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The Gita Education Society, C/o Kapil Goel Adv F-26/124 Sector 7 Rohini, Delhi-110085 vs. Income Tax Officer, Exemption Ward, Ghaziabad
May, 22nd 2019
                                    1                                  ITA No. /Del/2018



            IN THE INCOME TAX APPELLATE TRIBUNAL
                 DELHI BENCH: `G' NEW DELHI

       BEFORE HON'BLE SHRI G. D. AGRAWAL, PRESIDENT
                             AND
       HON'BLE SMT. SUCHITRA KAMBLE, JUDICIAL MEMBER

                 ITA No. 7441/DEL/2018 (A.Y 2010-11)

    The Gita Education Vs                Income Tax Officer, Exemption
    Society, C/o Kapil Goel              Ward, Ghaziabad
    Adv F-26/124 Sector 7
    Rohini, Delhi-110085
    PAN-AAAAT9753G
    (APPELLANT)                          (RESPONDENT)


                Appellant by         Sh. Kapil Goel, CA
                Respondent by        Sh. S.S. Rana, CIT DR

                  Date of Hearing                 07.05.2019
                  Date of Pronouncement           22.05.2019

                                        ORDER

PER G.D. AGRAWAL, V.P.

     This is an appeal filed by the assessee against the order dated
28.09.2018 passed by the CIT(A, Ghaziabad.

     In this appeal filed by the assessee, Ground No. 1 reads as under:-

       i. That order passed by Ld AO dated 13/11/2017 and further order passed by Id CIT
       (A) dated 28/09/2018 are bad in law in as much as impugned assessment is
       made in violation of jurisdictional conditions stipulated under the Act, ergo,
       orders of Ld AO and Ld CIT-A may please be quashed.
          a. That order passed by Ld AO dated 13/11/2017 and further order passed
          by Id CIT A dated 28/09/2018 are bad in law as reasons recorded are
          based on borrowed satisfaction and without independent application of
          mind as no where it is established that assessee is real beneficiary of
          stated amount of Rs 50,00,000 which is solely based on suspicion only
          and reasons recorded lack live nexus which is sine qua non for valid
          reopening action;
                                      2                                 ITA No. /Del/2018


             b. That order passed by Ld AO dated 13/11/2017 and further order passed
             by Id CIT A dated 28/09/2018 are bad in law as reasons recorded in
             extant case are delightfully silent on lack of disclosure on stated bank a/c
             in earlier assessment proceedings (order u/s 143(3) dated 27.02.2013)
             vide first proviso in section 147 of the Act and same is the position in
             notice u/s 148 dated 28.03.2017 for AY 2010-2011 and objection disposal
             dated 29.09.2017.
             c. That order passed by Ld AO dated 13/11/2017 and further order passed
             by Id C1T A dated 28/09/2018 are bad in law as reasons recorded as
             supplied are sans approval if any taken from competent authority.
             d. That order passed by Ld AO dated 13/11/2017 and further order passed
             by Id CIT A dated 28/09/2018 are bad in law as reasons recorded stated
             Rs 50,00,000 is unexplained amount simply where as Ld AO changing
             basis of reopening in order passed states that assessee has utilized
             undisclosed funds being cash for clearing of cheque in the bank a/c and
             Ld CIT-A further changes it to held that assessee could not substantiate
             the genuineness of transaction of Rs 50,00,000 being amount reed from
             SOWHAP which amorphous and fleeting allegation breaks the entire belief
             formed in reasons recorded.


2.    At the time of hearing before us, it is stated by the assessee's
counsel that the assessee is a society which has been granted
registration under section 12AA of the Income Tax Act. For the year
under consideration, the assessment was originally completed under
section 143(3) vide order dated 27.2.2013 on nil income. The assessment
was reopened vide notice under section 148 dated 28th March, 2017.
Thus, admittedly the assessment was reopened beyond the period of four
years when the original assessment was completed under section 143(3).
Therefore, the proviso to section 147 is clearly applicable. That no finding
is recorded by the Assessing Officer in the reasons recorded that the
alleged escapement of income is on account of any failure on the part of
the assessee to disclose any material fact and therefore, the reopening is
not valid.

3.    He further stated that in the reasons recorded it is alleged by the
Assessing Officer that as per the information received from the CIT(E)
Kolkata it was gathered by the Department that there was a society
                                         3                                ITA No. /Del/2018


named as M/s Society for Welfare of Handicapped Persons, which was
approved under section 35 (i)(ii) of the Income Tax Act and it is used to
transfer the bogus donation to the society / trust in lieu of cash. The
Assessing Officer alleged that the assessee had received the donation of
Rs. 50,00,000/- on 17th March, 2010 by cheque for which the assessee
made the payment in cash which was the undisclosed income of the
assessee.

4.      However, in the reasons recorded, the Assessing Officer himself has
recorded that the assessee furnished the list of donation during the
assessment proceedings but no name of the donor M/s Society for
Welfare of Handicapped Person is mentioned. Thus as per the books of
the assessee, no donation is received from the so called society.
Moreover, the Assessing Officer himself has mentioned in the reasons
recorded that the assessee received the sum of Rs. 50,00,000/- on 17th
March, 2010 and paid Rs. 50,00,000/- on 19th March, 2010. He stated
that by some mistake the cheque of Rs. 50,00,000/- was issued and
credited in the name of assessee when this fact came to the knowledge of
the assessee it returned the same immediately and therefore, there is no
credit of any donation in the accounts of the assessee.

5.      The learned DR on the other hand fiiled the written submissions
which is reproduced below:-

           "In the above case, it is humbly submitted that the following decisions may
        kindly be considered with regard to reopening of cases beyond 4 years u/s 147 of
        I.T.Act:

     1. PCIT Vs Paramount Communication (P.) Ltd.(2017-TIOL-253-SC-IT)(Copy
        enclosed)
        where Hon'ble Supreme Court dismissed SLP of assessee. Information
        regarding bogus purchase by assessee received by DRI from CCE which was
        passed on to revenue authorities was 'tangible material outside record' to initiate
        valid reassessment proceedings.
                                   4                                ITA No. /Del/2018


   PCIT Vs Paramount Communication (P.) Ltd.[2017] 79 taxmann.com 409
   (Delhi)/[2017] 392 ITR 444 (Delhi)
   where Hon'ble Delhi High Court held that Information regarding bogus purchase
   by assessee received by DRI from CCE which was passed on to revenue
   authorities was 'tangible material outside record' to initiate valid reassessment
   proceedings

2. Aradhna Estate (P.) Ltd.Vs DCIT [2018] 91 taxmann.com 119 (Gujarat) (copy
   enclosed)
   where Hon'ble Gujarat High Court held that where reassessment proceedings
   were initiated on basis of information received from Investigation wing that
   assessee had received certain amount from shell companies working as an
   accommodation entry provider, merely because these transactions were
   scrutinised by Assessing Officer during original assessment, reassessment could
   not be held unjustified







3. Pushpak Bullion (P.) Ltd. Vs DCIT[2017] 85 taxmann.com 84 (Gujarat)(copy
   enclosed)
   where Hon'ble Gujarat High Court held that where investigation wing of
   department had during course of investigation in case of a third party found that
   he was indulged in providing accommodation entries and bogus bills, and
   assessee had made sizeable purchases from him, reopening notice against
   assessee was justified
4. Ankit Financial Services Ltd. Vs DCIT[2017] 78 taxmann.com 58 (Gujarat)
   (Copy enclosed)
   where Hon'ble Gujarat High Court held that where material recovered in search
   of another person indicated that assessee had received bogus share applications
   through accommodation entries, since assessee was beneficiary, initiation of re-
   opening was justified.

5. Aaspas Multimedia Ltd. Vs DCIT[2017] 83 taxmann.com 82 (Gujarat)(Copy
   enclosed)
   where Hon'ble Gujarat High Court held that where reassessment was made on
   basis of information received from Principal DIT (Investigation) that assessee
   was beneficiary of accommodation entries by way of share application provided
   by a third party, same was justified.

6. Ankit Agrochem (P.) Ltd. Vs JCIT[2018] 89 taxmann.com 45
   (Rajasthan)(Copy enclosed)
   where Hon'ble Rajasthan High Court held that where DIT informed that
   assessee-company had received share application money from several entities
   which were only engaged in business of providing bogus accommodation entries
   to beneficiary concerns, reassessment on basis of said information was justified.

7. Mona Mahesh Bhojani Vs ITO (2017-TIOL-345-SC-IT)(copy enclosed)
   SLP dismissed against appeal challenging the judgment, whereby the High Court
   had held that reopening initiated in case of an assessee who had not filed his
   return, could not be claimed by the assessee to be based on 'change of opinion'.
                                   5                                 ITA No. /Del/2018


   The Assessee had also challenged the action of High Court in holding that when
   the AO had tangible material at his command to form a bonafide belief that
   income chargeable to tax had escaped assessment, the writ court would not
   interfere with the formation of such belief unless it is shown to be wholly
   perverse.


8. Indu Lata Rangwala Vs DCIT [2017]80taxmann.com102(Delhi)/[2016] 384
   ITR 337 (Delhi)/[2016] 286 CTR 474 (Delhi) (copy enclosed)
   where Hon'ble Delhi High Court held that where initial return of income is
   processed under section 143(1), it is not necessary in such a case for Assessing
   Officer to come across some fresh tangible material to form 'reasons to believe'
   that income has escaped assessment

9. Honda Siel Power Products Ltd. v. Dy. CIT [2012] 20 taxmann.com 5
   (SC)/[2012] 206 Taxman 33 (SC)(MAG.)/[2012] 340 ITR 64 (SC)/[2012] 247
   CTR 316 (SC) (Copy enclosed)
   where Hon'ble Supreme Court held that assessee having not pointed out during
   assessment proceedings about expenses incurred relatable to tax free income
   u/s 14A there was omission and failure on its part to disclose fully and truly
   material facts and hence reopening of assessment was justified

10. Honda Siel Power Products Ltd. v. Dy. CIT [2011] 10 taxmann.com 2
    (Delhi)/[2011] 197 Taxman 415 (Delhi)/[2012] 340 ITR 53 (Delhi)/[2012] 247
    CTR 322 (Delhi) (Copy enclosed)
    where Hon'ble Delhi High Court held that assessee having not pointed out during
    assessment proceedings about expenses incurred relatable to tax free income
    u/s 14A there was omission and failure on its part to disclose fully and truly
    material facts and hence reopening of assessment was justified

11. New Delhi Television Ltd. Vs DCIT[2017] 84 taxmann.com 136 (Delhi) (Copy
    enclosed)
    where Hon'ble Delhi High Court held that proceedings under section 147, beyond
    a period of 4 years can only be initiated if the Assessing Officer has reason to
    believe that there has been escapement of income and this escapement is owing
    to the lack of true and fair disclosure by the assessee. In this regard, it is
    essential to understand the meaning of the phrase 'true and fair disclosure'. The
    Court has considered the meaning of this phrase in Honda Siel Power Products
    Ltd. v. Dy. CIT [2012] 340 ITR 53/[2011] 197 Taxman 415/10 taxmann.com 2
    (Delhi) where the Court held that that the term 'failure' on the part of the
    assessee is not restricted to the return and the columns of the return or the tax
    audit report. There can be omission and failure on the part of the assessee to
    disclose material facts fairly and truly during the course of the assessment
    proceedings. [Para 42]


12. Sun Direct TV Pvt. Ltd. Vs ACIT [2018] 98 taxmann.com 201 (Madras) (Copy
    enclosed)
                                   6                                 ITA No. /Del/2018


   where Hon'ble Madras High Court held that completed assessment could be
   reopened within period of six years where there were some information with
   department that share premium invested by foreign company was income of
   assessee-company which had not been disclosed

13. A Sridevi Vs ITO (2018-TIOL-2246-HC-MAD-IT)(Copy enclosed)
    where Hon'ble Madras High Court held that any fresh information filed before the
    AO during the process of re-assessment u/s 147, which gives force to the belief
    of the AO that certain income of the assessee had escaped assessment, can be
    construed as tangible material for reopening the assessment once again. Since
    alleged escapement of income exceeds One lakh rupees, reopening in such
    case can be done within the period of six years from the end of relevant AY as
    prescribed by section 149(1)(b), and thus, the same cannot be said to be barred
    by limitation

14. South Asia FM Ltd. Vs ACIT [2018] 98 taxmann.com 200 (Madras) (Copy
    enclosed)
    where Hon'ble Madras High Court held that Reopening of assessment on basis
    of information on record with revenue that assessee had received share capital
    which according to CBI were revenue receipts camouflaged as capital receipts,
    was justified. Reasons to be recorded by Assessing Officer for taking decision to
    reopen escaped assessment does not mean that such reasons are to be
    communicated along with notice itself; very notice will not provide a cause of
    action for assessee to file writ petitions.

15. CIT Vs P.V.S. Beedies (P.) Ltd.[1999] 103 Taxman 294 (SC)/[1999] 237 ITR 13
    (SC)/[1999] 155 CTR 538 (SC) (Copy enclosed)
    where Hon'ble Supreme Court held that Audit party had merely pointed out a fact
    which had been overlooked by Assessing Officer and this was not a case of
    information on a question of law. Reopening of case under section 147(b) on
    basis of factual information given by internal audit party was valid in law

16. PranawaLeafin (P.) Ltd. Vs DCIT [2013] 33 taxmann.com 454
    (Bombay)/[2013] 215 Taxman 109 (Bombay)(MAG.)(Copy enclosed)
    where Hon'ble Bombay High Court held that where there was failure on part of
    assessee to make true and complete disclosure in respect of share transactions
    entered into by it, in view of proviso to section 147, Assessing Officer was
    justified in initiating reassessment proceedings even after expiry of four years
    from end of relevant assessment year

17. CIT Vs KiranbhaiJamnadasSheth (HUF)[2013] 39 taxmann.com 116
    (Gujarat)/[2014] 221 Taxman 19 (Gujarat)(MAG.) (Copy enclosed)
    where Hon'ble Gujarat High Court held that Assessment without scrutiny would
    mandate reassessment beyond 4 years even if assessee made true disclosure

18. Dishman Pharmaceuticals & Chemicals Ltd. Vs CIT[2012] 346 ITR 228 (Guj)
    (Copy enclosed)
    The assessee had shown an amount as loan from company. The assessee had
    not disclosed that it had substantial interest in the company. Reassessment
                                     7                                 ITA No. /Del/2018


     proceedings after four years to assess amount as deemed dividend was held to
     be valid.

                                                               Sd/-
                                                            (S S Rana)
                                                   Commissioner of Income Tax(DR)
                                                     G-Bench, ITAT, New Delhi.


6.   The learned counsel for the assessee on the other hand stated that
on the peculiar facts of the case, none of the above decision would be
applicable, on the other hand the decision of Hon'ble Jurisdictional High
Court in the case of Unitech Limited vide W.P. (C) 12324/2015 would
be squarely applicable wherein their Lordships have clearly mentioned
that for complying with the Jurisdictional requirement under the first
proviso to section 147 of the Act, the reasons would have to show in what
manner the assessee had failed to make a full and true disclosure of all
the material facts necessary for assessment.

7.   We have carefully considered the argument of both the sides and
perused the material placed before us. The copy of the reasons recorded
for reopening of the assessment is produced before us, which reads as
under:-

     Sub: Communication of Reasons for issue of notice U/s 148 of I.T. Act.- Reg:
           Please refer to your letter dated 25.04.2017 requesting reasons. As
     requested the reasons are communicated to you, as under:-
            In this case , an information is received from the Commissioner of Income
     Tax (Exemption), Kolkata vide letter dated 08.08.2016 that a large number of
     societies/trust, situated all over India have received huge donation from a Society
     named M/s Society for Welfare of Handicapped Persons located at 27, Tagore
     Avenue, Durgapur. This society has approval of section 35(l)(ii) of the income
     Tax Act. It transpires that one chartered Accountant based in Kolkata by
     fraudulent means opened a bank account in the name of this society in Axis
     Bank Limited. Prince Anwar Shah Road, Kolkata branch vide A/c No.
     255010100128834 which carried the transfer of several crores of rupees.
     Contributions were received u/s 25(l)(ii) of the Income Tax Act, 1961from various
     corporate/non - corporate entities in this fraudulent account and these amount
     were either withdrawn in cash through two or more layers, which happed to be
     societies/trusts or bogus donations were paid in lieu of cash to the societies
                                 8                                  ITA No. /Del/2018


/trusts, who are beneficiaries to these transactions of bogus donation, which are
situated all over India. The mediators, who are generally Chartered Accountants,
get commission of 15-20% in cash out of the contributions received u/s 35(l)(ii) of
the I.T. Act and 2-5% out of the bogus donation paid. By way of this mediators
get benefit from both parties. This facts relating to fraudulent bank account
opened by the Chartered Account, are further confirmed from the letter filed by
the President of the society before various enforcement agencies namely:-

1. The Manager, Axis Bank, Kolkata
2. The Chairman, Axis Bank, Mumbai
3. Officer Incharge, Durgapur Police Station
4. FIR/complain in Durgapur Police Station
5. Letter of ACIT, Durgapur

       The list of second/third layer Trust/Societies, through which money is
either withdrawn in cash or transacted for bogus donations alongwith their
respective bank account numbers are as follows:-


 S. No.    Name of the          Name     ofName of the           Account
           society              the Bank   Bank branch           Numbers
 1.        M/s Society for      Axis Bank  Prince Anwar          255010100128834
           Welfare of the       Ltd.       Shah     Road
           Handicapped                     branch,
           Person                          Kolkata
 2.        M/s Society for      Axis Bank New      Alipore       909010033440278
           Rural           &    Ltd.       branch,
           Development                     Kolkata
 3.        M/s Community         Axis Bank One      Town         911010041883071
           Rural      Orient    Ltd.       branch,
           Service Society                 Vijaywada


       The list of the beneficiary trust / societies who received donation in lieu of
cash is as per annexure-D, which speaks that the assessee society M/s Geeta
Education Society, has received donation of Rs.50,00,000/- on 17.03.2010 and
thereafter oil 19.03.2010 paid Rs.50,00,000/-. The name of the assessee finds
place in the bank statement of Axis Bank Limited. The assessee has taken the
amount of Rs.50,00,000/- from M/s Society for Welfare of the Handicapped
Person, which is in lieu of cash because before the clearing entry of cheque No.
228925 of Rs.50,00,000/- on 17.03.2010, there are two cash deposit of
Rs.25,00,000/- and 25,00,000/- in the bank account on 17.03.2010. Thus, this
amount of Rs.50,00,000/-is unexplained amount. In this case, assessee filed
return showing NIL income on 11.11.2010 and assessment was completed u/s
143(3) on 27.02.2013 on NIL income. The assessee furnished the list of donation
during assessment proceedings, but no name of donor M/s Society for Welfare of
Handicapped Persons located at 27 Tagore Avenue, Durgapur is mentioned.
                                      9                                  ITA No. /Del/2018


            Keeping in view the above facts, the above amount of Rs.50,00,000/-
     being amount of donation in lieu of cash is assessable in the hands of assessee.
     I have therefore reason to believe that the income of Rs.50,00,000/- has escaped
     the assessment within the meaning of section 147 of the Income Tax Act, 1961
     and is chargeable to tax for the A.Y 2010-11."

8.   We find that the identical issue is considered by the Hon'ble
Jurisdictional High Court in the case of Unitech Limited vs. DCIT in W.P.
(C) 12324/2015 wherein their Lordships of Jurisdictional High Court
vide order dated 24.7.2017quashed the notice under section 148. Their
Lordships followed the decision of the same court i.e. Hon'ble Delhi High
Court in the case of HCL Technologies Limited vs. DCIT in W.P. (C)
8164/2010 order dated 20.7.2017 wherein their Lordships held as
under:-

             "16. The AO has not made the effort of disclosing, in the reasons, what
     according to him constituted the failure by the Assessee to make a full and true
     disclosure. A mere reproduction of the language of the provision will not suffice.
     Also, although making such an averment either in the order rejecting the
     objections of the Assessee or subsequently in the counter-affidavit in the answer
     to a writ petition will not satisfy the requirement of the law. The reasons will have
     to speak for themselves. For complying with the jurisdictional requirement under
     the first proviso to Section 14/ of the Act, the reasons would have to show in what
     manner the Assessee had failed to make a full and true disclosure of all the
     material facts necessary for the assessment. The failure to do so would not be a
     mere irregularity. It would render the reopening of the assessment after four
     years vulnerable to invalidation. "(emphasis supplied)






     Thus wherever first proviso to section 147 is applicable the reasons
recorded should show in what manner the assessee had failed to make a
full and true disclosure of all material facts necessary for the
assessment. The failure to do so would not be more irregularity but it
would render the reopening of assessment after four year invalid.

9.   We have already reproduced above the reasons recorded for
reopening of assessment. In the reasons recorded, the Assessing Officer
nowhere mentioned that which material facts assessee failed to disclose.
                                 10                           ITA No. /Del/2018


There is no finding by the Assessing Officer that there is any failure on
the part of the assessee to make a full and true disclosure of any
material fact and therefore on these fact, the Hon'ble Jurisdictional High
Court in the case of HCL Technologies Limited (supra) as well as Unitech
Limited (supra) would be squarely applicable.

10.   Even otherwise an allegation in the reasons recorded is that there
was a society at Kolkata named as M/s Society for Welfare of
Handicapped Person. The assessee paid the cash of Rs. 50,00,000/- to
the said society and got the cheque of donation of Rs. 50,00,000/-. Thus
the assessee utilized its undisclosed income to get the accommodation
entry in the form of donation of Rs. 50,00,000/-. However, at the time of
conclusion of the reasons recorded the Assessing Officer himself has
mentioned that the assessee has furnished the list of donation during
assessment proceedings but no donor from M/s Society Welfare of
Handicapped Person is mentioned. Thus, when the assessee has not
claimed to have received any donation from the said society the question
of making any cash payment from undisclosed sources by the assessee
could not arise. Therefore, we are of the opinion that there was no
justifiable reason for arriving at the finding by the Assessing Officer that
there was undisclosed income of the assessee which was utilized for
obtaining Donation from M/s Society for Welfare of Handicapped Person.

11.   After considering the above facts and also relying upon the decision
of Hon'ble Jurisdictional High Court in the case of Unitech Limited and
also in HCL Technologies Limited (supra), we quash the notice issued for
reopening of assessment under section 148.

12.   Once the notice for reopening of assessment u/s 148 is quashed,
the assessment order passed in pursuance to such notice cannot survive
the same is also quashed. Since the assessment order itself has been
                                     11                              ITA No. /Del/2018


quashed, the other ground raised by the assessee which is against the
addition of Rs. 50,00,000/- made by the Assessing Officer does not
require any adjudication.

13.   In the result, assessee's appeal is allowed.

      Order pronounced in the Open Court on 22nd May, 2019.


                                                                   Sd/-
          Sd/-                                             (G. D. AGRAWAL)
 (SUCHITRA KAMBLE)                                         VICE PRESIDENT
  JUDICIAL MEMBER
Dated: 22/05/2019
SH

Copy forwarded to:

1.                            Appellant
2.                            Respondent
3.                            CIT
4.                            CIT(Appeals)
5.                            DR: ITAT




                                                         ASSISTANT REGISTRAR

                                                           ITAT NEW DELHI

                                                  Date
1.    Draft dictated on                      14.5.2019      PS
2.    Draft placed before author                            PS
3.    Draft proposed & placed before the                    JM/AM
      second member
4.    Draft discussed/approved by Second                    JM/AM
      Member.
5.    Approved Draft comes to the Sr.PS/PS                  PS/PS
6.    Kept for pronouncement on                             PS
7.    File sent to the Bench Clerk                          PS
8.    Date on which file goes to the AR
9.    Date on which file goes to the Head
      Clerk.
10.   Date of dispatch of Order.
11.   Date of uploading                      22.5.2019
12   ITA No. /Del/2018

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