Office of the

ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, VADODARA

Room No 603, 6th Floor, Aayakar Bhavan, Race Course, Vadodara.
Ph: 2355948, Fax: 2312438/2331536. E-mail id:
baroda.dcit.cen3@incometax.gov.in
No. VDR/ACIT-CC3/153C/SE/2023-24 Date: 29.03.2024

Satisfaction Note for initiation of Assessment proceedings u/s.153C of the Actfor

seized material pertains to the assessee seized from Searched Person/Party covered
u/s.153A of the I.T. Act, 1961

To be filled by the Assessing Officer of the person referred to in section 153 C

1. Name of the Group Diamond Group

Searched
2 Name and PANo. of Diamond Power Infrastructure Ltd. (PAN:
. the person referred ASGPS8965A)
to in section 153A

3. Date of initiation 10.04.2018

of search in the
case of the person
referred to in
section 153A
4 Name, address Swastika Electricals PAN- AAFFS2927K
and PANo. of the
person in whose
case action
under section
153C is proposed
5. Specific details of
the seized
material on the
basis of which
action under
section 153C is
proposed:
(a) Nature of Books of accounts/documents
 the seized
material
(money/Bullion Digital data &Loose papers files containing various
/jewellery/ documents.
other
valuable
article of thing
/books
ofaccount /
documents)
(b) Description of
the seized material 5/9-10 Essen House, BIDC Gorwa, 390016, Gujarat,
(c) Address India
ofpremise/place
from where such
material was
seized
(d) Date of
Panchnamas dated- 10.04.2018
seizure of such
material

(e) Particulars of
the
relevantPanchnam
a

(f) Annexure/
S.No./Page
number etc.
(Particulars to be
specified)

6. Relationship of Business Relation

the person
referred in S. No.4
with the person
referred to in S.
No.2
7. Satisfaction of the As per Enclosure "A" annexed herewith separately
Assessing Officer
of the person

2
 referred to in
section 153A that
the seized material
referred to in S.
No. 5 belongs to
the person referred
to in S. No.4
8. Assessment Years AY 2013-14 to AY 2018-19
involved

Vadodara (R. K. SIngh)

Date: 29.03.2024 Assistant Commissioner of Income-tax,
Central Circle-3. Vadodara

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 Enclosure "A"

Name & Address of the Assessee : Swastika Electricals

PAN : AAFFS2927K
Assessment Year/s. : AY 2013-14 to AY 2018-19
Date of recording reason : ……………….
Source PAN & Name : DPIL

1. A search and seizure operation was conducted u/s 132 of the Act by the officials of the
Directorate of Investigation of Income-tax on 10.04.2018 in the case of Diamond Power Group
of Vadodara including the M/s Diamond Power Infrastructure Limited at its premise, namely 5/9-
10 Essen House, BIDC Gorwa, 390016, Gujarat, India. Many incriminating documents has been
seized from the above premise. It is further emphasized that in the case of the above named
company similar search action were also conducted by other agencies viz., Central Bureau of
Investigation (CBI) and Directorate of Enforcement (ED), Ahmedabad prior to search operation
conducted by the Directorate of Investigation of Income-tax. Incriminating material received from
these agencies viz., Central Bureau of Investigation (CBI) and Directorate of Enforcement (ED),
Ahmedabad is also kept on records and verified during the assessment proceedings.
Assessment in the case of the above named company has been finalized on 01.07.2022.

2. During the assessment proceedings in the above case, while analyzing the incriminating
materials seized from the premise of M/s Diamond Power Infrastructure Limited and received
from the outside agencies, different bank account statement of the above-named company has
been found in the digital data. The list of such bank accounts are enumerated below: -

Bank of Baroda 26160500000018

Bank of India 251630110000001
Bank of India 251620110000036
Bank of India 251620110000047
Axis Bank 13010200051518
HDFC Bank 1432320005374
Dena Bank 74913021064
Diamond Power Dena Bank 74911021152
Infrastructure Limited Bank of India 20110000047
Bank of India 251665610000004
Bank of India 121371500000048
Bank of India 251620110000040
Bank of India 251620110000041
Bank of India 251620110000046
Bank of India 251665410000020
Bank of India 251665410000027

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 Bank of India 251665410000028
Bank of India 251665610000003
Allahabad Bank 50028027995
Allahabad Bank 50028362515
Allahabad Bank 50274223863
Axis Bank 13010300014702
Axis Bank 911020066034097
HDFC Bank 2758640000051
Indian Overseas Bank 292602000000008
Indian Overseas Bank 292602000000005
ICICI Bank 351000112
State Bank of Mysore 64118590035
State Bank of Hyderabad 62294475400
Kotak Mahindra Bank 8432180000291

On verification of the above bank details, it is further noticed that some of the above banks
details are not furnished by the company in its ITR filed till the date of search. On analysis of
data found from the bank statement, it is noticed that M/s. Diamond Power Infrastructure Limited
has made various transactions to the different suspicious entities, which are not related to its
day to day business activities of M/s. Diamond Power Infrastructure Limited.

3. Out of the above total transactions, it is noticed that M/s. Diamond Power Infrastructure
Limited has made following transactions to the M/s. Swastika Electricals.

Bank Of Baroda
CFS Baroda
Diamond Power Infrastructure Limited
Cash Credit Account Number: 26160500000018
Date Particulars Dr Cr
08/10/2012 Swastika Elec 10,000,000
Diamond Power Infrastructure Ltd
Bank Of India
CC Account Number: 251630110000001
06/01/2014 RTGS/SWASTIKA ELECTRICALS SOL-ID 02000 MUMBAI
(MAHARASHTRA ) 1,50,27,805.00
06-01-2014 NEFT-SWASTIKA ELECTRICALS FER SOL-ID 02000
MUMBAI (MAHARASHTRA ) 1,40,195.00
Diamond Power Infrastructure Limited
Bank Of India
Current Account Number: 251620110000036
RTGS/SWASTIKA ELECTRICALS FERTI SOL-ID 02000
20-Mar-18 MUMBAI (MAHARASHTRA ) 15,76,598.00
HDFC BANK
Account Number: 1432320005374

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 DIAMOND POWER INFRASTRUCTURE LTD
RTGS CR-BARB0POWERH-SWASTIKA ELECTRICALS
16/10/2017 FERTILIZERS-DIAMOND POWER INFRASTRUCTURE 3,500,000
RTGS CR-BARB0POWERH- SWASTIKA ELECTRICALS
01/12/2017 FERTILIZERS-DIAMOND POWER INFRASTRUCTURE 2,500,000
DENA BANK
DPIL
Account Number: 74911021152
13/03/2015 RTGS BARBH15072859680 SSWASTELECTRICALS 22,60,122
16/07/2015 RTGS BARBH15197909600 SSWASTELECTRICALS 10,00,000
16/07/2015 RTGS BARBH15197909604 SSWASTELECTRICALS 10,00,000
14/08/2015 RTGS BARBH15226936880 SSWASTELECTRICALS 10,00,000
14/08/2015 RTGS BARBH15226936904 SSWASTELECTRICALS 2,88,362
16/09/2015 RTGS BARBH15259968966 SSWASTELECTRICALS 3,07,890
15/12/2015 RTGS BARBH15349961068 SSWASTELECTRICALS 10,00,000
15/12/2015 RTGS BARBH15349961073 SSWASTELECTRICALS 3,93,464
05/03/2016 RTGS BARBH16065956707 SSWASTELECTRICALS 10,00,000
05/03/2016 RTGS BARBH16065956712 SSWASTELECTRICALS 4,41,303
10/03/2016 RTGS BARBH16070962362 SSWASTELECTRICALS 8,08,591
15/03/2016 RTGS BARBH16075762110 SSWASTELECTRICALS 10,00,000
28/03/2016 RTGS BARBH16088984637 SSWASTELECTRICALS 10,00,000
31/03/2016 RTGS BARBH16091990667 SSWASTELECTRICALS 6,95,360
31/03/2016 RTGS BARBH16091990674 SSWASTELECTRICALS 5,00,000
11/04/2016 RTGS BARBH16102903245 SSWASTELECTRICALS 10,00,000
11/04/2016 RTGS BARBH16102903258 SSWASTELECTRICALS 9,00,000
11/04/2016 RTGS BARBH16102904455 SSWASTELECTRICALS 2,85,141
26/04/2016 RTGS BARBH16117922317 SSWASTELECTRICALS 7,26,969
27/04/2016 RTGS BARBH16118924118 SSWASTELECTRICALS 7,34,209

3.1 On perusal of the above transactions, it is noticed that all these transaction are made to
M/s. Swastika Electricals. It is further verified from the materials available on record that M/s.
Diamond Power Infrastructure Limited has no business relation with M/s. Swastika
Electricals. Therefore, it is seen that M/s Diamond Power Infrastructure Limited has received
money or made payment from / to M/s. Swastika Electricals and the same is not reflected in its
books of accounts. Therefore, the source and nature of such fund generated through the above
mentioned unaccounted transactions remains unexplained in the hand of M/s. Swastika
Electricals. All the above transactions are summarized FY wise in the below given table: -

FY AY Payment by DPIL Receipt by DPIL Total

2012-2013 2013-14 10,000,000 10,000,000
2013-2014 2014-2015 15,168,000 15,168,000
2014-2015 2015-2016 2,260,122 2,105,791 4,365,913

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 2015-2016 2016-2017 10,434,970 10,434,970
2016-2017 2017-2018 3,646,319 3,646,319
2017-2018 2018-19 1,576,598 6,000,000 7,576,598

4. Considering the above facts and discussion, it is further reported that M/s. Swastika
Electricals has made above transactions in different FY as reflecting in the above table without
having any business relation with M/s. Diamond Power Infrastructure Limited.

5. In view of the above facts, I am satisfied that the above documents seized from the
searched premises as mentioned above (covered u / s.153A) pertain / pertains to or a
n y information contained therein, relates to the assessee firm Swastika Electricals. Since,
the assessee being other than the person referred to in section 153A of the Act, I have
satisfaction to proceed against the assessee firm Swastika Electricals as per the provision s of
section 153C of the Income Tax Act, 1961 as it has bearing on the determination of the total
income for the assessment years AY 2013-14 to 2019-20 i.e. six assessment years
immediately preceding the assessment year relevant to previous year in which search has
been conducted in the case of the person referred to in section 153A and 2019-20 assessment
year relevant to previous year in which search has been conducted. Therefore, it is a fit case for
initiation of proceedings u/ s.153C of the Act.

6. In view of the above facts, I am satisfied that this is a fit case for initiation of proceedings
u/s 153C of the Act for AY 2013-14 to 2019-20. Accordingly notices u/s 153C of the Act are to
issued.

Vadodara (R. K. SIngh)

Date: 29.03.2024 Assistant Commissioner of Income-tax,
Central Circle-3. Vadodara