TMI Blog2021 (7) TMI 883X X X X Extracts X X X X X X X X Extracts X X X X ..... explained transfer of money from Sri Suresh Garg to the assessee by way of supporting evidences - DR has not brought on record any documentary evidence including statements u/s 132(4) of the Act of the assessee, or sh Suresh Garg or personals of the company M/s MFL to contradict the claim of the assessee of transfer of money from sh Suresh Garg to the assessee. Similarly, regarding the availability of Pin money and savings the assessee has explained with the help of cash flow statement supported by assessment orders of assessee, his wife and their HUF, copies of their respective balance sheets and their cash withdrawal as reproduced by the Learned CIT(A) in para 4.1(m) of the impugned order. No reason not to accept availability of cash in the hands of the assessee and his wife to explain the cash has been made in the hands of the assessee. - Decided against revenue. Addition of unexplained foreign exchange - CIT-A deleted the addition - HELD THAT:- Revenue has failed to point out any error in the finding of the Ld. CIT(A) on the issue in dispute except the issue of the additional evidences, which has already been dealt by the Tribunal in order sheet dated 05/10/2009. In ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... whether it is a purchase of the goods or merely estimate. The document is not a bill of purchase andit mentions only certain items/name and certain figures against them. The document is dumb as far as indication of purchase or investment by the assessee or the number as currency. In our opinion, to treat those figures as purchase or investment by the assessee, is based on the presumption, without any corroborating evidence, and therefore Ld. CIT(A) is justified in deleting the addition. Unexplained investment - investment/expenditure recorded in concerned loose paper was different from alleged investment by Dr Shamsher Prakash - CIT-A deleted the addition - HELD THAT:- We find that first two dates mentioned in the loose paper is date next to what mentioned as remittance date. The amounts of these two dates are also approximately matching. The date and amount mentioned against NRO in the loose paper is matching exactly with the remittance from NRO account received in the bank account of M/s Mahaan Protein Ltd. In our opinion, matching of the date and amount of investment from NRO account establish that other entries in the loose paper are also related to investment by Dr Shamsh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bank having name as Bank One . AO has not carried out any enquiry from the relevant bank and ascertained to whom this card or the transaction relates. Making addition on the basis of incomplete information, only on the basis of the guess work is not justified in cases of search assessment. No infirmity in the finding of the Learned CIT(A) on the issue in dispute and accordingly, we uphold the same. The ground of the appeal of the Revenue is accordingly dismissed. Block assessment - Unexplained gifts - undisclosed income to be made as per section 158BA(2) - HELD THAT:- We find that gifts received were appearing in books of accounts and disclosed for the purpose of Income-tax return by the assessee and no incriminating material much less any material related to such gifts was found during the course of the search . The Ld. CIT(A) has relied on the decision of the Hon ble Delhi High Court in the case of Ravi Kant Jain [ 2001 (3) TMI 52 - DELHI HIGH COURT ] wherein it is held that block assessment is not substitute for regular assessment. We do not find any error in the order of the Learned CIT(A) in following decision of the Hon ble jurisdictional High Court. No error in the ord ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ained source can be made in the hands of the assessee. In view of the above, we do not find any error in the order of the Ld. CIT(A) on the issue in dispute and accordingly we uphold the same. - IT(SS)A No.81/Del/2004 - - - Dated:- 28-6-2021 - Shri O.P. Kant, Accountant Member And Shri Kuldip Singh, Judicial Member For the Appellant : Ms. Pramita M. Biswas, CIT(DR) For the Respondent : Sh. C.S. Aggarwal, Sr. Advocate, Sh. R.P. Mall, Advocate ORDER PER O.P. KANT, AM: This appeal by the Revenue is directed against order dated 31/12/2003 passed by the Learned Commissioner of Income-tax (Appeals)-I, New Delhi [in short the Ld. CIT(A) ] for block period from 01/04/1990 to 03/11/2000 raising following grounds: GROUNDS OF APPEAL On the facts and in the circumstances of the case, the Ld. CIT(A) erred in deleting the addition on account of unexplained cash of ₹ 1,52,150. On the facts and in the circumstances of the case, the Ld. CIT(A) erred in deleting the addition on account of unexplained source of foreign exchange of ₹ 3,96,484/-. On the facts and in the circumstances of the case, the Ld. CIT(A) erred i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd seized. Consequent to search action, a notice under section 158BC of the Act ( i.e. under provisions in operation during relevant period ) was issued on 01/08/2001 and in response the assessee filed a return of income for the block period (i.e. 01/04/1990 to 13/11/2000) on 24/09/2001 declaring following undisclosed income of ₹ 19,57,000/-: (i) Unexplained deposits in assessee s bank account No.6-354230-001 in Citi Bank ,Singapore ₹ 18,50,000 (ii) Unexplained cash ₹ 1,00,000/- (iii) Unexplained investment in Microwave oven ₹ 7000/- Total ₹ 19,57,000/- 3. During block assessment proceeding, the assessee was asked to explain source of income for investment in cash, jewellery etc. and also asked to explain various transactions recorded in documents seized. After providing opportunity of being heard to the assessee, the Assessing Officer in assessment order dated 29/1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e permitted to raise the ground at this belated stage. On the other hand, learned DR contended that the issue involved at present is about the admission of grounds whether it involves factual issue or not would be considered while adjudicating the issue raised in the additional ground on merit. According to the learned DR, unless revenue is permitted to raise this ground for consideration on merit all other attending circumstances exhibiting the investigation of facts or involvement of delay in raising such ground are irrelevant. These can be entertained when ground is admitted for adjudication on merit. We have heard the rival contentions and gone through the record carefully. Section 253(2) provides that if the Commissioner had any objection to any order passed by the First Appellate Authority under sec. 154 or under sec. 250 of the Act then he may direct the Assessing Officer to appeal to the HAT against that order. In every appeal of the Department along with the ground of appeal, approval of the Commissioner is also annexed by the revenue. In the present appeals also, the original grounds of appeals have been raised by the Assessing Officer after obtaining approval from ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s Pin money of assessee and his wife accumulated over the years. (iii) ₹ 1 lakh was offered to tax in the block return filed by the assessee. 5.2 Above explanation of the assessee was not accepted by the Assessing Officer due to following reasons: (i) All the cash withdrawals from bank account of M/s Mahan Foods Ltd were tallied with the cash book of the said company, which was seized during the course of the search, and deposits corresponding to withdrawal are found duly recorded. But, the same cash book, does not show any withdrawal by Sh Suresh Garg on corresponding dates, thus there is no question of handing over of cash by Sri Suresh Garg to the assessee. (ii) No details of household expenses and other evidences justifying saving of cash as Pin money were filed by the assessee. The assessee and his wife were maintaining bank accounts and the fact that cash was not deposited shows that it was undisclosed in nature. 5.3 The Assessing Officer held cash of ₹ 3,90,000/- as unexplained in the hands of wife of the assessee as same was found from the locker in her name and the balance unexplained cash of ₹ 1,52,150/-was held as undi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the seized day book viz. Annexure A-129, there is a clear mention of ₹ 5,25,000/- given to Shri Suresh Garg as 'imprest on 7/9/2000. The physical cash available during the time of the search at Paonta Shahib office and factory was ₹ 1,15,412/- whereas the cash in hand as per the books of Ms Mahaan Foods Ltd. was ₹ 5,41,401/-. The difference in cash found and that recorded in the cash book was explained to be the cash taken on imprest by Shri Suresh Garg. The imprest balance with Shri Suresh Garg is duly recorded in the combined day book maintained by the cashier of M/s Mahaan Dairies Ltd. and M/s Mahaan Foods Ltd. This day book was seized during the search and showed imprest balance available with Shri Suresh Garg, and the balance recorded against Shri Suresh Garg are sufficient to cover the amount given to the appellant. Since the availability of cash funds cannot be doubted, because the seized day book shows receipt of imprest amounts and balances of Shri Suresh Garg, the addition of cash of ₹ 1,52,150/- in the hands of the appellant is not justified and the same is deleted. 5.6 Before us, the Learned DR submitted that record ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 8377; 2 lakh on 07/09/2000 from MFL and this same money was given to the assessee on next day. Before the Ld. CIT(A), the assessee filed additional evidences to explain evidence in support of money withdrawn by Sh. Suresh Garg from MFL and money handed over by Sri Suresh Garg to the assessee. In the case of MFL cash-in-hand on the date of the search (i.e. 14/09/2000) as per cash book was of ₹ 5, 41, 401/- but physical cash of ₹ 1,15,412/- was only found from the common office of the factory/ premises of MFL and other companies, in which the assessee is director. The assessee explained before the Learned CIT(A) that the difference in cash as per books and physically found was primarily due to the cash taken on Imprest by Sh Suresh Garg and out of which he had given ₹ 5 lakh to the assessee in August/September 2000 for the purpose of official expenses. The assessee has explained that this ₹ 5 lakh received from Mr. Suresh Garg was partly kept in locker No. 138 and partly at his residence. 5.9 The Assessing Officer has rejected the explanation mainly on the ground that there is no mention of withdrawal of imprest money by Sh. Suresh Garg in the cash book ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... accordingly dismissed. 6. The ground No.2 of the appeal of the Revenue relates to addition of unexplained foreign exchange of ₹ 3,96,884/-, which has been deleted by the Learned CIT(A). The addition has been further reduced to ₹ 36,564/- by the Assessing Officer under section 154 of the Act. Before the Ld. CIT(A), the assessee explained source of US$ 911 found from his residence as under: (i) Unspent amount of USD 111, out of foreign currency acquired by the assessee from an Authorised dealer for travel abroad in relation to business trip of M/s MFL and MPL. (iii) $ 800 represented money left by one Mr. Satwant Singh Parley, UK resident , we personal friend of the assessee. 6.1 The Ld. CIT(A) considered the above submission of the assessee, which is supported by the affidavit and passport papers of Sri Satwant Singh. Before us the Revenue has failed to point out any error in the finding of the Ld. CIT(A) on the issue in dispute except the issue of the additional evidences, which has already been dealt by the Tribunal in order sheet dated 05/10/2009. In our opinion, the assessee has discharged his onus of explaining the source of currency found f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not discharged and merely on surmises and conjecture, made the addition. 7.3 The Learned CIT(A) deleted the addition observing as under: I have considered the facts of the case. The explanation furnished by the appellant is supported by the permission letter from the Reserve Bank of India, which contains the signature of the authorized signatory on the reverse of the page. The appellant has also filed copies of bank drafts and FIRCs in support of investment in shares made by Shri Shamsher Prakash. Copies of share applications filed by Dr. Shamsher Prakash and the affidavit of this party have been filed. The documentary evidences available on record clearly show the fact of investment in shares by Dr. Shamsher Prakash. The onus of establishing a benami transaction is on the assessing authority. In these circumstances of the case, it has not been established that the appellant is the benami owner of the shares in question. On the other hand, the documentary evidences furnished indicate the correctness of the explanation regarding investment in shares by Dr. Shamsher Prakash. Accordingly, the addition of ₹ 16,49,330/- is deleted. 7.4 We have heard r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ficer, seized paper indicated instruction for investment of US$ 20,000 for a period of 17 month and therefore same could not have been available for re-deposit. The Assessing Officer did not accept peak balance theory of the assessee and he treated entire deposit of US dollars 92,053.33 equivalent to Indian ₹ 40,50,346/-as undisclosed income of the assessee and after subtracting the income of ₹ 18,15,000/-already offered by the assessee in the return of block period, he made addition for the balance amount of ₹ 22,00 346/-to the income declared for block period. 8.2 Before the Ld. CIT(A), the assessee submitted that withdrawals from said account were made only for the purpose of specific investment in mutual funds/deposits , which were controlled by the CitiBank and the amount received on maturity/sale of those mutual fund investment/deposits was redeposited in the bank account. He also submitted that till the date of the search i.e. 14/09/2000 deposit of US dollar 73,051.30 was only appearing in the bank account. The Ld. CIT(A) accepted the contention of the assessee of peak balance and deleted the addition observing as under: 11. I have considere ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . The procedure adopted by Citibank. Singapore was that whenever investments were liquidated the proceeds of the same were credited to the bank account of the assessee. If the assessee wanted to withdraw funds from he had to withdraw funds from'though the savings bank account. It is thus noted that between 31/3/2000 and 14/9/2000, there are two credits of USD 16,953 on 18.4.2000 and USD 12,438 on 11.7.2000. The narration against these credits, FT incoming disinvestment clearly indicates that these credits are in respect of earlier investments out of the bank account which have been termed as FT outgoing investment . Thus the total investment to be considered is USD 41957.83 as on 31.3.2000 which has already been surrendered by the appellant in the block return. The remaining credits represent flotation of same funds as were already in the account as on 31.3.2000. Hence, further addition on account of unexplained deposits is not called for. Accordingly, the addition of ₹ 22,0,346/- is deleted. Ground No. 5 relates to addition of ₹ 3,17,530/- on account of alleged unexplained expenditure recorded on page 9 of Annexure A- 3. In the assessment order, th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lable on page 224 of the paper-book. Regarding, credit of 1500 USD appearing on 11/04/2000, the assessee submitted before the Ld. CIT(A) that it was in the nature of the deposit. We find that This amount is certainly not out of the withdrawals, but same has not been included for the purpose of peak balance. Regarding credits of USD 16,953 and USD 12,438 appearing on 18/04/2000 and 11/07/2000 respectively, the assessee has claimed the same as proceeds of liquidation of investment made earlier on the 10th and 11/04/2000, but no evidence in support has been filed except reference of banks terminology of FT INCOMING DISINVESTMENT in the bank statement. The assessee has also not disclosed the amount of income earned in liquidation of socalled investment. The assessee has also not included the interest income of USD 35.52, USD 33.75 , USD 32.72, USD 46.90 and USD 53.58 credited respectively on 29/04/2000, 31/05/2000, 30/06/2000, 31/07/2030 01/08/2000. The interest for the period from 01/09/2000 to 14/09/2000 ( till the date of search) has also not been computed. In view of all the observation, we are of the opinion that the disclosure made by the assessee on the basis of the peak balan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ncome. Accordingly, the addition is deleted. 9.2 Before us, the learned DR relied on the order of the Assessing Officer and submitted that the seized document clearly reflects expenditure on various items, and therefore, it was the onus of the assessee to explain the said expenditure and failure to do so the Assessing Officer has correctly made addition. 9.3 The Learned Senior Counsel of the assessee, on the other hand, relied on the finding of the Ld. CIT(A) and submitted that without any corroborating evidence brought on record, addition on the basis of the loose documents found was unjustified. 9.4 We have heard rival submission of the parties on the issue in dispute and perused the relevant material on record. For ready reference, a scanned copy of the said loose paper found from the residence of the assessee is reproduced as under: 9.5 From the above document, it is evident that narration of the items includes Tin plates, spoons, Singh etc. but the document does not speak whether the number(s) represent quantity or currency. In our opinion, even if we presume that this document belongs to the assessee and the assessee has failed to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... zed document that any investment has been made by the appellant. If such have been the case, it should have been established where and how the alleged investment had been made by the appellant. On the other hand the appellant s explanation that the figures roughly correspond to the investment made by Dr.Shamsher Prakash is reasonable. The presumption as made by the A.O. in the assessment order cannot be drawn in the absence of specific material regarding undisclosed investment. In these circumstances, the addition of ₹ 20,79,110/- is not warranted and the same is deleted. 10.2 Before us, the Learned DR relied on the order of the Assessing Officer and submitted that investment in question reflected in loose paper is different from the alleged investment by Dr. Shamsher Prakash as data-wise amounts remitted are not exactly matching with the amount recorded in the loose paper. 10.3 On the other hand, the Learned Senior Counsel of the assessee relied on the finding of the Ld. CIT(A) and submitted that Department has not been able to pinpoint any other investment corresponding to the amount recorded in loose papers, even after carrying out a thorough search of his ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2079100 10.6 On perusal of the above reconciliation, we find that first two dates mentioned in the loose paper is date next to what mentioned as remittance date. The amounts of these two dates are also approximately matching. The date and amount mentioned against NRO in the loose paper is matching exactly with the remittance from NRO account received in the bank account of M/s Mahaan Protein Ltd. In our opinion, matching of the date and amount of investment from NRO account establish that other entries in the loose paper are also related to investment by Dr Shamsher Parkash, because in case of other entries in loose paper , the amount are approximately equivalent to INR ( Indian rupees ) equivalent of amount remitted by Dr Shamsher Prakash. In our opinion, the assessee has discharged his onus of rebutting the presumption by the Assessing Officer under section 132(4A) of the act. We also find that the Assessing Officer has not been able to identify any other investment made by the assessee despite carrying out thorough search of his residential and official premises. In the circumstances, the finding of the Ld. CIT(A) on th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nce, a scanned copy of the relevant document, which is available on page 235 of the paper-book is reproduced as under: 11.4 On perusal of the above document, we find that no where it is mentioned that those items of the jewelry have been actually purchased by the assessee. There is no mention of any payment made by the assessee also. The addition cannot be made only on the basis of the existence of alleged well-known practice presumed by the Learned Assessing Officer. The Assessing Officer was required to bring on record name of the jeweller and corresponding purchase bills if any before making addition in the hands of the assessee on the basis of this loose paper. In our opinion, the Assessing Officer has squarely failed in bringing any such documentary evidence and thus no addition can be made without evidence of actual purchase of jewelry by the assessee. Even if we presume for a moment that the jewelry listed in the loose paper was purchased by the assessee, same is than included in the list of the jewelry found from the premises, and therefore no separate addition on the basis of this loose paper is required. In view of the above facts and circumstances, t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng name as Bank One . The Assessing Officer has not carried out any enquiry from the relevant bank and ascertained to whom this card or the transaction relates. Making addition on the basis of incomplete information, only on the basis of the guess work is not justified in cases of search assessment. We do not find any infirmity in the finding of the Learned CIT(A) on the issue in dispute and accordingly, we uphold the same. The ground of the appeal of the Revenue is accordingly dismissed. 13. The ground No. 9 of the appeal relates to deletion of the addition on account of unexplained gifts of ₹ 25,96,077/-. 13.1 The brief facts qua the issue in dispute are that the Assessing Officer observed gift received by his minor daughters and son from Sh. Shamsher Prakash during the block period and in absence of any details of gifts received filed by the assessee, the Assessing Officer made addition for ₹ 18,96,077/- in financial year 95-96 and addition of ₹ 7 lakh in financial year 98-99 corresponding to the block period. Before the Ld. CIT(A) the assessee submitted that all the documents in support of gift along with bank certificate and affidavit of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Learned CIT(A). 13.4 We have heard submission of the parties on the issue in dispute and perused the relevant material record. The Learned CIT(A) has held that under the block assessment addition for the undisclosed income has only to be made as per section 158BA(2) of the Act along with Explanation thereof. The undisclosed income has been defined in section 158BC of the Act, according to which, the undisclosed income includes: (a) assets like money, bullion, jewellary etc. found during the course of the search and source of which is not explained or disclosed in regular return of income filed or (b) any income based on entry in the books of accounts, or other documents are transaction, which has not been disclosed in the regular return of income filed or (c) any expense, deduction or allowance which is found to be false. 13.5 We find that gifts received were appearing in books of accounts and disclosed for the purpose of Income-tax return by the assessee and no incriminating material much less any material related to such gifts was found during the course of the search . The Ld. CIT(A) has relied on the decision of the Hon ble Delhi High Court ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat the assessee has also accompanied his family on these visits. Accordingly, unexplained travelling expenses by the assessee are taken at ₹ 1,53,276/- and an addition of ₹ 1,18,553 in F.Y. 98-99 and ₹ 34,723 in F.Y 2000-01 is made to the undisclosed income of the assessee. (d) Regarding travel to Europe, it is stated that tickets were received as complements by her husband , Sh. Sanjeev Goyal, since he is a frequent flyer. As already stated above no- explanation regarding foreign travel have been furnished by assessee who is claimed to be a frequent flyer in the course of block assessment proceedings of Smt. Saloni Goyal.The cost of hi Europe- Delhi ticket in the F.Y 99-00 was ₹ 34,000/-.For assessee and three family members unexplained expenditure on tickets alone is ₹ 1,36,000/- which is added to the undisclosed income of die assessee for the F.Y 1999-00. (e) No explanation regarding expenditure on boarding and lodging expenses incurred by assessee s family members during foreign visits has been furnished. The total period of stay abroad in different countries is 54 (fifty four) days .The unexplained boarding and lodging expenses are ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Learned DR relied on the order of the Assessing Officer, whereas the learned Counsel of the assessee relied on the finding of the learned CIT(A). 14.4 We have heard rival submission of the parties on the issue in dispute and perused the relevant metal on record. It is settled law that addition under block assessment can be made for undisclosed income only as laid down under section 158BA(2) of the Act read with explanation thereof. The undisclosed income has been defined in section 158B (b) as under: 158B. In this Chapter, unless the context otherwise requires,- (a) (b) undisclosed income includes any money, bullion, jewellery or other valuable article or thing or any income based on any entry in the books of account or other documents or transactions, where such money, bullion, jewellery, valuable article, thing, entry in the books of account or other document or transaction represents wholly or partly income or property which has not been or would not have been disclosed for the purposes of this Act, or any expense, deduction or allowance claimed under this Act which is found to be false. 14.5 From the above , it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... household withdrawal by the assessee in different financial years and also the documentary evidence of expenditure incurred for those goods, which were found recorded in the accounts of M/s Mahaan food Ltd and M/s Mahaan proteins Ltd. The Ld. CIT(A) deleted the addition made by the Assessing Officer on this ground. 15.2 Before us, the learned DR relied on the order of the Learned Assessing Officer. On the other hand, the Learned Senior Counsel of the assessee relied on the submission of the assessee before the Learned CIT(A) and finding of the Ld. CIT(A). 15.3 We have heard rival submission of the parties on the issue in dispute and perused the relevant material on record. A list of the items, explanation of the assessee before the Assessing Officer, and the addition made by the Assessing Officer have been summarized by the Ld. CIT(A) in para 24.1(a) , which is reproduced as under: 24.1 The submission of the appellant relating to this ground of appeal are as under:- (a) The learned assessing officer has made the following additions to the undisclosed income of the assessee Item Sourced as expla ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Total ₹ 2,52,500 15.3 The assessee has explained source and amount of investment in goods, which Ld. CIT(A) has reproduced in impugned order as under: Specific submissions on each item of addition are as under:- i) Camera Digital Zoon - 1 : Addition ₹ 20,000 -Purchased for ₹ 5,000 in F.Y. 1999-2000 out of cash available with the assessee (page 323 of the paper book). -Purchase of household items aggregating to ₹ 40,000 shown separately in cash flow statement for the F.Y. 1999-2000submitted during assessment proceedings (page 392 of the paper book). -Assessment in the case of assessee completed u's 143(3) for assessment year 2000-01 vide order dtd. 31.03.03 and no addition has been madetherein on any account (including household drawings). ii) Digital Sharp diary: Addition ₹ 1,500 -Purchase by assessee in F. Y. 86-87 for ₹ 1,500. -Assessee ownsa Palm Organisor which is a much improved version of a digital diary'. A palm organisor has all the functions of a digital diary and much mor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ice showing purchase by M/s. Mahaan Foods Limited and ledger account of the company filed before learned assessing officer (page 399 of the paper book). -The make/model of fax machine found, matcheswith that on the invoice. -Copy of relevant extracts of fixed assets register of Mahaan Foods Limited showing location to be at assessee's residence cum office is being filed (page 316 of the paper book). viii) VCR (Sony): Addition ₹ 8,000 -Purchased by assessee in F.Y. 97-98 out of cash available with him, for ₹ 6,500 (page 323 of the paper book). -Cash flow statement of relevant period filed showing purchase of household items separately. (Page 393 of the paper book). -Income-tax return of the assessee for A. Y. 98- 99 accepted by the Income-tax department. ix) Colour TV 21 (Optonica): Addition ₹ 14,000 -Purchased in F. Y. 88-89 for ₹ 8,000 by the assessee. -Optonica was brand of Ms. Kalvani Sharp Ltd. M/s. Kalvani Sharp Ltd. stopped being a leading player of TVs manufacturer in early nineties. -Optonica as a TV brand was popular upto late eighties only. x) LG-Fridge Model 4 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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