9911796707
TMI Blog2011 (7) TMI 1180X X X X Extracts X X X X X X X X Extracts X X X X ..... issue in Revenue's appeal in IT(SS)A Nos. 19 to 21/Kol/2011 is as regards to orders of CIT(A) deleting additions made on account of alleged on-money receipts for on-going projects amounting to Rs. 2,58,64,762, Rs. 1,73,16,880 and Rs. 64,83,07,492 for the asst. yrs. 2006-07, 2007-08 and 2008-09 respectively, relying on project completion method of accounting followed by assessee company. For this, Revenue has raised common and identically worded grounds, except amount. Following three grounds raised in asst. yr. 2008-09 are being reproduced, as it is and will take facts and figures from this year only and will be decided far all three years on that basis. "1. That, on the facts and circumstances of the case, learned CIT(A) has erred in both law and facts in deleting the addition of Rs. 64,83,07,492 on account of undisclosed income arising out of receipt of on-money from various projects. 2. That, in doing so, learned CIT(A) erred in putting emphasis on the project completion method of accounting ignoring the fact that books of account of the assessee company were rejected. 3. That, the learned CIT(A) failed to appreciate that on-money received in-respect of various projec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pounded Office premises of M/s Fort Projects (P) Ltd. at 7/1A Hazra Road, Kolkata-26 PC/1 to PC/3 Office premises of M/s Fort Projects (P) Ltd. and M/s Fort Builders at 38/1 Panditya Road, Kolkata-29 FP/1 to FP/11,FP/CD-1.FP/CPU/1 Office premises of M/s Fort Projects (P) Ltd. at 59C Chowringhee Road, Kolkata and 297/1A Hazra Road, Kolkata-26 GB/1 to GB/17, GB/CPU/1 During search at the residential premises of Sri Vivek Kumar Kathotia, director of company, documents, computer printouts etc. marked RM/1 to RM/4 were found and seized and papers marked RM 5 containing details of on-money receipts of assessee company in respect of flats in three projects namely (i) 20 Lee Road, Kolkata (ii) 22 Lee Road, Kolkata and (iii) 68 Hindustan Park, Kolkata were also found and seized. On the basis of seized document RM-5 a disclosure of Rs. 9.02 crores was made by assessee, whereas the allegation of assessee was that said seized documents were forcibly manufactured by Department at the time of search and seizure action in case of Sri Vivek Kumar Kathotia and he was forced by search party to write the said seized documents and make an exorbitant disclosure of Rs. 9.02 crores on the basis of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... admittedly received such rate from this flat, including on-money, in the project, there is no reason why the same rate was not received in respect of the other flats in the same project. The assessee has not disclosed any on-money in respect of most of the flats. The rates accounted for are different in most of the cases. There is no reason for variation of square foot rate in the same project. As per the details in pp. 56 and 57, the total amount of flat Nos. 2A, 2B, 3A, 3B, 3C, 3D, 4C, 4D, 5A, 5B, 5C and 5D, which were allocated to the buyers as well as from which on-money receipts are evidenced by RM/5 is Rs. 284.18 lakhs. The total amount @ 6,611 per sq. ft. works out to Rs. 14,41,99,132. The assessee has accounted for Rs. 6,20,16,500 on account of those flats. Besides, the assessee has disclosed on-money receipt totalling Rs. 2,87,18,000 from some flats as per RM/5. The balance amount, therefore, works out to Rs. 14,41,99,132 minus Rs. 6,20,16,500 minus Rs. 2,87,18,000 = Rs. 5,34,64,632. In view of the seized documents and the facts as stated above, the books of account of the assessee are not correct and complete and as such the same are rejected and the balance amount of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e foot for the flat No. 6B the total amount is Rs. 2,18,32,000 for total 2,729.ft. of flat. The rate works out to Rs. 8,000 per sq. ft. When the assessee admittedly received such rate from the flat, including on-money, in the project, there is no reason why the same rate was not received in respect of the other flats in the same project. The assessee has not disclosed any on-money in respect of most of the flats. The rates accounted for are different in most of the cases. There is no reason for variation of square foot rate in the same project. As per the details in pp. 51 and 52, the total area of flats is 86,987 sq. ft. The total 'area allocated to landlord is 19,684 sq. ft. Therefore, the assessee's share is 67,303 sq. ft. The total amount @ 8,000 per sq. ft. works out to Rs. 53,84,24,000. The assessee has accounted for Rs,4,39,84,900 as evident from p. 52 of GB/17. The assessee has disclosed on-money receipt totalling Rs. 3,56,66,000 from three flats as per RM/5. The balance amount, therefore, works out to Rs. 45,87,73,100 [Rs.53,84,24,000 minus (Rs.4,39,84,900 plus Rs. 3,56,66,000)]. In view of the seized documents and the facts as stated above, the books of account ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r documentary or circumstantial, pertaining to receipt of on-money for other flats in these three projects or other projects were found in course of search or survey operation and AO was thus completely unjustified in extrapolating on-money to the balance flats in these three projects merely on the basis of disputed seized loose papers and making an exorbitant addition of Rs. 64.83 crores on the basis of surmises and conjectures. However, assessee contended that CIT(A) was correct to the extent of holding that assessee was regularly following project completion method of accounting and these three projects were incomplete till asst. yr. 2008-09, no receipt, whether in cheque or cash was taxable for asst. yr. 2008-09. 5. We have heard rival contentions and gone through facts and circumstances of the case. First of all we have gone through the seized document RM/1, which is reproduced on p. 2 of the assessment order, which is again being reproduced for the sake of clarity, as under: Page No. of RM/5 Name of project Flat No. Area Name of buyer On money received in cash 1. 68 Hindustan Park 3493 sq. ft Smt. A.Das 91.32 lakhS 2. -do- 1778 sq.ft Smt. N. Ku ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ch party at the time of the search but were found from the possession and control of assessee in the course of search. As such, the presumption under s. 292C regarding the correctness of the contents of seized documents applies to RM/5 also. Further, it is assumed that the presumption regarding the correctness of contents of seized documents under s. 292C is applicable to KM/5, the said presumption is rebuttable and assessee unsuccessfully tried to rebut the presumption under s. 292C by pointing out defects/mistakes in RM/5, but unable to do the same by any cogent evidence. Accordingly, we have to accept the seized document RM/5 as correct and true. 6. When we have assumed that assessee was bound by the presumption under s. 292C in respect of the contents of seized documents marked as RM/5, the addition of Rs. 64.83 crores is also unsustainable because no corroborating document or evidence whatsoever was found in the course of search or survey action in support of addition of Rs. 64.83 crores. The said figure of Rs. 64.83 crores was arrived at by the AO by extrapolating the notings in RM/5 to all the other flats in three projects. We are of the view that AO was not justified in ex ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be determined only on completion of projects/The conduct of search and seizure operation in a particular year did not lead to an inference that undisclosed income detected as a consequence thereof had to be taxed in the assessment year relevant to previous year in which the search was conducted but accounting profits have yet to be made on the basis of method of accounting followed by assessee. Therefore, we agree with the findings of CIT(A) that assessee was following project completion method of accounting, therefore all the amounts whether allegedly received in cash or by cheque were taxable in the years in which the projects were completed. In regard to extrapolating of noting in RM/5, the same cannot be applied to other projects, because on-money would fructify into income or partake the character of income only in the year of completion of project in accordance with project completion method of accounting followed by assessee. The undisclosed income, if any, had to be computed in accordance with the method of accounting followed by assessee and not in the year of receipt in accordance with cash system of accounting. We find that Hon'ble Bombay High Court in the case of CI ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , in the matter of the second addition, the AO has worked out the said addition on the basis of excess of stock which finding is contrary to the finding of the AO while computing the closing stock. Under the above circumstances, the Tribunal was right in allowing the appeal. 7. Further, Hon'ble Rajasthan High Court in the case of CIT vs. Rajendra Prasad Gupta (2001) 166 CTR (Raj) 83: (2001) 248 ITR 350 (Raj) wherein Hon'ble High Court observed that under the scheme of provisions for block assessment it is apparent that it related to assessment of "undisclosed income" of assessee excluding incomes subjected to regular assessment in pursuance of returns filed by assessee for such period. and further observed that a perusal of s. 158BB of the Act makes it clear that returns are required to be filed in pursuance of a notice under s. 158BC(a) and assessment has to be framed on that basis in the light of material that had come into possession of assessing authority during the course of search which was the foundation of proceedings. The, correctness or otherwise of the returns filed in pursuance of the notice under s. 158BC(a) has to be examined with reference to the material in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... facts. No substantial question of law arises. Hence, the appeal is dismissed." 9. We find that even Hon'ble apex Court in Dhakeswari Cotton Mills Ltd. vs. CIT (1954) 26 ITR 775 (SC) laid down principle regarding estimation that while making assessment under s. 23(3) of the IT Act 1922, the ITO is not fettered by technical rules of evidence and pleadings, and he is entitled to act on material which may not be accepted as evidence in a Court of law, but he is not entitled to make a pure guess and make an assessment without reference to any evidence or any material at all. There must be something more than bare suspicion to support assessment under s. 23(3). Hon'ble apex Court on facts of the case held that both ITO and Tribunal in estimating the GP rate on sales of the assessee did not act on any material but acted on pure guess and suspicion and therefore it was a fit case for the exercise of the power of the Supreme Court under Art. 136 of the Constitution of India. The Hon'ble apex Court held as under: "As regards the second contention, we are in entire agreement with the learned Solicitor General when he says that the ITO is not fettered by technical rules of evide ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... de not to employ unnecessary haste and show impatience, particularly when it was known to the Department that the books of the assessee were in the custody of the Sub-Divisional Officer, Narayanganj. We think that both the ITO and the Tribunal in estimating the GP rate on sales did not act on any material but acted on pure guess and suspicion. It is thus a fit case for the exercise of our power under Art. 136." 10. In the present case before us, we find that assessee was following project completion method of accounting and these projects were incomplete during the year under consideration. Even if it is assumed that AO was justified in extrapolating the noting in RM/5, no income from other projects could be recognized for asst. yr. 2008-09. We are of the view that on-money would fructify into income or partake the character of income only in the year of completion of the project in accordance with the project completion method of accounting followed by the assessee. The AO was not justified in extrapolating few notings of RM/5 to balance flats of other three projects given that no incriminating evidence pertaining thereto was found during the course of search and even authenticit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s of account. The AO taxed the same as' income in the year of receipt ignoring the method of accounting followed by the assessee. Tribunal observed as under: The amount received by cheque by the assessee was shown in the liability side of the audited balance sheet filed by the assessee. The AO himself has observed in the assessment order for the relevant asst. yr. 1992-93 that the amount of Rs. 37,79,234 as per the audited balance sheet was shown as "advance from parties' and no adverse action on this amount has been taken by the AO. We find that although the assessee has not accounted for the amount of Rs. 36,17,453 received in cash from the prospective buyers in its accounts, but it shall not change the characteristic of the amount received by the assessee which remains an advance from the parties only. No flat was sold during the relevant period. We find that the payees of these amounts in cash were not examined by the AO to find out whether the amount represents some other nature and not advance from the payees for the purchase of flats. It is not the case of the Department that the identity of the payees of the advance money in cash or the genuineness of the transact ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... umar Kathotia in IT(SS)A Nos. 4 to 7/Kol/2011 of assessee's appeals, wherein vide para 15 to 17, we have held under: "15. We find that the term 'used' in the provision of s. 292C of the Act 'may be presumed' is discussed, but in the context of s. 132(4) of the Act, by Hon'ble apex Court in the case of P.R. Metrani (supra) and said term implies that the presumption is rebuttable. The term 'rebut' means to disprove. In other words, unless contrary is proved, what is stated in the seized documents has to be presumed to be true and thus, the provisions of s. 292C of the Act do not confer discretionary power on the Department to presume or not to presume the correctness of seized documents held by CIT(A). We find that CIT(A) observed that s. 292C of the Act is not for the benefit of the assessee but it is for benefit of Department. We are of the view that the provision will equally apply to both assessee as well as Department and s. 292C of the Act only creates a legal fiction, whereby in case of search and seizure, contents of seized material are presumed to be true unless rebutted by the party claiming contrary. Now, we are of the view that onus of re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gold and the rates of purchase and sales, the dates of purchase and sales have been mentioned. Further, in respect of paintings, minute details such as the exact size of the paintings and the names of the artists have also been mentioned in the seized documents. Thus, these are speaking documents and not dumb documents. A dumb document is a document which doesn't speak for itself and not a self-explanatory and detailed document like present one. Further, going through these documents it is revealed that these documents also record several regular transactions of the assessee which stand duly disclosed in regular books of account. The assessee has cited few examples in his written submissions of transactions of disclosed/regular nature found recorded in RM/1 are as under: Date Particulars of transactions 2-12-2002 Payment of Rs. 12,65,322 in the books of Ramani Projects on account of registration, stamp duty etc. to Registry office 15-2-2002 Payment of Rs. 11,15,514 in the books of Ramani Projects to KMC 30-3-2006 Cash withdrawn of Rs. 16,00,000 and Rs. 25,00,000 from Andhra Bank belonging to Salasar Mahanirman (P) Ltd. Similarly several other notings pertaining to wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee in reply to question No. 8 of his statement recorded on oath under s. 132(4) on 14th March, 2008, pp. 101 to 102 of assessee's paper book referred by learned counsel, wherein he stated that the gold after purchase was kept at various locations and this explains the reason why the remaining 2 kgs. of gold was not found in course of search at the residential premises of the assessee. Even during the course of search, in regards paintings, assessee admitted vide question No. 15 on the date of search that the same were on display at his residence and the same question No. 15, pp. 104-105 of assessee's paper book/is reproduced as under: "Ans 15. I am fond of paintings and have been collecting them for my personal purpose to display in my residence from year 1993. I got bored of having the same paintings in the house for so long and therefore decided to sell the old ones and purchased new ones to display in the residence which were also on display in the residence on the date of search. In view of these facts, we are of the opinion that RM/1 and RM/2 were a day-to-day account prepared by assessee and discovered as a result of search and the contents therein had to be pre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y to what extent the mind of the Court was affected by the irrelevant material used by it in arriving at its finding. Such a finding is vitiated because of use of inadmissible material and hence decision in such situation is based on conjectures, surmises and suspicion. Hence, we consider documents found from the possession of the assessee during the course of search were real and declaration made by assessee on the basis of entry recorded in these documents of long-term capital gain on account of sale of gold and diamonds and also receipts on account of sale of paintings are true and there is no basis not to accept the same. Accordingly, we delete the addition made by CIT(A) of Rs. 6.009 crores and Rs. 90 lacs for asst. yrs. 2006-07 and 2007-08. This interconnected issue of the assessee's appeals is allowed." Accordingly, out of these interconnected issues, the issue of assessee's appeals in IT(SS)A Nos. 11 to 13/Kol/2011 is dismissed. The interconnected issue of Revenue's appeals in IT(SS)A Nos. 19, 20 and 2 l/Kol/2011 is also dismissed. 11. Even we find from the records and arguments of both the sides that there are several mistakes and calculation errors having an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on pp. 7 and 8 of the assessment order under s. 144/153C for asst. yr. 2008-09, the AO committed the following errors: The AO has taken the total area of fiats sold at 54,008 sq. ft. (78,290 sq. ft. minus 24,282 sq. ft. (allocated to landlords). However, the area of flats allocated to the landlords was only 19,246 sq. ft. Further, the AO failed to appreciate that the flat mentioned against Mr. Vivek Agarwal (5,036 sq. ft.) was not sold to him. Mr. Vivek Agarwal was just a tenant in the showroom space and thus, he was paying rent to the appellant. Thus, the question of receiving any on-money from him did not arise. Further, flat No. 501 having an area of 2,518 sq. ft. was still lying in stock (as per noting on p. 52 of GB/17). Thus, the area of flats sold in 20, Lee Road works out to 51,490 sq. ft. (78,290 sq. ft. minus 19,246 sq. ft. minus 5,036 sq. ft. minus 2,518sq. ft). Thus the total amount at the alleged rate of 4,995 per sq. ft. works out to Rs. 25,71,92,550 (i.e. 51,490 x Rs. 4,995). In respect of the flats sold, the assessee has accounted for Rs. 9,77,88,200 (i.e. Rs. 13,30,40,200 minus Rs. 2,51,80,000 (Vivek Agarwal) minus Rs. 1,00,72,000 (stock)]. Thus, after reducing t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... been completed arid assessee is following project completion method, therefore, only the calculation errors (supra) committed by AO in respect of all the aforesaid three projects can be rectified by AO. For these years this exercise will be academic only, because we have already upheld the order of CIT(A) deleting addition. 12. The next common issue in these appeals of Revenue in IT(SS)A Nos. 15 to 20/Kol/2011 is in regard to deletion of addition on account of alleged on-money for asst. yrs. 2002-03 to 2007-08. In IT(SS)A No. 12/Kol/2001 for asst. yr. 2007-08 assessee is also aggrieved by the order of CIT(A) confirming the addition of undisclosed income on receipt of on-money in respect of project Fort Royal completed during the year under consideration. For this, assessee has raised the following ground No. 5: "5. That on the facts and in the circumstances of the case, the learned CIT(A) erred in confirming addition of undisclosed income by way of so-called receipt of on-money on flats in respect of the 'Fort Royal' project of the appellant company completed during the year under consideration at Rs. 39,95,243." Revenue in IT(SS)A Nos. 15 to 20/Kol/2011 for asst. yrs. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 14,57,000 14,57,000 Tower- 1 2006-07 19,61,520 19,61,520 Tower-2 2006-07 1,52,63,360 1,52,63,360 Block- 1 2006-07 2007-08 22,06,000 76,97,354 99,03,354 Block-2 2006-07 7,08,240 7,08,240 Oasis Block-4 2006-07 2007-08 9,42,500 27,57,810 37,00,310 Oasis Block-5 2005-06 2007-08 8,13,780 97,00,069 1,05,13,849 Oasis Block-7 2007-08 11,56,890 11,56,890 Before CIT(A) assessee argued that Ramani Project, Fort Point, Block-1 and Block 2, Tower-I and Tower-2 did not belong to the assessee company and as such, no addition could be made in the hands of assessee, as AO failed to appreciate that Ramani Project belonged to Ramani Projects (P) Ltd., Fort Point belonged to Balaji Grih Nirman (P) Ltd, and Tower-I and II, Block-I and 2 belonged to partnership firm M/s Fort Builders which were companies/partnership concerns distinct from assessee-company. Accordingly CIT(A) after verification of aforesaid facts deleted additions aggregating to Rs. 3,57,44,734 made in respect of Ramani Project, Fort Point, Tower 1 and 2 and Blocks 1 and 2 for the respective years as pertaining to separate taxable entities. Departmental ground challenging deletion of additions in respect of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rence on account . of different variables like location, time of booking, mode of payment, market fluctuations, extra fittings etc, hence, he held that AO was not justified in charging highest rate as base rate for making estimation and rejected books of account and arbitrarily estimated profit of the project @ 6 per cent of the total expenditure. CIT(A) worked out undisclosed income from the said project at Rs. 39,95,243. He thus made an addition of Rs. 39,95,243 as alleged undisclosed profit from Fort Royal project for asst. yr. 2007-08 as against Rs. 52,06,392 estimated by the AO for the said project for asst. yrs. 2003-04 and 2006-07. 14. We have heard rival contentions and gone through facts and circumstances of the case. We find that assessee has challenged addition of Rs. 39,95,243 made by CIT(A) for asst. yr. 2007-08 on account of estimated undisclosed profit for Fort Royal project. As shall be clearly evident from facts on record, this addition is not based on any incriminating evidence discovered as a result of search in respect of receipt of on-money for Fort Royal project or any of aforesaid projects. The CIT(A) doubted the profit disclosed by assessee for the said pro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e explanation, we are of the view that decision to sell a particular flat at a particular price was taken out of commercial expediency and on valid grounds and cannot be randomly doubted by Department in the absence of any tangible evidence to show that the same did not depict the actual state of affairs. Even otherwise, under taxing system, it is for the assessee to decide how to conduct the business. The Revenue cannot justifiably claim to put itself in the armchair of businessman and judge how business should be conducted or at what price a particular product should be sold. Hence, we are of the view that in the absence of conclusive evidence suggesting receipt of on money by assessee, prices at which flats were sold to purchasers vide duly executed agreement cannot be doubted and moreover, flats were sold to known and identifiable party at the rate mentioned above as per duly executed agreement. The agreements with the buyers of the flats were part of regular records and could have very well been verified by the AO and CIT(A). ' Accordingly, we have no hesitation in deleting the addition made in respect of Fort Royal projects for asst. yr. 2007-08. In regard to Revenue's ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd can be allocated to specific projects are included in WIP. However, costs that relate to the activities generally, or that relate to project activity but cannot be related to specific projects are debited in the P and L a/c as period costs. The assessee to elucidate this argument filed details of WIP for these assessment years and copies are filed at pp. 138-205 of assessee's paper book. From these details, it is verified that all the costs directly related to specific projects e.g. raw materials, carriage, labour charges, license, electricity charges, equipments, material and delivery charges, maintenance charges, motor car expenses, postage, printing and stationery, security charges, site development and cleaning charges, staff welfare, advance, travelling, transportation etc. are included in WIP. Further costs attributable to contract activity in general such as general expenses, insurance, construction overheads etc. are also allocated to specific contracts and included under WIP. Further, on a perusal of financial statements filed along with returns of income, we find that only costs which cannot be attributed to contract activity such as various general administration ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e framing assessments under s. 144/153C for the said years, under identical circumstances vis-a-vis past, the AO opined that a part of such expenses and interest should have been capitalized to WIP. Accordingly, the same was added back by the AO under s. 144/153C merely on the basis of change of opinion in the guise of search assessment. Hence, CIT(A) has rightly deleted this addition. Accordingly, these two common issues of Revenue's appeals in IT(SS)A Nos. 15, 16, 17, 18, 19, 20 and 21/Kol/2011 are dismissed. 18. The next issue in IT(SS)A No. 19/Kol/2011 of Revenue's appeal for asst. yr. 2006-07 is as regards to the order of CIT(A) deleting the addition made by AO on account of loan received from Toplight Vinimay (P) Ltd. For this, Revenue has raised following ground No. 4: "4. That on the facts and circumstances of the case learned CIT(A) erred both in facts and in law in deleting the addition of Rs. 10 lakhs on account of cash credit overlooking the fact that the paper trail was created to make the transaction look genuine which is otherwise bogus." 19. The brief facts are that assessee during financial year 2005-06 had received a sum of Rs. 10 lakhs as loan from To ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted P and L a/c of M/s Toplight Vinimay (P) Ltd. for the year ending 31st March, 2006-pp. 219-222 of the paper book. . (iv) Extract of bank book and bank statement in ABN-AMRO Bank of M/s Toplight Vinimay (P) Ltd. showing payment of Rs. 10 lacs to M/s Fort Projects (P) Ltd. on 23rd Feb., 2006 -pp. 223-224 of the paper book. (v) Confirmation of account relating to loan of Rs. 10,09,123 (including receipt of Rs. 10 lacs in cheque) from M/s Toplight Vinimay (P) Ltd. p. 225 of the paper book. We find that Toplight Vinimay (P) Ltd. is assessed to income-tax and loan was received through banking channel and disclosed in the financial statements filed along with returns of income both by assessee and Toplight Vinimay (P) Ltd. We find that AO for making addition referred to some enquiry conducted by the Investigation Wing against some Champal Lal Mittal and his associated bank accounts. The AO further observed that huge amount of cash had been deposited in certain bank accounts of Sri Mittal from where entire amount was transferred by cheques to various accounts in ABN-AMRO Bank and so on. After crossing five to eight intermediary layers, amounts were deposited in bank accounts of dif ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
