9911796707
TMI Blog2022 (2) TMI 591X X X X Extracts X X X X X X X X Extracts X X X X ..... s not justified in sustaining the addition of 10,00,000/-. The order of the Ld. CIT(A) on this issue is, therefore, set-aside and the AO is directed to delete the addition Unexplained property purchased - search proceedings - HELD THAT:- We find the assessee had stated categorically before the AO that these are rough calculation for purchase of property which did not materialize. It is an admitted fact that no such document or papers pertaining to purchase of any property was found either during the course of search or post search enquiries. Apart from the noting in the seized papers, the revenue has no other evidence of purchase of any property by the assessee. No post search enquiry or investigation was conducted by the AO to find out if at all any property has been purchased - no document/paper relating to the so called property was either found during the course of search or post search enquiry and no independent evidence was either found during the course of search or collected subsequent to the search, therefore, in the light of the above decisions, the assessee in our opinion cannot be fastened with the liability. We, therefore, set-aside the order of the ld. CIT(A) on this ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... itness to the MOU and the notary in whose register the same has been entered to find out the facts and veracity of the MOU. ii. The AO shall also summon and record the statement of Mr. O.P. Gulati in whose name receipts were found and which are related the MOU. iii. In case the above persons do not respond to the summons issued by the AO, the onus shall be on the assessee to produce them before the AO. If the assessee fails to produce them and they do not respond to the summons then the AO may take adverse view. AO shall decide the issue in the light of our above observation and in accordance with law after giving due opportunity of being heard to the assessee. Non-granting of credit received from Mr. Abhay Salwan and R.A. Financial Services while computing the peak cash balance - HELD THAT:- We find it is the contention of the ld. Counsel for the assessee that benefit of 50 lakhs as per receipt dated 01.01.2012 seized during the search and received back from Mr. Abhay Salwan and R.A. Financial Services should be given for computing the peak cash balance, Similarly, it is also his submission that the Assessing Officer has not given the benefit of 50 lakhs as per seized documents da ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Y. 2011-12 [Assessee] : 2. Facts of the case, in brief are that the assessee is an individual and derived income from salary, house property, income from business and income from other sources. He filed his return of income on 15.09.2011 declaring total income of ₹ 61,93,010/-. A search under section 132 of the I.T. Act was conducted on 28.02.2017 at the residential premises of the assessee at House No. 128, Sector-16, Faridabad, Haryana from where certain papers/documents belonging to the assessee were found and seized. The jurisdiction of the assessee was transferred from Pr.ClT-5, Delhi to PCIT, Central Circle-4, Delhi vide order under section 127(1) dated 30.11.2017. In response to notice under section 153A of the I.T. Act, the assessee filed return of income declaring total income of ₹ 61,93,010/-. The A.O. issued notice under section 143(2) and subsequently notice under section 142(1) along with questionnaire. In response to the same, the assessee appeared before the A.O. and filed the requisite details from time to time. The A.O. thereafter completed the assessment under section 153A of the I.T. Act determining the total income of the assessee at ₹ 1,64,54 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 00,000/- as unexplained money while treating the witness (assessee) u/s. 118 of Indian Evidence Act, 1872, as the assessee involved in the transaction resultingly an unreasonable finding without even calling and summoning the person involved namely RA Financial Services and Om Shanti Educational Society. 9. Because the action is being challenged on facts and law for making an addition of ₹ 3,207/- by invoking the provisions u/s 69C by making presumption on presumption while law is settled that the presumption is supplied by Statute namely Income Tax Act, 1961, Schedule VII List 1 Entry 82 it is presumption of income and not presumption on presumption. 10. Alternatively and without prejudice to above, the action for not allowing telescoping of addition on account of u/s. 69A, u/s. 69C & commission expenses against addition on account of bogus purchases of group concerns is challenged on facts and law as both additions cannot be made simultaneously. 11. For any consequential relief and/or legal claim arising out of this appeal and for any addition, deletion, amendment and modification in the grounds of appeal before the disposal of the same in the interest of substantial ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (i.e., 2 entries of ₹ 50,000/- each were kept with Mamaji and Mataji) and the other entry relate to an amount of ₹ 1,00,000/- received back by the assessee from Mataji. Therefore, the amount of ₹ 1,00,000/- which assessee has given to them was received back. Alternatively, it was argued that if any addition on this account is to be made then assessee is entitled to telescoping against addition made on account of Bogus purchases which is treated as undisclosed income of assessee. It was further submitted that if telescoping of income is not allowed, it will amount to double addition. 8.2. However, the A.O. was not satisfied with the arguments advanced by the assessee and made addition of ₹ 12 lakhs to the total income of the assessee. 8.3. In appeal, the Ld. CIT(A) deleted the addition of ₹ 2 lakhs and sustained the addition of ₹ 10 lakhs by observing as under : "4.6. As far as amount of ₹ 2,00,000/- given to 'Mamaji' on 07.08.2010 is concerned, it is clearly mentioned in the seized paper itself that it was given for purchasing gold jewellery. The AO has certainly not disputed cash in hand of Shri Vishnu Kumar Garg (₹ 1,75,446/-) a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed the same arguments as made before the AO and Ld. CIT(A). He submitted that Mamaji and Mataji were living with the assessee and assessee used to handover business cash to them for safe custody, whenever he used to go out of station for either business purpose or some personal purpose. Referring to Page-267 of the PB, Learned Counsel for the Assessee drew the attention of the Bench to the details of cash in hand as on 07.07.2010 in various proprietorship firms and companies which are as under : Sr. No. Particulars Amount PB Pg 1. Blossom Landeal Pvt. Ltd., 8,001.00 268 2. LV Rustore Applications Pvt. Ltd., FBD 4,51,455.07 269 3. LV Rustore Applications Pvt. Ltd., - DL 17,392.25 270 4. Vishnu Kumar Garg - Proprietorship Firm 86,520.00 271 5. Lata Garg - Proprietorship Firm 3,77,827.00 272 6. Vishnu Kumar Garg 1,75,446.59 273 7. Lata Garg 1,63,557.00 274 Total Cash Balance as on 07 Jul 2010 12,80,198.91 8.6. He accordingly submitted that since the amount of cash available as on 07.07.2010 is ₹ 12,80,198/- which is more than the amount of ₹ 10 lakhs kept with Mamaji and Mataji, the same should be deleted. In his ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ind the assessee before the AO had categorically stated that Mamaji & Mataji were staying with the assessee and he used to handover business cash to them for safe custody whenever he used to go out of station for either business purposes or personal work. The assessee has also given the availability of cash on 07.07.2010 (the date of entry in the seized document) in the books of accounts of various proprietorship concerns and companies in which the assessee is a director at ₹ 12,80,198.91/- which is more than the amount of ₹ 10.00 lakhs. Therefore, merely stating that the explanation is not acceptable is not justified. Since, the availabilities of cash of ₹ 12.80 lakhs on 07.07.2010 in the books of accounts of various concerns of the assessee is not doubted, therefore, we are of the considered opinion that the Ld. CIT(A) is not justified in sustaining the addition of ₹ 10,00,000/-. The order of the Ld. CIT(A) on this issue is, therefore, set-aside and the AO is directed to delete the addition. The ground raised by the assessee is accordingly allowed. 11. Ground of appeal number.4 relates to the order of the Ld. CIT(A) in confirming the addition of ₹ 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on page no.14 of Annexure-A1 seized from premise no.128, Sec. 16, Faridabad :- - 16,30,000 cash - 75,000 Registree - 6,05,000 bhaiyaa ne -11,00,000/- Vishnu 4.8 Before the AO, the appellant stated that the entries are rough workings s pertained to property relating Shri Mukut Bhaiya, elder brother of the appellant. The / did not accept this reply. The AO noted that ₹ 11,00,000/- were paid by the appella {Shri Vishnu Kumar Garg} and therefore, added this amount. This addition was dispute vide ground No. 3. 4.9 ' During the appellate proceedings, the appellant re-iterated the same stand as was taken before the AO. The appellant also raised alternative contention that the cash was available out of bogus purchases in the hands of Shri Vishnu Kumar Garg, Smt. Lata Garg, M/s. RR Carwell Pvt. Ltd. and M/s. L. V. Rustore Applications Pvt. Ltd. and this addition should be telescoped against the same. 4.10 In my considered opinion, there is a clear entry in the seized material to the effect that Shri Vishnu Kumar Garg paid ₹ 11,00,000/-. Therefore, there is no infirmity in the action of the AO in terms of making addition of ₹ 11,00,000/-. As far as alterna ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th the sides, perused the orders of the A.O. and the Ld. CIT(A) and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us by both the sides. We find the A.O. on the basis of seized document Page-14 of Annexure-A1 made addition of ₹ 11 lakhs since the amount of ₹ 11 lakhs was appearing against the name of the assessee. We find the Ld. CIT(A) sustained the addition on the ground that there is a clear entry in the seized material to the effect that Shri Vishnu Kumar Garg paid ₹ 11 lakhs. It is the submission of the Learned Counsel for the Assessee that the entries found in documents seized are rough calculations for purchase of same property which did not materialize and no such property was found to have been purchased by the assessee and, therefore, these are dumb documents and, therefore, in the absence of any corroborative evidence no addition should be made. It is the alternate contention of the assessee that benefit of telescoping should be given on account of additions made for bogus purchases etc. 14.1. We find the assessee had stated categorically before the AO that these are rough calculation for purc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or on investigation. Unless the document is clear and unambiguous, it is only a dumb document and no charge can be levied on the basis of a dumb document. We find the Tribunal at para 11 of the order has observed as under:- "11. For the sake of argument if we accept the submission of the Ld. D.R. that the Ld. CIT (A) erred in accepting fresh evidence then what is left after ignoring those affidavits is the bare document No. 7 with the bare details as referred to above. The moot question now arises is whether any addition can be made on the basis of that document. We have already pointed out above that this document is bereft of necessary details about year of transaction, ownership of transaction, nature of transaction, necessary code for deciphering the figures. It may be possible that a document may not be complete in all respects as the businessman or tax evaders may chose to record minimum details on a document and keep the rest in their memory. It is the duty of the AO to carry out necessary investigations by correlating the impugned document with other documents seized, with regular books of accounts, with record kept by outside agencies, such as banks or financial institu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ty relating to Mukut Bhaiya who is the elder brother of the assessee. However, the A.O. was not satisfied with the arguments of the assessee and held that the assessee could not explain the source of ₹ 14 lakhs. In absence of any satisfactory explanation given by the assessee, the A.O. made addition of the same to the total income of the assessee. 15.3. In appeal, the Ld. CIT(A) sustained the addition made by the A.O. He, however, accepted the alternate plea of the assessee for telescoping subject to his observation at para-4.6 of the order reproduced at para 8.3 of his order. The relevant observations of the Ld. CIT(A) at para 4.15 of his order reads as under : "4.15. In my considered opinion, there is a clear entry in the seized material to the effect that on 14.09.2010, ₹ 5,00,000/- cash was received. Also, the entry "650000" shows either an amount of ₹ 6,50,000/- were received or adjusted so that balance became ₹ 8,45,000/- (instead of earlier balance of ₹ 14,00,000/-). Therefore, there is no infirmity in the action of the AO in terms of making addition of ₹ 14,00,000/-. As far as alternative plea of telescoping is concerned, As far as alt ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h has been reproduced at Para 15.1 of this order clearly mentions ₹ 5,00,000/- cash received 14.09.2010. This, in our opinion, cannot be termed as rough calculation or estimation. However, a perusal of all the entries shows that out of ₹ 14,00,000/- there is still a balance of ₹ 3,45,000/- left. Therefore, addition, if any, has to be restricted to ₹ 10,55,000/- only (i.e., ₹ 14,00,000 - ₹ 3,45,000). We, therefore, modify the order of the Ld. CIT(A) and direct the A.O. to restrict the addition to ₹ 10,55,000/-. 18.2. So far as argument of Learned Counsel for the Assessee that telescoping benefit should be given is concerned, the same is acceptable in view of the decision of the Hon'ble Delhi High Court in the case of CIT vs. Sonal Construction reported in [2013] 359 ITR 532 (Del.) where the Hon'ble High court has accepted the theory of benefit of telescoping. We, therefore, direct the A.O. to allow the benefit of telescoping and deduct the addition of ₹ 10,55,000/- from profits from bogus purchases etc. added in the hands of the assessee and his proprietorship concerns and in the case of the 02 companies namely LV Rustore Applications ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... received any interest during the year on the loan given in January 2009 of ₹ 50 lakhs and June 2009 of ₹ 25 lakhs @ 1.5% per month. The A.O, therefore, calculated the interest on ₹ 75 lakhs at ₹ 11,25,000/- and added the same to the total income of the assessee treating the same as income from other sources. 20.3. In appeal, the Ld. CIT(A) upheld the action of the A.O. on the ground that the plea of the assessee that interest was not received cannot be accepted in the absence of any supporting evidence. 20.4. Aggrieved with such order of the Ld. CIT(A), the assessee is in appeal before the Tribunal. 21. Learned Counsel for the Assessee referring to Pages 95 and 96 of the paper book submitted that the seized documents Pages 125 & 126 of Annexure A-5 contain details of Loan. He submitted that the A.O. presumed that the said documents contain details of loan amounting ₹ 75 Lakh given to Shri Rattan Prakash Mishra in the year 2009 instead of Shri Abhay Salwan merely on the basis that the said document contains signature of Shri Rattan Prakash Mishra. He submitted that the A.O. overlooked that the seized document Page 125 contains signature of 4 persons ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... above said period and balance ₹ 50 Lakh (Principal) was still recoverable from Abhay Salwan and the same is mentioned on Page-125 of the seized Annexure A-5. Similarly, Interest amounting ₹ 6 Lakh on principal loan ₹ 25 Lakh was still recoverable as mentioned on Page-125 of the seized Annexure A-5. Thus, it is a proven fact that assessee has not received any interest on loan from Abhay Salwan during that year. AO overlooked the documents Pages 125 & 126 (supra) and submissions of assessee and merely on presumption added interest amount ₹ 11,25,000/- during the year. 21.2. Learned Counsel for the Assessee submitted that Shri Rattan Prakash Mishra, in his proceedings under section 153C has denied to have any transaction with the assessee. He referred to the copy of assessment orders passed under section 153A/153C for the A.Ys. 2011-12 and 2012-13, copies of which, are placed at Pages 16-24 of second synopsis dated 03.08.2021 and drew the attention of the Bench to the submission before the A.O. He submitted that when both assessee and Shri Rattan Prakash Mishra are denying of any transaction and there is no other corroborative evidence or material before the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lien of the state on all the belongings (moveable and immoveable assets) of the litigant whereby the assessee Vishnu Garg is an unsecured creditor. However an unsecured creditor with a unilaterally signed document bereft of bilateral and consensus-ad-idem is not an enforceable document in Law perse. Simultaneously and collaterally the state (statutory bodies for statutory levy) don't have any document of whatsoever kind to recover the amounts from said Shri Abhay Salwan and in spite of that they are a secure creditor in accordance with the principle of law laid down in the case of Vijay Bank vs., CIT (2010) 323 ITR 166 (SC). 21.7. He further submitted that in the Court of Saurab Gusain, Civil Judge (Sr. Div), Faridabad in the case of Vijay Sachdeva (Plaintiff) vs., Abhay Salwan (Defendant), vide order dt. 22.09.2015 (PB Pages 112-197) in suit for specific performance of contract where the issue is that the defendant Abhay Salwan agreed to sell the property to the plaintiff for a total sale consideration of ₹ 50 Lakhs vide sale agreement dt.31.12.2012. On same day defendant received a sum of ₹ 45 Lakh as part payment and also handed over the original sale deed dt.0 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ugh no document was found during search relating to recovery of interest and even overlooking the order of Hon'ble Allahabad High Court, Civil Court and Judicial Magistrate wherein Shri Abhay Salwan has been declared as a proclaimed person. 21.10. Alternatively and without prejudice to above, the Learned Counsel for the Assessee submitted that if any addition on this account is made, then, the assessee should be entitled to telescoping against addition made of Bogus purchases in the hand of assessee and two companies namely LV Rustore Applications Pvt. Ltd. and R R Carwell Pvt. Ltd. where he is the director and the controlling person as undisclosed income of assessee. He submitted that if telescoping of income is not given than there will be double addition in as much as both the undisclosed income and the investment made out of such income are both brought to tax which was contrary to the basic principles of assessment. Therefore, undisclosed income and the undisclosed investment are to be set off against each other, thus giving benefit of telescoping to the assessee. For the above proposition, the Learned Counsel for the Assessee relied upon the following Judgments :- (i) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... such interest should be made. 23.1. We find some force in the above arguments of the Learned Counsel for the Assessee. A perusal of the seized document at Page Number-125 of Annexure-A5 clearly mentions the following : "Principal Amount ₹ 75,00,000 Paid Balance up to 11.10.2010 ₹ 25,00,000/- 31.12.2010 ₹ 50,00,000/- [Interest @ 1.5% p.m.]" 23.2. From the above it cannot be deciphered that assessee has received any interest on the amount of ₹ 75 lakhs given to Shri Abhay Salwan. We find merit in the arguments of the Learned Counsel for the Assessee that the lower authorities have overlooked the submissions and added the interest merely on the basis of presumption and surmises. We find the Learned Counsel for the Assessee through various documents/Court order has established that Shri Abhay Salwan is absconding, is a proclaimed person and is a defaulter. Therefore, in absence of any evidence available with the Revenue, it cannot be said that the assessee has received the interest of ₹ 11.25 lakhs from Shri Abhay Salwan during the year especially when the seized document does not categorically mention that the assessee has in fact received the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y notional interest. 23.8. In view of the above discussion, we set aside the order of the Ld. CIT(A) on this issue and direct the AO to delete the addition. The grounds raised by the assessee are allowed. 24. In ground of appeal number.8, the assessee has challenged the order of the Ld. CIT(A) in confirming the addition of ₹ 40 lakhs made by the A.O. as unexplained money. 25. Facts of the case, in brief, are that during the course of search proceedings at premises 17/6, Hanspal Industrial Complex, Mathura Road, Faridabad, Page Nos.67 to 71 of Annexure-A5 Hanspal Industrial Complex were seized. These pages are letters issued by R.A. Financial Services to Mr. Rattan Prakash Mishra, President Om Shanti Educational Society. As per this letter, Sh. Vishnu Garg has received ₹ 40,00,000/- (₹ 18,00,000/- received on 19.10.2010 and ₹ 22,00,000/- received on 30.10.2010) from R. A. Educational Trust. The A.O, therefore, asked the assessee to explain the said amount and his interest in Omshanti Educational Society and the reasons as to why the said amount was paid to assessee. 25.1. The reply of the assessee vide letter dated 30.11.2018 has been reproduced by the A. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e by the A.O. He submitted that the documents Page Nos. 67 to 71 of Annexure 5 (PB-1 Pages 79-83) seized from 17/6, Hanspal Industrial Complex, Mathura Road, Faridabad, are letters issued by RA Financial Services to Rattan Prakash Mishra, President Om Shanti Educational Society. As per these letters assessee received cash of ₹ 40,00,000/- (40 Lakh) on behalf of Om Shanti Educational Society from R.A. Financial Services as Authorized Person which is specifically mentioned in Letter at PB Pages 81-82. Moreover, the impugned agreement mentioned in this letter was between RA financial services and Om Shanti Educational Society and assessee was not related to either with Om Shanti Educational Society or R. A. Financial Services. He submitted that assessee's role was only that of a witness to the transactions and he had not received any amount from any of the involved parties. During assessment proceedings under section 153A, statement of Sh. Rattan Prakash Mishra was recorded on dt. 16.11.2018 (PB Pg. 275-276) wherein specific question (Q-13) was asked relating to above said letter and money received by assessee amounting ₹ 40 Lakh from R A Educational Trust on behalf o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the order of the Ld. CIT(A) should be upheld and the ground raised by the assessee on this issue should be dismissed. 28. We have considered the rival arguments made by both the sides, perused the orders of the A.O. and the Ld. CIT(A) and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find the A.O. in the instant case made addition of ₹ 40 lakhs on the basis of the seized documents Page Nos.67 to 71 of Annexure-A5 on the ground that as per the letter issued by R.A. Financial Services to Mr. Rattan Prakash Mishra, President Omshanti Educational Society, Mr. Vishnu Garg has received ₹ 40 lakhs from R.A. Educational Trust on various dates i.e., ₹ 18 lakhs on 19.10.2010 and ₹ 22 lakhs on 30.10.2010. The submission of the assessee that he has received the cash of ₹ 40 lakhs on behalf of Omshanti Educational Society from R.A. Financial Services and were subsequently passed-on to Omshanti Educational Society was rejected by the A.O. on the ground that the assessee failed to furnish any evidence that this money was actually further given to Omshanti Educational Society. It is the submissi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... been paid till 16.10.2010 as admitted by you in your letter under reply. The balance amount of ₹ 40,00,000 (Rs.Fourty Lacs only) has been paid by R.A. Financial Services through its authorized signatory Mr. Abhay Salwan to Mr. Vishnu Garg, s/o. Sh. B.D. Garg, member Omshanti Educational Society as per your instructions and to your knowledge because you have to pay the aforesaid amount to Mr. Vishnu Garg. The details of payment are given below : 19.10.2010 - A sum of ₹ 18,00,000 (Rs.Eighteen Lacs only) was paid. 30.10.2010 - A sum of ₹ 22,00,000 (Rs.Twenty Two Lacs only) was paid. 3. That as per the clause 9 of MOU and the payment terms of the said agreement, the balance payment having already been paid to you on 30.10.2010 by R.A. Financial Services the land of RPS Education. Foundation has been transferred to Omshanti Educational Society vide Sale Deed No.149 dated 06.04.2011. It is further stated that after having received the amount of ₹ 1,35,00,000 (Rs. One Crore Thirty. Five lacs only) the undersigned and five of his associates were inducted as members of the Governing body of Omshanti Educational Society which fact is to your knowledge. The under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... OLUTION TO FINANCIAL MATTERS F-13, 2nd Floor, Sector-10, Faridabad Ph.9971797798 Email : [email protected] 29th August, 2011 To Mr. Rattan Prakash Mishra, President, Om Shanti Educational Society, H.No.1365, Sector-17, Faridabad. Dear Mr. Mishra, Please refer to your communication dated 23,08.2011. After going through the contents and without adverting to para-wise and point-wise reply, I wish to Inform you as under : At the outset, it is highly surprising and painful to say that despite having received- the entire amount in terms of the MOU dated 06.09.2010, you still have the audacity to deny the receipt of payment, although it is in your active and full knowledge. To steer clear the misgivings, it is once again brought to-your notice in order to straighten the records that admittedly a sum of ₹ 1,35,00,000 has been received by you. The remaining amount of ₹ 40,00,000 stands paid to you by the, undersigned and the payment has been received by you through Mr. Vishnu Garg, your authorised person.. The details of payment have been given in the last letter dated 17.08.2011. You can cross check and co ordinate with your own representative.. Your ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion is required. 30. In the result, ITA.No.9147/Del./2019 of the Assessee is partly allowed. ITA.No.9148/Del./2019 - A.Y. 2012-13 : 31. The grounds raised by the Assessee are as under: 1. "Because the action for initiation, continuation and conclusion of assessment proceedings u/s 153A at an amount of ₹ 79,47,790/- is being challenged on facts and law. 2. Because the action is being challenged on facts and law for making additions in assessment proceedings u/s 153A when there is no incriminating material/ document found during the course of search u/ s 132 of the Act for the impugned year. 3. Because the action is being challenged on facts and law for making an addition of ₹ 4,50,000/- (@ 1.5% of ₹ 50,00,000/- given to Mishra ji) which is unwarranted action by assuming the interest accrued of 1.5% which is a hypothetical income and against the principle of law (Godhara Electricity Co. Ltd., vs., CIT (1997) 225 ITR 746 (SC) whereas per assessee said loan of ₹ 50,00,000/- is given to Abhay Salwan & not to Mishraji. 4. Because the action is being challenged on facts and law for making an addition of ₹ 4,50,000/- (@ 3% of ₹ 50,00,000/- giv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ready decided the issue and the grounds raised by the assessee have been allowed wherein the addition of interest made by the AO and upheld by the Ld. CIT(A) has been deleted. Following similar reasoning the above grounds by the assessee are allowed. ITA No.9149/Del./2019(Assessee's appeal) A.Y. 2013-14 36. The grounds raised by the assessee are as under : 1. Because the action for initiation, continuation and conclusion of assessment proceedings u/s 153A at an amount of ₹ 3,70,94,992/- is being challenged on facts and law. 2. Because the action is being challenged on facts and law for making additions in assessment proceedings u/s 153A when there is no incriminating material/document found during the course of search u/ s 132 of the Act for the impugned year. 3. Because the action is being challenged on facts and law for invoking the jurisdiction u/s. 69A r.w.s. 115BBE as unexplained money for ₹ 2,39,25,000/- while assuming the presumption for addition bereft of material facts containing material particulars in the case proceedings. 4. Alternatively & without prejudice to above, the action for not giving benefit of ₹ 50,00,000/- (receipts dt. 01.01.2012 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l ground, for which, the Ld. D.R. has no objection. Accordingly, the additional ground by the assessee is dismissed. 39. Grounds of appeal numbers. 1 and 8 being general in nature, are dismissed. 40. Learned Counsel for the Assessee did not press ground of appeal number.2, for which, the Ld. D.R. has no objection. Accordingly, the same is dismissed as not pressed. 41. In ground of appeal number.3 the assessee has challenged the addition of ₹ 2,39,25,000/- made by the A.O. and sustained by the Ld. CIT(A). 42. Facts of the case, in brief, are that during the search operation at premises 17/6, Hanspal Industrial Complex, Mathura Road, Faridabad, Page numbers. 35 and 36 of Annexure A-10 was seized. It is an MOU entered into by the Assessee and Gyaneshwar Education Trust on 12.11.2012. According to this MOU assessee had given a cash loan of ₹ 3.5 crores to Gyaneshwar Education Trust @ 2.6% interest per month for one year till 11.11.2013. This MOU is duly signed by Shri Abhay Salwan on behalf of the Trust and was found in the custody of the assessee. The A.O, therefore, asked the assessee to explain the source of ₹ 3.5 crores and explain as to why the same should no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he AO treated ₹ 2,39,25,000/- being the difference between ₹ 3.5 Cr and ₹ 1,10,75,000/-, as unexplained and made addition of equivalent amount u/s 69A. 45. In appeal, the Ld. CIT(A) upheld the action of the A.O. by observing as under : 22.6. During the present appellate proceedings, that AR repeated the stand taken before the AO. Additionally, the AR argued that calculation of availability of cash as on 12.11.2012 was not correct because benefit of ₹ 1,00,00,000/- which was extended by way of four receipts of ₹ 25,00,000/- each {first evidencing payment of cash loan ₹ 25,00,000/- by Shri Vishnu Kumar Garg to Shri Abhay Salwan, second evidencing payment of cash loan of ₹ 25,00,000/- by M/s. L.V. Rustore Applications Pvt. Ltd. to Shri Abhay Salwan, third evidencing payment of cash loan of ₹ 25.00,000/- by Shri Vishnu Kumar Garg to M/s. RA Financial Services (signed by Shri Abhay Salwan) and fourth evidencing payment of cash loan of ₹ 25,00,000/- by M/s. L V. Rustore Applications Pvt. Ltd. to M/s. RA Financial Services (signed by Shri Abhay Salwan) } and cash generated out of bogus purchases in case of appellant, Smt. Lata Garg ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the above discussion, this ground (No. 3) of appeal is dismissed, subject to the above mentioned remarks/observations." 46. Aggrieved with such order of the Ld. CIT(A), the assessee is in appeal before the Tribunal. 47. The ld. Counsel for the assessee strongly challenged the order of the Ld. CIT(A) in sustaining the addition of ₹ 2,39,25,000/- made by the AO on the basis of seized documents at page no.36 & 37 of the Annexure A-10. He submitted that the First MOU dated 12.11.2012 has only the signature of Abhay Salwan, which was neither stamped nor notarized. Therefore, it has no evidentiary value. Further Shri Abhay Salwan is a fraud has already been brought on record by producing court orders while arguing for AY 2011-12. There is no corroborative evidence that the amount of ₹ 3.5 crores is given by the assessee to Abhay Salwan. He submitted that a perusal of the MOU and other details given by the assessee to the AO at the time of assessment proceedings conclusively prove the amount of ₹ 3.50 Crores consists of the principal, interest and interest on interest be recovered from Abhay Salwan. He accordingly submitted that the addition made by the AO and sustai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... j Bhushan Tyagi, who are parties to the second MOUs are declared as proclaimed offenders. However, the AO has not examined Mr. Sanjay Gupta, one of the witness of the MOU or the notary in whose register, such documents/MOUs were entered to find out the truth. 47.5. Ld. counsel for the assessee submitted that during the course of search, receipts in the name of O.P. Gulati and his wife Renu Gulati were also found, which is related to these MOUs. Although the AO has summoned O.P. Gulati and recorded his statement, however, no question was asked to him on these MOUs which shows that no proper examination was done by the AO. He submitted that since the AO has failed in his duty, the addition made by him and sustained by the Ld. CIT(A) should be deleted. 47.6. The ld. counsel for the assessee further submitted that addition has been made by the AO under section 69A of the I.T. Act. Referring to the provisions of section 69A, he submitted that these MOUs do not come under the category of money, bullion, jewellery or other valuable articles. Further, the date of payment is also not mentioned in the MOUs and therefore to which financial year it relates is not ascertainable which is manda ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ocuments at page 36 and 37 of the Annexure A-10 seized from the premise at 17/6, Hanspal Industrial Complex, Mathura Road, Faridabad. According to the AO, the seized document is an MOU entered into between the assessee and Gyaneshwar Education Trust on 12.11.2012, according to which the assessee had given cash loan of ₹ 3.50 Crores to Gyaneshwar Educational Trust @ 2.6% interest per month for one year till 11.11.2013. This MOU is duly signed by Shri Abhay Salwan on behalf of the Trust and was found in the custody of the assessee. We find the reply of the assessee that Mr. Abhay Salwan has not signed at First Party place but made initial only as proposal of MOU was rejected by the AO and for which the AO has given his reasoning at pra 5.4 to 5.10 onwards in his order. However, the AO while making the addition of ₹ 2,39,25,000/-, has given benefit of peak credit of ₹ 1,10,75,000/- and made the addition of balance ₹ 2,39,25,000/-. We find the ld. CIT(A) upheld the same, the reasoning of which have already been reproduced in the preceding paragraph. It is the submission of the ld. Counsel for the assessee that since Mr. Abhay Salwan defaulted in making the payme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 25 lakhs each would be forfeited. 3. On the basis of the MOUs, the Assessing Officer issued a questionnaire to Ravi Talwar and Madhu Talwar regarding receipt of the amount of ₹ 25 lakhs each but while they both admitted having signed the MOUs, they denied having received any amount. The Assessing Officer concluded that the denials by the Assessee of having made payments and of Ravi Talwar and Madhu Talwar of having received the amounts was only to escape payment of tax liabilities. Accordingly, an amount of ₹ 50 lakhs was added in the hands of the Assessee under Section 69 of the Income Tax Act, 1961 (for short the Act) as unexplained expenditure. 4. The view taken by the Assessing Officer was not accepted by the Commissioner of Income Tax (Appeals) and also by the Tribunal. Both concurrently were of the view that there was not enough evidence to add the amount in the hands of the Assessee. 5. The Commissioner was of the view that all the parties had denied the transaction and in fact the property in question was eventually sold by Ravi Talwar and Madhu Talwar to M/s. Delhi Tent and Decorators Pvt. Ltd. whose Director gave a statement on 4th February, 2002 to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Investment Corporation, [1988] 173 ITR 393. 11. Even in Income Tax Officer, B-Ward, Ernakulam v. T. Abdul Majeed, [1988] 169 ITR 440, it has been held as follows: - "It is true that section 132(4A) of the Act enables the court to presume the truth of the contents of such books. However, it is a presumption which can be rebutted. Moreover, the presumption envisaged therein is only a factual presumption. It is in the discretion of the court, depending upon other factors, to decide whether the presumption must be drawn. The expression used in the sub-section is "may be presumed" as is used in section 114 of the Evidence Act, 1872. It is not a mandate that whenever the books of account are seized, the court shall necessarily draw the presumption, irrespective of any other factors which may dissuade the court from doing so." 12. In so far as the present case is concerned, the Assessee had stated that in fact there was no transfer of money between him and Ravi Talwar and Madhu Talwar. On the other hand, Ravi Talwar and Madhu Talwar had denied receipt of any money from the Assessee. In the fact of these denials, there ought to have been corroborative evidence to show that there was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lhi High Court (cited supra), while deciding the issue. We hold and direct accordingly. The ground of appeal no.3 by the assessee is accordingly allowed for statistical purposes. 51. Ground of appeal no.4 relates to the non-granting of credit of ₹ 50 lakhs received from Mr. Abhay Salwan and R.A. Financial Services while computing the peak cash balance. 51.1. After hearing both the sides, we find it is the contention of the ld. Counsel for the assessee that benefit of ₹ 50 lakhs as per receipt dated 01.01.2012 seized during the search and received back from Mr. Abhay Salwan and R.A. Financial Services should be given for computing the peak cash balance, Similarly, it is also his submission that the Assessing Officer has not given the benefit of ₹ 50 lakhs as per seized documents dated 15.12.2011 seized during the course of search relating to L.V. Rustor Application Pvt. Ltd. where the assessee is shareholder and director and amount being received back from Mr. Abhay Salwan and R.A. Financial Services along with interest should be considered for computing the peak cash balance. Considering the totality of the facts of the case and in the interest of justice, we de ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ; 13,50,000/- made by the AO and sustained by the Ld. CIT(A) again on account of interest received from Mr. Abhay Salwan on the loan granted of ₹ 25 lakhs and ₹ 25 lakhs each. 55. After hearing both the sides, we find the above ground is identical to the ground of appeal no.6 and 7 in ITA No.9147/Del/2019 for AY 2011-12. We have already decided the issue and ground raised by the assessee has been allowed. Following similar reasonings, this ground raised by the assessee is allowed. 56. Ground No.7 by the assessee relates to the order of the Ld. CIT(A) in confirming the addition of ₹ 3,04,832/- made by the AO being interest paid on housing loan. 57. After hearing the both the sides, we find the AO on the perusal of the computation of income found that the assessee has shown interest payment on housing loan amounting to ₹ 12,05,686/- . On being questioned by the AO, it was submitted by the assessee that he has obtained housing loan of ₹ 2,00,75,720/- on which interest has been paid. However, the AO noted that the assessee has utilized only ₹ 1,50,00,000/- out of the above amount of ₹ 2,00,75,720/- for the purchase of the house property and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dismissed. 62. So far as the order of the ld. CIT(A) in granting telescoping benefit from additions made in various other companies are concerned, the same in our opinion is justified. Admittedly, the assessee Mr. Vishnu Kumar Garg is the director and controlling person of the two other companies namely R.R.Carwell (P) Ltd. and L.V. Rustore Applications Pvt. Ltd. . Therefore, there is no infirmity in the order of the Ld. CIT(A) on this issue since the profit was generated on account of bogus purchases, etc in the hands of the two companies are appropriated by Mr. Vishnu Kumar Garg only. Therefore, the grounds raised by the Revenue on this issue being devoid of any merit are dismissed. ITA No.9150/Del/2019 (Assessee's Appeal) for AY 2014-15. 63. The grounds raised by the assessee are as under:- 1. Because the action is under challenge on facts and law for arriving at the chargeable income of ₹ 6,03,53,210/- which is dehors material facts containing material particular to the case controversy during the course of case proceeding and contrary to the judgement S. Sankappa vs. ITO ((1968) 2SCR 674). 2. Because the action is being challenged on facts and law for making addi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... India Pvt. Ltd., 17/6, Hanspal Industrial Complex, Mathura Road, Faridabad, therefore the additions on the basis of the said documents can only be made u/s 153C of the Act & not u/s 153A of the Act. 65. However, the ld. Counsel for the assessee did not press the additional ground of appeal for which the Ld. DR has no objection. Accordingly, the additional ground filed by the assessee is dismissed as not pressed. 66. Ground No.1 and 2 were not pressed by the ld. counsel for the assessee for which the Ld. DR has no objection. Accordingly, the grounds of appeal no. 1 and 2 are dismissed as not pressed. 67 Grounds of appeal no.3 and 4 relate to the order of the Ld. CIT(A) in confirming the addition of ₹ 3,59,64,000/-. 68. Facts of the case in brief are that the AO noted that during the search operation at premise 17/6, Hanspal Industrial Complex, Mathura Road, Faridabad , page No. 13 & 14 Of Annexure- A10 was seized. It is an MOU entered into by the assessee and Gyaneshwar Educational Trust on 28.09.2013. According to this MOU, the assessee had given a cash loan of ₹ 5 Cr in cash to Gyaneshwar Educational Trust on 28.09.2013 @ 3% interest per month for three years from ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of Gyaneshwar educational trust would sign on an agreement which clearly mentioned that Gyaneshwar educational trust is receiving ₹ 5 Cr in cash on 28.09.2013@ 3% interest for three year till 28.09.2016. 71. The AO further observed that MOU of ₹ 5 Cr was entered into by the assessee and Gyaneshawar Educational Trust on 28.09.2013 whereas MOU of ₹ 3.5 Cr was entered into by the assessee and Gyaneshawar Educational Trust on 12.11.2012 for one year. Therefore, the MOU of ₹ 5 Cr was entered before completion of the MOU of ₹ 3.5 Cr. Therefore, Both MOUs are independent and not related to each other. The AO therefore concluded that the assessee had given a cash loan of ₹ 5 Cr to Gyaneshwar Educational trust @ 3% interest per month on 28.09.2013 for three year till 28.09.2016. 72. From the various seized material found during course of search, the AO noted that the following transactions pertain to the assessee and were occurred in cash. In order to find peak cash balance on a given date, the AO recorded these transactions in chronological order with narration as shown below: AY 2011-12 Date Amount Received Amount Paid Narration 30.09.2010 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ,86,000 Cash in hand as on 31.03.2014 AY 2014-15 31.8.2013 45,50,000 Interest income from cash loan of 3.5 Cr given to Gyaneshwar Trust on 12.11.2012 for period from 01.04.2013 to 31.08.2013 1,40,36,000 Total cash in hand as on 28.09.2013 73. He observed that on 28.09.2013, the assessee had a peak cash balance of ₹ 1,40,36,000/-. The assessee had given a cash loan of ₹ 5 Cr to Gyaneshwar Educational Trust on 28.09.2013. Out of total cash of ₹ 5 Cr given to the Gyaneshwar Educational Trust, ₹ 1,40,36,000/- is adjusted against total cash in hand on 28.09.2013. For the remaining amount of ₹ 3,59,64,000/- out of ₹ 5 Cr, the source remained unexplained. The assessee has not recorded these transactions in his books of account/statement of affairs. The assessee is found to be owner of ₹ 3,59,64,000/- but he did not furnish any explanation regarding the source of the money. Therefore, he treated the amount of ₹ 3,59,64,000/- as unexplained money of the assessee u/s 69A of IT Act. 74. In appeal, the Ld. CIT(A) confirmed the addition made by the AO by observing as under:- 29.7. During the present appellate proceedings, that AR re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... emarks made therein are applicable to this addition, mutus mutandi." 75. Aggrieved with such order of the Ld. CIT(A), the assessee is in appeal before the Tribunal. 76. After hearing both sides, we find this ground is identical to ground of appeal no.3 in ITA No.9149/Del/2019 for AY 2013-14. We have already decided the issue and restored the issue to the file of the AO for fresh adjudication. This issue was also discussed in the said ground. Following similar reasonings, we restore this issue to the file of the AO for fresh adjudication. The AO shall decide the issue as per fact and law after giving due opportunity of being heard to the assessee in the light of our direction given therein. We hold and direct accordingly. This ground by the assessee is accordingly allowed for statistical purposes. 77. In ground no.4, the assessee made alternate contention regarding giving benefit of ₹ 3.56 lakhs which was received back from M/s Gyaneshwar Educational Trust as per MOU dated 12.11.2012. 77.1. Since, we have already restored ground of appeal no.3, this ground is also restored to the file of the AO for fresh adjudication. The ground raised by the assessee is accordingly allowe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , the assessee has challenged the order of the Ld. CIT(A) in sustaining the addition of ₹ 5,47,261/- on account of disallowance of housing loan interest. 86. After hearing both the sides, we find this ground is identical to ground of appeal no.7 in ITA No.9149/Del/2019 for AY 2013-14. We have already decided this issue and dismissed the ground. Following the similar reasoning, the ground raised by the assessee is dismissed. ITA No.9449/Del/2019 (Revenue's Appeal) for AY 2014-15 87. The ground raised the Revenue are as under:- 1. The order of Ld. CIT (A) is not correct in law and facts. 2. Whether the facts and circumstances of the case, the Ld. CIT (A) has erred in allowing telescoping effect of ₹ 1,8186,816/- on account of bogus purchases made in the hand of other entity of Group to the assessee's case. 3. Whether the facts and circumstances of the case, the Ld. CIT (A) has erred in allowing the benefit of cash generated due to the additions of bogus purchases in the hands of other entity of Group to the assessee's case. 4. Whether the facts and circumstances of the case, the Ld. CIT (A) has erred in allowing the cash generated due to out of books transa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... making disallowance of interest for ₹ 5,06,563/- which is a deduction allowable while computing chargeable income u/s 22 to 24. 6. Because the action for addition amounting ₹ 30,00,000/- is being challenged on facts and law as assessee failed to prove identity, genuineness and credit worthiness of unsecured loan whereas per assessee the said amount received is repayment of loan given to Abhay Salwan by assessee substantiated through document seized in search. 7. For any consequential relief and/or legal claim arising out of this appeal and for any addition, deletion, amendment and modification in the grounds of appeal before the disposal of the same in the interest of substantial justice to the assessee." 90. The assessee has also raised the following additional ground : i) Because the action is being challenged on facts & law for making additions in assessment proceedings u/s 153A wherein the seized documents Pg. 13-14 of Annexure A-10 & Pg.46 of Annexure A-10 relating to assessee were found from the premises of third parties i.e., LV Rustore Appliations Pvt. Ltd., RR Carwell Pvt. Ltd., Blossom Landeal Pvt Ltd., & Elvi Bardahl India Pvt. Ltd., 17/6, Hanspal Indu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ness of the transaction. But the assessee failed to provide any of the above mentioned documents. Further, page no 46 of Annexure A-10 seized from the premise of the asessee contains above mentioned loan amount from Giant maker developers P Ltd and NBS Engineers P Ltd. Vide questionnaire dated 15.10.2018, the assessee was asked to explain these entries. Thereafter, the assessee was asked to show cause as to why the amount ₹ 25,00,000/- received from M/s Giant maker Developers Pvt. Ltd and ₹ 5,00,000/- received from M/s NBS Engineers P Ltd not to be considered bogus/unaccounted and added back to total income of the assessee. The assessee did not file any satisfactory reply. The AO noted that the assessee could not provide any document in support of his claim of unsecured loan received during the year. Secondly, the assessee is contradicting himself when he is mentioning that ₹ 25,00,000/- received from Giantmaker Developers Pvt Ltd and ₹ 5,00,000/- received from M/s NBS Engineers India Pvt Ltd is actually a payment made by Abhay Salwan against the loan given by the assessee in earlier years. He noted that as per submission made by the assessee, this payment o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... discharge initial onus of proving identity and creditworthiness of the lender and genuineness of the transaction. It is also noted that the amount of ₹ 50 Lakhs was not added in the AY 2012-13 (because due to telescoping, the source of two cash loans of ₹ 25 each were extended on 01 January, 2012 to Shri Abhay Salwan and M/s. RA Financial Services, were treated as explained, as discussed in para 15.2, above ). Moreover, the AO has already given credit for receipt of this amount after one year i.e. on 01.01.2013 as per the chart of cash availability in para 5.8 of the AY 2014-15. 39.6. Therefore, this ground (No. 5) of appeal is dismissed." 100. Aggrieved with such order of the Ld. CIT(A), the assessee is in appeal before the Tribunal. 101. The ld. Counsel for the assessee submitted that the seized document at page no.46 Annexure A-10 from the premises at 17/6, Hanspal Industrial Complex, Mathura Road, Faridabad, shows certain hand written entries of receipt of amount from Mr. Abhay Salwan in his group companies. The ld. Counsel for the assessee drew the attention of the Bench to the following details:- S. No. Date Amount (Rs.) Mode of Payment Name of Party ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... settling the whole case on presumption which is not correct. He accordingly submitted that the order of the Ld. CIT(A) be set-aside and the ground raised by the assessee be allowed. 103. The Ld. DR, on the other hand, heavily relied on the order of the Ld. CIT(A). 104. We have heard the rival arguments made by both the sides, perused the orders of the A.O. and the Ld. CIT(A) and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find the AO in the instant case made addition of ₹ 30,00,000/- to the total income of the assessee being unsecured loans of ₹ 25 lakhs from M/s Giant Maker Developers Pvt. Ltd. aned ₹ 5 lakhs from NBS Engineers India Pvt. Ltd. obtained by the assessee on the ground that the assessee has failed to prove the identity, genuineness and creditworthiness of the loan creditors and also tried to hide actual nature of the payment by showing its liability. 105. We find the ld. CIT(A) upheld the action of the AO, the reasons of which have already been reproduced in the preceding paragraph. It is the submission of the Ld. counsel for the assessee that the amount of ₹ 30,00,000/- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fore the additions on the basis of the said documents can only be made u/s 153C of the Act & not u/s 153A of the Act. 109. However, the ld. Counsel for the assessee did not press the additional ground for which the ld. DR has no objection. Accordingly, the additional ground raised by the assessee is dismissed. 110. In ground no. 1, the assessee has challenged the order of the Ld. CIT(A) in confirming the addition of ₹ 2,39,785/- made by the AO being interest on borrowed capital for house property. 111. After hearing both the sides, we find the above ground is identical to the ground of appeal no. 7 in ITA No.9149/Del/2019. We have already decided this issue and the ground raised by the assessee on this issue has been dismissed. Following similar reasoning, this ground of the assessee is dismissed. 112. In ground no.2, the assessee has challenged the addition of ₹ 1 lakhs made by the AO as unexplained money. 113. After hearing both the sides, we find the AO during the course of assessment proceedings noted that during the course of search at premises H. No.128, Sec 16, Faridabad, page 11 of Annexure A-1 was seized. It contains entry dated 14.04.2015 of ₹ 1,00, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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