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Manoj Kumar Singhal C/o. Shiv Raj Kumar Batra, Advocate, H. No. 310-A, Old Partap Talkies Road, Peerji Mohalla, Rohtak vs ITO Ward-1 Narnaul
March, 13th 2014
                   DELHI BENCH: `E' NEW DELHI


                           I.T.A .Nos.-6238 /Del/2012
                           (ASSESSMENT YEAR-2003-04)
     Manoj Kumar Singhal                     vs ITO
     C/o. Shiv Raj Kumar Batra, Advocate,         Ward-1
     H. No. 310-A, Old Partap Talkies             Narnaul
     Road, Peerji Mohalla, Rohtak
     (APPELLANT)                                  (RESPONDENT)
                           I.T.A .Nos.-6239/Del/2012
                       (ASSESSMENT YEAR-2003-04)
     Manoj Kumar Singhal & Sons HUF,         vs ITO
     C/o. Shiv Raj Kumar Batra, Advocate,         Ward-1
     H. No. 310-A, Old Partap Talkies             Narnaul
     Road, Peerji Mohalla, Rohtak
     (APPELLANT)                                  (RESPONDENT)

            Appellant by:       Sh. Shiv Raj Batra (Adv).
            Respondent by:      Sh. Keyur Patel, Sr. DR


       These two appeals filed by two different assessee's against separate orders
of CIT(A), Rohtak are being decided by a common order as it was a common
stand of the parties that facts and circumstances being identical the arguments
consequently advanced in one appeal would cover the other also.
2.     A perusal of the impugned orders shows that the Ld. CIT(A) in his orders
has confirmed the action of the Assessing Officer in both the appeals imposing
                                             2                   ITA Nos.6238, 6239/Del/12

penalty of Rs.66,151 & 1,32,259/- respectively on facts pertaining to 2003-04
assessment year which common to both the appeals.
3.    It is seen that apart from difference in the mention of penalty amounts the
grounds are identical in both the appeals for ready reference we reproduce the
grounds in ITA 6328/Del/12:-
            "1.      That the Ld. CIT(Appeals) Rohtak has erred in law as well as
            on facts of the case in confirming penalty of Rs.66151/-(ITA 6329/Del/
            12,Rs. 1,32,259)wrongly levied u/s 271(1)(c) of I.T Act by the Assessing
            Officer. Thus the said appellate order is totally wrong and illegal.
            2.       That the authorities below have further erred in law as well as
            on facts of the case in wrongly applying the provision of Section
            271(1)(c) of I.T Act. Thus the order passed on wrong application of the
            provision of Section 271(1)(c) of I.T Act is totally wrong and illegally.
            3.       That the authorities below have further erred in appreciating
            the record and facts of the case that the appellant has duly disclosed all
            the particulars of gift received in his capital account. Thus there was
            no concealment or furnishing of inaccurate particulars of income.
            Thus the order of confirming the penalty u/s Section 271(1)(c) is totally
            wrong and illegal.
            4.       That the authorities below have further failed to appreciate
            that true and complete particulars of donor were duly furnished
            showing his identity capacity and genuineness of transaction as
            address, PAN No., Bank A/c, Copy of I.T Return and affidavit of the
            donor were furnished. Thus treating the true and correct particulars of
            gift received from donor as concealed income is totally wrong, illegal
            and void0ab-initio.
            5.       That the appellant craves, leave to add, delete or amend any
            ground/grounds of appeal at the time of hearing.

4.    Reference is being made to the facts of ITA No-6328/Del/2012 as both the
parties advanced their arguments qua the said appeal. The record shows that the
assessee individual returned an income of Rs.1,84,880/- which was processed u/s
143(1) and thereafter was re-opened by issuance of notice on the basis of
information received in regard to gift received by the assessee from Shri Sunil
Kumar Garg of Rs.2 lac. The assessment was concluded wherein the amount
received by way of a cheque was added to the income of the assessee as the
assessee failed to prove identity and creditworthiness etc of the donor by way of
                                             3                  ITA Nos.6238, 6239/Del/12

producing him who is claimed to be assessee's friend. Since the assessee failed
to prove the same the genuineness of the transaction was held to be not proved
and the finding of the AO challenged by the assessee was confirmed by the ITAT
in quantum proceedings vide its consolidated order dated 15th January 2010 in the
case of the assessee individual and HUF in ITA 4259/Del/2009 & ITA
4.1.   The Assessing Officer based on the satisfaction recorded in the assessment
order taking note of the fact that the order has been confirmed by the CIT(A) (at
that stage) initiated penalty proceedings. Taking further note of the fact that the
said order of the CIT(A) was also confirmed by the ITAT he granted a fresh
opportunity to the assessee to advance his arguments in response to the penalty
4.2.   A perusal of the record shows that reliance was placed upon CIT Vs.
Balbeer Singh 214 CTR 147 and also advanced the following submission:-

            " In response to this notice the assessee filed a written reply which has
            been placed on record. In the written submissions the assessee has
            stated that, "it is submitted that nothing has been concealed in this
            matter because both the gifts are duly shown in the books of accounts
            and in the return of income-tax after showing these gifts in capital
            account which has already put on record. So I have not concealed any
            particulars regarding these gifts. Due to change in opinion at the time
            of re-assessment the assessing officer has treated this amount as
            incomes and taxed accordingly."

4.3.   The Assessing Officer not convinced with the explanation offered further
held that the decision rendered by the Punjab & Haryana High Court was
distinguishable on facts as in the facts before the Punjab & Haryana High Court
the identification of the donor; genuineness of the transaction was not doubted
which was not a fact in the present case. Accordingly, minimum penalty of
Rs.66,151/- was imposed by him.
                                            4                  ITA Nos.6238, 6239/Del/12

5.    The assessee agitated the issue before the CIT(A).                  The facts were
marshaled by the CIT(A) in the following manner:-
      "2.   Brief facts are that the assessee filed return of income declaring total
            income of Rs.1,84,800/- which was processed u/s 143(1) of the Act.
            The A.O received information from CIT, Rohtak that there was an
            accommodation entry through an entry operator Sh. Sunil Kumar
            Garg, resident of 2244, Gali Raghunandan, Naya Bazar, Delhi of
            Rs.2,00 lacs vide DD No. 626823 dated 20/6/2002 through jai Luxmi
            Co-op Bank Ltd. Fatehpuri, Delhi in the bank a/c of the assesssee
            maintained in State Bank of Patiala, Narnaul. It was found that this
            amount of Rs.2,00 lacs has been credited in the capital a/c of the
            assessee for the AY 2003-04. A letter was written by the A.O to Sh.
            Sunil Kumar Garg at the address given in the affidavit for verification
            of gift made to the assesssee but the letter has come back unserved
            with the remarks that `no such person resides at this address'. In view
            of the above, the A.O issued notice u/s 148 to re-assess the income of
            the assessee.
      2.1   In response to the notice u/s 148, the assessee filed return income
            declaring the same income as in the original return. During the
            course of assessment proceedings, the assessee was asked to intimate
            the relationship between him and Sh. Sunil Kumar Garg and the
            whereabouts of Sh. Sunil Kumar Garg who made the alleged gift. In
            response to this, the assessee stated that he was having friendly
            relationship with Sh. Sunil Kumar Garg and he is trying to trace the
            latest address of Sh. Sunil Kumar Garg. Thereupon, the AO asked the
            assessee to intimate the latest whereabouts of Sh. Sunil Kumar Garg
            and produced him for examination. The assessee expressed his
            inability to produce Sh. Sunil Kumar Garg and requested the A.O to
            issue summons u/s 131 at the address supplied on his affidavit and the
            IT return filed by him. The AO accordingly issued summons u/s 131
            for which Sh. Sunil Kumar Garg did not respond.
      2.2   The A.O made enquiries regarding bank a/c no. 14154 in Jai Luxmi
            Co-op Bank Ltd. Fatehpuri, Delhi of Sh. Sunil Kumar Garg and noted
            that a cheque of Rs. 2,01,000/- was deposited in this a/c on 20/06/2002
            and on the same day demand draft of Rs.2.00 lacs was issued to the
            assessee. The cheque of Rs.2,01,000/- was transferred from a/c no.
            3401 of the same bank i.e Jai Luxmi Co-op Bank Ltd. Fatehpuri, Delhi
            on the same day and a/c no. 3401 was in the name of one M/s Usha
            Motor Co.
      2.3   From the above facts, the A.O held that the assessee has not
            discharged the primary onus of establishing the identity and
            creditworthiness of the donor and it was only a colorful device used by
            the assessee to bring his undisclosed money in the garb of a gift. The
            AO made an addition of Rs.2.00 lacs and a further sum of Rs.10,000/-,
            being brokerage paid @ 5% for the accommodation entry, u/s 68 of
            the Act and initiated penalty proceedings u/s 271(10(c) of the Act. The
                                              5                   ITA Nos.6238, 6239/Del/12

             assessee could not succeed against the above mentioned addition in
             the first and second appeals."

5.1.   Considering the submissions advanced on behalf of the assessee the
finding of the AO was confirmed by the CIT(A). For ready-reference the same is
extracted hereunder:-
       "5.   I have considered the issue and the submissions made the AR. The
             appellant contended that the gift of Rs.2.00 lacs has been received
             through banking channels from Sh. Sunil Kumar Garg who affidavit
             and copy of IT return were filed before the AO and therefore it cannot
             be held to hve furnished inaccurate particulars of income or concealed
             any income. Though the appellant furnished affidavit of Sh. Sunil
             Kumar Garg, he was not produced before the A.O. Mere affirmation
             on affidavit is not enough and the contents of the affidavit have to be
             confirmed along with documentary evidence. Even though the AO
             insisted the appellant to produce Sh. Sunil Kumar Garg before him to
             examine the veracity of the affidavit, the appellant failed to discharge
             the onus cast on him. Further, the appellant has failed to prove the
             creditworthiness of Sh. Sunil Kumar Garg for the alleged gift. Mere
             filing of copy of IT return does not absolve the assessee of the onus to
             prove the creditworthiness of the donor. From the facts as noted by
             the A.O, it is seen that Sh. Sunil Kumar Garg gave similar entries of
             gifts to other persons through a web of transactions through different
             bank accounts. The assessee has failed to establish the relationship
             with Sh. Sunil Kumar Garg and the occasion on which the alleged gift
             was received. The above mentioned facts clearly come within the
             purview of `furnishing inaccurate particulars' and therefore attract
             the provisions of section 271(10(c).
             It has been held in the cases of (i) Union of India vs. Dharmendra
             Textile Processors, 306, ITR 276C(SC), (ii) Guljag Industries Ltd. Cs
             CTO, 293 ITR 584 (SC) and (iii) CIT Vs. Atul Mohan Bindal, 317 ITR
             1(SC) that Mens rea not essential for civil liability of penalty-Penalties
             under fiscal statutes are for breach of civil liabilities-Willful
             concealment is not an essential ingredient for attracting civil liability
             as is the cas in the matter of prosecution u/s 276C. Further, in the
             case of CIT Vs. Lal Chand Tirath Ram 225 ITR 675 (P&H) that mere
             offering explanation is not sufficient-Explanation to be substantiated
             by cogent and reliable evidence.
                      Coming to the case laws relied upon the assessee, it is seen
             that in the case of CIT Vs. Reliance Petroproducts Ltd. (Supra),
             Hon'ble Supreme Court held that making an incorrect claim in law
             cannot tantamount to furnishing of inaccurate particulars. In the
             present case, no incorrect legal claim has been made and therefore
             this case law is not applicable to the facts of the appellant. The facts
             in the case of CIT Vs. Balbir Singh (supra) were different as the donor
                                              6                    ITA Nos.6238, 6239/Del/12

             in that case was an NRI and further the identification of the donor and
             the genuineness of the transaction was not doubted. In the case of
             Bhartesh Jain Vs. ITO (Supra), the facts are entirely different in as in
             that case in response to the summons issued by the AO, the party
             appeared and accepted that the cheques in question of Rs.4.00 lacs
             was given by it to the assessee though not as a loan. The other case
             laws relied upon by the AR are either distinguishable on facts or
             entirely on different issues.
             In view of the above, it is held that, it is a fit case for levy of penalty
             u/s 271(1)(c) and therefore the penalty levied by the A.O is upheld and
             the grounds of appeal are dismissed."

5.2.   Aggrieved the assessee is in appeal before the Tribunal. The Ld. AR
submitted that the assessee has not furnished any inaccurate particulars of income
and the factum of receipt of gift of Rs. 2.00 lac from his friend Shri Sunil Kumar
Garg through banking channels supported by affidavit and copy of the Income
Tax return of Shri Sunil Kumar Garg has been placed on record. The said
evidence it was argued is sufficient to prove the identity, genuineness and
capacity of the donor. It was argued that no doubt in quantum proceedings the
issue has been decided against the assessee, however, simply because the
assessee could not prove the fact does mean that the evidence available on record
is disproved. It was also argued that the evidence is not false and the judgment of
the Gujrat High Court dated 22/6/2011 in Tax Appeal No. 496/10 in the case of
CIT Vs. Kokila Behan Isha copy placed at pages 7 to 9 in the paper book was
relied upon. Reliance was also placed upon the order dated 5th August 2009
rendered by the Hon'ble Bombay High Court in I.T Appeal (L) No. 1860/2009 in
CIT Vs. Upendra V. Methani (copy filed in the Court). It was his sub mission
that similar arguments and propositions of law would be relied upon in ITA No-
6239/Del/2012 in the case of Manoj Kumar Singhal HUF wherein a gift of Rs.4
lac has been received is identical manner through Banking Channels.
6.     Ld. Senior DR on the other hand heavily relying upon the impugned order
invited specific attention to para 5 of the impugned order so as to contended that
                                         7                ITA Nos.6238, 6239/Del/12

Shri Sunil Kumar Garg has been found to be making similar entries of gifts to
other persons through a web of transactions through different bank accounts. It
was argued that the assessee has failed to establish the relationship of Shri Sunil
Kumar Garg nor has he addressed the occasion on which the alleged gift was
received and in the penalty proceedings also the position remains the same.
Referring to the judgment of the Apex Court in the case of Union of India Vs.
Dharmendra Textile 306 ITR 276 (SC) it was submitted that no doubt Mens rea is
not essential for civil liability of penalty but at-least some explanation worthy of
being accepted should be offered. The case law relied upon by the assessee it
was argued is not applicable. Attention was also invited to the findings recorded
by the Tribunal in assessee's own case in Quantum proceedings which it was
argued clearly demonstrates the web of transaction created to hoodwink the
department by creating bogus evidences to pass off unaccounted monies as
"gifts". Specific attention was invited to Para 5.1 pages 15 & 16 of the order
passed in the case of the assessee in the quantum proceedings so as to emphasizes
that on examining the bank account of the donor the Tribunal came to the
conclusion that there was a systematic attempt to launder money by way of gifts
in favour of a number of persons including the assessee. It was emphasized that
the Tribunal herein on examination had concluded that the evidences on record in
the form of bank account of the donor led to the inference that the same was
operated only with a view to furnishing accommodation entries. It was argued in
the face of these cateogric findings the argument that evidences has not been
disproved is of no relevance as the entire claim is bogus and no explanation has
been offered to address why penal action for such actions was not attracted.
Accordingly, it was his prayer that the impugned order should be confirmed.
7.    We have heard the rival submissions and perused the material available
on record. A perusal of the facts recorded in the case Manoj Kumar Singhal
                                        8                ITA Nos.6238, 6239/Del/12

(Individual) pertaining to the loan of 2 lacs stated to be received from Shri Sunil
Kumar Garg would show that the assessee vide its reply dated 08.12.2008
claimed that donor being a friend accommodated the assessee by providing a gift
of the said amount as the assessee was in need of money to purchase the land at
Udaipur and ultimately during the said assessment year 2003-04, the assessee
advanced Rs.7,50,000/- for purchase of land. These facts are found recorded in
para 3 of the assessment order. The record shows that the so called friend
despite the request of the Department was not produced and instead the assessee
requested the AO to issue summons to him.          The AO issued summons on
assessee's request which remained uncomplied with. In the circumstances the
CIT(A) and the Tribunal concluded in the quantum proceedings that neither the
creditworthiness nor the identity of the donor could be proved. The donor was
held to be a stranger to the assessee who was never produced to support the gift
having been made.
7.1.   Regarding the claim that the gift was received through banking channels
the evidence on examination has been held to be not sufficient to establish the
genuineness. The record shows that on considering the particulars of the bank
account 14154 from Jai Laxmi Co-operative Bank Ltd, Fatehpuri, Delhi from
which the gift was given it was disclosed that the amount had been transferred
from Account No. 3401 of the very same branch on the very same date. These
facts are recorded in Para 11 & 12 of the assessment order. It is further seen that
on examining the particulars of Account No. 3401. It was noticed that the
account was in the name of Usha Motor Company and from the said account two
cheques transferring the amount of 2 lacs and Rs.Rs. 4 lacs odd were transferred
in Account No. 14154 and 14125 in the names of Shri Sunil Kumar Garg and
Shri Om Prakash. The gifts of Rs. 4 lac was made from the said account by Sh.
Om Prakash to Shri Manoj Kumar Singhal HUF. The department has also
brought on record that in the bank account of Shri Sunil Kumar Garg there was a
                                                        9                        ITA Nos.6238, 6239/Del/12

total of Rs.44, 30,643/- credited in this account out of which Rs.17,81,250/- was
deposited in cash and the remaining was transferred from Account Nos. 3401,
3328, 3434 & 12446 maintained with the same bank and branch in the name of
Usha Motor Company, Winsome Port Folio (P) Ltd.; Diamond Graphics; and
Shri Santosh Kumar respectively. A perusal of the assessment order further
shows that out of the total deposit of Rs.44,30,643/- in the bank account of Shri
Sunil Kumar Garg, a sum of Rs.44,28,122 had been given away as gifts. On the
basis of these cumulous facts it was concluded that no amount has been given as
gift and in-fact Shri Sunil Kumar Garg and the other persons were engaged in the
business of providing accommodation entries on commission basis to various
persons, these facts are found recorded in Para 13 & 14 of the assessment order.
The record further shows that these facts have been confirmed by the ITAT in the
quantum proceedings passed in the case of both the assessees. A perusal of page
No. 15 para 5.1 would show that the Co-ordinate Bench considering the claim of
the assessee in regard of genuineness and the applicability of the principle laid
down by the Apex Court in CIT vs Orissa Co-operation Ltd. (1986) 159 ITR 78
(SC) distinguished the same on facts with that of the assessee. The relevant
portion of the said para is extracted hereunder :-

      5.1.   ".............................................................................................

             The facts of this case are distinguishable, in as much as the A.O had
             tried to ascertain the genuineness of the gift before reopening of the
             assessment as well as in the course of the assessment proceedings.
             Summons were issued to the donor at the instance of the assessee,
             which were not complied with. The assessee was also given an
             opportunity to produce the donor and the assessee expressed his
             inability to do so. The AO also examined the bank account of the
             donor, which fairly leads to a conclusion that there was a systemic
             attempt to launder money by way of gifts in favour of a number of
             persons including the assessee. Thus, it is not a case where the AO
             did not make any further enquiry. In the face of this enquiry and non-
             production of the donor, the contents of the memorandum of gift and
             affidavits can only be said to be self-serving and unsubstantiated
                                              10                  ITA Nos.6238, 6239/Del/12


7.2.   It is further see that the finding of the Assessing Officer that the bank
account of the donor was operated only with the view to furnish accommodation
entries has also been confirmed by the ITAT. For ready reference we reproduce
Para 5.2 from Page 19 of the order of the Co-ordinate Bench in quantum

       "5.2. On considering all these case, it is clear that all facts will have to be
             taken into account in coming to the conclusion whether the gift was
             genuine or not. The facts clearly show that the bank account of the
             donor was used for providing accommodation entries to a number of
             persons including the assessee. The assessee was not related to the
             donor. The averment made regarding friendship between them in the
             memorandum of gift and the affidavit remain unproved. In fact, the
             contents of the both these documents remained unproved in absence of
             the production of the donor. After all, the donor was the witness of the
             assessee and it was for him to produce him for examination of the ITO
             at the earliest opportunity. The donor was not found to be existing on
             the given address and the assessee has not been able to furnish the
             present address till date. Even before us, no statement was made that
             the donor could be produced now for the examination of the AO. All
             these facts and attendant circumstances clearly lead to the conclusion
             that the gift was not genuine. It is held accordingly. We may hasten to
             add that the assessee is not required to prove the source of the source,
             but the primary onus of proving the gift to the genuine by adducing
             satisfactory evidence about three primary conditions lies on him,
             which remains undischarged. As a matter of fact, the evidence by way
             of bank account of the donor, collected by the AO and confronted to
             the assessee, directly proves the gift to be non-genuine. In the light of
             this discussion, the case of the assessee does not stand on merits.
             Therefore, the addition of this amount to the total income of the
             assessee is upheld."
7.3.   In the above factual background, considering the explanation offered by
the assessee in the penalty proceedings it is seen that the same cannot be of much
help. The argument that evidence in the quantum proceedings has not been
disproved as such can be said to be proved is of no help in the face of the
categoric findings recorded in the orders which remain unassailed namely that the
donor was found to be operating by furnishing accommodation entries which
                                         11                ITA Nos.6238, 6239/Del/12

were resorted to as the assessee was in need of funds to purchase some land in
Udaipur. The case law relied upon is entirely distinguishable. Whether penal
action has rightly been invoked or not is a matter of fact. The principle of law
laid down in facts where the genuineness of the gift has been accepted is a
distinguishable fact which is not present in the facts of the present cases.
7.4.   Accordingly having through the penalty order and the explanation offered
therein which has been extracted in the earlier part of this order and also having
gone through the impugned order wherein the explanation offered remains more
or less the same after hearing the arguments of the parties before the Bench, we
find no good reason to interfere with the finding arrived at in the impugned order.
Being satisfied on account of the above-mentioned detailed reasons recorded
hereinabove the assessee's grounds are dismissed.
8.     In the result the ITA No-6238/Del/2012 is dismissed.
8.1.   Since the arguments on behalf of the parties in ITA No-6239/Del/2012 in
Manoj Kumar Singhal & Sons (HUF) remained the same barring the difference in
facts as herein alleged gift was of Rs.4 lac from the donor Sh. Om prakash who
too has received the amount from the Bank A/c of Usha Motor Company
maintained in the same branch wherein also accommodation entries by way of
gift etc. was found to be recorded of the entire amount received from the same
group of companies. The facts being decided against the assessee in quantum
proceedings. Accordingly since arguments remanded is same for similar reasons
as in ITA No-6238/Del/2012 the assessee's appeal herein also is dismissed.
9.     In the result, both the appeals of the assessee's are dismissed.
       The order is pronounced in the open court on 11th of March, 2014.
       Sd/-                                                               Sd/-
(B.C.MEENA)                                                      (DIVA SINGH)
ACCOUNTANT MEMBER                                           JUDICIAL MEMBER
Dated: 11/03/2014
*R. Naheed & Amit Kumar*
                     12     ITA Nos.6238, 6239/Del/12

Copy forwarded to:
1.   Appellant
2.   Respondent
3.   CIT
4.   CIT(Appeals)
5.   DR: ITAT
                          ASSISTANT REGISTRAR
                                ITAT NEW DELHI
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