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4. During the course of search proceedings at the office premises of NKPL, blank signed cheque books and vouchers of number of concerns were found. Endorsed blank cheques of NKPL by these concerns were also found from the office premises of NKPL. Endorsement was on the back of the cheques. Blank bill books, letter heads and vouchers of these concerns were found and seized from the factory premises of NKPL. These documents found and seized from the premises of NKPL relate to various parties as discussed in para 6 of the assessment order. Purchases made from these concerns have been treated by the AO as bogus purchases in view of elaborate reasons recorded in the assessment order. Copies of bank accounts of these bogus parties were also obtained from the respective banks. The entire deposits in the bank accounts of these parties were treated as assessee's income on protective basis. It. has been observed in the assessment order that inquiries are being conducted to find out the names of concerns which made these payments for purchases and other expenses to these parties. Substantive additions/disallowances will be made in those concerns after conclusion of inquiries. However, these additions were made protectively in the case of the assessee as "additions made as unaccounted payments". The summary of such additions made on account of bogus purchases and in respect of deposits in the bank accounts of these parties as given on p. 9 of the order passed by the CIT(A) are as under :

Q. 8 I am showing you loose paper file A/22 pp. 93 to 97 which has been seized from the 9th floor office of N.K. Proteins Ltd. during the income-tax search. These are blank cheques of account No. 4046 of Visnagar Nagrik Sahakari Bank Ltd., Usmanpura Branch in the name of Karnavati Industries Have you signed on these cheques?
Ans. Yes, I have signed on these blank cheques.
Q. 9 Now I am showing you loose paper file A/22 pp.-82 to 91 which are cheques of Visnagar Nagrik Sahakari Bank Ltd., Usmanpura Branch pertaining to N.K. Proteins Ltd. Have you signed on back of these cheques?

2.5.3 The purchases can be considered as bogus when the identity of the supplier is not established and goods are not received. In the present case, the identity of the supplier is established inasmuch as some of them have filed the affidavits and some of them have given statements. The goods purchased are actually received and the payment is made by cheque. The suppliers hold sales-tax number and such number is printed on bills. The AO has not made any inquiry with sales-tax department.

2.5.4 Certain blank cheques, bills, vouchers, etc. were found from the factory premises of the company. In this connection, it may please be noted that the blank cheques/bills were kept at the factory premises of the company for the sake of convenience.

3.3 Signature of Shri Jaysukhlal Doshi on sales bills and those on blank cheques are not same. It appears that sales bills have been signed by somebody other than Shri Doshi. Sample copy of sales bills of M/s Adinath Corporation and M/s Tirupati Corporation have been filed by the Authorised Representative of the assessee on page No. 139 and 142 of its paper book dt. 1st July, 2002.
3.4 It may be seen from the bank a/c which is on page No. 63 of assessee's paper book mentioned above that cash has been withdrawn on same date as and when cheques are deposited in the bank account. Cheques bearing Nos. 74301 to 74341 have been used for withdrawal of cash as is apparent from the above bank a/c statement and the Department has seized signed blank cheques of above concerns from 74342 to 74345 which shows the control over cheque books of M/s Adinath Corporation.