9911796707
TMI Blog2000 (5) TMI 1070X X X X Extracts X X X X X X X X Extracts X X X X ..... ssing Officer has also pointed out that the assessee admitted in his statement recorded under section 131 that he is advancing cash loans. The assessee has also admitted in answer to question No. 2, when pointed out certain entries in the personal memorandum diaries relating to 1992 and earlier period, that these entries are written in the coded language. Regarding one amount of ₹ 2,000 written against one Ramakant Kadam on entry No. 4182 in Annexure A-7, the assessee admitted that this amount really represented a sum of ₹ 2 lakhs paid to Shri Ramakant Kadam. 2. The search and seizure action under section 132 was conducted in the business and residential premises of the assessee on 15/16th July, 1996. As a result of search, the assessment was completed by the Assessing Officer under section 158BC of the Income-tax Act, 1961 for the block period 1-4-1986 to 15-7-1996. During the course of search, cash of ₹ 1,25,000 was seized apart from seizure of jewellery to the extent of ₹ 1,07,703 (out of jewellery worth ₹ 3,45,092 found at the Vile Parle residence of the assessee) and seizure of shares and debentures etc. worth ₹ 39,29,432 out of such assets ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Officer like reduced market demand etc. The Assessing Officer has mentioned that it is not understood why the assessee voluntarily reduced the agreed price by ₹ 8.50 lakhs. The Assessing Officer has stated that the only reasonable explanation appeared to be that the assessee had received the difference in cash. The assessee had argued before the Assessing Officer as well as the CIT that the land was never in his possession nor the possession was given to M/s. Vishal Developers. The assessee had also produced 7/12 extract and a letter dated 30-7-1997 from M/s. Vishal Developers showing that M/s. Vishal Developers do not have any physical possession of the plot due to non-availability of the right of way. However, the assessee agreed that he is having Power of Attorney for sale of this plot. The Assessing Officer has stated that by virtue of the Power of Attorney the assessee became owner and in view of the agreement mentioned above, the assessee sold the plot of land for ₹ 31.11 lakhs to M/s. Vishal Developers. The Assessing Officer pointed out that this transaction is not declared by the assessee in his return of income. The Assessing Officer has pointed out that the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erred without permission of Collector. 6.1 The learned Counsel further stated that no addition could be made on presumptions. Reliance was placed on the following decisions : - (i)St. Teresa';s Oil Mills v. State of Kerala (1970) 76 ITR 365 (Ker.), (ii)K.P. Varghese v. ITO (1981) 131 ITR 597(SC), (iii)Umacharan Shaw & Bros. v. CIT (1959) 37 ITR 271(SC), (iv)Patel Rajeshkumar Kantilal & Co. v. CIT (1998) 62 TTJ (Ahd.) 189. 6.2 The learned Counsel further stated that the apparent state of affairs is to be treated as real unless contrary is proved and no addition can be made on presumption: - (i)Kalwa Devadattam v. Union of India (1963) 49 ITR 165(SC), (ii)CIT v. Durga Prasad More (1971) 82 ITR 540(SC), (iii)CIT v. Daulat Ram Rawatmull (1973) 87 ITR 349(SC). 6.3 The learned Counsel further contended that no addition could be made on the basis of rough sheets/loose papers. In this regard, reliance was placed on the following decisions: - (i)Ashwani Kumar v. ITO (1991) 39 ITD 183(Delhi), (ii)Kishanchand Sobhrajmal v. Asstt. CIT (1992) 41 ITD 97(Jp.), (iii)Kantilal & Bros. v. Asstt. CIT (1995) 52 ITD 412(Pune), (iv)Shri Ram Bhagwandas Raheja v. ACIT, IT (S&S) A No. 118/ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ge Bhayender and the balance amount of ₹ 23 lakhs was still due and payable to the assessee. To the assessee';s argument that no addition could be made on presumptions, the learned Departmental Representative pointed out that there is no presumption and the addition is based on the documents found during search. To the argument of the learned Counsel of the assessee that no addition can be made on the basis of rough sheets or loose papers, the learned Departmental Representative contended that the relevant papers are not rough sheets or loose papers, but they are duly signed documents. To the assessee';s argument that presumption under section 132(4A) is available only for the limited purpose of section 132(5) and 132(11), the learned Departmental Representative relied upon the decision of the ITAT Hyderabad Bench ';B'; Third Member in the case of Smt. Kesari Bai v. ITO (1990) 32 ITD 1 (TM) (SB) and the decision of Jaipur Bench of the ITAT in the case of R.N. Ghiya v. Asstt. CIT (1995) 54 ITD 269and contended that section 132(4A) raises a presumption, though rebuttable, that the available article or thing found during the course of search in the possession or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... losed sources. 9. We have given a careful consideration to the rival submissions and to the facts and circumstances of the case. We find that in this case though the property under consideration was in dispute, yet as the assessee was having a Power of Attorney he could be treated as owner in view of the extended meaning of "owner" contemplated by the provisions of section 2(47). However, as the Capital Gains of ₹ 23 lakhs are proposed to be taxed on accrual basis, it is important to see whether there was a transfer within the meaning of section 2(47). Even before the Assessing Officer the assessee had taken the stand that M/s. Vishal Developers do not have any physical possession over the plot of land due to the non-availability of the right of way. In this regard a letter dated 29th July, 1997 (wrongly mentioned as dated 30-7-1997 by the Assessing Officer) from M/s. Vishal Developers was produced before the Assessing Officer along with 7/12 extract. The Assessing Officer has not proved that the transferee had taken possession of the property or otherwise became the owner of the property. On the other hand, looking to the evidence produced before the Assessing Off ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the order under section 158BC of the Act. 4. Even assuming for the sake of argument that any sum could be part of an assessment under section 158BC as a result of dealings with Mr. S.R. Dantal, the Assessing Officer erred in including the following in the figure of ₹ 78,34,000 - (i)Some amount allegedly being interest. (ii)An amount in excess of ₹ 20,00,000. (5) The Assessing Officer ought to have appreciated that there was no material in support of the case that an amount of ₹ 78,34,000 was the undisclosed income of the appellant and in fact all the available material was to the contrary." 11. The Assessing Officer has made addition of ₹ 78,34,000 on the ground that the source of the capital for financing the loans advanced by the assessee could not be explained and hence full amount of capital along with the interest amounting to ₹ 78,34,000 was added as assessee';s income from undisclosed sources. The relevant seized papers on which the addition is based, are page Nos. 104, 105 and 106 of Annexure A-1 (available at Exhibit-II to the assessment order). The relevant extracts from the Assessing Officer';s order are reproduced as und ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... A/8 the calculation for this deal is made with interest in the coded form. Same is decoded as under : 10000/00 25-2-1993 10,00,000 25-2-1993 5000/00 10-10-1993 5,00,000 10-10-1993 5000/00 1-12-1993 5,00,000 1-11-1993 Further on page 67 for calculation of interest as on 23-2-1993 ₹ 10 lakhs are shown as ₹ 10.00. Accordingly after the addition of interest, the amount with interest as on 30-9-1995 comes to ₹ 78,34,000. As the source of capital for financing this loan is not known, full amount of capital with interest is added as undisclosed income. The documents referred above are enclosed as exhibit." 12. The learned Counsel of the assessee invited our attention to page 364 of the Paper Book wherein the copy of affidavit of Shri S.R. Dantal is available. The relevant extracts from the aforesaid affidavit are reproduced as under : "I have further to declare that I have received ₹ 20,000 from Shri P.R. Patel on different dates and he promised to pay me the remaining amount within three months, but he has failed to make further payments. The amounts written on Page No. 3 as ₹ 10,00,000, ₹ 5,00,000 and ₹ 5,00,000 are ne ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Konkar please explain all the abovementioned agreements and documents ? A. :We have not entered into any monitory transaction with the above documents except ₹ 30,000 paid to Shri S.R. Dantal on different dates. Today we have given a copy of affidavit made by Shri S.R. Dantal in this connection. Q. 21 :Now I am showing you page No. 66 of file A/8. The date exactly tallies with the date mentioned in Indemnity Bond and date of different agreements as mentioned above. What you want to say about this ? A. :The diary serial No. A/8 was written by my Son-in-law Shri Arvind Patel. The basis on which he has maintained the diary is not known to me. As appearing on page No. 66 I have made the payments of ₹ 30,000 on different dates to Shri S.R. Dantal. To best of my knowledge the amounts written in diary is actual and there is no code or quoted figure." 12.2 Further to replies to question Nos. 20 and 21 by the assessee the learned Counsel contended that undisclosed cash, jewellery or shares/debentures were not found during the course of search. It was stated that this shows that the transactions shown by the seized documents/agreements did not materialise. The learned Co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessment order. It was stated that not only the figures tally, but the dates of receipt of the amounts by Shri S.R. Dantal also tally. The figures mentioned in the seized document available at page 360 are in coded language whereas the figures mentioned in the Indemnity-cum-Declaration are the normal figures and the learned Departmental Representative stated that this proves that the figures recorded in the seized document (copy of which is available at page 360 of the Paper Book) are in coded language. The learned Departmental Representative also relied upon the decision of Pune Bench of ITAT in the case of Parakh Foods Ltd. (supra). 14. We have given a careful consideration to the rival submissions and the facts and circumstances of the case. In the Indemnity-cum-Declaration (copy available at Exhibit-II to the assessment order) from S.R. Dantal to the assessee which is duly signed by Shri S.R. Dantal as Proprietor of M/s. S.R. Dantal, it is clearly stated that as agreed the assessee had already paid Shri S.R. Dantal the following amounts : ₹ 10 lakhs on 25-2-1993 ₹ 5 lakhs on 10-10-1993 ₹ 5 lakhs on 1-11-1993. It is stated in the said declaration that o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he affidavit cannot be rejected. In view of the documentary evidence found and seized from the assessee';s premises showing the transactions entered into by the assessee with Shri S.R. Dantal, not much evidentiary value can be given to the affidavit of Shri S.R. Dantal, which is a self-serving statement and goes against the documentary evidence seized during the course of search. 15. There is a receipt available in each of the Memorandums of Understanding for allotment of flat. One such receipt is reproduced as under : "RECEIPT Received from Shri/Smt. .......................................................................................................... ................................................................. a sum of ₹ 2,24,000 (Rupees Two Lakhs Twenty Four Thousand Only) IN CASH or vide Cheque No........... dated 24-4-1994 drawn on................., ............. Branch, as earnest money deposit as agreed above for the booking of a flat as mentioned above in the said proposed project. Promoter S.R. Dantal Sd. Promoter." Similar receipts are there for the other amounts, namely, ₹ 2,24,000, ₹ 2,24,000, ₹ 40,000, ₹ 5 la ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rovisions of other laws, like the Indian Evidence Act, e.g., section 110 of that Act. When a presumption can be so raised under the provisions of another law and the application of the provisions of such other law is not expressly prohibited by any statute including the statute under which the assessee is being proceeded against, such presumption cannot be termed as having been raised under section 132(4A) and, hence, not permissible at law. The evidentiary value of the incriminating evidence found and seized in the course of search proceeding should then be examined and judged not with reference to the provisions of section 132(4A) but the other provisions in the allied law which are applicable to the proceedings under the Act. Therefore, the incriminating evidence which was found and seized in the course of search could be used against the assessee without any reference to the provisions contained in section 132(4A), provided such evidence was found to be relevant and material for the assessment of the assessee and the same had been put to him before its use against him at his assessment(s). In holding the above view, we are fortified by the decision of the I.T.A.T. Jaipur Bench ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt order and also invited our attention to questions No. 32 and 33 put to the assessee in this regard. It was stated that the assessee denied having entered into any transactions pertaining to the said agreements. The learned Counsel also invited our attention to pages 261 and 278 of the assessee';s Paper Book, wherein the replies were filed with regard to these documents before the Assessing Officer and CIT respectively. The case of the assessee is that the agreements in question were given by Shreeganesh Developers to the assessee to raise finance for their project. However, according to the assessee, as the plot was reserved by Municipal Authorities for a garden, finance could not be arranged. It is further stated that apart from the said agreements, the Assessing Officer has no other evidence that the amounts in question were given by the assessee to Shreeganesh Developers. Reliance is placed upon the same decisions which are relied upon in respect of grounds of appeal Nos. 1 and 2. 20. The learned Departmental Representative invited our attention to the seized paper marked 84A and 84B, copy of which is available at page 396 of the Paper Book filed by the assessee. The lea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... osed with the assessment order as Exhibit-III. At the end of the each of the agreement for allotment of flat there is a receipt duly signed by Shri S.R. Dantal on behalf of Shreeganesh Developers acknowledging the receipt of the amounts of ₹ 3,21,000, ₹ 4,44,000 and ₹ 3,59,000 respectively. These agreements/receipts were found from the premises of the assessee during the course of search and hence it is the normal presumption, though rebuttable, that the assessee after making the payments in question to Shreeganesh Developers kept the receipts in his custody. The assessee has not been able to rebut this presumption. Therefore, we are of the opinion that the addition of ₹ 11,24,000 made by the Assessing Officer is fully justified. The decision of the Jaipur Bench of ITAT in R.N. Ghiya';s case (supra) supports the case of the Revenue. As the receipts duly signed by Shri S.R. Dantal on behalf of Shreeganesh Developers indicating that the payments were received by Shreeganesh Developers were found from the custody of the assessee, it is the normal presumption that the assessee had made the payments to Shreeganesh Developers, though the name of the other part ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... osed income of the assessee in this regard." 23. The next addition of ₹ 4,50,000 is based upon seized document marked as Page 190 of Annexure A-4, copy of which is enclosed at Exhibit- V to the assessment order. The seized paper is not signed by anybody but indicates the calculation of ';Vasai Profit';. There is also indication that the seized papers belong to M/s. K.C. Builders and the share of the assessee is ₹ 4,50,000. The assessee';s share in ';Vasai Profit'; is indicated at 50% of ₹ 9,000.00 and after de-coding the figures the Assessing Officer has assumed that the sum of ₹ 9,000.00 should really be read as ₹ 9 lakhs. 24. The learned counsel of the assessee has contended that neither the assessee or M/s. K.C. Builders have any property at Vasai. It was stated that M/s. K.C. Builders had a property at Virar which the partners were unable to sell. Moreover, it is stated that the share of the assessee in M/s. K.C. Builders is 30% and not 50%. It is further stated that the rough sheet is not in the handwriting of the assessee. The learned counsel of the assessee took us through paragraph 14 of the assessment order and also ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not accounted for in the regular books of account by K.C. Builders. We are inclined to accept the argument of the learned Departmental Representative that even if the assessee has no property at Vasai, he could be involved in any other business undisclosed to the department. As the paper is found from the custody of the assessee and bears the name of the assessee, it is the natural presumption that the paper belongs to the assessee, which indicates the ';Vasai profit'; and the assessee';s share therein. We also hold that the Hon';ble Supreme Court';s decision in V.C. Shukla';s case (supra), which pertained to the criminal proceedings is not relevant in the Income-tax proceedings, which are not strictly governed by the Rules of evidence as per the Indian Evidence Act. We also hold that the profit is not worked out on any presumption but it is based upon the seized incriminating paper. We, therefore, uphold the addition of ₹ 4,80,000. The appeal of the assessee, therefore, fails on this point. 27. The ground No. 9 reads as under : - "9. The Assessing Officer erred in holding that a sum of ₹ 5,16,500 allegedly being undisclosed rent income of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rty are not admissible, firstly on the ground that the assessee had not made this submission as a ground in the original ground of appeal and no additional ground should be admitted and secondly, as per section 158BC, no deductions are admissible. 31. We have given a careful consideration to the rival submissions and the facts and circumstances of the case. The argument of the assessee that he does not own any property from which such huge rent can be received, has not been dislodged by the Assessing Officer nor any material has been brought out by him to link the seized paper with the rental income of the assessee. The seized rough sheet does not bear the name of the assessee nor does it indicate the name or address of the property from which the rent is alleged to be received. It seems to be working of the proposed project only. Therefore, keeping in view the various decisions quoted by the assessee, we hold that the addition cannot be made on the basis of rough/loose sheet, which cannot be linked to the source of income of the assessee. We, therefore, delete the addition of ₹ 5,16,500 made by the Assessing Officer. As the addition has been deleted by us, the additional gr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nterest. The alternative argument of the learned Counsel of the assessee that if at all the addition has to be made, it should be of the figures mentioned in the seized papers, is not acceptable as de-coding has to be done in respect of the figures mentioned in the coded language. As pointed out by the Assessing Officer in para 6 of her order, the assessee has admitted that the entries are made in the coded language. Therefore, we are of the opinion that the amount mentioned as ₹ 4,496.52 in the seized paper is in fact the amount of ₹ 4,49,652 as interpreted by the Assessing Officer. The decisions relied upon by the learned Counsel are distinguishable in facts as the seized papers here are not dumb papers, but they indicate the amounts, dates and the calculation of interest, on the amounts concerned. As the papers are seized from the custody of the assessee, we are of the opinion that the Assessing Officer is not wrong in presuming that they relate to the assessee himself. We are of the opinion that the incriminating evidence, which is found and seized in the course of search, could be used against the assessee without any reference to provisions contained in section 13 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ended that, if at all, the addition is to be made, it should be made in the hands of the firm and not in the hands of the individual partner. The learned Counsel of the assessee further contended that it can be seen from the seized paper that the Balance Sheet is not tallied and hence the reliability of the same has to be doubted. 39. We have given a careful consideration to the rival submissions and to the facts and circumstances of the case. We are of the opinion that as some of the figures in the seized paper tally with the declared Balance Sheet of M/s. Gem Builders as on 31-3-1993, the seized paper cannot be brushed aside as not relevant to the assessment of the assessee. It shows the capital account of the assessee, who is a partner in M/s. Gem Builders. As the source of the capital has not been explained by the assessee, we are of the opinion that the Assessing Officer was justified in making the addition. However, as the capital to the extent of ₹ 1,64,818 has been declared in the Balance Sheet of M/s. Gem Builders as on 31-3-1993, we feel that the addition has to be reduced by this figure. We, therefore, restrict the addition to ₹ 26,58,590 (Rs. 28,23,408 minu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y confronted with this paper. Relying upon the decision of the ITAT, Jaipur Bench in the case of R.N. Ghiya (supra) the learned Departmental Representative contended that the addition made should be confirmed. 43. We have given a careful consideration to the rival submissions and the facts and circumstances of the case. Though the seized paper does not bear the assessee';s name, yet as it is found from the custody of the assessee, it was for him to explain the entries made therein. The assessee has been duly confronted with the seized paper, but rather than explaining the entries therein, the assessee has given only evasive reply. As the seized paper gives details of the advancing of amount of ₹ 2 lakhs on interest and the working of interest has also been given on the seized paper, we are of the opinion that the Assessing Officer was within her right to presume that the amount was advanced by the assessee and the interest to the extent of ₹ 56,256 was also charged by the assessee. Though this paper does not bear the assessee';s name, yet it gives the amounts and the dates and the working of the interest. Therefore, this paper cannot be called a dumb paper. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eivable from one Mr. Jain from 10-4-1988 to 22-6-1988. It has been stated that since the assessee could not explain this amount, the same was added as assessee';s income from undisclosed sources. 49. The learned Counsel of the assessee contended that the assessee does not know any Mr. Jain. It is further stated that no amount has been advanced on interest to any such person. Without prejudice to these arguments, it is stated that only a sum of ₹ 2,000 has been shown against the name of Jain. It is also contended that the seized paper is not in the handwriting of the assessee and hence the assessee is not liable to explain the entries made therein. 50. On the other hand, the learned Departmental Representative contended that the paper is seized from the custody of the assessee and some definite calculation of interest has been made therein date-wise aggregating to ₹ 25,000. It is contended that as the assessee could not satisfactorily explain the entries made in the seized paper, the addition made is justified and should be confirmed. 51. We have given a careful consideration to the rival submissions and the facts and circumstances of the case. The scrutiny of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t are the calculations in the said paper. Without prejudice to this argument, it is contended by the learned Counsel that the amount mentioned in the second sheet which is the reverse page of seized paper is ₹ 6,029.88 and not ₹ 6,02,988. It is stated that front page of the loose paper (page 418 of the Paper Book) is the copy of account of a party of Gem Builders (P.) Ltd., where TDS has also been deducted. Hence, according to the learned Counsel, no additions can be made in the assessee';s hands. 55. The learned Departmental Representative invited our attention to Annexure A-4 to the assessment order and pages 418 and 420 of the assessee';s Paper Book. It is contended that the loans have been advanced by the assessee out of the undisclosed income on which interest has been received. Therefore the interest received has to be treated as undisclosed income of the assessee. 56. We have given a careful consideration to the rival submissions and the facts and circumstances of the case. As the assessee was duly confronted with the seized paper found from his custody, we are of the opinion that he was liable to explain the entries made therein. The natural presumptio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are also available at pages 422 and 424 of the Paper Book. The English translation of these copies are also available at pages 423 and 425 of the Paper Book. These seized papers contain certain calculation of interest on the basis of which the Assessing Officer has made additions as the assessee';s income from undisclosed sources because the assessee could not explain the entries in the seized papers. 59. The argument of the learned Counsel of the assessee is that the papers are not in assessee';s handwriting and the assessee does not know what are the calculations and they pertained to whom. Without prejudice to this argument, it is also contended that the amount in the seized papers which are written as ₹ 6,720.04 and ₹ 5,262.38 should be read as such and not ₹ 6,72,004 and ₹ 5,26,238. On the basis of the same reasons as given in the preceding grounds of appeal pertaining to loose papers, we confirm the additions made by the Assessing Officer. 60. Grounds No. 17, 18 and 19 read as under : - "17. The Assessing Officer erred in treating amounts of ₹ 2,61,769 and ₹ 16,67,922 as undisclosed income of the appellant includible in the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (b)Dipesh Daga v. Asstt. CIT 26 ITC 180 (Indore), (c)Sitadevi Daga v. Asstt. CIT 26 ITC 122 (Indore), (d)Salvi Divashnka IT(SS) A No. 79/PN/1997. The learned Counsel of the assessee also contended that advance-tax has been paid in respect of the assessment years 1994-95 and 1995-96 (as per details given at page 512 of the Paper Book) and hence this income should be treated as disclosed and not added in the block assessment. It is further contended that on the dividend income tax of ₹ 4,477 has also been deducted at source. 63. On the other hand, the learned Departmental Representative contended that provisions of section 158BB are very clear and as per sub-clause (c) of sub-section (1) of section 158BB, the income in respect of the assessment years has to be added in the block assessment where the due date for filing of the returns of income had expired but no returns of income were filed. It is also contended that the assessee did not have any income which was subject to TDS and hence the case laws relied upon by the assessee are distinguishable. It was stated that the assessee';s returns are much above the taxable limits. The learned Departmental Representative also ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r income in the normal assessments under section 143(3) or section 144 or section 143(3)/144 read with section 147. The Assessing Officer is, therefore, directed to delete such income from the block assessment. 64.2 Once the income is assessed in the regular assessment and not under block assessment, we are of the opinion that the assessee will be entitled to the normal deductions, like, Standard Deduction in respect of salary income and Chapter VI-A deductions from the gross total income. The capital gains, if included in the income assessed in the regular assessment, will also be subject to deductions at the rate of 20% as per law. 65. Ground No. 20 is of general nature and no comment or adjudication is needed for the same. 66. The additional grounds A-1 and A-2 are of general nature and no adjudication is required in respect of the same. 67. The additional ground No. B-3 relating to statutory deductions from rental income has already been dealt with along with ground No. 9 and hence no further discussion is required in respect of the same. 68. Ground No. D-7 is of general nature and hence no adjudication or discussion is required in respect of the same. 69. Ground Nos. C-5 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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