TMI Blog2017 (7) TMI 173X X X X Extracts X X X X X X X X Extracts X X X X ..... 43 (3) has no legs to stand. Appeal of the assessee is allowed - ITA No.4966/Mum/2014 - - - Dated:- 24-10-2016 - SHRI R.C.SHARMA, AM AND SHRI PAWAN SINGH, JM For The Assessee : Shri J.P.Bairagra For The Revenue : Shri Sanjay Bahadur ORDER PER R.C.SHARMA (A.M) : This is an appeal filed by the assessee against the order of CIT(A) for the Assessment Year 2005-2006, in the matter of order passed under Section 153C read with section 143(3) of the IT Act. 2. In this appeal, the assessee is aggrieved for making addition u/s. 153C without finding any incriminating material during course of search, when assessment was already completed u/s.143(3) and nothing was pending as on the date of search. Assessee is also aggrieved for satisfaction having been not recorded in the file of searched person before transfer of file to the AO of the assessee. 3. Rival contentions have been heard and record perused. 4. Facts in brief are that the assessee is a company carrying on agricultural activities on the agricultural land and sells agricultural produce, nursery plants etc., For the previous year relevant to the assessment year 2005-06, the assessee filed return o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iteback of term loan and dividend income. By the impugned order CIT(A) deleted the part of the addition made on account of agricultural income and dividend income offered u/s 10(34). Assessee is in further appeal before us against the order of CIT(A). However, no appeal was filed before department against the relief given by CIT(A). 6. We have heard rival contentions and found that the return of income of the assessee company for assessment year 2005-06 has been filed in October 2005 declaring its total income at Rs. Nil/ -. With the return of Income the assessee had enclosed its Audited Balance Sheet and Profit Loss Account along with Audit Reports, Computation of Total Income and other details. Scrutiny assessment notice u/s. 143(2) was issued dated 20 June 2007. Thereafter, scrutiny assessment order dated 29 October 2007 was passed by the AO under section 143(3) of the Act accepting the income as returned by Assessee Company. The assessee had challenged that the assessment had been completed u/s.143(3) and therefore, the assessment had become final and was not pending and therefore, there was no question of abatement. In such a case, no addition could be made u/s.153C of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... T v. Jayendra P. Jhaveri [2014] 65 SOT 118 * Jodhpur ITAT in the case of Ayushi Builders Developers vs. DCIT [2014] 166 TTJ 25. * ITAT Pune Bench incase of ACIT vs. SRJ Peety Steels P. Ltd. [2011] 137 TTJ 627. * Mumbai Tribunal in the case of Nikki Agarwal vs. ACIT dated 22-01-2014 being ITA No. 879/M/2011. * Jaipur Tribunal in the case of Jadau Jewellers Manufacturers (P) Ltd. vs. ACIT in ITA No. 686/JP/2014-[2016j 175 TTJ 344. * Delhi Tribunal in the case of M/ s Suncity Projects Pvt. Ltd Vs DCIT dated 21 March 2016 [ITA no 14/Del/2012] [2016-TIOL-643-ITAT. 10. With regard to requirement of recording satisfaction, learned AR submitted that no satisfaction was recorded in the file of searched person and inspite of assessee asking to the AO during assessment proceedings to supply copy of satisfaction note, however, no satisfaction note was supplied to it. 11. Learned AR placed on record the order of the Tribunal in the case of Group Company M/s. Bermaco Energy Systems Ltd., dated 31/05/2016 in ITA No.2198, 2199 2202/M/2013, wherein additions made under Section 153A were upheld to be not justified in so far as no incriminating material was found during cou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... urn was furnished. Accordingly, the AO should have issued notice u/s.143(2) by 31-10-2005. However, no such notice was issued, thus, the assessment is treated to be completed since on the date of search i.e. 31-10-2009, limit for issuing notice u/s.143(2) was already expired. In respect of assessment year 2005-06 assessee has filed its return of income on 29-10-2005, which was also processed u/s.143(1). For taking into scrutiny notice u/s.143(2) was required to be issued before 31-10-2006 i.e. time limit for issuing notice during the relevant assessment year under consideration. However, no notice u/s.143(2) was issued. Even no notice u/s.148 was issued for reopening of the assessment. Thus, the assessment for both the assessment years i.e. A.Y.2004-05 2005-06, had become final and was not pending, therefore, there was no question of abatement. We had carefully gone through the order of AO as well as CIT(A). We had also gone through the statement recorded u/s.132(4) and did not find any mention of incriminating material with regard to bogus share capital or unsecured loans having been received by assessee in these years. Whatever share capital and unsecure ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n inserted and with a defined intent. Where search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132Aafter 31-5- 2003, that the Assessing Officer is in a position to and mandated to issue notice within the meaning of sub-section (1) of section 153A. That is because, Chapter XIII within which the powers of search and seizure and powers to requisition books of account are spelt out enable the revenue to take care of cases where it effects a search and seizure. That search and seizure is effected and after the same is effected, books of account, other documents, money, bullion, jewellery or other valuable article or thing is found as a result thereof that notwithstanding anything and within the meaning of the above provisions having been concluded, it is open for the revenue to make an assessment. It is also open to the revenue to make a reassessment in cases where it exercises the powers to requisition books of account etc. This is because it is of the view that the books of account are required to be summoned or taken into custody. It, therefore, issues a summons in that regard. It may also requisition the books of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... would not abate. Therefore, the argument of the revenue, that on initiation of proceedings under section 153A, the assessments/reassessments finalised for the assessment years covered under section 153A stand abated cannot be accepted. Similarly on annulment of assessment made under section 153A (1) what stands revived is the pending assessment/reassessment proceedings which stood abated as per section 153A(1). ■ Once it is held that the assessment has attained finality, then the Assessing Officer while passing the independent assessment order under section 153A read with section 143 (3) could not have disturbed the assessment/reassessment order which has attained finality, unless the materials gathered in the course of the proceedings under section 153A establish that the reliefs granted under the finalised assessment/reassessment were contrary to the facts unearthed during the course of 153A proceedings. If there is nothing on record to suggest that any material was unearthed during the search or during the 153A proceedings, the Assessing Officer while passing order under section 153A read with section 143(3) cannot disturb the assessment order ■ The s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is conducted or requisition is made. Thus, the crucial words 'search' and 'requisition' appear in the substantive provision and the provisos. That would throw light on the issue of applicability of the provision. It being enacted to a search or requisition that its construction would have to be accordingly. That is the conclusion reached by the Division Bench in Murli Agro (supra). These are the conclusions which can be reached and upon reading of the legal provisions in question. ■ Therefore, the Special Bench's understanding of the legal provision is not perverse nor does it suffer from any error of law apparent on the face of the record. ■ Further, revenue would submit that the above observations and conclusions of the Special Bench are specifically disapproved in CIT v. Anil Kumar Bhatia [2012] 24 taxmann.com 98/211 Taxman 453 (Delhi). However, this argument is not found to be accurate. Upon reading of the observations of the Delhi High ITA No.2198,2199 2202/13 Court as a whole and in entirety, it is not possible to agree with revenue that the High Court of Delhi reached a conclusion different than the view taken by the Division B ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in its recent decision on the issue in the case of Shri Kabul Chawla (supra) and others vide order dated 23.5.2014 has expressed the similar view. It has also discussed the decision of Hon‟ble Jurisdictional Delhi High Court in the case of CIT vs. Anil Kumar Bhatia(2012) 211 Taxmann 453 (Del.), while deciding the issue. The relevant para No. 8 9 in this regard is being reproduced as under :- 8. We are unable to accept the contention advanced on behalf of the Revenue for the reason that if both the pending and completed assessment were to be taken on same pedestal, then there was no need to enshrine second proviso to sec. 153A( 1) providing that the pending assessments within the period of six assessment years shall abate. The Hon'ble Delhi High Court in the case of Anil Kumar Bhatia (supra) dealt with a situation in which some incriminating material was found in respect of a non-pending assessment. It was in that background that the Hon'ble High Court held that sec. 153A applies if incriminating material is found even if assessments are completed. The question as to whether any addition can be made in respect of completed assessments when no incriminating ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pending vis-a-vis the years for which assessments are non-pending. In respect to the assessment years for which the original assessments have already been completed on the date of search, the total income shall be determined by restricting additions only to those which flow from incriminating material found during the course of search. If no incriminating material is found in respect of such completed assessment, then the total income in the proceedings u/s 153A shall be computed by considering the originally determined income. If some incriminating material is found in respect of 11 such assessment years for which the assessment is not pending, then the 'total income' would be determined by considering the originally determined income plus income emanating from the incriminating material found during the course of search. In the other scenario of the assessments pending on the date of search which would abate in terms of second proviso to sec. 153A( 1), the total income shall be computed afresh uninfluenced by the fact whether or not there is any incriminating material. In fact, this is the position which follows when we read the judgment of the Hon'ble Delhi High Cour ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... it is not the case of the appellant - assessee that initiation of proceedings u/s 153A was bad or unwarranted in law as no incriminating material was found during the search. The contention raised by the appellant - assessee is that the addition, which is the subject matter of questions no. (II) and (III), was/is not justified in the assessment order u/s 153, as no incriminating material was found concerning the addition u/s 115JB of the Act. The Hon‟ble High Court has rejected this contention of the assessee with this finding that u/s 153A of the Act, the additions need not to be restricted or limited to the incriminating material, which was found during the course of search. Thus, it is clear from the facts of this case before the Hon‟ble High Court that several additions relying upon the incriminating material found in the course of search were made by the AO in the assessment proceedings u/s 153A of the Act and addition u/s 115JB was made by the AO in absence of incriminating material concerning this addition. This addition was questioned by the assessee on the basis that there was no incriminating material found concerning the addition made in the assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ned, the issue raised before the Hon‟ble High Court was regarding validity of revisional order passed u/s 263 of the Act by the ld. CIT partly upheld by the Tribunal and during that course the Hon‟ble High Court has also been pleased to discuss the decision in the cases of Anil Kumar Bhatia (supra) and the decision of Special Bench of the Tribunal in the case of All Cargo Global Logistic Ltd. (supra). It has been observed by the Hon‟ble High Court that the condition precedent for application of sec. 153A is that there should be a search u/s 132 and initiation of proceedings u/s 153A is not dependent on any undisclosed income being unearth during the such search. The Hon‟ble Rajasthan High Court in the case of Jai Steel (supra) has been pleased to hold that if any books of accounts or other documents relevant to the assessment had not been produced in the course of original assessment and found in the course of search, such books of accounts or other documents have to be taken into consideration while assessing or re-assessing the total income under the provisions of sec. 153A of the Act. Even any undisclosed income or undisclosed property has been found afte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of search no addition can be made in a case where original assessment was already framed on the date when search took place. 19. In absence of rebuttal of this material fact by the Revenue in the present case before us that no incriminating material was found during the course of search relating to the assessee for the assessment year under consideration to justify the additions made in the year by the Assessing Officer and assessment based on the original return of income filed under sec. 139 of the Act was not pending as on the date of search, we following the above cited decisions by the learned AR, discussed above, hold that the assessment framed under sec. 153A read with sec. 143(3) of theIncome-tax Act, 1961 for the assessment year under consideration is not valid and the same is accordingly held as null and void. The related ground nos. 2 to 6 on the issue is thus allowed. 20. In view of the above findings, whereby the assessment itself has been held null and void, the other issues raised in other ground nos. 7 and 8 questioning the validity of the disallowance ofITA No.2198,2199 2202/13 deduction u/s 80IB on scrap sales (ground no.7) and disallowance made u/s 14 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat stood abated shall stand revived. ITA No.2198,2199 2202/13 Thus, on a plain reading of section 153A, it becomes clear that on initiation of proceedings under section 153A, it is only the assessment/reassessment proceedings that are pending on the date of conducting search under section 132 or making requisition under section 132A stand abated and not the assessment/reassessments already finalised for those assessment years covered under section 153A. By a circular No. 8, dated 18-9-2003 the CBDT has clarified that on initiation of proceedings under section 153A, the proceedings pending in appeal, revision or rectification proceedings against finalised assessment/reassessment shall not abate. It is only because, the finalised assessments/reassessments do not abate, the appeal, revision or rectification pending against finalised assessments/reassessments would not abate. Therefore, the argument of the revenue, that on initiation of proceedings undersection 153A, the assessments/reassessments finalised for the assessments years covered under section 153A stand abated cannot be accepted. Similarly on annulment of assessment made under section 153A(1) what stands r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... section 143(3) though it may be interpreted as mere intimation assessment or otherwise, but the same shall be deemed to be accepted by the Assessing Officer and it will not have any different colour other than the return which is processed under section 143(3). Admittedly, in the case in hand, the return was processed under section 143(1) but the same has attained finality due to the expiry of limitation period of twelve months from the end of the month in which the return was filed. Hence, the assessment is deemed to be completed and not pending on the date of search on 14-8-2008. Admittedly, no incriminating material was found from the premises of the assessee during the search under section 132. Once assessment under section 143(3) had been annulled by higher authorities on the ground of legality of notice under section 143(2), re-opening under section 147 on that very ground would mean nothing else but abuse of process of law. Hence, the contention of the revenue that as the return was processed under section 143(1), it was a mere intimation and the Assessing Officer had reason to believe that income had escaped assessment and it was open to the Assessing Officer to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he case of M/s Rakam Money Matters Pvt. Ltd., ITA No.2821/Del/2011, order dated 10-16-2014. 28. Our view is also supported by following decisions :- i) ITAT Mumbai Bench in the case of Shri Gurinder Singh Bawa vs. DCIT - 28 taxmann.com 328 ii) ITAT Mumbai Bench in the case of Anil P. Khimani vs. DCIT - No. 2855 to 2860/Mum/2008 dated 23-02-2010 iii) ITAT Jodhpur Bench in the case of Vishal Dembla vs. DCIT - 157 TTJ 189 iv) High Court of Bombay on the case of CIT v. Murli Agro Products Ltd. [2014] 49 Taxmann.com 172 ITA No.2198,2199 2202/13 v) ITAT Mumbai Bench in case of ACIT v. Jayendra P. Jhaveri [2014] 65 SOT 118 vi) Jodhpur ITAT in the case of Ayushi Builders Developers vs. DCIT [2014] 166 TTJ 25 vii) ITAT Pune Bench in case of ACIT vs. SRJ Peety Steels P. Ltd. [2011] 137 TTJ 627 viii) Mumbai Tribunal in the case of Nikki Agarwal vs. ACIT dated 22-01-2014 being ITA No. 879jMj2011 [20 14-TIOL- 75-ITAT-MUM] ix) Mumbai Tribunal in the case of Parag M. Sanghvi vs. ACIT in ITA No. 8027/Mum/2010 dated 30-09-2015 x) Mumbai Tribunal in the case of Zeenat P. Sanghvi vs. DCIT in ITA No. 8026/Mum/2010 dated 19-12-2014 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... v. In absence of any incriminating material, the completed assessment can be reiterated and the abated assessment or reassessment can be made. The word assess‟ in Section 153A is relatable to abated proceedings (i.e. those pending on the date of search) and the word reassess‟ to completed assessment proceedings. vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record of the AO. vii. Completed assessments can be interfered with by the AO while making the assessment underSection 153A only on the basis of some incriminating material unearthed during the course of search or requisition of documents or undisclosed income or property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment. Conclusion 38. The present appeals concern AYs 2002-03, 2005-06 and 2006- 07. On the date of the search the said assessme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ound during the course of search. Since we have already decided the legal issues in favour of the assessee, we are not going into merit of the addition so made. ITA No.2198,2199 2202/13 30. In the result, appeal for the assessment year 2004-05 2005-06 are allowed in terms indicated hereinabove. 15. After going through the order of the AO and CIT(A), we found that the assessee is in appeal against the additions confirmed by the CIT(A) and the order framed u/s 153C, AO made addition on account of unexplained cash credit, agricultural income, writing back of term loan and dividend income assessee challenged legality of addition made u/s. 153C before the CIT(A). CIT(A) has summarised the submissions of the assessee including judgements relied on this issue in para 5.2 and 5.3 of the order. In para 7.4 the Ld CIT(A) held that Further it may also be mentioned that the books of account and documents seized are incriminating in nature. The authorised officer on the basis of findings during the course of search showed that the share capital introduced in the books of account are not genuine and this led the AO to raise a question regarding the genuineness of the same in t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... zure conducted on Om Sai group on 20 August 2009 wherein Om Sai Group has surrendered amounts invested by the same shareholder companies as that of the assessee as their own money. However none of these alleged materials were provided to the assessee even after requests made by the assessee vide letter dated 19.11.2012. Also when these alleged facts were known to the AO, there is no mention of this in the satisfaction note and the same only appears in showcause notice dated 2.11.2011 which is at least 18 months after issue of notice under section 153C. Further till date these materials have not been provided to the assessee so that he could verify the same. 19. We also found that during the course of search the search Officer had not questioned the director of the Company on this issue which shows that at the time of search the search party was not having this information in possession on the basis of which addition was made. 20. Thus, the case of the assessee is that the additions were made to its income on the basis of details submitted by the assessee during 153C assessment and in respect of transactions which were duly accounted in the audited books of account of the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n 153C to the assessee. He contended that the satisfaction note was never provided to the assessee inspite of requests made during the course of assessment proceedings nor the assessment order anywhere mentioned regarding recording of satisfaction note. 25. Our attention was also invited to the copy of remand report issued by the AO pursuant to request of CIT(A). It is only based on request of CIT(A) that the AO has shared satisfaction note which is incorporated in para 6.2 of CIT(A) order. Regarding the satisfaction note, learned AR contended that there is no mention of any date in the satisfaction note issued by the AO. Under these circumstances, as per learned AR it can be safely presumed that the satisfaction note is not recorded which is mandatory to be followed and hence the entire proceedings are bad in law. 26. Our attention was also invited to para 7.3 of the CIT(A)‟s order which reads as under:- The appellant also submitted that the AO instead of recording satisfaction in the case of 153A person recorded the satisfaction only in the case of 153C person and therefore then entire proceedings is vitiated. The contention of the appellant is not acceptable. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n recorded by Assessing Officer who had jurisdiction over both searched person and assessee - Whether recording of satisfaction is a pre-condition for invoking jurisdiction under section 153C and, therefore, Tribunal had correctly followed principle in quashing assessment framed under section 153C - Held, yes [Paras 6 to 9) [In favour of assessee]. 29. As per learned AR, this view has also been accepted by the CBDT which is clarified in Circular No 24/2015. As per para 4 of CBDT Circular No 24/2015 dated 31.12.2015, relying on judgment given by the Supreme Court in the case of M/s Calcutta Knitwears (362 ITR 673) the satisfaction note could be prepared at any of the following stages : (a) at the time of or along with the initiation of proceedings against the searched person under section 158BC of the Act; or (b) in the course of the assessment proceedings under section 158BC of the Act; or (c) immediately after the assessment proceedings are completed under section 158BC of the Act of the searched person. 30. It was vehemently argued by learned AR that even if the AO of searched person and the other person is one and the same, then also he is required to record h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in accordance with the guidelines laid down by the Supreme Court in the case of M/s Calcutta Knitwears (Civil Appeal No 3958 of 2014). It was accordingly submitted that in view of the Circular No 24/2015 dated 31.12.2015 the order passed u/s. 153C rws 143(3) of the Act is bad in law and the same should be quashed on this ground. 35. With regard to merit of the addition it was contended by learned AR that although the Assessing Officer has referred to the surrender of income by M/ s. Om Sai Motors group to the DDIT(Inv), Unit - 1(3), he has not furnished any copy of the material relied upon by him. It is submitted that the assessee has requested the Assessing Officer to furnish a copy of the same vide its letter dated 19.11.2012 but till date no response has been received. The Assessing Officer has not given to the assessee the material relied upon by him nor he has given any opportunity to cross examine the parties relied upon by him. Therefore, it is submitted that the addition made by the Assessing Officer is in gross violation of principles of natural justice. It is submitted that the Assessing Officer has relied upon the material that has not been given to the assessee and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , learned AR contended that assessee has discharged its onus to prove that the companies are in existence. Further in case the Assessing Officer could not locate the Company they could have approached the auditors of the Company which have certified in their audit report the activities carried out and state of affairs of these companies. 40. As per learned AR department has not brought any evidence that share application money received by the assessee is actually assessee‟s own money. With regard to AO‟s direction to the assessee to produce the share applicant, it was submitted that assessee had requested many times to share applicant to appear before income tax authorities but they could not produce them since these parties had denied to appear. Further after providing all the required documents before the AO, he has not taken any effort to issue them notice u/s. 133(6) or summons u/s. 131 of the Act to verify the various details regarding share application filed by the assessee company. 41. With regard to the addition made under the head income from other sources and allowing only ₹ 6,00,000/- as agricultural income, it was contended that the agricultural ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... agricultural activity. One of the important features of the verification exercise carried out by Assessing Officer was emphasized by the Ld. Representative before us. In this reference was made to the report of the Inspector, which has also been reproduced in the assessment order, which reveals that the farm of assessee was spread over around 100 acres. The Inspector found 300 to 400 saplings of different type of flowers. A Green House was also found which contained potted plants ranging from 7,000 to 8,000. The report also reveals existence of horticulture plantation and a half stage grown paddy field. Apart from the aforesaid, the report also reveals that the Inspector found around 20 laborers working on the farm, who confirmed that they were regular employees receiving wages from the assessee company. The aforesaid material definitely points out carrying on of agricultural activities, a factum which has been otherwise also accepted by the CIT(A). 13. In the context of the quantum of agricultural income, the declaration made by the assessee is based on its Books of Account, which are duly audited. It is also abundantly clear from the orders of the lower authorities that wha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sment made uls 143(3) of the Act for assessment years 2004-05 to 2006-07, the incomes declared from agricultural activity has been accepted as per the account books, though, such assessments were made prior to the search on the assessee group on 31.10.2009. Nevertheless, the search not having revealed any incriminating material to doubt the entries made in the Books of Account, we, therefore, find little justification for the CIT(A) not to have accepted the quantum of agricultural income as returned in the Books of Account. The verification carried out by the Assessing Officer in the course of assessment proceedings also does not reveal any evidence to support non acceptance of the agricultural income as per Books of Account. The action of CIT(A) in considering the income level for assessment years 2009-10 and 2010-11 and, thereafter,making a reverse computation and deducing incomes for earlier assessment 2006-07 to 2008-09 is also quite flawed. No reasons have been assigned CIT(A) for such a methodology which in any case does not operate as a good substitute to the income computed as per the Books of Account, especially where no clinching infirmity has been found in the Books of A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Bank. The assessee company has taken term loan for acquiring the capital asset, i.e., namely floriculture and mushroom cultivation plants and other machineries. As the assessee company was not able to repay the said loan in the subsequent years and as per settlement arrived with the bank vide letter dated 28.01.2005, the assessee company has got the remission of the total amount of ₹ 1,71,64,933 /- from Canara Bank. Besides the above a sum of ₹ 90,231 was written back on account of a payment due to a creditor for supply of equipments. Thus the total amount written back was ₹ 1,72,55,164 which was disclosed in the Profit and Loss account under the head Extra ordinary Items as One time write back. This amount written back consists principal amount of ₹ 1,34,39,922 and interest of ₹ 37,25,011. The detailed break up is as under :- i ₹ 2,72,74,239 Add Interest payable outstanding - Rs 37,25,011 Total dues - ₹ 3,09,99,250 Less Payment made as per terms of settlement - ₹ 1,38,34,317 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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