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TMI Blog2018 (9) TMI 1867X X X X Extracts X X X X X X X X Extracts X X X X ..... 2006-07,2006-07, 2006-07 & 2012-13, and by the other assessee M/s.Kishanlal & Sons (HUF) ITA No. 2932/Mds/2017 for the AY 2006-07. 2. Mr. B. Ramakrishnan represented on behalf of the Appellant and Mr.R.clement Ramesh Kumar, Additional CIT, represented on behalf of the Respondent. 3. It was submitted by the Ld.AR that the total demand in all the five appeals in the case of the assessee is to an extent of Rs. 3.18 crores. It was a submission that the whole demand came to an existence on account of cash loan given by the assessee to Mr.Darmendra Bafna of M/s.Surana Corporation Ltd. It was a submission that on account of search conducted on the assessees by the Department, all the assets of the assessees are under seizure with the De ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... res, not properly explained in the assessment proceedings in the case of Mr.C.Kishanial for AY 2006-07. Wherever the sources were explained through Loans/ advances, penalty u/s 271D and 271E of the Act was levied amounting to Rs. 10,00,000/- and Rs. 3,00,000/-. In the case of C.Kishanlal and Sons HUF, the amount Rs. 4.65 Crores was added as unexplained loan. Further, in the case of Late Mr.Champalal, the assets found during the course of search was added as unexplained for AY 2012-13 and the balance tax amounting to Rs. 15.93 Lakhs is outstanding. The undersigned is the legal heir and son of Late Mr. Champalal. It is most humbly and respectfully submitted that undersigned Assessee/ Petitioner has no objection in entire disputed demand ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in respect of the assessee from the assessee's debtor as recognized by the Revenue being Mr.Darmendra Bafna whose address has been provided by the assessee. The attachments in respect of the assets of the assessees, which have been done by the Revenue, shall remain unaltered. The Bank account, if any, of the assessee which have been attached by the Revenue, shall stand lifted. It must be understood that when all the assets of the assessees have already been attached, obviously the assessee would be incapable of making any further payments as assessee would be unable to take loans by mortgaging the assets. However, the debtors of the assessee are still available and enforceable. This being so, the recovery of disputed tax against the assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X
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