THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), AHMEDABAD vs. M/S. DESAI IMPEX PVT. LTD., AHMEDABAD

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ITSSA 25/AHD/2023Status: DisposedITAT Ahmedabad29 February 2024AY 2015-1619 pages

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

AI SummaryDismissed

What did the Tribunal hold?

The ITAT upheld the order of the CIT(A) and dismissed the Revenue's appeal. Regarding Ground No. 1, the Tribunal found the Revenue's ground frivolous as the Revenue failed to produce any order from the Hon'ble Apex Court staying proceedings on the identical issue. For Ground No. 2, concerning the addition of Rs. 18,99,178/- for unexplained entries, the Tribunal noted that the loose papers were petty cash books of the assessee and its sister concerns, and the entries matched the assessee's main audited cash book. The Tribunal held that the AO erred in making the entire addition in the assessee's hands for transactions related to sister concerns and that the Revenue failed to provide corroborative evidence of unaccounted transactions. Therefore, the deletion of this addition was upheld. For Grounds 3, 4, and 5, the Tribunal found that these issues also flowed from the basic observations of the CIT(A) and that the deletions made by the CIT(A) were without ambiguity, thus upholding the deletions. Grounds 6 and 7 were considered general. The Tribunal held that the AO could not make an addition in the assessee's hands for transactions related to sister concerns without corroborative evidence, especially when the entries matched the audited books.

What were the facts?

The Revenue is in appeal against the order of the CIT(A) for Assessment Year 2015-16. The assessment was made under Section 143(3) read with Section 153C of the Income Tax Act, 1961. The Revenue's appeal challenges the deletion of additions made by the Assessing Officer (AO) on multiple grounds. These grounds include issues related to unexplained entries in seized materials, unexplained cash deposits, unexplained credit entries, and disallowance under Section 40(a)(ia). The original assessment stemmed from a search and seizure action on Shri Mahendra Shantilal Patel (MSP) and his group, where the assessee, M/s. Desai Impex Pvt. Ltd., was found to be a beneficiary of accommodation entries. The AO quantified unexplained transactions for AY 2015-16 to 2017-18. The CIT(A) deleted the additions, leading to the present appeal by the Revenue.

What were the issues?

The Income Tax Appellate Tribunal (ITAT) had to decide the following issues: 1. Whether the CIT(A) erred in granting relief to the assessee by holding that no incriminating materials were found regarding the issue on which additions were made, citing a pending SLP before the Hon'ble Supreme Court on an identical issue (Ground No. 1). 2. Whether the CIT(A) erred in deleting the addition of Rs. 18,99,178/- on account of unexplained entries in seized/impounded materials (Ground No. 2). 3. Whether the CIT(A) erred in deleting the addition of Rs. 99,86,236/- on account of unexplained cash deposits in the bank account under Section 68 of the Act (Ground No. 3). 4. Whether the CIT(A) erred in deleting the addition of Rs. 7,77,045/- on account of unexplained credit entries (Ground No. 4). 5. Whether the CIT(A) erred in deleting the addition of Rs. 61,90,847/- on account of disallowance under Section 40(a)(ia) (Ground No. 5). 6. Whether the AO's order should have been upheld (Ground No. 6). Assessee's Contentions: - For Ground No. 1, the assessee argued that the CIT(A) correctly granted relief as no incriminating material was found, and an SLP was pending. The Revenue failed to show any order staying proceedings. - For Ground No. 2, the assessee contended that the loose papers found were daily cash books of the assessee and sister concerns, and the entries matched the main audited cash book. The AO made the entire addition in the assessee's hands, which is not permissible for transactions related to sister concerns. No corroborative evidence was brought by the Revenue to establish unaccounted transactions. - For Grounds 3, 4, and 5, the assessee relied on the CIT(A)'s observations and deletions. Revenue's Contentions: - The Revenue argued that the CIT(A) erred in deleting the additions on the grounds mentioned in the appeal.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 153C,Section 132,Section 68,Section 40(a)(ia),Section 133A,Section 143(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, AHMEDABAD

Before: SHRI WASEEM AHMED&

For Respondent: Shri Sudhendu Das, CIT. DR, Shri M. J. Shah & Shri Rushin Patel
Pronounced: 29/02/2024

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD

BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER & Ms. MADHUMITA ROY, JUDICIAL MEMBER I.T(SS).A. No. 25/Ahd/2023 (�नधा�रण वष� / Assessment Year : 2015-16)

Deputy Commissioner of M/s. Desai Impex Pvt. बनाम/ Income Tax Ltd. Vs. Central Circle - 1(3), 407, 4th Floor, Sigma Ahmedabad Ceejay Legacy, Nr. Panjara Pole Cross Roads, Gulbai Tekra, Ahmedabad 380015 �थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AABCD4327M (Appellant) .. (Respondent) Revenue by : Shri Sudhendu Das, CIT. DR Shri M. J. Shah & Shri Rushin Patel, Assessee by : A.R. 14/02/2024 Date of Hearing Date of Pronouncement 29/02/2024 O R D E R PER Ms. MADHUMITA ROY - JM: The instant appeal filed at the instance of the Revenue is directed against the order dated 16.12.2022 passed by the Commissioner of Income Tax (Appeals)-11, Ahmedabad [‘the CIT(A)], arising out of the order dated 28.12.2018 passed by the DCIT, Central Circle - 1(3), Ahmedabad, under Section 143(3) r.w.s. 153C of the Income Tax Act, 1961 (hereinafter referred as to ‘the Act’) for Assessment Year 2015-16 with the following grounds:

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 2 – “1. "Whether on the facts and in the circumstances of the case and in law, the Ld.CIT(A) has erred in giving relief to the assessee by holding that no incriminating materials were found with regard to the issue on which additions were made in the assessment order because an SLP on this issue is pending before the Hon'ble Supreme Court?" 2. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition on account of unexplained entries in seized/impounded materials of Rs.18,99,178/-. 3. On the facts and in the circumstances of the case and in law, the Ld. C!T(A) erred in deleting the addition on account of unexplained cash deposits in bank account u/s 68 of the Act of Rs.99.86,236/-. 4. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition made on account of unexplained credit entries of Rs.7,77,045/- 5. On the facts and in the circumstances of the case and in law, the Ld, CIT(A) erred in deleting the addition made on account of disallowance u/s 40(a)(ia) of Rs.61,90,847/- . 6. On the facts and in the circumstances of the case and in law, the Ld.ClT(A) ought to have upheld the order of the AO.”

2.

Ground No.1 relates to granting relief to the assessee on the ground of not having been found any incriminating materials with regard to the issue on which the additions were made as SLP is pending before the Hon’ble Apex Court on the identical issue. The CIT(A)’s order of such granting relief on this issue is, thus, being questioned. The Ld. DR failed to show any order passed by the Hon’ble Apex Court staying proceeding before the Hon’ble High Court or Tribunal on identical issue in the absence of which, this ground of appeal is found to be frivolous and dismissed.

3.

Ground No.2 relates to addition in respect of unexplained entries in seized/impounded materials of Rs.18,99,178/-.

4.

The brief facts leading to this case is this that a search and seizure action was carried out in the case of one Shri Mahendra Shantilal Patel (hereinafter referred to as ‘MSP’) and his group

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 3 – concern on 06.02.2017. During the course of such search under Section 132 of the Act at his residence evidences were impounded wherefrom it was found by the authorities that the said MSP through web of concerns, run and operated by him, was engaged in providing accommodation entries of various nature and prominently accommodation entries of bogus bills. Such activities were also accepted by the said MSP as his statement recorded under Section 132(4) of the Act using 5 PANs as per the Revenue authority. The Ld. AO quantified unexplained transaction to the tune of Rs.21,36,56,070/- for A.Ys. 2015-16 to 2017-18. The details whereof is as follows:

Sr. Annexure A.Y. Amount of unexplained No. transaction (In Rs.) 1. Annexure - A/1 2015-16 18,99,178 2 Annexure-A/1 2016-17 14,87,533 3. Annexure - A/2, Page - 1 2017-18 3,36,00,000 4. Annexure - A/2, Page - 5 to 7 2017-18 2,75,00,000 5. Annexure - A/2, Page -23 2017-18 15,61,687 6. Annexure - A/2, Page - 59 2017-18 1,23,16,333 7. Annexure - A/2, Page - 67 2017-18 1,66,17,501 8. Annexure - A/2, Page - 68 2016-17 27,88,751 9. Annexure - A/2, Page - 68 2017-18 1,19,68,628 10. Annexure - A/2, Page - 80 2017-18 5,05,500 11. Annexure - A/2, Page - 85 2017-18 11,16,750 12. Annexure - A/2, Page - 91 2017-18 3,25,000

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 4 – 13. Annexure - A/2, Page - 93 2017-18 8,63,000 14. Annexure - A/2, Page - 94 2017-18 29,09,850 15. Annexure - A/2, Page - 96 2017-18 13,91,325 16. Annexure - A/2, Page - 102 2017-18 9,68,05,034

5.

The appellant was found to be one of the beneficiaries and given ample opportunities but as no explanation was submitted by the assessee alongwith documentary evidence, the addition to the tune of Rs.18,99,178/- was made in the year A.Y. 2015-16 which was finally deleted by the Ld. CIT(A). Hence, the instant appeal before us.

6.

During the course of appellate proceeding, additional evidences alongwith explanation was submitted by the assessee which was sent to the Ld. AO by the First Appellate Authority asking for a remand report. The said remand report was finally furnished on 13.12.2021 objecting the admission of those additional evidences as ample opportunities and reasonable time was furnished to the assessee for submitting the same during the assessment proceeding without considering the fact that one of the Directors who was diagnosed with Diabetes and Hypertension met with an accident and had undergone surgery during assessment 2018 and due to such chain of events, the necessary details in the scrutiny assessment proceeding could not be filed by the assessee The contents of the remand report is reproduced hereinbelow:

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 5 –

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 6 –

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 7 – 7. Against the same, the assessee filed rejoinder dated 18.03.2021 with the following contents:

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 8 –

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 9 –

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 10 –

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 11 –

8.

The reply of the said remand report was further forwarded to the Ld. AO whereupon a further remand report dated 09.05.2022 with the following contents were submitted by the Ld. AO:

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 12 –

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 13 –

9.

So far as the addition of Rs.18,99,178/- on account of unexplained entries is concerned, it was pointed out by the Ld. AO in the remand report that no new evidence on this issue except the loose paper in the form of cash book for 3 entries, namely, Desai Metalinks, Desai Impex Pvt. Ltd. and Desai Enterprise were submitted by the assessee. However, such detail doesn’t establish the source of the transaction mentioned in the seized and impounded documents as was the view of the Ld. AO. Further fact reveals that on the date of search, the time limit for issuing notice under Section 143(2) of the Act for the year under consideration had expired, meaning thereby, the year under consideration is an unabated year for all purposes for making assessment under Section 153A/153C of the Act. Furthermore, the Ld. AO not specified the incriminating

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 14 – material found and/or seized during the course of search action on the basis of which the additions were made. After the careful consideration of the entire set of documents and the order passed by the authorities below, it appears that the proceeding under Section 153C of the Act was initiated for A.Ys. 2011-12 to 2016-17 on the basis of documents pertaining to the assessee found and seized during search action on MSP Group on 06.02.2017. Relevant to mention that on the same day, survey action under Section 133A of the Act was carried out at the premises of the assessee and books of accounts were impounded. During the course of survey proceeding, incriminating evidences were found and impounded the details of which as narrated by the Ld. AO in the assessment order is as follows: Para 3 of Page 46 of Ld. CIT(A)

Annexure Pages Contents A-1 1-302 Details of day to day cash transaction A-2 1-62, 76-95 Various transactions A-2 96 Details of cash transaction of Rs.13,16,175/- A-2 97-102 & 63-75 Details of bogus transaction with bogus concerns of MSP, namely Krishna Sales Corporation, Satyam Tradelink, Crystal Agency, Sai Enterprise.

10.

Thereafter, show cause notice under Section 142(1) of the Act dated 03.12.2018 was issued to the assessee in regard to the transactions made with the MSP Group mentioned in the books of accounts alongwith the supporting evidences but the assessee did not file any reply. The addition on the basis of seized document found to be remained unexplained to the extent of impugned amount of Rs.18,99,178/- or A.Y. 2015-16 and the same was added to the total income of the assessee. However, it appears from Page No.52

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 15 – of the assessment order that this particular addition was made on the basis of the seized document found being Annexure A-1 appearing from Page 1-302 of the seized documents found in course of survey took place in assessee’s premises and thus having no relation with the documents found and seized during the course of search on MSP Group. Relevant to mention that the other additions made by the Ld. AO was not on the basis of any seized documents. However, this particular fact has been mistakenly mentioned as impounded and seized during search action by the Ld. CIT(A) at Page No.25 of the order impugned before us. We could ascertain this particular fact from the assessment order, at Page No.46 whereof mentions about such evidence being Annexure A-1 appearing from Page Nos. 1 to 302 containing the details of day-to- day transactions. It was specifically mentioned that this particular document was found and impounded from the assessee’s premises on survey which is basically a petty cash book kept by the appellant company to keep recording of daily miscellaneous expenses and the average balance mentioned therein is approximately Rs.25000/- to Rs.30000/-. Moreso, the assessee claimed the said loose papers to be the daily cash book of the assessee Company, namely, Desai Metalinks (DM), Desai Impex Pvt. Ltd. (DI) and Desai Enterprise (DE). To the utter surprise, we find that the Ld. AO has made addition only in the hands of the assessee company. He made the entire addition related to the cash deposit in the bank, addition on account of unexplained credits under Section 68 of the Act (difference in closing and opening amount of trade payable creditors) and disallowance on account of non-deduction of TDS under Section 40(a)(ia) of the Act without mentioning any live nexus with the incriminating material claimed to have been found

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 16 – during the course of search. We further find that while deleting the impugned addition made by the Ld. AO, the Ld. CIT(A) upon perusal of the entire set of records observed as follows:

“5.11 As regard the addition of Rs. 18,99,178/- on account of documents found and seized during the search action is concerned, the is being decided on merit in the following paras. 5.11.1 In this regard, it is observed from the rejoinder (supra) dated 18.03.2022 that the appellant had furnished page wise explanation of the loose paper addition of Rs. 18,99,178/-which is as per Page 52 and Page 53 of the assessment order. In the said rejoinder, the appellant has stated that in the assessment order, the details of page numbers based on which such addition was determined, is not mentioned. But it is only mentioned that page nos 1 to 302 of Annexure-A/1 contains petty cash book kept by the appellant company to keep transactions of daily misc. expenses. The average balance in the said cash book is approximately Rs 25,000/- to Rs 30,000/- Further, the appellant has claimed that the impugned loose papers on record are daily cash book of the appellant companyie Desai Impex (DI) and also two other sister concernie. Desai Metalinks (DM) and Desai Enterprises (DE) However, the AO had made only addition in the hands of appellant company, which is wrong Further, the appellant has contended that the AO had added daily balances while making the addition on this account, which is wrong in fact and in law 5.11.2 It is also observed from the remand report (supra) dated 09.05.2022 that the AO has stated that the appellant has furnished the copy of loose paper in the form of cash book for 3 entities i.e. DM: Desai Metalinks, DI: Desai Impex Pvt. Ltd. and DE: Desai enterprise. However, the appellant has not furnished any details regarding the source of the said transaction. Thus, the AO has requested to upheld the addition made. 5.11.3 Thereafter, the appellant in its rejoinder uploaded on ITBA system on 19.07.2022 in which it has requested to delete the addition made by the AD 5.11.4 In this regard, on perusal of the records, the undersigned has observed that the claim of the appellant is acceptable because on perusal of the said seized loose papers no. 1 to 302, it is observed that the said papers were petty cash book of the appellant company as well as its two sister concerns. Further, it is also observed that on the loose paper, it was clearly written as DI, DE & DM which means Desai Impex Pvt. Ltd, Desai Enterprise & Desai Metalinks respectively. Further, on perusal of the cash books and said seized daily petty cash book, it is observed that the entries written in the seized petty cash are tallied with cash book furnished by the AO It is an undisputed fact that the appellant case was audited case and the entries in the petty cashbook for the appellant was matching with the main cash. book of the appellant. It is also significant to mention here that the appellant company has filed its return of income on time and showing total income of Rs. 17,84,590/- Further, no addition was made by the AO related to transaction made with MSP for the any assessment year except for A Y 2016-17 & AY 2017- 18 which is evident from the assessment order. It is

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 17 – also observed that the appellant's arguments regarding the impugned loose papers on record are daily cash book of the appellant company i.e. Desai Impex (DI) and two other sister concern ie. Desai Metalinks (DM) and Desai Enterprises (DE) having force, as the AO had made entire addition in the hands of appellant company. It is settled law that the AO cannot make an addition in the hand of appellant for any such transactions which are related to other assessees i.e. sister concerns of the appellant company. Further, the AO had not brought any corroborative evidence to establish that the figures mentioned in the seized documents are unaccounted transactions Since, all the transactions related to appellant company mentioned in the seized petty cash book are matching with the main cash book, the addition made by the AD does not survive Thus, addition of Rs. 18,99,178/- made on the basis of Petty Cash Book is deleted.” 11. It was also argued by the Ld. Counsel appearing for the assessee that the satisfaction note must speaks of the incriminating material seized pertains to assessment order in question. In this regard he has relied upon the judgment passed by the Hon’ble Apex Court in the case of CIT vs. Singhad Technical Education Society, reported in [2017] 397 ITR 344 (SC), wherein it was observed as under:

“18. The Income-tax Appellate Tribunal permitted this additional ground by giving a reason that it was a jurisdictional issue taken up on the basis of facts already on the record and, therefore, could be raised. In this behalf, it was noted by the Income-tax Appellate Tribunal that as per the provisions of section 153C of the Act, incriminating material which was seized had to pertain to the assessment years in question and it is an undisputed fact that the documents which were seized did not establish any co-relation, document-wise, with these four assessment years. Since this requirement under section 153C of the Act is essential for assessment under that provision, it becomes a jurisdictional fact. We find this reasoning to be logical and valid, having regard to the provisions of section 153C of the Act. Para 9 of the order of the Income-tax Appellate Tribunal reveals that the Income-tax Appellate Tribunal had scanned through the satisfaction note and the material which was disclosed therein was culled out and it showed that the same belongs to the assessment year 2004-05 or thereafter. After taking note of the material in para 9 of the order, the position that emerges therefrom is discussed in para 10. It was specifically recorded that the counsel for the Department could not point out to the contrary. It is for this reason the High Court has also given its imprimatur to the aforesaid approach of the Tribunal. That apart, learned senior counsel appearing for the respondent, argued that notice in respect of the assessment years 2000-01 and 2001-02 was even time barred.”

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 18 – 12. In this particular case, the document being Annexure A1 appearing from Page Nos. 1-302 containing the details of day-to- day transactions is not relating to A.Y. 2015-16 neither undisclosed and cannot be said to be incriminating, because of the reason that the entries recorded in the audited books of account of the assessee matches with the same which has not been able to be controverted by the Ld. DR before us.

13.

It appears from the above that it was factually found by the Ld. CIT(A) from the documents on record including the seized documents, particularly, the entries written in seized petty cash book of the appellant company and impugned loose papers written as DI, DE & DM was matching with the main cash book of the appellant. The books of accounts of assessee is also audited one. Though, it is also a fact that as the loose papers on record are the petty cash book of the appellant company and two other sister concerns, the entire addition has been made in the hands of the appellant company which is not permissible in the eye of law under the facts and circumstances of the case. Neither any corroborative evidence are forthcoming from the Revenue showing the figures mentioned in the seized documents are unaccounted transaction, particularly, when all the transactions related to the appellant company mentioned in the seized petty cash book matching with the main cash book, the addition has rightly been held as unsustainable by the Ld. CIT(A), deletion whereof is found to be just and proper so as to warrant interference. Thus, we upheld the order passed by the Ld. CIT(A). This particular ground of appeal filed by the Revenue is found to be devoid of any merit and, thus, dismissed.

IT(SS)A No. 25/Ahd/2023 (The DCIT vs. M/s. Desai Impex Pvt. Ltd.) A.Y.– 2015-16 - 19 – 14. So far as the other issue of addition impugned before us by way of Ground Nos. 3, 4 & 5, the same also flows from the basic observation made by the Ld. CIT(A) at Para 5 mentioned therein and on the same pretext as deleted by the Ld. CIT(A) is found to be without any ambiguity so as to warrant interference. The deletion of addition is therefore upheld. Therefore, Ground Nos. 3, 4 & 5 are also dismissed.

15.

Ground Nos. 6 & 7 are general in nature and no order needs to be passed.

This Order pronounced on 29/02/2024

Sd/- Sd/- (WASEEM AHMED) (MADHUMITA ROY) ACCOUNTANT MEMBER JUDICIAL MEMBER Ahmedabad; Dated 29/02/2024 S. K. SINHA True Copy आदेश क� ��त�ल�प अ�े�षत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant 2. ��यथ� / The Respondent. 3. संबं�धत आयकर आयु�त / Concerned CIT 4. आयकर आयु�त(अपील) / The CIT(A)- 5. �वभागीय ��त�न�ध, आयकर अपील�य अ�धकरण, अहमदाबाद / DR, ITAT, Ahmedabad 6. गाड� फाईल / Guard file. आदेशानुसार/ BY ORDER,

उप/सहायक पंजीकार (Dy./Asstt. Registrar) आयकर अपील�य अ�धकरण, अहमदाबाद / ITAT, Ahmedabad

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