DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE vs. ARYAN ARCADE LIMITED , RAJKOT

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 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. 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 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. 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 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. 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 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. same is reflected in page no.

The ledger of Manishbhai cash payment is reproduced by assessing officer on page number 19 of the assessment order.

The above ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. The relevant statement is reproduced by the assessing officer on page number 20.The ledger is retrieved from the Miracle database file named "OD". Miracle Software maintained by Shri Himanshu Raiyani for unaccounted cash transaction of Square 9 project wherein date wise entries of unaccounted cash receipt in sale consideration of various units from their buyers and investors, have been posted. Similarly, there are ledgers of other units as well whereby on money receipts in cash have been clearly mentioned. From this, it can be concluded that they have been maintaining two set of books, one is accounted for and another is unaccounted and not reflected in the books of accounts i.e. cash account. The same fact, corroborates with the statement of Himanshu Raiyani taken during the search proceedings on 26/09/5018, in which he stated that cash portion is maintained separately and not reflected in the books of accounts of the company. Page 8 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. which is over and above the documented price. Since the documents pertains to the assessee-company in which Shri Chetan Rokad and Shri Gopal Chudasama are major stakeholders, the statement of Shri Nikhil Patel was got countersigned by these persons. Further, during the course of post search proceedings, statement of Shri Nikhil Patel was recorded, which is reproduced by the assessing officer on page no.5 to 6 of the assessment order. Here again, he has reiterated that the assessee-company is involved in unaccounted transactions. From the above, it can be concluded that during the course of search, Shri Nikhil Patel 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 from latter's residential premise. From the above, it can be seen that the contents of the materials seized in the form of digital data, from the residence of Shri Himanshu Raiyani has been admitted and accepted to be true and correct by both Shri Himanshu Raiyani and Shri Nikhil Patel. It is also undoubtedly clear that such entries were element of huge unaccounted transaction in within them.

About unaccounted cash “on-money” of Rs.82,32,34,811/- in the sale consideration of offices and sops of Square 9 project, the assessing officer noticed that during the course of search at the residence of Shri Himanshu Raiyani, certain digital data was found and seized which were accounts of the assessee-company maintained by the name of “OD” in Miracle software. These accounts were parallel books of the assessee whereby unaccounted transactions were mentioned. The same were printed, annexure, as Annexure- DD-1 and confronted to Shri Nikhl Patel. Page No.9-15 of Annexure DD-1 are those documents which revealed huge cash inflow in the form of advances received towards the booking of units in the project Om Decora Square, under the head income particulars', there are details like sales collection, demolition Page 6 IT(SS)A Nos. 14/Rjt/2024, 63-65/Rjt/2023 & ITA No.229/Rjt/2023, AYs 14-15, 16-17 to 19-20 Gopal B Chudasama & Aryan Arcade Ltd. income misc. income etc. The expense particulars reveals the details like distribution of cash by the stakeholders, cost of construction and selling expenses. The total gross inflow till the date of preparation of this account is Rs.82,32,34,811/-. In this connection, the assessing officer reproduced the profit and loss account and balance sheet on page number 11 to 18 of assessment order.

The assessing officer had gone through the profit and loss account and 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 AND LOSS account and BALANCE SHEET. The dates are from 01.01.2015 to 31.03.2026. Thus, it is from the beginning till endless (as this is parallel unaccounted accounts and therefore, the range is set by the person who maintains the same and year wise bifurcation is not made). The entries in Pendrive data reflect unaccounted transactions till the date of search & seizure action 26.09.2018. The broad break up of these accounts were discussed by the assessing officer in the assessment order.

The assessing officer noticed from the broad break up of these accounts that there is credit entries (Sale Collection Rs.78,85,77,200/-, the top left of Page 9 of Annexure DD-1 produced in assessment order shows details of sale collection. There are two wings, viz: A-Wing and B-Wing. The total unaccounted cash collection towards sale is to the tune of Rs. 78,85,77,200/-. The bifurcation of this is given in page Nos. 11, 12, 13 and 14 of the seized documents as produced in assessment order. There is clear mention of 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. One important 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