Surendra M. Khandhar v. ACIT

224 CTR 409High Court2009#5233 most cited

What is Surendra M. Khandhar v. ACIT authority for?

A presumption under section 292C of the Income Tax Act, 1961, regarding the ownership and truth of contents of a seized document is applicable when the document is seized from the assessee's control and its Xerox copy is not denied by the assessee, especially when signatories are also not denied.

22

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

Surendra M. Khandhar · ACIT · section 292C · section 132(4A) · seized document · presumption of ownership · presumption of truth · Xerox copy · not denied

Sections most often in play

Section 292CSection 142(1)Section 143(2)Section 153ASection 69Section 143(3)Section 69CSection 69A

Issues it is cited on

section 181section 150(2)section 110section 114(e)section 106section 150(1)section 245hasection 33(4)percentage completion methodsection 150dumb documentssection 34(1)

Judgments citing Surendra M. Khandhar v. ACIT

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

ITA 500/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

…ED 2. Statutory Presumption under Section 292C • Section 292C provides a rebuttable presumption that: 1. Documents or assets found belong to the person searched; 2. Are genuine; 3. Contain truthful contents. Citation: • Surendra M. Khandhar v. ACIT (2009) 224 CTR 409 (Bom) Assessee never objected that the documents were not genuine or does not belong to assessee. 3. Onus on Assessee to Rebut Presumption • Once documents/assets are found, initial burden lies on the assessee to explain the contents. • AO is not required to disprove them at the threshold. 32 ITA Nos. 493. 495 to 498/JP/2025 Sh. Mahendra Ku…

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. DCIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

ITA 498/JPR/2025[2020-21]Status: DisposedITAT Jaipur15 Sept 2025AY 2020-21
For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

…n2. Statutory Presumption under Section 292C\n• Section 292C provides a rebuttable presumption that:\n1. Documents or assets found belong to the person searched;\n2. Are genuine;\n3. Contain truthful contents.\nCitation:\n• Surendra M. Khandhar v. ACIT (2009) 224 CTR 409 (Bom)\nAssessee never objected that the documents were not genuine or does not\nbelong to assessee.\n\n3. Onus on Assessee to Rebut Presumption\n• Once documents/assets are found, initial burden lies on the assessee to\nexplain the contents.\n• AO is not required to disprove them at the threshold.\nCitations:\n• CIT v. Chuharmal (1988) 172 ITR 25…

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

ITA 497/JPR/2025[2019-20]Status: DisposedITAT Jaipur15 Sept 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आंकड़ुठरधारी आइटीएए सं.र@ITA Nos.493, 495 to 498, 500/JP/2025 निर्धारण वर्ष@Assessment Years : 2014-15 to 2016-17, 2018-19 to 2020-21 Mahendra Kumar Goyal चुके Vs. ACIT/DCIT Ward No. 2, Shahpura Road Neem Ka Thana, Sikar Central Circle-03, Jaipur लेखा संख्याल्लेय सं.जीआइआर सं.पान@PAN/GIR No.: ACFPG0306G अपीलार्थी@Appellant प्रत्यार्थी@Respondent निर्धारीती की आर से@ Assessee by : Shri P. C. Parwal, CA राजस्व की आर से@ R

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

…ED 2. Statutory Presumption under Section 292C • Section 292C provides a rebuttable presumption that: 1. Documents or assets found belong to the person searched; 2. Are genuine; 3. Contain truthful contents. Citation: • Surendra M. Khandhar v. ACIT (2009) 224 CTR 409 (Bom) Assessee never objected that the documents were not genuine or does not belong to assessee. 3. Onus on Assessee to Rebut Presumption • Once documents/assets are found, initial burden lies on the assessee to explain the contents. • AO is not required to disprove them at the threshold. 32 ITA Nos. 493. 495 to 498/JP/2025 Sh. Mahendra Ku…

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

ITA 496/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Sept 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

…ED 2. Statutory Presumption under Section 292C • Section 292C provides a rebuttable presumption that: 1. Documents or assets found belong to the person searched; 2. Are genuine; 3. Contain truthful contents. Citation: • Surendra M. Khandhar v. ACIT (2009) 224 CTR 409 (Bom) Assessee never objected that the documents were not genuine or does not belong to assessee. 3. Onus on Assessee to Rebut Presumption • Once documents/assets are found, initial burden lies on the assessee to explain the contents. • AO is not required to disprove them at the threshold. 32 ITA Nos. 493. 495 to 498/JP/2025 Sh. Mahendra Ku…

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

ITA 493/JPR/2025[2014-15]Status: DisposedITAT Jaipur15 Sept 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

…ED 2. Statutory Presumption under Section 292C • Section 292C provides a rebuttable presumption that: 1. Documents or assets found belong to the person searched; 2. Are genuine; 3. Contain truthful contents. Citation: • Surendra M. Khandhar v. ACIT (2009) 224 CTR 409 (Bom) Assessee never objected that the documents were not genuine or does not belong to assessee. 3. Onus on Assessee to Rebut Presumption • Once documents/assets are found, initial burden lies on the assessee to explain the contents. • AO is not required to disprove them at the threshold. 32 ITA Nos. 493. 495 to 498/JP/2025 Sh. Mahendra Ku…

SHREE BALAJI REALTY ,PUNE vs. INCOME TAX, CENTRAL CIRCLE 2(3), PUNE , PUNE

In the result, appeals for

ITA 877/PUN/2024[2019-2020]Status: DisposedITAT Pune07 Feb 2025AY 2019-2020

Bench: Shri R. K. Panda & Ms. Astha Chandra

Section 132Section 143(2)Section 153A

…hat the document belongs to the persons from whose possession and control it was found. The second presumption is that the contents of such documents are true. The following case laws are relied in support of above proposition: (i) Surendra M. Khandhar [2009] 224 CTR 409 (Bombay): The Hon'ble Bombay High Court has held that "Where Xerox copy of document seized from Assessee was not denied the same showed advancement of certain sums to one 'C' and two signatories of said document were also not denied by Assessee and as the document was seized from Assessee's control, presumption under section 132(4A) and 292C was…

SHREE BALAJI REALTY ,PUNE vs. INCOME TAX, CENTRAL CIRCLE 2(3), PUNE , PUNE

In the result, appeals for

ITA 876/PUN/2024[2018-19]Status: DisposedITAT Pune07 Feb 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

Section 132Section 143(2)Section 153A

…hat the document belongs to the persons from whose possession and control it was found. The second presumption is that the contents of such documents are true. The following case laws are relied in support of above proposition: (i) Surendra M. Khandhar [2009] 224 CTR 409 (Bombay): The Hon'ble Bombay High Court has held that "Where Xerox copy of document seized from Assessee was not denied the same showed advancement of certain sums to one 'C' and two signatories of said document were also not denied by Assessee and as the document was seized from Assessee's control, presumption under section 132(4A) and 292C was…

SHREE BALAJI REALTY,PUNE vs. INCOME TAX, CENTRAL CIRCLE 2(3), PUNE, PUNE

In the result, appeals for assessment years 2017-18 and 2018-19 are allowed and the appeal for assessment year 2019-20 is partly allowed

ITA 875/PUN/2024[2017-18]Status: DisposedITAT Pune07 Feb 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: S/Shri Amol Kharnar CIT-DR &
Section 132Section 143(2)Section 153A

…hat the document belongs to the persons from whose possession and control it was found. The second presumption is that the contents of such documents are true. The following case laws are relied in support of above proposition: (i) Surendra M. Khandhar [2009] 224 CTR 409 (Bombay): The Hon'ble Bombay High Court has held that "Where Xerox copy of document seized from Assessee was not denied the same showed advancement of certain sums to one 'C' and two signatories of said document were also not denied by Assessee and as the document was seized from Assessee's control, presumption under section 132(4A) and 292C was…

MEENAMANI GANGA BUILDER LLP,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(3), PUNE

ITA 873/PUN/2024[2019-20]Status: DisposedITAT Pune07 Feb 2025AY 2019-20

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri Amol Kharnar CIT-DR
Section 132Section 143(2)Section 153A

…from whose possession and control it was found. The second presumption is that the contents of such documents are true. The following case laws are relied in above proposition: true. The following support of above proposition : (1) Surendra M. Khandhar [2009] 224 CTR 409 (Bombay): The Hon'ble Bombay High Court has held that "Where Xerox copy of document seized from Assessee was not denied the same showed advancement of certain sums to one 'C' and two signatories of said document were also not denied by Assessee and as the document was seized from Assessee's control, presumption under section 132(4A) and 292C was…

MEENAMANI GANGA BUILDER LLP,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(3), PUNE

In the result, all the three appeals filed by the assessee are partly allowed

ITA 872/PUN/2024[2018-19]Status: DisposedITAT Pune07 Feb 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri Amol Kharnar CIT-DR
Section 132Section 143(2)Section 153A

…from whose possession and control it was found. The second presumption is that the contents of such documents are true. The following case laws are relied in above proposition: true. The following support of above proposition : (1) Surendra M. Khandhar [2009] 224 CTR 409 (Bombay): The Hon'ble Bombay High Court has held that "Where Xerox copy of document seized from Assessee was not denied the same showed advancement of certain sums to one 'C' and two signatories of said document were also not denied by Assessee and as the document was seized from Assessee's control, presumption under section 132(4A) and 292C was…

MEENAMANI GANGA BUILDER LL,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(3), PUNE

ITA 871/PUN/2024[2017-18]Status: DisposedITAT Pune07 Feb 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri Amol Kharnar CIT-DR
Section 132Section 143(2)Section 153A

…from whose possession and control it was found. The second presumption is that the contents of such documents are true. The following case laws are relied in above proposition: true. The following support of above proposition : (1) Surendra M. Khandhar [2009] 224 CTR 409 (Bombay): The Hon'ble Bombay High Court has held that "Where Xerox copy of document seized from Assessee was not denied the same showed advancement of certain sums to one 'C' and two signatories of said document were also not denied by Assessee and as the document was seized from Assessee's control, presumption under section 132(4A) and 292C was…

ASHOK VIRAMBHAI PATEL,MUMBAI vs. DCIT CC 5 (1), MUMBAI

In the result, the appeals of the assesse is partly allowed

ITA 7336/MUM/2018[2012-13]Status: DisposedITAT Mumbai30 Jan 2023AY 2012-13

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopal

For Appellant: Viraj MehtaFor Respondent: Achal Sharma
Section 132(1)Section 143(2)Section 153D

…hat paper was found from the premises of the assesse, therefore, presumption u/s 292C applied in the fact of this case. The ld. D.R referred the following judicial pronouncements: i. Hon’ble Bombay High Court in the case of Surendra M. Khandar Vs. ACIT (2009) 224 CTR 409 (Bombay) ii. Hon’ble Madras High Court in the case of M. Vivek Vs. DCIT, CC-2(i/c) Trichy (2020) 121 taxmann.com 366 (Madras) iii. Hon’ble Jharkhand High Court in the case of Mahabir Prasad Rungta Vs. CIT(A) Ranchi (2014) 43 taxmann.com 328 (Jharkhand) 5. Heard both the sides and perused the material on record. During the course of search action…

ASHOK VIRAMBHAI PATEL,MUMBAI vs. DCIT -CC - 5(1), MUMBAI

In the result, the appeals of the assesse is partly allowed

ITA 7335/MUM/2018[2011-12]Status: DisposedITAT Mumbai30 Jan 2023AY 2011-12

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopal

For Appellant: Viraj MehtaFor Respondent: Achal Sharma
Section 132(1)Section 143(2)Section 153D

…hat paper was found from the premises of the assesse, therefore, presumption u/s 292C applied in the fact of this case. The ld. D.R referred the following judicial pronouncements: i. Hon’ble Bombay High Court in the case of Surendra M. Khandar Vs. ACIT (2009) 224 CTR 409 (Bombay) ii. Hon’ble Madras High Court in the case of M. Vivek Vs. DCIT, CC-2(i/c) Trichy (2020) 121 taxmann.com 366 (Madras) iii. Hon’ble Jharkhand High Court in the case of Mahabir Prasad Rungta Vs. CIT(A) Ranchi (2014) 43 taxmann.com 328 (Jharkhand) 5. Heard both the sides and perused the material on record. During the course of search action…

ASHOK VIRAMBHAI PATEL,MUMBAI vs. DCIT -CC - 5(1), MUMBAI

In the result, the appeals of the assesse is partly allowed

ITA 7333/MUM/2018[2013-14]Status: DisposedITAT Mumbai30 Jan 2023AY 2013-14

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopal

For Appellant: Viraj MehtaFor Respondent: Achal Sharma
Section 132(1)Section 143(2)Section 153D

…hat paper was found from the premises of the assesse, therefore, presumption u/s 292C applied in the fact of this case. The ld. D.R referred the following judicial pronouncements: i. Hon’ble Bombay High Court in the case of Surendra M. Khandar Vs. ACIT (2009) 224 CTR 409 (Bombay) ii. Hon’ble Madras High Court in the case of M. Vivek Vs. DCIT, CC-2(i/c) Trichy (2020) 121 taxmann.com 366 (Madras) iii. Hon’ble Jharkhand High Court in the case of Mahabir Prasad Rungta Vs. CIT(A) Ranchi (2014) 43 taxmann.com 328 (Jharkhand) 5. Heard both the sides and perused the material on record. During the course of search action…

PRAKASH GEMS,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-5(1), MUMBAI , MUMBAI

In the result, the appeals of the assesse is partly allowed

ITA 7332/MUM/2018[2014-15]Status: DisposedITAT Mumbai30 Jan 2023AY 2014-15

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopal

For Appellant: Viraj MehtaFor Respondent: Achal Sharma
Section 132(1)Section 143(2)Section 153D

…hat paper was found from the premises of the assesse, therefore, presumption u/s 292C applied in the fact of this case. The ld. D.R referred the following judicial pronouncements: i. Hon’ble Bombay High Court in the case of Surendra M. Khandar Vs. ACIT (2009) 224 CTR 409 (Bombay) ii. Hon’ble Madras High Court in the case of M. Vivek Vs. DCIT, CC-2(i/c) Trichy (2020) 121 taxmann.com 366 (Madras) iii. Hon’ble Jharkhand High Court in the case of Mahabir Prasad Rungta Vs. CIT(A) Ranchi (2014) 43 taxmann.com 328 (Jharkhand) 5. Heard both the sides and perused the material on record. During the course of search action…

ALKESH PATEL (PROP. OF M/S UMIYA GEMS),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-5(1), MUMBAI

In the result, the appeals of the assesse is partly allowed

ITA 7328/MUM/2018[2014-15]Status: DisposedITAT Mumbai30 Jan 2023AY 2014-15

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopal

For Appellant: Viraj MehtaFor Respondent: Achal Sharma
Section 132(1)Section 143(2)Section 153D

…hat paper was found from the premises of the assesse, therefore, presumption u/s 292C applied in the fact of this case. The ld. D.R referred the following judicial pronouncements: i. Hon’ble Bombay High Court in the case of Surendra M. Khandar Vs. ACIT (2009) 224 CTR 409 (Bombay) ii. Hon’ble Madras High Court in the case of M. Vivek Vs. DCIT, CC-2(i/c) Trichy (2020) 121 taxmann.com 366 (Madras) iii. Hon’ble Jharkhand High Court in the case of Mahabir Prasad Rungta Vs. CIT(A) Ranchi (2014) 43 taxmann.com 328 (Jharkhand) 5. Heard both the sides and perused the material on record. During the course of search action…

SHRI.B.H.BASHA,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all the appeals filed by the assessee are partly allowed

ITA 1375/BANG/2016[2008-09]Status: DisposedITAT Bangalore28 Oct 2021AY 2008-09

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri B.S Balachandra, AdvocateFor Respondent: Shri Roumvan Paite, CIT(DR)
Section 131Section 132Section 153ASection 69Section 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH : BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER ITA Nos.1375 to 1378/Bang/2016 Assessment year : 2008-09 to 2011-12 Shri B.H Basha, Vs. The Dy. Commissioner of Income- Prop. M/s Bahar Films, tax, No.18, 13th Cross, Central Circle-1(4), Jayamahal Extension, Bengaluru. Bengaluru-560 046. PAN – AEBPB 0242 C APPELANT RESPONDENT Appellant by : Shri B.S Balachandra, Advocate Respondent by : Shri Roumvan Paite, CIT(DR) Date of hearing : 01.10.2021 Date of Pronouncement : 28.10.2021 O R D E R Per Chandra Poojari, Accou…

SMT. KUNDAN SINGH,NEW DELHI vs. ACIT, NEW DELHI

Appeal of the Department is dismissed

ITA 2061/DEL/2015[2009-10]Status: DisposedITAT Delhi29 Apr 2019AY 2009-10

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Shri J.K. Mishra, CIT_D.R
Section 132Section 153ASection 69B

…in the sale deed. The Ld. D.R. relied upon Judgment of the Hon’ble Kerala High Court in the case of CIT, Kozhikode vs. O. Abdul Razak (2012) 20 taxmann.com 38 (Kerala), Judgment of Hon’ble Bombay High Court in the case of Surendra M. Khandhar vs. ACIT (2009) 224 CTR 409 (Bom.) and Judgment of Hon’ble Delhi High Court in the case of Bela Juneja vs. CIT 201 taxmann.com 392 (Del.). The Ld. D.R. submitted that since same parties are involved in the agreements to sell found during the course of search and the sale deeds executed of the same property, therefore, it was proved that higher consideration was paid by the…

ACIT, NEW DELHI vs. KUNDAN SINGH, NEW DELHI

Appeal of the Department is dismissed

ITA 1797/DEL/2015[2009-10]Status: DisposedITAT Delhi29 Apr 2019AY 2009-10

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Shri J.K. Mishra, CIT_D.R
Section 132Section 153ASection 69B

…in the sale deed. The Ld. D.R. relied upon Judgment of the Hon’ble Kerala High Court in the case of CIT, Kozhikode vs. O. Abdul Razak (2012) 20 taxmann.com 38 (Kerala), Judgment of Hon’ble Bombay High Court in the case of Surendra M. Khandhar vs. ACIT (2009) 224 CTR 409 (Bom.) and Judgment of Hon’ble Delhi High Court in the case of Bela Juneja vs. CIT 201 taxmann.com 392 (Del.). The Ld. D.R. submitted that since same parties are involved in the agreements to sell found during the course of search and the sale deeds executed of the same property, therefore, it was proved that higher consideration was paid by the…

RAMNAGAR DEVELOPMENT CORPORATION,MUMBAI vs. ASST CIT CEN CIR 24 & 26, MUMBAI

In the result, the appeals filed by the assessee in ITA N0

ITA 77/MUM/2012[2008-09]Status: DisposedITAT Mumbai22 Aug 2016AY 2008-09

Bench: Shri Saktijit Dey & Shri Ramit Kocharआयकर अपील सं./I.T.A. No. 76/Mum/2012 ("नधा"रण वष" / Assessment Year : 2007-08) आयकर अपील सं./I.T.A. No. 77/Mum/2012 ("नधा"रण वष" / Assessment Year : 2008-09) आयकर अपील सं./I.T.A. No. 7421/Mum/2012 ("नधा"रण वष" / Assessment Year : 2009-10)

For Respondent: Shri A.K. Srivastava,CIT DR
Section 132Section 132(1)Section 139(1)Section 143(3)Section 153A

…ssessment year 2007-08 based merely on extrapolating the statement of the assessee for the surrender made for the assessment year 2008-09 . The ld. CIT D.R. relied on the decision of Hon’ble Bombay High Court in the case of Surendra M. Khandhar v. ACIT [2009] 224 CTR 409 (Bombay) and submitted that the assessee has accepted that cash ‘on-money’ has been received by the assessee. He further relied on the decision of Hon’ble Bombay High Court in the case of Harish Textile Engineers Ltd. v. DCIT, [2015] 63 taxmann.com 66 (Bombay), in the case of Mahabir Prasad Rungta v. CIT, [2014] 43 taxmann.com 328 (Jharkhand) and…

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Surendra M. Khandhar v. ACIT (224 CTR 409) — Cited in 22 Judgments | BharatTax