the black money is social evil. It is also known fact that in most of the cases, the black money is generated in Real Estate Business by taking on money in cash over and above the sale consideration in most of the cases. Both the persons Builders/Developers and Customers who booked the units are responsible in generating black money because the Builders/Developers are understating their income and the Customers are giving on money out of his undisclosed income. The income Tax Department is very vigilant on the issue of generation of black money. Therefore, whenever any information or evidences found, the department carried out various majors such as search u/s. 132 and survey u/s.133A etc. In the instant case also the search was conducted in the case of HN Safal Group and as discussed above, the evidences of on money have been found. On the basis of evidences found during the course of search, it is clear that the assessee has paid on money in respect of purchase of Unit in Mondeal Business Park scheme. The HN Safal Group has also admitted the additional income before Hon'ble Settlement Commission for receipt of on money in respect of various scheme developed by it and accordingly Hon'ble Settlement Commission has passed the order u/s. 245D(4) of the IT Act. The evidence found during the course of search is also correlate with the instant case. The assessee has purchased the Block No. C, in Mondeal Business Park scheme and name of the buyer/seller and other details are found in the sale deed itself. All these sequence of event proved that the assessee has paid on-money of Rs.24,44,444/- for the purchase of unit in Mondeal Business Park scheme developed by Adicorp Deal S G Project and the assessee failed to the source of such cash payment. In the absence of the any details//documentary evidence/ to prove the genuineness and creditworthiness of the source of cash on money payment of Rs.24,44,444/- to M/s Adicorp Deal S C Project for the purpose of purchasing of Block C in the Mondeal Business Park scheme is nothing but the undisclosed income of the assessee for the year under consideration and accordingly added to the total income of the assessee as per provisions of the Income Tax Act. Penalty proceedings u/s 271(1)(c) of the IT Act are also initiated separately for concealment of income.”

15.

Being aggrieved by the said order of the AO, the assessee preferred appeal before the ld.CIT(A), but remained unsuccessful. The assessee, thus, has come in appeal before us.

16.

We have heard rival contentions and gone through the record. In this case, no-doubt, the assessee from the very beginning has been insisting that he had not paid on-money to the seller for the purchase of the property in question. The assessee had also, time and again, insisted to allow him cross- examination of the concerned person, who allegedly prepared excel-sheet or made statement to the search party, regarding aforesaid excel-sheet data depicting on-money payments. On being denied the opportunity to cross- examine the concerned person, namely, Shri Paurav I Patel, the assessee approached the ld.Joint Commissioner of Income Tax, who in turn directed the AO to allow the assessee to cross-examine the concerned witness. Though, the AO issued summons to the said witness, Shri Paurav I Patel under section 131 of the Act, however, the said witness did not come present on the stipulated date before the AO. The AO, thereafter proceeded to make assessment, and made impugned addition after appreciating the evidences available on record. No doubt, the evidence available on the file, which was recovered during the search action from the premises of the developer of the property, is reliable evidence which cannot be simply brushed aside, however, the fact on the file is that the assessee from the very beginning has denied the payment of on-money and has, time and again, requested to allow him to cross-examine the concerned person, Shri Paurav I Patel. The said request to cross-examine the concerned witness has also been accepted by the concerned ld.JCIT and directions were issued to the AO to allow him to cross- examine the concerned person. Merely because the concerned person did not come present on the stipulated date fixed for his cross-examination, that itself did not bar the AO to enforce his personal presence by way of exercising his powers under section 131 of the Act along with relevant provision of Civil Procedure Code by way of summoning him including by way of issuing of bailable/non-bailable warrants etc.. Though, there was a prima facie strong evidence available against the assessee, however, in our view, the assessee must be given an opportunity to rebut the said evidence. In this case, the principles of natural justice have been violated by not providing the assessee opportunity to cross-examine the concerned witness, despite ordered to do so by the competent income tax authority. However strong the evidences available on the file is, since, the assessee has disputed the same, the assessee under the circumstances, is required to be given an opportunity to rebut the same by way of cross-examination of the concerned witness.

In view of this, the impugned order of the ld.CIT(A) is set aside, and the matter is restored to the file of the AO with the directions to comply with the order of the ld.JCIT dated 12.12.2018 and to give the assessee an opportunity to cross-examine the concerned witness/witnesses, and thereafter to pass assessment order afresh in accordance with law. It is directed that the AO will exercise the powers available to him under the relevant provisions of the Income Tax Act, read with relevant provisions of Code of Civil Procedure to ensure the attendance of the concerned witness/es, and thereafter to decide the matter after considering the evidences on the file

18.

In the result, the appeal of the assessee, IT(SS)A.No.131/Ahd/2023 is treated as allowed for statistical purpose.

19.

Since the facts and circumstances involved in all the appeals are identical to that have been discussed above, as the addition in all the cases has been made in relation to the same transaction in respect of property purchased jointly by the assessees/appellants herein, hence, our finding given above will mutatis mutandis apply to all the captioned appeals with the direction, as given above.

20.

In the result, all the captioned appeals are, accordingly, treated as allowed for statistical purpose.

Order pronounced in the Open Court on 24 /06/2025.

Sd/- Sd/- ( Narendra Prasad Sinha ) ( Sanjay Garg ) Accountant Member Judicial Member अहमदाबाद/Ahmedabad, िदनांक/Dated 24/06/2025

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