Indian Kanoon - Search engine for Indian Law

On the issue of approval u/s 153D the assessee relies on the submissions given supra for AY 2005-06.

The grounds on interest u/s 234A/B/C are consequential in nature."

15.4.1 Revenue's submissions are as under :

" Assessment Year 2008-09 (ITA No.779/Bang/2015) i. During the course of search it was found that Mrs Snehalatha Singhi entered into raising and processing contracts with mine owners M/s.Karthikeyas Manganese and Iron Ores Pvt Ltd (KMIORE) and Mrs.Ambika Ghorpade (AKG). The processed ore was handed over by ITA Nos.911, 912, 779 to 781, 1106 & 1113/Bang/2015 Mrs Snehalatha Singhi to the mine owners and the mine owners in turn sell the ore to the entities owned by Mr.DineshKumar Singhi i.e Bharat Mines and Minerals and BMM Ispat. The mines KMIORE belongs to Mr.Karthik M Ghorpade and and his wife Mrs Ambika Ghorpade. The mines have been termed as new mines (NM) and old mines (OM) as per the timing of start of the mining lease of two mines. The profit has been shared between the mine owners and the assessee in the ratio of 70: 30.

23. iii. On analysis of the entire documents and the statements, it is clear that: -

a. BMM group is carrying on the activity of extraction, excavation and processing of iron ore in the mines of KMIORE and AKG in the name of Mrs Snehalatha Singhi.

b. The entire quantity of iron ore with and without permits is purchased by BMM group and the same has been admitted by sellers and the purchasers.

M/s.Karthikeyas Manganese and Iron Ores Pvt Ltd (KMIORE) and Mrs.Ambika Ghorpade (AKG). The processed ore was handed over by Mrs Snehalatha Singhi to the mine owners and the mine owners in turn sell the ore to the entities owned by Mr.DineshKumar Singhi i.e Bharat Mines and Minerals and BMM Ispat. The mines KMIORE belongs to Mr.Karthik M Ghorpade and his wife Mrs Ambika Ghorpade. The mines have been termed as new mines (NM) and old mines (OM) as per the timing of start of the mining lease of two mines. The profit has been shared between the mine owners and the assessee in the ratio of 70: 30.

iii. On analysis of the entire documents and the statements, it is clear that: -

a. BMM group is carrying on the activity of extraction, excavation and processing of iron ore in the mines of KMIORE and AKG in the name of Mrs Snehalatha Singhi.

b. The entire quantity of iron ore with and without permits is purchased by BMM group and the same has been admitted by sellers and the purchasers.

c. Sellers have admitted cash payments reflected in the seized materials received from Shri Dinesh Kumar Singhi.