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43/Mum/2010], Saf Yeast Co. Pvt. Ltd. v ACIT {ITA 1074/PN/2007], B.R. Machine Tools P. Ltd. v ACIT {ITA 4174 to 4177/Mum/2013], Gurinder Singh Bawa [ITA No. 2075/Mum/2010], Raksha Chhadwa v ACIT {ITA no. 8576 & 8577/Mum/2010] ands Monoplan Securities Pvt. Ltd. v DCIT (ITA No: 5174/Mum/2007).
The facts of the case are that a search action was carried out on 06.03.2018 u/s 132 of the Act at the premises of M/s D'décor Export group and M/s. D'decor Home Fabrics group. The appellant belongs to D'décor Export group. The D'eccor Export group is managed and operated by Shri Sanjay Arora whereas M/s. D'decor Home Fabrics group is managed and operated by Shri Ajay Arora, Both these groups are managed and operated by two different individual. The offices of these two groups are located at different floors of same building. Employees of these two groups are different and there is no common employee working for both group. The nature of products manufactured by both the group are different in their quality, style and design. In the case of M/s. D'décor Home Fabrics group, a document containing receipt of cash on sale of old loom machinery was found and seized from premises of M/s. D'décor Home Fabrics group. The statement of Shri Sandeep Galagali, an employee of D'décor Home Fabrics group was recorded during the ITA NOs. 1050, 1051, 1052 & 1053/MUM/2021 & other appeals D'Decor Exports Pvt. Ltd., search, in which he admitted having received cash over and above the cheque receipts on sale of the old machinery by D''décor Home Fabrics group.

(ii) Sampa Balaram Das The services rendered by M/s. Tanushree Arts is of mending on schifli embroidered fabrics. Statement of Smt. Sampa Balaram Das was recorded u/s131 of the Act. Copy is filed at page 176 to 179 of paper book. The operative part of the statement recorded are stated as under:

"Q9. Please state the detail of your business activities and the address of your business office "

Ans. Sir, I have a proprietary business in the name of M/s. Tanushree Arts. As per my knowledge, M/s. Tanushree Arts is in the business of contract work of embroidery work which is of mending of embroidered fabrics and address of the business office is my residence itself. And Sir, all the business activities is managed by husband Shri Balaram Das and I do not know all the details of the business activities"

(iii) Sheela Singh The Appellant has availed the services of M/s. Shiv Shakti Enterprises who provides laborer to the Appellant for dyeing of fabrics. Bills have been raised by M/s. Shiv Shakti Enterprises on the dyeing work done on the fabrics. Statement of Smt. Sheela Singh was recorded u/s 131 of the Act. Copy of statement is at page 180-185 of paper book. The operative part of the statement recorded are stated as under:

"Q.5) Please give details of your source of income and do you file return of income?
Q. 10 Please state the name of all the companies to which you have supplied labour during last 6 years.
Ans. I have supplied labour to D'decor HOME Fabrics Private Limited and D'decor Export Private Limited and Agatpal Industries Private limited. All these 3 companies are situated at Boisar, MIDC"
(iv) Manjula Devi Jha:
The services rendered by M/s Jai Ambe Enterprises is mending of Multi Embroidered fabrics Statement Smt. Manjula Devi has been recorded u/s 131 of the Act is filed at page 186 to 188 of paper book wherein she has admitted that she provides laborers to the assessee. The question and answer reads as under: