DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE vs. ARYAN ARCADE LIMITED , RAJKOT
What did the Tribunal hold?
The Tribunal held that the Ld. CIT(A) had erred in deleting the additions made by the AO. Regarding the addition of Rs.17,83,19,200/- (Issue 1), the Tribunal found that the seized pen drive data, corroborated by the statement of Shri Himanshu Raiyani and Shri Nikhil Patel, clearly indicated the maintenance of two sets of books – one accounted and one unaccounted. The 'MIRACLE' software contained date-wise entries of unaccounted cash receipts. The Tribunal noted that the AO had relied on this digital data which was admitted by the stakeholders. Therefore, the deletion by the Ld. CIT(A) was set aside, and the AO's addition was restored. On the issue of the profit rate (Issue 2), the Tribunal found that the Ld. CIT(A) had adopted an arbitrary rate of 15% without proper appreciation of the facts. Given the clear evidence of unaccounted transactions, the Tribunal restored this issue to the Ld. CIT(A) to re-examine and decide the profit rate on the unaccounted receipts, considering the evidence on record. Regarding the timing of income recognition (Issue 3), the Tribunal held that the Ld. CIT(A) erred in applying the accrual basis. The Tribunal reasoned that when unaccounted cash receipts are found, the income should be taxed in the year of receipt, as it represents actual cash inflow. The deletion by the Ld. CIT(A) was set aside, and the AO's method of taxing on receipt basis was restored. Concerning the deletion of Rs.2,83,20,000/- from sale of scrap (Issue 4), the Tribunal found that the Ld. CIT(A) had deleted this without appreciating the seized documents which clearly mentioned the assessee receiving this sum towards the sale of demolition scrap (IMLA). The AO had relied on the P&L account from the seized soft data. The Tribunal restored this issue to the Ld. CIT(A) for fresh adjudication based on the evidence. The Tribunal did not expressly leave any issue undecided.
What were the facts?
The Income Tax Appellate Tribunal (ITAT), Rajkot Bench, heard a consolidated batch of five appeals filed by the Revenue. These appeals pertained to Assessment Years (AYs) 2014-15 and 2016-17 to 2019-20. The appeals involved two assessees: Shri Gopal Bhupendra Chudasama (for AY 2014-15) and M/s Aryan Arcade Ltd. (for AYs 2016-17 to 2019-20). The Revenue challenged orders passed by the learned Commissioner of Income-Tax (Appeals) [Ld. CIT(A)] which had deleted additions made by the Assessing Officer (AO) under section 143(3)/153A r.w.s. 143(3) of the Income Tax Act, 1961. The core of the dispute arose from a search operation conducted on September 26, 2018, which led to the seizure of a pen drive containing unaccounted transactions related to the assessee's real estate project, 'Om Decora Square 9'.
What were the issues?
The Tribunal had to decide the following questions: 1. Whether, on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition of Rs.17,83,19,200/- as business income, considering the seized pen drive containing unaccounted transactions maintained in 'MIRACLE' software and Excel files. 2. Whether the Ld. CIT(A) erred in adopting a real estate business income rate of 15% of unaccounted cash on-money receipts instead of 80%. 3. Whether the Ld. CIT(A) erred in determining business income on an accrual basis (year of transfer of title and possession) instead of the year of receipt of on-money from real estate business. 4. Whether the Ld. CIT(A) erred in deleting the addition of Rs.2,83,20,000/- representing income from the sale of scrap (IMLA) and other miscellaneous income. Assessee's Contentions (implied from Revenue's grounds and Tribunal's discussion): The Ld. CIT(A) correctly deleted the additions made by the AO. The seized data, while indicating unaccounted transactions, was not definitively linked to the assessee's income in the manner calculated by the AO. The profit margin applied by the Ld. CIT(A) was reasonable, and income should be taxed on accrual basis. The sale of scrap was correctly treated as miscellaneous income or not taxable. Revenue's Contentions: The Ld. CIT(A) erred in deleting the additions. The seized pen drive, containing key accounts of unaccounted transactions in 'MIRACLE' software and Excel files, formed a strong basis for the AO's additions. The AO correctly applied a higher profit margin (80%) to unaccounted receipts and taxed income on the year of receipt. The income from the sale of scrap was also wrongly deleted. The Ld. CIT(A) ignored crucial evidence, including admissions by key persons and seized documents detailing cash advances.
Which sections of the Income-tax Act were involved?
Section 143(3),Section 153A,Section 132,Section 143(1),Section 142(1),Section 132A
AI-generated summary — verify with the full judgment below
Cause title — parties, addresses and appearances
आदेश/Order PER BENCH: This is bunch of five appeals by the Revenue, pertaining to separate
assessment years, (AYs) i.e., 2014-15, 2016-17 to 2019-20 (assessment year- wise), all are directed against the separate orders passed by the Learned Commissioner of Income-Tax (Appeals)-11, Ahmedabad (for short ‘Ld. CIT(A)', which in turn arise, out of separate assessment orders passed by the Assessing Officer under section 143(3)/153A r.w.s. 143(3) of the Income Tax Act, 1961 (in short ‘the Act').
Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order.
In this group of five appeals, four appeals are pertaining to M/s Aryan Arcade Ltd., and one appeal in IT(SS)A No.14/RJT/2024 for A.Y 2014-15 pertaining to Shri Gopal B. Chudasama, individual, who is main director in M/s Aryan Arcade Limited. Since the issue involved in these appeals are interconnected and mix, therefore, we shall adjudicate these appeals together to avoid conflicting decisions.
First, we shall take the appeals pertaining to M/s Aryan Arcade Ltd, wherein Revenue have filed four appeals which are pertaining to assessment years (AYs) 2016-17, 2017-18, 2018-19 and 2019-20. The grounds of appeal raised by the revenue in these four appeals are similar and identical. Therefore, in order to adjudicate these appeals, we take "lead" case IT(SS)A No.63/RJT/2023 for assessment year (AY) 2016-17, wherein the grounds of appeal raised by Revenue are as follows: "(i) On the facts and in the circumstances of the case and in law, learned Commissioner (Appeals) erred in deleting the addition of Rs.17,83,19,200/-, as business income, ignoring Page 2 the facts that during the course of search proceedings, one pen drive has found and seized from the premise of Himanshu Raiyai (accountant of the assessee as well as group concerns of the DECORA group), which contained key accounts of unaccounted transactions of the entire project and entire accounts were maintained in software known as MIRACLE and also contained certain excel files whereby unaccounted transactions relevant to the assessee company were maintained, on which the AO has relied upon. (ii) On the facts and in the circumstances of the case and in law, the Ld.CIT(A) erred in adopting real estate business income @ 15% of unaccounted cash on-money receipts in place of @ 80% without appreciating the facts, evidences found and seized during the course of search and circumstances of the peculiar case. (iii) On the facts and in the circumstances of the case and in law, the ld.CIT(A) has erred in determining business income on account of receipts of on-money from the real estate business on accrual basis (i.e. in the year of transfer of title and possession of property) instead of year of receipts without appreciating the facts, evidences found and seized during the course of search and circumstances of the peculiar case. (iv) On the facts and in the circumstance of the case and in law, learned Commissioner (Appeals) erred in deleting the addition of Rs.2,83,20,000/- a income from sale of scrap and other miscellaneous income made by Assessing Officer, ignoring the facts that the entire Grand Central mall has been demolished and on the said land, construction of OM DECORA NINE SQUARE Building is coming up and the assessee received the above sum towards sales of IMLA (demolition scrap popularly known as IMLA in local parlance), which have been clearly found from relevant P&L A/c. from seized soft data contained in file OD. (v) On the facts and in the circumstances of the case and in law, learned Commissioner (Appeals) erred in ignoring the facts that, Shri Nikhil Patel (key promoter of the DECORA group and stakeholder in the assessee-company) had admitted that unaccounted transactions are maintained in separate software of MIRACLE and the same were maintained by his accountant Shri Himanshu Raiyani in pen drive that was seized during the course of search proceedings. The entries reflected in pen drive data are totally unaccounted transactions. (vi) On the facts and in the circumstances of the case and in law, learned Commissioner (Appeals) erred in ignoring the facts that during the course of search proceedings the bifurcation of page No.11,12,13 & 14 given in the seized documents, wherein it is clearly mentioned the names of the persons who had given advances in cash. These are on-money receipts which are not recorded in the regular books of accounts, on which AO has relied upon. (vii) On the facts and in the circumstances of the case and in law, the Ld. CIT(A) ought to have upheld the order of the AO. (viii) It is, therefore, prayed that the order of the Learned Commissioner(Appeals) be set aside and that of the AO be restored to the above extent.”
The relevant material facts, as culled out from the material on record, are as follows. The assessee filed its return of income u/s 139(1) on 24.03.2017 declaring total loss of Rs.21,15,440/-. Further, the loss claimed by the assessee was reduced to Nil vide order us/ 143(1) of the Act. A search and survey action by the name of “Operation Star Alliance” was carried out on the Page 3 builders and financier groups in and around Rajkot. During the course of search action u/s 132 of the Act, the search was also carried out at the premises of the assessee on 26.09.2018, therefore, proceedings u/s 153A was initiated in the case of assessee and notice u/s 153A was issued on 08.02.2019. In response to the notice issued, assessee filed its return of income on 23.09.2019 declaring therein total loss of Rs.21,15,440/-.
The notice u/s 129 was issued on 09.11.2020 and thereafter notices u/s 143(2) r.w.s. 142(1) issued on various dates. The assessee-company was incorporated on 01.04.2010. Om Decora Square 9 project is a commercial project developed by the assessee. This is a commercial project having two towers of 14 floors comprising 364 shops and offices and show rooms at ground to 2nd floor. Initially on the land on which this project came up, there was a mall known as Grand Central mall. This mall was demolished and the project Om Decora Square 9 was developed on the said land. Although this is a public limited company, however, the stake holding is limited to following four families only. a. Gopal Chudasama and family – 35% stake b. Chetan Rokad and family – 35% stake c. Nikhil Patel and family – 20% stake d. Kuldeep Rathore and family – 10% stake Along with the search on the assessee-company, the residential premises of Shri Himanshu Riyani was also covered under the search operation u/s 132A of the Act on 26.09.2018. During the course of search at the premises of Shri Himanshu Raiyani (accountant of the assessee as well as group concerns of the Decora group), one pen drive was found and seized which contained key accounts of unaccounted transactions of the entire project in a very systematic manner. The entire accounts were maintained in software known as Miracle. Further, the pen drive also contained certain excel files whereby unaccounted Page 4 transactions relevant to the assessee-company were mentioned. The digital data pertaining to assessee-company comprised of 2 types, viz: (i) excel file mentioning unaccounted investment by the stakeholders in the assessee- company and (ii) miracle software contained account of the assessee-company by the name “OD', thereby meaning Om Decora and GC meaning Gopal Chudasama. Shri Himanshu Raiyani during the course of search proceedings has accepted that the said pen drive contained unaccounted transactions. Shri Himanshu Raiyani, during the course of search proceedings averred that he carries out accounting work under the instruction of Shri Nikhil Patel. Further, the entire digital data was confronted with Shri Nikhil Patel (key promoter of the Decora group and stakeholder in the assessee-company) and he has accepted that the accounts maintained by Himanshu Raiyani in Mireacle software, belongs and pertain to the Decora and allied groups only. Therefore, the genuineness of the data ownership of the data and the transactions recorded therein, have been accepted to be belonging to the Decora group and others only including the assessee. In this regard the statement of Shri Nikhil Patel, is reproduced by the assessing officer on page number four of assessment order and Himanshu Rayani statement is reproduced on page number three of the assessment order.
The assessing officer noticed that the account of the assessee-company were scrupulously maintained in coded format named “OD', Shri Himanshu Raiyani in his statement recorded u/s 132(4) of the Act on 26.09.2018 during the search operation at his residence decoded the name of concerns. The same has been confirmed by Shri Nikhil Patel main person of Decora group in response to Q.No.8 during his post search statement recorded u/s 131(1A) of the Act on 06.03.2019. Moreover, at the time of search, statement of Shri Nikhil Patel was also recorded. During the course of search Shri Nikhil Patel has accepted that the assessee-company is in receipt of on-money in cash Page 5 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 reproduced by assessing officer on page number 19 of the assessment order.
The above ledger is retrieved from the Miracle database file named units as well whereby on money receipts in cash have been clearly mentioned.
statement of Himanshu Raiyani taken during the search proceedings on maintained by Shri Himanshu Raiyani for unaccounted cash transaction of accounts of the company. Page 8 to the assessee-company in which Shri Chetan Rokad and Shri Gopal the materials seized in the form of digital data, from the residence of Shri them. 8. noticed that during the course of search at the residence of Shri Himanshu assessee-company maintained by the name of “OD” in Miracle software.
transactions were mentioned. The same were printed, annexure, as Annexure- the head income particulars', there are details like sales collection, demolition Page 6 expenses. The total gross inflow till the date of preparation of this account is assessment order. 9. balance sheet of the assessee, which were reproduced on page number 11 to 18 of assessment order and noticed that these papers are titled as PROFIT maintains the same and year wise bifurcation is not made). The entries in the assessing officer in the assessment order. 10. that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-.
investor in the units of the assessee company is Shri Manishbhai of M/s. Rolex Bearings. He has paid the whole amount of Rs.17,00,00,000/- in cash, the Page 7 IT(SS)A Nos. 14/Rjt/2024, 6
More judgments on Section 153A
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Ashok Singh, Jaipur vs ACIT, Circle-2 Jaipur, JaipurITA 1540/JPR/2025[2015-16]Status: Disposed21 Oct 2026AY 2015-16
- Deputy Commissioner of Income Tax, Central… vs Ig3 Infra Limited, KanchipuramITA 2578/CHNY/2026[2020-21]Status: Disposed16 Oct 2026AY 2020-21
- Deputy Commissioner of Income Tax, Central… vs Ig3 Infra Limited, OggiamthoraipakkaITA 2577/CHNY/2026[2019-20]Status: Disposed16 Oct 2026AY 2019-20
- Deputy Commissioner of Income Tax, Central… vs Shanmugham Thiagarajan, ChennaiITA 2576/CHNY/2026[2020-21]Status: Disposed16 Oct 2026AY 2020-21
Recent GST High Court judgments
Search GST case law →- M/S Jsw Cement Limited,Jajpur vs. State Of OdishaOrissa · 16 Oct 2026
- M/S.Sreeshobi Enterprises vs. The Appellate AuthorityMadras · 16 Oct 2026
- S.T.Promotors vs. The Commercial Tax OfficerMadras · 16 Oct 2026
- Prashanti Das (M/S. Panchamukhi Enterprises) vs. Assistant Commissioner Of State Tax, CT And GST, Jagatsinghpur CircleOrissa · 16 Oct 2026
- M/S Utkal Highways, Bidanasi vs. Union Of INDIAOrissa · 16 Oct 2026
