TMI Blog2018 (1) TMI 318X X X X Extracts X X X X X X X X Extracts X X X X ..... of cross examination and not supported by independent evidence. The provisions of Transfer of Property Act also does not permit admission of oral evidence in contradiction to the written and registered documents. Hence, in these peculiar facts and circumstances of the case, the purchases consideration declared in respect of the Plot No. D-112A and D-112B, Power House Road, Bani Park, Jaipur admeasuring 500 sq. yards each at ₹ 1.00 crore (@ ₹ 20,000 x500 sq yard) each cannot be rejected. As regards the purchase of Plot (admeasuring 1000 Sq. Yards) No. D-112, Power House Road, Bani Park by the assessee from M/s. Rawat Construction Pvt.Ld, Jaipur for ₹ 1.14 crores, it is noted that the Plot No. D-112 as per registered sale deed was at ₹ 11,400/- per sq. yard. The AO noted that the market value of the plot should exactly be the same as of the above Plots No. D-112A & D-112B i.e. ₹ 7.00 crores. According to the AO, the size of the both the plots No. D-112A & D-112B (500+500 sq.yards) are similar to Plot No. D-112, Power House Road, Banipark, Jaipur. Hence, the AO took the value of the same at ₹ 70,000/-per sq. yard instead of ₹ 11,400/- per s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in law the ld. CIT(A) has erred in confirming the addition of ₹ 10,63,66,700/- which is merely based on statement of Shri Nirmal Kumar Jain and Shri Bimal Kumar Jain, opportunity of whose cross examination was never provided. The action of the ld. CIT(A) is illegal, unjustified, arbitrary and against the facts of the case. Relief may please be granted by deleting the entire addition of ₹ 10,63,66,700/- In the facts and circumstances of the case and in law the ld. CIT(A) has erred in confirming the action of the AO in not referring the matter to the Department Valuation Officer (DVO). The action of the ld. CIT(A) is illegal, unjustified, arbitrary and against the facts of the case. Relief may please be granted by deleting the addition as being without any basis. 2.1 During the course of hearing, the ld.AR of the assessee has not pressed the Ground No. 1 and 2 of the appeal. Hence, the same are dismissed being not pressed. 3.1 Apropos Ground No. 2(a) and (b) of the assessee, facts as emerges from the order of the ld. CIT(A) is as under:- 3.1.2 I have duly considered the assessee s submission and also carefully gone through the assessment order. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is fact, the AO observed that FMV ( Fair Market Value) of this plot should to be taken on the basis of two other plots purchased by the assessee, which are marked as plot no D-112A and D112B from Jain brothers namely Sh Nirmal Kr Jain Sh Bimal Kr Jain. The area of those two plots is also 1000 sq. yds for which the purchase price has been adopted by the AO at ₹ 7 Crore, as against aggregate amount of ₹ 2 crores shown in the two sale deeds. The AO took the rate @ ₹ 70000/= per sq. yrds and on that basis, the AO has held that the land in this area should accordingly be computed at the same purchase price of adjacent plot measuring 1000 sq. yrds purchased from M/s Rawat Construction Pvt. Ltd. Finally, he estimated at ₹ 7,40,60,000/- and added the difference u/s 69B of the Act. For the sake of clarity, relevant extract of AO s finding in page 9 12 of the assessment order are reproduced inter alia here as under: ...................................................................................... .. In view of above facts, the contention of the assessee has no force in it. The addition is not proposed only on the basis of oral evidences. There ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... common plot( Refer Asst Order Pg 7) . In respect of Plot no D-112 A D-112B, purchased from Sh Nirmal Kr Jain and Sh Bimal Kr Jain, both the sellers have accepted fact of receipt of on money to the extent of ₹ 5 Crores and offered the same in their respective returns. This on money payment by Nirmal Kr Jain is also supported by the documents seized in search. Once, the seller has accepted the fact of giving on money, the same has to be considered as paid by the buyer. Similarly, plot no D-112 is part of the plot D-112A D-112B and therefore, the on money payment in respect of plot no D-112 cannot be denied in view of circumstantial evidences. In view of facts and circumstances of the case and duly considering the facts of the evidences found from the sellers premises, the addition made u/s Sec 69B of the Act is confirmed. 3.2 During the course of hearing the ld.AR of the assessee prayed for deletion of addition of ₹ 10,63,66,700/- u/s 69 of the Act for which the ld.AR of the assessee filed the following written submissions dated 11 08-2017 and dated 8-03-2017 respectively. Before A.O 1. Ld. AO completed the assessment u/s 143(3), making t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... PB 118 6 CIT vs. Ashwani Gupta (2010) 191 Taxman 51 (Del) PB 118 7 Unique Organisers Developers (P) Ltd. Vs. Dy. CIT (2001) 70 TTJ (Ahd) 131 PB 118 SUBMISSIONS 1. Written Submissions, made before the ld. CIT(A), appearing at Paper Book Pages 9-107, 108-119 and 120-125 may please be considered. 2. Ld. CIT(A) has passed a very skeptical and non speaking order in a most summary manner. His findings are contained in merely 3 pages at para 3.1.2 (CIT(A) Order pg 23-26), out of which page 25 is only reproduction of the ld. AO finding. 3. Ld. CIT(A) has not considered the pleadings madebefore him. The factual and legal issues raised are not even dealt with by the ld.CIT(A). 4. Ld. CIT(A) has rejected the appeal for the following reasons: Reason by ld. CIT(A) i. Incriminating documents suggesting on money payment with regard to property at Plot No. D-112-A and D-112-B were found and seized. Submissions Ld. CIT(A) has mentioned about the incriminating documents suggesting on money payment. Neither the ld. AO nor the ld. CI ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at no incriminating documents were found and even ld. AO has not examined the directors of the company. Therefore, confirming the addition is unjustified. Reason by ld. CIT(A) v. Ld. CIT(A) finally upheld the order of the ld. AO holding that once the seller accepted the fact of on money, the same has to be considered as paid by the buyer and in respect of Plot No. D-112 on money payment cannot be denied in view of circumstantial evidences. Submissions The final conclusion of the ld. CIT(A) is based on his misconception that once seller accepts the fact of on money receipt, the payment of the same by the buyer cannot be denied. Under the peculiar facts of the instant case, the buyers have admitted the on money receipt in their self interest and there is no corroborative evidence in this regard. Therefore, their acceptance has no evidentiary value against the appellant company. The request for cross examination was turned down which renders the statements of no evidentiary value. 5. Before the ld. CIT(A), following cases relied upon by the ld. AO were adequately distinguished: 6. Positive material needed to prove higher consideration: In the following judi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7. Before the ld. CIT(A), reliance was placed on following judicial pronouncements where alleged unexplained investment in house was deleted. It was requested that assessee case was stronger on facts and therefore, additions deserved deletion. S. No. Case law Gist at PB Page 1 CIT v/s K. Bhuvanendran Ors. (2008) 303 ITR 235 (Mad.) 56 2 CIT v/s Dr. Raj Dhariwal ITA No. 138/2011 (Raj.) 56-59 3 Ramesh Pershad V/s Inspecting Assistant Commissioner 28 ITD 550 (Hyd.) 59-61 4 DCIT v/s Ratan Corporation (2005) 197 CTR (Guj) 536 61 5 Ushakant N. Patel V/s CIT (2006) 282 ITR 553 (Guj.) 61 6 Ms. Aishwarya K. Rai v/s DCIT (2007) 104 ITD 166 (MUM) (TM ) 62-63 7 Dadamchand Mochi V/s ITO (2006) 36 Tax World 11 (Jd) 63 8 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Ors. (1974) 94 ITR 616 (Bom) 74-75 7 CIT v. Haji jan Mohd. Gaur (2004) 267 ITR 765 (Raj.) 75 8 Add. CIT v. karnail Singh V. Kaleran (1974) 94 ITR 505 (P H) 75-76 9 V. Ramaswami Naidu v. CIT (1974) 93 ITR 341 (Mad) 76 10 CIT v. R.Y. Durlabhji (1995) 211 ITR 178 ( Raj) 76-77 11 Prahlad maliram v. CIT (1987) 166 ITR 149 (Raj) 77 12 Kalwa Devadattam Ors. V. UOI Ors. (1963) 49 ITR 165 (SC) 77 13 CIT v. Suresh Kumar Goyal (2004) 32 tax World 128 (Raj) 78 In the instant case, additions have been made without discharging the heavy burden where unexplained investment is alleged. Evidences have to be conclusive to suggest unexplained investment. 9. Suspicion, however strong, cannot take the place of evidence. Following judicial pronouncements cited before the ld. CIT(A) have ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Raj.) 40 87-88 11 ITO v/s Dr. R.L. Narang (2008) 174 Taxman 96 (Mag.) (Chd.) 88-89 12 Eagle Seeds Biotech Ltd. V/s ACIT (2006) 100 ITD 301 (Ind.) 89 13 CIT v. Gujarat Heavy chemicals Ltd. (2002) 256 ITR 795 (SC) 89-90 14 Shri J.R.C. Bhandari v. ACIT (2003) 79 TTJ (Jd) 90-91 15 Narayan Dass Singhi v/s Income Tax Officer (2004) 87 TTJ (JD) 615 91-92 16 Dr. Chetan Prakash Ranka v/s ITO (2005) 33 Tax World 72 (Jp.) 92-93 17 Unique Organisers Developers (P) Ltd. v/s DCIT (2001) 70 TTJ (Ahd) 131 93 18 Kishanchand Sobhrajmal v/s Assistant Commissioner of Income Tax (1992) 41 ITD 97 (Jp) 94 19 Smt. Purnima Beri v/s Dy. CIT (2003) 264 ITR 54 (Amritsar) 94-95 20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er authorities renders their orders unsustainable in the eyes of law and, therefore, deserves to be quashed. 13. The addition so made does not pertain to the Assessment year 2010-11. The statements of ShriNirmal Kumar Jain and ShriBimal Kumar Jain on the basis of which additions have been made do mention (Question No. 14 to Nirmal Kumar Jain AO Page 8) that the alleged on money was paid during the period January 2009 to April 2009. The assessment year 2010-11 starts from 1st of April 2009. Therefore the addition so made does not pertain to the assessment year 2010-11 and, therefore, the addition deserves to be deleted on this account. It is the onus of the ld. AO to specifically pinpoint the dates for the purpose of deciding the relevant assessment year. The statements are very precise that the payments have been made during the period January 2009 to April 2009. This is without agreeing to the merit of the additions made by the ld. AO. This is an alternative argument and may not be treated as our agreeing to the addition. 14. The ld. AO has very conveniently ignored the following requests of the assessee company during the course of assessment proceedings: i. Cros ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Relevant Law Judicial Pronouncements 1 Contents of the duly Executed and Registered Sale Deed become final and unchallengeable. Section 54 - Transfer of Property Act 1882 CIT v. Motor General Stores (P.) Ltd. 66 ITR (1967) page 692 (SC) 16 Sec. 17 - Indian Registration Act, 1908 Indian Stamp Act, 1899 2 Oral Evidence is not admissible against Registered Sale Deed. Section 91 and 92 - Indian Evidence Act, 1872 Divansingh vs. Gurbachan Singh and others AIR 1932 Lahore 276 (Lahore High Court ) 17-18 Doddamallappa v. Gangappa AIR 1962 Mysore 44 (Mysore High Court) Leelamma Ambikakumari and another Vs. Narayanan Ramakrishnan AIR 1992 Kerala 115 (Kerala High Court) Febril Gasosa vs. Labour Commissioner and others AIR 1997 (S.C.) 954 Paramjit Singh Vs. Income Tax Officer (2010) 323 ITR 0588 (P H) Smt. K.Narasamma vs. ITO (1990) 32 I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... esses were made the basis of the impugned order is a serious flaw which makes the order nullity inasmuch as it amounted to violation of principles of natural justice because of which the assessee was adversely affected (Case Law Page 35). The said order of the Apex Court in the case of Andaman Timber Industries (Supra) has also been followed by the Hon ble Gujarat High Court in the case of Raman Bhai B Patel (Tax Appeal No. 207,208,2010 of 2008) (Case Law Page 45) In view of the above, this ground of appeal may please be allowed and additions, made by the ld. AO and upheld by ld. CIT(A), may please be deleted GIST OF SUBMISSIONS II (FURTHER TO GIST DATED 11.08.2016) 1. Department Paper Book received on 22.08.2016 (covering letter dated 19.08.2016) 1.1 Department has provided a Paper Book on 22.08.2016 which is not in compliance with the Income Tax (Appellate Tribunal) Rules, 1963. There is no certificate in the said Paper Book. There has to be certification from the Department whether these were confronted to the assessee at assessment stage. 1.2 If these papers have not been confronted to the assessee during assessment, we strongly object their admissi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessment is completed without reference to any pin-pointed document but even appeal was also dismissed without any mention of such documents or allowing opportunity of cross examination. 3.4 Therefore, the documents, now referred by the ld. DR, have no relevance to the proceedings before the Hon ble ITAT. 3.5 Ld. AO did not read these documents against the assessee or alternatively, he was not aware of these documents. In either situation, now at this stage, these documents cannot be referred. The recourse available to the Department may be re-opening the assessment or invoking revisionary powers u/s 263. 3.6 Any attempt to improve the case of the ld. AO is not permissible at this stage. 3.7 Without prejudice to above in respect of so-called notings by Shri Bimal Kumar Jain, attention is drawn towards the judgement of the C.B.I v. V.C. Shukla 1998 (3) SCC 410 wherein Hon ble Supreme Court observed as under:- In Beni Vs. Bisan Dayal [ A. I. R 1925 Nagpur 445] it was observed tat entries in book s of account are not by themselves sufficient to charge any person with liability, the reason being that a man cannot be allowed to make evidence for himself b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3,46,50,000 Less: Purchase cost of the property 4,52,062 Assessee's share 1/2 of the same 2,26,031 Indexed cost (2,26,031 * 632 /133) 10,74,072 Long term Capital Gain 3,35,75,928 Less: Deduction u/s 54F for purchase of residential flat Purchase cost (53,23,000 / 3,46,50,000 x 3,35,75,928) 51,57,999 Chargeable Long Term Capital Gain 2,84,17,929 Tax on above @ 20% 56,83,586 Add: Cess @ 3% 1,70,508 Total Tax 58,54,094 5. Shri Nirmal Kumar Jain Acceptance of on-money to cover his own unaccounted investments Similarly, Shri Nirmal Kumar Jain also made investments in purchase of properties, part of which was funded out of his own undisclosed income and evidences of which were found and seiz ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... me and there was no electricity connection when the assessee took the possession of this flat. The total investment made by the assessee in this flat is ₹ 82,33,780/-. 6. The appellant seeks the opportunity of cross examination and also the opportunity to make submissions in respect of alleged incriminating documents now referred before the Hon ble ITAT. However, without prejudice to the above, it is submitted that no second innings can be allowed to AO for making up the deficiency in the completed assessment. Reliance is placed on following judicial pronouncement:- A. JURISDICTIONAL BENCH Abdul Latif [2011] 130 ITD 255 (JAIPUR) 5 . We do not feel to provide second inning to the revenue because the entire facts were before the Assessing Officer and the Assessing Officer made an addition on wrong grounds. Indian Shaving Products Ltd. [2007] 106 ITD 80 (JAIPUR) (TM) In the case of CIT v. Harikishan Jethalal Patel [1987] 168 ITR 4721 , Hon ble Gujarat High Court through Justice A.M. Ahmadi as his Lordship then was, observed as under : . . . It is obvious from the demand made before the Appellate Tribunal that the Revenue desires to exam ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e transaction in question, a second innings should not be permitted to the Revenue as it would result in avoidable hardship and harassment to hundreds of assessees whose cases stand covered by the aforesaid decision of the Supreme Court. It was only because the Income-tax Officer thought that the transaction in question was a genuine one and the agricultural land was transferred to the firm, the genuineness of which was not in doubt, that the Income-tax Officer, after deducting the cost of acquisition of the land, computed the capital gain at ₹ 1,32,172 and added the same to the net income of the assessee for the assessment year 1976-77. The genuineness of the firm as well as the transaction was, therefore, never in doubt. Therefore, the Appellate Tribunal was right in law in not remanding the matter to the Income-tax Officer for redeciding the issue. 24. In this respect we further find support from the order of the Hon'ble apex court in case of Suresh Chand AIR 1988 SC 247 (sic) wherein it was observed that in case where it is found that no useful purpose will be served by a remand and the issue can be decided on admitted facts, empty formality must be eschewed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... result would be that hundreds of assessees would be unnecessarily vexed and put to avoidable hardship. Therefore, in cases where foundational facts did not exist raising even a remote doubt regarding the genuineness of the firm and/or the transaction in question, a second innings should not be permitted to the revenue as it would cause considerable harassment, hardship and expenditure to the assessees. Saraladevi Sarabhai (P-1) D Trust [2002] 123 Taxman 1064 (Gujarat) In the case of Harikishan Jethalal Patel (supra), this Court has already observed that in cases where foundational facts do not exist raising even a remote doubt regarding the genuineness of the firm and/or the transaction in question, a second innings should not be permitted to the revenue, as it would result in avoidable hardship and harassment to hundreds of assessees whose cases stand covered by the aforesaid decision of the Supreme Court. We are of the opinion that there are no foundational facts on the record of this reference raising doubt regarding genuineness of the partnership firm and/or the transaction in question and, therefore, a second innings should not be permitted to the revenue for rec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ith learned standing counsel that this part of the reasoning of the Tribunal may not be strictly correct in law, but the said observation, in our opinion, has not vitiated the finding of the Tribunal which has been arrived at independently on the basis of the material on record. Manish Build Well (P.) Ltd [2011] 16 taxmann.com 27 (Delhi) In our view of these facts and circumstances it cannot be held that CIT(A) (sic) violated Rule 46A, he had acted in a judicious and proper manner and his order being based on proper appreciation of facts and record cannot be called violative of a procedural provision. CIT(A) is statutory first appellate authority and has independent power of calling for information and examination of evidences and poses conterminous power of assessment apart from appellate powers. In our view CIT(A)'s order is to be upheld. The matter should not be set aside on general ground as it amounts to causing the assessee injustice and giving the AO another innings. Besides it is not explicit that AO insisted for confirmations. Dell International Services India P. Ltd. [2016] 382 ITR 37 (KAR) it was a settled law that remand was not a po ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2016) relied upon by ld. DR are distinguished below:- Case 1:- Smt. Kusum Lata Thakral vs. CIT 327 ITR 424 (P H) The facts of this case are very different. In this case Hon ble Supreme Court held that there was no necessity for cross examination of donor because of the peculiar fact that donor had denied giving gift and there was no relationship between donor and assessee. Attention is drawn towards the recent decision of Hon ble Supreme Court in case of Andaman Timber Industries (Civil Appeal no. 4228 of 2006). Case 2 and 3:- B. Kishore Kumar vs. DCIT 273 CTR 468 (MAD) and B. Kishore Kumar vs. DCIT 62 taxmann.com215 (SC) In this case additions were based on sworn statement of assessee during search whereas in the present appeal additions are based on the basis of statement of third party. Case 4:- CIT vs. P.M. Aboobacker 45 taxmann.com 172 (KER) In this case opportunity of cross examination was granted which in the present appeal has not been granted inspite of specific request. Case 5: Amar Kumari Surana vs. CIT 226 ITR 344 In this case before the Hon ble Rajasthan High Court assessee offered no explanation as to why l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is case non furnishing of copy of statement given by production incharge did not amount to denying opportunity of cross examination to assessee as it did not cause any prejudice to assessee especially when addition was made solely on the basis of return filed, document produced and submission made by assessee. Such is not the case of the assessee appellant. Case 15:- GTC industries Ltd. vs. ACIT 65 ITD 380 This case is with reference to secondary and subordinate material which is evident from the following:- Section 143(3) of the Income-tax Act, 1961 - Assessment - Principles of natural justice - Assessment year 1985-86 - Whether, where material or evidence used for purposes of assessment is of collateral nature, rule that adverse evidence and material relied upon to reach finality should be disclosed to assessee is not applicable - Held, yes - Whether right to cross-examine witness who made adverse report is an invariable attribute of requirement of dictum audi alteram partem - Held, no - Whether where statements of witnesses were only secondary and of subordinate material used to buttress main matter connected with amount of additions, it had to be held that th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... purchased the following properties for the sale consideration as mentioned against each. (i) Plot No. D-112-A, at Power House Road, Bani Park, Jaipur measuring to 500 sq. yards from Shri Nirmal Kumar Jain S/o late Shri Nathmal Jainfor ₹ 1.00 crore vide registered agreement dated 17-04-2009. (ii) Plot No. D-112-B at Power House Road, Bani Park, Jaipur measuring 500 sq. yars from Shri Bimal KumarJain S/o late Shri Nathmal Jain for ₹ 1.00 crore vide registered sale agreement dated 17-04-2009. (iii) Plot No. D-112 at Power House Road, Bani Park, Jaipur measuring to 1000 sq. yards from M/s. Rawat Construction Pvt. Ltd for ₹ 1.14 crores vide registered agreement dated 28-052009. The AO noted that after including the registration cost of ₹ 22,33,300/- the value of above investment comes to ₹ 3,36,33,300/- (Rs. 1,00,00,000+Rs. 1,00,00,000+1,14,00,000+Rs. 22,33,300/-). Further the AO in this case also mentioned that a search u/s 132 of the Act was carried out on 23-07-2009 at the business and residential premises of Shri Bimal Kumar Jain and Shri Nirmal Kumar Jain wherein various incriminating documents were found and seized. But no incriminating do ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee from M/s. Rawat Construction Pvt Ltd Jaipur for a consideration of ₹ 1.14 crores vide registered agreement dated 28-05-2009 which is exactly adjacent to Plot No. D-112A and D-112B. The AO observed that the plots D-112A and D-112B are nothing but parts of Plot No. D-112. Later on Plot No. D-112 was sub-divided creating plot No D-112A (D-112A was further divided into two parts i.e. D-112A and D-112B). Thus the above Plot No. D-112 as per registered sale deed was at ₹ 11,400/- per sq. yard. According to the AO, both the above plots D-112 and ( D-112A D-112B) combined are exactly of same size i.e. 1000 sq. yards as well as adjacent to each, therefore, there seems to be no concrete reasons for having any major variation in the market of the above mentioned properties. According to the AO, it is evident that the market value of the above properties are higher side but the registries of the same are made at lower value. The AO adopted the market value of Plot No. D-112 exactly the same as of the above Plots Nos. D-112A D-112B i.e. ₹ 7.00 crores (since the size of Plot No. D-112 and Plot No. D-112A + D-112B is exactly same i.e. 1000 sq. yard each) or to say S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ards 11,400,000 claimed benefit of section 54 of the Act on this amount so disclosed to be unaccounted investment. The AO considered the rate of property at ₹ 70,000/-per sq. yard for working out the on money in respect of D-112A and D-112B, Power House Road, Banipark. Assessee prayed for cross examination from both these persons i.e. Shri Bimal Kumar Jain and Shri Nirmal Kumar Jain but the same was not allowed. Admission by a person is good evidence in his own case but it is not sufficient and conclusive in case of other person when that person had own interest in giving such statement unless the other person is given cross examination and statement is supported by any other independent evidence. The facts of this case clearly establishes that denial of appointment of cross examination resulted into violation of principles of natural justice. The object of cross examination is to test the veracity of the version given in examination in chief. In this case the persons who gave statements were interested persons as they were found in possession of unaccounted investment and by giving such statement they have explained such unaccounted investment and also claimed benefit u/s 54 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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