RATNA INFRASTRUCTURE PROJECTS PVT.LTD., HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES “B” : HYDERABAD (THROUGH VIDEO CONFERENCE)

BEFORE SHRI S.S.GODARA, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

I.T.A. Nos. 730 & 731/HYD/2016 & C.O. Nos.8 & 9/HYD/2021 (in ITA Nos.730 & 731/Hyd/2016) Assessment Years: 2011-12 & 2012-13 M/s.Ratna Infrastructure Deputy Commissioner of Projects Pvt. Ltd., Vs Income Tax, HYDERABAD Central Circle-3, [PAN: AADCR5836P] HYDERABAD / Asst. Commissioner of Income Tax, Circle-3(1), HYDERABAD (Appellant) (Respondent/Cross-Objector) For Assessee : Shri Mohd. Afzal, AR For Revenue : Shri Y.V.S.T.Sai, CIT-DR Date of Hearing : 10-02-2022 Date of Pronouncement : 29-03-2022 O R D E R PER S.S.GODARA, J.M. : These twin assessee’s appeals ITA Nos.730 & 731/Hyd/2016 with Revenue’s corresponding cross objections C.O.Nos.8 & 9/Hyd/2021 for AYs.2011-12 & 2012-13 arise against the CIT(A)-12, Hyderabad’s separate orders; both dated 26-02-2016 passed in appeal No.0123 & 0122/2014-15, involving proceedings u/s.143(3) r.w.s.153A and u/s.143(3) of the Income Tax Act, 1961 [in short, ‘the Act’]; respectively.

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Heard both the parties. Case files perused.

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CIT(A) has erred in law and on facts in deleting Section 40A(3) disallowance of Rs.10 crores in AY.2011-12 and Rs.4 crores in AY.2012-13; respectively. The CIT(A)’s identical detailed discussion in issue reads as follows: “5.0 Addition on account of unexplained expenditure/disallowance u/s.40A(3) and declarations made u/s.132(4), but not admitted in return of income - Rs.10,00,00,000 /-: 5.1 During the course of assessment proceedings, conducted in this case on 26-03-2012, the AO observed that certain valuables were found along with certain incriminating information. The information found and seized/impounded are shown as under; (a) Pages 1 to 113 of Annexure A/RIPPL/01 to the Panchnama dated 26-03-12 drawn at plot no.88, Road No.72, Prashasan Nagar, Jubilee Hills, Hyderabad-500 033. (b) Two external hard disks Annexure A/RIPPL/02&03, dated 26-03- 12 at plot no.88, Road No.72, Prashasan Nagar, Jubilee Hills, Hyderabad- 500 033. (c) Pages 1 to 23 of Annexure A/RIPPL/04, dated 26-03-12 drawn at plot no.88, Road No.72, Prashasan Nagar, Jubilee Hills, Hyderabad- 500 033. (d) Annex.A/Ratna/off/03, impounded on 26-03-12, at the office premises of M/s.Ratna Infrastructure Projects Pvt Ltd located at Plot No.144, Road No.17, Prashasan Nagar, Jubilee Hills, Hyderabad. 5.1.1 While finalising the assessment, the AO made reference to the contents of the seized/impounded material found during the course of search/survey proceedings at the premises of group concerns and observed that assessee is indulging huge payments of cash to local groups which were not accounted in books. Such amounts are quantified at Rs.68,87,500/-, which also formed part of declarations made for A.Y.201213 along with A.Y.2011-12 which was confirmed by the assessee and such amounts shown to have been paid for illegal gratification. It was also observed that there are huge cash withdrawal of cash from the bank accounts maintained at various places such as Kohima, Mekarkong, apart from the bank account at central office, immediately on receipt of the amounts from principal contractors such as M/s.Gayatri Projects Ltd., M/s.IL&FS, etc and assessee for not being in position to explain such withdrawals with reasons and also unable to produce books to explain the same, as such the company declared undisclosed income of Rs.10.00 crores for A.Y.2011-12 and Rs.14.00 crores for A.Y.2012-13, to cover up all

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these deficiencies/short comings. The essence of statement by Mr.MML Narsimham, Managing Director of the company was brought on record to indicate the basis of declaring. the additional/undisclosed income for A.Y.2011-12 and 2012-13. Since the assessee did not honor the declarations, based on the changed stand that the cash withdrawals are meant for meeting the expenses at work. sites and such payments are covered by Rule 600, with the vouchers for expenses, which could not be produced at the time of search, are verified later and such information support the stand taken by assessee, the AO analysed the said explanation and rebutted the same on following lines: - Disclosure was made by the assessee after verifying the books/vouchers and availability of bank accounts at work sites and the assessee changed it's mind subsequently to treat the expenses as genuine and allowable. - Disclosure was made after considering the fact that entire receipts were withdrawn in cash from bank accounts and after examining the allowable nature of expenses claimed and as such it is not Possible to believe after long gap of time that disclosure made was without such examination. - The assessee failed to prove the existence of conditions so as to come under the purview of Rule 6DD, by not proving the fact that no banks were existing at work sites and all the payees are located/residing at work sites, with no such information brought on record. - The vouchers which were not available at the time of search, were prepared with each of such amounts below Rs.20,000/- which is nothing but after thought on part of the assessee. - The assessee, prevented the department/Assessing Authority, from further investigation, by making a declaration u/s.132(4), as such retraction after a long gap is not acceptable. In this regard the AO relied on the judicial decision. Accordingly, the AO treated the undisclosed amount of Rs.10 crores, as declared u/s.132(4) during the course of search proceedings, as undisclosed income of the appellant company for the year under reference and computed the total income at Rs.14,73,61,155/-. 5.2 The appellant objected for the addition of Rs.10,00,00,000/- and filed his written submissions and the main contents of the same run as under: 1. The turnover of the assessee for the subject assessment year is at Rs.444,33,66,270/- and other income at Rs.4,39,03,377/-, on which income of Rs.4,73,61,155/- was admitted claiming a depreciation of

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Rs.10,50,35,858/- and books of accounts of the assessee are audited as provided u/s 44AB of the IT Act and as per the Accountants the amount disaIlowable u/s 40A(3) of the IT Act r.w.r 6DD is at Rs.40,20,600/- which is added back to the book profit in the computation of income of the assessee. 2. During the Course of assessment proceedings the assessee submitted books of accounts and vouchers for verification and the learned Assessing Officer has not pointed out any defects in the books of accounts except stating that some of the vouchers are self made vouchers. It is submitted that the assessee is dealing with an unorganized sector of persons particularly in respect of labour payments and also to some extent certain purchases, therefore, the self vouchers are bound to occur and very common in this lines of business and therefore, an acceptable phenomena. 3. The assessee is executing works at remote areas at Mizoram and Naqaland and the Banking facility from the works site is far away, therefore, the assessee is protected by the c1ause-(g) of Rules 6DD of the IT Rules. 4.The only addition to the income returned u/s 153A is made u/s 40A(3) of the IT Act at Rs. 10,00,00,000/-, with an assumption that the cash payments are made in violation of section 40A(3) r.w.r. Rule 6DD on account of cash expenditure not supported by the supporting evidence and in this regard, it is respectfully submitted that the assessee produced books of accounts and supporting vouchers at the time of assessment proceedings. Without rejecting the books of accounts no addition can be made u/s.40A(3) and disallowance may be limited to specific amount which is paid in violation of the said section and it is pertinent to mention here that the learned Assessing Officer has not identified any specific items from the books produced to attract the provisions of section 40A(3) of the IT Act. 5. The company has executed works awarded by various departments and works taken on sub-contracts executed by the company directly by the men and machinery of the company and partly through sub-contractors. In addition to that the company has also under taken works on back to back basis wherein the work is given sub-contract with a low margin of profits. The details are as under for the subject assessment year:

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Direct 6332.20 953.38 15.06 323.16 5.10 Sub- 2407.38 468.68 19.47 2.02 contract Executed 35694.06 0.00 0.00 0.00 by B2B contractors Gross 444433.64 1422.05 3.20 371.69 0.84 turnover

As seen from the above table the profit before depreciation in respect of works executed both direct and sub-contract is at 17.26% and net profit is about 7.12%. In respect of back to back the profit is about 0.84%, as there only commission aspect involved, as the transaction routed through assessee and no involvement of men and machinery of the assessee is there in this turnover. Therefore considering the rate of profit as per books of accounts is @ 17.26% before depreciation on works executed. 5.3 Perused the submissions of appellant and the findings/observations of the AO. As could be made out from the facts of the case, the appellant company and the main promoters, namely Mr.MML Narasimham, were covered by the proceedings u/s.132/133A, on 26-03-2012, in connection with search proceedings in other connected cases of infrastructure companies, based on the information that the assessee company and associations are acting as conduits/sub-contractors for siphoning the amounts on behalf of their principals. These facts have come to the light, during the proceedings in this case, where in it was clearly observed that amounts were withdrawn from the bank account in cash and the assessee tried to explain that cash withdrawals were for the purpose of business and payments were made at the distant working sites where there are no banking facilities and for the purpose of payments to the labour charges. The other reason quoted were the extreme situation prevailing at the work sites, where the cash accumulations in bank accounts were targeted by the extortioners, as such cash could not be transferred through the bank accounts maintained at Kohima and Mekarkong etc. However, this theory of the assessee falls flat, for the reason that the assessee already found to be paying huge amounts as extortion money and having paid such money, there could not have been any trouble to the assessee. Further, the amounts could have easily transferred through the bank account in the near by places of work sites, in small amounts, on daily or weekly basis, from the head office. Further as per the information brought on record, equally good amounts were routed through the bank accounts located at Kohima and Mekarkong in some of the years, notably during A.Y.2012-13. This may prove the assessee's theory that extortionist attacks bank accounts, on the

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accumulated balances, if maintained at place like Kohima and other nearby places. 5.3.1 In this context, it may be relevant to refer to the amounts paid as extortion money which was quantified at Rs.68,87/S00/- and offered as additional income for A.Y.2011-12 and A.Y.2012-13, based on the entries found in seized/impounded material/books. It was also a fact that no books/vouchers were produced by the assessee at the time of search and production of the same at the stage of assessment was certainly an after thought. The payment of extortion money and non-maintenance of vouchers and books as evidenced at the time of survey/search in this case prove clearly that books are not reliable and for the same reasons deemed to have been rejected, though it is a fact that Audit Reports were shown to be furnished and returned incomes shown to have been filed on such basis. 5.3.2 The other factor that assessee relied upon for admitting undisclosed income at the time of search and subsequent withdrawal/retraction, was the applicability of provisions of Sec.40A(3) rwr 6DD, in allowing or disallowing the cash payments exceeding Rs.20,000/-. In this regard, it may be relevant to refer to the situation based on which such declaration was made i.e., books of account/vouchers are not readily available and the assessee was not sure whether the cash payments made will be explained reasonably with reference to the provisions of Sec.40A(3). The same factor appeared to have turned in favour of the assessee, after a period of few months of date of search, where cash payments have become explainable by proper vouchers and the amounts of cash payments are covered by Rule 6DD of I.T.Rules. In this context, it may be further relevant to refer to the fact that there is no change in the filed situation or the real facts, but same are twisted to the extent it suited the assessee. Vouchers which were not available at the time of search proceedings, appeared to have been created later, as it is not a difficult proposition, where every payment shown to have been made in cash. However, as opined by the AO in asst. order, the assessee failed to establish/prove that there are no banks at the work sites and all the persons who received the payments were residing at work sites, by failing to furnishing any information in this regard. In this context, it may not be out of context to recite the decision if Hon'ble Supreme Court in the case of Attar Singh Gurmukh Singh Etc. Vs. ITO [191 ITR 667 (1991)] on the issue of scope of provisions of Sec.40A(3), where the ratio of the Hon'ble Court was that provisions of Sec.40A(3), not intended to restrict the business activities, but is only a restraint intended to curb the chances and opportunities to use or create black money. The relevant portion (part) of the head note of the decision referred runs as under:

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“Sec.40A(3) only empowers the Assessing Office to disallow the deduction claimed as expenditure in respect of which payment is not - made by crossed Cheque or cross bank draft. The payment by cross cheque or crossed bank draft is insisted on to enable authority to ascertain whether the payment was genuine or whether it was out of the income from disclosed sources. The terms of s.40A(3) are not absolute. Consideration of business expediency and other relevant factors are not excluded. The genuine and bona fide transactions are not taken out of the sweep of the section. It is open to the assessee to furnish to the satisfaction of the Assessing Officer the circumstances under which the payment in the manner prescribed in s.40A(3) was not practicable or would have caused genuine difficulty to the payee. It is also open to the assessee to identify the person who has received the cash payment. It will be clear from the provisions of s.40A(3) and r.6DD that they are intended to regulate the business transactions and to prevent the use of unaccounted money or reduce the chances to use black money for business transactions." 5.3.3 This is very crucial factor in this regard for which the assessee could not establish that Rule 6DD clearly applicable to him. It is also a fact that the amounts assessee tried to explain through the cash payments/transfers, are mainly related to the main contract executed and apparently there is no such explanation on the amounts involved in back to back contracts, which are running in to hundreds of crores of rupees. The amounts of back to back contracts are quantified at Rs.273.62 cr. for A.Y.2009-10, Rs.638.90 cr. for A.Y.2010-11, Rs.356.94 cr. for A.Y.2011-12 and Rs.74.51 Cr. for A.Y.2012-13. There is no such explanation for the amounts involved in back to back contracts, where the provisions of Sec.40A(3) are equally applicable. Further, it is also a fact that all the amounts that are shown as expenses are related to main contracts, with major expenses such as labour charges were paid in only in cash, at work sites. However, there would be element of cost for materials, services, which need not be paid at work sites and in cash. All these factors easily prove that the theory of incurring every expenses in cash is not correct and this only prove that this method adopted by the assessee/appellant only generating unaccounted income/black money, in the process. This fact further prove that the books of account that tried to be relied upon by the assessee to explain these expenses and the income offered through return of income are held to be not reliable and deemed to have been rejected. 5.4 Quantification of disallowance u/s.40A(3), as worked out by the AO was based on the chart prepared for the amounts of cash withdrawn bank accounts for A.Y.2010-11, 2011-12, 2012-13, which has been worked out to Rs.4518 lakhs, as reduced by cash re- deposited in bank account to the extent of Rs.190 lakhs which left a

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balance of Rs.73.28 lakhs for spending/expenses out of which the amount of Rs.28.01 crores representing labour charges. The same is indicated by a chart as under: The analysis of the transfer of cash and their utilization asst. year- wise are as under: (Amounts in lakhs) Name of the Bank Asst. Year 2010-11 2011-12 2012-13 2012-13 Total Andhra Bank, Chanda 370 1570 1004 0 2944 Nagar Other Banks 110 0 110 ICICI Bank, Kohima 696 696 Canara Bank, Meronkong 768 768 370 1570 1114 1464 4518 Less: Cash Deposits 185 5 0 0 190

Utilization Asst. Year 2010-11 2011-12 2012-13 2012-13 Total Deposit 0 0 0 100 100 Advance/Creditors 105 415 110 367 996 Staff Advance 58 41 0 41 140 Labour Charges 0 984 1004 813 2801 Other than Labour Charges 22 126 140 288 185 1565 1114 1461 4325 As could be seen from the chart, the amount of Rs.28.01 crores represent the labour charges paid in cash for two years, with Rs.10.00 cr. for A.Y.2011-12 and Rs.18.01 cr. during A.Y.2012-13. The AO applied the provisions of Sec.40A(3) and disallowed the amounts for the two respective years holding that the expenses were not explained and without bringing the reasons on record, Rule 6DD, cannot be applied in the case of the appellant. Hence, the disallowance made u/s.40A(3) by the AO. However, the fact remains that based on the facts of the case books are deemed to be unreliable, as such the disallowance could not have been made u/s.40A(3) and such disallowance could not be made, without specifying the amounts paid in cash. This proposition is held by Judicial decisions, as relied on by the assessee. Accordingly, it is held that the disallowance could not have been made by the AO as such the disallowance of Rs. 4.01 cr. made separately, as per provisions of Sec.40A(3), are held to be unsustainable. The appellant gets part relief on this aspect. 5.5 It may be further relevant to refer to the disclosures made u/s. 132(4), during the course of the search proceedings, where an amount of Rs.10.00 crores was offered as additional income for A.Y.2011-12 and Rs.14.00 crores for A.Y.2012-13, as the assessee could not explain the reasons for withdrawal of entire contract

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receipts in cash and such amounts could not be established to be the actual expenses relatable to the business. Though it is fact that disclosures made without invalid material/evidence, may lead to unrealistic situation, there being certain incriminating information established and accepted by the assessee, the disclosures, in this case were proved to be based on specific information/tax evasive methods adopted by the assessee. Quantification of extortion monies paid and the non-maintenance of books/vouchers was such information, formed the basis for undisclosed income admitted and also supported the disclosures made voluntarily by the assessee. There were no material changes subsequent to the event of search proceedings, to enable the assessee to retract the disclosures made, voluntarily. Further, the appellant company along with Mr.MML Narsimham, have filed an affidavit signed on 28-05-2012 where in the amounts of disclosures made vide sworn statement from Mr.MML Narsimham on 17-05-2012, were reiterated and reconfirmed. The relevant portion of the affidavit runs as under: "Further in my individual hand I offer additional income of Rs.2 crore representing investments in Gold/Jewellery/and silver articles for Rs.1 crore and for other investments an amount of Rs.1 crore the details of income and such investments shall be submitted separately. Thus the total additional income admitted for 2011-12 and 2012-13 is Rs.26 crore in the hands of the Company and my individual hands." 5.4.1 Having accepted and confirmed the disclosures at two different times, on the same set of facts that to reconfirmed through affidavit, there was no reasons for the assessee too retract the same and there Is no material change between the date of search and furnishing return of income, for doing so. In this regard, It may be relevant to mention that neither the affidavit nor the declaration was Withdrawn, In Writing, except the expression through which the incomes disclosed u/s.132(4) were not admitted in return of income. In this Context, It may be relevant to refer to the judicial decisions on the issue of the validity and reliability of an affidavit. In it's judgment, in the case of Sri Krishna Vs. err, Hon'ble High Court of Allahabad, held that "It is neither a rule of prudence nor a rule of law that the statements made in an affidavit which remains uncontroverted, must invariably be accepted as true and reliable. Ordinarily, in the absence of denial, the statements may be accepted as true but if there are circumstances which Suggest that the statements on affidavit should not be accepted as true, the absence of denial by the other side, would not by itself be sufficient to Clothe the statements on affidavit 'ith truthfulness and reliability. "

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5.4.2 Reverting to the facts of the case, the assessee While, explaining the reasons for making the disclosure and confirming the amounts of disclosure in affidavit dtd.28-05-2012, could not be altered, with no change in facts. As such the declarations made were held to be not controverted with reasonable explanation or the change in evidence or facts. 5.5 In this context, it is also relevant to refer to the submission of the assessee (at para 5), where in it was stated that the profit before depreciation in respect of works executed both direct and sub- contract is at 17.26% and net profit is about 7.12% and in respect of back to back contract the profit is at 0.84%, since there is only commission in it. However, the fact remains that what assessee claims of net profit of 7.12% on overall contracts is factually incorrect and the average profits of main contract is only 5.10%, where as on sub-contracts it is at 2.02 and aggregate average net profit on of all (gross) receipts including receipts of back to back contracts, is only 0.84%, where the profits shown by the assessee is NIL, as could be made out from the table given by the assessee itself. Considering the fact that business is no charity and the assessee is also expected not to do charity to the principals/main contractors by accommodating them in back to back contracts. The total contracts executed by the assessee on back to back basis has been put at as high as Rs.356.94 crores for A.Y.2011-12 itself and even if 3% of such amounts are considered as profits, the undisclosed income of Rs.10.00 crores made by the assessee for the year, is easily explainable. Thus, based on the facts of the case for all the reasons that are brought on record and discussed, it is reasonable to hold that the explanation of the assessee to explain the expenses in cash with help of Rule 6DD is not well established and the disclosure made u/s.132( 4) is not retracted With valid grounds and with the disclosed monies confirmed through affidavit, the amounts of Rs.10,00,00,000/- as admitted as undisclosed income during the course of search proceedings, is held to be established, which means the unexplained incomes are not explained through books. Hence, the addition of Rs.10,00,00,000/- made in assessment order is held to be justified and confirmed. Thus, the grounds related to this issue are treated as Dismissed”.

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Section 40A(3) business expenditure disallowance paid at various project sites in cash mode. We make it clear that neither of the assessment orders before us has made any un- disclosed income addition despite the fact that there has been a long discussion on identical lines to this effect. Learned CIT- DR could hardly rebut the fact that Section 40A(1) itself makes it clear that this statutory provision carries overriding effect on all other provisions of the Act since containing non-obstante clause i.e. “this section shall effect notwithstanding anything to the contrary contained in any other provision of this Act”. Hon'ble apex court’s landmark decision in Shri Sajjan Mills Ltd., Vs. CIT (1985) [156 ITR 585] (SC) has settled the law long back that Section 40A is an overriding provision in very terms. 6. Mr.Sai next vehemently argued during the course of hearing that the assessee’s search statement through its authorised person had duly admitted un-disclosed income (supra). He quoted (2014) 362 ITR 13 (AP) Kernex Micro Systems (India) Ltd., Vs. DCIT, that such an addition based on law search statement ought to be confirmed only. He next cited A.K.K. Nambiar Vs. Union of India (1970) AIR 652 (SC) that the assessee had also filed an affidavit with due verification before the learned lower authorities during the course of search regarding the un-disclosed income in issue.

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incurred in cash. There is no rebuttal to the CIT(A)’s clinching findings that the assessee’s books are neither reliable nor do they indicate the specific violation of the impugned statutory provision that the impugned cash payments had exceeded the specified limit; payee-wise, as the case may be. We thus invoke stricter interpretation of the impugned disallowance provision in Section 40A(3) that it is attracted only when an assessee incurs “any expenditure in respect of which a payment of aggregate of payments ……..in a day”. We also quote hon'ble apex court’s recent landmark decision in Commissioner of Customs Vs. Dilip Kumar (2018) 9 SCC 1 (FB)(SC) that provisions in the Act have to be strictly construed only. We accordingly uphold the CIT(A)’s findings deleting Section 40A(3) disallowance.

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jurisdiction co-terminus with the Assessing Officer. Their lordships make it clear that Section 251(1) enhancement jurisdiction does not extend to a new source of income. We therefore accept assessee’s arguments and reject Revenue’s stand regarding the alleged undisclosed income addition which was never added in both assessment orders since the Assessing Officer had merely invoked Section 40A(3) disallowance. We therefore accept the assessee’s pleadings to this limited extent in its appeals ITA Nos.730 & 731/Hyd/2016. The Revenue’s cross-objections Nos.8 & 9/Hyd/2021 seeking restoration of Section 40A(3) disallowances fail in above terms. No other substantive ground; whether additional or main, has been pressed before us in light of our preceding discussion.

Order pronounced in the open court on 29th March, 2022

Sd/- Sd/- (LAXMI PRASAD SAHU) (S.S.GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Hyderabad, Dated: 29-03-2022 TNMM

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Copy to : 1.M/s.Ratna Infrastructure Projects Pvt. Ltd, C/o.Mohd.Afzal, Advocate, 11-5-465, Flat No.402, Sherson's Residency, Criminal Court Road, Red Hills, Hyderabad. 2.The Deputy Commissioner of Income Tax, Central Circle- 3, Hyderabad. 3.The Asst.Commissioner of Income Tax, Circle-3(1), Hyderabad. 4.CIT(Appeals)-12, Hyderabad. 5.Pr.CIT(Central)-Hyderabad. 6 6.D.R. ITAT, Hyderabad. 7.Guard File.