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1.19. in the alleged 'Sauda Inkrarnama' i.e., undated, unsigned and un-witnessed, it was mentioned that the bank loan will be closed up by the seller group up to the cutoff date i.e., 15-9-17, however, this condition was also not fulfilled by the seller group, and the bank loan has, in fact, been closed up in the month of Mar, 2018 and thus, this condition has also not been complied with by the seller group;

1.20. it was also mentioned in the alleged 'Sauda Inkrarnama' i.e., undated, unsigned and unwitnessed, that all the pending statutory dues/ liability, pending returns/ statements and any amount dues, related to income-tax, sales tax, excise, GST, water tax and all other statutory dues till 15-9-17 to be borne by the seller group, but none of the terms & conditions has been fulfilled/ complied with by the seller Group; and thus, no act/ work done by the seller group (i.e., Seleno Steels) which is in consonance with the terms & conditions mentioned in the alleged 'Sauda Inkrarnama' i.e., undated, unsigned and un-witnessed, and thereafter, as on 1-10-17, it was agreed between both the parties that shares of M/s.Seleno Steels Ltd would be transferred to the family members of the assessee-Group at total sales consideration of Rs. 12.50 crores, which is also evident from the statement recorded on 24-10-17 to 26-10-17 u/s132(4) of the assessee-Sanjay Agrawal (the purchaser party) in which in Ans. to Que. No.12, it is said by the assessee that said Ikrarnama is fake, unknown to him and no cash transaction has been done with M/s. Seleno Steels Ltd, 1.21. and thereafter, in Ans. to Que.No.13, he again explained that from the meaning of 'fake', it only said that the purchase deal has been made at Rs.12.50 crores which has been duly accounted, instead of Rs.25 crores.