New Delhi: The 24-page notice issued by the Income Tax department to Young Indian (YI) Pvt Limited termed Congress chief Sonia Gandhi and party vice-president Rahul Gandhi as “the real beneficiary of the transaction” carried out to acquire properties worth Rs 2,000 crore.

CNN-News18 has accessed a copy of the I-T notice, a day after a political storm broke out in the wake of the Delhi High Court’s refusal to stay the tax proceedings against YI and its directors.

Apart from its indictment of Sonia and Rahul, the notice reveals that I-T department has ascribed a role of complicity on Priyanka Gandhi Vadra as well. Dated January 10, 2017, the notice claims that Priyanka played a role in ascertaining that YI, which has Sonia and Rahul as its majority shareholders, comes in control of 100 per cent shares of this company.

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According to the I-T department, Rahul and Priyanka, through Rattan Deep Trust and Janhit Nidhi Trust, acquired additional shares of Associated Journals Ltd to get the Gandhi family out-and-out control.

As per the notice issued under Section 148 of the I-T Act for a reassessment of YI’s income for the financial year 2010-11, a clear-cut case of attempts to evade taxes through sham transactions and incorrect reporting of financials was made out. YI was incorporated as a non-profit making company with its stated objective as: ‘Youth commitment to the ideal of democratic and secular society’.

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The I-T notice, however, questions every step in the series of the transaction which, it contended, resulted in transferring control of assets worth around Rs 2,000 crore from Associated Journals Ltd (AJL) – the publishers of now-defunct The National Herald newspaper, to Sonia, Rahul and other directors of YI. Congress leaders Motilal Vora and Sam Pitroda, perceived as trusted aides of Nehru-Gandhi family, figured as other directors in YI.

The I-T points out AJL’s properties at Delhi, Mumbai, Lucknow, Panchkula and Patna to provide an estimated value of assets that allegedly stand transferred to YI after the takeover.

“The takeover of AJL by YI has resulted in the acquisition of all the immovable properties of AJL along with the right to enjoy a huge rental income of several crores from some of the properties. Since more than 75 percent shares of YI are held by Sonia Gandhi and Rahul Gandhi, they were the real beneficiary of the transaction,” states the I-T notice.

The department censures the manner in which AJL, which allegedly owed Rs 90 crore to Congress, was taken over through shareholding by YI in lieu of Rs 50 lakh. Rs 50 lakh was reportedly paid by YI to Congress for assuming the Rs 90 crore loan.

The I-T department found it curious that all the people involved in the series of transactions were common and were connected to Congress, AJL and YI.

“If one looks at illogical sequences of events and the celerity at which these transactions were made by the common office-bearers of AJL, YI and AICC, then conclusion is simple to guess that Sonia Gandhi and Rahul Gandhi, along with their trustworthy associates, have taken over property of more than Rs 2,000 crore for a paltry sum of Rs 50 lakh,” reads the notice.

The department adds: “A pre-meditated scheme was devised to obtain control over immovable properties of AJL worth several hundred crores by persons who incorporated YI... acquisition of property was the real target of the transaction.”

It further maintains that the swiftness with which the properties of AJL at prime locations across India were acquired by YI by making a meager investment of Rs 50 lakh through the takeover of AJL was possible due to common office-bearers of these parties, who were in-charge of management of all the parties to these transactions.

“This proves that all the three entities were same and one in reality but on the paper, these three are distinct and different legal entities,” says the notice.

About the alleged role played by Priyanka, the I-T department claims: “In order to achieve the object of taking over 100 percent shares of AJL by YI, Sonia, Rahul and Priyanka Gandhi Vadhera also purchased additional 47513 and 26244 shares of AJL through Rattan Deep Trust and Janhit Nidhi Trust respectively.”

The department, in its notice, has furnished brief profile of Sonia, Rahul, Fernandes, Vora, Pitroda and Suman Dubey to assert those office bearers of Congress, directors of the YI and the AJL are common persons. “…which had helped these entities in carrying out transactions among these entities with great speed even without following the logical sequence of transactions as a prudent businessman, which lead to an irresistible conclusion that these transactions were pre-determined, pre-planned and stage-managed,” it contends.

Describing the transactions as “sham”, the notice states that even though AJL continues to remain a legal entity with a right to hold properties, the true character of these transactions has to be judged by looking at reality and after removing the veil of AJL, YI and All India Congress Committee.

“The real purpose of the loan from INC and allotment of share to YI by AJL was in reality only to transfer immovable properties of AJL to YI along with full right over rental income and business income from real estate business of AJL without paying any taxes. The artificially inserted steps have no business purpose except for evading taxes on income earned by YI on the takeover of immovable properties of AJL,” according to the I-T notice.

It accused YI of “unfair reporting of its financials” by calling transaction of taking over the loan of AJL as an insignificant investment. “How come full takeover of a company having properties worth Rs 1600 crore or more could be an insignificant investment? There appears to be a conscious effort to avoid detection of real transaction leading to the payment of taxes,” questions the notice.

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