TMI Blog2018 (7) TMI 1882X X X X Extracts X X X X X X X X Extracts X X X X ..... ibunal we hold that the show cause issued by the AO in the case assessee is not sustainable and liable to the quashed. AO has accepted the explanation of the assessee regarding substantiation of the manner for earning the undisclosed income in question. The details of the entries in the seized material disclose certain amounts are recorded as advance to the persons, expenditure on construction of house and expenditure on the marriage of daughter. Thus, measure amount of undisclosed income consisted the sundry advances. All these transactions do not pertain to the business activity of the assessee but these are either advances given by the assessee or expenditure incurred on construction of the house or expenditure on the marriage of the daughter. Therefore, the entries in the seized material are not the transactions generating income except some interest income. When the assessee is not required to maintain the books of account as per section 44AA, then the matter is required to be examined whether the alleged undisclosed income is recorded in the other documents maintained in the normal course as per clause (c) to Explanation to section 271AAB. Undisputedly the alleged incom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ITA No. 855 & 856/JP/2017 Assessment Year : 2013-14 & 2014-15 - - - Dated:- 24-7-2018 - Shri Vijay Pal Rao And Shri Bhagchand, JJ. Assessee by : Shri S.L. Poddar (Adv.) Ms Isha Kanungo (Adv.) Revenue by : Sri A.S. Nehra (JCIT) ORDER Vijay Pal Rao, These two appeal by the assessee are directed against separate orders of CIT (A), Jaipur both dated 01.11.2017 arising from penalty order passed U/s 271AAB of the IT Act for the assessment years 2013- 14 2014-15 respectively. First, we taken up assessee s appeal in ITA No. 855/JP/2017 wherein the assessee has raised the following grounds:- 1. Under the facts and circumstances of the case the learned CIT(A) erred in passed the order U/s 271AAB of the Income Tax Act, 1961 which is void ab-inito deserves to be quashed. 2. Under the facts and circumstances of the case the Learned CIT(A) has erred in confirming the action of the Learned Assessing Officer in imposing the penalty of ₹ 81,34,155/- U/s 271AAB of the Income Tax Act, 1961. 3. The assessee craves your indulgence to add amend or alter all or any grounds of appeal before or at the time of hearing. The assessee has also raised the ad ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ve considered the rival submissions as well as relevant material on record. At the outset, we note that the issue raised in the additional ground was very much before the ld. CIT(A). The ld. CIT(A) has noted at page 8 and 9 of the impugned order as under:- The appellant has raised an objection that specific sub-section or submissions-clause of 271AAB was not specified while initiating the penalty has no basis as different sub-clause pertain to rate of imposition of penalty and it does not change the qualitative aspect of imposition of penalty U/s 271AAB. The reliance on Manjunath Cotton ginning [259 ITR 565] has no bearing on the case as judgment was delivered in context of U/s 271(i)(c). It is clear from the discussion above that penalty u/s 271AAB is mandatory penalty and there is no discretion with the income tax authorities. In view of the above the penalty imposed of ₹ 81,34,155/- by the AO is correct and is upheld. Thus, the issue raised in the additional ground is not a fresh plea raised before this Tribunal but it was very much raised before the ld. CIT(A). Further, the said issue is purely legal in nature and can be decided on the basis of the facts availa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Officer has imposed penalty U/s 271AAB(1)(a) but assessee was not issued any show cause notice mentioning this specific section nor the penalty proceedings were initiated in the assessment order mentioning Section 271AAB(1)(a). In view of these illegalities the levy of penalty deserves to be deleted. The Assessing Officer issued the following two show cause notices scanned below which do not disclose that assessee was required to show cause specifically for default U/s 271AAB(1)(a) of the Act. In view of the above facts the penalty proceeding was not initiated, validity and before imposition of penalty show cause notices were not issued validity as there was no specific mention of section 271AAB(1)(a) for which the Assessing Officer subsequently imposed the penalty. The assessee was not aware to put his defense for dis-levy of penalty. It is the submission of the assessee that a duty was cast upon the Assessing Officer to initiate penalty proceedings specifically and seek reply of the assessee accordingly. But nothing was done of this sort. Thus, the initiation of the penalty proceeding itself was unlawful, illegal and unjust. In the circumstances the levy of penalty was not justif ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the issue of levy of penalty is not automatic but the Assessing officer has to examine all the facts and record and then to take a decision whether it is a fit fact for levy of penalty U/s 271AAB. 8. Having considered the rival submissions as well as relevant material on record we note that there is no quarrel on the fact that in the show cause issue U/s 271AAB r.w.s. 274 of the Act the AO has not specified the particular clause which is applicable or propose to be applied in the case of the assessee for levy of penalty U/s 271AAB of the Act. Thus the AO has not mentioned in the show cause notice to but what would be the quantum of penalty to be levied U/s 271AAB of the Act whether it would be 10% or 20% or 30% of the undisclosed income in terms of clause-(a) to (c) of section 271AAB(1) of the Act. We further note that an identical issue was considered by this Tribunal in case of Shri Ravi Mathur vs. DCIT vide order dated 13.06.2018 in ITA No. 969/JP/2017 in paras 4 to 7 as under:- 4. We have considered the rival submissions as well as relevant material on record. A search was conducted under section 132 of the IT Act on 30th October, 2014 at the premises of the assessee. Th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as under :- 271AAB. (1) The Assessing Officer may, notwithstanding anything contained in any other provisions of this Act, direct that, in a case where search has been initiated under section 132 on or after the 1st day of July, 2012 49[but before the date on which the Taxation Laws (Second Amendment) Bill, 2016 receives the assent of the President50], the assessee shall pay by way of penalty, in addition to tax, if any, payable by him,- (a) a sum computed at the rate of ten per cent of the undisclosed income of the specified previous year, if such assessee- (i) in the course of the search, in a statement under sub-section (4) of section 132, admits the undisclosed income and specifies the manner in which such income has been derived; (ii) substantiates the manner in which the undisclosed income was derived; and (iii) on or before the specified date- (A) pays the tax, together with interest, if any, in respect of the undisclosed income; and (B) furnishes the return of income for the specified previous year declaring such undisclosed income therein; (b) a sum computed at the rate of twenty per cent of the undisclosed income of the specified previous year, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e expires, as the case may be; (b) specified previous year means the previous year- (i) which has ended before the date of search, but the date of furnishing the return of income under sub-section (1) of section 139 for such year has not expired before the date of search and the assessee has not furnished the return of income for the previous year before the date of search; or (ii) in which search was conducted; (c) undisclosed income means- (i) any income of the specified previous year represented, either wholly or partly, by any money, bullion, jewellery or other valuable article or thing or any entry in the books of account or other documents or transactions found in the course of a search under section 132, which has- (A) not been recorded on or before the date of search in the books of account or other documents maintained in the normal course relating to such previous year; or (B) otherwise not been disclosed to the 54[Principal Chief Commissioner or] Chief Commissioner or 54[Principal Commissioner or] Commissioner before the date of search; or (ii) any income of the specified previous year represented, either wholly or partly, by any entry in resp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (4) would not ipso facto par take the character of undisclosed income but the facts of each case are required to be analyzed in objective manner so as to attract the provisions of section 271AAB of the Act. Since it is not automatic but the AO has to give a finding that the case of the assessee falls in the ambit of undisclosed income as defined in Explanation to the said section. Therefore, the provisions of section 271AAB stipulate that the AO may come to the conclusion that the assessee shall pay the penalty. The only mandatory aspect in the provision is the quantum of penalty as specified under clauses (a) to (c) of Sec. 271AAB(1) of the Act as 10% to 30% or more as against the discretion given to the AO as per the provisions of section 271(1)(c) of the Act where the AO has the discretion to levy the penalty from 100% to 300% of the tax sought to be evaded. Thus the AO is duty bound to come to the conclusion that the case of the assessee is fit for levy of penalty under section 271AAB and then only the quantum of penalty being 10% or 20% or 30% has to be determined subject to the explanation of the assessee for the defaults. 5. Before we proceed further, the decisions relied ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CIT vs. Amit Agarwal (supra), we find that the said decision was subsequently recalled by the Tribunal and a fresh order dated 14th March, 2018 was passed by the Tribunal in favour of the assessee. Therefore, the decision relied upon by the ld. D/R is no more in existence. 6. The question whether levy of penalty under section 271AAB by the AO is mandatory or discretionary has been considered by the Visakhapatnam Bench of this Tribunal in case of ACIT vs. M/s. Marvel Associates (supra) in para 5 to 7 as under :- 5. We have heard both the parties, perused the materials available on record and gone through the orders of the authorities below. During the appeal hearing, the Ld. A.R. vehemently argued that the A.O. has levied the penalty under the impression that the levy of penalty in the case of admission of income u/s 132(4) is mandatory. The Ld. A.R. further stated that penalty u/s 271AAB of the Act is not mandatory but discretionary. The provisions of section 271AAB of the Act is parimateria with that of section 158BFA of the Act relating to block assessment and accordingly argued that the levy of penalty under section 271AAB is not mandatory but discretionary. When there is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... section (1). Section 158BFA(2): (2) The Assessing Officer or the Commissioner (Appeals) in the course of any proceedings under this Chapter, may direct that a person shall pay by way of penalty a sum which shall not be less than the amount of tax leviable but which shall not exceed three times the amount of tax so leviable in respect of the undisclosed income determined by the Assessing Officer under clause (c) of section 158BC: Provided that no order imposing penalty shall be made in respect of a person if- (i) such person has furnished a return under clause (a) of section 158BC; (ii) the tax payable on the basis of such return has been paid or, if the assets seized consist of money, the assessee offers the money so seized to be adjusted against the tax payable. (iii) Evidence of tax paid is furnished along with the return; and (iv) An appeal is not filed against the assessment of that part of income which is shown in the return: Provided further that the provisions of the preceding proviso shall not apply where the undisclosed income determined by the Assessing Officer is in excess of the income shown in the return and in such cases the penalty shall be im ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Act is not mandatory but directory. Accordingly we hold that the penalty u/s 271AAB is not mandatory but to be imposed on merits of the each case. Thus the Tribunal has held that the levy of penalty under section 271AAB is not mandatory but the AO has the discretion to take a decision and shall be based on judicious decision of the AO. Hence we fortify our view by the above decisions of Tribunal in case of ACIT vs. Marvel Associates. 7. As regards the validity of notice under section 274 for want of specifying the ground and default, we find that when the basic condition of the undisclosed income not recorded in the books of accounts does not exists, then the same has to be specified by the AO in the show cause notice and further the AO is required to give a finding while imposing the penalty under section 271AAB. Even if the AO is satisfied and come to the conclusion that the assessee has not recorded the undisclosed income in the books of accounts or in the other documents / record maintained in normal course relating to specified previous year, the show cause notice shall also specify the default committed by the assessee to attract the penalty @ 10% or 20% or 30% of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... otice issued under Section 274 without taking into consideration the assessment order when the assessing officer has specified that the assessee has concealed particulars of income? 3. The Tribunal has allowed the appeal filed by the assessee holding the notice issued by the Assessing Officer under Section 274 read with Section 271(1)(c) of the Income Tax Act, 1961 (for short the Act ) to be bad in law as it did not specify which limb of Section 271(1)(c) of the Act, the penalty proceedings had been initiated i.e., whether for concealment of particulars of income or furnishing of inaccurate particulars of income. The Tribunal, while allowing the appeal of the assessee, has relied on the decision of the Division Bench of this Court rendered in the case of CIT vs. Manjunatha Cotton and Ginning Factory (2013) 359 ITR 565. 4. In our view, since the matter is covered by judgment of the Division Bench of this Court, we are of the opinion, no substantial question of law arises in this appeal for determination by this Court. The appeal is accordingly dismissed . In the earlier case of Manjunatha Cotton and Ginning Factory (supra) their lordship had observed as under:- Noti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ision of the AO. 9. As regards the validity of notice U/s 274 for want of specifying the ground and default of the assessee the Tribunal has held that the AO is required to specifically state in the show cause notice the gfound and the default committed by the assessee as to attract the penalty U/s 271AAB of the Act @ 10% 20% or 30% of the undisclosed income. In the absence of specifying the default and charge against the assessee for which the penalty was proposed to be levied the show cause notice issued by the AO and initiation of proceeding for levy of penalty U/s 271AAB are not valid. Hence, following the earlier order of this Tribunal we hold that the show cause issued by the AO in the case assessee is not sustainable and liable to the quashed. 10. Ground No. 2 is regarding merits of levy of penalty. The ld. AR of the assessee has submitted that in the statement recorded U/s 132(4) the assessee has very specifically stated that he was declaring/surrendering income subject to his request that no penalty and prosecution proceedings will be initiated. In view of this it was requested to the AO not to impose any penalty in the case as the assessee furnished return in good f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t assessee should not be penalized for cooperating the departmental authorities and payment of tax because in actual there were no concealment and the total surrender was divided in earlier years and the assessee was having bonafide belief that no penalty was leviable on such surrender. The legal help was also not available at the time of surrender so the assessee was not knowing the consequences of surrender in earlier years and the surrender was made by the assessee with a bonafide belief that no penalty was leviable. The Ld. Assessing officer in the para 3 on page no. 2 of the assessment order has mentioned that the total income declared in the ROI for the specified year includes this undisclosed income of ₹ 8,13,41,547/- which represented the undisclosed income as explained in clause (c) of explanation given in the section 271AAB. It is not clarified that why the Learned Assessing Officer has treated the income of ₹ 8,13,41,547/- as undisclosed income. Because the assessee was maintaining a separate account for the income surrendered during the course of search. These papers were also maintaining as books of accounts placed on paper book page number 1 to 92. In thes ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s activity of the assessee but these are either advances given by the assessee or expenditure incurred on construction of the house or expendi ture on the marriage of the daughter. Therefore, the entries in the seized material are not the transactions generating income except some interest income. At the outset we note that the Coordinate Bench of this Tribunal in case of Shri Ravi Mathur vs. DCIT (supra) has considered the issue of levy of penalty U/s 271AAB in paras 8 and 9 as under:- 8. Even otherwise, without restricting ourselves to the validity of show cause notice, we note that section 271AAB of the Act contemplates imposition of penalty pursuant to the disclosure of undisclosed income in the statement recorded under section 132(4) and, therefore, the levy of penalty under this section does not depend on the addition made during the assessment proceedings. Hence the penalty proceedings under section 271AAB are completely independent of the enquiry and finding of the AO in the assessment order except for the limitation provided as per section 275 of the Act. We have already held that the penalty is not automatic but the AO has to take a decision to impose the penalty afte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e was not required by any mandate of law to maintain regular books of accounts. In the computation of income, the assessee has shown income from Salary, income from house property and income from other sources. The returned income was accepted by the AO while framing the assessment under section 143(3) and hence assessee s case does not fall in the category where the regular books of accounts are mandatory. The entries of investment in real estate were found recorded in the diary and in the absence of any other document maintained in the normal course relating to the year under consideration, the entries in the diary are to be considered as recorded in the documents maintained in the normal course. It is not the case of the revenue that the assessee has recorded the other transactions in the other documents maintained in the regular course relating to the year under consideration and only these entries are recorded in the diary. Since the levy of penalty under section 271AAB is not based on the addition and enquiry conducted by the AO in the assessment proceedings, therefore, it is incumbent on the AO to conduct a proper examination of facts, circumstances and explanation furnished ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d rival submissions and gone through the facts and circumstances of the case. We find that the issue involved herein is squarely covered in favour of the assessee in the case of DCIT vs Manish Agarwala (another member in the same Nezone Group) in ITA No. 1479/Kol/2015 for AY 2013-14 dated 9.2.2018 by the order of this tribunal , wherein it was held as under:- 3. We have heard rival submissions and gone through the facts and circumstances of the case. We note that the AO has levied the penalty u/s. 271AAB on the ground that the income from commodity profit has been found during search u/s.132 of the Act which is not reflected in the regular books of account. The AO has accepted that during search the assessee has admitted u/s. 132(4) of the Act the income from speculative trading. The undisputed facts the AO has given finding pertaining to this case is as follows: i) The assessee has substantiated the manner in which the income was derived. ii) Furnished the return of income therein and iii) Paid the tax along with interest. Based on the said finding, according to AO, the assessee satisfies the conditions enumerated in sec. 271AAB(i)(a) of the Act and thereafter levie ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y in our opinion, gives a discretion to the AO to levy the penalty or not to levy, even if the assessee has made the default under the said provision. Therefore, the 2nd ground of Revenue fails and we hold that penalty u/s. 271AAB of the Act is not mandatory and is discretionary. Before proceeding further, we note that the ex parte order passed by the Coordinate Bench relied upon by Ld. DR, Manoj Beswal, supra, have been recalled in MA Nos. 218 to 220/Kol/2017 dated 12.01.2018 by observing as under: By virtue of these miscellaneous applications, the assessee seeks to recall the order passed by this Tribunal in I.T.A. Nos. 1471, 1475 1476/Kol/2015 in the hands of Amit Agarwal, Madan Lal Beswal and Manoj Beswal respectively for the assessment year 2013-14 on the ground that notice was not served on the assessee for the hearing and on certain factual error that had crept in the order of the Tribunal. The first preliminary objection raised by the Ld. AR was that the notice of hearing was not served on the assessee for the hearing scheduled on 06.11.2017 and hence, the assessee could not be present on the said date by way of personal appearance. The second objection raised by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ain any books of account as per the Act. According to Ld. AR, undisputedly the assessee was engaged for the first time this AY only in trading of commodities, that too which was conducted in a non-systematic manner and the income from it was duly offered to tax by the assessee in his return of income under the head Income from Other Sources , which, according to Ld. AR was accepted as such by the AO and drew our attention to page one of assessment order, (not the penalty order) wherein we note that the AO has acknowledged that the assessee owned up ₹ 3 cr. as his income from commodity profit and it has been disclosed in his income and expenditure for AY 2013-14 under the head income out of speculative business from sale of commodities , and thereafter the AO confirmed the assessee s claim and thereafter total income was assessed by the AO as per the return submitted by the assessee. In the light of the aforesaid facts discerned from assessment order, the assessee s case is that for the first time in this AY he was doing unsystematic speculative activity which earned income and, it was brought under the head Income from Other Sources , and so, accordingly, he is not require ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... keep and maintain such books of account and other documents as may enable the [Assessing] Officer to compute his total income in accordance with the provisions of this Act. (3) The Board may, having regard to the nature of the business or profession carried on by any class of persons, prescribe, by rules, the books of account and other documents (including inventories, wherever necessary) to be kept and maintained under sub-section (1) or sub-section (2), the particulars to be contained therein and the form and the manner in which and the place at which they shall be kept and maintained. (4) Without prejudice to the provisions of sub-section (3), the Board may prescribe, by rules, the period for which the books of account and other documents to be kept and maintained under sub-section (1) or sub-section (2) shall be retained.] So from a reading of the above provisions which clearly stipulates that assessee who are carrying on business or profession shall keep and maintain such books of account and other documents which may enable the AO to compute the total income. We note that assessee in the statement of total income filed before the AO has shown income only under tw ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... able to negate the claim of the assessee by bringing the income from commodity transactions as part of business income. It should be remembered that under the Income Tax Act 1961, the total income of an assessee individual /company is chargeable to tax u/s. 4 of the Act. The total income has to be computed in accordance with the provisions of the Act. Section 14 of the Act lays down that for the purpose of computation, income of an assessee has to be classified under five heads. It is possible for an assessee/individual/company to have five different sources of income, each one of it will be chargeable to Income Tax Act. Profits and gains of business or profession is only one of the heads under which an assessee s income is liable to be assessed to tax. If an assessee has not commenced business there cannot be any question of assessment of its profits and gains of business. That does not mean that until and unless the assessee commences its business, its income from any other source will not be taxed as held by the Hon ble Supreme Court in the case of Tuticorin Alkali Chemicals Ltd. Vs. CIT (1997) 227 ITR 172 (SC). It has been further held that when the question is whether a rec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t in dispute that assessee is not engaged in any business. And the AO cannot change the character of income in a derivative proceeding which is an off-shoot of assessment proceedings i.e. the penalty proceedings without contesting and making a finding against the claim of the assessee in the assessment order as discussed above. 7. Finally, the Ld. AR submitted that during the search, the search party found the records of the assessee s transactions in speculative commodity from the drawer of assessee s accountant from which the AO could compute the income of the assessee from the said transaction which amount assessee declared during search and which was duly returned and which figure was accepted by the AO. According to Ld. AR, the fact that search happened on 01.08.2012 need to be taken note of since undisputedly there was enough and more time for the assessee to submit the accounts during assessment proceedings which fact has been taken note of and concurred by the Ld. CIT(A). Thereafter, the Ld. AR drew our attention to the definition of undisclosed income given under section 271AAB which reads as under: Penalty where search has been initiated. '271AAB. (1) The As ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... me from Other Sources which was accepted by the AO in toto. We note that since the income under question (Rs. 3 cr.) was in fact entered in the other documents maintained in the normal course relating to the AY 2013-14, which document was retrieved during search, hence, the amount of ₹ 3 cr. offered by the assessee does not fall in the ken of undisclosed income defined in Sec. 271AAB of the Act. So, ₹ 3 cr. which was commodity profit recorded in the other document maintained by the assessee which was retrieved during search cannot be termed as undisclosed Income in the definition given u/s. 271AAB of the Act. Since ₹ 3 cr. cannot be termed as Undisclosed Income as per sec. 271AAB of the Act, no penalty can be levied against the assessee. Therefore, we uphold the order of the Ld. CIT(A) on the aforesaid reasoning rendered by us. 8. In the result, the appeal of the revenue is dismissed. 4. We find that the facts in the aforesaid case and the decision rendered thereon are squarely applicable to the facts of the instant cases before us and respectfully following the same, we dismiss the appeals of the revenue. Therefore, when the assessee is not req ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... losure made by the assessee is an amount of ₹ 1,65,38,920/- out of the total disclosure of ₹ 11 crores. The said disclosure was made by the assessee on the basis of the valuation of the stock as per the valuation report of the department valuer apart from a disclosure of ₹ 20 lacs on account of interest income. The assessee filed his return of income and offered the said amount of ₹ 1,65,38,920/- to tax. The AO completed the assessment by accepting surrender income offered to tax and thereafter initiated the penalty proceedings U/s 271AAB and levied penalty @ 10% of the undisclosed income. The assessee challenged the action of the AO before the ld. CIT(A) but could not succeed. 16. Before us, the ld. AR of the assessee has submitted that the disclosure made by the assessee is not based on the incriminating material found during search and seizure proceeding but the measure part of it is based on the valuation of stock of the assessee by the valuer. The ld. AR of the assessee has submitted that the departmental valuer has taken the valuation as per the market rate as against the cost or realization value whichever is less of the stock. Therefore, the discl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e tax on the undisclosed income surrendered under section 132(4) of the Act. She has relied upon the orders of the authorities below. 18. We have considered the rival submissions as well as relevant material on record. At the outset, we note that the surrender of ₹ 1,65,38,920/- was made by the assessee during the course of search and Seizure proceedings and offered to tax for the year under consideration. The details of the surrendered income pertains to the year under consideration are as under:- On account of debtors (advances given ₹ 80,00,000/- Unexplained cash found ₹ 10,00,000/- Accrued interest on debtors ₹ 20,00,000/- Excess stock found during search ₹ 55,38,920/- Total ₹ 1,65,38,920/- We find that out of these four items of surrenders only advances of ₹ 80,00,000/- is based on the incriminating material and all other items are not based on the seized material. The interest on advances/ debtors is only an estimated amount disclo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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