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For these and other grounds that may be adduced at the time of hearing, it is prayed that the Order of the learned Commissioner of Income Tax (Appeals) be set aside and that of the Assessing Officer be restored.

3. The brief facts of the case are that there was a Survey u/s. 133A of the Income Tax Act, 1961 conducted in the business premises of M/s. GSNR Rice Industries P Ltd (formerly known as M/s. SNR Rice Industries P Ltd) on 30.01.2018. During the course of survey proceedings, several incriminating materials were found. These include (i) Diary (impounded as "Ann.SNR/PVD/B&D/Diary- S.no.2"); (ii) Note book (impounded as "Ann.SNR/PVD/B&D/Diary-- S.no.6"); (iii) loose sheets (impounded as Ann.SNR/PVD/B&D/LS- 1--44&45"); and (iv) Computer CPU, laptop, pen drives etc. Analysis of these materials revealed that the above diary (Ann.SNR/PVD/B&D/Diary-S.no.2) contained noting (in Tamil) showing cash receipts Rs.5.80 crores from Xl' during the F.Y.2010- 11 and cash receipts Rs.6.50 crores during the F.Y.2011-12. Further, in the Note book (Ann.SNR/PVD/B&D/Diary--S.no.6) at Page no.28 it was mentioned that Rice stock - Rs.17 lakh, Cash received from Minister - Rs. 16,23,90,000/- and at Page no.31 Money from Minister - Rs.16,24,00,000/-. Similarly, Loose sheets marked as (Ann.SNR/PVD/B&D/LS-1 -- 44&45) contained details of expenditure Rs.3,00,30,312/- relating to DMK 10th Maanila Maanadu (DMK 10th State level conference) held in 2013-14. The Computer CPU was sent to Forensic examination and Forensic imaging of the CPU was done and the deleted data was retrieved and analyzed. The retrieved data was relating to the assessee transactions, maintained in 'Tally' software. The data was compared with the assessee regular books of accounts and found that the following transactions (found in the retrieved 'tally' software) were not reflected in the regular books of accounts.