Smt. Ritaben R.Patel, Ahmedabad V. The Dy.CIT.,Cent.Circle-1(3), Ahmedabad

ITSSA 663/AHD/2011

• Counselvise Citation: [2015] 122 COUNSELVISE.COM (IT) 0715 (ITAT-AHMEDABAD)
• Duration Of Justice: 3 year(s) 3 month(s) 29 day(s)
• Appeal Type: Income Tax (Search & Seizure) Appeal
• Pronouncement Date: 17-04-2015
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Next Hearing Date: 07-04-2015
• Assessment Year: 2007-2008
• Appeal Filed On: 19-12-2011
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: DINESH SINGH
• Assessee Lawyers: SANJAY VASTUPAL
• Keywords: Corroborative evidences
• Section: 27

Judgement Text

IT(SS)A NOS. 661 TO 672/AHD/2011 PREMANAND S. PATEL AND OTHERS VS. DCIT 1 , , , , IN THE INCOME TAX APPELLATE TRIBUNAL A BENCH, AHMEDABAD BEFORE SHRI G.D. AGRAWAL, VICE PRESIDENT AND SHRI S. S. GODARA, JUDICIAL MEMBER ITA/IT(SS)A/CO NO. AY APPELLANT RESPONDENT IT(SS)A NO. 661/AHD/2011 2007-08 PREMANAND SOBHAI PATEL, CHANDRA PREM, PRERNA PARK, OPP. L.G. HOSPITAL, MANINAGAR, AHMEDABAD PAN : AFVPP 8305 F DCIT, CENTRAL CIRCLE- 1(3), AHMEDABAD IT(SS)A NO. 662/AHD/2011 2007-08 ARVIND NATVERBHAI PATEL, ASHIRWAD, 8, RADHANPUR SOCIETY, NR. SWAMINARAYAN TEMPLE, RAMBAUG, MANINAGAR, AHMEDABAD PAN : ACNPP 2156 M REVENUE IT(SS)A NO. 663/AHD/2011 2007-08 RITABEN RAKESHBHAI PATEL, 48, PREMSAGAR, JAGABHAI PARK, OPP LG HOSPITAL, MANINAGAR, AHMEDABAD PAN : ABRPP 6410 H REVENUE IT(SS)A NO. 664/AHD/2011 2007-08 RAKESH DAHYABHAI PATEL, 48, PREMSAGAR, JAGABHAI PARK, OPP LG HOSPITAL, MANINAGAR, AHMEDABAD PAN : AAWPP 6152 C REVENUE IT(SS)A NO. 665/AHD/2011 2007-08 DAHYABHAI S. BHAGAT, AMARJYOT, PRERNA PARK, OPP LG HOSPITAL, MANINAGAR, AHMEDABAD PAN : AAWPP 6157 H REVENUE IT(SS)A NO. 666/AHD/2011 2007-08 ATULBHAI DAHYABHAI PATEL AMARJYOT, PRERNA PARK, OPP LG HOSPITAL, MANINAGAR, AHMEDABAD PAN : ABHPP 4100 G REVENUE IT(SS)A NO. 667/AHD/2011 2007-08 SEJALBEN ATULBHAI PATEL AMARJYOT, PRERNA PARK, OPP LG HOSPITAL, MANINAGAR, AHMEDABAD PAN : ABHPP 4100 G REVENUE IT(SS)A NOS. 668 TO 672/AHD/2011 2003-04 2004-05 2005-06 2007-08 ONILBHAI NATVARBHAI PATEL, VIRAL, 5/B, GOKUL PARK SOCIETY, OPP. PARIMAL HOSPITAL, MANINAGAR, AHMEDABAD PAN : AAWPP 6158 J REVENUE IT(SS)A NOS. 661 TO 672/AHD/2011 PREMANAND S. PATEL AND OTHERS VS. DCIT 2 IT(SS)A NO. 672/AHD/2011 2007-08 BHARTIBEN ONILBHAI PATEL, VIRAL, 5/B, GOKUL PARK SOCIETY, OPP. PARIMAL HOSPITAL, MANINAGAR, AHMEDABAD PAN : ABHHP 4102 E REVENUE ASSESSEE(S) BY : SHRI SANJAY VASTUPAL, AR REVENUE BY : SHRI DINESH SINGH, SR. DR / // / DATE OF HEARING : 07 /04/2015 !'# / // / DATE OF PRONOUNCEMENT: 17/04/2015 $% $% $% $%/ // / O R D E R PER G.D. AGRAWAL, VICE PRESIDENT: THIS BUNCH OF APPEALS BY THE DIFFERENT ASSESSEES HA VE BEEN FILED AGAINST A CONSOLIDATED ORDER OF LEARNED CIT(A)-III, AHMEDABAD DATED 18.10.2011. SINCE THESE APPEALS INVOLVE COMMON ISS UES, THESE WERE HEARD TOGETHER AND ARE BEING DISPOSED OF BY THIS CONSOLID ATED ORDER FOR THE SAKE OF CONVENIENCE. 2. THE ONLY COMMON GROUND RAISED IN ALL THESE APPEA LS BY VARIOUS ASSESSEES IS AGAINST THE CONFIRMATION OF THE PENALT Y LEVIED U/S 271(1)(C) BY THE LD. CIT(A). THE NAME OF THE ASSESSEES, ASSETS WHICH ARE TREATED AS UNEXPLAINED AND THE PENALTY LEVIED ARE TABULATED AT ANNEXURE-1 APPENDED HEREWITH THE ORDER. 3. AT THE TIME OF HEARING BEFORE US, THE LD. COUNSE L FOR THE ASSESSEE ARGUED AT LENGTH. HIS MAIN SUBMISSION WAS THAT THE GOLD ORNAMENTS WERE ACQUIRED BY THE VARIOUS ASSESSEES AND THEIR SPOUSE AND CHILDREN IN THE PRECEDING YEAR. THE ASSESSING OFFICER TREATED THE S MALL PORTION OF THE GOLD ORNAMENTS AS UNEXPLAINED MERELY BY PARTIALLY ACCEPT ING ASSESSEES EXPLANATION. THE ASSESSEE HAD EXPLAINED TOTAL GOLD ORNAMENTS FOUND FROM EACH AND EVERY ASSESSEE. HE FURTHER SUBMITTED THAT SOME GOLD ORNAMENTS IT(SS)A NOS. 661 TO 672/AHD/2011 PREMANAND S. PATEL AND OTHERS VS. DCIT 3 ARE ALSO RECEIVED BY THE MEMBERS OF THE FAMILY AS G IFTS, ETC. ON VARIOUS OCCASIONS FROM THEIR IN-LAWS AND OTHER RELATIVES FR OM TIME TO TIME. SOME PART OF THE GOLD ORNAMENTS MIGHT HAVE BEEN ACQUIRED BY THE ASSESSEES IN THE PRECEDING YEAR. HE FURTHER SUBMITTED THAT ALL THE A SSESSEES AND THE FAMILY MEMBERS HAVE SUFFICIENT INCOME FROM PAST MANY YEARS AND SUBSTANTIAL WITHDRAWAL FOR HOUSEHOLD EXPENSES. HE ALSO SUBMITT ED THAT THE ASSESSEE DID NOT FILE THE APPEAL AGAINST THE ADDITIONS MADE BY THE ASSESSING OFFICER FOR UNEXPLAINED JEWELRY OR CASH SO AS TO END THE LI TIGATION AND TO BUY PEACE. THAT MERELY BECAUSE THE ADDITIONS HAVE BEEN ACCEPTE D BY THE ASSESSEE, IT SHOULD NOT AUTOMATICALLY RESULT INTO THE LEVY OF PE NALTY U/S 271(1)(C) OF THE ACT, ESPECIALLY WHEN THE ASSESSEE HAD GIVEN THE PLA USIBLE EXPLANATION FOR THE JEWELRY AS WELL AS THE CASH FOUND AT THE TIME O F SEARCH. THAT MERELY BECAUSE THE EXPLANATIONS OF THE ASSESSEE HAVE BEEN PARTLY ACCEPTED, IT DOES NOT MEAN THAT THE ASSESSEE HAD ANY CONCEALED INCOME . HE FURTHER SUBMITTED THAT THE ASSESSEE DISCHARGED THE ONUS BY GIVING PRO PER EXPLANATION WITH REGARD TO JEWELRY, CASH AND OTHER VALUABLES FOUND A T THE TIME OF SEARCH. HE, THEREFORE, SUBMITTED THAT THE PENALTY LEVIED U/S 27 1(1)(C) IN THE CASE OF ALL THE ASSESSEES SHOULD BE CANCELLED. 4. THE LD. DEPARTMENTAL REPRESENTATIVE, ON THE OTHE R HAND, RELIED UPON THE ORDERS OF THE AUTHORITIES BELOW. 5. WE HAVE CAREFULLY CONSIDERED THE ARGUMENTS OF BO TH THE SIDES AND PERUSED THE MATERIAL PLACED BEFORE US. SO FAR AS T HE GOLD ORNAMENTS ARE CONCERNED, WE FIND THAT SIGNIFICANT PART OF THE GOL D ORNAMENTS HAVE BEEN ACCEPTED BY THE ASSESSING OFFICER AS EXPLAINED IN T HE CASE OF ALL THE ASSESSEES AND ONLY A VERY SMALL PORTION IS TREATED AS UNEXPLAINED. FOR EXAMPLE, IN THE CASE OF ATULBHAI D. PATEL, OUT OF 1 453 GMS OF THE GOLD ORNAMENTS ONLY 107 GMS ARE TREATED AS UNEXPLAINED. IN THE CASE OF SEJALBEN A. PATEL, OUT OF 1919 GMS, 188 GMS IS TREATED AS UN EXPLAINED. THUS, IT(SS)A NOS. 661 TO 672/AHD/2011 PREMANAND S. PATEL AND OTHERS VS. DCIT 4 APPROXIMATELY 90% OF THE GOLD ORNAMENTS HAVE BEEN A CCEPTED TO BE EXPLAINED. IT IS NOT IN DISPUTE THAT THE GOLD ORNAM ENTS WERE ACQUIRED BY ALL THESE ASSESSEES FROM TIME TO TIME AND THE ASSESSEE MAY NOT BE ABLE TO MAINTAIN THE COMPLETE DOCUMENTARY EVIDENCE FOR THE ACQUISITION OF EACH AND EVERY GOLD ORNAMENT. SUBSTANTIAL PORTION OF TH E GOLD ORNAMENTS FOUND FROM THE ASSESSEE HAVE BEEN ACCEPTED AND ONLY A SMA LL PORTION OF WHICH IS TREATED AS UNEXPLAINED ON ESTIMATED BASIS. THIS BY ITSELF DOES NOT AMOUNT TO CONCEALMENT OF INCOME. THE ASSESSEE HAS GIVEN THE P LAUSIBLE EXPLANATION IN RESPECT OF ALL THE GOLD ORNAMENTS FOUND WITH THEM A ND MERELY BECAUSE THE ASSESSING OFFICER PARTLY ACCEPTED THE GOLD ORNAMENT S TO BE EXPLAINED, IT WOULD NOT BE PROPER TO LEVY THE PENALTY U/S 271(1)( C) IN RESPECT OF THE SMALL PORTION OF THE GOLD ORNAMENTS WHICH ARE TREATED AS UNEXPLAINED. HOWEVER, THE SAME LOGIC CANNOT BE APPLIED IN RESPECT OF CASH FOUND FROM VARIOUS ASSESSEES; SUBSTANTIAL PORTION OF WHICH IS TREATED AS UNEXPLAINED. THE ASSESSEE HAS NOT BEEN ABLE TO GIVE ANY PROPER EXPLA NATION FOR THE SUBSTANTIAL CASH FOUND WITH DAHYABHAI S PATEL, PREMANANDBHAI S. PATEL, ARVINDBHAI N. PATEL AND ONIL N. PATEL. THE ASSESSEE HAS SIMPLY C LAIMED THAT THE CASH BELONGED TO VARIOUS FAMILY MEMBERS. HOWEVER, WE FIN D THAT THE ASSESSING OFFICER HAS GIVEN SUFFICIENT CREDIT FOR THE CASH WH ICH CAN BE PRESUMED TO HAVE BEEN BELONGING TO VARIOUS FAMILY MEMBERS. DESP ITE GIVING THE ABOVE CREDIT, MORE THAN 50% OF THE CASH FOUND FROM EACH P ERSON IS TREATED AS UNEXPLAINED WHICH IS ACCEPTED BY THE ASSESSEE BY NO T FILING THE APPEAL. THE ASSESSEES CONTENTION IS THAT THE SUBSTANTIAL WITHD RAWALS ARE FOR HOUSEHOLD EXPENSES AND THEREFORE, THE ACCUMULATION OF CASH IS OUT OF SAVING FROM HOUSE HOLD WITHDRAWAL. THIS EXPLANATION OF THE ASS ESSEE CANNOT BE ACCEPTED BECAUSE THE WITHDRAWAL IS NOT MUCH. 6. THE CIT(A) HAS GIVEN AT PAGE 17, THE YEAR-WISE W ITHDRAWAL FOR HOUSEHOLD EXPENDITURE BY SHRI ONILBHAI N. PATEL, WH ICH IS REPRODUCED BELOW FOR READY REFERENCE. IT(SS)A NOS. 661 TO 672/AHD/2011 PREMANAND S. PATEL AND OTHERS VS. DCIT 5 ASS. YEAR TOTAL WITHDRAWALS DURING THE YEAR CASH WITHDRAWALS DURING THE YEAR 2007-08 270880 180000 2006-07 251425 175000 2005-06 148580 100000 2004-05 236235 155000 2003-04 128862 105000 2002-03 94449 75000 2001-02 98773 90000 TOTAL 1229204 880000 FROM THE ABOVE, IT IS EVIDENT THAT HIS CASH WITHDR AWAL DURING THE ACCOUNTING YEAR RELEVANT TO ASSESSMENT YEAR 2001-02 TO 2003-04 WAS LESS THAN RS.10,000/- PER MONTH AND IN OTHER YEARS ALSO IT IS LESS THAN RS.20,000/- PER MONTH. WHILE THE TOTAL CASH FOUND FROM SHRI ON ILBHAI N. PATEL WAS RS.4,72,900/-, OUT OF WHICH RS. 3,52,900/- HAVE BEE N TREATED AS UNEXPLAINED; IN ADDITION TO WHICH, THE INVESTMENT MADE BY SHRI O NILBHAI N. PATEL IN THE PRECEDING YEAR, WITHOUT RECORDING IN THE BOOKS OF A CCOUNTS WAS RS.60,000/- IN KISAN VIKAS PATRIKA, RS.10,000/- IN NSC AND RS.3 ,20,000/- IN SBI BOND. NO SATISFACTORY EXPLANATION HAS BEEN GIVEN FOR SOUR CE OF INVESTMENT IN KVP, NSC AND SBI BOND. THEREFORE, IN OUR OPINION, THESE INVESTMENTS AS WELL AS RS.3,52,900/- OUT OF CASH FOUND FROM THE ASSESSEE A RE CLEARLY THE UNDISCLOSED INCOME OF THE ASSESSEE AND PENALTY U/S 271(1)(C) HA S RIGHTLY BEEN LEVIED THEREON. 7. WITH SHRI ARVINDBHAI N PATEL, CASH OF RS.1,58,90 9/- WAS FOUND, OUT OF WHICH RS.1,00,000/- WAS TREATED AS UNEXPLAINED. AT PAGE NO.20, THE CIT(A) HAS GIVEN THE YEAR-WISE WITHDRAWAL WHICH IS REPRODU CED BELOW FOR READY REFERENCE:- ASS. YEAR TOTAL WITHDRAWALS DURING THE YEAR CASH WITHDRAWALS DURING THE YEAR 2007-08 230658 135000 2006-07 122635 77500 2005-06 103309 60000 IT(SS)A NOS. 661 TO 672/AHD/2011 PREMANAND S. PATEL AND OTHERS VS. DCIT 6 2004-05 127298 99000 2003-04 124385 95000 2002-03 115514 110000 2001-02 88373 79000 TOTAL 912172 655500 FROM THE ABOVE, IT IS EVIDENT THAT HIS CASH WITHDRA WAL WAS LESS THAN OR AROUND RS.10,000/- PER MONTH, WHILE TOTAL WITHDRAWA L WAS ALSO LESS THAN RS.20,000/- PER MONTH. IN THE ABOVE CIRCUMSTANCES, THE ASSESSING OFFICER HAS RIGHTLY TREATED THE CASH OF RS.58,909/- TO BE E XPLAINED AND BALANCE RS.1,00,00/- AS UNDISCLOSED INCOME. 8. ALMOST SIMILAR POSITION IS IN THE CASE OF PREMAN AND S. PATEL. THE TOTAL CASH FOUND WITH HIM WAS RS. 3,49,679/-, OUT OF WHIC H THE ASSESSING OFFICER HAS ACCEPTED MORE THAN A LAC TO BE EXPLAINED AND TR EATED RS. 2,49,000/- TO BE UNEXPLAINED. DETAILS OF HIS CASH WITHDRAWAL ARE AS UNDER:- ASS. YEAR TOTAL WITHDRAWALS DURING THE YEAR CASH WITHDRAWALS DURING THE YEAR 2007-08 537973 149000 2006-07 521256 15000 2005-06 59759 43000 2004-05 50630 46000 2003-04 113663 28000 2002-03 29117 21000 TOTAL 1312398 302000 HIS CASH WITHDRAWAL IS LESS THAN RS.5,000/- PER MO NTH IN 5 YEARS, AND IN ONLY ONE YEAR IT IS AROUND RS.12,000/- PER MONTH . IN THE ABOVE CIRCUMSTANCES, IN OUR OPINION, THE ASSESSING OFFICE R WAS FAIR ENOUGH IN ACCEPTING THE CASH OF RS.1,00,000/- TO BE EXPLAINED . 9. IN THE CASE SHRI DAHYABHAI S. PATEL, TOTAL CASH FOUND WAS RS.2,73,800/, OUT OF WHICH RS.1,61,000/- WAS TREATED AS UNEXPLAIN ED. HIS POSITION OF WITHDRAWAL FOR HOUSEHOLD EXPENSES IS AS UNDER:- IT(SS)A NOS. 661 TO 672/AHD/2011 PREMANAND S. PATEL AND OTHERS VS. DCIT 7 ASS. YEAR TOTAL WITHDRAWALS DURING THE YEAR CASH WITHDRAWALS DURING THE YEAR 2007-08 40873 110000 2006-07 43870 55000 2005-06 156713 60000 2004-05 39285 65000 2003-04 252104 100000 2002-03 19653 60000 TOTAL 552493 450000 FROM THE ABOVE, IT IS EVIDENT THAT OUT OF SIX YEAR S, IN FOUR YEARS HIS CASH WITHDRAWAL WAS ONLY RS.5000/- PER MONTH AND IN OTHER TWO YEARS ALSO IT IS LESS THAN RS.10,000/- PER MONTH. IN THE ABOV E CIRCUMSTANCES, IN OUR OPINION, THE ASSESSING OFFICER WAS QUITE FAIR IN AC CEPTING THE CASH OF MORE THAN A LAC AS EXPLAINED AND TREATED THE BALANCE CAS H OF RS.1,61,000/- AS UNEXPLAINED BEING THE UNDISCLOSED INCOME OF THE ASS ESSEE. NO PROPER EXPLANATION HAS BEEN GIVEN BY THE ASSESSEE DURING T HE PENALTY PROCEEDINGS ALSO IN RESPECT OF UNEXPLAINED CASH FOUND AND INVES TMENTS IN KISAN VIKAS PATRIKA, NSC, SBI BOND ETC. 10. AFTER CONSIDERING THE FACTS OF THE CASE AND THE ARGUMENTS OF BOTH THE SIDES, WE ARE OF THE OPINION THAT SO FAR THE GOLD O RNAMENTS ARE CONCERNED, THE ASSESSEE HAS GIVEN THE PROPER EXPLANATION FOR T HE SOURCE OF GOLD ORNAMENTS IN RESPECT OF EACH AND EVERY ASSESSEE. TH E ASSESSING OFFICER SUBSTANTIALLY ACCEPTED THE ASSESSEES EXPLANATION A ND TREATED ONLY A SMALL PART OF THE GOLD ORNAMENTS TO BE UNEXPLAINED. THERE FORE, IN OUR OPINION, THE ASSESSEE HAS GIVEN PROPER EXPLANATION IN RESPECT OF THE GOLD ORNAMENTS WHICH IS NOT FOUND TO BE FALSE OR UNTRUE, THOUGH TH E ASSESSING OFFICER ACCEPTED THE ASSESSEES EXPLANATION PARTIALLY ON ES TIMATED BASIS. IN THE ABOVE CIRCUMSTANCES, IN OUR OPINION, LEVY OF PENALT Y IN RESPECT OF PART OF THE GOLD ORNAMENTS WHICH ARE TREATED AS UNEXPLAINED IS NOT JUSTIFIED. HOWEVER, THE FACTS ARE DIFFERENT IN RESPECT OF CASH FOUND AN D INVESTMENTS IN OTHER IT(SS)A NOS. 661 TO 672/AHD/2011 PREMANAND S. PATEL AND OTHERS VS. DCIT 8 ASSETS LIKE KVP, NSC AND SBI BOND. NO PROPER EXPLAN ATION HAS BEEN GIVEN IN RESPECT OF CASH FOUND OR THE INVESTMENT IN KVP, NSC AND SBI BOND. THE ONLY EXPLANATION FOR CASH IN HAND WAS THAT IT BELON GS TO VARIOUS FAMILY MEMBERS AND THE SAVINGS IS OUT OF THE WITHDRAWAL FO R HOUSEHOLD EXPENDITURE IN THE PRECEDING YEAR. WE HAVE SEEN TH AT THE WITHDRAWAL BY THE ASSESSEE IN THE PRECEDING YEAR IS MEAGER WITH W HICH THE ASSESSEE WOULD BE ABLE TO MANAGE THE HOUSEHOLD EXPENSES ONLY AND W OULD NOT BE ABLE TO SAVE MUCH. NO EVIDENCE HAS BEEN GIVEN THAT THE PART OF THE CASH BELONGS TO THE FAMILY MEMBERS. THE ASSESSING OFFICER HAS ALREA DY GIVEN THE CREDIT ON ESTIMATED BASIS IN RESPECT OF SOME CASH IN HAND. IN VIEW OF ABOVE, WE ARE OF THE OPINION THAT IN RESPECT OF CASH IN HAND WHICH I S TREATED AS UNEXPLAINED AND ALSO THE INVESTMENTS IN KVP, NSC AND SBI BOND, IT CANNOT BE SAID THAT THE ASSESSEE WAS ABLE TO SUBSTANTIATE HIS EXPLANATI ON. THE EXPLANATION GIVEN WAS GENERAL, WITHOUT ANY SUPPORTING EVIDENCES. IN V IEW OF ABOVE, WE ARE OF THE OPINION THAT THE LEVY OF PENALTY U/S 271(1)(C) IN RESPECT OF UNEXPLAINED JEWELRY WAS NOT JUSTIFIED WHILE THE LEVY OF PENALTY IN RESPECT OF UNEXPLAINED CASH AND INVESTMENTS IN KVP, NSC, SBI BOND WAS JUST IFIED. ACCORDINGLY, THE ASSESSING OFFICER IS DIRECTED TO RECALCULATE TH E PENALTY AS INDICATED ABOVE. 11. IN THE RESULT, THE APPEAL BEARING IT(SS)A NOS. 663, 664, 666, 667 & 672 ARE ALLOWED. THE APPEAL BEARING IT(SS)A NOS. 661, 6 65 & 671 ARE PARTLY ALLOWED. THE APPEAL BEARING IT(SS)A NOS. 662, 668, 669 & 670 ARE REJECTED. ORDER PRONOUNCED IN THE COURT ON 17 TH APRIL, 2015 AT AHMEDABAD. SD/- SD/- (S. S. GODARA) JUDICIAL MEMBER (G.D. AGRAWAL) VICE-PRESIDENT AHMEDABAD; DATED 17/04/2015 BIJU T., PS IT(SS)A NOS. 661 TO 672/AHD/2011 PREMANAND S. PATEL AND OTHERS VS. DCIT 9 ANNEXURE-1 SR. NO. IT(SS) NO. NAME OF THE ASSESSEE AY JEWELRY FOUND JEWELRY TREATED AS UNEXPLAINED (IN GMS) CASH FOUND (IN RS.) CASH TREATED AS UNEXPLAINED (IN RS.) OTHERS PENALTY LEVIED (IN RS.) IN GMS AMOUNT 1 661/AHD/2011 PREMANAND SOBHAI PATEL 2007-08 3050 441 GMS RS.4,15,038 3,49,679 2,49,000 - 2,44,798 2 662/AHD/2011 ARVINDBHAI N PATEL 2007-08 - - 1,58,909 1,00,000 - 29,690 3 663/AHD/2011 RITABEN R. PATEL 2007-08 1910 329 GMS RS.3,09,486 - - - 88,280 4 664/AHD/2011 RAKESH R. PATEL 2007-08 978 253 GMS RS.2,38,047 - - - 60,310 5 665/AHD/2011 DAHYABHAI S. PATEL 2007-08 1412 35 GMS RS. 33,022/- 2,73,800 1,61,000 - 88,040 6 666/AHD/2011 ATULBHAI D. PATEL 2007-08 1453 107 GMS RS. 1,01,041 - - - 34,010 7 667/AHD/2011 SEJALBEN A. PATEL 2007-08 1919 188 GMS RS.1,77,190 - - - 54,220 8 668/AHD/2011 ONIL N. PATEL 2003-04 - - - - INVESTMENT IN KVP RS.60,000 18,000 9 669/AHD/2011 ONIL N. PATEL 2004-05 - - - - NSC RS.10,000 3,000 10 670/AHD/2011 ONIL N. PATEL 2005-06 - - - - SBI BOND RS.3,20,000 97,918 11 671/AHD/2011 ONIL N. PATEL 2007-08 1399+1982 297 RS.2,70,466 4,72,900 3,52,900 - 2,50,660 12 672/AHD/2011 BHARTIBEN O. PATEL 2007-08 2402+233 308 RS.2,89,567 - - - 81,740 IT(SS)A NOS. 661 TO 672/AHD/2011 PREMANAND S. PATEL AND OTHERS VS. DCIT 10 $% &' ($'# $% &' ($'# $% &' ($'# $% &' ($'#/ COPY OF THE ORDER FORWARDED TO : 1. )* / THE APPELLANT 2. &+)* / THE RESPONDENT. 3. ,, - / CONCERNED CIT 4. - ( ) / THE CIT(A) - I II , AHMEDABAD 5. '01 & , , / DR, ITAT, AHMEDABAD 6. 123 4 / GUARD FILE . $% $% $% $% / BY ORDER, TRUE COPY 5 55 5/ // / ,6 ,6 ,6 ,6 ( DY./ASSTT.REGISTRAR) , , , , / ITAT, AHMEDABAD