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IN THE INCOME TAX APPELLATE TRIBUNAL "F" BENCH, MUMBAI
BEFORE S/SHRI B.R. BASKARAN, AM AND AMARJIT SINGH, JM
./I.T.A. Nos.711 to 715/Mum/2011
( / Assessment Years: 2004-05 to 2008-09)
Shri Uday C Tamhankar, / Dy.Commissioner of Income Tax
Vs. (OSD)-II, Central Circle-7,
C/8 Nand Dham Society,
L T Road, 4th floor, Ayakar Bhavan,
Borivali (W),
Mumbai-400092
M.K.Road,
Mumbai-400020
( /Appellant) .. ( / Respondent)
./I.T.A. Nos.857 to 862/Mum/2011
( / Assessment Year: 2002-03 to 2007-08)
Dy.Commissioner of Income / Shri Uday C Tamhankar, C/8 Nand
Tax (OSD)-II, Central Circle-7, Vs. Dham Society,
Ayakar Bhavan, L T Road,
Borivali (W),
M.K.Road, Mumbai-400092
Mumbai-400020
( /Appellant) .. ( / Respondent)
./I.T.A. Nos.3579 to 3582/Mum/2013
( / Assessment Years: 2005-06 to 2008-09)
Shri Uday C Tamhankar, C/8 / Dy.Commissioner of Income Tax
Vs. (OSD)-II, Central Circle-7,
Nand Dham Society,
L T Road, 4th floor, Ayakar Bhavan,
Borivali (W),
Mumbai-400092
M.K.Road,
Mumbai-400020
( /Appellant) .. ( / Respondent)
./I.T.A. No.3583/Mum/2013
( / Assessment Year: 2008-09)
Shri Uday C Tamhankar, C/8 / Dy.Commissioner of Income Tax
Vs. (OSD)-II, Central Circle-7,
Nand Dham Society,
L T Road, 4th floor, Ayakar Bhavan,
Borivali (W),
Mumbai-400092
M.K.Road,
Mumbai-400020
( /Appellant) .. ( / Respondent)
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and other 15 appeals
./ ./PAN. :AABPT1667K
/ Assessee by Shri Hariom Tulsyan
/Revenue by Shri G M Das
/ Date of Hearing : 26.8.2015
/Date of Pronouncement: 11.9.2015
/ O R D E R
Per Bench:
All these appeals and cross-appeals filed by the assessee and
Revenue for the assessment years mentioned in the cause title are
directed against the orders passed by Ld CIT(A)-40, Mumbai in quantum
proceedings as well as in penalty proceedings.
2. The assessee has filed appeals numbered as ITA 711 to 715 against
the orders passed by Ld CIT(A) in the quantum proceedings for the
assessment years 2004-05 to 2008-09. The revenue has filed appeals
numbered as ITA 857 to 862 for assessment years 2002-03to 2007-08
against the orders passed by Ld CIT(A) in the quantum proceedings. The
remaining appeals have been filed by the assessee against the orders
passed by Ld CIT(A) against the penalty orders passed by the AO u/s
271(1)(c) for assessment years 2005-06 to 2008-09 and u/s 271AAA for
the assessment year 2008-09. Since all these appeals arise out of
common set of facts, they were heard together and are being disposed of
by this common order, for the sake of convenience.
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and other 15 appeals
3. The facts relating to the case are set out in brief. The assessee is a
dentist and carries on his profession from different places and also through
different hospital names. He was subjected to search and seizure
operations on 17-01-2008. On the very same day, some of his concerns
were also surveyed u/s 133A of the Act. During the course of search
operations, cash balance of Rs.1,13,57,110/- was found as against the
book balance of Rs.9,10,548/-. In the statement recorded from him u/s
132(4) of the Act, he admitted the excess cash balance of
Rs.1,04,68,512/- as his unaccounted income. The assessee agreed to
offer a sum of Rs.1,25,00,000/- (including excess cash balance) as his
income for the years stated below:-
Assessment year Amount
2005-06 5,00,000
2006-07 5,00,000
2007-08 10,00,000
2008-09 1,05,00,000
Accordingly, the assessee filed returns of income for the above said years
offering additional income as stated above.
4. The assessing officer, however, completed the assessments by
making following types of additions:-
(a) disallowances out of expenses claimed by the assessee.
(b) additions u/s 69C of the Act in respect of certain expenses
and assets found.
(c) estimation of professional income and addition of
difference amount.
5. The Ld CIT(A) confirmed the additions relating to disallowance of
expenses and also the additions made u/s 69C of the Act. He, however,
deleted the additions relating to estimated professional income. Hence
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and other 15 appeals
both the parties have filed these appeals challenging the orders of Ld
CIT(A) on the points decided against each of them.
6. We shall first take up the appeals filed by the assessee. In all these
years, the assessee is contesting the disallowances made out of expenses
claimed by the assessee.
7. The first item relates to the disallowance made out of expenses as
detailed below:-
Assessment year Car expenses Telephone
2004-05 20,000 17,662
2005-06 52,346 20,000
2006-07 40,010 10,000
2007-08 46,527 10,000
2008-09 25,010 10,000
The disallowances made by the AO was also confirmed by Ld CIT(A). The
Ld A.R submitted that the car expenses disallowed by the assessing officer
include proportionate amount of depreciation and interest on car loan.
The L.R submitted that both the items are statutory deductions prescribed
under the Act and hence the disallowance of the same was not justified. In
this regard, he placed reliance on the decision rendered by the co-ordinate
bench of Mumbai Tribunal in the case of Mukesh K Shah (2005)(92 ITD
349). The Ld A.R further submitted that the assessee has offered
additional income of about Rs.20.00 lakhs in order to cover up any other
deficiencies. He submitted that the assessee has not capitalized the above
said disclosure in his books of account. Accordingly he submitted that all
the disallowances are to be telescoped against the additional disclosures.
8. The Ld A.R further submitted that the assessments of the assessment
years up to AY 2006-07 were not pending as on the date of initiation of
search and hence the AO was not justified in making the additions in those
years without there being any incriminating materials. In this regard, he
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and other 15 appeals
placed reliance on the decision rendered by the special bench of Tribunal
in the case of All Cargo Global logistics Ltd (137 ITD 287) which has
since been upheld by the Hon'ble jurisdictional Bombay High Court.
9. The Ld D.R, on the contrary, submitted that the assessee has
admitted additional income for various years in the statement recorded
from him u/s 132(4) of the Act. Accordingly he submitted that there were
incriminating materials available with the AO and hence the impugned
additions were made by him.
10. We heard the parties on this issue and perused the record.
Admittedly, these are estimated disallowances made out of expenses that
were already claimed in the original return of income filed by the assessee.
The assessee has submitted that the assessment years up to 2006-07 fall
in the category of concluded assessments, i.e., assessments of those years
were not pending on the date of initiation of search. Hence, in our view,
the assessing officer could not have made these additions for AY 2004-05
to 2006-07 in the absence of any incriminating materials. Alternative
contentions of the assessee also merits acceptance, i.e., the assessee has
made additional disclosure of about 20.00 lakhs, which is more than
enough to cover the above said disallowances. We accept the alternative
contentions of the assessee and hence the additions made by the AO,
after accepting the additional disclosure of Rs.20.00 lakhs, would result in
double assessment, since it is stated that the assessee has not capitalised
the above said amount in his books of account. Accordingly, we set aside
the orders of Ld CIT(A) in respect of the above said issues in all the years
cited above and direct the AO to delete the disallowances, referred above.
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and other 15 appeals
11. The next item of addition relates to the additions made u/s 69C of
the Act in various years as tabulated below:
A.Y Addition u/s 69C
2004-05 Talwalkar Rs.24,030 Rs.24,030
2005-06 i) Refrigerator Rs.14,070
ii)Jewellery Rs.5,718 Rs.19,788*
2006-07 i)Talwalkar Rs.43,000
ii)Jewellery Rs.20,059 Rs.63,059
2007-08 i)Talwalkar Rs.35,000
ii)Mobile Rs.16,000
iii)TV Rs.71,000
iv)Jewellery Rs.26,380 Rs.1,48,380
2008-09 i)Talwalkar Rs.25,000
ii)Jewellery Rs.1,69,187 Rs.1,94,187
Total Rs.4,49,444
(Addition made is Rs.22,808/-)
12. We heard the parties on this issue and perused the record. The
main contention of the Ld A.R is that the assessee and his wife have
drawn sufficient money for personal purposes and they are sufficient to
cover up the expenses cited above. Alternatively, the Ld A.R also
submitted that the additional disclosure of Rs.20.00 lakhs is sufficient to
cover these expenses. On the contrary, the Ld D.R placed strong reliance
on the orders passed by Ld CIT(A).
13. We have already noticed that the assessee has offered additional
income of about Rs.20.00 lakhs over and above the excess cash balance
found during the course of search. It is also an admitted fact that the
revenue did not seize any other incriminating material which compelled the
assessee to make this disclosure. Hence the additional income of about
Rs.20.00 lakhs was a voluntary offer. We notice that the disallowances of
expenses as well as the addition made u/s 69C of the Act formed a small
part of the above said amount of Rs.20.00 lakhs, thus leaving huge
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balance remaining to be adjusted. Hence, we are of the view that, even if
it is assumed that the additions made u/s 69C is required to be sustained,
the same should be telescoped against the above said amount of Rs.20.00
lakhs. This is for the reason that the addition towards source and also
investments made out of said source cannot be made and if made, the
same would result in double assessment of same item of income. Further,
since it is stated that the assessee has not capitalized the above said
amount of Rs.20.00 lakhs, in our view, the telescoping benefit should be
given. Hence the net result would be that there is no necessity to make
any addition u/s 69C of the Act. Even otherwise, we notice that the
assessing officer has made the additions u/s 69C of the Act without
examining the claim of availability of sources out of drawings made by the
assessee and his wife. Accordingly, we set aside the order of Ld CIT(A) on
this issue in all the assessment years referred above and direct the AO to
delete the impugned additions.
14. We shall now take up the appeals filed by the revenue. As stated
earlier, the assessing officer proceeded to estimate the professional
income of the assessee for assessment years 2002-03 to 2007-08. The
reasoning given by the AO is explained in brief. The excess cash found at
the time of search was declared by the assessee as his income for the AY
2008-09. Accordingly, the assessee included the same in the professional
receipts. Accordingly the professional receipts for AY 2008-09 was shown
at Rs.328.70 lakhs. The AO took the total number of working days for that
year as 300 and accordingly worked out the average collection per day as
Rs.1,09,000/-. Then the AO presumed that the assessee would have
earned professional collections in the same pattern in the earlier years
also. Accordingly, he estimated the average daily collection at
Rs.1,00,000/-, Rs.90,000/-, Rs.80,000/-, Rs.70,000/-, Rs.60,000/- and
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and other 15 appeals
Rs.50,000/- respectively for assessment years 2007-08, 2006-07, 2005-06,
2004-05, 2003-04 and 2002-03. Accordingly the assessing officer worked
out the gross receipts. Then the AO worked out the difference between
the gross receipts declared by the assessee and that was worked out by
him. Thereafter he applied the net profit rate declared by the assessee on
the difference and accordingly worked out the additions. The said
workings are tabulated below by the AO as under:-
S.No. A.Y./Receipt Gross Gross Difference Net Proposed
per day receipts as receipts profit% additions on
per as per as per difference per
estimation return IT return net profit %
1 2007-08 300.00 165.41 134.59 29.00% 39.03
Rs.1,00,000
per day
2 2006-07 270.00 167.71 102.29 34.17% 34.95
Rs.90,000
per day
3 2005-06 240.00 147.99 92.01 29.24% 26.90
Rs.80,000
per day
4 2004-05 210.00 131.59 78.41 31.57% 24.77
Rs.70,000
per day
5 2003-04 180.00 108.40 71.60 39.12% 28.00
Rs.60,000
per day
6 2002-03 150.00 103.12 46.88 37.00% 17.34
Rs.50,000
per day
The assessing officer made the additions in the respective years as per the
workings given above. The Ld CIT(A) deleted the additions in all the years
mainly on the reasoning that there is no material to support the inference
drawn by the assessing officer. Hence the revenue has filed these appeals
before us.
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and other 15 appeals
15. We heard the parties on this issue and perused the record. For the
sake of convenience, we extract below the observations made by the ld.
CIT(A) in paragraph 6.5.4 and 6.5.5 of the order passed for AY 2004-05:-
"6.5.4 In my considered opinion, whether estimate can be
made in search assessment or not depends on the facts of the case
and how a subject matter of estimate is linked to any paper seized.
I found that there is no material in the possession of the AO
on the basis of which the AO has worked out extra receipts
and extra profits. Whatever books of account and loose sheets
were found during the course of search are in the possession of the
department, the only addition that could be sustained was in respect
of unexplained cash found during the course of search at
Rs.1,13,57,110/-(sic). The appellant has already offered
Rs.1,25,00,000/- for tax as additional income. As per provision of
section 69A, the cash found and not recorded in books of accounts
for which no reasonable explanation is available is to be deemed to
be the income of the financial year. This cash cannot be taken
as a piece of evidence for estimation of income of the earlier
year, in the absence of any documentary evidence. The AO
has not given any findings in the assessment order that the receipts
recorded on the loose papers found during the course of search
were not recorded in the books of account. The finding is about
certain expenses which were recorded on the loose papers and were
not found to be recorded in the books of accounts.
6.5.5 On the basis of the facts narrated above, it is apparent that
the ld. AO does not have, in his possession, any material evidence to
suggest that cash income of similar nature was earned during the
years prior to the year of search, and in any given proportion.
Under the circumstances, the presumption has always to be made
that the unaccounted income relates to the assessment year
pertaining to the date of search. The appellant's explanation has to
be believed unless a finding to the contrary can be deducted from
the seized material or pursuant enquiries.
6.5.6 Under the circumstances, it is held that in view of the fact
of the cash seizure of Rs.1,13,57,110/-, the appellant's offer of
additional income in different AYs under, has to be believed, unless
material to suggest the contrary exists.
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and other 15 appeals
A.Y Additional income offered
2008-09 Rs.1,05,00,000
2007-08 Rs.10,00,000
2006-07 5,00,000
2005-06 Rs.5,00,000
2002-03 to NIL
2004-05
Total Rs.1,25,00,000
Evidence of unaccounted income found in one year, cannot be
presumed to exist in other years and estimated of unaccounted
income based on such presumption cannot be approved. "
16. During the course of hearing, the Ld D.R strongly supported the
estimation made by the AO. There is no dispute with regard to the fact
that the revenue did not unearth any incriminating material, which could
suggest that there was under billing or evasion of professional receipts.
The revenue only stumbled with excess cash balance and the same was
surrendered as income of the year in which the search took place. The
assessee offered the same as his professional income. As observed by Ld
CIT(A), the unexplained cash is required to be assessed in the year in
which it was found as per the deeming fiction of provisions of sec. 69A of
the Act, which does not mean that the assessee would have earned the
entire excess cash balance in one year. Hence, in our view also, the
assessing officer misguided himself by presuming that the entire
undisclosed cash balance represents his professional fee collected during
the financial year relevant to the assessment year 2008-09. Hence, in our
view, the Ld CIT(A) has rightly concluded that the assessing officer did not
bring any material on record to support his case of estimation of
professional receipts of earlier years. We also notice that the assessing
offer has assessed the net profit on the alleged suppressed professional
receipts, meaning thereby, the assessing officer has presumed that the
assessee would have suppressed corresponding expenses also. Again it is
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and other 15 appeals
only a guess work only, unsupported by any material. Similarly, the
average daily collection estimated by the AO was also mere guess work. In
effect, there is no material available with the AO to show that the assessee
has suppressed professional receipts as well as expenses in order to
substantiate the estimation made by him. During the course of hearing,
the Ld D.R placed reliance on the decision rendered by Hon'ble Punjab &
Haryana High Court in the case of Ved Prakash Vs. CIT (265 ITR 642) to
support the estimation made by the assessing officer. However, we notice
that the Hon'ble Punjab & Haryana High Court has considered a case,
wherein materials were found during the course of search. However, in
the instant case, no material relating to suppression of professional fee
receipts was found. Accordingly, we are of the view that the ld CIT(A)
was justified in deleting the additions in all the years.
17. Now we shall stake up the penalty appeals filed by the assessee for
assessment years 2005-06 to 2008-09 against the penalty levied u/s
271(1)(c) of the Act. The assessing officer levied penalty u/s 271(1)(c) of
the Act on the following items:-
(a) Additions made u/s 69C of the Act in AY 2005-06 to 2008-09.
(b) Additional income disclosed by the assessee in AY 2005-06 to
2007-08.
In the preceding paragraphs, we have deleted the additions made u/s 69C
of the Act and hence the penalty levied on those additions is liable to be
deleted, since the said additions themselves does not survive.
18. With regard to the penalty levied on the additional income
surrendered by the assessee, the Ld A.R submitted that the assessee has
offered excess amount of about Rs.20.00 lakhs voluntarily and the revenue
did not seize any material to support the said disclosure. He submitted
that the revenue has seized excess cash balance of Rs.1.04 crores and the
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and other 15 appeals
said amount was offered as assessee's income in AY 2008-09. The Ld A.R
submitted that the voluntary surrender should not be construed as
concealment of income, in the absence of any incriminating material. The
Ld A.R also submitted that the assessee has offered the same in the
returns of income filed u/s 153A of the Act and they were also accepted by
the AO. Accordingly he submitted that there is no difference between the
returned income and assessed income in sec. 153A proceedings and hence
there is no presumption of concealment of income. The Ld A.R submitted
that the assessing officer was not justified in law in comparing the income
assessed u/s 153A of the Act with the return filed u/s 139 of the Act. In
support of this proposition, he placed reliance on the decision rendered by
the Delhi bench of Tribunal in the case of Prem Arora Vs. DCIT (2012)(78
DTR(Del)(Trib) 91).
19. The Ld D.R, on the contrary, submitted that the assessee has
undisclosed income, which is within his personal knowledge, by way of
additional disclosure. He submitted that the assessee would not have
disclosed additional income, had there been no search. Accordingly, the
Ld D.R contended that the additional disclosure made by the assessee is
liable for penalty u/s 271(1)(c) of the Act. The Ld D.R placed reliance on
the decision rendered by Delhi bench of Tribunal in the case of JRD Stock
Brokers (P) Ltd Vs. ACIT (2009)(124 TTJ 566).
20. We heard rival contentions and perused the record. We notice that
the decision in the case of JRD Stock brokers (P) Ltd (supra) has been
rendered in the context of penalty levied u/s 158BFA of the Act. Further,
we notice that the assessee therein did not disclose additional income in
the return of income filed by it u/s 158BC of the Act. Further it is stated
that the undisclosed income was discernible from the seized materials.
Where as in the instant case, the penalty has been levied u/s 271(1)(c) of
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and other 15 appeals
the Act, the assessee has disclosed additional income in the return of
income filed by him and further there was no seized material to support
the additional disclosure made by the assessee. Hence, we are of the view
that the decision rendered in the case of JRD Stock Brokers (P) Ltd (supra)
is not applicable to the instant case.
21. If we analyze the facts behind the additional disclosure of about
Rs.20.00 lakhs made by the assessee, we notice that he has voluntarily
offered the same and no material was seized during the course of search
warranting the additional disclosure. The assessee has duly disclosed the
income voluntarily offered by him in the returns of income filed in
response to the notices issued u/s 153A of the Act. During the course of
penalty proceedings also, the assessee has offered the explanation to that
effect and the said explanation was not found to be false. During the
course of search proceedings, the revenue has noticed/seized all the
materials available with the assessee and no incriminating material
supporting the additional disclosure was found. Under these set of facts,
we are of the view the tax authorities are not justified in presuming that
the additional disclosure voluntarily made by the assessee shall constitute
concealed income warranting penalty u/s 271(1)(c) of the Act.
22. In view of the foregoing discussions, we set aside the order of Ld
CIT(A) in all the impugned years and direct the assessing officer to delete
the penalty levied u/s 271(1)(c) of the Act in all the years under
consideration.
23. We shall now take up the appeal filed by the assessee for
assessment year 2008-09 against the penalty levied u/s 271AAA of the
Act. As noticed earlier, the assessee had offered the excess cash balance
of Rs.1.05 crores as his income for AY 2008-09 out of the cash of Rs.1.13
crores found during the course of search. Hence the assessing officer
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and other 15 appeals
levied penalty u/s 271AAA of the Act at 10% of the additional offer of
Rs.1.05 crores made in the statement taken u/s 132(4) of the Act. Before
the Ld CIT(A), the assessee claimed immunity from penalty by contending
that he has complied with the conditions prescribed in sec. 271AAA(2) of
the Act. However, the Ld CIT(A) took the view that the assessee has not
disclosed the manner in which the undisclosed income was earned and
accordingly the Ld CIT(A) confirmed the penalty.
24. We heard the parties and perused the record. The assessee is
seeking immunity from penalty levied u/s 271AAA(1) of the Act on the
reasoning that he has complied with the provisions of sec. 271AAA(2) of
the Act. As per the provisions of sec. 271AAA(2), penalty u/s 271AAA(1)
of the Act is not leviable if the assessee:-
(a) in the course of search, in a statement under sub-section (4) of
section 132, admits the undisclosed income and specifies the
manner in which such income was derived;
(b) substantiates the manner in which the undisclosed income was
derived; and
(c) pays the tax, together with interest, if any, in respect of the
undisclosed income.
25. There is no dispute with regard to the fact that the assessee has
complied with conditions that the assessee has disclosed the income in the
statement taken u/s 132(4) of the Act and the assessee has paid the tax
together with interest, if any, in respect of the undisclosed income. The
Ld CIT(A) has taken the view that the assessee has not
disclosed/substantiated the manner in which undisclosed income was
derived. The Ld A.R submitted that the assessee has disclosed the
undisclosed income in the return of income as his professional income and
hence the disclosure so made satisfied the condition of "manner in which
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the undisclosed income was derived". In this regard, he placed reliance on
the decision rendered by the Cuttack bench of Tribunal in the case of
Ashok Kumar Sharma Vs. DCIT (2012)(149 TTJ (Ctk)(UO) 33), wherein it
was held as under:-
"Undisputedly the assessees have shown the undisclosed income
under the head "income from business" in the returns filed by them
and that was accepted by the Department by passing the
assessment orders accordingly. Therefore, the cases of the
assessees fall exactly within the purview of sub-s (2) of s. 271AAA.
Therefore the provisions contained in sub.s (1) of s. 271AAA are not
applicable..."
26. On the contrary, the Ld D.R contended that the assessee did not
specify the manner in which the undisclosed income was derived.
27. We have heard rival contentions on this issue. There is no dispute
with regard to the fact that the assessee has disclosed the undisclosed
income as his professional income and the same has been accepted by the
assessing officer. In fact, the assessing officer has proceeded to estimate
the professional income of the preceding years on the basis of the above
said disclosure. Hence, we are of the view that the decision rendered by
the Cuttack bench in the above said case squarely applies to the facts
prevailing in the instant case. We also notice that the Nagpur bench of
Tribunal has also taken identical view in the case of Concrete Developers
V/s ACIT in ITA No.381/Nag/2012 dated 20.3.2013.
28. Consistent with the view taken by the co-ordinate benches in the
above cited cases, we also hold that the assessee has complied with all the
three conditions specified in sec. 271AAA(2) of the Act and accordingly,
the penalty levied by the AO u/s 271AAA(1) of the Act is liable to be
deleted. Accordingly, we set aside the order of Ld CIT(A) and direct the
AO to delete the penalty levied u/s 271AAA of the Act for AY 2008-09.
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and other 15 appeals
29. In the result, all the appeals filed by the assessee are allowed and
all the appeals filed by the revenue are dismissed.
Pronounced accordingly on 11th Sept, 2015.
11th Sept, 2015
Sd sd
(AMARJIT SINGH) ( B.R. BASKARAN)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Mumbai: 11th
Sept, 2015.
.../ SRL , Sr. PS
/Copy of the Order forwarded to :
1. / The Appellant
2. / The Respondent.
3. () / The CIT(A)- concerned
4. / CIT concerned
5. , , /
DR, ITAT, Mumbai concerned
6. / Guard file.
/ BY ORDER,
True copy
(Asstt. Registrar)
, /ITAT, Mumbai
|
