TMI Blog2016 (11) TMI 1239X X X X Extracts X X X X X X X X Extracts X X X X ..... sun glasses, Uktamal, perfumes, watches etc. - Held that:- The main grievance of the assessee is that 7% deduction given by the AO on account of bargain which has been upheld by the CIT(A) is very low since these are of fancy items and with the arrival of latest designs these items become obsolete and the assessee allows higher bargaining. It is also the submission of the Ld. Counsel for the assessee that the assessee gives higher discount to VIP and privileged customers. While we find some force in the above argument of the Ld. Counsel for the assessee, however, the plea to allow 25% reduction for bargaining appears to be very high whereas the 7% allowed by the revenue appears to be slightly low. Considering the totality of the facts of the case, we direct the AO to allow 15% reduction on account of bargain as against 7% considered by him which has been upheld by the CIT(A). The AO is directed to recompute the addition accordingly. Addition of unaccounted stock - Held that:- No reason in the order of the CIT(A) that shortages are there because of the unaccounted sales carried out by the assessee regularly. Since he has not appreciated that for the unaccounted sales separate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g justifying the addition made by the AO and since the Ld. Counsel for the assessee could not controvert the factual findings given by the CIT(A), therefore, we do not find any infirmity in the order of the CIT(A) on this issue - Decided against assessee Addition on account of excess stock of gold - Held that:- We find the CIT(A) accepted the genuineness of the bill on the ground that the bill issued by M/s. H. Kumar Gems International to the assessee was found in the assessee’s premises. Shri Anil Ranka and Shri Omprakash Ranka had also purchased jewellery from the said party which were duly recorded in their books before the date of search. Therefore, the AO should not have disbelieved the bill issued to M/s. Ranka Jewellers Pvt. Ltd. i.e., the assessee. Further, M/s. H. Kumar Gems International had accepted that the jewellery was sold to the assessee and the sale was found recorded in his books of account. M/s. H. Kumar Gems International has given their confirmation. M/s. H. Kumar Gems International is a registered dealer in State and Central Sales Tax Act and the sales tax on this transaction has been paid by M/s. H. Kumar Gems International which are regularly assessed to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Assessee : Shri S.U. Pathak For The Revenue : Shri A.K. Modi ORDER PER R.K.PANDA, AM : These are Cross appeals. The first one is filed by the Assessee and the second one filed by the Revenue and are directed against the order dated 09-04-2012 of the CIT(A)-I, Pune relating to Block Period 01-04-1996to 24-10-2002. For the sake of convenience, these were heard together and are being disposed of by this common order. 2. Facts of the case, in brief, are that the assessee is engaged in the business of manufacturing and sale of Gold and Diamond jewellery and also deals in Silver articles. A search action u/s.132(1) of the I.T. Act was conducted on 24-10-2002 at the business premises and the residential premises of the Directors, i.e. entire Ranka Jewellers group along with some of their trusted employees and persons from whom the group makes purchase etc. During the course of search at the business premises at Laxmi Road, Gold jewellery weighing 14032.700 gms valued at ₹ 70,11,529/-, Diamond jewellery valued at ₹ 18,95,786/-, Silver articles weighing 22.781 kg valued at ₹ 1,76,553/-,Gems valued at ₹ 8,33,683/-, Sunglasses valued at ₹ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d CIT(A) erred in holding that the asst. u/s 158BC(c) was valid in law (Page 156 to 158 of CIT(A)). 1.1 The learned CIT(A) failed to appreciate that: a. The asst. is barred by limitation as the search was prolonged unreasonably without justification. b. The seizure of Gold ornament and diamond ornament has been made out of stock which is not kept in the prohibitory order. c. The seizure of ornaments was made prior to reconciliation of stock and without giving proper opportunity to explain. d. The seizure of ornaments was made even though there was no excess in the stock. e. The prohibitory order was only for one room in which no ornaments were kept. 2. The learned CIT(A) erred in holding that there was an excess stock of Gems of ₹ 5,27,733/- on the basis of the average of the two valuations done by the valuers and accordingly, he erred in sustaining the above addition. (page No. 92 of CIT(A)) 2.1 The learned CIT(A) failed to appreciate that a. In reality, there was no excess stock of Gems found during the search and hence, no addition was required to be made on that account. b. Without prejudice, the registered valuer Shri Parag Gadgil had valu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in restoring the matter to the A.O. when he himself has accepted on page 108 of his order that the claim of the appellant was reasonable and correct and also that the special auditor has also opined that the claim of the appellant was acceptable. 4.3 The learned CIT(A) was not justified in not giving a finding on the contentions of the appellant in this context. He further erred in not giving the telescopic benefit of the addition against the unaccounted income. 5. The learned CIT(A) erred in extrapolating the unaccounted sales for the entire block period instead of restricting the addition only to the period for which the evidences were found during the search. (Page 142 to 146 of CIT(A) order). 5.1 The learned CIT(A) accordingly, erred in sustaining the addition of Rs.l,03,53,679/- for the period 01.04.2002 to 24.10.2002 (Page 142 of CIT(A)) and addition of ₹ 76,90,694/- for the period F.Y. 1996 - 97 to 2001 - 02 (Page 146 CIT(A)). 5.2] The learned CIT(A) was not justified in holding that a. In a block asst. the addition could be made on the basis of estimation - and extrapolation and it need not have been restricted only to the evidences found during the se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... issioner of Income-tax (Appeals has erred on facts and in law in not agreeing to the working of the undisclosed turnover for the F.Y. 2002-03 given by the Assessing Officer and the Special Auditor on the basis of the seized documents and substituting it with his own working. 7. For this and other such grounds as may be urged at the time of the hearing, the order of the Commissioner of Income-tax (Appeals) may be vacated and that of the Assessing officer be restored. 8. The appellant craves leave to add, amend, alter or delete any of the above grounds of appeal during the course of the appellate proceedings before the Hon'ble ITAT. 7. Grounds of appeal No. 1 and 7 by the assessee being general in the nature are dismissed. 8. Grounds of appeal No.2 by the assessee and grounds of appeal No.4 by the revenue relate to the order of the CIT(A) in sustaining the addition of ₹ 5,27,733/- on account of excess stock of Gems as against ₹ 8,33,683/-made by the AO. 9. Facts of the case, in brief, are that during the course of search Gems and Jewellery valued at ₹ 8,33,651/- was seized as per Annexure C to the Panchanama dated 25-11-2002. During the course of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at the special auditor appointed by the department has considered both the valuation report and has opined that the valuation done by the departmental valuer is more acceptable. However, the auditor has not given any finding about the acceptance or rejection of the second report which was also given by a registered valuer prepared during the period of search itself and was given to the Investigation Unit. There is no material available on record which can suggest why the difference was existing except by the argument made by the assessee in its submission that Shri Uttam Jain has not done valuation in detail and has done this on estimation. He observed that it is not possible to verify the objections of the assessee at this stage. Since the difference as per the revenue as well as the assessee is only ₹ 6,11,900/-, i.e. ₹ 8,33,683 Rs.2,21,783/- he arrived at a figure which is somewhere in between the two. Since the average of difference comes to ₹ 5,27,733/- he held that the excess gems should be assessed at ₹ 5,27,733/- as against ₹ 8,33,683/- made by the AO. 12. The Ld. Counsel for the assessee strongly opposed the order of the CIT(A). He submitt ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rity of gold, gross/net weight etc. whereas such details are not available in the report given by the departmental valuer, Shri Uttam Jain. It is also the submission of the Ld. Counsel for the assessee that the valuation difference should not constitute undisclosed income in the block assessment year. 17. We find merit in the above submission of the Ld. Counsel for the assessee. Admittedly, there are two valuation reports, one given by the valuer appointed by the department and the other one given by the valuer appointed by the assessee. The report of the valuer appointed by the assessee was given to the DDIT (Investigation) on 25-11-2002 which is after the search proceedings. We find there is no reason whatsoever has been given for either accepting or rejecting the said valuation report. Since the valuation report given by Shri Parag Gadgil, the valuer appointed by the assessee, gives the details of weights of the stones, purity of gold, gross/net weight etc. whereas such details are not given in the report of the departmental valuer, therefore, we find no reason why the report of the valuer appointed by the assessee should not be accepted. Since the report given by the valuer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that there is lot of bargaining and benefit of 25% should be given for bargaining etc. It was further submitted that these items are such wherein there are lots of latest design and fashion which keep on changing because of which part of the stock is obsolete. No such benefit has been given by the department, Further, in respect of the items such as watches and Uktamal the difference is very small and therefore there is no reason to make any addition. It was also submitted by the assessee that assessee gives substantial discount to VIP and privileged customers. No reduction on this account has been given by the AO. 21. However, the CIT(A) was not satisfied with the explanation given by the assessee and upheld the addition made by the AO on the ground that such addition is fair and reasonable. The various arguments made by the assessee according to him are based on assumptions and presumptions and therefore cannot be accepted. 22. Aggrieved with such order of the CIT(A) the assessee is in appeal before us. 23. The Ld. Counsel for the assessee submitted that the main business of the assessee is that of jewellery and these items are just a fancy items kept in the stock. Ther ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ngs valued at ₹ 4,41,000/- both totaling to ₹ 20,23,777/- were received from Shri Ranka Jewellers, Karve Road. 28. However, the AO did not accept the above contention of the assessee on the ground that in the course of search the assessee did not give any explanation about the receipt of the jewellery found though specifically asked. Further, in the course of search there was a shortage in stock of diamonds to the tune of 100 karat worth ₹ 19.18 lakhs. It was requested by the assessee to set off the shortage, vis- -vis the diamonds found with the Directors. It was accordingly argued that no addition is warranted on this account. However, the AO did not accept the above plea of the assessee and made addition of ₹ 27,73,230/- to the total undisclosed income of the assessee. 29. Further, certain gold/diamond jewellery was found in the strong room at the premises of the Director which was valued at ₹ 51,61,014/-. In absence of any satisfactory explanation given by the assessee the AO added the above amount as unexplained investment in the hands of the assessee company. Thus the AO made addition of ₹ 79,34,244/- (i.e. ₹ 27,73,230 + ₹ 51 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ised of 40.47 ct. which were already seized and 16.68 ct. which were found but not seized. The claim of the appellant that some jewellery pertaining to Smt. Geeta Ranka and was lying at the premise to explain the excess diamond was found by the Assessing Officer not acceptable, as it was found that whatever explained diamond was available in the hands of Mrs. Geeta Ranka in her Wealth tax return, were already considered in their hand and therefore, the claim was held to be not correct. In view of the above, the value of jewellery represented by the excess diamond found but not seized at Sr. No. 18, 19, 21, 24, 27, 28 and 30, having the total valuation of ₹ 6,24,453 were treated as unexplained in addition to the seizure of ₹ 21,48,777, made by Annexure C-1 of panchanarna dated 25.10.2002 at the residence. Therefore, in this fashion the Assessing Officer computed the addition in respect ofjewellery found at the residence except the jewellery found at concealed strong room at ₹ 27,73,230. It is also apparent that the claim made by the appellant that out of the jeweller) of ₹ 21,48,777, found and seized at the residence vide AnnexureC-1, the jewellery of the val ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Road, was also found to be not acceptable by the Assessing Officer for the same reasons as discussed in para 36 of the assessment order while dealing with another similar claim for explanation of diamond bangles of ₹ 15,82,977. In view of these facts and considering that the appellant has no acceptable explanation for the jewellery and silver articles found at the concealed strong room, addition of ₹ 51,61,014, representing the entire assets found in the underground strong room was held as taxable u/s. 69A. In this manner, the Assessing Officer computed the addition of ₹ 79,34,244, which is the subject matter of this ground of appeal. During appeal the appellant has made explanations which have been quoted in para 10.2 of this order and can be referred to for details. The major issues raised by the appellant relates to denial of benefit for the jewellery claimed to have been received on Jangad from Ranka Jewellers, Karve Road of the value of ₹ 15,82,777 and ₹ 4,41,000, as described above. It is noted that the appellant has contended in this respect that the aforesaid claims were genuine. In support of the same the appellant produced the copy of Jangad ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... anka and the descriptions are the same. Therefore, the Assessing Officer is directed to verify these facts once again and allow the benefit to the appellant in respect of jewellery appearing in the Jangad. Another objection of the appellant relates to gold bar of 1168 gms. The Assessing Officer has himself admitted in the assessment order that Shri F.N. Ranka, in his statement on oath during search has explained the same to have been purchased by his late son Shri Shreepal Ranka under gold bond scheme of 1998 and the documents were found and seized during search. The Assessing Officer has not given any finding on this claim for not allowing the same. The claim of the appellant appears reasonable and correct. However, the Assessing Officer is directed to verify these facts again and if such gold bars were seized or found along with the documents of its declaration under the RBI scheme with roper legal entry in the books and returns of late Shri Shreepal Ranka,, then there is no reason for not allowing this claim. The Assessing Officer is therefore, directed to verify the same and allow it if the facts described above are found to be correct. As regards the other claims made by the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , this reasoning has no bearing on the issue. He submitted that the set off of the shortages in gold and diamond stock found during the search should be given against the stock at the residence. 34. The Ld. Counsel for the assessee submitted that the addition sustained by the CIT(A) on this count is ₹ 59,10,467/-. If set off of shortage of gold of ₹ 29,18,113/-, shortage of diamond of ₹ 19,18,000/- and Gold bar of late Shreepal of ₹ 6,01,520/- is given then the net addition comes to ₹ 4,72,834/-. He accordingly submitted that the addition should be restricted to ₹ 4,72,834/-. 35. The Ld. Departmental Representative on the other hand heavily relied on the order of the CIT(A). 36. We have considered the rival arguments made by both the sides, perused the orders of the AO and CIT(A) and the paper book filed on behalf of the assessee. We find the AO made addition of ₹ 27,73,230/- on account of diamonds found in the basement of the residential premises of Shri F.N. Ranka on the ground that out of the total diamonds found at ₹ 92.93 karat the assessee could explain only 40.7 karat and could not explain the balance items at 57.15 ka ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted the purchased under the gold bond scheme 1998 for 1,168 grams, therefore, we direct the AO to allow the benefit of 1,168 grams from the unaccounted stock. 40. So far as the contention of the Ld. Counsel for the assessee that set off should be given from the shortage of stock of 5,666.24 grams out of the excess stock found we find some merit in the above contention of the Ld. Counsel for the assessee. It is an undisputed fact that the AO as well as the CIT(A) have taxed the excess stock at residence in the hands of the assessee company. Therefore, when they have accepted that the stock at the residence belongs to the assessee company, therefore, the set off of the same against the shortage at the shop should have been given. We do not find any reason in the order of the CIT(A) that shortages are there because of the unaccounted sales carried out by the assessee regularly. Since he has not appreciated that for the unaccounted sales separate addition has been made by the AO, therefore, we find merit in the arguments advanced by the Ld. Counsel for the assessee that the reasoning given by the CIT(A) is devoid of merit. In view of the above, we set aside the order of the CIT(A) a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sclosed income at ₹ 1,58,98,430/-. Adopting the same yard stick of the period mentioned above he went on estimating the unaccounted turnover for the financial years 1996-97 to 2001-02 and calculated the undisclosed income for each of these years at the rate of GP disclosed in the returns for those respective years. The details of such computation determining the undisclosed profit of ₹ 1,01,14,255/- for the financial years 1996-97 to 2001-02 are as under : Sr. No. F.Y. Disclosed Turnover Rate at which undisclosed turnover computed Undisclosed Turnover Gross Profit rate Profit 1 1996-1997 148826683 5% 74,41,334 5.30% 3,94,930 2 1997-1998 185990256 5% 92,99,513 4.85% 4,51,026 3 1998-1999 165127629 7.5% 1,23,84,572 8.90% 11,02,227 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e seized papers is incorrect. Therefore, the AO should have computed the unaccounted income by way of profit on the suppressed sales for the period on the basis of and in relation to the unaccounted purchases which are actually noticed as per the seized papers instead of presuming that the unaccounted turnover for the period was in the same proportion as the unaccounted turnover for the period 21-08-2002 to 24-09-2002. It was accordingly argued that addition on account of unaccounted profit for the period 01-04-2002 to 24-10-2002 at the most can be only on the unaccounted purchases found during that period. 45. The assessee further submitted that the AO is not justified in estimating the income for the balance period solely on the basis of loose papers found for 28 days. There is no reason for the AO to ignore the other evidence found for the balance period in the form of purchases which clearly indicate that the unaccounted transactions for the balance period were not in the same yardstick. There are no clinching evidences in the form of seized papers indicating actual purchases for the balance period and therefore to apply the same yardstick by the AO is totally unjustified. R ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... chases themselves indicate that quite a few of the loose papers indicate that the goods were received only on estimate/for approval. Further, certain papers indicate that the assessee has not purchased the jewellery but the customers have given their old jewellery for repairs or remaking. It was submitted that certain papers also indicate that the assessee has given gold for remaking the ornaments to the goldsmith and has received ornaments back from them and has only given the Mazuri, i.e. labour charges. Therefore, considerable deduction should be given for the unaccounted purchases of ₹ 72,12,505/- determined by the auditor. 47. However, the Ld.CIT(A) was not satisfied with the arguments advanced by the assessee. So far as the argument of the assessee that AO cannot resort to estimation in a block assessment is concerned, the Ld.CIT(A) relying on various decisions rejected the same on the ground that when there is evidence of evasion whether small or large the AO can very well estimate the income of the assessee for the block period. So far as the issue of extrapolation is concerned he also upheld the action of the AO in view of the evidence showing unaccounted purchase ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ound. The appellant, as can be seen from the careful examination of their submissions, has also more or less interpreted these judgements in the similar manner but has tried to contend that either the estimation is not possible or should be strictly linked to the specific evidences found in that particular year. In other words, the main objection of the appellant can be seen to disregard the evidences found in the form of jama kharcha pana of 28 days to the remaining period of F.Y. 2'002-03 as well as other financial years of the block period. The arguments of the appellant look incorrect. Undoubtedly, the evidence giving complete picture of evasion has been found for 28 days only but the other evidences found for the entire block period clearly shows that the same practice has been followed from the first year of the block to the last year of the block. 12.3.2 In view of the discussions made above, the only objection which can be examined relates to quantification of undisclosed income of the block period. It can be seen from the materials available on record i.e. various documents, slips, papers seized from the premise of the appellant as well as the evidences of the trust ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed expenses. The auditor has also taken into account the unaccounted purchase as income in the first year of the block. The auditor, for these years also has applied the GP rate of 13% for calculating the turnover on the basis of figures of unaccounted purchases found in seized papers in respective years. Along with above he has also considered the unaccounted expenses for arriving at the final figure of unaccounted income of different years. The finding of the special auditor. for aforesaid financial years can be seen from Annexure 1 of the special audit report. From the same it can be seen that the auditor has computed following income or loss for the different assessment years. Sl.No. Financial Year Unaccounted purchase (in Rs.) Income/loss (in Rs.) 1 1996-97 14,759 2,48,229 2 1997-98 0 0 3 1998-99 14,03,149 2,31,225 4 1999-2000 76,04,023 5,16,233 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fore, the Assessing Officer has every right to estimate the undisclosed income in a manner which can be considered as correct as well as just. Only because the evidences found for other than the jama panas are not complete, it would be incorrect to say that the computation of undisclosed income should be restricted to those evidences only. This proposition has been upheld by different Courts also as relied by the Assessing Officer. Therefore the claim made by the appellant to peg the computation of undisclosed income to the evidences of undisclosed purchases only cannot be accepted. Furthermore, it is also important to point out that the nature of the documents seized, except the jama kharcha panas are in the nature of rough notings only and therefore they cannot be considered to give the complete picture of evasion. At the most it can represent that the evasion cannot be less than the figures appearing in those papers in respective years. However, any material brought on record which can merit consideration for applying a principle of computation of undisclosed income has to be given due attention. It has already been held that the objection of the appellant in respect of no comp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... days comes to ₹ 5,97,35,095. By adding both the figures the total unaccounted transaction for the period 1/4/2002 to 24/10/2002 has been computed at ₹ 7,96,43,684 and by applying the same GP rate of 13%, which has been computed by the Special Auditor for this year on the basis of material available on record, the unaccounted profit for this period comes to ₹ 1,03,53,679. On careful consideration of the materials available on records, which clearly show that the method adopted by the Assessing Officer and the auditor has not taken into consideration the fluctuation of business normally happening in different months, the method discussed above was found to be more appropriate and just. In, view of the above and also because the unaccounted transaction in this method becomes more proximate to the figure of unaccounted purchases found, the undisclosed income for the FY 2002-03 is directed to be adopted, at ₹ 1,03,53,679 subject to verification of different figures supplied by the appellant during appeal. The Assessing Officer is directed to verify these figures while giving the appeal effect. 12.3.4 As regards the addition made for the balance years, I have ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ses found in different years of block, was found to have some merit. In view of these facts which were clearly not taken into account by the Assessing Officer as per the discussions available in assessment order, the figures taken by the Assessing Officer for computing the undisclosed transaction based on disclosed transaction were decided to be examined. It is apparent that the shop size increased many folds after renovations and therefore the percentage of undisclosed income found in the jama kharch panas has to be reduced substantially to take into account the various considerations discussed above as well as to keep in mind the actual evidence of unaccounted purchases found in respected years, was found reasonable. The Assessing Officer has not discussed anything in the assessment order for justifying the rates adopted by him for different years for computing the undisclosed transactions, however he can be seen to have very correctly applied the rates in a decending order by substantially reducing it from the actual percentage of unaccounted transactions appearing in jama kharch panas. Though he has correctly kept the rate minimum in FY 1996-97 and has gradually increased it up ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 66,05,105 8.9% 587854 14,03,149 4 1999-00 11,53,94,725 7% 80,77,630 10.85% 876422 76,04,023 5 2000-01 19,27,05,612 13% 2,50,51,729 9.73% 2437533 7,095 6 2001-02 14,74,22,910 20% 2,94,84,582 11.13% 3281633 72,12,505 7690694 12.3.5. Therefore, from the discussions made above, it is held that the undisclosed income of the appellant for F.Y.1996-97 to 2001-02 should be assessed at ₹ 76,90,694 as against the computation of the Assessing Officer made for ₹ 1,01,14,255. The appellant gets part relief for these years. With aforesaid discussions, the issues raised by the appell ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that during the year of search full records were found for 28 days. Therefore, it was fully justified on the part of the AO for extrapolation for the entire year. The Ld.CIT(A) has passed the order after considering the submission of the assessee that paper found for the period of 28 days was the peak period and therefore extrapolation of the same for the entire year is not correct. He submitted that based on the various submissions made by the assessee the Ld.CIT(A) has directed the AO to adopt 3% of the undisclosed turnover as the disclosed turnover as against 5% adopted by the AO. Therefore, the grievance of the assessee is well taken care and therefore, the same should be upheld. 51. We have considered the rival arguments made by both the sides, perused the orders of the AO and CIT(A) and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find during the course of search conducted in the business and residential premises of the assessee and its directors, certain papers for various years were found indicating the unaccounted purchases and sales. Based on the loose papers found the special auditor appointed by th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for F.Y. 1996-97, the department has found unaccounted purchases of only ₹ 14,759/-. Therefore, the addition of ₹ 7,47,133/- is not justified. 55. However, the CIT(A) was not satisfied with the explanation givne by the assessee and upheld the addition made by the AO by observing as under : 13.3 It is also noted from the materials available on record that on 16.01.2007, and order u/sec. 250(4) was passed and the Assessing Officer was directed to examine the purchases computed by the auditor in different years vis-a-vis the seized documents and to re-examine the computation of undisclosed investments in unaccounted purchases. The Assessing Officer has submitted the report vide his letter dated 13.2.2007 and in this letter it was submitted that the seized material found relates to unaccounted sales and purchases made by the assessee during the block period and its study suggests that the appellant has carried out unaccounted sales and purchases during the entire block period. However, the seized material was stated to be in the form of loose papers, chits, scribblings etc. and not in the form of proper accounts. In view of the above, the Assessing Officer submitted ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reated as investment. It has further been stated that no unaccounted stock was found during search. I have carefully considered the discussions available on record along with the report of the Assessing Officer and the submissions made thereupon. Now first of all coming to the ground raised by the appellant for the addition of ₹ 7,44,133 as initial investment in the undisclosed turnover in F.Y.1996-97, it is noted that the Assessing Officer while completing the block assessment has considered all the evidences in a holistic manner and therefore, in F.Y. 1996-97, which was the first year of the block period and for which the evidence .of unaccounted purchase of only ₹ 14,759 was found, the undisclosed turnover was computed as 5% of disclosed turnover at ₹ 74,41,334. Therefore, in the absence of any other materials available on record, which can negate the earlier finding given in the assessment order that the unaccounted business continued from F.Y. 1996-97 in a regular manner and has gradually increased over the period, it cannot be held that an addition can be made on the basis of 53% of the unaccounted transaction computed in F.Y. 2001-02. Furthermore, the unacc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... maintaining its stock for accounted and unaccounted transactions together, it is logical to maintain a higher percentage of stock vis-a-vis recorded transactions. In fact such a phenomenon is an indicator of concealment of transaction generally. For the discussions made above, I do not find any merit in either the report of the Assessing Officer for higher estimation of initial investment nor in the argument of the appellant for reducing the initial investment made by the Assessing Officer in the assessment order. It is also important to reiterate that in the case of another group' business concern i.e. M/s Ranka Jewellers, Raviwar Peth, it has been seen that the Assessing Officer initially missed to make any addition for the initial investment in the unaccounted business transactions found during search and therefore, made an application before the then CIT(A)-I, Pune and the Ld. CIT(A) in his order made an addition of ₹ 10 lakhs as initial investment in the facts and circumstances of that case. Both the Department as well as the appellant has filed appeals against the impugned order of the CIT(A) Pune, before the ITAT, Pune in ITA No. 8 20/PN/2006 and ITA No. 801 /PN ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ccount of initial investment by the CIT(A). In appeal by the assessee the Tribunal vide ITA No.820/PN/2006 and ITA No.801/PN/2006 order dated 06-06- 2011 decided the issue against the assessee. Since the Ld.CIT(A) while deciding the issue has followed the order of the Tribunal in the case of sister concern of the assessee and since he has also given detailed reasoning justifying the addition made by the AO and since the Ld. Counsel for the assessee could not controvert the factual findings given by the CIT(A), therefore, we do not find any infirmity in the order of the CIT(A) on this issue. Accordingly, the ground raised by the assessee on this issue is dismissed. 59. Grounds of appeal No.1,7 and 8 by the revenue being general in nature are dismissed. 60. In ground of appeal No.2 the revenue has challenged the order of the CIT(A) in deleting addition of ₹ 66,73,715/- on account of excess stock of gold. 61. Facts of the case, in brief, are that the AO noted that during the course of search Gold jewellery weighing 1,33,313.351 gms were found from the shop out of which jewellery weighing 13865 gms (net weight) was seized vide panchanama dated 31-10-2002. During the course ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... jewellery to M/s Ranka Jewellers, Raviwar Peth and Shri Om Prakash N. Ranka has claimed that he has sold the jewel1ery to M/s Ranka Jewellers Pvt. Ltd. Thus, the assessee, i.e. M/s Ranka Jewellers Pvt. Ltd. has tried to explain its gold stock found during the course of search by including the jewellery claimed to have been purchased from M/s. H. Kumar Gems International in its own name as well as in the name of Shri Omprakash N. Ranka. He observed that Shri Anil P. Ranka has claimed purchase of 16050.350 gms jewellery vide invoice no 9 dated 22-10-2002, Shri Omprakash Ranka has claimed purchase of 4979.150 gms ornaments vide invoice no. 10 dated 22-10-2002 and M/s Ranka Jewellers Pvt. Ltd. has claimed purchase of 13865.250 gms jewellery vide invoice no 8 dated 22-10-2002. Thus all the three persons have claimed the purchases vide invoices dated 22-10-2002, while the search action u/s.132(1) was conducted on 24-10-2002. The AO further thought worthwhile to mention that in the case of Shri Anil P.Ranka, M/s H. Kumar Gems International has prepared an issue voucher no 715 dated 19-10-2002, On this voucher, initially the description of goods was old gold jewellery, which was changed t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bills issued by H. Kumar International were accommodation bills issued to the assessee and other members of Ranka family. The bill issued to the assessee, i.e. Ranka Jewellers Pvt. Ltd. and was fabricated as there was over writing of the date on the bill. The date written on the bill is 22-10-2002 while according to the department it may be 12-10-2002. According to the AO there were certain discrepancies in the statements of Shri Pragnesh P. Sukhadi, vis- -vis the statements given by Shri F.N. Ranka, Shri Anil Ranka and Shri Omprakash Ranka regarding the date of order and the date of receipt of the gold ornaments. Thus, he was of the opinion that the bills were accommodation bills. According to the AO the assessee informed the department about the bill only on 28-10-2002 while the search was carried on 24-10-2002. The AO doubted as to why the assessee waited for four days to submit to the department that one bill of H. Kumar International was not debited in the books prior to search. The assessee made the payments to M/s. H. Kumar International after a few months and therefore according to the AO this fact does not prove the genuineness of the transaction. As per the AO the assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e in advance or after few days out there was no purchases as per invoice date 22/10/2002 and it was only bill entry, hence payment was made after a gap of one year. That is another question that in the case of unrecorded purchases from this party, sometimes, there was delay in the payments by the assessee, but for that M/s. H. Kumar Gems International has charged interest from the assessee and this fact was evidenced by the seized documents Nos.31, 32 of A-13 and document No.1 of A-15 seized from the residence of the trusted employee, Shri Rakesh Soni. 25. From the above discussion, it can be observed that there was no actual delivery of the gold ornaments to Shri Anil Ranka on 20/10/2002 and to Shri Omprakash, Ranka and Shri Fatechand Ranka on 22/10/2002. The story of receipt of ornaments from M/s H. Kumar Gems International by Ranka Group is a concocted story which has no legs to stand. Thus the explanation given by the assessee to explain the stock of gold ornaments and calculation of shortage of gold stock at 5666.240 gms is not accepted. In fact, there was excess stock of gold ornaments as on the date of search which is computed a under : Gold stock as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... arch. The jewellery purchased by Shri Omprakash Ranka of 4990.150 gms and given to M/s. Ranka Jewellers Pvt. Ltd. was not accepted by the AO while working out the stock. It was argued that the total stock found in the shop of the assessee was to the tune of 136279.54 gms. The stock as per book after considering the jewellery purchased from M/s. H. Kumar Gems International and the jewellery received from Shri Omprakash Ranka was 141945.78 gms. Thus there was shortage of 5,666.240 gms. Further survey was conducted on the premises of M/s. H. Kumar Gems International on 29-10-2002 wherein Shri Hitendra Gundecha, proprietor of M/s. H. Kumar Gems International had accepted the sale of gold ornaments to the assessee, Shri Anil Ranka and Shri Omprakash Ranka. It was argued that the AO did not accept the bills issued by M/s. H. Kumar Gems International treating the same as accommodation bill and was fabricated as there was overwriting of the date on the bill. According to the AO date written on the bill is 22- 10-2002 is not correct and it should be 12-10-2002. 66. It was argued that the bill issued by M/s. H. Kumar Gems International to the assessee was found in the assessee s premises. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ived before the search and if undisputedly the payment was made after the search no addition is possible in the hands of the assessee. 68. As regards the contention of the AO that the assessee did not specify the designs to justify that the bills were merely accommodation bill, it was submitted that the same is not correct at all. It was submitted that it is a regular practice to ask for the goods and the assessee nowhere specifies any design etc. It was argued that during A.Y. 2003-04 Shri Omprakash Ranka has shown capital gain on transfer of the jewellery purchased from M/s. H. Kumar Gems International to M/s. Ranka Jewellers Pvt. Ltd. and the capital gains was offered to tax. The assessment u/s.143(3) was completed and the department has accepted the sale of jewellery as genuine by taxing capital gains thereon. 69. So far as the variations in the statements of family members of Ranka group, vis- -vis the statement of Shri Pragnesh Sukhadia, who was an employee of M/s. H. Kumar Gems International is concerned it was argued that when all the persons had accepted the transaction of sale of gold ornaments to the assessee and when the discrepancy in the statement of Shri Pragne ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent on 26/10/2002 and therefore the appellant claims to have no occasion to give details in respect of impugned bills. It has further been submitted that the appellant on the first available occasion on 28/10/2002, when Mr. F. K. Ranka was asked about the details of bills which are not entered in system, had not only given the details of the purchases made by the appellant company from M/s H. Kumar but also showed where the said bill was laying in the business premises. It has been further stated that the controversy raised by the Authorized Officer, suggesting implanting of the impugned bill was without any basis and was only due to his suspicion. It has been claimed that the appellant kept on explaining the facts properly and never accepted, as the same was not true, that any such implanting has taken place. The argument has further been made during appeal that the Authorized Officer, almost immediately carried out survey at the selling party and it is a matter of record that not only the transactions were found recorded in the books of Mr. H.Kumar, but even during statement, the proprietor as well as the concerned employee accepted the impugned transaction. Except for the differ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... journey by supplier, date of invoice on the date of arrival in Pune, etc., which are clear from the assessment order already quoted above for this addition. On the basis of these reasons the Assessing Officer has treated the two purchases as bogus and computed the excess gold stock to arrive at the addition of ₹ 66,73,715. The appellant has claimed this finding as prejudiced and erroneous. For the contradictions appearing in various statements as noted by the Assessing Officer in para 20 of the block assessment order (which can be referred to for details in para 6.2 above), it is the claim of the appellant that the gold jewellery appearing in these bills were received prior to the date of search and in support of that appellant is relying upon the sale invoices, the issue vouchers which have been found and seized during the course of search and is part of the panchanama prepared during search. The argument of the appellant about the discrepancy noted in the statements of different persons relied upon by the Assessing Officer is that the minor slippages occurring in the statement here and there are due to mental stress which is so common while facing any interrogation from a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed gold sales for the F. Y. 2002-03 has been estimated on the basis of Jama kharcha paper found and seized during the course of search. This estimated unaccounted gold sales covers the shortage in gold stock . The Assessing Officer, apparently has not given any reason in his assessment order as to why he was not convinced with the finding of the Special Auditor on this issue. However, he has given detailed reasons for making the additions as is apparent from relevant portion quoted earlier in para 6.2. 6.3.2. On careful consideration of the materials available on record, it is noted that the appellant has claimed that the bills for the purchases from H. Kumar Gems International in the name of appellant company, which were not entered in the books were found and seized during the course of the search. It is noted from the materials available on the record that though the Assessing Officer has relied on some confusion about the discovery of the aforesaid bills from the drawer of the director's office as noted in the statement on oath of Shri F.N. Ranka recorded u/s 132(4) and also on the circumstantial facts for arriving at the finding that the impugned bills were bogus, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ized or recording of any statement. It is noted in this panchnama that the premise was sealed and prohibitory order u/s 132(3) was served on the Director. On 26/10/2002, the search resumed at 11.45 am and continued till 1.30 am of 27/10/2002, there upon again the premise was sealed and prohibitory order was served. The search thereafter subsequently commenced on 27/10/2002 at 10.30 am and was temporarily suspended on 29/10/2002 at 1.30 am. The premise was again sealed and prohibitory order was served. As per this panchnama the statement of Shri. F.N. Ranka was recorded. Therefore from the perusal of the panchnama also, it has to be accepted that the business premise has remained in the control of the search party and there is no material available on record which can suggest that the prohibitory order served on the appellant u/s 132(3) was violated. If it is assumed that the suspicion of the Authorized Officer that somebody during the course of the search implanted these bills, then also the responsibility has to be on the search party, in charge of the search, as the same would suggest lapse on their part. Nobody saw anybody or caught anybody placing the bills in the d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t obtained the same subsequent to the search to explain the excess stock found, as was attempted by the Assessing Officer, the matter could become acceptable. In the present case since the bill was found in the regular course of business during search itself, it cannot be assumed to be representing a bogus bill. Furthermore, this fact was not found at the end of seller also. The survey party could not find that the bills were bogus or the bills were issued without having any stock with him and therefore the findings of the Assessing Officer cannot be accepted. This view further gets strength from the fact that the shortage has been determined by the appellant in its explanation, which has been found acceptable by the Special Auditor at 5666.240 gms. For this, both the impugned purchases of 13,189 gms and 4950.150 gms have been considered. After treating these purchases as bogus, the Assessing Officer has computed the excess gold stock at 13,189.160 gms to make addition of ₹ 66,73,715 @ ₹ 506 per gm. If the claim of the Assessing Officer is taken as correct that the appellant arranged for these two bogus bills on 28.10.2002 after the reconciliation was made during search ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . to the discrepancy in the statement of Shri. Pragnesh, which he had corrected in the same statement is not justified for drawing adverse inference. The learned A.O. has not taken into account the direct and relevant evidences available on the issue, apparently because they were not his findings. An Assessing Officer cannot disregard an evidence which is direct and relevant on certain presumptions. He is duty bound to consider all the materials available on records and evaluate the same in a dispassionate manner to finally conclude the inference. Therefore, the appellant has been able to show that the Assessing Officer by ignoring certain facts available on record, viz. seizure of bills at the search premise, acceptance of the same on the first available occasion by the Director, entries of sale appearing in the books of Shri. O.N.Ranka seized during simultaneous search and also in the books of M/s. H.Kumar International, during survey almost at the same time i.e. on 29/10/2002 and similar such evidences, has ignored to consider many relevant issues for coming to the finding which is in dispute in this ground of appeal. In view of the above and after considering all the relevant ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... clearly shows that the transactions were carried Gut together and part of it were not recorded in the disclosed books of account. Therefore, even if on the strength of overwriting, it is presumed that the impugned bill related to concealed purchases and was not to be accounted for before search, and the date was changed from 12/10/2002 to 22/10/2002, after search to explain the excess stock, still it will have to be considered for arriving at the quantum of excess stock as the stocks for disclosed and undisclosed business was same and the income for concealed transactions are separately being computed. It is an admitted fact that the books were recorded upto 21/10/2002 and payments for impugned purchases were made after search, though unduly late but this will not justify exclusion of these purchases. As already discussed, the overwhelming evidences were on record which over weighs the objections raised by the Assessing Officer. The Assessing Officer has given the finding by ignoring these relevant facts, mostly on placing reliance of circumstantial evidences. Though the circumstantial evidences are many and create a reasonable doubt but the same cannot overrule direct evidences. I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... u/s.143(3) accepting such sale of goods to the assessee and the other members, then there is no reason to doubt the purchases made by the assessee from M/s. H. Kumar Gems International. He submitted that when one wing of the department has accepted sale of jewellery as a genuine sale, there is no reason to doubt the purchases made by the assessee. For the above proposition he relied on the decision of the Hon ble Supreme Court in the case of CIT Vs. Berger Paints India Ltd. reported in 266 ITR 99 and the decision of the Pune Bench of the Tribunal in the case of A.E. Lokhandwale reported in 35 ITD 50. Further, M/s. H. Kumar Gems International is a registered dealer both under the State and Central Sales Tax Acts and tax on this transaction has been paid. The special auditor has also accepted the transaction as genuine. Therefore, the order of the CIT(A) being in consonance with law should be upheld. 74. The Ld. Departmental Representative in his rejoinder submitted that the special auditor cannot say the transaction as genuine or not. He is to base his report on the basis of the papers found. 75. We have considered the rival arguments made by both the sides, perused the order ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eir books of account. Further, assessment has been completed u/s.143(3) for A.Y. 2003-04 in the case of M/s. H. Kumar Gems International wherein such sale of gold to the assessee has been accepted as genuine. We therefore find merit in the submission of the Ld. Counsel for the assessee that when one wing of the department has accepted the sale of jewellery as genuine sale, there is no reason to doubt the purchases made by the assessee from the said party. Further, the special auditor in his report has also accepted the purchases from M/s. H. Kumar Gems International as genuine. We find during the survey at M/s. H. Kumar Gems International, Ahmedabad Shri Pragnesh Sukhadia, an employee and Shri Hitendra Gundecha, the owner were examined and their statements were recorded. They have accepted that sales have been effected to M/s. Ranka Jewellers Pvt. Ltd., Shri Anil Ranka and Shri Omprakash Ranka. Further, the submission of the Ld. Counsel for the assessee that in A.Y. 2003-04 Shri Omprakash Ranka has shown the capital gains on transfer of these jewellery purchased from M/s. H. Kumar Gems International to M/s. Ranka Jewellers Pvt. Ltd. and that capital gain was offered to tax which ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee reconciled the stock and it was submitted that the excess, if any is only 22780.570 gms. The assessee accordingly submitted that there is actually no excess stock. 78. However, the AO did not accept the above contention of the assessee. He noted that the approved valuer while valuing the silver items has given due credit for the weight of the plastic bags and boxes. This shows clear cut of excess silver articles which comes to 22,780.570 gms. Applying the rate of ₹ 7750/- per kg, the AO determined such excess stock of silver at ₹ 1,76,553/- which he added to the total undisclosed income of the assessee for the block period u/s.69A of the Act. 79. Before CIT(A) it was submitted that the main difference is on account of valuation of plastic bags. The bags contain the silver articles and the weight of the bags ranges from 2 gms to 15 gms. It was submitted that Shri Uttam Jain, departmental valuer has reduced 114.400 kg on account of weight of plastic bags of around 22000 bags and thereby taking an adhoc weight of 5 gms per bag. Shri F.N Ranka in his statement recorded u/s.132(4) has pointed out certain discrepancies in the valuation made by Shri Uttam Jain and h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... atement recorded on 25.11.2002 that the weight of container is more, and even if the weight of 22000 container is raised from 5gm to 6gm per container, the excess will get explained, was not accepted by the Assessing Officer. This was claimed to have been rejected without assigning much reasons only on the ground that the valuation was done by a qualified person. The appellant has disputed the same and has relied on the valuation report of the department wherein Mr. Uttam Jain was claimed to have estimated the weight of plastic bags at 114400 gms by taking the weight of 22,000 bags @ 5 gms per bag. It has been contended that Mr. Ranka in his statement given u/s. 132(4) during the search itself on 25/11/2002 has pointed out this .discrepancy but the department did not take the said seriously. It has been stated in this respect that if the weight of these bags is increased from 5 gms to 6 gms the difference would vanish. It is noted that the auditor in his report prepared u/s 142(2A), at Annexure 8- 2 has given the reconciliation of the silver stock found in the business premise and has arrived at the excess silver stock of 22,780.570 gms. However, in the concluding para in the same ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... econcile the same, however, the AO noted that there is excess stock of 22780.570 gms. The submission of the assessee that there is no excess stock as at many places the weight of plastic bags and boxes are not deducted and in some cases the weight of plastic bags has been taken at random was rejected by the AO on the ground that the valuer has given due credit for the weight of plastic bags and boxes. We find the Ld.CIT(A) considering the submission of the assessee that the weight of plastic bags have not been properly considered by the search party as well as the valuer accepted the contention of the assessee and deleted the addition which has already been reproduced in the preceding paragraph. We find the order of the CIT(A) in the instant case is a detailed and well reasoned one which does not call for any interference from our side. We therefore uphold the same and the ground raised by the revenue on this issue is dismissed. 83. Ground of appeal No.4 raised by the revenue has already been adjudicated while deciding ground of appeal of appeal No. 2 in assessee s appeal. Therefore, this ground is not being separately adjudicated. 84. Ground of appeal No.5 by the Revenue rea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... valued on the same line and hence effect will be negligible. 87. However, the AO was not satisfied with the explanation given by the assessee. He referred to the order in the case of M/s. Ranka Jewellers, sister concern of the assessee where similar additions were made. Rejecting the various explanations given by the assessee the AO made addition of ₹ 19,97,934/- by observing as under : 52. The contention of the assessee has been considered but for the reasons discussed above and example given, the contention of the assessee is not accepted. During the course of search at the business premises of Ranka Jewellers Pvt. Ltd. gold jewellery weighing 88627.28 gms was found and the total value shown in the books was 4,41,59,424/-. Thus the stock was valued at ₹ 4982.59 for 10 gms (44159424/88627.28). However as discussed above the minimum value of acquisition of jewellery after June 2002 was ₹ 5208 per 10 gms. Therefore, the value of the gold jewellery lying at the premises of the assessee should be 520.8 x 88627.28 = ₹ 4,61,57,358/-. Thus the assessee has overvalued the stock by ₹ 19,97,934/- which is added to the undisclosed income of the block per ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r dated 30-04-2014 for the block period 01-04-1996 to 24-10-2002 deleted the addition by observing as under : 4. After hearing both the sides, we find an identical issue had come up before the Tribunal in the case of M/s. Ranka Jewellers Vs. Addl.CIT vide ITA Nos. 801, 820 and 984/PN/2006 order dated 06-06-2011 for the block period 01-04-1996 to 24-10-2002. We find the Tribunal while deciding identical issue has dismissed the appeal filed by the Revenue by observing as under : 30. Ground No.3 The relevant facts are that the assessee firm engaged in jewellery business and following average cost method for valuing the stock in the books i.e. it takes average of opening stock and purchases during the year and values the closing stock at that rate. This method was being followed regularly and the same was being accepted by the department in the past. During the course of assessment proceedings, the A.O. held that the average cost method followed by the assessee is not correct and the assessee should have followed the FIFO method for valuing the stock. The A.O. was thus of the view that the closing stock should be valued as per the closing purchase rate in the month of March ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d by the Tribunal in the case of sister concern of the assessee which has been followed by the CIT(A) while deleting the addition made by the AO on this issue, therefore, in absence of any contrary material brought to our notice against the order of the Tribunal in the case of the sister concern of the assessee on identical issues we find no infirmity in the order of the CIT(A) deleting the addition. Accordingly, the same is upheld and the ground raised by the Revenue on this issue is dismissed. 93. Ground of appeal No.6 by the Revenue reads as under : 6. The Commissioner of Income-tax (Appeals has erred on facts and in law in not agreeing to the working of the undisclosed turnover for the F.Y. 2002-03 given by the Assessing Officer and the Special Auditor on the basis of the seized documents and substituting it with his own working. 94. After hearing both the sides, we find the Ld.CIT(A) at para No.12.3.3 of his order has discussed the issue where the assessee has challenged the computation of unaccounted transactions made by the auditor as well as the AO for F.Y. 2002-03 at ₹ 12,22,96,618/-. The explanation of the assessee as well as the finding of the Ld.CIT(A) ..... X X X X Extracts X X X X X X X X Extracts X X X X
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