NAVNITLAL K PARIKH,MUMBAI vs. ACIT CC-45, MUMBAI

आदेश / O R D E R Per Joginder Singh (Judicial Member) This appeal is by the assessee against the confirmation of penalty of Rs.4,95,000/- for Assessment Year 2004-05 imposed u/s 271(1)(c) of the Income Tax Act, 1961 (hereinafter the Act).

2.1. On the other hand, the ld. DR, Shri Suman Kumar, though defended the penalty but did not controvert that on identical facts, in the case of Shri Yogesh Parikh, son of the assessee, the penalty was deleted by the Tribunal.

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2.2. We have considered the rival submissions and perused the material available on record. In view of the above, we are reproducing hereunder the relevant portion from the aforesaid order dated 25/07/2012 of the Tribunal for ready reference and analysis:-

“These 3 appeals by the assessee are directed against 3 separate orders of CIT(A) arising from the penalty order is passed under section 271(1)(C) of I T Act for the assessment year 2003 –04, 04-05 and 05-06 respectively. 2 The assessee has raised common grounds in these appeals except the amount of penalty levied. 2.1 The effective ground raised for the assessment year 2003-04 is reproduced as under: “1. On the facts and in the circumstances of the appellant’s case and in law the ld Commissioner of Income Tax(Appeals) erred in confirming the penalty of Rs.63,000/- out of penalty of Rs.94,500/- imposed by the Assessing Officer u/s 271(1)( c). 3 The brief facts leading to the levy of penalty are as under: 3.1 A search and seizure operation was conducted on 10/01/2006 in the case of M/s Unimark Remedies Ltd and it’s group concerns. The assessee had filed return of income in response to the notice under section 15 3A for all these 3 years. 3.2 For the assessment year 2003-04, the assessee declared a total income at Rs. 5,92,050/- including an amount of Rs. 2 lacs declared by the assessee only in the return filed u/s 153A. The Assessing Officer noticed that at page no. 51 of Annexure A-1 seized from the residence of the assessee, there was a calculation of interest of Rs. 20,000/- up to 31/03/2003, which indicated that the assessee had received interest of Rs. 20,000 out of loan given to Shri Ketan. The Assessing Officer completed the assessment by accepting the income declared by the assessee in the return of income filed in response to notice under section 153A. 3.3 For the assessment year 2004-05, the original return of income under section 139 (1) was filed on 27/10/2004 declaring income at Rs. 4,53,810/-. In response to notice under section 153A, the assessee filed the return of income for the same income on 10/7/2006, the assessee has shown the gift of Rs. 9,25,000/- from his uncle Shri ChampakLal Parekh on 1.10.2003, who is settled in USA. In support of the gift received, the assessee furnished the gift deed signed by Shri Anil Parekh, Power of Attorney holder of Shri

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Champaklal Parekh. During the assessment proceedings, the Assessing Officer recorded the statement of the assessee on 23/10/2007 and asked the assessee to produce Shri ChampakLal Parekh to prove the creditworthiness and genuineness of gift. At this stage, the assessee filed a revised return and offered the said gift amount of Rs. 9, 25, 000/- to tax. 3.4 The Assessing Officer was of the view that the revised return cannot be termed and treated as valid return as it is not voluntarily submitted as per the provisions of sub-section 5 of section 139 and accordingly, made an addition of gift amount of Rs.9,25 lacs to the total income of the assessee. 3.5 For the assessment year 2005- 06, the assessee filed original return of income on 29/08 2005 declaring total income of Rs. 9,95,456/-. In the return of income filed in response to notice under section 153A, the assessee declared an amount of Rs.9.50 lakh and accordingly, declared the total income of Rs. 19,45,460/-. The Assessing Officer framed the assessment on the return income filed by the assessee under section 153A. 3.6 The penalty proceedings were initiated under section 271(1)(c) of Income Tax Act in respect of the income declared by the assessee in the return of income filed in response to notice under section 153A for the assessment year 2003-04 and 2005- 06 and for the assessment year 2004–05 against the addition of gift amount of Rs. 9,25,000/-. Accordingly, the Assessing Officer levied the penalty under section 271(1)(c), which is 150% of tax sought to be evaded on the income declared/addition made by the Assessing Officer . 3.7 On appeal, the CIT(A), though confirmed the levy of penalty made by the Assessing Officer ; however, restricted the same to100% of the tax sought to be availed. 4 Before us, the learned A.R. of the assessee has submitted that the notice under section 274 read with section 271(1)( c) of income tax act issued by the Assessing Officer is without any specific charge of concealment of particulars or furnishing of inaccurate particulars of income. The ld AR has further submitted thateven in the order passed under section 271(1)( c), the Assessing Officer has not mentioned specifically whether the assessee has concealed the particulars of income or furnished inaccurate particulars of income. The ld AR has referred para 8 of the penalty order and submitted that the Assessing Officer himself was not sure about the charge against the assessee; therefore, the penalty order is not sustainable and void. In support of his contention, he has relied upon the decision of honourable Gujarat High Court in case of New Sorathia Engineering Co. v. Commissioner of Income-tax reported in 282 ITR 642 and submitted that when there is no clear cut finding that the penalty was levied for concealment of particulars of income or furnishing of inaccurate particulars of income, then the penalty could not be

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sustained and is liable to be cancelled. Thus, the ld AR has submitted that in the identical circumstances, the honourable Gujarat High Court has held that the penalty order is invalid when the Assessing Officer has not given a clear cut finding whether the assessee has concealed the particulars of income or furnished inaccurate particulars of income. 4.1 The 2nd leg of the argument of learned A.R of the assessee is that the seized document is a dumb paper without any signature and name and therefore, the same cannot be the basis for any addition of income. He has further submitted that the said paper was not confronted with the assessee during the search proceedings and therefore, the same cannot be used against the assessee when the assessee has not accepted the same. The income declared in the return of income filed in response to notice under section 153A was to buy peace and to avoid the litigation and the same would not automatically invoked the provisions of section 271(1)(c). Moreover, the assessee disowned the said paper in his reply to the show cause notice under section 271(1)(c). The learned A.R has referred paragraph 3 of the order passed under section 271(1)(c) and submitted that the assessee has categorically stated that the said paper does not belong to the assessee. 4.2 As regards the revised return filed for the assessment year 2004- 05, the ld AR of the assessee has referred the provisions of section 153A and submitted that as per clause (a) of sub. section 1 of section 153A, the return of income filed under the said provision is treated, if such return were a return required to be furnished under section 139; therefore, the revised return can be filed as per section 139 (5) of the income tax act and the Assessing Officer cannot treat the same as invalid. 4.3 As regards the gift amount of Rs. 9,25,000/- ,the ld AR of the assessee has submitted that the gift was received by the assessee from his uncle, who is settled in USA; but when the Assessing Officer asked the assessee to produce the donor in person, then to avoid the harassment to his uncle, the assessee offered the said amount to tax to buy peace. The learned A.R. of the assessee has submitted that offering of the gift amount to tax would not invite levy of penalty under section 271 once the assessee furnished all relevant documents including gift deed and other e-mail correspondence. The ld counsel for the assessee has further submitted that the amount of gift was from the sale of flat, which has not been disputed by the Department. He has relied upon the decision of honourable Madras High Court in the case of Commissioner of Income-tax v. M. Pachamuthu reported in 295 ITR 502(Mad). 4.4 For the assessment year 2005-06, the learned A.R. of the assessee has submitted that the income was offered by the assessee voluntarily as the same cannot be added on the basis of the seized material which is a dumb document. The 3rd line of

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argument of the ld AR of the assessee is that the provisions of explanation 5 to section 271(1)(c) are not applicable in the case of the assessee when no addition was made on the basis of seized material and further when no money, bullion, jewellery or other valuable articles or things was found during the search, then it cannot be deemed that the assessee has concealed the particulars of income or furnished inaccurate particulars of income as per explanation 5 to section 271(1)(c). In support of his contention, the ld AR of the assessee has relied upon the decision of the honourable Supreme Court in case of Commissioner of Income-tax v. Suresh Chandra Mittal reported in 251 ITR 9(SC). 4.5 He has also relied upon the decision of coordinate Bench of this Tribunal in case of Sanjoy Sankar Salvi vs ACIT dated 31/10/2011 as well as decision of Delhi Benches of this Tribunal in case of Shri Prem Arora vs DCIT dated 9th March 2012 in ITA number 4702/Del/2010. The Ld AR of the assessee has submitted that in the identical facts, the coordinate Bench of this Tribunal in case of Sanjoy Sankar Salvi (supra) has cancelled the penalty levied by the Assessing Officer. He has pointed out that in case of Shri Prem Arora (supra), the Delhi benches of the Tribunal has held that no penalty under section 271(1)(c) is leviable when there is no variation in the return of income and total income assessed by the Assessing Officer under section 153. 4.6 On the other hand, the ld DR has submitted that in paragraph 5 of the penalty order the Assessing Officer has specifically mentioned that “had there being no search the concealment/filing of inaccurate particulars of income would have never come to light.” The learned D.R. has then referred to para 6 of the assessment order for the assessment year 2003-04 and submitted that the Assessing Officer had specifically mentioned that the assessee declared the additional income on account of the seized material and notings therein and therefore, thepenalty proceedings under section 271(1)(c) read with explanation 5 were initiated separately. The ld DR has relied upon the orders of the authorities below. 5 We have considered the rival submissions as well as relevant material on record. The Assessing Officer has relied upon the seized material being the document at page number 51 of Annexure A-1 having some notings regarding the interest of ` 20,000/- up to 31st of March 2003 and other entries regarding some figures for air ticket interest from April to Feb 2005. 5.1 For the assessment year 2003-04, as per the seized document only Rs. 20,000/- was shown as interest and nothing else has been mentioned in the said document. The assessee offered Rs.2 lakh in the return filed in response to the notice under section 153A. Even, as per the said document more than Rs. 20,000/- cannot be treated as undisclosed income of the assessee; therefore, the remaining amount of Rs. 1,80,000/- is nothing but a voluntary declaration by the

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assessee and not based on the seized material. The income returned by the assessee, which is otherwise cannot be added on the basis of seized material, would not automatically lead to the conclusion that the assessee has concealed particulars of income or furnished inaccurate particulars of income. Further, the explanation 5 to section 271(1)( c) is applicable only in the cases when the additional income has been admitted by the assessee because of some incriminating material showing material showing undisclosed income found and seized during the search and seizure action. 5.2 For the assessment year 2003-04, the incriminating material shows only Rs. 20,000/- as interest and therefore, it cannot be presumed in the absence of any material or information that the additional income offered by the assessee isotherwise liable to be added to the income of the assessee on the basis of seized material. 5.3 For the assessment year 2004-05, the gift of Rs. 9,25,000/- was already shown in the capital account of the assessee; therefore, the said amount was already recorded in the books of accounts and cannot be said that the additional income offered by the assessee was because of something, which was not recorded in the books of account; but only because of seized material. Once the gift was duly shown in the books of accounts, then the explanation 5 to section 271 (1)(c)would not apply. It appears from the assessment order that during the course of assessment proceeding, the Assessing Officer asked the assessee to produce his uncle, who has given this gift to the assessee and only at this point and stage, the assessee decided to offer the said amount to tax. 5.4 It is apparent and manifest from the facts and circumstances of the case that to avoid the harassment of bringing his uncle from abroad and to produce before the Assessing Officer, the assessee has offered the gift amount to tax. The Assessing Officer himself has recorded the fact that in the e-mail correspondence, the uncle of the assessee has accepted the said amount. Even the source of the gift was also explained as the sale proceed of flat and therefore, though the assessee offered the said amount to tax, the same was not held as a bogus. 5.5 Further, in the penalty proceedings, the Assessing Officer has not conducted any enquiry to prove and establish that the gift initially claimed by the assessee was a bogus claim of the assessee. 5.6 On the question of revised return filed by the assessee, the provisions of section 153A clearly stipulates that the return filed in response to notice under section 153A will be treated as return filed under section 139 and all other provisions of the Act are applicable. Hence, once the return filed in response to notice u/s section 153A is treated as return filed under section 139, then if assessee filed a revised return within the permissible period of time as provided under section 139(5), the same cannot be rejected or treated invalid;

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though for the purpose of penalty the Assessing Officer could treat the action of the assessee as not voluntary; but because of the investigation and enquiry of the Assessing Officer. Therefore, the revised return filed by the assessee within the period of limitation as prescribed under section 139 (5), cannot be held invalid. It is to be noted that when the assessee has already recorded the gift amount in the books of account and only to avoid the inconvenience and harassment to his uncle, the assessee offered the same to tax, would not automatically lead to the conclusion that the assessee had furnished inaccurate particulars of income or concealed particulars of income in the absence of any conclusive finding that the claim of the assessee was a bogus. 5.7 Similarly, for the assessment year 2005–06, the income offered by the assessee in the return filed in response to section 153A does not borne out from the seized material. When there is no co-relation and nexus of the additional income offered by the assessee and the figures return in the seized documents, then it cannot be said that the additional income admitted in the return of income filed under section 153A is based on some incriminating material or information found during the course of search and seizure action. 5.8 Further, in the case of Sanjoy Sankar Salvi (supra), the coordinate Bench of this Tribunal has dealt with a similar issue in para 7 and 8 as under: “7. We have considered the rival submissions, perused the record and gone through the orders of the authorities below as the decision cited. In the course of search some material was found. When the assessee filed revised return of income in pursuance to section 153A of the Act, some additional income was declared voluntarily. During the course of assessment proceedings, no verification and enquiry was made by the Assessing Officer and accepted whatever income declared by assessee. Even in the course of penalty proceedings, the Assessing Officer without investigating and without making any enquiry into the facts of the case simply imposed penalty rejecting the explanation offered by the assessee. The learned CIT(A) confirmed the penalty by following third member decision of ITAT, Ahmedabad “B” Third Member Bench, in Asst. Commissioner of Income- tax in the case of Kirit Dahyabhai Patel. On perusal of the said case, we find the said case is not applicable to the facts of the case. We find that the judgment of the Hon’ble Supreme Court in the case of CIT Vs. Suresh Chandra Mittal, (supra), on which reliance placed by the assessee, is squarely applicable to the facts of the case under consideration. The Hon’ble Supreme Court affirmed the decision of the Madhya Pradesh High Court in the said Case and the facts of the said case are as under: “The assessee had originally filed returns showing meagre income. When, after action u/s 132 of the Income-tax Act, a notice under section 148 was served on him, he filed revised returns showing higher income. Eventually, assessment orders were passed and the returns submitted regularized under section 148. In penalty proceedings u/s 271, the assessee claimed that he

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had offered additional income to buy peace of mind and avoid litigation. Penalty orders were passed and the CIT(A) confirmed the orders. But the appellate Tribunal held that the Department had not discharged its burden of proving concealment and had simply rested its conclusion on the act of voluntary surrender done by the assessee in good faith, and that penalty could not be levied. On a reference, the High Court held that no penalty could be levied for concealment. The department preferred appeals to Supreme Court. The Supreme Court dismissed the appeals holding that no interference with the order of the High Court was called for and the decision of the High Court was affirmed by the Hon’ble Supreme Court. 8. In the present case, the assessee originally filed return of income by showing some income and after action u/s 132, the assessee filed revised return of income u/s 153A, which was .accepted by the AO. Even in the penalty proceedings, the AO has not made any investigation or enquiry with regard to the income shown by the assessee. It was submitted before us, the additional income shown by the assessee voluntarily in good faith and bonafide belief that no penalty proceedings would be levied. We find that the facts of the case under consideration are similar to that of the case decided by the Hon’ble Supreme Court in the case of CIT Vs. Suresh Chandra Mittal, (supra). Therefore, respectfully following the said judgment, we set aside the order of the CIT(A) and delete the penalty levied by the AO u/s 271(1)(c) of the Act in all the years under consideration.” 5.9 Similarly, in the case of Shri Prem Arora (supra), the Delhi Bench of this Tribunal has held in paragraph 9 to 12 as under: 9. We have heard both the parties and gone through the material available on record. The first contention of ld. AR of the assessee is that the return of income filed under sec. 153A is voluntary and assessee can declare the income, which was not earlier disclosed. On the other hand, the contention of the Revenue is that the return filed under sec. 153A, is not voluntary and is intended to assess the undisclosed income. Sec. 153A was inserted into statute with effect from 1st June, 2003 by the Finance Act, 2003 which reads as under: “153A Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall— (a) issue notice to such person requiring him to furnish within such period, as may be specified in the notice, the return of income in respect of each assessment year falling within six assessment years referred to in clause (b), in the prescribed form and verified in the prescribed manner and setting forth such other particulars as may be prescribed and the provisions of this Act shall, so far as may be, apply accordingly as if such return were a return required to be furnished under section 139;

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(b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made: Provided that the Assessing Officer shall assess or reassess the total income in respect of each assessment year falling within such six assessment years: Provided further that assessment or reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this section pending on the date of initiation of the search under section 132 or making of requisition under section 132A, as the case may be, shall abate. Explanation.—For the removal of doubts, it is hereby declared that,— (i) save as otherwise provided in this section, section 153B and section 153 C, all other provisions of this Act shall apply to the assessment made under this section; (ii) in an assessment or reassessment made in respect of an assessment year under this section, the tax shall be chargeable at the rate or rates as applicable to such assessment year.” 10. On bare reading of Sec. 153A it is seen that this section starts with a non-obstante clause relating to normal assessment procedure covered by Sections 139, 147, 148, 149, 151 and 153 in respect of searches made after 31st May, 2003. The sections, so excluded, relate to filing of return, assessment and re-assessment proceedings. Further section 153A intends to assess or reassess total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made. Thus the legislative intention is not to assess escaped income as in section 147 or undisclosed income as was assessed uls 158BC of the Act. The First Proviso to sec. 153A makes it clear, that notice under sec. 153A will be for each such six assessment years for assessment or reassessment of total income. Second Proviso to Section 153A provides that such notice will have the effect of abating all the pending assessment or reassessment proceedings, so as to avoid multiplicity of proceedings, which was a feature of block assessment. Hon’ble Allahabad High Court in the case CIT (Central), Kanpur v Shaila Agarwal [2011] 16 taxmann.com 232 (All.) has held that the word ‘abatement’ is referable to something, which is pending alive, or is subject to deduction. The abatement refers to suspension or termination of the proceedings either of the main action, or the proceedings ancillary or collateral to it. The word is commonly used in the legislations, which provide for abatement of action/suit; abatement of legacies; abatement of nuisance; and all actions for such nature, which have the pendency or continuance. The proceedings, which have already terminated are not liable for abatement unless statute expressly provides for such consequence thereof. The word pending’ occurring in the second proviso to section 153A of the Act, is also significant. It is qualified by the words “on the date of initiation of the search “, and makes it abundantly clear that only such assessment or reassessment proceedings are liable to abate. The pendency of an appeal in

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the Tribunal against the order of assessment against which an appeal has been decided by Commissioner (Appeals) is not a continuation of the proceedings of assessment. 11. Thus while section 153A prescribes for assessment or reassessment of total income in search cases, section 153B prescribes the time limit for completion of assessment under sec. 153A. Section 153C relates to the cases where books of accounts or documents or assets seized under sec. 132 or requisition made under sec. 1 32A belong to a person other than a person in whose case search under sec. 132 or requisition under sec. 132A was made. Thus provisions of sections 153A, 153B and 153C are complete code for search assessments wherein search has been initiated after 3 1st May, 2003. The existence of the words “all other provisions of this Act shall apply to the assessment made under this section” in Explanation (i) of section 153A makes it clear that in search assessments, amongst others the provisions relating to penalty and prosecution will also be applicable. However, when normal assessment procedure covered by Sections 139, 147, 148, 149, 151 and 153 has been completely excluded by operation of non-obstante clause “Notwithstanding anything contained” the search assessments made u/s section 153A of the Act cannot be treated as continuance of normal assessment proceedings whether abated or not. Thus there is complete detachment of assessment proceedings u/s 143 or 147 from search proceedings u/s 153A of the Act. When scheme of search assessment as designed by the Legislature does not prescribe to take into account the earlier assessment proceedings whether abated or not, it will not be proper orjustified to refer to returned income u/s 139 for the purpose imposition of penalty u/s 271(1 )(c) of the Act. It follows that the concealment of income has to be seen with reference to additional income brought to tax over and above returned by the assessee in response to notice issued u/s 153A of the Act. Accordingly in our considered opinion for the purpose of imposition of penalty u/s 271(1)(c) resulting as a result of search assessments made u/s153A, the original return of income filed u/s 139 cannot be considered. 12. Further in case of search initiated after 1.6.2003 a return of income is always filed on issue of notice u/s 153A. As held above the penalty u/s 271(1)(c) is imposable when there is variation in assessed and returned income. If there is no variation, there will be no concealment. When there is no concealment, question levy of penalty uls 271(1)(c) of the Act will not arise. This is settled position of law. The concept of voluntary return of income may be important in penalty proceedings initiated in course of normal assessment proceedings made u/s 143(3) or 147 but not u/s 153A. From above discussion it follows that where retuned income filed u/s 153A is accepted by the assessing officer, there will be no concealment of income and consequently penalty u/s 171(1)(c) cannot be imposed.” 6 In view of the above decisions of the coordinate Benches of this Tribunal as well as in the facts and circumstances of the present case, we cancel the penalty levied under section 271(1)(c) of the I T Act. 7 In the result, he appeals filed by the assessee are allowed.”

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2.4. We find that in the aforesaid case also, who is son of the assessee, the Assessing Officer recorded the statement on 23/10/2007 and asked the assessee to produce Shri Champaklal Parikh to prove the creditworthiness and genuineness of the gift. To buy peace with the Department, the assessee revised the return and offered the gift to tax. The Ld. Assessing Officer was of the view that the revised return may not be valid return as the same was not filed voluntarily submitted as per section 139(5) of the Act and therefore, he made the addition of the gift amount. The Tribunal has made an elaborate discussion and place reliance upon the decision from Hon'ble Gujarat High Court in the case of New Sarathia Engineering Co. vs CIT 282 ITR 642, decision of the Co- ordinate Bench in Sanjay Shankar Savli vs ACIT dated 31/10/2011, Delhi Bench of the Tribunal in the case of Prem Arora vs DCIT ITA No.4720/Del./2010 order dated 09/03/2012, the provision of the Act and thereafter reached to a conclusion. The person who donated the gift is the brother of the present assessee residing abroad and thus could not be produced before the Assessing Officer. Considering the totality of facts and following the aforesaid decision of the Tribunal, which is exactly on identical fact and also no contrary facts/decision were brought to our notice by the Revenue. It is also noted that for imposing penalty u/s 271(1)(c) of the Act either there should be concealment of income or furnishing of inaccurate particular of such income. We find that the conditions for imposing

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penalty under the present set of facts are not fulfilled as the assessee neither concealed his income nor furnished inaccurate particulars of such income, therefore, we direct the Assessing Officer to delete the penalty imposed u/s 271(1)(c) of the Act. Thus, the appeal of the assessee for Assessment Year 2004-05 is allowed.

Finally, the appeal of the assessee is allowed.

This Order was pronounced in the open court in the presence of ld. representatives from both sides at the conclusion of the hearing on 05/04/2017.

Sd/- Sd/-

(Ramit Kochar) (Joginder Singh) लेखा सद�य / ACCOUNTANT MEMBER �या�यक सद�य / JUDICIAL MEMBER मुंबई Mumbai; �दनांक Dated : 18/04/2017 f{x~{tÜ? P.S /�नजी स�चव आदेश क� ��त�ल�प अ�े�षत/Copy of the Order forwarded to :

आदेशानुसार/ BY ORDER, स�या�पत ��त //True Copy// उप/सहायक पंजीकार (Dy./Asstt. Registrar) आयकर अपील�य अ�धकरण, मुंबई / ITAT, Mumbai,