RAKESH BHOJANI,SIYAGANJ INDORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE -4(1), INDORE, CGO COMPLEX
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Income Tax Appellate Tribunal, INDORE BENCH, INDORE
Before: SHRI B.M. BIYANI & SHRI UDAYAN DAS GUPTA
आदेश/ O R D E R
Per B.M. Biyani, A.M.:
Feeling aggrieved by order of first appeal dated 05.11.2024 passed by learned Commissioner of Income-Tax (Appeals)-NFAC, Delhi [“CIT(A)”] which in turn arises out of assessment-order dated 07.12.2019 passed by learned DCIT/ACIT-4(1), Indore [“AO”] u/s 143(3) of Income-tax Act, 1961 [“the Act”] for Assessment-Year [“AY”] 2017-18, the assessee has filed this appeal on various grounds as mentioned in Form No. 36 (Appeal Memo).
The background facts leading to present appeal are such that the assessee-individual is engaged in the business of trading of PVC/CPVC/
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Rakesh Bhojani ITA No. 811/Ind/2024 – AY 2017-18 CI/Cement pipes, fittings and valves in the name and style of M/s Suhag
Syndicate Indore. For AY 2017-18, the assessee filed return declaring a total
income of Rs. 37,75,400/-. The case of assessee was selected for scrutiny
assessment and notices u/s 143(2)/142(1) were issued. Finally, the AO
completed assessment vide order dated 07.12.2019 u/s 143(3) after making
twin additions, namely (i) addition of Rs. 40,00,000/- u/s 68 on account of
cash deposited in Bank A/c during demonetization period, and (ii) addition
of Rs. 2,50,37,941/- u/s 68 on account of unexplained unsecured loans.
Aggrieved, the assessee carried matter in first-appeal before CIT(A) but did
not get any success. Now, the assessee has come in next appeal before us.
Although the assessee has raised as many as four grounds with
several sub-grounds in Form No. 36 (Appeal Memo), the Ld. AR for assessee
made pleadings challenging the twin additions made by AO, narrated above,
on merit and the Ld. DR for revenue made submissions in reply to same. We
accordingly proceed to adjudicate the issued pleaded before us.
Addition of Rs. 40,00,000/- u/s 68 on account of cash deposited in
Bank A/c during demonetization period:
Ld. AR for assessee carried us to Para 6 of assessment-order to show
that the AO has made impugned addition with the reasoning that the
assessee explained made cash-deposit of Rs. 40,00,000/- in bank account
during demonetization period but failed to file any reply when asked to
produce sale-bills/confirmation from debtors. Ld. AR submitted that the
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Rakesh Bhojani ITA No. 811/Ind/2024 – AY 2017-18 assessee actually deposited Rs. 28,00,000/- in Current A/c and Rs.
40,00,000/- in SB A/c during demonetization period and the assessee’s
reply dated 25.11.2019 before AO (copy at Page 18 of Paper-Book-I)
explaining the “sale of business/receipt from debtors” as source was qua the
deposit of Rs. 28,00,000/- and not qua the deposit of Rs. 40,00,000/-. Ld.
AR submitted that the AO has not made any addition qua the deposit of Rs.
28,00,000/-. So far as the deposit of Rs. 40,00,000/- in SB A/c for which
the AO has made addition is concerned, the AO has wrongly or mistakenly
tagged it with the sale of business/receipt from debtors. In fact, the assessee
declared a cash holding of Rs. 40,00,000/- in “The Income Declaration
Scheme, 2016” (“IDS”) and paid applicable taxes under IDS on 29.09.2016
much prior to the declaration of demonetization; Copy of assessee’s
declaration under IDS and the certificate issued by Income-tax Department
in Form No. 4 are filed at Pages 254-255 of Paper-Book-I. This cash held by
assessee and declared in IDS was the source of deposit of Rs. 40,00,000/- in
SB A/c during demonetization. Ld. AR pointed out that the assessee filed
copy of declaration to CIT(A) during first-appeal as an evidence under Rule
46A of Income-tax Rules, 1962 but the CIT(A) has, vide Para 4.3 of his order,
rejected the same as additional evidence. Further, in next Para 4.3.1 of
order, the CIT(A) went ahead to make a wrong/invalid observation that the
assessee was not permitted to declare undisclosed income of past in current
year i.e. AY 2017-18.
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Rakesh Bhojani ITA No. 811/Ind/2024 – AY 2017-18 5. Ld. DR for revenue relied upon orders of lower-authorities and left the
issue for the wisdom of Bench.
We have considered rival submissions of both sides and perused the
documents held on record including the orders of lower authorities. At first,
we find that the assessee’s explanation as to source from “sale of
business/receipts from debtors” was qua the deposit of Rs. 28,00,000/- in
Current A/c and the AO has accepted this explanation and that is why not
made any addition in regard to deposit of Rs. 28,00,000/-. The said
explanation given by assessee was, however, not for another deposit of Rs.
40,00,000/- made by assessee in SB A/c. In so far as the source of deposit
of Rs. 40,00,000/- is concerned, the assessee has declared a cash holding of
Rs. 40,00,000/- in IDS and the department has issued a certificate in Form
No. 4 which is placed in Paper-Book. The Column No. 5 of From No. 4
issued by department gives details of declaration and certifies description of
asset as “CASH IN HAND”. Thus, the assessee’s cash holding is very much
accepted by department. We note that the CIT(A) has rejected assessee’s
documents of IDS terming the same as additional evidence but those
documents are statutory documents forming part of record of Income-tax
Department itself and the CIT(A) is neither justified in rejecting the same in
Para 4.3 of order nor making a wrong/invalid conclusion in Para 4.3.1 of his
order as discussed above when the assessee has declared cash of Rs.
40,00,000/- under IDS and paid tax thereon and the same has been
accepted by department. Ld. DR for revenue, though dutifully relied upon
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Rakesh Bhojani ITA No. 811/Ind/2024 – AY 2017-18 orders of lower-authorities, is not able to controvert the submission of Ld.
AR. Being so, we agree that the source of cash deposit of Rs. 40,00,000/-
stands explained by assessee from cash declared in IDS and hence the
addition made by AO is not sustainable. We direct the AO to delete the
addition. This issue of assessee is accepted.
Addition of Rs. 2,50,37,941/- u/s 68 on account of unexplained
unsecured loans:
The AO has made this addition in Para 7 of assessment-order. The AO
has made a tabular list of 26 lenders with a noting that the assessee has
taken loans from those 26 lenders during the year. In the tabular list, the
AO has also mentioned amount of loan taken from each lender and finally
totalled the same to Rs. 2,50,37,941/-. The AO has noted that the assessee
was asked to submit Bank Statements, ITRs and A/c Confirmations of
lenders but failed to file the same. With these observations, the AO has
treated the loans as unexplained credit u/s 68 and made addition.
During first-appeal, the CIT(A) has passed following order upholding
the addition:
“5.3 I have gone through the grounds of appeal, submissions and the assessment order. As the assessee had not offered any explanation with regard to credit-worthiness and genuineness of transactions with the parties, the same remained un-established. It was submitted by the appellant that out of 25 loans, 12 loans are old and the remaining 13 are partly old balances with fresh deposits or totally fresh deposits. The AO held that giving multiple opportunities, the assessee had failed to discharge onus and also failed to establish the identity, genuineness and creditworthiness of the above unsecured loans taken. It appears the non-adherence to notices is deliberate. Section 114(g) of Indian Evidence Act, 1872 lays a presumption
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Rakesh Bhojani ITA No. 811/Ind/2024 – AY 2017-18 that evidence which could be and is not produced when, if produced, be unfavourable to the person who withholds it. Sometimes, if information provided would more damageable to the assessee, at that time, the appellant will not provide the information called for. In case the AO has not satisfied with the information provided, there is a possibility to issue notice u/s 133(6) to those parties to obtain the information, or possibility of issue of commission to JAO/suggest their cases to the concerned Jurisdictional Assessing officer, which the appellant does not want. Therefore, during the assessment proceedings, the appellant was silent on this issue. 5.3.1 The Hon'ble Supreme Court in the decision of PCIT vs M/s. NRA Iron and Steel Pvt. Ltd., dated 5th March, 2019 (103 taxmann.com 48) held as follows:- Identity, Creditworthiness and Genuineness have to be proved by the appellant to the satisfaction of the Assessing Officer. The mere mention of the income tax file number of an investor was not sufficient to discharge the onus u/s 68 of the Income Tax Act.
The investor companies which had filed income tax returns with meager or nil income had to explain how they had invested huge sums of money in the appellant company. Hence, the onus to establish the creditworthiness of the investor companies was not discharged and the entire transaction seem bogus and lacked credibility. The practice of conversion of unaccounted money though the cloak of share capital / premium must be subjected to careful scrutiny. This would be particularly so in the case of private placement of shares where a higher onus is required to be placed on the assessee since the information is within the personal knowledge of the assessee. The assessee is under a legal obligation to prove the receipt of share capital / premium to the satisfaction of the Assessing Officer, failure of which, would justify addition of the said amount to the income of the assessee. 5.3.2 It is a fact that the appellant company has not established Identity, Creditworthiness and Genuineness as per the rigors of Section 68 to the satisfaction of the Assessing Officer and subsequently also in the appellate proceedings. The mere mention the financials of the investor was not sufficient to discharge the onus u/s 68 of the Income Tax Act. Hence, the onus to establish the creditworthiness of the investor companies was not discharged and the entire transaction was bogus and lacked credibility. The practice of conversion of unaccounted money though unsecured loans has been duly noticed. In the case of unsecured loans onus is placed on the appellant company since the information is within its knowledge. The appellant is under a legal obligation to prove the receipt of unsecured loan to the satisfaction of the Assessing Officer and failure of this justifies addition of the said amount to the income of the appellant company. On the other hand, from the facts and surrounding circumstances, human conduct,
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Rakesh Bhojani ITA No. 811/Ind/2024 – AY 2017-18 preponderance of probabilities etc., the Assessing Officer in the assessment has clearly established that the impugned transactions were without any basis and clearly were arranged or manipulated transactions. 5.3.3 Respectfully following the judgment of the Hon'ble Supreme Court in the case of M/s. NRA Iron and Steel Private Limited and also after examining various facts and circumstances of the appellant's case is, it is held that the Assessing Officer has aptly held that the appellant failed in discharging its onus of proving the identity, genuineness of the transaction and creditworthiness of the investor-companies. In view of the facts of the case mentioned above and the judicial pronouncements discussed above, I agree with the AO that these are unexplained cash credits in the books of the appellant and the addition of Rs. 2,50,37,941/- is confirmed. Ground No. 2 and 3 of the appeal are dismissed.” 9. During hearing before us, Ld. AR referred various Pages in the Paper-
Books-I and II and the orders of lower-authorities. He submitted that the AO
has made impugned addition by alleging assessee’s failure in submitting
Bank Statements, ITRs and A/c Confirmations of lenders. But the factual
position is totally different. He submitted that during assessment-
proceeding when the AO queried assessee to explain loans, the assessee
filed a reply-letter dated 23.11.2019 (Copy at Pages 15-16 of Paper-Book-I)
to AO informing that the assessee and accountant were out of station for a
week and that they were trying to prepare all required details. Thereafter, on
25.11.2019, the assessee filed another reply-letter and vide point no. 3 of
same (Copy filed at Pages 17-19 of Paper-Book-I), the assessee filed part of
the evidences; supplied addresses of all lenders and requested the AO to get
the loans confirmed from respective lenders as they were taking time to
confirm their dues to their own reasons. The assessee also submitted that
all loans were raised through a/c payee cheques and were genuine. The
reply so filed by assessee is re-produced below for an immediate reference:
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Rakesh Bhojani ITA No. 811/Ind/2024 – AY 2017-18 “3. The assessee has raised fresh loans during the year plus their old loans existing as on 01/04/2016. Copy of accounts are attached. The assessee has raised fresh loans during the year from outsiders whose statements showing their name, PAN, address and amount are enclosed with their copy of accounts. We request to Your Honour to get these loans confirm from the respective creditors whose address has been given in the statement of loans (details of unsecured loan chart) as they are taking time to confirm due to their own reason. All the loans were raised through account payee cheques and these are genuine. Two of loans are from NBFC named Bajaj Finserv ltd. and Magma Fin Corp Ltd. reflected in the loan statement.” Ld. AR submitted that the AO, however, passed assessment-order on
07.12.2019 alleging assessee’s failure whereas the assessee made all since
efforts to provide details/documents to AO and even provided PAN data and
addresses of lenders to AO with a request to get confirmation directly from
lenders.
Be that as it may, Ld. AR went ahead to submit, the AO has made a
list of 26 lenders with amounts of loans against respective lenders and
alleged that the assessee has taken a total loan of Rs. 2,50,37,941/- during
the year but this observation is factually wrong because out of 26 lenders
listed by AO, 1 lender named ‘Manisha Kalra HUF’ was doubly mentioned,
loans from 12 lenders were purely old brought forward from earlier year and
the remaining 13 lenders were those from whom loans were taken during
the year. The assessee took new loans aggregating to Rs. 1,04,31,897/- from
those 13 lenders. Ld. AR submitted that during first-appeal, the assessee
filed a detailed submission to CIT(A) which is re-produced by CIT(A) in his
order [Para 5.2 / Pages 6-10 of CIT(A)’s order]. The complete tabular charts
of 26 lenders considered by AO with the details of only 13 lenders from
whom new loans of Rs. 1,04,31,897/- were taken are mentioned therein
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Rakesh Bhojani ITA No. 811/Ind/2024 – AY 2017-18 [Page 9 of CIT(A)’s order]. Then, Ld. AR pointed out an important fact that
the assessee filed all supporting evidences [including the part-evidences
already filed to AO during assessment-proceeding] to CIT(A) under an
application in terms of Rule 46A of Income-tax Rules, 1962 [copy of
assessee’s application is filed at Page 29-30 of Paper-Book-I] and acting
thereupon, the CIT(A) sought remand-report from AO pursuant to which the
AO conducted remand-proceeding and issued letter dated 07.05.2024
bearing DIN & Letter No.: ITBA/COM/F/17/2024-25/1064701273(1) to
assessee. In response to this letter of AO, the assessee submitted a detailed
reply-letter dated 10.05.2024 to AO with all those supporting evidences
marking them as “Annexures D-1 & D-2” which proved the identity,
creditworthiness and genuineness of all new loans taken during the year.
This reply-letter to AO was submitted by assessee’s regular counsels CA
Vijay Bansal and CA Nisha Lahoti., the same is placed at Pages 107-113 of
Paper-Book-I which is scanned and re-produced below for an immediate
reference:
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However, Ld. AR submitted, the CIT(A) has not made any comment in
his order qua the remand-proceedings conducted by him. CA Vijay Bansal
was present in the Court and immediately joined the Ld. AR, confirming that
the AO conducted remand-proceeding and afterwards did not file any
remand-report to CIT(A). Thus, Ld. AR contended, the AO was not having
any objection against the documents submitted by assessee which
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Rakesh Bhojani ITA No. 811/Ind/2024 – AY 2017-18 sufficiently established the identity and creditworthiness of lenders and
genuineness of loans taken.
Having explained thus, Ld. AR submitted that it is an accepted
proposition that no addition can be made in respect of opening balances of
loans. So far as new loans of Rs. 1,04,31,897/- taken during the year are
concerned, the assessee has taken two loans of Rs. 15,31,897/- (+) Rs.
11,00,000/- = Rs. 26,31,897/- from Bajaj Finance Company which is a
renowned NBFC and there cannot be any doubt regarding identity,
creditworthiness and genuineness of loan taken from this NBFC. Further,
the assessee has filed all required documents of new loans to AO/CIT(A),
copies whereof are also filed in Paper-Book-II, the Index of Paper-Book-II
gives a list of these documents as under:
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Ld. AR then carried us to the above documents in an attempt to show
that the assessee has taken all loans through a/c payee cheques; interest
has been paid to lenders; the TDS had been deducted out of interest
payment and remitted to Income-tax Department; the ITRs/PAN-datas of
lenders are filed by asesesee; there are no cash deposits in the accounts of
lenders prior to giving loans to assessee or if there was a cash deposit, the
same was proved by declaration of cash-in-hand by the concerned lender in
“IDS”. Thus, there is no adverse feature in any of the loans which could
raise even slightest doubt qua the identity and creditworthiness of lender or
the genuineness of loan taken. Ld. AR submitted that the AO has not given
any adverse report to the CIT(A) even after conducting remand-proceeding.
Hence, the addition made by AO must be deleted.
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Rakesh Bhojani ITA No. 811/Ind/2024 – AY 2017-18 14. Replying to this, Ld. DR for revenue firstly agreed to the claim of
assessee that the details of opening balances of loans was available before
CIT(A) and that no addition can be made in current year on account of
opening balances. So far new loans of Rs. 1,04,31,897/- taken during the
year are concerned, Ld. DR was fair enough in accepting that the loans of Rs.
15,31,897/- and Rs. 11,00,000/- = Rs. 26,31,897/- taken from Bajaj
Finance Co. Ltd. does not have any room for doubting identity,
creditworthiness and genuineness. For remaining new loans, Ld. DR though
dutifully supported the orders of lower-authorities yet asserted that from the
documents held on record, there appears no adverse feature. Ld. DR,
however, submitted that he has no clue from the order of CIT(A) to make
submission regarding remand-proceeding.
We have considered submissions of both sides and carefully perused
the documents held in Paper-Books and the orders of lower-authorities. The
assessee is aggrieved by an addition of Rs. 2,50,37,941/- made by AO u/s
68 on account of unexplained loans. In the assessment-order, the AO has
made a list of 26 lenders with the amounts of loans alleged to have been
taken by assessee during the year. The AO has made impugned addition by
stating that the assessee did not file documents of those 26 lenders. Before
us, the assessee has filed copies of letters submitted by him to AO according
to which the assessee filed part-evidences of loans while filing addresses and
PAN data of all lenders. It is also on record that the assessee requested the
AO to get confirmations directly from the lenders because the lenders were
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Rakesh Bhojani ITA No. 811/Ind/2024 – AY 2017-18 taking time. Thereafter, during first appellate proceeding, the assessee filed
an application to CIT(A) under Rule 46A of Income-tax Rules, 1962 with
required evidences. Then, the AO conducted remand-proceeding at the
behest of CIT(A) and issued letter dated 07.05.2024 bearing DIN & Letter No.:
ITBA/COM/F/17/2024-25/1064701273(1) to assessee. In response, the
assessee submitted a detailed reply-letter dated 10.05.2024 to AO with all
required evidences marked as “Annexures D-1 & D-2” to establish the
identity, creditworthiness and genuineness, copy of assessee’s letter is
already re-produced in foregoing para. Although the CIT(A) has not
mentioned anything in his order about the remand-proceeding, the
assessee’s regular counsel CA Vijay Bansal who attended remand-
proceeding and filed the abovesaid reply letter dated 10.05.2024 to AO has
confirmed in open court that the AO conducted remand-proceeding and
afterwards did not submit any report to CIT(A). These facts are also reflected
in the letter dated 21.10.2024 filed by assessee to CIT(A), copy at Page 114
of Paper-Book-I, as under:
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Rakesh Bhojani ITA No. 811/Ind/2024 – AY 2017-18
The above scanned letter is not readable. Therefore, the submission made
therein by assessee to CIT(A) is re-produced below:
“Hon’ble Sir, as submitted in our previous reply a notice from the Ld. Jurisdictional Assessing Officer (JAO) – Ld. ACIT-4(1), Indore on 07.05.2024 was served to appellant with reference to remand report proceedings. This notice was duly complied by the assessee by submitting all relevant documents. The lenders are mostly the family members of the assessee. It has been informed by them that even they have duly complied with the notices received from the Ld. JAO by submitting all the relevant documentary evidences. Your appellant request that in case any adverse remand report is issued by JAO then appellant may be provided reasonable opportunity to submit rejoinder to that report. As submitted earlier, the AO is pressing very high for recovery of the demand. Hence, it is once again humbly submitted that the appeal may please be allowed as the assessee should not be punished or held liable for the mistake of the Tax Auditors in the reporting of details related to 269SS/T in Form 3CD. All the relevant documents have already been submitted in response to our grounds of appeal. Thanking you. Yours Truly.
Thus, in the above letter, the assessee has submitted to CIT(A) about the
remand-proceeding conducted by AO. So far as the addition of Rs.
2,50,37,941/- made by AO qua the alleged loans having been taken during
the year from 26 lenders is concerned, the assessee has sufficiently proved
by documents that it has taken new loans of Rs. 1,04,31,897/- from 13
lenders only and the rest were opening balances brought forward from
earlier year. In so far such opening balances are concerned, it is an accepted
view that no addition can be made u/s 68 in current year and this view is
also asserted by Ld. DR for revenue. Hence, we straightaway reach to a
conclusion that no addition can be made in respect of opening balances.
Now, turning to the new loans of Rs. 1,04,31,897/- taken during the year,
there are loans of Rs. 26,31,897/- taken from Bajaj Finance Company, a
renowned NBFC, for which there can hardly be any dispute qua the identity,
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Rakesh Bhojani ITA No. 811/Ind/2024 – AY 2017-18 creditworthiness and genuineness. Thus, there remains a net loan of Rs.
78,00,000/- taken from other lenders [Rs. 1,04,31,897 (-) Rs. 26,31,897].
The assessee has filed enough documents qua all new loans and as stated
earlier, the AO has conducted remand-proceeding and has not made any
adverse reporting to CIT(A) by way of filing remand-report. This shows that
the AO was very much satisfied with the documents submitted by assessee
and did not find any fallacy therein worth reporting to CIT(A). Even before us,
Ld. AR for assessee has analysed those documents held in Paper-Book and
successfully shown that the assessee has taken all loans through a/c payee
cheques; interest has been paid to lenders; the TDS had been deducted out
of interest payments and remitted to Income-tax Department; the ITRs/PAN-
datas of lenders are filed by asesesee; there are no cash deposits in the
accounts of lenders prior to giving loans to assessee or if there was a cash
deposit, the same was proved by declaration of cash-in-hand by the
concerned lender in “IDS”. These documents were deliberated during
hearing and Ld. DR for revenue could not point out any adverse feature.
Thus, considering the fact that neither the AO has reported any adverse
feature to CIT(A) despite having conducted remand-proceeding nor the
revenue is now able to demonstrate any adverse feature in any of the new
loans taken by assessee, no addition can be made even for the new loans of
Rs. 1,04,31,897/- taken during the year. This brings us to conclude that the
entire addition of Rs. 2,50,37,941/- made by AO is not sustainable.
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Rakesh Bhojani ITA No. 811/Ind/2024 – AY 2017-18 Consequently, we direct the AO to delete this addition also. The issue of
assessee is accepted.
Resultantly, this appeal is allowed.
Order pronounced by putting on notice board as per Rule 34 of ITAT Rules, 1963 on 27/02/2025
Sd/- Sd/-
(UDAYAN DAS GUPTA) (B.M. BIYANI) JUDICIAL MEMBER ACCOUNTANT MEMBER
Indore
िदनांक/Dated : 27/02/2025
Patel/Sr. PS Copies to: (1) The appellant (2) The respondent (3) CIT (4) CIT(A) (5) Departmental Representative (6) Guard File By order UE COPY Sr. Private Secretary Income Tax Appellate Tribunal Indore Bench, Indore
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