M/S. ISCON CRYSTAL DEVELOPERS,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-2(4), AHMEDABAD

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ITSSA 10/AHD/2021Status: DisposedITAT Ahmedabad07 June 2023AY 2013-1411 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer had not brought any concrete evidence, such as receipts, vouchers, or unregistered agreements, to support the receipt of on-money from purchasers. The sole reliance was on a PDF file from Ms. Kalindi S. Shah's computer, who was not an employee of the assessee. Furthermore, Ms. Shah stated the papers were given to her by Shri Jatin Gupta, also not an employee of the assessee, and neither was involved in the assessee's business. The Assessing Officer neither made inquiries with Shri Jatin Gupta nor with the purchasers but based the addition solely on Ms. Shah's statement, which was contrary to law. The Tribunal upheld the CIT(A)'s decision to estimate the net income at 8% of the on-money receipts, following the jurisdictional High Court's judgment in CIT vs. President Industries and the co-ordinate bench's decision in ITO Vs. Anand Builders, which was upheld by the Gujarat High Court and had its SLP dismissed by the Supreme Court. The Tribunal found no infirmity in the CIT(A)'s order and dismissed both the assessee's and the Revenue's appeals, as well as the assessee's cross-objection.

What were the facts?

The assessee, M/s. Iscon Crystal Developers, a partnership firm engaged in development and construction, is part of the JP Iscon Group. During search and seizure proceedings under Section 132 of the Income Tax Act, 1961, conducted on the JP Iscon Group on February 25, 2016, loose papers were found in the bedroom almirah of Ms. Kalindi S. Shah, a senior marketing manager. These papers, inventoried as annexure-A-3 of the Panchnama dated February 26, 2016, contained details of transactions for the Iscon Crystal Project in Deesa, Palanpur, reflecting a cash receipt of Rs. 1,77,84,870/-. Ms. Shah, in her statement under Section 132(4), accepted these as computerized cash book pages for the period July 7, 2012, to September 4, 2012. Based on this, proceedings under Section 153C were initiated against the assessee, leading to an addition of Rs. 1,77,84,870/- as unexplained income under Section 68.

What were the issues?

1. Whether the addition of Rs. 1,77,84,870/- as unexplained income under Section 68 of the Income Tax Act, 1961, is sustainable in law, considering the seized material was found from a third party (Ms. Kalindi S. Shah) and not from the assessee's business premises, and whether the assessee was provided with an opportunity for cross-examination of the said third party. Assessee's Contention: The assessee argued that since no search was conducted at its business premises, and the seized material originated from a third party (Ms. Kalindi S. Shah), the provisions of Section 132(4A) r.w.s. 292C are not applicable. They contended that the loose papers were not maintained or signed by the assessee or its employees, and Ms. Shah was the one who needed to explain the notings. The assessee also relied on the principle of natural justice, citing Andaman Timber Industries Vs. Commissioner of Central Excise, Kolkatta II, and Gujarat High Court judgments, arguing that adverse inferences cannot be drawn based on a statement recorded under Section 132(4) without providing the assessee with the statement copy and an opportunity for cross-examination. They further argued that the statement of Ms. Shah was binding only on her, not the assessee, citing CBI Vs. V.C. Shukla and Others. Revenue's Contention: The Revenue contended that the seized material related to the project developed by the assessee. Although Ms. Shah was not an employee of the assessee firm, she was an employee of JP Iscon Pvt. Ltd., a partner of the assessee firm. The Revenue argued that the assessee failed to prove that purchasers initially paid cash and then issued cheques, despite opportunities, and therefore, the entire addition made by the Assessing Officer under Section 68 should be restored.

Which sections of the Income-tax Act were involved?

Section 153C,Section 143(3),Section 132,Section 132(4),Section 132(4A),Section 292C,Section 68,Section 133A,Section 142(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AHMEDABAD “A” BENCH

Before: Shri Waseem Ahmed & Shri T.R. Senthil Kumar

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “A” BENCH Before: Shri Waseem Ahmed, Accountant Member And Shri T.R. Senthil Kumar, Judicial Member

IT(SSA No. 10/Ahd/2021 Assessment Year 2013-14

M/s. Iscon Crystal The ACIT, Developers Central Circle-2(4), Iscon House, Vs Ahmedabad Opp. Associated Petrol Pump, Off. C.G. Road, (Respondent) Ahmedabad-380015 PAN: AADFI0473Q (Appellant) IT(SS)A No. 31/Ahd/2021 & C.O. No. 20/Ahd/2021 Assessment Year 2013-14 The DCIT, M/s. Iscon Crystal Central Circle-2(4), Developers Ahmedabad Vs Iscon House, Opp. Associated Petrol Pump, Off. C.G. Road, Ahmedabad-380015 PAN: AADFI0473Q M/s. Iscon Crystal Vs The DCIT, Developers Central Circle-2(4), Iscon House, Ahmedabad Opp. Associated Petrol Pump, Off. C.G. Road, (Respondent) Ahmedabad-380015 PAN: AADFI0473Q (Appellant)

I.T(SS)A Nos. 10 & 31/Ahd/2021 and Ors. A.Y. 2013-14 Page No 2 M/s. Iscon Crystal Developers vs. ACIT

Assessee Represented: Ms. Nupur Shah, A.R. Revenue Represented: Shri Vijay Kumar Jaiswal, CIT-DR Date of hearing : 03-04-2023 Date of pronouncement : 07-06-2023 आदेश/ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:-

These cross appeals are filed by the Assessee and the Revenue as against the Appellate order dated 05.01.2021 passed by the Commissioner of Income Tax (Appeals)-12, Ahmedabad, arising out of the assessment order passed under section 153C r.w.s. 143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year (A.Y) 2013-14. The Cross Objection filed by the assessee as against the Revenue appeal in IT(SS)A No. 31/Ahd/2021.

2.

The brief facts of the case is that the assessee is Partnership Firm engaged in the business as Developer and Construction activities. The assessee is part of JP Iscon Group. There was a search and seizure proceedings u/s. 132 of the Act in JP Iscon Group on 25-02-2016 and also its senior marketing manager Ms. Kalindi S. Shah. Certain loose papers from the bedroom almirah of Ms. Kalindi S. Shah were found, inventorized and seized as annexure-A-3 of Panchnama dated 26-02-2016. In the statement recorded u/s. 132(4) of the Act, Ms. Kalindi S. Shah has categorically accepted the details of transactions by Iscon Crystal Project in Deesa, Palanpur which is a commercial project, wherein

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cash receipt of Rs. 1,77,84,870/- is reflected. In reply to question no. 35, she accepted that the pages contained details of transactions of Iscon Crystal Project. It was noticed that this was a computerized cash book page for the period 07-07-2012 to 04-09- 2012. On the basis of the above aforesaid documents, proceedings u/s. 153C were initiated in the case of the assessee and search assessment was completed by making addition.

2.1. The assessee submitted that it is a partnership firm consisting of five partners including JP Iscon Ltd. There was neither search proceedings u/s. 132 of the Act nor survey proceedings u/s. 133A of the Act carried out at the business premises of the assessee firm. Therefore invocation of the provisions of Section 132(4A) r.w.s. 292C that the seized material from third party namely Ms. Kalindi S. Shah is not applicable to the assessee’s case. It is Ms. Kalindi S. Shah who was to explain the notings made in the aforesaid loose/dump papers as the content of the same is not known to the assessee. Neither these loose papers have been maintained nor signed by the assessee or its partners or its employees, but other employee of the group concern. Thus the assessee claimed that the seized documents found from the search proceedings from the third party place cannot be treated as material evidence in the case of the assessee firm and the assessment proceedings itself is bad in law. However the above explanation was not accepted by the Assessing Officer and held that the assessee received on money of Rs. 1,77,84,870/- and added the same as the unexplained income of the assessee u/s. 68 of the Act.

I.T(SS)A Nos. 10 & 31/Ahd/2021 and Ors. A.Y. 2013-14 Page No 4 M/s. Iscon Crystal Developers vs. ACIT

3.

Aggrieved against the addition, the assessee filed an appeal before Ld. Commissioner of Income Tax (Appeals). The Ld. CIT(A) after detailed discussion held that the entire on money is not liable to be taxed, since the same cannot represent the income of the assessee but only the net profit embedded in the sales is liable to be taxed. After considering the various judicial precedents, the Ld. CIT(A) estimated net income at 8% of the on money receipts as income liable to be taxed which works out to Rs. 14,22,970/- and the balance amount of Rs. 1,63,62,080/- is deleted observing as follows: “….5.5 The AO has not brought any independent evidences in the form of cash receipts or vouchers except to PDF file in the computer seized from an employee of the other group concern. Further in answer to question No. 35, Ms. Kalindi S. Shah had stated that these pages were given to her by Shri Jatin Gupta and she was never involved in the project and she has not narrated any reason of keeping such papers in her possession. Even in her statement recorded u/s. 132(4) of the 1.7. Act, she has not stated anything about the cash entries having received as on money receipts. Therefore, there was no exclusive averment by anyone for and on behalf of appellant to the fact that the entries found noted in the computer sheet were on money receipts charged by the appellant firm. 5.6 Moreover, Shri Jatin Gupta who stated to have given the papers to Ms. Kalindi S. Shah was neither a partner nor an employee in the appellant firm and his connection to the appellant firm has not been brought on record to examine how and in what manner the aforesaid computer PDF file was maintained by Shri Jatin Gupta and subsequently by Ms. Kalindi S. Shah who was also not involved or engaged in the business activity of the appellant firm. Even Shri Jatin Gupta was never examined and recorded his statements to verify the statement of Ms. Kalindi S. Shah whereby the above papers stated to have been given to her by Shri Jatin Gupta. Except in the notice issued u/s. 142(1) of the 1.T. Act by the AO on 14.11.2018 whereby question and answer No. 35 of Ms. Kalindi S. Shah did 25.2.2016 has been reproduced but the copy of such statement was not made available to the appellant for cross examination by appellant and therefore there is lack of principle of natural justice as such statement has been utilized against the appellant behind the back. The whole statement ought to have been provided for assessee's contention upon the same and providing the opportunity of cross examination also but the same is found absent In this regard, reliance has been placed on the judgement of Hon'ble Supreme Court in the case of Andman Timber Industries Vs.

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Commissioner of Central Excise, Kolkatta II (2015) 62 Taxman.com 3. Said ratio was subsequently followed by Hon'ble Gujarat High Court in the case of CIT Vs. Ramanbhai B. Patel in Tax Appeal No. 207 to 210 of 2008 and CIT Vs. Indrajeetsingh Suri 215 Taxman 581. Subsequently, jurisdictional High Court has followed the aforesaid ratio in the case of Heirs & Legal Representatives of Shri Laxmanbhai S. Patel Vs. CIT 327 ITR 290. In view of the said judicial pronouncement, on the basis of statement of Ms. Kalindi S. Shah recorded u/s. 132(4), no adverse inference can be drawn against the appellant. 5.7 It has also been argued by the appellant that the statement recorded u/s 132(4) of Ms. Kalindi S. Shah was binding upon herself and the same could not be considered against the appellant as per the ratio laid down by the Hon'ble Supreme Court in the case of CBI Vs. V.C. Shukla and Others reported in 3 SCC 410 (1998). The appellant also emphasized the CBDT's Instruction No. 767 dated 4.10.1994 whereby it has been brought that it was a wide spread tendency on the part of the Income-tax Officer to make unrealistic or over pitch assessment without (a) making requisite enquiry (b) bringing on record sufficient evidence in support of the addition made (c) confronting the assessee with the material collected by them and (d) affording a reasonable opportunity to the assessee to rebut the material and explain his case. Therefore, the appellant emphasized that the AO has failed to confront the assessee the statements of Ms. Kalindi S. Shah and her cross examination by not complying to the directions or the instructions of the highest body and failed to bring on record sufficient evidences in support of the allegations. 5.8 In this regard, reliance has been placed on the judgement of Hon'ble Supreme Court in the case of Navnitlal C. Zaveri Vs. K.K. Sen 56 ITR 198 thereby it has been held that circulars issued by the Central Board of Revenue would be binding on all officers and persons employed in the Execution of the Income Tax Act. Thereafter various Hon'ble courts have followed the said judicial pronouncement. 5.9 It has also been argued that during the course of search proceedings at the main office premises of JP Iscon Pvt Ltd no incriminating material has been found with respect to the project at Deesa undertaken by the appellant and therefore the allegation of on money receipts is not correct. 5.10 It has also been submitted that the entry in the books of accounts maintained in the regular course of business is relevant for the purpose of considering the nature and impact of the transaction but notings of sheet of papers or loose sheet of papers are required to be supported/corroborated with the loose papers found from the possession of appellant firm or found from the possession of the third party. In the instant case, the AO has

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made the addition u/s. 68 of the IT. Act stating that the sum is credited to the books of accounts in the form of cash book. Although the computer page with the header of ZYX Iscon Crystal Deesa book are loose sheets and not the books of accounts of the appellant firm. Neither it was the cash book of the appellant firm maintained in regular course. If fact, it was not a regular cash book maintained by the appellant firm. Therefore, the transactions noted in the said loose sheets does not attract the provisions of Section 68 of the I.T. Act and the addition made thereupon is not sustainable as per the requirement of Section 68 of the Act. The said seized computerized ZYX loose sheets found cannot be considered as having evidential value for the assessment proceedings in absence of any incriminating material brought on record to corroborate and substantiate the entries in the said loose sheets. Therefore, the said loose sheet do not meet the provisions of Section 34 of Indian Evidence Act, 1872.” ………………..

5.16 In view of the above discussion, it has been noticed that certain loose sheets found during the course of search at the place of Ms. Kalindi S. Shah have not been corroborated with any supporting evidences including her statement. Neither Ms. Kalindi S. Shah nor Shri Jatin Gupta has been made available for cross examination by the appellant. The maintenance of such papers by the above persons is unexplained more so when neither those were partners or employees of the appellant firm. In other words, their relation/connection to the appellant has not been brought on record. Thus, the authenticity of the loose sheets found does not focus any action in the case of the appellant. Further, there is lack of principle of natural justice and no adverse view of such papers could be taken against the appellant in view of the judgment of Apex Court and other Courts. Even no one including partners of the appellant firm or Ms. Kalindi S. Shah in their statements have admitted about the receipt of on money received in respect of the project undertaken by the appellant firm. Further, as per the various judicial pronouncements of Hon'ble Supreme Court and various High Courts the provisions of Section 132(4A) in respect of computer sheets found and seized at the search premises of a third party and not in the place of appellant firm cannot be considered as a material evidence against the appellant firm. 5.17 Without prejudice to the above, if the entries noted in the seized computer sheets are considered as on money receipts, then also the net profit thereupon has to be taken as income of the appellant firm as per the prevalent net profit rate in the real estate business. If the entire on money receipts is considered as income, then the NP rate of the appellant firm works out very high which is not prevailing in this business. In this regard, no comparable case of that high net profit level has been brought on record by the AO. Therefore, before making such addition, the AO ought to have brought on record some comparable cases to compare such NP rates which could justify the addition of the on money receipts in the case of the appellant.

I.T(SS)A Nos. 10 & 31/Ahd/2021 and Ors. A.Y. 2013-14 Page No 7 M/s. Iscon Crystal Developers vs. ACIT

5.18 The reliance has been placed on the decision of Hon'ble ITAT, Ahmedabad in the case of ITO Vs. Anand Builders whereby it has been held that in such circumstance, 8% of the unaccounted on money could be taxed in place of the entire unaccounted on money receipts. It is needless to mention that the entire on money receipts cannot be taxed for the reason that against the unaccounted receipts there is always the unaccounted payments. Therefore, certain part of such unaccounted receipts only remains in the hands of appellant and the same can only be taxed. Subsequently, the above decision of the Hon'ble ITAT was upheld by the Hon'ble Gujarat High Court and the SLP filed against the judgement of Hon'ble Gujarat High Court was dismissed as reported in 265 ITR 37. For ready reference, the relevant extract of the Hon'ble Apex Court's decision is reproduced as under: "dismissed the special leave petition filed by the Department against the judgment dated January 21, 2002 of the Gujarat High Court in ITA No,. 52 of 20-02 whereby the High Court dismissed the Department's appeal on the ground that no substantial question of law arose. The question of law raised in the appeal before the High Court was whether the Appellate Tribunal's finding while directing the Assessing Officer to tax only 8 per cent of the unaccounted on money receipt instead of fully taxing it, in the absence of any evidence of expenditure, could not be stated to be perversed: ITO Vs. Anand Builders: SLP (C) No. 14166 of 2003.”

5.19 Reliance has also been placed on the judgment Hon'ble Gujarat High Court in the case of CIT Vs. President Industries reported at (2002) 124 Taxman 654 whereby it has been held that the amount of sales by itself cannot represent the income of the assessee who has not disclosed the sales, only the net profit embedded in sales and not whole sale proceeds itself would be treated as undisclosed income of the appellant. 5.20 Reliance has also been placed on the decision of Hon'ble ITAT "A" Bench, Ahmedabad in the case of Greenfield Realty Pvt. Ltd. Vs. ACIT Central Circle-1(2) B Ahmedabad in IT(SSIA No. 289, 290, 291 & 292/Ahd/2018 dated 21.2.2020 whereby in the similar facts of cases the net income @ 8% of the on money receipts have been decided considering various judgments of Hon'ble Jurisdictional High Court.

…...................... 5.19 The AO has made the reliance on the decision of Hon'ble ITAT, Mumbai in the case of Prime Developer Vs. DCIT which was confirmed by Hon'ble Bombay High Court whereby 17.8% of the on money has been confirmed. However, as discussed above, in the case of Anand Builders considering the decision of Hon’ble ITAT. Jurisdictional High Court and subsequently dismissal of SLP by Han’ble Supreme Court has concluded

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the matter by estimating the net income of 8% of the on money receipts as income liable for tax. Since we have to follow the judgment of Hon'ble jurisdictional High Court and as per the ratio laid in that case, it would be fair and reasonable to estimate the income at the rate 8% of the on money receipts of Rs.1,77,84,870/- which works out to Rs.14,22,790/-. Thus, the addition of the income out of the on money receipts to the extent of Rs. 14,22,790/- is confirmed and relief is granted for the balance amount of Rs.1,63,62,080/-. Thus, this ground of appeal is partly allowed.” 4. Aggrieved against the Appellate Order, the assessee is in appeal against the 8% confirmation of the on money receipts and the Revenue is in appeal against the deletion of Rs. 1,63,62,080/-.

4.1. Ld. Counsel Ms. Nupur Shah appearing for the assessee submitted that there was no search conducted at the business premises of the assessee firm and no incriminating material was recovered from the assessee firm as well as from the premises of JP Iscon Group where search was conducted relating to the project carried out by the assessee firm. However only in the residential premises of Ms. Kalindi S. Shah some dump papers were recovered and statement were recorded. The above dump material was not given to the assessee and no opportunity of cross examination was given to the assessee as held by the Hon’ble Supreme Court in the case of Andaman Timber Industries Vs. Commissioner of Central Excise reported in [2015] 62 taxmann.com 3. The assessee further relied upon Gujarat High Court judgment in the case of CIT vs. Ramanbhai B. Patel in Tax Appeal Nos. 207 to 210 of 2008, DCIT vs. Mahendra Ambalal Patel [2010] 40 DTR 243 (Guj.) and Prathana Construction Pvt. Ltd. in Tax Appeal No. 79 of 2000 (Guj.). that the addition made by the A.O. is not sustainable in law. Thus the Ld. counsel for the assessee submitted that the seized materials found from third party cannot be treated as material

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evidence in the case of assessee firm, in view of the provisions of section 132(4A) of the Act. Thus the Ld. CIT(A) ought to have deleted the entire addition rather estimating 8% of the on-money as the income of the assessee. Thus prayed to delete the entire addition made by the Assessing Officer.

5.

Per contra, the Ld. CIT-DR Shri Vijay Kumar Jaiswal appearing for the Revenue submitted the material seized from Ms. Kalindi S. Shah more particularly relating to the project developed by the assessee firm namely by Iscon Crystal Project in Deesa, Palanpur. Though Ms. Kalindi S. Shah is not the employee of the assessee firm, but she is an employee of JP Iscon Pvt. Ltd. which is one of the partner of the assessee firm. Further the assessee’s contention the purchasers of the flats initially paid cash and then after issued cheques is not proved beyond doubt by the assessee in spite of various opportunities given to the assessee. Therefore the entire addition made by the Assessing officer made u/s. 68 is to be restored and department appeal is to be allowed.

6.

We have heard the rival submissions and perused the materials available on record. The Assessing Officer has not brought any concrete evidence in the form of receipts, vouchers or unregistered agreement on the receipts of on money received from the purchasers. The only document that was relied upon by the A.O. is a PDF file in the computer seized from Ms. Kalindi S. Shah who is not the employee of the assessee firm. Ms. Kalindi S. Shah stated these excel pages were given to her by one Shri Jatin Gupta who is also not an employee of the assessee firm. Both the persons are not

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engaged in the business activity of the assessee firm. Further the A.O. neither made any enquiry with Shri Jatin Gupta about the excel sheet notings nor with the purchasers of the flat, but simply based on the statement of Ms. Kalindi S. Shah made the addition which contrary to the provisions of law.

6.1. In the above circumstances, the Ld. CIT(A) taking note of the Jurisdictional High Court judgment in the case of CIT vs. President Industries wherein it has held that the amount of sales by itself cannot represent the income of the assessee, who has not disclosed the sales, only the net profit embedded in sales and not whole sale proceeds itself would be treated as undisclosed income of the assessee. This ratio is been followed in the case of ITO Vs. Anand Builders wherein Co-ordinate Bench of this Tribunal held that in such circumstances, 8% of the unaccounted on money could be taxed in place of the entire unaccounted on money receipts since there is always the unaccounted payments. The above decision of the Hon’ble ITAT was upheld by the Hon’ble Gujarat High Court and the SLP filed against the judgment before the Supreme Court was also dismissed and reported in 265 ITR 37 held as follows: “Dismissed the special leave petition filed by the Department against the judgment dated January 21, 2002 of the Gujarat High Court in ITA No,. 52 of 20-02 whereby the High Court dismissed the Department's appeal on the ground that no substantial question of law arose. The question of law raised in the appeal before the High Court was whether the Appellate Tribunal's finding while directing the Assessing Officer to tax only 8 per cent of the unaccounted on money receipt instead of fully taxing it, in the absence of any evidence of expenditure, could not be stated to be perversed: ITO Vs. Anand Builders: SLP (C) No. 14166 of 2003.”

6.2. Respectfully following the above judgments, we do not find any infirmity in the order passed by the Ld. CIT(A) who has estimated

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the net income as 8% on the receipts of on-money. Thus the appeals filed by the Assessee and the Revenue are devoid of merits and the same are hereby dismissed. The C.O. filed by the Assessee in support of the order of the Ld. CIT(A), consequently the same is also dismissed.

7.

In the result, the appeals filed by the Assessee and the Revenue and cross objection filed by the Assessee all are dismissed.

Order pronounced in the open court on 07-06-2023

Sd/- Sd/- (WASEEM AHMED) (T.R. SENTHIL KUMAR) ACCOUNTANT MEMBER True Copy JUDICIAL MEMBER Ahmedabad : Dated 07/06/2023 आदेश क� ��त�ल�प अ�े�षत / Copy of Order Forwarded to:- 1. Assessee 2. Revenue 3. Concerned CIT 4. CIT (A) 5. DR, ITAT, Ahmedabad 6. Guard file. By order/आदेश से, उप/सहायक पंजीकार आयकर अपील�य अ�धकरण, अहमदाबाद

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