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3. At the time of hearing, Ld. counsel for the assessee stated that the addition in dispute has been made in respect of the share capital receipt received by the assessee which was subscribed by the Corporate Entity except (one individual) at premium. He draw our attention towards the details of the same. He further stated that the original assessment in respect of each of the year in dispute has been completed u/s. 153A/143(3) of the Act on 30.3.2014. The only addition made with reference to the share capital and share premium received in the respective assessment year which fact has already been accepted in the original assessment. He further stated that at the time of search and seizure no incriminating material was found inspite of the fact that the AO had made the addition in dispute on the basis of post search enquiry and on the evidence already available on record which was produced by the assessee at the time of filing the return. He draw our attention towards the order of the AO at Page 3 and stated that the addition has been made on the basis of the material already on record and not on the basis of any incriminating material. It is only for the reason of making enquiries after the conduct of search and during the course of assessment proceedings carried out in pursuance to section 153A, the AO formed an opinion expressing his doubt regarding genuineness of share capital and creditworthiness of entities which have invested share capital with the assessee, therefore, the same has been added to the income of the assessee. He further submitted that the addition otherwise is not maintainable even on merits as there exists sufficient documentary evidence to prove the genuineness of share application money, it is also the case of the assessee that these assessments being completed assessments, addition on account share application money could not be made in absence of any incriminating material having been found during the course of search. In support of contention, he filed a Paper Book containing pages 1 to 335 in which he has attached the copy of various documentary evidences which were available before the authorities below i.e. show cause notice u/s. 153A /143(2) dated 19.11.2013; reply to show cause notice dated 19.11.2013; assessment orders u/s. 143(3) for AY 2007-08 to 2009-10; entity wise and assessment year wise evidence of share capital and share premium (AY 2007-08) confirmation of M/s Poddar Aircom Pvt. Ltd.; Application form for equity shares of M/s Poddar Aircon Pvt. Ltd; Memorandum and Articles of Association of M/s Poddar Aircom Pvt. Ltd; Certificate of Incorporation of M/s Poddar Aircom Pvt. Ltd; Board Resolution of M/s Poddar Aircom Pvt. Ltd.;Auditor's Report of M/s Poddar Aircom Pvt. Ltd With Balance Sheet & P&L A/C; Share Certificate M/s Poddar Aircom Pvt. Ltd; M/s Saraosi Commercial Pvt. Ltd.; Confirmation of M/s Saraogi Commercial Pvt. Ltd. Application Form For Equity Shares of M/s Saraogi Commercial Pvt. Ltd.; Certificate of Incorporation of M/s Saraogi Commercial Pvt. Ltd.; Cheques Issued By M/s Saraogi Commercial Pvt. Ltd. to Assessee Ledger Report of M/s Saraogi Commercial Pvt. Ltd.; Acknowledgment of e-retum of M/s Saraogi Commercial Pvt. Ltd.; Auditor's report with balance sheet & P&L A/C of M/s Saraogi Commercial Pvt. Ltd.; Share Certificate of M/s Saraogi Commercial Pvt. Ltd.; M/s Hooslv Vinimay Pvt. Ltd.; Confirmation by M/s Hoogly Vinimay Pvt. Ltd.; Courier details of reply to notice u/s 131 of M/s Hoogly Vinimay Pvt. Ltd.; Form of application for equity shares for M/s Hoogly Vinimay Pvt. Ltd.; Transaction statement of M/s Hoogly Vinimay Pvt. Ltd.; ITR for A.Y 2007-08 of M/s Hoogly Vinimay Pvt. Ltd.; Director's report of M/s Hoogly Vinimay Pvt. Ltd.; Auditors report of M/s Hoogly Vinimay Pvt. Ltd. with balance sheet p& L A/C; Certificate of registration by RBI of M/s Hoogly Vinimay Pvt. Ltd.; Memorandum & Articles Of Association of M/s Hoogly Vinimay Pvt. Ltd.; Share Certificate of M/s Hoogly Vinimay Pvt. Ltd.; M/s NKP Holdings Pvt. Ltd; Furnishing Information u/s 131 of M/s NKP Holdings Pvt. Ltd; Courier Receipt of reply to section 131 Notice by M/s NKP Holdings Pvt. Ltd; Transaction Statement of M/s NKP Holdings Pvt. Ltd; Form of Application of M/s NKP Holdings Pvt. Ltd; Memorandum And Article of Association of M/s NKP Holdings Pvt. Ltd; Certificate of Registration of M/s NKP Holdings Pvt. Ltd; Certificate of Incorporation of M/s NKP Holdings Pvt. Ltd; Courier Details of M/s NKP Holdings Pvt. Ltd; ITR of M/s NKP Holdings Pvt. Ltd For A.Y 2007-08; Directors report of M/s NKP Holdings Pvt. Ltd; Auditors report of M/s NKP Holdings Pvt. Ltd Balance Sheet and P & L A/C; Account statement of M/s NKP Holdings Pvt. Ltd; Share Certificate of M/s NKP Holdings Pvt. Ltd; (ASSESSMENT YEAR 2008-09) M/s Disha Medical Systems Pvt. Ltd.- Applications of shares by M/s Disha Medical Systems Pvt. Ltd.; Auditors report of M/s Disha Medical Systems Pvt. Ltd. With Balance Sheet and P & L A/C; Account statements of M/s Disha Medical Systems Pvt. Ltd.; Confirmation of Accounts of M/s Disha Medical Systems Pvt. Ltd.; Letters of allotment of shares to M/s Disha Medical Systems Pvt. Ltd.; List of allotment of shares to M/s Disha Medical Systems Pvt. Ltd.; Share Certificate of M/s Disha Medical Systems Pvt. Ltd.; Memorandum And Article Medical Systems Pvt. Ltd; (Sh. Ram Pal) Share application forms of Sh. Ram Pal; Confirmation from Sh. Ram Pal along with affidavits; Share Certificate of Sh. Ram Pal (ASSESSMENT YEAR 2009-10) M/s Disha Medical Systems Pvt. Ltd.Confirmation of M/s Disha Medical Systems Pvt. Ltd.; Application form for shares from M/s Disha Medical Systems Pvt. Ltd.; Bank statement of M/s Disha Medical Systems Pvt. Ltd.; ITR of M/s Disha Medical Systems Pvt. Ltd. for A.Y 2009- 10 With Balance Sheet and P & L A/C; Auditors report of M/s Disha Medical Systems Pvt. Ltd; Confirmation of accounts of M/s Disha Medical Systems Pvt. Ltd; Letter of allotment of shares of M/s Disha Medical Systems Pvt. Ltd; Reply of notice u/s 131 of the Income Tax Act 1961 by M/s Shevin Advisory Services Pvt. Ltd. along with courier receipt; Form of application for equity shares of M/s Shevin Advisory Services Pvt. Ltd; Share Certificate of M/s Disha Medical Systems Pvt. Ltd.M/s Shevin Advisory Services Pvt. Ltd.; Bank statement of M/s Shevin Advisory Services Pvt. Ltd; Computation of Income of M/s Shevin Advisory Services Pvt. Ltd; Auditors report and directors report of M/s Shevin Advisory Services Pvt. Ltd along with balance sheet and P & L A/C; ITR of M/s Shevin Advisory Services Pvt. Ltd for A.Y. 2009-10 and share Share Certificate of M/s Shevin Advisory Services Pvt. Ltd. In support of his contention, he stated that the legal issue in dispute viz. absence of incriminating material having been found during the course of search, addition could not have been made by the AO which is squarely covered by the decision of the Hon'ble Delhi High Court in the case of CIT vs. Kabul Chawla (2015) 61 taxmann.com 412 (Delhi) vide order dated 28.8.2015, wherein the Hon'ble High Court has held that if the additions are made, but not based on any incriminating material found during search operation, then these additions are not sustainable in the eyes of law. Ld. counsel for the assessee also submitted a copy of Case Status of the Supreme Court Of India in the case of CIT vs. Kabul Chawla wherein, it has been mentioned that Civil Appeal No. 6415 of 2016 has been dismissed vide order dated 17.9.2018.