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TMI Blog2022 (11) TMI 368X X X X Extracts X X X X X X X X Extracts X X X X ..... t accepting the above view. Therefore, Ld. CIT(A) held that there is no reason to make any addition in hands of assessee-firm, as the addition in the hands of Shri Rajendrakumar Ramdas Patel (one of the partners of the assessee firm) was deleted. Accordingly, the impugned additions for assessment years 2011-12 and assessment year 2014-15 were deleted. That being so, we decline to interfere with the order of Ld. CIT(A) in deleting the aforesaid additions. His order on this addition is, therefore, upheld and the grounds of appeal of the Revenue of both appeals, are dismissed. Addition made on protective basis on account of cash seized - CIT-A deleted the addition - as per revenue actual effect of ROI filed in the case of Shri Rajendra Ramdas Patel for A.Y. 2014-15 wherein the income offered to tax on account of disclosure u/s. 132(4) has been reduced by claiming set off of unallowable bad debt and thereby substantially reducing incidence of tax on the income disclosed u/s. 132(4) of the Act - HELD THAT:- We note that during the appellate proceedings, the Ld. CIT(A) observed that assessing officer has made addition in respect of cash found during search action u/s. 132 at the pre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (iii) On the facts and circumstances of the case and in Law, the Ld. CIT(A) has erred in holding commission income @ 0.50% as commission or khep charges on the total amount noted and treating it as already offered in undisclosed income without any plausible reasons do so. (iv) On the facts and circumstances of the case and in Law, the Ld. CIT(A), Surat ought to have upheld the order of the Assessing Officer. It is, therefore, prayed that the order of the Ld. CIT(A)-4, Surat may be set-aside and that of the Assessing Officer's order may be restored. 4. The grounds of appeal raised by the Revenue in (IT(SS)A No. 03/SRT/2020, for assessment year 2014-15, are reproduced below: (i) On the facts and circumstances of the case and in Law, the Ld. CIT(A) has erred in deleting the addition amounting to Rs. 20,39,80,040/- on account of unaccounted income. (ii) On the facts and circumstances of the case and in Law, the Ld. CIT(A) has not appreciated the facts of the case properly, the notings in seized material decoded and deciphered by the assessing officer and more specifically the deliberate and complete failure on the part of the assessee to explain the content of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... section 143(2) u/s. 142(1) of the Act along with questionnaire was issued dated 21.12.2015 calling certain details and also requested to explain the page wise contents of the seized materials. 7. In response to the notices issued u/s. 153A and 142(1) of the Act, the assessee has attended and filed details and other documents before the Assessing Officer. The assessing officer noticed from the Form No. 3CD of Audit Report that the assessee firm was engaged in the business of Angadia Business i.e. Courier agent. During the course of search proceedings, certain loose papers were found and seized as per Annexure-PSR/1 to PSR/3 of Panchnama dated 27.03.2014. During the course of assessment proceedings, the assessee vide letter dated 8.01.2016 requested to provide copies of seized materials. Accordingly, copy of all the seized materials were provided to the assessee on 29.01.2016. The assessing officer noted that assessee has not submitted any explanation of seized materials; therefore, to understand the content of seized materials, summons u/s. 131 of the Act was issued to the assessee on 18.02.2016. In response to same Shri Dashratbhai Hargovindbhai Patel, one of the partner of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n as S.R. Courier. In answer to question No. 5, he also admitted that the amount of' Rs. 29,81,300/- which was found from the above business premise was unaccounted and undisclosed in the books of M/s. Patel Somabhai Ramdas Co. The cash seized from the premises was belonging to firm. As the seized document were recovered from the premises belonging to firm, they also belong, to M/s. Patel Somabhai Ramdas Co. 4. Statement of Shri Patel Rajendrakumar Ramdas, one of the partner of the assessee firm was recorded on oath u/s. 131 on 22.04.2014. He has stated that he is a partner of M/s. Patel Somabhai Ramdas Co. which is engaged in the money courier. Vide answer to question No. 4, he specifically stated that their business was also known as Angadia System which is old practice of transferring money, prevalent mostly in Gujarat, Maharashtra and across North India. He has further stated that his firm has branches across the country including this branch at Kolkata. The PAN of the firm is AADFP 1968 P. The search warrant was executed in the name of S.R. Courier and Patel Somabhai Ramdas Co. on 27.03.2014. It is pertinent to mention here that at the time of execution of w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... respective assessment years and added to assessee's total income for reasons stated vide above refereed to letter. In this regard it is submitted as under: 1. In para 2 of the above referred to letter it is stated that the search warrant was executed in the name of S.R. Courier and M/s. Patel Somabhai Ramdas Co. on 27/03/2014 at Kolkata. It is further stated that during the search proceedings certain loose papers were found and seized as per Annexure PSR/1 to PSR/3. In this regard it is submitted that the assessee has already produced before Your Goodself copy of the partnership deed, its visiting card, its books of accounts in support of the fact that the assessee is/was not having any branch or office at Kolkata. Moreover not a single piece of evidence was found which even suggests that the assessee firm was having its branch office at the above address. During the course of the assessment proceedings, Your Goodself has recorded statement of partner Dashratbhai Hargovanbhai Patel on 01.03.2016 wherein he had categorically stated that the assessee firm is/was not having any branch or office in Kolkata. The most important fact in this case is that in case of P ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... omadas Ramdas Co. is factually incorrect and the words In the books of Patel Somabhai Ramdas Co. are substituted in place of Nature . He never said that it is unaccounted for and in the books of M/s. Patel Somabhai Ramdas Co. for the sake of convenience answer No. 5 is reproduced below: A. 5. The amount of Rs. 29,81,300/- (Rupees Twenty Nine Lakhs Eighty One Thousand Three Hundred) only found from the business premise today is unaccounted for and undisclosed in nature. I do not have any books of accounts. Therefore, I have no objection to the seizure of the same. Regarding this cash found Shri Patel Rajendrakumar Ramdas categorically stated vide answer to question No. 8 recorded stated that the said cash belonged to him and is unaccounted. He also disclosed an amount of Rs. 50,00,000/- inclusive of the amount seized. The relevant question and answer of the statement recorded on 22.04.2014 is reproduced below; Q.9. Do you want to add, alter or modify the above statement? A. 9. Yes, I would like to voluntarily disclose Rs. 50 lakhs inclusive of the amount seized from my premise as additional income for taxation over above my last returned income. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... search proceeding. Not raising the objection on execution of warrant in name of the assessee firm will not change the fact that the assessee firm is not having branch or office at Kolkata. Moreover in response to notices u/s. 153A of the Act, in his case, he has filed the returns income. In the return of income filed for 2014-15, he has shown the income of Rs. 50,00,000/- which includes cash found and seized during the course of the search. Income tax department also believes, accepts the fact that (a) search was in the case of shri Patel Rajendrakumar Ramdas, (b) cash found during the cause of search belonged, owned by him (c) the material found during the course of search belonged to him, and on that basis initiates proceedings u/s. 153A in his case. 4. Vide para 5 it is observed that statement of Shri Dashratbhai Hargovanbhai Patel was recorded on 1/03/2016. In his statement he any knowledge of the search proceedings. He also expressed his inability to explain the contents of the seized documents and stated that the same can be explained by Patel Rajendrakumar Ramdas whose statement was recorded by ADIT (Investigation) Unit 3(1) Kolkata on 22/04/2014. Shri Dashratbhai also ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ding the said cash and covering the transactions carried on by him form that office, allegation that the loose paper found from the said premises does not belong to Shri Patel Rajendrakumar Ramdas and to the assessee firm is not justified. It is worth noting that in the case of Shri Patel Rajendrakumar Ramdas notices are issued u/s. 153A of the Act and the proceedings in his case are in progress. He has already filed his return of income for 2014-15 showing undisclosed income of Rs. 50,00,000/- owning the transactions carried out from the said premises. The assessee is not able to understand the stand taken by your goodself that the cash found from the said premises and the disclosure made by him in respect of the transactions done from the said office are belonging to him while the seized material from the said premises does not belong to him and it belongs to assessee firm. The assessee firm does not understand the logic of bifurcating the unaccounted cash found, disclosure as belonging to Shri Patel Rajendrakumar Ramdas and seize material belonging to assessee firm. The most reasonable approach is to accept the fact that the cash found during the course of the search and disclos ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssuming that they are noted after removing 3 zeros. There is no evidence even remote to presume that the said figures are coded. Has those figures been coded the authorized officers would have definitely decoded the same and would have taken a confession from the persons present at the time of the search and or appeared before them. The said figures could not be decoded, deciphered till 6 pm on 28/03/2016. This is evident from the fact that a show cause notice was issued to the assessee firm as to why the case of the assessee be not referred for special audit mainly and only for decoding deciphering and understanding properly the entries recorded in the seized material. The relevant portion of the said notice is reproduced: 6. I have gone through the seized documents and the statements recorded during the search and assessment proceedings. I am of the opinion that is a fit case for applying provisions of section 142(2A) of the Act, i.e. to direct the assessee to get the accounts audited by an Accountant for following reasons: a) The entries recorded in the seized documents are very complex. They contain voluminous coded entails i.e. name, amount and dates which 'deco ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s regard the assessee relies in the decision of Honourable ITAT, Ahmedabad in the case, of M/s. Patel Somabhai Kanchanlal Co. (ITA No. 842/Ahd/1984) in case of courier i.e. angadia the provisions of section 68, 69, 132(4A) are not applicable in the same way as is applicable in respect of loans and deposits as courier service is akin to postal services. Once it is proved that the parcels were received during the ordinary course of angadia business, no addition can be made In view of above your goodself is requested to not make addition as proposed in the show cause notice and oblige. 10. However, assessing officer rejected the contention of the assessee and observed that during the course of search proceedings certain loose papers were found and seized (as per Annexure-PSR/1 to PSR/3) and cash of Rs. 29,81,300/- was found. The amount of cash of Rs. 29,81,300/- has already been owned by one of the partners however no explanation about the content of seized material was given during the course of search or during the course of assessment proceedings. The document seized from the branch office belonged to the assessee and the responsibility to explain the content o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nted and undisclosed in books of accounts of firm. Learned DR further pointed out that Assessee firm has not produced one partner Shri Rajendrakumar Ramdas Patel as One Partner Shri Dashrathbhai Hargovanbhai Patel denies to have any knowledge about search proceedings and expressed his inability to explain the contents of seized documents and stated that same can be explained by other partner of the firm but not produced the partner during assessment proceedings, therefore in these circumstances addition made by the assessing officer may be sustained. 13. On the other hand, Shri Vartik Chokshi, Learned Counsel for the assessee vehemently argued that Shri Rajendrakumar Ramdas Patel appeared before the Ld. ADIT (Inv.) Kolkata and owned up the cash found in searched premises. He admitted and offered Rs. 50 Lacs as undisclosed income earned in his individual capacity from the activities carried out from that premises (including Rs. 29,81,300/- cash found). The Ld. ADIT(Inv.) has not probed, further, nor has he questioned in detail on seized material etc, implying that, he was satisfied that Rs. 50 Lacs declared adequately covers the undisclosed income earned from business activities ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vities in all its branches HO. Hence there is no reason to further make any addition and therefore Ld. CIT(A) has rightly deleted the high pitched addition. This way, Ld. Counsel prays the Bench that Ld. CIT(A) has passed a reasoned and speaking order therefore, the same may be upheld. 15. We have heard both the parties and carefully gone through the submission put forth on behalf of the assessee along with the documents furnished and the case laws relied upon, and perused the fact of the case including the findings of the Ld. CIT(A) and other materials brought on record. We note that assessee submitted before us the remand report under Rule 46A(1)/46A(3) of the Rules dated 01.10.2019, vide Page No. 69 to 71 of assessee's paper book. The Rejoinder to remand report dated 04.10.2019 is placed at paper book page Nos. 72 to 79. The copy of statement of Rajendera kumar Ramdas, recorded on 22.04.2014, is placed vide paper book page No. 80 to 81. The assessee also submitted copy of acknowledgement receipt of Return of Income, computation of income, balance sheet, profit loss account and capital account, vide paper book page Nos. 161 to 168. We note that during the appellate pro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... filed on 08.10.2015 showing same income as in original ITR. In response to show-cause notice dated 28.03.2016, assessee filed reply dated 30.03.2016. The assessee in para 5(a) claimed that the said premises from where the materials were found seized is not office/branch of the assessee firm and therefore the seized material cannot be presumed to be belonging to assessee firm. The Ld. assessing officer discussed this in para 6.3. The Ld. assessing officer mentions that Shri Patel Rajendrakumar Ramdas admitted that the firm has branches across the country including this branch at Kolkata. The Ld. assessing officer mentions that no explanation was offered regarding contents of seized material when the fact is, no question was asked to concern on seized material. Summons was issued to partner of assessee Shri Dashrathbhai appeared on 01.03.2016 and stated that the seized materials can be explained by Shri Patel Rajendrakumar Ramdas, whose statement was already recorded by ADIT (Inv.) Unit 3(1), Kolkata on 22.04.2014. Further, it is stated that Shri Patel Rajendrakumar Ramdas was admitted to Hospital and is in ICU, so he could not appear before Ld. assessing officer. It transpires t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee filed copies of the typical records maintained in course of business. Assessee also made its without prejudice claim, that even if the impugned loose sheets are treated as pertaining to assessee, the amounts mentioned therein cannot be totaled up and added as income. The assessee is in business of money courier service, the amounts noted in alleged loose sheets are the moneys received from consigners and paid to consignees. The assessee only gets the charges it collects over the amounts moved by it. He claimed that couriers services or angadia's charged Rs. 100-200 per Rs. 1 Lac moved by them. The Ld. assessing officer has not accepted this explanation, I have examined the same and I find typical records maintained by assessee in its business is totally different from loose sheets founds and seized at Kolkata premises and the Ld. assessing officer has missed this vital point. 7. It is seen that there was no questioning, over seized material by ADIT(Inv.), Kolkata either to Shri Rajendra or to employee Shri Upesh. It is seen from statement that the ADIT was satisfied that the cash found in the premises searched at Kolkata belongs to Shri Rajendrakumar Ramdas Pate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Investigation Wing to belong to Shri Rajendrakumar Ramdas Patel in his individual capacity and disclosure made by him covers the same, (ii) Even if the seized material is treated to pertain to business of assessee, then the income is to be estimated at Rs. 200 per Rs. 1 Lacs noted in seized material (without pre-judice plea of assessee). 10. The Ld. assessing officer is directed to examine seized materials, reports of ADIT and Investigation wing Kolkata assessment records and give factual findings regarding the facts, circumstances and arguments made in all the above paragraphs along with your comments. Your report may be furnished on or before 09.09.2019. 16. Then after, Ld. CIT(A) received the remand report from the assessing officer, vide assessing officer letter No. SRT/ITO/Ward-2(3)(8)/PSR Co/2019-20 dated 09.09.2019. Relevant portion of the remand report is reproduced below: 2. In this regard, your goodselfs has directed to examine seized materials reports of DIT (Investigation) Wing Kolkata assessment records and give factual findings and legal arguments (if any) regarding the facts, circumstances and discussion made in all assessment order. 3. Fro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the business of money courier also known as Angadia System which was old practice of transferring money, prevalent mostly in Gujarat, Maharashtra and across North India and also confirmed that his firm has branches across the country including this branch at Kolkata. It is pertinent to mention here that at the time of execution of warrant on 27.03.2014 and subsequently during the course of statement of the partners, nobody raised any objection to execution of warrant in the name of firm M/s. Patel Somabhai Ramdas Co. 5.2 During the course of assessment proceedings, a statement of Shri Dashratbhai Hargovindbhai Patel, one of the partner of the firm was recorded u/s. 131 on 01.03.2016, on being asked, to explain the content of the materials seized during the course of search at the branch office of M/s. Patel Somabhai Ramdas Co., at Kolkata, he expressed his inability to explain the contents of the seized documents and stated that same can be explained by his partner whose statement was recorded during the search proceedings. Therefore, the assessing officer had asked to him to produce Shri Patel Rajendrakumar Ramdas, whose statement was recorded by ADIT(Inv.), Kolkata ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rried on there from is owned by him. 6. The above mentioned facts and circumstances, during the course of assessment proceedings, the A.O. has not refused to accept the any submissions of the assessee, there is no such sufficient cause of the assessee (as per case records) for non-producing the required documents/evidences, and the A.O. had given sufficient opportunities during the course of assessment proceedings. Therefore, the assessing officer has correctly made additions for the both assessment years on account of unaccounted income. In view of the above facts and circumstance, the justification arrived by the Assessing Officer is reasonable and most judicious and therefore requires to be upheld. Therefore, your honour is kindly requested to dispose off the appeal on merits. 17. Then after, Ld. CIT(A) forwarded the Copy of Remand report dated 09.09.2019 to the assessee for comments/rejoinder. The Reply on the remand report furnished by the assessee, is reproduced below: 1. With regard to the above subject, the Assessee states that it is in receipt of calling report under rule 46A(1)/46A(3) of the I.T. Rules dtd. 23.08.2019 and remand report submitted by ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s. Patel Somabhai Ramdas Co. is also known as S.R. Courier. ASSESSEE'S COMMENTS: (i) The above comments/observation were made in the assessment order and are repeated in this report. In this regard it is submitted that the assessee contended that Upeshbhai Patel who was present at the premise at the time of search and whose statement was recorded, was not an employee of the assessee firm. In support of the same the assessee firm had produced its books of accounts and the particulars relating to salary paid to employees. It was found that the assessee had no employee namely Upeshbhai Ramanlal Patel in its payroll. Therefore his statement cannot be relied upon. (ii) Regarding the seized documents found from the premises of the firm, the assessee produced the copy of the partnership deed, its visiting card, its books of accounts in support of the fact that the assessee is/was not having any branch or office at Kolkata. As the assessee proved beyond doubt that the said premises was neither office nor branch of the assessee firm, the question that the seized documents belong to assessee firm does not arise at the first place. 2.4. assessing officer's COMMEN ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... from the said premises and also offers, discloses an amount of Rs. 5000000 including the cash and covering the transactions carried on by him from that office. ASSESSEE'S COMMENTS: (i) The Assessing officer himself have accepted the fact that vide his statement Shri Patel Rajendrakumar Ramdas accepted the ownership of the unaccounted cash of Rs. 29,81,300/- seized from S.R. Courier and also offered Rs. 50,00,000/- including the cash and covered all the transaction carried by him from S.R. Courier. Even the Assessing officer of Shri Patel Rajendrakumar Ramdas accepted the fact that (a) search was in the case of Shri Patel Rajendrakumar Ramdas, (b) cash found during the course of search belonged to owned by him (c) the material found during the course of search belonged to him, and on that basis initiated proceedings, completed assessments, and assessed cash and seized documents U/s. 153A in his case. The assessment of Shri Patel Rajendrakumar Ramdas was completed accordingly assessing the cash found unaccounted income of seized materials. (ii) No. 2 of the calling report dtd. 23.08.2019. Your Honour have observed and called report for the same. Perusal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g inaccurate particulars and concealment of income. ASSESSEE'S COMMENTS: (i) In the first part of para 5.3 the assessing officer has reported that the assessee could not produce Shri Patel Rajendrakumar Ramdas and all the contains/entries remained unexplained. The said observation was made in the assessment order and is repeated in this report. In this regard it is once again stated that the assessee firm was required to produce Shri Patel Rajendrakumar Ramdas by the second week of March 2016. During that period only Shri Patel Rajendrakumar Ramdas fell seriously ill as his kidneys were failed and he was on dialysis. Gradually due to many complications he went in coma and was on ventilator. Thus, he could not attend due to serious illness and ultimately died on 19.07.2016. (ii) With the regards to the assessee's submission regarding the reasons for not presenting Shri Rajendra Ramdas Patel, Your Honour has called for report for the following vide letter dtd 23.08.2019. The Ld. assessing officer did not make any effort to record the statement of Shri Rajendrakumar Ramdas either by travelling to Ahmedabad himself or by issuing commission. It transpires th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... transfer of money and valuables of the customers which varies from Rs. 100 to Rs. 200 per every Rs. 1,00,000/- which is verifiable from the regular books of accounts. The assessing officer only applied the prevalent trade practice and custom in angadia business at the time of decoding the figures of seized records and on the very next moment he ignores the income which Angadia derives from the said business i.e. commission. Thus adding the entire sum of figures to determine income is unfair, unjust and against the principles of natural justice. (iii) Further Your Honour has vide para No. 6 of letter dtd. 23.08.2019 called for the report for the following. During assessment the assessee filed copies of the typical records maintained in course of business. The assessee also claimed that if the impugned loose sheets are treated as pertaining to assessee the amounts mentioned therein cannot be totalled up and added as income. The amounts noted in the alleged loose sheets are the money received from consigners and money paid to consignees. The assessee only gets the charges it collects over the amounts moved by it. He claimed that courier services or angadias charge Rs. 100- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a whole. It only shows that ADIT (Inv) Kolkata and higher officers in investigation wing were of opinion that the cash seized material belongs to Shri Rajendra Ramdas Patel the disclosure made fairly covers both the cash the seized material. The Assessing officer failed to offer any clarification or comments in its report on the above observation. The assessee has already discharged its onus by proving beyond doubt that the seized documents did not belong to assessee firm and the said fact was also accepted by the investigation wing Kolkata and therefore no adverse action was taken by them. 2.8 Your Honour observed vide para No. 9 of the letter dtd 23.08.2019 as under and called for report for the same from the Assessing officer. From the above facts and circumstances and the discussion made it is clear that 1. The cash seized material is accepted by ADIT (INV) higher officer in investigation wing to belong to Shri Rajendrakumar Ramdas Patel in his individual capacity and disclosure made by him covers the same. 2. Even if the seized material is held to pertain to business of assessee then the income is to be estimated at Rs. 200 per Rs. 1 lac no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ctivities carried on from the said premises in Kolkata including the notings found in incriminating seized material. The search action is minutely monitored by Addl. DIT (Inv.) and DIT(Inv.), hence absence of further enquiry, and absence of any consequent action u/s. 132 etc, shows that the higher authorities in the Investigation Wing Kolkata were of same considered opinion. (ii) Shri RRP filed ITR disclosing this income Jurisdictional assessing officer at Ahmedabad has made assessment accordingly as discussed in para 3 of my letter dated 23.08.2019 supra. So it is clear that cash found seized material found in searched premises at Kolkata have been owned up and resultant income is offered to tax and assessed accordingly in hands of Shri RRP as concluded in para 7 of my letter dated 23.08.2019 (supra). The Ld. assessing officer in his remand report vide para 5.2 and again in 5.5 has also given the same finding. (iii) The Ld. assessing officer of assessee firm gives finding that the assessee firm is engaged in business of 'angadia' or money courier services as evident from his interpretation of figures noted in seized material (ref para 6.1 show cause notice of Ld. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessment years and this has been accepted by both Investigation-Wing assessing officer at Ahmedabad. The assessing officer of assessee firm at Surat has deviated from this view, however, he has not given/placed on record any cogent evidences or given any discernible line of reasoning. There is no whisper in assessment order, as to the reason for not accepting the above view. Therefore, Ld. CIT(A) held that there is no reason to make any addition in hands of assessee-firm, as the addition in the hands of Shri Rajendrakumar Ramdas Patel (one of the partners of the assessee firm) was deleted. Accordingly, the impugned additions for assessment years 2011-12 and assessment year 2014-15 were deleted. That being so, we decline to interfere with the order of Ld. CIT(A) in deleting the aforesaid additions. His order on this addition is, therefore, upheld and the grounds of appeal of the Revenue of both appeals, are dismissed. 20. In ground No. 4 in the Revenue's appeal in (IT(SS)A No. 03/SRT/2020, for assessment year 2014-15, the main grievance of the revenue is that the Ld. CIT(A) has erred in deleting the addition made by the assessing officer on protective basis amounting to Rs ..... X X X X Extracts X X X X X X X X Extracts X X X X
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