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2019 (6) TMI 351

..... ny years. It is a known fact that regular maintenance of books of accounts and documentary evidences for each and every transactions entered into during the course of agricultural operations for buying the seeds, labour charges, sale of produced, purchase of fertilizers etc. cannot be fully documented for various practical reasons. AO has also not placed any contrary material to support its finding. Only remedy is estimation of income per acre. In certain cases as referred in the finding of the Ld. CIT(A), the tribunal has estimated income per acre at ₹ 15000/- during A.Y. 1998-99 and ₹ 25000/- during A.Y. 2005-06. We are of the view that Ld. CIT(A) has rightly estimated the agricultural income of ₹ 30000/- per acre for A.Y. 2009-10. No interference is therefore called for in the well reasoned finding of the Ld. CIT(A). We uphold the same and dismiss the revenue’s ground. Unexplained investment in gold - HELD THAT:- CIT(A) has rightly given the benefit of 350 gms of gold jewellery (250 gms for daughter and 100 gms for son) thereby giving relief of ₹ 5,80,555/- and confirming the remaining amount as unexplained investment at ₹ 86,535/-. No reason .....

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..... undisclosed investment. Return were filed on 31.03.2010 and notice u/s 148 of the Act issue within 4 years i.e. before 31.03.2014. Proper opportunity was given to assessee(s) to reply to the reasons recorded for reopening. In our considered view the cases of 14 assessee’s were fit case for issue of notice u/s 148 of the Act and for conducting reassessment proceedings u/s 147. Addition on protective basis in the hands of the assessee’s for the unaccounted investment in purchase of 1.9 hectare land jointly with Mr. Mukesh Sharma purchased from Mr. Vinod Vaish - addition based on loose papers - HELD THAT:- Following the holding in Assessment Year 2009-10, we are of the view that both the lower authorities were not justified in making the addition on protective basis in the hands of all the 14 assessee’s. We accordingly allow this common issue in the case of the 14 assessee’s and delete the addition made on protective basis on un accounted investments in purchase of land Disallowance for expenses - difference between the amount deposited in the bank/amount of land taken and the amount admitted as undisclosed income - HELD THAT:- In the instant case though the a .....

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..... ITANo.700/Ind/2016 Chandra Kumar Sharma 22.03.2016 Assessee 6 ITANo.701/Ind/2016 Sanjay Kumar Sahu 22.03.2016 Assessee 7 ITANo.702/Ind/2016 Sukhdev Singh Dhariwal 22.03.2016 Assessee 8 ITANo.703/Ind/2016 Khemraj Singh Chauhan 22.03.2016 Assessee 9 ITANo.704/Ind/2016 Kamlesh Kumar Choudhary 22.03.2016 Assessee 10 ITANO.705/Ind/2016 Santosh Kumar Sharma 22.03.2016 Assessee 11 ITA No.706/Ind/2016 Lalta Prasad Choudhary 22.03.2016 Assessee 12 ITANo.707/Ind/2016 Pradeep Kumar Sharma 22.03.2016 Assessee 13 ITANo.708/Ind/2016 Ramesh Chandra Parashar 22.03.2016 Assessee 14 ITANo.709/Ind/2016 Vijay Kumar Shrivastava 22.03.2016 Assessee 15 ITANo.710/Ind/2016 Dharmendra K. Choudhary 22.03.2016 Assessee 16 ITANo.711/Ind/2016 Ram Kumar Swami 22.03.2016 Assessee 17 ITANo.542/Ind/2017 Virendra Kumar Sharma 22.03.2016 Assessee 2. As most of the issues raised in these appeals are common, these were heard together and therefore are being disposed off by this common order for sake of convenience and brevity. 3. We will first take up the Revenue s appeal and assessee s cross objection in the case of Shri Mukesh Sharma pertaining to A.Y.2009-10 4 Briefly stated facts as culled out from the records are .....

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..... itting additional evidences without following the provisions of rule 46A of the Income Tax Rules and relying on the facts of the case not presented by the assessee before the AO 4. deleing the addition of ₹ 50500/- made by the AO on account of non- genuine agricultural income treated 5 deleing the addition of ₹ 15000000/- made by the AO on account of unexplained investment in share 6.deleting the addition of ₹ 580555/- made by the AO on account of unexplained investment in gold 7.deleting the addition of ₹ 8746000/- made by the AO on account of payment of on money for purchase of land. 8. deleting the addition of ₹ 6500000/- made by the AO on account of non genuine unsecured loans. The appellant reserves his right to add, amend or alter the grounds of appeal on or before the date, the appeal is finally heard for disposal. C.O.No.76/Ind/2014 (Assessee) That on facts and circumstances of the case and in law and in any view of the matter, the Ld. Assessing officer and Ld. CIT (A), Bhopal have erred in assessing and upholding the agricultural income at ₹ 25,000/- and ₹ 30,000/- per acre respectively as against total agricultural income declared .....

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..... the record placed before us. From going through the letter issued by the Office of Commissioner of Income Tax (DR) bearing No.FCIT( DR)I.T.A.T./Ind/2018-19 dated 13.05.2019 we observe that the department has requested for not pressing ground No.1 & 2 raised by the Revenue in IT(SS) No.88/Ind/2013. We, therefore, dismiss ground No.1 & 2 as not pressed. 10. Now we take up ground no.3 through which revenue has challenged that the ld. CIT(A) admitted additional evidences without following provisions of Rule 46A of I.T. Rules. 11. At the outset, Ld. senior counsel for the assessee submitted that the additional evidences challenged in ground no.3 relats to addition for unexplained cash credit of ₹ 70,00,000/- which were placed before the ld. CIT(A) and are going to the root cause of the issue but no remand report was called from Assessing Officer. Therefore, the issues raised in this ground no.8 for which assessee has filed additional evidences may be remanded back to the file of Ld. CIT(A) for afresh adjudication. 12. Ld. DR raised no objection if the additional evidences relating to the addition for unexplained cash credit of ₹ 70 lacs raised in Ground no.8 are set .....

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..... from undisclosed sources. The AO has observed that the appellant was required to substantiate the claim of earning agricultural income shown at the declared amount by furnishing documentary evidences regarding holding of agricultural lands, details of agricultural lands put to cultivation, crops grown, quantities produced, sale consideration, expenses incurred, etc. and also to file agricultural profit and loss account. It was held that as per details filed, the agricultural income comes as high as ₹ 57,500/- per acre in A.Yr.2003-04 and ₹ 1,20,100/- in A.Y..2009-10. The crops cultivated were traditional crops, like wheat, chana, hence, it was possible to earn such huge income. It was also observed that out of nearly 10 acres of agricultural land owned in 2005-06 to 2009-10, around 6 acres is located at village Kalapani, where only one crop of Soybean was grown. According to the AO, hardly any income would have been earned from the other smaller pieces of land. Giving the details of copies of 34 bills for expenses, and summarizing his findings, the AO has observed that the relevant documents relied also include papers pertaining to the appellant's spouse. Most of t .....

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..... , the ld. Counsel for the appellant has contended that the appellant owned agricultural lands with all agricultural facilities. All the necessary details were submitted during the course of assessment proceedings and since the agricultural income was exempt, no regular and proper books of accounts were maintained. According to the ld. A.R, the AO has not doubted agricultural landholdings and cultivation activity. He has accepted a part of agricultural income and estimated the balance as non-agricultural on the ground that bills, etc. were not maintained. It was contended that the two comparable cases referred by the AO cannot be taken as correct, because, the agricultural produce obtained from two lands located at different places cannot be compared, as it largely depends on various factors like fertility, availability of irrigation facilities, nature of crops grown, area of cultivation, extent of agricultural inputs, extent of mechanization, climatic conditions, availability of fertilizers, pesticides and financial capacity of the cultivator to hold the crops to get better prices in the market. The AO has not considered all these factors and estimated the agricultural income on ad .....

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..... eal is, therefore, partly allowed. date of bill being 28.01.2007, it relates to F.Yr.2006-07 relevant to A.Yr.2007-08 and not in the A.yr.2008-09. Therefore, the addition made by the AO is not correct. 11.2) I have gone through the observations of the AO and submissions of the appellant. Admittedly, this bill confirms the purchase of a phone in cash. The disputed paper being cash memo, mentioning of the appellant's name is not necessary. Further, as per of provision of Section 292C of the Act, the A.O. has rightly presumed that the said paper belongs to the appellant. The appellant has not rebutted the presumption. Therefore, the addition made by the A.O. is confirmed. However, since it pertains to A.Yr.2007-08, the AO is directed to exclude the same from computation total income for A.Yr. 2008-09 and include the same in the total income of A.Yr. 2007-08.The appeal is, accordingly, dismiss. 17. From perusal of the above finding of the Ld. CIT(A) which goes uncontroverted by the ld. DR, we observe that the Revenue authorities have nowhere disputed that the assessee holds agricultural land measuring 10 acres since last many years. It is a known fact that regular maintenance of bo .....

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..... ed share capital & share premium of ₹ 1.50 crores was received in the hands of the company namely Prem Prakash Tube P. Ltd. in which Shri Mukesh Sharma is a shareholder. The Tribunal vide in ITANo.188/Ind/2013 in the case of ACIT vs. Prem Prakash Tube P. Ltd. has restored this issue of protective addition of ₹ 1.50 crores relating to A.Y. 2009-10 to Ld. CIT(A) for afresh adjudication vide order dated 09.07.2015. He prayed that this ground raised by the Revenue should also be set aside to the file of the Ld. CIT(A) for deciding afresh. 23. On the other hand, Ld. DR could not controvert the submissions made by the Ld. counsel for the assessee and raised no objection if the issue for unexplained investment of ₹ 1.50 crores is set aside to the file of Ld. CIT(A) for deciding afresh. 24. We have heard the rival contentions and perused the record placed before us. The revenue s grievance in ground No.5 is against the finding of Ld. CIT(A) deleting addition of ₹ 1.50 crores made by the Ld. AO on account of unexplained investment in shares. We observe that the assessee Mr. Mukesh Sharma along with his relatives are shareholders in the company named Prem Prakash .....

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..... during the search along with certain evidences showing that gold jewellery weighing 1602.330 gms were sold during the A.Ys. 2002-03 and 2007-08. The Ld. Assessing Officer asked the assessee to explain the total jewellery of 2802.16 gms. Necessary reply was submitted and after considering the same Ld. Assessing Officer treated 402.160 gms jewellery asunexplained and made a addition of ₹ 6,67,090/-. The assessee challenged this addition before the Ld. CIT(A) and partly succeeded. 29. Now the revenue is in appeal before the Tribunal. 30. Ld. DR vehemently argued supporting the order of the Ld. Assessing Officer and Ld. senior Counsel for the assessee supported the finding of the Ld. CIT(A). 31. We have heard the rival contentions and perused the record placed before us. The revenue s grievance in ground no.6 is against deletion of addition for unexplained investment in gold jewellery of ₹ 5,80,555/-. We observe that the assessee s family consists of the assessee his mother Smt. Vimla Rani Sharma, wife Neena Sharma, son Indra Prakash and daughter Miss Ronak Sharma. As per the CBDT Instruction No.1916 dated 11.05.1994 jewellery should not be seized to the extent of 500 gms p .....

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..... en as per the CBDT's instructions regarding seizure of jewellery, jewellery in respect of unmarried daughter at 250 gms and unmarried son at 100 gm was to be considered reasonable. Therefore, even as per the standards of the Board, the credit of 350 gms should have been allowed and after giving credit of 350gms of jewellery of the children, only meager quantity of 52.160 gms remains to be explained and looking to the family status, this much of jewelery deserves to be accepted, specifically, when the A.O. has adopted ownership of inherited jewelery on estimate basis. 13.2 I have gone through the observations of the AO and submissions of the appellant. It appears, looking to the family status, the AO has given credit for 1500 gms of jewellery as received by Smt. Vimla Rani Sharma and Smt. Neena Sharma and the appellant on their marriages and that was inherited by the family and it is reasonable. However, he did not consider the availability of jewellery in the case of the children and considering the family status, it cannot be ruled out. Therefore, after considering the facts and circumstances of the case, the appellant deserves further credit of350 gms of jewellery against hol .....

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..... (0.4 00 hec.) 0.080 hec. 6 -do- 2647000 235000 3000 21355 556/(1.180 hec.) 0.100 hec. 7 Khemraj singh Chouhan 12680 2647000 235000 3000 21355 556/(1.180 Hec.) 0.100 hec. 8 -do- 1563000 138720 680 12680 556/(1.160 hec) 0.060 Hec 9 -do- 1084000 96205 1000 8850 559/(0.1 60 hec. 0.040 hec. 10 Santosh Kumar Sharma 2647000 235000 2500 21355 558/(1.1 60 hec. 0.100 hec. 11 Sukhdev Singh 2647000 235000 3000 21355 557/(0.400 hec. 0.100 hec. 12 Suresh Upadhya 2647000 235000 3000 21355 556/(1.180 Hec.) 0.100 hec. 13 Dharmendra Choudhary 2647000 235000 3000 21355 556/(1.180 Hec.) 0.100 hec. 14 Ram Kumar 2647000 235000 3000 21355 557/(0.400 hec. 0.100 hec. 15 Virendra Kumar Sharma 2647000 235000 3000 21355 557/(0.400 hec. 0.100 hec. 16 Sanjay Sahu 2647000 235000 3000 21355 559/(0.160 hec. 0.100 hec. 17 Pradeep Kumar Sharma 2647000 235000 3000 21355 559/(0.160 hec. 0.100 hec. 18 Chandra Kumar Sharma 2647000 235000 3000 21355 556/(1.180 Hec.) 0.100 hec. 19 Vijay Kumar Shrivastava 2647000 235000 3000 21355 556/(1.180 Hec.) 0.100 hec. Total 45000000 3994880 45560 363385 20 Mukesh Sharma 2647000 235000 900 21355 556/(1.180 Hec.) 0.100 hec. 21 Mukesh Sharma 2647000 235000 900 21355 556/(1.180 Hec.) 0. .....

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..... amed Kaushal Bhaiya for arranging entries in the name of various parties i.e. the copurchasers. This unaccounted payment in the entire deal was worked out by Ld. A.O at ₹ 8,74,60,600/- (₹ 13,65,60,600/-+ ₹ 9,00,000/- (-) ₹ 5,00,00,000/-). Since the assessee s share in the stated consideration is 1/10th only, the unaccounted payment alleged to have been made by the assessee was added at ₹ 87,46,000/- as undisclosed income. On the basis of the finding by the Ld. A.O in the case of Mr. Mukesh Sharma addition for unaccounted receipt of ₹ 8,74,60,600/- was also made in the hands of the seller namely Mr. Vinod Vaish. Subsequently Ld. CIT(A) vide his order dated 28.32013 passed u/s 263 of the Act held that the order of the Ld. A.O passed in the case of Mr. Mukesh Sharma dated 31.12.2010 was erroneous and prejudicial to the interest of revenue and directed the Ld. A.O to examine the issue of undisclosed income invested in the purchase of said agriculture land and to make total addition of ₹ 8,74,60,600/- in the hands of Mr. Mukesh Sharma as the other co-partners were merely accommodation entry providers as they were funded by Mr. Mukesh Sharma to m .....

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..... 51 to 55 of the assessment order depicted in the seized document are rough notings. They do not contain any date, name or narration against the calculations. The assessee along with other buyers has made a planning regarding future prospects of the land after completion of the transaction and the alleged seized documents are dumb documents and they cannot be relied as the assessment order making additions by it is mischievous. The calculation made by the Ld. A.O are based only on suspicion and assumption and are not supported with any coherent material as assumed by the Ld. A.O, over and above the amount of investment shown by the appellant. Ld. Counsel for the assessee further asserted that the alleged papers relates to future planning with respect to the land and loose paper No.74 & 75 was shown for the prospective buyers in furtherance of their business. No such transaction ever happened. The situation of land i.e. Ratanpur, Misrod is slightly away from Bhopal and at the relevant point of time at no stage the rate was ₹ 660/- per sq.ft. It was also submitted that the land under consideration was agriculture land and un diverted land which was not commanding such price .....

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..... part 51-62 7 (2008) 307 ITR 137(Guj) CIT vs. Maulik Kumar K Shah The addition made by the AO toward on money on the basis of seized paper along without any corroborative evidence accnot be sustained Para 6 63-66 8 (2007) 291 ITR 36 (Delhi) CIT v. Kulwant Rai No addition can be made based on surmises and gues work Para 12 & 13 67-70 9 (2007) 289 ITR 509 ACIT v. Kences Foundation P. Ltd. Seized docuemnts are not a conclusive proof to arrive at undisclosed income Para 16 & 17 71-75 10 (2009) 308 ITR 230 (Del) CIT v. D.K. Gupta If there is no corroborative or direct evidence to presume that the notings/jottings has materialized into transactions giving rise to income not disclosed in the books by the assessee the department s presumption cannot be tenable in law Para 3 76-78 11 (2008) 301 ITR 134 (MP) Prakash Chand Nahta v. CIT That seized document must be speaking document no addition permissible on the basis of dumb papers 15 & 16 79-83 12 (2007) 295 ITR 352(Jabalpur I.T.A.T.) ACIT v. Satyapal Wassam That seized document must be speaking document no addition permissible on the basis of dumb papers Para 29 84-110 13 (2008) 25 SOT 387 (Kol) Nirmal Fashions (P) L. v. DCIT Si .....

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..... 7 ITR 137 (Guj.) (viii) Commissioner of Income Tax Vs. Kulwant Rai (2007) 291 ITR 36 (Delhi) (ix) Assistant Commissioner of Income Tax Vs. Kences Foundation Pvt. Ltd (2007) 289 ITR 509 High Court of Madras (x) Commissioner of Income tax Vs D.K. Gupta (2009) 308 ITR 230 (Del) High Court of Delhi (xi) Prakash Chand Nahta Vs Commissioner of Income Tax (2008) 301 ITR 134 (MP) High Court of Madhya Pradesh (xii) ACIT V/s Sri Satyapal Wassan (2007) 295 ITR 352 ITAT, Jabalpur Bench (xiii) Nirmal Fashions (P) ltd Vs. DCIT (2008) 25 SOT 387 (Kol) ITAT, Kolkata Bench (xiv) Commissioner of Income Tax Vs Tam Narain Goel (1997) 224 ITR 180, Punjab & Haryana High Court. (xv) Commissioner of Income Tax Vs. Faqir Chand Chaman Lal (2003) 262 ITR 295 (P&H) (xvi) Commissioner of Income Tax Vs. Emerald Commercial Ltd & Ors (2001) 250 ITR 539, High Court of Calcutta (xvii) Commissioner of Income Tax Vs. Atam Valves (P) Ltd 332 ITR 468 (P&H) (xviii) Starptex (India) (P) Ltd Vs. Deputy Commissioner of Income Tax (2003) 84 ITD 320 (Mum) (xix) Bansal Strips Pvt. Ltd Vs. Asstt. Commissioner of Income Tax (2006) 99 ITD 177 (Del.) (xx) Common Cause (A registered Society) Vs Union of India (2017 .....

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..... 0 hec. 13 Dharmendra Choudhary 2647000 235000 3000 21355 556/(1.180 Hec.) 0.100 hec. 14 Ram Kumar 2647000 235000 3000 21355 557/(0.400 hec. 0.100 hec. 15 Virendra Kumar Sharma 2647000 235000 3000 21355 557/(0.400 hec. 0.100 hec. 16 Sanjay Sahu 2647000 235000 3000 21355 559/(0.160 hec. 0.100 hec. 17 Pradeep Kumar Sharma 2647000 235000 3000 21355 559/(0.160 hec. 0.100 hec. 18 Chandra Kumar Sharma 2647000 235000 3000 21355 556/(1.180 Hec.) 0.100 hec. 19 Vijay Kumar Shrivastava 2647000 235000 3000 21355 556/(1.180 Hec.) 0.100 hec. Total 45000000 3994880 45560 363385 20 Mukesh Sharma 2647000 235000 900 21355 556/(1.180 Hec.) 0.100 hec. 21 Mukesh Sharma 2647000 235000 900 21355 556/(1.180 Hec.) 0.100 hec. Grand Total 50000000 4464880 47360 406095 54918335 42. During the course of search various documents were seized which also included LPS 1/1 page No.74 & 75 (front and back). These seized loose papers contained certain entries and calculations. These are not signed by any of the parties. For better understanding we reproduce below the scan copy of the typed version of seized document on the basis of which the Ld. A.O came to a conclusion that ON MONEY of ₹ 8,74,60,600/- was pa .....

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..... conclusion that the fair market value of the land was much more than stated consideration. 46. We find that Ld. CIT(A) after appreciating the fact deleted the addition of ₹ 87,46,000/- observing as follows:- This ground of appeal is directed against addition of ₹ 87,46,000/- made on account of payment on money for purchase of land. The AO has observed that certain documents along with a memorandum of agreement for purchase of land of 1.9 hectares (4.70 acres) at Ratanpur, Miss Road near Bhopal was seized in the course of search at the appellant's residential premises. Further, it was held that in the course of subsequent enquiry, it was found that the. land was purchased by the appellant along with 14 other persons on 23.06.2008 for total sale consideration of ₹ 5 crores and ₹ 49,18,355/- (roughly ₹ 50,00,000/-) was incurred towards registry charges, stamp duty, etc. This land was purchased from Shri Vinod Vaish and his family members through 21 registries. In the course of search, the appellant has admitted that the entire amount of ₹ 5 crores pertains to him and he was ready to surrender the amount as his undisclosed income. The AO further .....

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..... tings found in the papers reproduced at page no.51-55 of the assessment order are rough notings. There are no dates, names or narration mentioned against these calculations. The appellant along with the other buyers has made a planning regarding further prospects of the land after completion of the transaction and these papers are dumb documents and they cannot be relied up on for the purpose of assessments by any stretch of imagination. It was further contended that the calculations made by the AO are. merely based on suspicion and presumption and without any supporting cogent material to establish the fact of investment as assumed by the AO over and above the amount of investments shown by the appellant. In this connection, the appellant further contended that these papers relate to future planning with respect to the land and loose paper no.74 and 75 were made for showing them to a prospective buyer in furtherance of their business. The figures were written only to make believe the prospective customers about the transaction, whereas no such transactions had ever happened. The appellant further contended that Ratanpur, Misrode is slightly away from Bhopal and the relevant land h .....

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..... ervation is found to be correct, the subsequent observations are only inferences and are not based on facts. There is nothing unusual in tallying the land area. The amount of registration expenses were incurred at ₹ 49, 18,335/- and not ₹ 50,OO,OOOI-, i.e., the figure mentioned against the narration. The total of the amount deposited through DD/ cheques in the bank accounts of the 14 persons comes to ₹ 2,70,05,400/- and it is not matching with the figure of '225'. Similarly, the total amount of cash deposited in the bank: accounts of the 14 persons comes to ₹ 2, 76, 77 ,877/-. Thus, it is also not tallying with the figure of' 323'. Since, the above figures are not tallying with the above figures, it cannot be concluded that page no.74 backside and 75 are corroborative to each other. Except these jottings, there are no other corroborative evidences to justify the addition. On the contrary, the appellant's contention that the entire exercise is based on inferences carries more force.No incriminating documents establishing transfer of funds between the buyers and the sellers were found. The land was purchased at a price higher than the Guide .....

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..... . There must be something more than more where suspicion to support the assessment u/s 23(3) . The rule of law on this subject has been fully and rightly stated by Hon ble High Court in the case of Sree Shanmugar Mills Ltd v/s Commissioner of Income Tax, Punjab 1944 12 ITR 393. Similar view was also taken by Delhi Tribunal in the case of Bansal Strips V/s ACIT (supra) observing that the A.O cannot first make certain conjectures and surmises and thereafter deemed provisions based on such conjectures and surmises . In the absence of material as to the nature of ownership of the transaction, undisclosed income cannot be assessed in the hands of the assessee summarily by arithmetically total various figures dotting down on the loose document. Any other seized for the purpose of exercising to deemed provisions dumb documents order documents with no certainty for no evidential value . 49. Hon ble High Court of Delhi in the case of CIT V/s Anil Bhalla (2010) 322 ITR 191 (Del) also held that when no independent material or evidence has been brought on record by the A.O to establish that the notices of jottings of loose sheets or on the paper written on accounted transactions cannot be made .....

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..... xplained away as a result of intimidation?" 2. The facts leading to the above questions of law are as under: i) The assessment was made under Section 158BC of the Income Tax Act. The relevant Block Period was 01.04.1988 to 08.12.1998. The assessee had purchased land at Brindavan Road, Fairlands, Salem on 26 .10.1 998. The land was registered for ₹ 4.10 lakhs. During the course of search in the office premises of Polimer Net Work, certain notings were found in the seized material RK/S/B&D/25. In the statement recorded on 08.12.98, the assessee stated that he did not remember for what purpose he had made notings, which was confirmed by the assessee in a subsequent statement recorded on 11.12.1998. The land was purchased from one Shri Rajarathinam. His statement was also recorded on the date of search i.e. 08.12.1998 and also on 11.12.1998. In the sworn statement dated 08.12.1998, in question No.3, Shri Rajarathinam admitted that he had received ₹ 4.10 lakhs as sale consideration but in question No.4, he admitted that he had received ₹ 34.35 lakhs. Again in the statement recorded on 11.12.1998, Shri Rajarathinam, the seller admitted that a total consideratio .....

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..... rest amount was held by him in cash. The Revenue authorities could well have seized the cash invoking Section 132 of the Act, but for obvious reasons this was not done. Had the cash been seized from the seller, the matter would have been concluded in favour of the Revenue. In a subsequent submission, the seller claimed on 20.11.2000 that he had paid ₹ 15 lakhs out of the sale proceeds to settle old family debts, ₹ 4 .80 lakhs for construction of house in Pullkasi Village and the balance was advanced to parties for keeping ₹ 2 lakhs and ₹ 3 lakhs in the house for family expenses and educational expenses of his daughter, respectively. It was also noted that the revised return was filed by the seller wherein he had shown approximately ₹ 2.5 lakhs being available with him in cash. Even after giving the retraction and admitting that he had sold the property for a sale consideration of ₹ 4.10 lakhs, the seller filed his I.T. Return on 28.01.2000 wherein he did not admit the cash on money consideration for the sale transaction. Subsequently he revised the I.T. Return wherein he admitted the sale consideration and showing ₹ 4.80 lakhs out of the a .....

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..... there probative value. Mr. Altaf Ahmed took great pains to decode and analyses the entries in the above book and, correlating them with the entries in the other three books and in some of the loose sheets found in the files, submitted that the intrinsic evidence furnished by their internal corroboration and inter-dependence unmistakably demonstrated their authenticity and trustworthiness. According to Mr. Altaf Ahmed the entries reflect such periodicity and regularity as was compatible with the modus operandi of the business of Jain brothers of corrupting public servant including Members of Parliament and Ministers in order to influence their decisions and seek their favours for promotion of their (Jain brothers) economic interests. Besides, he submitted, the external independent corroboration of those entries as required under Section 34 was also available to the prosecution from the statements made by Shri Jacob Mathai, Danial P. Rambal and P. Ghoshal and Ejaj Ilmi during investigation, in that, they have admitted receipts of the payments as shown against them in MR.71/91. While on this point, he made a particular reference to those entries in MR 71/91 Which, according to him m .....

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..... en drives etc. have revealed that the transactions noted on documents were not genuine and have no evidentiary value and that details in these loose papers, computer print outs, hard disk and pen drive etc. do not comply with the requirement of the Indian Evidence Act and are not admissible evidence. It further observed that the department has no evidence to prove that entries in these loose papers and electronic data were kept regularly during the course of business of the concerned business house and the fact that these entries were fabricated, non-genuine was proved. It held as well that the PCIT/OR have not been able to show and substantiate the nature and source of receipts as well as nature and reason of payments and have failed to prove evidentiary value of loose papers and electronic documents within the legal parameters. The Commission has also observed that Department has not been able to make out a clear case of taxing such income in the hands of the applicant firm on the basis of these documents. 24. Since it is not disputed that for entries relied on in these loose papers and electronic data were not regularly kept during course of business, such entries were discussed .....

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..... ontrary material in the form of valuation report of the impugned land to support the market price of land adopted for making the addition ON MONEY payment. Therefore the alleged seized loose papers are Dumb documents and addition cannot be made on such dumb documents. Rather the jottings on the seized papers were stated to be a part of future planning and references of the transaction in the loose papers are not supported by any corroborative evidence and the evidence in the form of registered sale deeds only indicates that the transaction of purchase/sale of land between the various concerned parties was actually entered at consideration of ₹ 5 crores only and no evidence of any ON MONEY of ₹ 8,74,60,600/- has been paid. We therefore find no reason to interfere in the finding of Ld. CIT(A) deleting the addition of ₹ 87,46,600/- and dismiss the revenue s Ground No.7. 59. Though Ground No.8 revenue has challenged the deletion of addition of ₹ 65,00,000/- which was made by the Ld. Assessing Officer on account of non-genuine unsecured loans. 60. At the outset, Ld. Senior Counsel for the assessee giving reference to his submissions for ground no.3 submitted that .....

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..... ced before the assessing officer should be sent to the assessing officer calling for remand report and thereafter decide the issue afresh as per the provisions of law after giving reasonable opportunity of being heard to the assessee. We, therefore, allow the revenue s ground no.8 for statistical purposes. 64. In the result appeal of the revenue for Assessment Year 2009- 10 is partly allowed for statistical purposes as per the terms indicated herein above. 65. Now we take the Cross Objection raised by the assessee in the case of Mr. Mukesh Sharma for Assessment Year 2009-10. 66. Ground No.1 relates to addition for agriculture income. We have already dealt with this issue in the revenue s appeal and have confirmed the finding of Ld. CIT(A) thereby dismissing the revenue s Ground No.4 relating to addition of ₹ 50,500/- made on account of non genuine agriculture income. Since we have confirmed the finding of Ld. CIT(A) this Ground No.1 of the assessee s Cross Objection deserves to be dismissed. 67. Ground No.2 of the Cross Objection relates to unexplained investment of ₹ 1.50 crores. We find that the same issue has been raised by the revenue in Ground No.5 of its appeal fo .....

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..... osal. 74. The facts in brief are that Mr. Vinod Vaish filed return of income on 30.7.2009 declaring total income of ₹ 3,32,98,372/-. During the course of search conducted on 21.07.2008 at the residential premises of Mr. Mukesh Sharma certain documents were found which indicated that the assessee i.e. Mr. Vinod Vaish has sold agriculture land measuring 1.9 hectare to Mr. Mukesh Sharma and others. The stated consideration received by Mr. Vinod Vaish was ₹ 5 crores but the Ld. A.O on the basis of the finding in the case of Mr. Mukesh Sharma came to a conclusion that on money of ₹ 8,74,60,600/-has been paid by all the purchasers to Mr. Vinod Vaish. Ld. A.O made the addition of ₹ 8,74,60,600/- in the hands of Mr. Vinod Vaish and assessed the income at ₹ 12,07,58,972/- vide his order dated 29.12.2011 u/s 143(3) of the Act. Against this impugned addition of ₹ 8,74,60,600/- assessee preferred appeal before Ld. CIT(A) and succeeded as the Ld. CIT(A) deleted the addition. 75. Now the revenue is in appeal before the Tribunal. 76. We have heard rival contentions and perused the records placed before us. The issue raised by the revenue in Ground No.3 deleting .....

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..... e appellant has contended that the A.O. has erred in making the addition without providing copies of the evidences used against him and without allowing cross-examination of the person giving the statement. Copies of written submissions, copy of appellant's statement recorded by the A.O., copy of appellant's affidavit denying receipt of any on money and other details filed before the A.O. were filed. It was contended on the basis of the replies and other details filed that the notings if the loose papers seized from Shri Mukesh Sharma are not corroborated by any other evidences to establish that the appellant has received any on money. It was contended that the land was sold at the ruling market price which was higher than guideline price and capital gain on the same was offered to tax in the return filed. There is no basis for making the addition except the A.O's findings contained in the assessment order. The rough jottings relate to the calculation of estimated return on sale of such land, provided the land is diverted for residential and commercial purposes after obtaining approvals from various authorities. The land can be sold in terms of square feet only, when us .....

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..... ons of the appellant. The AD has made the addition mainly on the basis of inferences drawn about the jottings contained in loose papers - LPS-III page no. 74 back side and page no. 75. The A D has summarized the basis of his conclusions at page no. 58 of the assessment order by stating that the cheque payment of ₹ 50,00,0001- on the backside of page no. 74 tallies with the actual amount of ₹ 50 lakhs paid on 23.5.200B. The area of land and registry expenses tally with the actual land area and the expenses incurred on registration. The figure of '225' mentioned at page no. 75 denotes the amount of ₹ 225 lakhs deposited by DDI cheque in the bank documents of 14 persons of Dabra. The figure of '323' mentioned in these documents tallies with the amount of cash deposited in the bank accounts of the 14 persons plus registration charges and page no. 74 back side and page no. 75 corroborated each other. Though the first observation is found to be correct, the subsequent observations are only inferences and are not based on facts. There is nothing unusual in tallying the land area. The amount of registration expenses were incurred at ₹ 49, 18,335/- an .....

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..... Year 2009-10 stands dismissed. 81. Now we take up the bunch of 14 appeals of the following assessees in which protective addition for unaccounted investments in purchase of land as well as disallowance of expenses have been made. Details of the assessee s with appeal Nos along with total income disclosed, additions made and income assessee is detailed below; Name of Assessee & ITANo. Total income Addition on disallowance of expenses Addition on protective basis Assessed income 1 Suresh Kumar Upadhyay ITANo.699/Ind/2016 26,33,230 19,520 46,01,538 72,54,288 2 Chandra Kumar Sharma ITANo.700/Ind/2016 42,96,651 3,68,349 29,38,117 76,03,117 3 Sanjay Kumar Sahu ITANo.701/Ind/2016 4,62,060 NIL 67,72,708 72,34,768 4 Sukhdev Singh Dhariwal ITANo.702/Ind/2016 22,21,765 17,78,235 50,13,003 90,13,003 5 Khemraj Singh Chauhan ITANo.703/Ind/2016 50,21,671 NIL 94,47,865 1,44,69,536 6 Kamlesh Kumar Choudhary ITANo.704/Ind/2016 25,91,668 NIL 1,18,77,868 1,44,69,536 7 Santosh Kumar Sharma ITANO.705/Ind/2016 26,33,954 NIL 46,00,814 72,34,768 8 Lalta Prasad Choudhary ITA No.706/Ind/2016 22,94,656 3,55,913 49,40,112 75,90,681 9 Pradeep Kumar Sharma ITANo.707/Ind/2016 57,33,205 1,21,795 15,01,563 73, .....

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..... The CIT(A) on one hand is doubting the financial capacity of the appellant to make the investment and on the other hond is confirming the protective addition as substantive addition. The said finding is perverse and contrary to the entire matrix built up by the CIT(A) 9.That the Ld. CIT(AJ has exceeded her jurisdiction in giving directions to the AO to reopen the case for AY 2010-11 and giving directions for examining the opening capitol which are I10t within the scope of the assessment year under consideration and which were not even the Subject matter of assessment. ITA No.700/Ind/2016 1.That the Ld. CIT{A} erred both in law and on facts in upholding the validity of reassessment proceedings u/s 148. The Id. CIT(A} has failed to appreciate that the reassessment proceedings' initiated by the AO were illegal, void and without jurisdiction. 2.That the Ld. CIT(A) erred in law and on facts in failing to appreciate that reassessment proceedings were initiated on the basis of incorrect facts since the income alleged to have escaped assessment was already offered to tax in the return of income. 3. That the Ld. CIT(A) erred both in law and on facts in deciding the entire appeal on a pr .....

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..... CIT(A) erred both in law and on facts in deciding the entire appeal on a preconceived hypothesis and predetermined notion without considering the written submissions and facts on record. Most of the findings in the appellate order are without any basis and appear to be on presumptions and surmises. 4. That the Ld. CIT{A} has erred in law and on facts in not appreciating that since no addition has been made in respect of the income on the basis of which assessment was reopened therefore the addition made for item in respect of which reason of reopening was not recorded is unsustainable. 5. That the Ld. CIT{A) has erred in law and on facts in confirming the addition of ₹ 67,72,708/- made on the basis of a dumb document unrelated to the assessee and not found from the assessee s possession. 6. That the manner in which the Ld. CIT(A) has upheld the addition in para 14 over the alleged excess investment in land without even discussing the alleged document, submissions of the assessee and simply relying on the Assessment order is unwarranted and perverse and is devoid of any merit. 7. That the Ld. CIT{A) erred in law and on facts in confirming the protective addition as substantiv .....

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..... any merit. 8. That the Ld. CIT{A) erred in law and on facts in confirming the protective addition as substantive addition in the hands of the appellant. The CIT(A) on one hand is doubting the financial capacity of the appellant to make the investment and on the other hand is confirming the protective addition os substantive addition. The said finding is perverse and contrary to the entire matrix built up by the CIT(A) 9. That the Ld. CIT(AJ has exceeded her jurisdiction in giving directions to the AO to reopen the case for AY 2010-11 and giving directions for examining the opening capitol which are I10t within the scope of the assessment year under consideration and which were not even the Subject matter of assessment. ITA No.703/Ind/2016 1. That the Ld. CIT{A} erred both in law and on facts in upholding the validity of reassessment proceedings u/s 148. The Id. CIT(A} has failed to appreciate that the reassessment proceedings' initiated by the AO were illegal, void and without jurisdiction. 2. That the Ld. CIT(A) erred in law and on facts in failing to appreciate that reassessment proceedings were initiated on the basis of incorrect facts since the income alleged to have escap .....

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..... ed to tax in the return of income. 3. That the Ld. CIT(A) erred both in law and on facts in deciding the entire appeal on a preconceived hypothesis and predetermined notion without considering the written submissions and facts on record. Most of the findings in the appellate order are without any basis and appear to be on presumptions and surmises. 4. That the Ld. CIT{A} has erred in law and on facts in not appreciating that since no addition has been made in respect of the income on the basis of which assessment was reopened therefore the addition made for item in respect of which reason of reopening was not recorded is unsustainable. 5. That the Ld. CIT{A) has erred in law and on facts in confirming the addition of ₹ 1,18,77,858/-. made on the basis of a dumb document unrelated to the assessee and not found from the assessee s possession. 6. That the manner in which the Ld. CIT(A) has upheld the addition in para 14 over the alleged excess investment in land without even discussing the alleged document, submissions of the assessee and simply relying on the Assessment order is unwarranted and perverse and is devoid of any merit. 7. That the Ld. CIT{A) erred in law and on fact .....

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..... addition as substantive addition in the hands of the appellant. The CIT(A) on one hand is doubting the financial capacity of the appellant to make the investment and on the other hond is confirming the protective addition of substantive addition. The said finding is perverse and contrary to the entire matrix built up by the CIT(A) 8. That the Ld. CIT(AJ has exceeded her jurisdiction in giving directions to the AO to reopen the case for AY 2010-11 and giving directions for examining the opening capitol which are I10t within the scope of the assessment year under consideration and which were not even the Subject matter of assessment. ITA No.706/Ind/2016 1.That the Ld. CIT{A} erred both in law and on facts in upholding the validity of reassessment proceedings u/s 148. The Id. CIT(A} has failed to appreciate that the reassessment proceedings' initiated by the AO were illegal, void and without jurisdiction. 2. That the Ld. CIT(A) erred in law and on facts in failing to appreciate that reassessment proceedings were initiated on the basis of incorrect facts since the income alleged to have escaped assessment was already offered to tax in the return of income. 3. That the Ld. CIT(A) er .....

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..... scaped assessment was already offered to tax in the return of income. 3. That the Ld. CIT(A) erred both in law and on facts in deciding the entire appeal on a preconceived hypothesis and predetermined notion without considering the written submissions and facts on record. Most of the findings in the appellate order are without any basis and appear to be on presumptions and surmises. 4. That the Ld. CIT{A} has erred in law and on facts in not appreciating that since no addition has been made in respect of the income on the basis of which assessment was reopened therefore the addition made for item in respect of which reason of reopening was not recorded is unsustainable. 5. That the Ld. CIT{A) and the AO were not justified in law and on facts in sustaining the addition of ₹ 1,21,795/-. 6. That the Ld. CIT(A) has erred in law and on facts in confirming the addition of ₹ 15,01,563/- made on the basis of a dumb document unrelated to the assessee and not found from the assessee's possession. 7. That the manner in which the Ld. CIT(A) has upheld the addition in para 14 over the alleged excess investment in land without even discussing the alleged document, submissions of .....

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..... e alleged excess investment in land without even discussing the alleged document, submissions of the assessee and simply relying on the Assessment order is unwarranted and perverse and is devoid of any merit. 8. That the Ld. CIT{A) erred in law and on facts in confirming the protective addition as substantive addition in the hands of the appellant. The CIT(A) on one hand is doubting the financial capacity of the appellant to make the investment and on the other hond is confirming the protective addition os substantive addition. The said finding is perverse and contrary to the entire matrix built up by the CIT(A) 9. That the Ld. CIT(AJ has exceeded her jurisdiction in giving directions to the AO to reopen the case for AY 2010-11 and giving directions for examining the opening capitol which are I10t within the scope of the assessment year under consideration and which were not even the Subject matter of assessment. ITA No.709/Ind/2016 1.That the Ld. CIT{A} erred both in law and on facts in upholding the validity of reassessment proceedings u/s 148. The Id. CIT(A} has failed to appreciate that the reassessment proceedings' initiated by the AO were illegal, void and without jurisdi .....

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..... at the reassessment proceedings' initiated by the AO were illegal, void and without jurisdiction. 2. That the Ld. CIT(A) erred in law and on facts in failing to appreciate that reassessment proceedings were initiated on the basis of incorrect facts since the income alleged to have escaped assessment was already offered to tax in the return of income. 3. That the Ld. CIT(A) erred both in law and on facts in deciding the entire appeal on a preconceived hypothesis and predetermined notion without considering the written submissions and facts on record. Most of the findings in the appellate order are without any basis and appear to be on presumptions and surmises. 4. That the Ld. CIT{A} has erred in law and on facts in not appreciating that since no addition has been made in respect of the income on the basis of which assessment was reopened therefore the addition made for item in respect of which reason of reopening was not recorded is unsustainable. 5. That the Ld. CIT{A) and the AO were not justified in law and on facts in sustaining the addition of ₹ 4,55,561/-. 6. That the Ld. CIT(A) has erred in law and on facts in confirming the addition of ₹ 50,39,760/- made on .....

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..... es. 6. That the Ld. CIT(A) has erred in law and on facts in confirming the addition of ₹ 49,45,794/- made on the basis of a dumb document unrelated to the assessee and not found from the assessee's possession. 7. That the manner in which the Ld. CIT(A) has upheld the addition in para 14 over the alleged excess investment in land without even discussing the alleged document, submissions of the assessee and simply relying on the Assessment order is unwarranted and perverse and is devoid of any merit. 8. That the Ld. CIT{A) erred in law and on facts in confirming the protective addition as substantive addition in the hands of the appellant. The CIT(A) on one hand is doubting the financial capacity of the appellant to make the investment and on the other hond is confirming the protective addition os substantive addition. The said finding is perverse and contrary to the entire matrix built up by the CIT(A) 9. That the Ld. CIT(AJ has exceeded her jurisdiction in giving directions to the AO to reopen the case for AY 2010-11 and giving directions for examining the opening capitol which are I10t within the scope of the assessment year under consideration and which were not even th .....

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..... tter of assessment. 9. That the Ld. CIT(A) has erred in law and on facts in confirming the addition of ₹ 2,92,010/- shown as agricultural income savings of the assessee without appreciating the facts and circumstances of the case. 83. From perusal of the above grounds following four common issues needs to be adjudicated:- (i) Challenging the validity of reassessment u/s 147 of the Act (ii) Protective addition made on the basis of dumb document unrelated to the assessee. (iii) Addition for disallowance of expenses (iv) Direction by Ld. CIT(A) for reopening of case for Assessment Year 2010-11. 84. Facts in brief commonly for all the assessee s are that pursuant to search u/s 132 of the Act at the residence of Shri Mukesh Sharma on 21.07.2008 various documents were seized. In the document one memorandum of agreement was found for purchase of 1.9 hectare of agriculture land at Ratanpur, Misroad, near Bhopal showing that Mr. Mukesh Sharma along with other co-purchasers i.e. 14 assessee s referred above in the chart jointly purchased the land from Mr. Vanod Vaish for consideration of ₹ 5 crores. Ld. A.O on the basis of these documents concluded that ON MONEY of ₹ 8,74,6 .....

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..... ctare land jointly with Mr. Mukesh Sharma purchased from Mr. Vinod Vaish. We find that this issue stands adjudicated by us in the case of Mr. Mukesh Sharma and Mr. Vinod Vaish vide ITA (SS)No.88/Ind/2014 for Assessment Year 2009-10 and ITA No.189/Ind/2013 for assessment Year 2009-10 wherein we have held that no addition was called for the ON MONEY payment of ₹ 8,74,60,600/- as it was based on the seized loose papers which are merely dumb documents having no nexus with any corroborating evidence to prove the transaction. In the light of our decision in the case of Mr. Mukesh Sharma and Mr. Vinod Vaish, we are of the view that both the lower authorities were not justified in making the addition on protective basis in the hands of all the 14 assessee s. We accordingly allow this common issue in the case of the 14 assessee s and delete the addition made on protective basis on un accounted investments in purchase of land totalling to ₹ 8,07,43,547/-. 88. Now we take up third common issue relating to disallowance of expenses totalling to ₹ 45,24,621/- made in the case of 10 assessee s as referred in the chart above. Brief facts relating to this common issue are that the .....

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..... the instant case though the actual source of earning the undisclosed income has not been stated but claiming certain expenses against the earning of said undisclosed income cannot be brushed aside. However, Ld. CIT(A) failed to adjudicate this issue and in the interest of justice we are of the view that this common issue needs to be set aside to the file of Ld. CIT(A) for adjudication after giving reasonable opportunity of being heard to the assessee s. In the result this common issue of disallowance totalling to ₹ 45,24,621/- relating to 10 assessee s is allowed for statistical purposes. 91. Now we come to the fourth common issue through which the respective assessee s are aggrieved with the findings of Ld. CIT(A) to have exceeded her jurisdiction in giving direction to the Ld. A.O to reopen the cases for assessment year 2010-11 giving direction for examining the correctness of opening capital, which is not within the scope of Ld. CIT(A). 92. We observe that Ld. CIT(A) in her common appellate order for the 14 assessee s have directed the Ld. A.O to consider the reopening of the cases for Assessment Year 2010-11. We find that the power of the Commissioner (Appeals) are provi .....

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