IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND Ms. ASTHA CHANDRA, JUDICIAL MEMBER Assessment year : 2014-15 DCIT, Central Circle – 2, Abhayraj Fattehraj Chordiya Nashik C/o Laxmi Oil Mill Vs.

Bhusawal Road, Jamner, Jalgaon – 424206 PAN: AAMPC0248E (Appellant) (Respondent)

CO No.36/PUN/2024 Assessment Year : 2014-15 Abhayraj Fattehraj Chordiya DCIT, Central Circle – 2, C/o Laxmi Oil Mill Nashik Vs.

Bhusawal Road, Jamner, Jalgaon – 424206 PAN: AAMPC0248E (Appellant) (Respondent)

Assessee by : Shri Jayant R Bhatt Department by : Shri Amol Khairnar CIT-DR Date of hearing : 25-11-2025 Date of pronouncement : 19-12-2025

O R D E R

PER R.K. PANDA, VP:

The above appeal filed by the Revenue is directed against the order dated

31.03.2024 of the Ld. CIT(A), Pune-12 relating to assessment year 2014-15. The assessee has filed the Cross Objection against the appeal filed by the Revenue. For the sake of convenience, the appeal filed by the Revenue and the Cross Objection filed by the assessee were heard together and are being disposed of by this common order.

2. Facts of the case, in brief, are that the assessee is an individual and derives income from salary as a Director of Abhay Kumar Le Fin Investment Pvt. Ltd., Jalgaon, income from house property, income from business and income from other sources. He filed his return of income on 31.07.2014 declaring total income of Rs.17,01,810. A search and seizure action u/s 132 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) was conducted in the case of M/s. C & M Farming Ltd. (C&M Group cases) on 21.02.2020 by the ADIT(Inv)-1, Nashik. As a part of this search action, the residential premises of Mr. Rudolph Lima, Nashik was searched. During the course of search certain incriminating documents pertaining to the assessee i.e. Shri Abhayraj F. Chordiya were found from the searched premises. This information was forwarded to the jurisdictional Assessing Officer i.e. ACIT, Circle-1, Jalgaon. Based on information received, the Assessing Officer of the assessee issued notice u/s 153C of the Act after recording satisfaction on 25.01.2022 for assessment years 2014-15 to 2020-21. The assessee in response to the said notice issued u/s 153C filed the return of income on 01.07.2022 declaring total income of Rs.17,01,810/-. Subsequently the Assessing Officer issued notice u/s 143(2) of the Act which was duly served on the assessee. Thereafter, notice u/s 142(1) of the Act was issued to the assessee along with an Annexure in response to which the assessee filed various details from time to time. 3. The Assessing Officer noted that during the search action at residential premises of Mr. Rudolph Lima, Nashik, various documents / notings relating to land transactions were found and seized. In these documents there were some loose papers showing details of amounts received from Dhumal in respect of sale of land and its utilization. These amounts were written in coded form. He observed that on page Nos.9 and 10 of Annexure-A, item No.6 (loose paper bundle No.1) under the head ‘Received from Dhumal’, the amounts are noted as 50.00 as cheque, 350.00 cash and 159.00 in cash. Total is noted as ‘559.00 total received from Dhumal’. The Assessing Officer reproduced the scanned image of the page. He further noted that page No.10 contains notings in coded form under the head ‘Utilization of money’. The amount of Rs.50.00 as cheque deposited in HDFC is on account of amount received from Dhumal. The other amounts of 150.00 i.e. Rs.1,50,00,000/- paid to Mr. Prem, 200.00 i.e. Rs.2,00,00,000/- paid to Abhayraj and 159.00 i.e. Rs.1,59,00,000/- to be paid on 25.02.2014 to Mr. Abhayraj. Below the name of Abhayraj the name of Dhumal is also written. He, therefore, asked the assessee to explain his relationship with C&M Farming Pvt Ltd and his role of C&M Farming Pvt Ltd in respect of land transaction.

4. The assessee in response to the same submitted that he has no person