brick kiln and the total turnover of
the basis of impounded documents, estimated at Rs.
19335724/- + 3170795/- = 2,25,06,519/-. The average of sale ... loose papers containing pages 1-86 were impounded
and certain pages of impounded document related to M/s
Sugan Gram Udyog Mandal, for example Page
service
was an adhoc figure and after going through the impounded
documents, unexplained deposits aggregated to the tune of Rs. 28.30
crores and, therefore ... crores from the
other additions based upon the impounded documents.
11. The AO rubbished the claim of the assessee by observing that the
assessee
During the course of
survey various incriminating documents were found and some of the
documents were also impounded.
2.3 In this connection, the AO stated ... records were also impounded from the premises D-
6, Anupam Plaza, Azad Apartments, Hauz Khaas, New Delhi. From the
impounded documents, it was noted that
indicate that the
document belonged to the assessee. In the document the details
of rent are noted which indicate that the document belonged ... submissions made before authorities below as well
as referred to impound documents and statement of Sh. Ravinder
Singh recorded by the AO and submitted that
2007 to the appellant
in which he has referred the impounded documents. On appreciation of
entries recorded in the impounded document (Annexure A-10 being ... impounded
material commission is Rs.45,10,874/-. Against this commission claim
of expenses is made based on the entries contained in impounded
documents
asked to furnish
various details including explanation/detail in respect of
documents seized /impounded from the residence of the
assessee, residence of Shri ... reasons as to why the
transactions recorded on the above seized/impounded
documents should not be treated as unexplained and be added
as undisclosed income
impounded. In his statement recorded on the date of survey i.e. 04/12/2003,
vide question No. 19, he was shown the impounded documents ... various aspects of business in detail and also
identifies the various documents impounded from the premises
and gave a brief overview of them. Also
action of the AO in
making addition on the basis of impounded documents.
(ii) On the facts and circumstances of the case, the learned ... from the above discussion, I hold that on the basis of
impounded documents which relates to two assessment years
expenditure of Rs. 33539332/-
c. disallowance of expenses in view of impounded documents of
Rs. 100051049/-
6. Above disallowances were challenged before ... when the
survey was conducted, as it was part of the impounded documents.
He further submitted that the details was submitted before the Ld.
assessing
explained that the said transactions contained in
the impounded documents in respect of Shri Bharatpal (who was director of M/s
GWC infrastructure ... argued that the transaction
contained in the referred material of the impounded documents were having no
relation with the appellant except in the capacity
