TMI Blog2022 (10) TMI 224X X X X Extracts X X X X X X X X Extracts X X X X ..... dditional income of Rs.15.00 crores. As the submission of the learned Counsel for the assessee that it is not an un-accounted receipt but the same is on account of sale of land and the assessee has claimed such receipt as exempt income. Further, in absence of maintenance of any books of account by the assessee no addition u/s 68 can be made. It is also his submission that although admission is an important piece of evidence but the same is not conclusive. Hon'ble Supreme Court in the case of Pullangode Rubber Produce Co. vs State Of Kerala And Anr. [ 1971 (9) TMI 64 - SUPREME COURT ] has held that an admission is an extremely important piece of evidence but it cannot be said that it is conclusive. It has been held that it is open to the person who made the admission to show that it is incorrect. We find the assessee in the instant case in the return of income filed by him, has claimed an amount as exempt on account of sale of agricultural land. Therefore, we find some force in the argument of the learned Counsel for the assessee that the same cannot be treated as unexplained cash receipts, However, the alternate contention of the learned Counsel for the assessee that the sam ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessee to explain the source of such investment. Merely stating that the assessee has sufficient funds will not absolve the assessee from his responsibilities especially when no cash flow statement was filed to explain the availability of funds and the assessee is also not maintaining any books of account. In this view of the matter and in view of the detailed reason given by the CIT (A) while sustaining the addition made by the Assessing Officer, we do not find any infirmity in the order of the learned CIT (A) on this issue. Accordingly, ground of appeal No.6 is dismissed. Addition u/s 68 - undisclosed income in absence of satisfactory explanation - HELD THAT:- As entire amount cannot be added to the total income of the assessee. Since the assessee is involved in the real estate business and the entries in the books of account do not indicate whether it is in the nature of money received for purchase of land or loan etc., and the assessee has not declared any income from business, therefore, considering the totality of the facts of the case, we are of the considered opinion that the adoption of profit rate at 10% on the amount of Rs.21.00 lakhs will meet the ends of justice. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d is on account of the agricultural land which was used for agricultural activity, therefore, the order of the learned CIT (A) in our opinion is fully justified. Accordingly, ground raised by the assessee is dismissed. Recomputation of capital gain - HELD THAT:- We do not find any infirmity in the order of the CIT (A) in directing the Assessing Officer to recompute the capital gain after reducing the cost of acquisition from the sale proceeds - DR could not point out any error in the order of the learned CIT (A) on this issue. We, therefore, uphold the order of the learned CIT (A) and direct the Assessing Officer to recompute the capital gain after reducing the cost of acquisition from the sale proceeds after due verification. Needless to say, the Assessing Officer shall give due opportunity of being heard to the assessee while deciding the issue. We hold and direct accordingly. Ground of appeal No.9 by the assessee and ground of appeal by the Revenue are accordingly allowed for statistical purposes. Addition u/s 68 - HELD THAT:- We find the AO in the instant case made addition being the cash deposit in the Bank A/c maintained with Kotak Mahindra Bank on the ground that t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d no information is available that the assessee has received the amount of Rs.25.00 lakhs from Sri Sudhakar or from anyone. However, we do not find any merit in the above argument of the learned Counsel for the assessee in absence of any satisfactory explanation. Therefore, the order of the CIT (A) sustaining the addition made by him so is upheld. Undisclosed receipts - HELD THAT:- A perusal of the copy of the return of income filed by the assessee shows that the assessee has declared sale considerationbeing 1/5th in the sale of land at Marepally, Ghatkesar Mandal, Hyderabad. After deducting the purchase cost of Rs.75.00 lakhs, the assessee has declared profit of Rs.21,30,654/- which is not disputed by the Assessing Officer in the assessment order. Since the Assessing Officer himself has accepted capital gain therefore, again making the addition for the same seized document, in our opinion, is not justified. Therefore, we set aside the order of the learned CIT (A) and direct the Assessing Officer to delete the addition. Accordingly, this ground raised by the assessee is allowed. - Appeal in ITA No : 132/Hyd/2018, 133/Hyd/2019, 134/Hyd/2019, 135/Hyd/2019, 126/Hyd/2019 - - - D ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eals) erred in confirming the action of the Assessing officer in initiating the proceedings u/s 153A of the I.T. Act inspite of the fact that search was not contemplated in the case of the appellant. 3. The learned Commissioner of Income-Tax (Appeals) ought to have accepted the explanations furnished in respect of each receipt and expenditure without relying on the statement recorded at the time of search. 4. The learned Commissioner of Income-Tax (Appeals) erred in confirming the addition of Rs.1,07,35,000/-holding that the cash receipt to the said extent was not properly explained. 5. The learned Commissioner of Income-Tax (Appeals) erred in confirming the action of the Assessing officer in considering the receipt of Rs.51,80,000/- as unexplained receipt. 6. The learned Commissioner of Income-Tax (Appeals) erred in confirming the addition of Rs.25,87,000 made by the Assessing officer and in holding that the said amount represents unexplained investment in acquisition of the land. 7. The learned Commissioner of Income-Tax (Appeals) erred in Confirming levy of interest u/s 234A(3) and 234B(3) of the I.T. Act. Any other ground that may be urged at the time o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th the seized material. He noted that the assessee during the course of search action had declared Rs 15 crores as additional income for different A.Ys vide his statement recorded u/s 132(4) on 20.11.2014 and resumed on 21.11.2014. The above additional income of Rs.1,07,35,000/- was once again admitted by the assessee vide his explanation submitted to the DDIT (Inv.) Unit.II(1) Hyderabad which is specifically mentioned at para 11.5 of the said explanation. Since the assessee failed to offer any convincing reply during the assessment proceedings, the Assessing Officer treated the cash receipts of Rs.1,07,35,000/- as his undisclosed income and brought the same to tax. 8. Before the learned CIT (A), the assessee submitted that he along with another co-owner Shri K.Narasimhulu executed the sale deed on 8.12.2011 in favour of Turbovent Industries Private Limited. It was submitted that the entire land is agricultural land situated beyond 8 kms from Hyderabad Municipal Corporation limits. The lands were not converted into non-agriculture. Revenue records also show that the lands are agriculture in nature. The assessee and the co-owner have carried on agricultural operations on the said ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Ors. in the case of M/s Nitin Agarwal (HUF) Ors Vs. ITO 11. He submitted that all the receipts cannot be treated as the income of the assessee except when such receipt is falling under any particular head of income as provided under the I. T. Act. The Assessing Officer did not consider the nature of the receipt and the head of income under which the amount is assessable. Therefore, the said amount cannot be brought to tax. He submitted that before the Assessing Officer as well as the learned CIT (A), the assessee has stated that he sold the land along with one Shri K. Narsimhulu to Turbovent Industries Ltd vide sale deed dated 8.12.2011 and his part of sale consideration was already admitted as capital gain which was claimed as exempt. He accordingly submitted that the addition made by the Assessing Officer and sustained by the learned CIT (A) is not called for. Referring to various decisions he submitted that an admission is an extremely important piece of evidence but it cannot be said that it is conclusive. In his alternate contention, he submitted that due indexation benefit be given for computing the capital gain. 12. The learned DR, on the other hand, heavily relied ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dmission is an extremely important piece of evidence but it cannot be said that it is conclusive. It has been held that it is open to the person who made the admission to show that it is incorrect. We find the assessee in the instant case in the return of income filed by him, has claimed an amount of Rs.1,07,35,000/- as exempt on account of sale of agricultural land. Therefore, we find some force in the argument of the learned Counsel for the assessee that the same cannot be treated as unexplained cash receipts, However, the alternate contention of the learned Counsel for the assessee that the same can be treated as capital gain and due indexation benefit be allowed is acceptable. We, therefore, deem it proper to restore the issue to the file of the Assessing Officer with a direction to consider the amount of receipt at Rs.1,07,35,000/- by the assessee as sale proceeds of a capital asset and allow consequential indexation benefit of the cost of the asset and determine the long-term capital gain after verifying the details. Needless to say, that the Assessing Officer while deciding the issue shall give due opportunity of being heard to the assessee and decide the issue as per fact a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eriod of two years from the date of search till the date of assessment proceedings, the assessee could not offer any satisfactory explanation and the assessee during the course of search had himself declared additional income of Rs.15.00 crores. 16.2 It is the submission of the learned Counsel for the assessee that it is not an un-accounted receipts but the same is on account of sale of land and the assessee has claimed such receipt as exempt income. Further, in absence of maintenance of any books of account by the assessee no addition u/s 68 can be made. 17. The learned Counsel for the assessee drew the attention of the Bench to Page No.2 of the Paper Book where a copy of the seized paper is placed. He submitted that a perusal of the same would show that this is the a/c of the assessee Shri Puajala Mahesh Babu as on 31.5.2011 with Shri T. Jangaiah. He submitted that the totaling of the first 3 entries comes to Rs.51,80,000/- out of which Rs.15,90,000 represents cheque receipts. The fourth entry is return of cheque against payment of cash. The balance amount of Rs.36,80,000/- after deducting the amount of Rs.15.00 lakhs received in cheque from the total of Rs.51,80,000/- was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... during the same year. Therefore, no addition is called for. We find some force in the above arguments of the learned Counsel for the assessee. As mentioned earlier in the preceding paragraphs, an admission is an importance piece of evidence but it cannot be said that it is conclusive. It is open to the person who made the admission to show that it is incorrect. A perusal of the seized document placed at page 2 of the Paper Book clearly shows that this is the a/c of Shri Pujala Mahesh Babu as on 31.5.2011 with Shri T. Jangaiah. The total of the first three entries i.e., Rs.15,90,000/-, Rs.30,00,000 and Rs.5,00,000/-comes to Rs.51,86,000). The first amount is again received by cheque, whereas the subsequent entries are received in cash. Further, the fourth entry shows that an amount of Rs.15,00,000 was returned by cheque and other amounts were returned by cash. Thus, the account is squared up during the year itself. Further, the assessee does not maintain any books of account. Therefore, the addition of the same u/s 68 in our opinion, is not called for. However, when the assessee is undertaking certain transactions with one Shri T. Jangaiah and he was engaged in the business of real ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 8097/11 1,50,000 Total 20,54,500/- 22. He noted that the assessee was unable to explain the source of the amount of investments. Hence, he added Rs.20,54,500/- to the total income of the assessee as unexplained investments. 23. In appeal, the learned CIT (A) confirmed both the additions made by the Assessing Officer by observing as under: 9.5 I have carefully considered the submissions made by the appellant as well as the observations of the AO in the impugned order. It is seen that inspite of repeated and sufficient opportunities having been given during the course of search proceedings as well as during the course of assessment proceedings, the assessee and his AR did not avail of the same, for reasons best known to them. Now, during the course of appellate proceedings, the assessee's AR has tried to explain the investment of Rs.5,32,000/- in land by stating that the said investment was made in the preceding year. However, as pointed out by the Assessing Officer, the consideration paid for the said lands was in cash and no dates are mentioned in the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d CIT (A) sustained the addition made by the Assessing Officer, the reasons of which have already been reproduced in the preceding paragraph. We do not find any infirmity in the order of the learned CIT (A) on this issue. Admittedly, the assessee could not explain the source of such investment. Further, as mentioned earlier, this land was purchased during the year itself and the onus was on the assessee to explain the source of such investment. Merely stating that the assessee has sufficient funds will not absolve the assessee from his responsibilities especially when no cash flow statement was filed to explain the availability of funds and the assessee is also not maintaining any books of account. In this view of the matter and in view of the detailed reason given by the CIT (A) while sustaining the addition made by the Assessing Officer, we do not find any infirmity in the order of the learned CIT (A) on this issue. Accordingly, ground of appeal No.6 is dismissed. 28. Ground of appeal No.7 relates to levy of interest under section 234A(3) and 234B(3) of the I.T. Act which are mandatory and consequential in nature. Accordingly, this ground is dismissed. 29. In the result, ap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... I.T. Act. 11. Any other ground that may be urged at the time of hearing . ITA No.126/Hyd/2019 A.Y 2013-14 (Revenue) A.Y 2013-14 31. The ground raised by the Revenue are as under: 1. The ld.CIT(A) is not justified in facts and in law in deleting the addition made by the assessing officer U/s. 68 of the IT Act. 2. The ld.CIT(A) is not justified in facts and in law in deleting the addition made on account of cash deposits ignoring the fact that the assessee has not submitted the details of bank accounts and even failed to prove the sources for such deposits. 3. ld.CIT(A)) is. not justified in facts and in law in allowing the expenditure of Rs. 1,48,00,000/ relying on the seized document vide page no-51 A/PMB/06, having confirmed the addition on account of unaccounted receipts of Rs. 1,48,00,000/- relying on the same seized material. 4. The appellant craves leave to amend or alter any ground(s) or add a new ground which may be necessary . 32. Ground of appeal No.1, 3 11 by the assessee being general in nature are dismissed. 33. In Ground of appeal No.2, the assessee has challenged the validity of 153A proceedings. 33.1 After hearing bot ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the amount paid by Shri Ranga Reddy did not represent the income of the assessee and therefore, no addition is called for. 36. Referring to the seized material, it was submitted that the contention of the assessee is supported by the entries in the seized material. Referring to the provisions of section 132(4A) it was submitted that the contents of the seized material are to be considered as to be true and affidavit of Shri Ranga Reddy also supports the statement of the assessee. 37. Based on the arguments advanced by the assessee, the learned CIT (A) called for a remand report on this issue and after considering the remand report of the Assessing Officer and the rejoinder of the assessee to such remand report from the Assessing Officer, he upheld the action of the Assessing Officer by observing as under: 2.5 I have carefully considered the submissions made by the appellant as well as the observations of the AO in the impugned order. The case records and the seized material have also been perused. It is seen that during the search and seizure proceedings, the assessee had admitted Rs.15 crores as additional income in the statement recorded u/s.132(4). He had filed an Af ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not maintain any books of account and the amount of Rs.15.00 lakhs was also not recorded in his books. Under these circumstances, neither the provisions of section 68 nor the provisions of section 69 are applicable. He submitted that the said amount was never received as the income of the assessee and the seized material also does not provide any such information. Therefore, the amount cannot be added and hence should be deleted. 40. The learned DR, on the other hand, heavy relied on the order of the Assessing Officer and the learned CIT (A). 41. We have heard the rival arguments made by both the sides, perused the orders of the AO and the learned CIT (A) and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us by both sides. We find the AO in the instant case made addition of Rs21.00 lakhs on the ground that page No.49 of the impugned Annexure shows that the assessee has received an amount of Rs.33,50,000/- from Shri Ranga Reddy on different dates out of which an amount of Rs.28,50,000/- was received in cash and Rs.5.00 lakhs by cheque. Since the amount of Rs.21.00 lakhs relates to the financial year 2012-13, the Asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at Annexure APMB/06 is a Black Diary of SBI General Insurance containing written pages numbered from 01 to 21 which was impounded from the business premises of the assessee. As per Page No.46 of the above impounded Annexure, the assessee has received Rs.81,25, 000/- under the head Tulsi Bhavani Nagar, Chengicherla during the Financial Year 2012-13. When confronted, the assessee had no reply. Hence, the amount of Rs 81,25,000/- was brought to tax in the hands of the assessee as his undisclosed income. 43.1 The Assessing Officer similarly noted that as per Para 41 of the above impounded annexure, the assessee has received an amount of Rs.77,00,000/- under the head Tulsi Bhavani Nagar, Chengicherla during financial year 2012-13 (Rs.56.00 lakhs) and Rs.21,00,000/- (financial year 2013-14). In absence of any satisfactory reply, the Assessing Officer made addition of the same to the total income of the assessee. While doing so he noted that the assessee, during the course of search action had declared Rs 15 crores as additional income for different assessment years vide his statement recorded u/s 132(4) on 20-11-2014 resumed on 21-11-2014 The above income was once again admitted by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 0,000/- but it is a part of the said amount. 45. So far as Rs.56.00 lakhs is concerned, it was submitted that According to the Assessing Officer, page No.41 Annexure A/PMB/06 indicates receipt of Rs.56 lakhs which is from the venture Tulasi Bhavani Nagar. It was argued that Tulasi Bhavani Nagar is the name of the Chengicherla venture. The assessee admitted sale consideration of Rs.1,74,33,695/-in the return of income filed by him. The amount of Rs.77 lakhs is a part of the said amount. Therefore, the Assessing Officer is not justified in making a separate addition of Rs.56 lakhs pertaining to this year when the assessed income admitted includes short term capital gain. 46. Based on the arguments advanced by the assessee, the learned CIT (A) called for a remand report from the Assessing Officer. After considering the remand report of the Assessing Officer and the rejoinder of the assessee to such report, he sustained the addition. While doing so, he noted that the amounts in question have been disclosed by the assessee himself in his written submission made before the DDIT (Inv.) and the assessee himself has worked out the undisclosed income. The assessee had offered the addit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the learned CIT (A) is equally not justified in sustaining the addition. 48. The learned DR, on the other hand, heavily relied on the order of the Assessing Officer and the learned CIT (A). He submitted that despite sufficient opportunities granted by the Assessing Officer as well as the learned CIT (A), the assessee was not able to substantiate the claim which is now being made before the Tribunal. Therefore, the order of the learned CIT (A) should be upheld and the ground raised by the assessee should be dismissed. 49. We have heard the rival arguments made by both the sides, perused the orders of the AO and the learned CIT (A) and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us by both sides. We find the AO in the instant case on the basis of entries at Page No.46 of the Annexure A/PMB/6 and page No.41 of Annexure APMB/ 6 made addition of Rs.81,25,000/- and Rs.56 lakhs respectively on account of undisclosed receipts under the head Tulsi Bhavani Nagar . We find the learned CIT (A) upheld the above two additions made by the Assessing Officer on the ground that the assessee had made declaration before the Investi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e is accordingly partly allowed. 51. In ground of appeal No.6, the assessee has challenged the order of the learned CIT (A) in sustaining the addition of Rs.12.00 lakhs, Rs.10.00 lakhs (wrongly typed as Rs.100,00,000) and Rs.49,05,000/- respectively on account of unaccounted expenditure. 51.1 Facts of the case, in brief, are that the Assessing Officer noted that Annexure A/PMB/06 is a Black Diary of SBI General Insurance containing written pages numbered from 01 to 51 which was impounded from the PMB premises of the assessee As per Page No 19 of the above impounded Annexure, the assessee has incurred an expenditure of Rs 12,00,000/- under the head Balapur on 20 02.2013. Similarly Page No.50 of the above annexure contains that the assessee has incurred expenditure of Rs.10.00 lakhs during the financial year 2012-13. When the assessee was asked to furnish the sources of the said expenditure with supporting evidence, the assessee failed to furnish any explanation. Hence the amount of Rs 12,00,000/- and Rs.10,00,000/- were brought to tax in the hands of the assessee as his unaccounted expenditure. The Assessing Officer further noted that as per Page No 48 of the impounded Annexur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... icer and rejoinder of the assessee to such remand report, the learned CIT (A) sustained the addition by observing as under: 10.5 I have carefully considered the submissions made by the appellant as well as the observations of the AO in the impugned order. The case records and the seized material have also been perused. Here again, it is seen that the amounts in question have been disclosed by the assessee himself in his written submissions made before the DDIT(Inv), and the assessee himself has worked out the undisclosed income and offered the same for taxation. It is seen that during the course of post-search proceedings, the assessee has been given ample opportunity and he has analyzed each and every seized record, and offered his explanation on the same. As discussed in detail in Para 9.5 above, the assessee had offered Rs.15 crores as additional income for various years in the statement recorded u/s.132(4), and had also filed an Affidavit to this effect before Investigation wing, which he retracted after a period of two years, which cannot be considered as retraction within 'reasonable time'. In view of the discussion above, and considering the fact that suffi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nts as unaccounted expenditure because it is the seized material showing that the assessee has actually made the payments and the entire seized material pertains to the projects undertaken by the assessee and as such he cannot categorize these payments as unaccounted expenditure. This is especially, when the assessee has not been maintaining regular books of account, it cannot be said that the said payrments are unaccounted. Further, the seized material should be considered in its entirety and as appearing thereon. The Assessing Officer cannot disbelieve certain part of the seized material when it comes to the payments and believes certain part of the seized material when it comes to receipts. Therefore, the addition of Rs.10 lakhs representing the payments made by the assessee cannot be made. Hence, the same need to be deleted . 58. The learned DR, on the other hand, heavily relied on the order of the Assessing Officer and the learned CIT (A). 59. We have heard the rival arguments made by both the sides, perused the orders of the AO and the learned CIT (A) and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us by bo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the same is based on seized document copy of which is placed at Page No.2 of the Paper Book. A perusal of the same shows Rs.49,90,000/- is written under Sai Krishna Envlave, Mar Palley, Ghatkesar. The first three entries of Rs.5 lakhs, Rs.2 lakhs and Rs.10,000/- do not have any dates. Therefore, it cannot be said that the above three entries totaling to Rs.7,10,000/- belong to this year. We, therefore, are of the opinion that out of Rs.49.90 lakhs, an amount of Rs.7,10,000/- cannot be considered as relating to this A.Y. So far as the balance amount of Rs.42,80,000/- is concerned, it is the submission of the learned Counsel for the assessee that he has sufficient sources for making payment. It is his alternate contention that the seized documents mention assessee s share at 30%. We, therefore, accept the alternate contention of the assessee that out of the remaining amount of Rs.42,80,000/-, only 30% of the same being the share of the assessee as mentioned can be added which comes to Rs.12,84,000/-. So far as the addition of Rs.10,00,000/- is concerned, the learned Counsel for the assessee could not give any satisfactory explanation for which the same has to be sustained. We, theref ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d the land in less than 13 months. There was no evidence of agricultural activity being carried out. Hence it does not satisfy the test laid down by the Supreme Court for treating certain receipts as received from sale of agricultural property and hence exempt. The addition made by the Assessing Officer is therefore sustained and all the grounds related to this issue are DISMISSED . 66. Aggrieved with such order of the learned CIT (A), the assessee is in appeal before the Tribunal. 66.1 The learned Counsel for the assessee submitted that the assessee in the return of income admitted capital gain of Rs.41,84,550/- arising on sale of 10 acres 30 guntas of agricultural land and claimed the same as exempt u/s 10(14) of the I.T. Act. He submitted that the Assessing Officer without considering the claim of exemption of capital gain added the amount by presuming that the assessee admitted agricultural income from agricultural lands. He submitted that the Assessing Officer should have held that the agricultural land is not an asset within the meaning of section 2(14) of the I.T. Act. Even the learned CIT (A) dismissed the ground raised by the assessee holding that there was no evide ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , therefore, the order of the learned CIT (A) in our opinion is fully justified. Accordingly, ground raised by the assessee is dismissed. 69. Ground of appeal No.9 by the assessee and Ground of appeal No.3 by the Revenue relate to the order of the learned CIT (A) in directing the Assessing Officer with certain directions to recompute the capital gain. 69.1 Facts of the case, in brief, are that the Assessing Officer, during the course of assessment proceedings, noted that during the year the assessee has declared short term capital gain of Rs 22,07,990/- from sale of land at Chengicherla Ac 2.32 guntas AcO.23 guntas. However, the assessee failed to substantiate his claim and no evidences were furnished even after giving numerous opportunities to the assessee. Hence an amount of Rs 1,52,25,705/- was held as income from undisclosed sources after reducing gain offered by assessee from sales consideration of Rs 174,33,695/- i.e., (1,74,33,695-22,07,990) and added to the total income of the assessee. 70. Before the learned CIT (A) it was submitted that the assessee derived sale consideration of Rs.1,74,33,695/- which is not disputed by the appellant. Further, the Assessing Off ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Assessing Officer to pass a consequential order. The learned DR, on the other hand, heavily relied on the order of the Assessing Officer. 73.1 After hearing both sides, we do not find any infirmity in the order of the learned CIT (A) in directing the Assessing Officer to recompute the capital gain after reducing the cost of acquisition from the sale proceeds of Rs.1,74,33,695/-. The learned DR could not point out any error in the order of the learned CIT (A) on this issue. We, therefore, uphold the order of the learned CIT (A) and direct the Assessing Officer to recompute the capital gain after reducing the cost of acquisition from the sale proceeds after due verification. Needless to say, the Assessing Officer shall give due opportunity of being heard to the assessee while deciding the issue. We hold and direct accordingly. Ground of appeal No.9 by the assessee and ground of appeal by the Revenue are accordingly allowed for statistical purposes. 74. Ground of appeal No.10 relates to relates to levy of interest under section 234A(3) and 234B(3) of the I.T. Act which are mandatory and consequential in nature. Accordingly, this ground is dismissed. ITA No.126/Hyd/2019 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Assessing Officer without considering such receipts added Rs.17,77,000/- deposited into the bank account. 77. Based on the arguments advanced by the assessee the learned CIT (A) called for a remand report from the Assessing Officer. The remand report was confronted to the assessee who filed his rejoinder. After considering the remand report of the Assessing Officer and the rejoinder of the assessee, the learned CIT (A) deleted the addition by observing as under: 7.5 have carefully considered the submissions made by the appellant as well as the observations of the AO in the impugned order. It is seen that the Assessing Officer has added all the receipts separately while completing the assessment, which are more than the amount of the cash deposit in the bank account. These additions made by the AO are separately dealt with in the subsequent paras of this order. It is also seen that the AO has also added business income of Rs.7,72,275/- which the assessee had shown in the original Return, but which he failed to include in the u/s.153A. The appellant has not raised any ground against the said addition. Since all the receipts and the business income is already taxed, no separa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ome-Tax (Appeals) based on the facts of each addition. 4. The learned Commissioner of Income-Tax (Appeals) erred in confirming the additions made by the Assessing officer of Rs.12,50,000; Rs.94,50,000/- and Rs.2,89,38,000/-; Rs.1,55,00,000/- on the ground that they represent unexplained cash receipts. 5. The learned Commissioner of Income-Tax (Appeals) ought to have considered the fact that the said amounts were properly explained and a detailed explanation was filed before the learned Commissioner of Income-Tax (Appeals) explaining the sources for the receipt of the said amounts. 6. The learned Commissioner of Income-Tax (Appeals) erred inn confirming the action of the Assessing officer in making addition on account of unaccounted expenditure of Rs.25 lakhs, Rs.25 lakhs; Rs.12.50 lakhs; Rs.12.50 lakhs; Rs. 12.50 lakhs; and Rs.12.50 lakhs without properly considering the explanation offered by the appellant. The learned Commissioner of Income-Tax (Appeals) ought to have seen that the appellant properly explained the source for each expenditure incurred and the learned Commissioner of Income-Tax (Appeals) ought to have held that the Assessing Officer is not justified ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sing Officer noted that as per Page No.30 of the above impounded Annexure, the assessee has received cash amounting to Rs. 94,50,000/- towards Ghatkesar Venture during the F.Y.2013-14. When confronted, the assessee did not offer any satisfactory reply. Hence, the receipts of Rs 94,50,000/- was treated as undisclosed income and brought to tax. 88.1 So far as the addition of Rs.1,55,00,000/- is concerned, the Assessing Officer noted that as per Page No.20 of the impounded Annexure, the assessee has received cash amounting to Rs.1,35,00,000/- from Sri. R. Brahmmanna, Badupet during the F.Y.2013-14. The assessee has also received cash of Rs.20,00,000/- towards Chengicherla on 20.07.2013. When confronted, the assessee did not offer any satisfactory reply. Hence, the entire receipts of Rs.1,55,00,000/- was treated as his undisclosed income and brought to tax. While making the above addition, the Assessing Officer noted that assessee during the course of search action had declared Rs 15 crores as additional income for different assessment years vide his statement recorded u/s 132(4) on 20-11-2014 resumed on 21-11-2014. The above income was once again admitted by the assessee vide his ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dy. The amounts are not credited in the books of the appellant. Therefore, the Assessing Officer is not justified in making addition of Rs.12,50,000/. 92. So far as the addition of Rs.94,50,000/- is concerned, it was argued that this payment of Rs.94,50,000/- relates to the previous year. It was submitted that the assessee proposed-to enter into a venture at Ghatkeswar. Sri K.Gopal Goud was interested in joining the said venture. He paid the amount of Rs.94,50,000/- On receipt of the amount, the project was aborted and the entire amount was returned to Sri K.Gopal. The amount was neither recorded in the books of account of the appellant nor related to any venture which was undertaken by the appellant. The evidence also indicates that it relates to the Ghatakeswar venture and the receipt is from Sri K.Gopal. Therefore, the Assessing Officer is not justified in making addition of Rs.94,50,000/- on the presumption that the amount represent receipt. 93. So far as the addition of Rs.1,55,00,000/- is concerned, it was argued that a reference may be made to page No.21 which relates to the account of Sri R.Brahmanna. He is having 20% share in Boduppal property. He paid an amount of R ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The amounts appearing in the seized paper carries the progressive total showing the receipts at different points of time. Such final progressive total of the said receipts is Rs.1,82,94,000/-i.e. Rs.1,58,44,000 24,50,000. It can be seen from the said seized paper (Page No.10 of the Paper book) that the first total of Rs.59,54,000/- represent receipts up to 11.5.2013; then, the second total of Rs.85,44,000/- includes Rs.59,54,000/; then the third such total of Rs.1,06,44,000/- includes Rs.85,44,000/; and then the total of Rs.1,58,44,000/- includes Rs.1,04,44,000/- and the final total of Rs.1,82,94,000/- includes Rs,1,58,44,000/- Therefore, in total, the seized paper shows the receipts of Rs.1,82,94,000/-only and not Rs.2,89,38,000/- as taken by the Assessing Officer. The Assessing Officer has wrongly added Rs.1,06,44,000/- to the final total of Rs.1,82,94,000/- and arrived the figure of Rs.2,89,38,000/- which is wrong. The figure of Rs.2,89,38,000/- taken by the Assessing Officer included Rs.1,06,44,000/- twice. Therefore, the correct receipts in the seized paper are Rs.1,82,94,000/- only. 10. Secondly, the said receipts of Rs.1,82,94,000/- represents the sale consideration re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of account and, therefore, the provisions of Sec.68 have no application. The amount was not invested anywhere and, therefore, the provisions of Sec.69 have no application. Further, the seized material shows about Ghatkesar venture. The venture of 7 acres 20 guntas at Ghatkesar did not take place and the amounts were returned to Sri K.Gopal Goud. Further, the seized material itself is the proof that the amount was received from Sri K.Gopal Goud. Further, the seized material itself is the proof that the amount was received from Sri K.Gopal Goud. The sad evidence is a reliable evidence in view of Sec.132(4A) of the Act. Therefore, the Assessing Officer is not justified in making addition. 14. Cash receipt of Rs.1.55.00.000 The Assessing Officer has considered the seized material on page 6 of the paper book for making this addition. One Sri R.Brahmanna, is a shareholder in Boduppal venture along with 9 others. He paid towards his share in the venture and not to the appellant. It is the amount of Sri Brahmanna in respect of Boduppal and Chengicherla ventures and has nothing to do with the appellant. The amounts were not received by the appellant. They were not recorded in the book ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f Rs.2,89,38,000/- therefore, the amount of Rs.1,06,44,000/- is directed to be deleted. 99. So far as the remaining amount of Rs.1,82,94,000/- is concerned, we find merit in the argument of the learned Counsel for the assessee that the same represents the sale consideration received on sale of plots in Sai Krishna Enclave where the assessee s share is only 50% i.e. Rs.91,47,000/-. The assessee in his return of income for the impugned A.Y has adopted sale consideration at Rs.99,42,558/- being 50% share in the project after claiming the purchase cost of Rs.78,11,904/- and admitted capital gain of Rs.21,30,654/-. Since the sale consideration admitted in the return of income is more than the receipt appearing in the seized papers, therefore, in our opinion, no addition is called for. Accordingly, the addition made by the Assessing Officer and sustained by the learned CIT (A) is directed to be deleted. 100. So far as the cash receipt of Rs.12,50,000/- is concerned, it is the submission of the learned Counsel for the assessee that the above amount was received from Mr. M. Ranga Reddy for acquisition of a suitable property. Since the same was not located, the amount was returned. We ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ,00,000/-. 103. In ground of appeal No.6, the assessee has challenged the order of the learned CIT (A) in sustaining the unaccounted expenditure 1,00,00,000/- which consists of various amount made by the Assessing Officer. 104. After hearing both the sides, we find the above addition of Rs.1,00,00,000 consists of Rs.25.00 lakhs each twice and Rs.12,50,000/-(4 times). The above additions are made on the basis of cash receipts and certain working in the seized documents during the course of search. So far as first Rs.25.00 lakhs is concerned, the Assessing Officer noted that Annexure A/PMB/02 containing pages numbered from 01 to 56 was seized from the residence of the assessee As per Page No 29 30 of the above Seized Annexure, Sri. Brahmanna Goud has paid an amount of Rs. 25,00.000/- to Sri N Sudhakar on 20.01.2014 as advance money towards purchase of Agricultural Land Admeasuring Ac 2-33 Guntas., at Sy.No.215/part, Boduppal. Ghatkesar, Ranga Reddy Dist. The assessee failed to furnish the sources of the said expenditure with supporting evidence Hence. the amount of Rs 25.00,000/- was brought to tax in the hands of the assessee as his unaccounted expenditure. 105. So far as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ized annexure, the assessee has made cash payment of Rs.12,00,000/- towards Balapur venture on 20.07.2013. Since the assessee failed to furnish the source of such expenditure with supporting evidence, the Assessing Officer made the addition of Rs.12,50,000/- as his unaccounted expenditure to the total income of the assessee although the amount as per the seized document is only Rs.12,00,000/-. 110. Before the learned CIT (A) the assessee made elaborate arguments based on which the learned CIT (A) called for a remand report from the Assessing Officer. After considering the remand report from the Assessing Officer and the rejoinder of the assessee to such remand report, the learned CIT (A) sustained the addition on the ground that the assessee himself has worked out the undisclosed income in his submissions made before the DDIT (Inv.). Further, the assessee himself has declared the additional income of Rs.15.00 crores which he is retracting after a lapse of two years without any justice. 111. Aggrieved with such order of the learned CIT (A) the assessee is in appeal before the Tribunal. 112. The learned Counsel for the assessee while making his arguments drew the attention o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ,89,38,000/-. Secondly, the said amount represents the consideration received on sale of plots and the appellant had 50% share which was already admitted in the return of income filed for the assessment year 2014-15. Therefore, the Assessing Officer is not justified in making the addition and the CIT (A) is not justified in confirming the addition. 12 Cash receipt of Rs.12.50,000/-: This was taken by the Assessing Officer from page Annexure APMB/06 and the seized material is at page No.1 of the paper book. The appellant submitted that Sri M.Ranga Reddy paid the amount for acquisition of suitable property. As required plot was not located, the amount was returned. The fact that the amount was received from Sri M.Ranga Reddy through cheque is confirmed by the entry in the seized document itself. (Kindly refer to Sec.132 (4A) of the Act). It is also submitted that the appellant did not maintain books of account. He did not record the receipt in his books. In the circumstances, nether the provisions of Sec.68 nor the provisions of Sec.69 are applicable. The said amount was never received as the income of the appellant and the seized material d0es not provi0 any such information. T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s and to consider the cash payments made by him as if they belonged to the assessee Therefore, the Assessing Officer has wrongly made the addition of Rs.1,55,00,000 Rs.1,35,00,000 of Boduppal venture and Rs.20,00,000 of Chengicherla venture] and the Ld. CA) has wrongly confirmed the said addition without properly appreciating the entries appearing in the seized material. In view of the above, the addition of Rs.1,55,00,000/- need to be deleted . 113. The learned DR, on the other hand, heavily relied on the order of the Assessing Officer and the learned CIT (A). He submitted that when the assessee, during the course of search proceedings had himself made the calculation and offered the income before the DDIT (Inv.) and further the assessee himself has admitted additional income of Rs.15.00 crores in his statement recorded u/s 132(4), therefore, after a period of 2 years retraction by the assessee is not justified. He accordingly submitted that the order of the learned CIT (A) should be upheld and the ground raised by the assessee should be dismissed. 114. We have heard the rival arguments made by both the sides, perused the orders of the AO and the learned CIT (A) and the pap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mount was paid by one Mr. Narasimha for development of the Bodupal venture where his share is 10%. We, therefore, find merit in the submission of the learned Counsel for the assessee that it was not the payment made by the assessee but payment made by Shri Narasimha whose share in the Bhodupal project is 10%. Accordingly, the order of the learned CIT (A) is set aside and the Assessing Officer is directed to delete the addition of Rs.12,50,000/- being related to Shri Narasimha. 117. So far as the 2nd addition of 2nd Rs.12.50 lakhs is concerned, we find the Assessing Officer made the addition on the ground that cash payment of Rs.10.00 and Rs.12.50 lakhs were made for the Bhodupal venture. However, a perusal of the seized document copy of which is placed at Page 21 of the Paper Book shows that the amount was paid by Shri T. Ravi Yadav who is having 10% share in the Bhodupal venture. We, therefore, find merit in the argument advanced by the learned Counsel for the assessee that it is not a payment made by the assessee but payment made by Shri T. Ravi Yadav for his 10% share in the Bhodupal venture. Therefore, the order of the learned CIT (A) is set aside and the Assessing Officer i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the learned CIT (A) in confirming the addition of Rs.21.00 lakhs as undisclosed receipts. 120.1 Facts of the case, in brief, are that Annexure A/PMB/06 is a Black Diary of SBI General Insurance containing written pages from 01 to 21 which was impounded from the business premises of the assessee. As per Page No.41 of the above impounded Annexure, the assessee has received Rs.77,00,000/- under the head Tulsi Bhavani Nagar during the FY 2012-13(Rs 56 lakhs) FY 2013-14 (Rs 21,00,000/-). When confronted, the assessee had no reply. Hence, the Assessing Officer made addition of the amount of Rs 21,00,000/- pertaining to FY 2013-14 as his undisclosed income. 121. Before the learned CIT (A), it was submitted that as per the seized documents, the amounts were received under the head Tulsi Bhavani Nagar and the amount has already been admitted in the return of income. Therefore, the Assessing Officer is not justified for the above said addition. 122. Based on the arguments of the learned Counsel, the learned CIT (A) called for a remand report from the Assessing Officer and after considering the remand report of the Assessing Officer and the rejoinder of the assessee to such rem ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion of land at Tulsi Bhavani Nagar for an amount of Rs.99,42,558/- and has admitted the capital gain of Rs.21,30,654/-. It is his submission that despite the same being offered in the return of income, the Assessing Officer again made the addition which is not justified. We find some force in the above argument of the learned Counsel for the assessee. A perusal of the copy of the return of income filed by the assessee shows that the assessee has declared sale consideration of Rs.94,42,558/-being 1/5th in the sale of land at Marepally, Ghatkesar Mandal, Hyderabad. After deducting the purchase cost of Rs.75.00 lakhs, the assessee has declared profit of Rs.21,30,654/- which is not disputed by the Assessing Officer in the assessment order. Since the Assessing Officer himself has accepted capital gain of Rs.21,30,654/-, therefore, again making the addition of Rs.21.00 lakhs for the same seized document, in our opinion, is not justified. Therefore, we set aside the order of the learned CIT (A) and direct the Assessing Officer to delete the addition of Rs.21.00 lakhs. Accordingly, this ground raised by the assessee is allowed. 126. Ground of appeal No.8 relate to the order of the learn ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ious decisions cited before us by both sides. We find the Assessing Officer in the instant case made addition of Rs.78,11,904/- as income from undisclosed sources on the ground that the assessee failed to substantiate the purchase cost of the land which it has reduced from the sale consideration while computing capital gain. We find the learned CIT (A) sustained the order of the Assessing Officer the reasons of which are already reproduced in the preceding paragraph. It is the submission of the learned Counsel for the assessee that it has reduced the cost price of Rs.78,11,904/- from the sale consideration of Rs.99,42,558/- for computing the short term capital gain. Since according to the Assessing Officer, the assessee could not substantiate the purchase cost of Rs.78,11,904/-, therefore, considering the totality of the facts of the case and in the interest of justice, we deem it proper to restore the issue to the file of the Assessing Officer with a direction to give an opportunity to the assessee to substantiate with evidence to his satisfaction regarding purchase cost of Rs.78,11,904/- which the assessee has claimed as deduction from the sale consideration of Rs.99,42,558/-. Th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed by the assessee is dismissed. 135. Ground of Appeal No.3 relates to the order of the learned CIT (A) in confirming the addition of Rs.25.00 lakhs made by the Assessing Officer on account of unaccounted receipts. 136. Facts of the case, in brief are that Annexure A/PMB/01 is a loose sheet of paper containing pages numbered from 01 to 58 which was seized from the residence of the assessee. Page no.6 of the seized Annexure is a cash receipt, dated 31.10.2014 wherein an amount of Rs.25 lakhs is seen to have been received by the assessee in cash from Smt.Nagineny Pradamda during the financial year 2014-15, towards sale of Open Plot at Sy.No.351 354, Area 1625 Sq.Yds, Uppal, R,R. Dist. i.e. @ Rs.22,000/ per Sq.Yds. The Assessing Officer asked the assessee to confirm whether the said receipt of Rs.25,00,000/- was offered to tax. The assessee was also asked to show cause as to why entire receipt of Rs.25,00,000/- should not be treated as his undisclosed income and brought to tax for the A.Y.2015-16. The assessee failed to file any reply in this regard. Accordingly, the entire receipts of Rs.25,00,000/- was treated by the Assessing Officer as undisclosed income of the assessee. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ards at Uppal in R.R. District. Therefore, the learned CIT (A) was fully justified in sustaining the addition made by the Assessing Officer. 142. We have heard the rival arguments made by both the sides, perused the orders of the AO and the learned CIT (A) and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us by both sides. We find the Assessing Officer in the instant case made addition of Rs.25.00 lakhs on the ground that the assessee has received an amount of Rs.25.00 lakhs in cash from one Smt. Nagini Pramada towards sale of one plot in Survey No.351 354. Area 1625 sq. yards and the assessee has not disclosed the same, therefore, it is an unaccounted receipt. We find the learned CIT (A) upheld the action of the Assessing Officer on the ground that despite ample opportunity given by the search party as well as the Assessing Officer during the course of assessment proceedings, the assessee failed to offer any satisfactory explanation. Further, the amount in question was disclosed by the assessee himself in his written submission made before the DDIT (Inv.) and he has himself has worked out the undisclosed income. Fur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n absence of any satisfactory explanation regarding the source of the said expenditure, the Assessing Officer made the addition of the same. Similarly, as per the said written pages 1 to 21, the Assessing Officer noted that the assessee has incurred an expenditure of Rs.1,97,90,000/- during the financial year 2014- 15 and the assessee failed to furnish any explanation to explain the source of the said expenditure. Therefore, the Assessing Officer made addition of the same. 145. Similarly, as per page No.58 of the said annexure, he noted that the assessee has incurred an expenditure of Rs.1.00 lakhs on 6.6.2014. In absence of any satisfactory explanation by the assessee to explain the source of such expenditure, the Assessing Officer made addition of Rs.1.00 lakh. The Assessing Officer further noted that the assessee has made declaration of additional income of Rs.15.00 crores before the DDIT (Inv.) Hyderabad which was subsequently confirmed by an affidavit dated 5.1.2015. In the explanation before the DDIT (Inv.), the assessee had arrived at income of Rs.14,56,68,000/- for various years and further offered an amount of Rs.43,32,000/- to cover the discrepancy and honor the commit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ppal village. The appellant was the owner of the property and the developers are Sri K.Gopal and 7 others. The appellant is entitled for 15% of the amount and the developer is entitled for 85%. The amount of 15% was paid by the developers to the appellant and is noted in the said paper. 8. Plotwise payments were effected and the receipts against the development agreement entered into in respect of the property. Therefore, it is not an expenditure incurred and the Assessing Officer is not justified in making the addition. 9. Without prejudice, the appellant submits that the said amount even if it were to be an expenditure should not have been added as there were number of receipts earlier and the expenditure incurred needs to be given set off. 10. Addition of Rs 197.90 lakh: According to the Assessing Officer, the expenditure incurred as per the annexure A/PMB/6 amounted to Rs. 1,97,90,000/-. The Assessing Officer is of the view that there was expenditure to the extent of Rs.1,97,90,000/- as per the annexure A/PMB/06. There is no such figure in Annexure 6. The expenditure towards Boduppal venture is noted at page 24. In respect of Boduppal venture the appellant is the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The appellant submits that the said admission was retracted later by the appellant. However, the Assessing Officer is of the view that the said amount of Rs.15 crores should be added for all the years together. According to the Assessing Officer, the additions made by him for all the years together works out to Rs.14,56,68,000/- as against the alleged declaration made. Therefore, the Assessing Officer added Rs.43,32,000/- This is not legally valid. When the Assessing Officer is treating certain sum of money as the income there should be a basis for him either from the seized material or from any source. Without any such basis, without any information and simply based on a retracted declaration made, he cannot add the said amount to the income admitted . 148 The learned DR, on the other hand, heavily relied on the order of the Assessing Officer and the CIT (A). He submitted that the learned CIT (A) has given justifiable reasons while sustaining the addition. The assessee in the instant case had himself worked out the undisclosed income in his submission made before the DDIT (Inv.) followed by an affidavit. Further, despite ample opportunity given, the assessee could not substant ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h a direction to compute the final addition that has been sustained on account of unaccounted receipts and allow set off of the same to explain the unexplained expenditure of Rs.55.60 lakhs. The first issue raised by the assessee in the ground of appeal is accordingly allowed for statistical purposes. 151. So far as the 2nd addition of Rs.197.90 lakhs is concerned, we find the Assessing Officer made the addition on the basis of seized document page No.1 to 21 annexure A/PMB/01 wherein certain amounts are mentioned as expenditure as miscellaneous , the total of which comes to Rs.1,97,90,000/-. It is the submission of the learned Counsel for the assessee that the same relates to the expenditure towards Boduppal venture where the assessee is the owner of the land and not the developer and the developer is Shri K. Gopal Goud 7 others who in turn entrusted the venture to Mansani Constructions and Sri Kishore was the person Incharge of the concern. It is also his submission that the seized document shows that the expenditure for each of the venture undertaken, the details of expenditure incurred and the persons who incurred the expenditure were mentioned in the document. It is his ..... X X X X Extracts X X X X X X X X Extracts X X X X
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