Income Tax Appellate Tribunal – Hyderabad
Shailaja Kalvakuntla, Hyd, … vs Ito, Ward-3(1), Hyd, Hyderabad on 6 January, 2021 IN THE INCOME TAX APPELLATE TRIBUNAL
Hyderabad ‘ B ‘ Bench, Hyderabad
(Through Video Conferencing)
Before Smt. P. Madhavi Devi, Judicial Member
AND
Shri D.S. Sunder Singh, Accountant Member
ITA Nos. 734/Hyd/2014 & 1364/Hyd/2015
Assessment Years: 2009-10 & 2010-11
Shailaja Kalvakuntla, Vs. Income-tax Officer,
Hyderabad. Ward – 1(2), Hyderabad.
PAN – AHGPK 9438D
(Appellant) (Respondent)
Assessee by : Shri K.C. Devdas
Revenue by: Shri Sunku Srinivas
Date of hearing: 19/11/2020
Date of pronouncement: 06/01/2021
ORDER
Per D.S. Sunder Singh, A.M.
Both these appeals are filed by the assessee for the AYs 2009 -10
and 2010-11.
ITA No. 734/Hyd/2014
2. This appeal is directed against the order of CIT(A) – IV, Hyderabad,
dated 14/02/2014 for AY 2009-10.
3. All the grounds in this appeal are related to the addition confirmed
by the ld.CIT(A) for an amount of Rs.85,63,498/ – made by the AO u/s 69 of
the IT Act.
ITA Nos. 734/Hyd/2014 & 1364/Hyd/2015
Shailaja Kalvakuntla, Hyd.
4. Brief facts of the case are that the assessee did not file the return of
income for the AY 2009-10, hence, the AO issued notice u/s 148 of the Act,
to which, there was no response from the assessee. Later, the AO issued
the notice u/s 142(1) of the IT Act calling for the details and, in response to
which, the AR of the assessee appeared before the AO and furn ished the
details and the assessment was completed u/s 144 rws 147 of the Act on a
total income of Rs. 1,04,57,680/-. In the assessment order framed u/s 144
r.w.s.147 of the Act, the AO made the following additions:
(i) Income from house property as admitted
In the computation of total income filed
During the assessment proceedings Rs. 7,57,680
(ii) Unexplained investment made in purchase
of land at Shaikpet assessed to
tax u/s 69 Rs.97,00,000
Out of the above additions, the dispute is with regard to the
unexplained investment made in purchase of land at Shaikpet, which is
assessed u/s 69 of the Act.
4.1 During the assessment proceedings, the AO found that the assessee
has advanced the amount of Rs. 97,00,000/- for purchase of land
admeasuring 1800 sq.yds. in Shaikpet and made the payments as under:
i) Paid through cash on 21/07/2008 Rs. 45,00,000
ii) Paid through cas on 05/08/2008 Rs. 45,00,000
iii) Paid through Ch. No. 430219,
dt. 21/07/08 of ABN AMRO Bank,
Banjara Hills. Rs. 2,00,000
iv) Paid through Ch.No. 430221,
dt. 05/08/2008 of ABN AMRO Bank,
Banjara Hills. Rs. 5,00,000
Total Rs 97,00,000
==========
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Shailaja Kalvakuntla, Hyd.
The assessee has explained the source for purchase of the land by way of
cash flow statement compiled for the FYs 2007-08 and 2008-09.During the
scrutiny assessment proceedings of the A.Y.2008-09 the assessee has
furnished the cash flow statements, up to the A.Y.2008-09. As per which
the opening cash balance was Rs. 64,30,048/- as on 01/04/2007 and the
receipts during the F.Y. 2007-08 were Rs.38,53,914/- and closing cash
balance was Rs.75,70,268/- as at the end of the year 31/03/2008. The
assessee also submitted the balance sheet before the AO as on
31/03/2008.The AO picked up one of the items of Rs.5.00 lacs deposited in
ABN-AMRO Bank on 25/07/2007 from the cash flow statement and made the
addition under section 68 to the returned income in the order made under
section144 r.w.s 147 dated 31/12/2011 for the A.Y.2008 -09.
4.2. The Asst.year under consideration is 2009-10 relevant to the
F.Y.2008-09 the assessee furnished the cash flow statement in page No. 51
of the paper book with the opening balance of Rs.75,70,268/-(Closing
balance of 31/03/2008) and the receipts during the year of Rs.61,98,780/-
and thus the assessee explained the sources for acquiring the land through
cash flow statement in page 51 of the paper book which contain the sources
and application of funds.
4.3. The AO during the assessment proceedings of 2009 -09, examined
the cash flow statement of F.Y.2008-09 and viewed that there was no basis
for the opening cash balance of Rs.64,30,048/- as on 01.04.2007. The
assessee claimed the receipt from HSBC amounting to Rs.39,50,000/ as a
source and the AO did not allow the credit for source, since, the assessee
failed to explain the nexus between the loan taken from HSBC and the
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Shailaja Kalvakuntla, Hyd.
advance made for purchase of land. Similarly, the assessee said to have
been received the sums from Aparna Constructions & Estates Pvt. Ltd. and
from her husband, which was also not allowed by the AO. All the
transactions were related to the A.Y.2008 -09. Thus the AO reduced the
source of opening cash balance available to the assessee.
4.4. In the cash flow statement for the A.Y.2009-10, the assessee has
shown the receipts of Rs. 20 lakhs from Shri G. Balakishan Rao, G.
Narayana Rao and Sri. E. Madan Mohan Rao towards sale of land as under:
Shri G. Balakishan Rao Rs.5.00 lacs
SriG. Narayana Rao Rs.10.00 lacs
Sri. E. Madan Mohan Rao Rs.5.00 lacs
The Assessee furnished the confirmation letters from Shri G.
Balakishan Rao, and G. Narayana Rao in support of the advance. However,
since the assessee failed to establish creditworthiness of the said crditors,
the AO did not believe the source of Rs. 15.00 lakhs advance received from
Shri G. Balakishan Rao and G. Narayana Rao.With regard to Sri. E. Madan
Mohan Rao also since, the assessee failed to file confirmation from Sri E.
Madan Mohan Rao, the AO rejected the claim of the assessee with regard
to sources. Accordingly the AO disbelieved the source of entire investment
of Rs. 97,00,000/- towards purchase of land and made the addition u/s 69
of the Act.
5. Aggrieved by the order of the AO, the assessee preferred an appeal
before the CIT(A) and received part relief from the ld. CIT(A). The ld. CIT(A)
worked out the cash balance as on 01/04/200 7 at Rs. 11,36,502/- as under:
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Shailaja Kalvakuntla, Hyd.
Opening cash balance on 01/04/2001 Rs. Nil
Add: Receipt from Aparna Construction Rs. 4,00,000
Advance from Husband Rs. Nil
Loan from HSBC Rs. 39,50,000
Total Rs. 43,00,000
Less: Outflow during FYs 2002-03 to
2005-06 Rs. 31,63,498
Cash balance as on 01/04/2007 Rs. 11,36,502
===========
With regard to Rs. 20 lakhs received from Shri G. Balakishan Rao,
G. Narayana Rao and Sri. E. Madan Mohan Rao was disbelieved by the
Ld.CIT(A) also and rejected the assessee’s claim. With regard to cash flow
statement of F.Y.2007-08, relevant to A.Y.2008-09, the ld. CIT(A) has
viewed that the AO has no occasion to examine the correctness of the cash
flow statement and hence held that the AO is right in rejecting the
contention of the assessee with regard to correctness of the entries in cash
flow statement and the closing balance. Accordingly, Ld.CIT(A) allowed part
relief to the assessee. Against the order of Ld. CIT(A), the assessee is in
appeal before the Tribunal.
6. During the appeal hearing, ld. AR of the assessee submitted that the
source for the investment of Rs. 97,0 0,000/- was out of opening cash
balance, the borrowings and own sources of income which was explained by
the assessee before the Ld.AO by cash flow statement and a copy of the
same was placed at page No. 51 of the paper book. He further submitted
that the AO doubted the genuineness of the opening cash balance of Rs.
75,70,268/- reported in the cash flow statement merely because huge
balances were maintained which is the presumption of the AO. Ld. AR
further submitted that for AY 2008 -09, the assessment was completed in a
scrutiny manner and the assessee furnished the cash flow statement and
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Shailaja Kalvakuntla, Hyd.
the balance sheet before the AO for AY 2008-09, which is placed at page
no. 91 of the paper book, wherein the assessee had worked out the
opening balance of Rs. 64,30,048/- as on 01.04.2007 and the closing
balance of Rs. 75,70,268/- as on 31.03.2008 which was accepted by the
AO. In the assessment proceedings, for AY 2008 -09, out of the entries in
cash flow statement, the AO picked up one item i.e. advances for land of
Rs. 5 lakhs and added the same to the returned income and thus accepted
the remaining cash flow statement and the balance sheet . The Ld.AR
argued that the balance available in cash flow stat ement as at the end of
the FY 2008-09 has become final and, therefore, the AO cannot revisit the
same in the proceedings for the subsequent years and reject the opening
balances and entries in the cash flow statement of 2008 -09. There must be
an end for litigation and therefore, argued that the payment for advance of
land stands explained, hence, no addition is warranted.
6.1. With regard credits made in respect of Shri G. Balakishan Rao, and
G. Narayana Rao aggregating to Rs.15 lakhs, ld. AR submitted that the y
have filed confirmation letters and the sources were explained by the
respective creditors before the AO. He, therefore, submitted that there is no
reason to suspect the genuineness of the receipts from Shri G. Balakisha n
Rao, and G. Narayana Rao, who have deposed the statement u/s 131 of
the Act. The ld. AR of the assessee explained that the source in the hands
of the assessee stands explained and if, the genuineness of the source of
source is suspected, the same is required to be taxed in the hands of the
respective creditors, but, not in the hands of the assessee. The ld. AR
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further argued that the Ld.CIT(A) considered the cash flow statement and
accepted the loan from HSBC, but, rejected the opening cash as on
01.04.2001 and the remaining entries which is incorrect and contradictory
to her own observation. Since the assessee has filed the cash flow
statement, the CIT(A) ought to have taken entire cash flow statement
instead of considering the statement in piecemeal. He submitted that the
Ld.CIT(A) allowed the credit of Rs.4 lakhs receipt from Aparna construction
and Rs. 39,50,000/- from HSBC as the source and reduced the cash out
flow for the entire period of 2002-03 to 2005-06 ignoring the income tax
returns filed by the assessee which sho ws contradictory approaches of the
Ld.CIT(A). He further submitted that the assessee has filed necessa ry
evidences before the AO as well as the CIT(A). It is submitted that the
assessee’s husband Shri Ram Gopal Rao is a Forest Settlement Officer and
has filed the returns of income regularly and having sufficient sources. It is
contended that the ld. CIT(A) has rejected the sources explained by the
assessee in respect of the receipts received from her husband, which were
reflected in the balance sheet of her husband and it is unfair to reject the
same in the hands of the assessee. It is submitted that since the assessee’s
husband has filed return of income for AY 2008 -09 and is regularly
assessed to tax, if the AO suspects the source of her husband, the same
required to be assessed in the hands of her husband, but, not in the hands
of the assessee. It is, thus, argued that in spite of the fact that assessee is
having sufficient sources of income and explained before the AO and the
Ld.CIT(A), both the lower authorities have rejected the contentions of the
assessee without any evidences. Ld. AR brought the attention of the Bench
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Shailaja Kalvakuntla, Hyd.
to page 140 of paper book relating to remand report submitted by the AO to
CIT(A) wherein he had acknowledged the filing of cash flow statement by
the assessee for FY 2007-08 and no defects were brought by the AO to
reject the assessee’s contention.
6.2. With regard to the addition of Rs 5 .00 lakhs addition made by the
AO for the A.Y.2008-09, the ld. AR submitted that the Hon’ble ITAT has
remitted the matter back to the file of the AO vide its order dated
12/01/2016 and, thus, argued that the source for the payment of Rs.
97,00,000/- was clearly explained in the cash flow statement and balance
sheet, filed at page 51 of the pa per book. therefore, he argued that there is
no case for making the addition u/s 69 of the Act. He, accordingly,
contended that the orders of the lower authorities be set aside and allow the
appeal of the assessee.
6.3. The ld. AR also submitted that since, the additions were made u/s
69 of the Act, the burden is on the AO to dis prove the claim of the
assessee. Apart from the above, the ld. AR also argued that the AO ought
to have made the addition u/s 68 of the Act. The ld. AR of the assessee
relied on the following cases in support of assessee’s case:
1. CIVT Vs. Dinesh Jain, HUF, 352 ITR 629 (Del.)
2. CIT Vs. Kulwinder Singh [2019] 415 ITR 49 (P&H)
7. The ld. DR, on the other hand, vehemently opposed the contentions
of the ld. AR and argued that there is no bas is for cash flow statement
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submitted by the assessee. He argued that assessee has shown opening
cash balance of Rs. 75,70,268/-, which was rejected by the ld. CIT(A) in
her reasoned order. He submitted that the CIT(A) has rejected the source of
Rs. 20,00,000/- advance received by the assessee during the year and the
sums received from her husband amounting to Rs. 25 lakhs and, therefore,
he argued that the opening balance claimed in the cash flow statement
deserves to be rejected for want of evidence. Ld. DR further submitted that
the AO did not have any occasion to verify the cash flow statement filed by
the assessee for AY 2008-09, since, the assessment was taken up for
scrutiny for limited purpose. In the limited scrutiny, AO required to examine
the issue for which the case was selected for scrutiny, thus, he argued that
the CIT(A) has rightly rejected the contention of the assessee that the AO
has not examined the correctness of the cash flow statement for the AY
2008-09. Ld. DR further argued that the assessee failed to establish the
source for the investment for payment of land at Shaikpet, hence, the ld.
CIT(A) rightly sustained the addition of Rs. 85,63,498/ – after allowing the
credit of Rs. 11,32,502/-. Accordingly, he argued that no interference is
called for in the order of CIT(A) and requested to uphold the order of CIT(A)
and dismiss the appeal of the assessee.
8. We have heard both the parties and perused the material on record.
In the instant case, during the impugne d AY, the assessee has made
payment of Rs. 97,00,000/- for purchase of land admeasuring 1800 sq.yds. ,
which was brought to tax u/s 69 of the Act. The assessee explained the
payment through cash flow statement, which is placed at page 51 of the
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paper book and as per which, the assessee had the opening cash balance
of Rs.75,70,268/-, which the AO disbelieved on the pretext of impossibility
of maintaining such huge cash balances and not substantiating the
correctness of entries made in the cash flow statement of earlier years. In
the immediately preceding AY, the assessment was completed in scrutiny
manner u/s 144 r.w.s. 147 of the Act and the assessment orders are placed
at page nos. 139A and 139B of the paper book II. During the assessment
proceedings for AY 2008-09, the assessee has furnished cash flow
statement, which is also placed at page 149 of the paper book II. As per
the cash flow statement of A.Y.2008-09, the opening balance was
Rs.64,30,048/- and the closing balance was Rs.75,70,268/-. From the
cash flow statement of F.Y.2007-08 , the receipts and payments aggregated
to the sum of Rs.1,02,83,962/ including the opening and the closing
balances of cash. The AO selected the item of advance for land of Rs. 5
lakhs and disbelieved the source of Rs.5 .00 lakhs and added back to the
returned income of the assessee for AY 2008 -09. The remaining entries and
opening and closing cash balances were untouched by the AO in the
assessment proceedings for AY 2008-09. Thus, it is established that entries
made in the cash flow statement for AY 2008 -09 became final, except the
sum of Rs.5 lakhs which was added back to the income . The contention of
the ld. CIT(A) that there was no occasion for the AO to ex amine the
correctness of cash flow statement for AY 2008 -09 is incorrect and
misinterpretation of the provision of the Act. Since, the cash flow statement
was furnished to the AO, if there is any doubt or suspicion regarding the
entries in the cash flow statement, the AO is having mandatory obligation to
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Shailaja Kalvakuntla, Hyd.
verify the correctness of entries converting the case in to full scrutiny after
obtaining the approval from competent authorities. If there was an
understatement of income relating to the A.Y.2008-09, the AO has to
examine and make addition in the A.Y.2008-09 itself but not in the
subsequent assessment years. Having not verified the entries and accepted
the same, the AO is not permitted to agitate and revisit the same issues
under the pretext of non verification. There must be an ending for litigation
and it should not be prolonged after completing the scrutiny assessment
without sufficient reasons. AO in his remand report, furnished at page 140
of the paper book, clearly spelt out that the assessee has filed cash flow
statement for the FY 2007-08 and, thus, the contention of the CIT(A) with
regard to non-verification of the cash flow statement for the AY 2008 -09 by
the AO does not hold waters. Even though, the case was taken up for
limited scrutiny, during the assessment proceedings, if any entries are
suspicious or any other suppression of income, comes to the notice of the
AO, it is mandatory obligation of the AO to take necessary permission from
the authorities i.e. Pr. CIT/CIT as applicable and examine the suspicious
entries to bring the true and correct income to tax and it is the duty of the
AO to assess true and correct income. Therefore, we are unable to accept
the argument of the ld. DR that merely because the case was taken up for
limited scrutiny, the AO is barred from verifying the other entries in the
cash flow statement. Since the assessee has furnished cash flow statement
during the assessment proceedings for the A Y 2008-09, the entries in the
cash flow statement, which were already reflected in AY 2008-09, cannot be
disturbed by revisiting the same statements in later years. For income tax,
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each year is independent and what is to be examined in the impugned AY is
the entries made in the relevant AY i.e. receipts and payments during the
year under consideration, but, not the entries that were made in the earlier
year. Thus, the closing balance declared by the assessee as at the end of
the FY2007- 2008 stands explained and the assessee is entitled to claim
the credit for the opening balance in the year under consideration. Hence,
we hold that the assessee is permitted to take opening balance of Rs.
75,70,268/- as source.
8.1. Then the issue comes to sources for receipts during the year . Out of
the receipts during the year, the AO rejected the advance amount of Rs. 20
lakhs received from S/Shri G. Balkishna Rao, G. Narayana Rao and E.
Madan Mohan Rao. The assessee furnished confirmation letters from G.
Balkishna Rao and G. Narayana Rao and the AO did not make any further
enquiries. From the order of CIT(A), it is observed that during the appellate
proceedings, G. Balkishna Rao and G. Narayana Rao have confirmed the
payment to the assessee u/s 131 of the Act. Therefore, there is no reason
to reject the credit. If the AO was not convinced with the explanation offered
by the creditors, the same is required to be brought to tax in the hands of
the creditors, since, they have confirmed the credit and explained the
source, but, not in the hands of the assessee. Thus we hold that there is no
case for rejection of opening balance and the loans from G.Balakrishna Rao
and G.Narayana Rao and accordingly we direct the AO to accept the same.
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8.2. With regard to the amount of Rs.5.00 lakhs received from Shri E.
Madan Mohan Rao, as seen from the paper book page No.73 and 74 the
creditor has issued the legal notice for recovery of the loan with the dates
of amounts lent. Since the legal notice is available the AO should have
caused necessary enquiries instead of pressing the assessee to produce
the creditor. Having not caused the enquiries and did not bring any
material to show that the advance received from E.Madan Mohan Rao was
bogus, the AO is not permitted to make the addition in the hands of the
assessee. Thus we direct the AO to accept the credit from E.Madan Mohan
Rao.
8.3. In respect of Rs. 25 lakhs received from her husband, the same was
reflected in the balance sheet of her husband and he is assessed to tax.
Her husband Shri Ram Gopal Rao also filed confirmation having given the
loans to the assessee, therefore, there is no reason to suspect the source.
Even if it is to be suspected, the same is required to be examined in the AY
2005-06, but, not in the impugned assessment year.
8.4 From the cash flow statement, we find that the payment of Rs.97
lakhs on account of advance for land was clearly explained by the assessee
and therefore, we hold that there is no case for making the addition, hence,
we delete the addition made by the AO on this count and set aside the order
of the Ld.CIT(A) and appeal of the assessee is allowed.
ITA No. 1364/Hyd/2015 for AY 2010-11
9. The assessee filed her return of income for the AY 2010 -11 on
11/12/2012 admitting a total income of Rs. 8,78,560/ – besides agricultural
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income of Rs. 75,000/-. Since the assessee did not file a valid return of
income, a notice u/s 148 dated 06/02/2013 was issued Subsequently, the
AO had issued notice u/s 142(1) of the Act, in response to which, the
assessee filed return of income admitting total income of Rs. 8,78,560/ – and
the AO completed the assessment on a total income of Rs. 59,28,560/-.
9.1. During the assessment proceedings, the AO made addition of Rs.
50,50,000/- relating to investments made by the assessee in partnership
firm. i,e Rs. 20 lakhs in Shivam Builders, Rs. 10,50,000/ – in SSAARGORAP
Constructions Pvt. Ltd. and Rs. 20 lakhs in Land at Shaikpet admeasuring
1800 sq.yds., aggregating to Rs. 50,50,000/ -. The assessee explained the
sources of the above investment was out of the opening cash balance of
Rs. 33,13,802/- and rental deposit of Rs. 20 lakhs. The AO did not believe
the source of rental deposit as well as opening cash balance, hence, mad e
the addition u/s 69 of the Act. When the assessee carried the matter in
appeal before the CIT(A), the Ld.CIT(A) confirmed the assessment order.
10. As regards the first issue of opening cash balance of Rs. 33,13,802/ –
available as on 01/04/2010, we have already made a detailed discussion
and allowed the closing balance of Rs. 33,13,802/ – in the appeal for the
A.Y.2009-10. Therefore, the balance of Rs. 33,13,802/ – stands explained.
Hence, we delete the addition of Rs. 33,13,802/- in respect of opening cash
balance.
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11. As regards the issue of rental deposit of Rs. 20 lakhs, which was
stated to have been received by the assessee, the AO made the addition
disbelieving the rental deposit and the ld. CIT(A) confirmed the addition
made by the AO in the absence of any evidence or information.
12. The assessee stated to have received the sum of Rs. 20 lakhs for
letting out the property at MLA Colony. The AO addressed a letter to the
lessee / creditor and there was no response from the lessee. The assessee
failed to submit the details of receipt with dates and mode of payment.
Therefore, the CIT(A) confirmed the addition made by the AO. Hence, the
assessee is in appeal before us.
13. During the appeal hearing, ld. AR submitted that the amoun t in
question was received form a tenant for letting out the property located in
MLA Colony. He further submitted that the receipt of the amount of advance
was supported by the lease deed dated 28/11/2009. The assessee had let
out the house located at MLA Colony, Road No. 12, Banjara Hills to Shri M.
Venkata Srinivasa Prasad and as per the le ase deed, a deposit of Rs.20
lakhs was received. However, the details of deposit w ere not mentioned
with date and mode of payment etc. The ld. AR argued that, in this r egard,
there was a dispute going on in the Civil Court, as per the plaintiff copy in
OS No. 308 of 2007, annexed as page Nos. 5 to 7 of paper book, assessee
had acknowledged the adjustment of advance of Rs. 20 lakhs towards
monthly rents paid till the end of the December, 2013. In the counter filed
by the respondent Shri M. Venkata Srinivas Prasad, he ha s not disputed the
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Shailaja Kalvakuntla, Hyd.
adjustment of rent. Thus the Ld. AR of the Assessee submitted that the
assessee had received the sum of Rs. 20 lakhs as advance, which was
adjusted subsequently through monthly rentals. He, therefore, argued that
there is no reason to suspect the genuineness of receipt of advance and,
hence, requested to set aside the order of CIT(A) allow the appeal of the
assessee.
14. The ld. DR, on the other hand, relied on the orders of lower
authorities.
15. We have heard both the parties and perused the material on record.
In the instant case, the assessee has claimed rent advance of Rs. 20 lakhs
received from Shri M. Venkata Shiva Prasad for letting out the house at
MLA Colony, Banjara Hills. Lease agreement was placed on record.
However, the details of date of receipt and mode of payment were not
furnished by the assessee. Similarly, the lessee has not responded to the
notice issued u/s 133(6) of the Act. However, there was a civil case filed by
the assessee in the Civil Court wherein the sum of Rs. 20 lakhs stated to
have been adjusted towards monthly rent als. Therefore, the issue needs to
be considered after verification of the details and genuineness of the
transaction. Both the parties have agreed to remit the issue back to the file
of the AO to examine the receipt of Rs. 20 lakhs as advance from the
tenant. The assessee is directed to cooperate with th e AO and submit
necessary information to substantiate her claim with regard to the receipt of
rent deposit of Rs. 20 lakhs. Since the legal dispute is pending the AO also
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need to make sincere efforts to verify the correct fact by causing the
enquiries instead of simply asking the assessee to produce the creditor.
Thus, the issue is remitted back to the file of AO to decide af resh on merits
and in accordance with law. Thus, this issue is treated as allowed for
statistical purposes.
16. In the result, appeal in ITA no. 734/hyd/2014 for AY 2009 -10 is
allowed and the appeal in ITA no. 1364/Hyd/2015 for AY 2010 -11 is partly
allowed for statistical purposes.
Order pronounced in the Open Court on 6 th January, 2021.
Sd/- Sd/-
(P. MADHAVI DEVI) (D.S.SUNDER SINGH)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Hyderabad, dated 6 th January, 2021.
kv
Copy to:
1 Shailaja Kalvakuntla, C/o B. Narasing Rao & Co., CAs., Plot No. 554,
Road No. 92, Jubilee Hills, Hyderabad – 500 096
2 ITO, Ward – 3(1), Hyderabad.
3 CIT (A) – IV, Hyderabad
4 CIT – III, Hyderabad
5 The DR, ITAT Hyderabad
6 Guard File
Page 17 of 17
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