J.K.RANKA,J. - (1.) The instant appeal at the instance of assessee under Section 260A of the Income Tax Act, 1961, is directed against the order dated 27.10.2015 passed by Income Tax Appellate Tribunal, Jaipur Bench, Jaipur. It relates to the assessment year 2006-07.
(2.) Brief facts for disposal of the present appeal, are that the appellant is a private limited company, incorporated on 12.7.2005 and is, inter alia, engaged in developing Farm Houses at National Highway no.8 near Village Mehala Distt. Jaipur. It filed return declaring an income of Rs. 1,87,697/- on 29.11.2006. A survey operation was directed against the appellant on 26.2.2008 which continued upto 28.2.2008 at the business premises of the appellant and during the survey operation, certain incriminating documents were found and impounded under Section 133A(3)(ia) of the Income Tax Act, 1961. The survey resulted into undisclosed investment in purchase of agricultural lands and other properties, which was noticed and admitted by the Directors of the appellant. It was noticed on perusal of the incriminating documents found at the site office of the company located at Village Mehala Distt. Jaipur, that these included loose papers having details in respect of purchase of agricultural lands and the actual purchase consideration paid. It, inter alia, was noticed on perusal of the loose papers that the purchase consideration was recorded at a lesser value than the actual value of the transaction. During the course of survey, statements of some of the persons, namely Nagesh Bhaskar s/o Chet Ram, and Ram Kishore Jat s/o Ram Lal Jat were recorded. Statements of Nagesh Bhaskar and Ram Kishore Jat were provided to Sunil Bansal, Director, and thereafter statements of Sunil Bansal, one of the Directors of the appellant, were recorded and the statements of Sunil Bansal were confirmed by Atma Ram Gupta and Vimal Singhvi the other two Directors, wherein surrender was sought to be made of undisclosed investment and offering income. A show cause notice was issued during the course of regular assessment proceedings on 12.3.2008, bringing it to the notice of the assessee about the statements recorded of various persons including Sunil Bansal and confirmation by the other Directors. It is only thereafter that on 27.3.2008 the assessee sought to file a revised return declaring an additional income offered during the course of survey at Rs. 3,02,33,672/-. Since the incriminating documents also related to the assessment years 2007-08 and 2008-09 as well, therefore, the assessee offered and furnished revised returns offering therein substantial amounts making total surrender to the tune of Rs. 15 crore, including the assessment year under appeal.
(3.) Taking into consideration the revised return filed by the assessee, the Assessing Officer added the said amount of Rs. 3,02,33,672/-, and thus computed the total income at Rs. 3,04,21,370/-.;