before
AO), does not match with the gross sales reflected in impounded documents
(Annexure C-1, C-2, and C-3) which are receipt books ... reliability and
credibility of such recorded figures emerging from the impounded digital records
(impounded documents).One of the two partners , present at the premises
relating to purchase of a plot of land , information flowing from
impounded document Annexure A - 3.
4. The assessee's husband Mr. Anil Kapahi ... matter of this appeal.
5. The nature and character of the impounded document has been described as a
plane, unsigned, piece of white typed paper
Asstt. Years
2008-09 & 2009-10, based on the impounded documents ignoring the fact
that the surrendered amount has never been assigned ... have been made in Asstt. Year
2008-09, based on the impounded documents ignoring the fact that the
surrendered amount has never been assigned
hostel building and no such
hostel income whereas the documents impounded during survey
operation on 03.03.2009 mention hostel income ... explain
the difference in total receipts and expenditure as per the impounded
documents and as per books of account furnished. The assessee is a school
discrepancies, if any, found relating to the alleged incriminating
documents impounded during the survey.
6. (a) That in the facts and circumstances of the case ... aforesaid Satguru Foundation. On the basis of the
impounded documents, the Assessing Officer initiated reassessment
proceedings by issue of notice under section 148 of Income
which included an
addition of Rs.1.80 crores flowing from impounded documents relating to sundry
debtors and partners slips and an addition ... addition of Rs.1,80,00,000/- on the basis of impounded
documents found out during survey operation as shown below.
A-1(Slip
recorded statement of the assessee and on the
basis of the documents impounded during survey, he made an addition ... assessee. This addition was also made on the basis of documents
impounded during the survey. Further, addition of Rs.15 lacs was made
course of survey,
vis a vis explanation regarding entries contained in impounded documents in
Annexure A-1 and A-2 , consisting of loose sheets ... loose papers and documents ,
diaries , impounded as per Annexure - 1 and 2 ( of impounded documents ) points to
the fact that there has been unrecorded transactions
assessed accordingly in
their respective capacity in due course and the impounded documents if any gathered
in course of survey from the respective business premises ... impounded
in form of registers and annexures as stated in the remand report, has been collected
from the four separate units, and the impounded documents
assessed accordingly in
their respective capacity in due course and the impounded documents if any gathered
in course of survey from the respective business premises ... impounded
in form of registers and annexures as stated in the remand report, has been collected
from the four separate units, and the impounded documents
