Income Tax Appellate Tribunal - Ahmedabad
Navratna Organisers & Developers Pvt. ... vs Assessee on 27 August, 2014
IN THE INCOME TAX APPELLATE TRIBUNAL " A " BENCH, AHMEDABAD
(BEFORE SHRI MUKUL Kr. SHRAWAT, J.M. & SHRI ANIL CHATURVEDI, A.M.)
I.T. A. No. 2143 /AHD/2009 & C.O. No. 145/A/2009
(Assessment Year: 2000-2001
The D.C.I.T., Central Circle- V/S M/s. Navratna Organisers &
1(1), Ahmedabad Dev. Pvt. Ltd. 2nd Floor,
Kaycrest, Opp. Gujarat Gas
Co. Ltd., Nr. Parimal
Crossing , C.G. Road,
Ahmedabad
(Appellant) (Respondent)
M/s. Navratna Organisers & V/S The D.C.I.T., Central Circle-
Dev. Pvt. Ltd. 2nd Floor, 1(1), Ahmedabad
Kaycrest, Opp. Gujarat Gas
Co. Ltd., Nr. Parimal
Crossing , C.G. Road,
Ahmedabad
(Appellant) (Respondent)
PAN: AAACN5181E
Appellant by : Shri Subhash Bains, CIT/D.R.
Respondent by : Shri Deepak Soni, A.R.
आदे श)/ORDER
(आदे Date of hearing : 15-07-2014 Date of Pronouncement : 27-08-2014 PER SHRI ANIL CHATURVEDI,A.M.
1. This appeal is filed by the Revenue against the order of CIT(A)-III, Ahmedabad dated 31.03.2009 for A.Y. 2000-01 and Assessee has also filed a C.O.
2. The facts as culled out from the material on record are as under.
2ITA No 2143/AHD/09 & C.O No. 145/A/09 . A.Y. 2000-2001
3. Assessee is a company engaged in the business of construction of housing projects. The Assessee filed its return of income for A.Y. 2000-2001 on 30.11.2000 and total income of Rs. 18,749/- was declared u/s. 115JA of the Act and the return was processed u/s. 143(1) on 14.02.2002. A search and seizure operation was carried out on 10.05.2006 and during the course of search and seizure operation, certain documents were found and seized, the modus operandi of Assessee's business was also examined by the ADIT and it was found that the Assessee was the real owner of the various projects carried out in the name of Co-operative Housing Societies. On being confronted with the various documents found and seized, Shri Pranav Shah, Managing Director of the Assessee admitted undisclosed profit from Kalhar Bungalow Project (The main project which was being developed by the Assessee during the year under consideration) .at Rs. 4 crore and offered the same for taxation. On the basis of search and seizure operation, notice u/s. 148 was issued and served on Assessee on 23.02.2007 in response to which Assessee filed return of income on 16/04/2007 declaring loss of Rs. 42,625/-. Thereafter assessment was framed u/s. 143(3) read with section 147 vide order dated 28.12.2007 and the total income was determined at Rs. 53,00,095/-. Aggrieved by the order of A.O, Assessee carried the matter before CIT(A). CIT(A) vide order dated 31.03.2009 partly allowed the appeal of the Assessee. Aggrieved by the order of CIT(A), Revenue is now in appeal before us and Assessee has also filed C.O. The grounds raised by the Revenue reads as under:-
1. The Ld.CIT(A) has erred in law and on facts in deleting the addition of Rs. 14,95,000/-
made u/s.68 of the I.T. Act, without considering the fact that the assessee has failed to discharge the onus cast upon it u/s.68 of the I.T. Act.
2. The Ld.CIT(A) has erred in law and on facts in deleting the addition as mentioned in Ground No.l, without considering the fact that the assessee itself has admitted vide reply dated 26.12.2007 that it was not possible to collect details within short period and hence there was no question of furnishing all details as relied in the appellate order. The Ld.CIT(A) has further erred in observing that some of the credits were transferred from other concerns ignoring that the addition of 9 fresh credits was made as against 58 credits in all amounting to Rs.l .78 crores.
3. The Ld.CIT(A) has erred in law and on facts in deleting the addition of Rs.34,79,726/- made on account of bogus and unexplained liability, without considering the glaring facts that the assessee has failed to prove as to how the liabilities have increased when there was no purchase of goods and expenses to such extent.
4. The Ld.CIT(A) has erred in law and on facts in deleting the addition of Rs. 3,11,094/- made by applying 8% net profit rate, without considering the facts of suppression of receipts and incorrect claim of expenses claimed to be recoverable from the project.
3 ITA No 2143/AHD/09 & C.O No. 145/A/09
. A.Y. 2000-2001
5. The Ld.CIT(A) has erred in law and on facts in deleting various additions without considering the facts that sufficient opportunities of being heard vide notices dated 07.09.2007, 26.10.2007, 23.11.2007 and show cause dated 20.12.2007 were provided to the assessee by Assessing Officer besides issue of penalty notice u/s.271(l)(b) dated 26.10.2007.
4. On the other hand the grounds raised by the Assessee in C.O reads as under:-
1.0 The order passed by the Assessing Officer was bad in law. The order was contrary to the provisions of law and the facts of the assessee's case. The order passed by the Assessing Officer ought to have been cancelled by the Commissioner of Income tax (Appeals). It is submitted that it be so held now.
2.0 The Commissioner of Income tax (Appeals) erred in upholding the validity of notice u/s 148 and validity of order u/s. 147. The appellant submits that the notice issued u/s 148 was invalid. The assessee submits the notice being invalid be quashed. 2.1 The assessee further submits that the order of reassessment is contrary to the facts and provisions of law. The assessee submits order of reassessment being invalid ought to have been quashed by the Commissioner of Income tax (Appeals). The assessee submits that the order be quashed.
We first take up the CO of Assessee as it challenges the validity of issue of notice u/s. 148 and the reassessment framed thereunder:-
Though the assessee has raised various grounds but before us it was submitted by ld. AR that the only question is that the validity of issue of notice u/s. 148 and the assessment framed u/s 143 (3) r.w.s. 147.
5. Assessee has challenged the re-opening u/s. 147,148 of the Act. Before us, the ld. A.R. submitted that the notice u/s. 148 was issued beyond 4 years and the A.O was not having any new material on the basis of which he had proceeded for re-assessment. He further submitted that A.O had examined the material and therefore re-opening was on account of change of opinion and it was not permissible in law. He placed reliance on the decision of Bombay Tribunal in the case of H.V Transmission Ltd. vs. ITO ITA NO. 2230/Mum/2010 order dated 07.10.2011, Signature Hotels P. Ltd vs. ITO (2011) 338 ITR 51 (Del) decision of Delhi High Court in the case of CIT vs. Atul Jain & Others (2008) 299 ITR 383, and also the decision in the case of CIT vs. Kelvinator of India Ltd (2010) 320 ITR 561 (SC).
4ITA No 2143/AHD/09 & C.O No. 145/A/09 . A.Y. 2000-2001
6. The ld. D.R. on the other hand submitted that the original return of income in the case of Assessee was processed u/s. 143(1) and there was no assessment u/s. 143(3). He further submitted that ADIT on examining the modus operandi of Assessee's business found that Assessee was the real owner of various projects carried out in the name of co-operative housing societies and the Managing Director of Assessee had admitted undisclosed profit and also offered the same to tax and thus the Assessing Officer had proceeded to re- open the assessment. He further submitted that since the original assessment was u/s. 143(1) there was no application of mind by the A.O and therefore the A.O was fully justified in resorting to reopening of assessment. He placed reliance on the decision in the case of Rajesh Javeri 291 ITR 500 and in the case of Rakesh Agarwal ACIT 225 ITR 496 (Delhi). He thus supported the order of CIT(A).
7. We have heard the rival submissions and perused the material on record. In the present case, it is an undisputed fact that the return of income for A.Y. 2000-01 was filed by Assessee on 30/11/2000 and it was processed u/s. 143(1) of the Act on 14/12/2002. No assessment was subsequently made u/s. 143(3) of the Act. Hon'ble Apex Court in the case of Rajesh Javeri (supra) has held that intimation u/s. 143(1)(a) cannot be treated as assessment order. It is only when regular assessment is made, the Assessing Officer gets an opportunity of applying his mind to various aspects concerning the assessment.
8. Section 147 deals with income escaping assessment and explanation (2) provides for the deemed cases of escapement of income. This explanation has 5 clauses namely (a), (b), (ba), (c) and (d) which deals with distinct and different situations of escapement of income namely where no return of income has been furnished by the Assessee, where return of income has been furnished by the Assessee, but no assessment has been made; where Assessee has failed to furnished report in respect of international transactions required u/s. 92E ; where assessment has been made and where a person is 5 ITA No 2143/AHD/09 & C.O No. 145/A/09 . A.Y. 2000-2001 found to have any assets including financial interest in any entity located outside India.
9. The present case fits in Expl. 2 (b) which states that "where a return of income has been furnished by the Assessee but no assessment has been made and it is noticed by the Assessing Officer that the Assessee has understated the income or has claimed excessive loss, deduction, allowance or relief in the return. " On perusal of this provision, it is borne out that even if no assessment was originally made by the Assessing Officer but subsequently it comes to his notice that the Assessee has understated the income, it shall be deemed to be a case of escaping assessment. The only requirement for assuming jurisdiction in the light of Explan. 2(b) is that "it is noticed by the Assessing Officer that the Assessee has understated the income etc." Thus the requirement of noticing is of understatement of income. We are of view that such noticing as may be from the material already on record or some new material coming to his knowledge. So long as noticing of understatement of income is true, the source of such noticing as emanating from some "new material" or an existing material is wholly irrelevant in the context of Expln. (b). In the present case, on examination of the material found during the course of search and seizure operation, ADIT noticed that Assessee was the real owner of various projects and the Managing Director of the Assessee had also admitted to undisclosed profit from Kalhar Bunglow Project, the main project being developed by Assessee and offered the same to tax. We are of the view that the aforesaid material was sufficient to the Assessing Officer to proceed with the proceedings of reopening of the assessment more so in view of the settled law that at the stage of issue of notice, the only question is whether there was relevant material on which reasonable person could have formed the requisite belief. Whether material would conclusively prove escapement of income is not the concern at that stage. We further find that Hon'ble Apex Court in the case of ACIT vs. Rajesh Javeri Stock Brokers Pvt. Ltd (2007) 291 ITR 500(SC) has held that principles relating to change of opinion are not applicable in respect of the provisions u/s. 147(1) where the return was processed.
6 ITA No 2143/AHD/09 & C.O No. 145/A/09 . A.Y. 2000-2001
8. Considering the aforesaid decision of Hon'ble Apex Court in view of the fact stated above we are of the view that the A.O was fully justified in re-opening the assessment. Further the decisions relied by the ld. A.R are distinguishable on facts and are not applicable to the present facts. We therefore find no infirmity in the order of A.O in re-opening the assessment. Thus, the grounds of Assessee are dismissed.
9. In the result, the Appeal of Assessee is dismissed.
We now take up Revenue's appeal in ITA No. 2143/Ahd/2009 Ground no. 1 and 2 are interconnected and therefore considered together. It is with respect to addition u/s. 68 of the Act.
10. During the course of re-assessment proceedings, A.O noticed that Assessee had received unsecured loan aggregating to Rs. 14,95,000/- from 9 parties listed on page 3 of the assessment order. The Assessee was asked to explain the cash credits appearing in the books by furnishing the full name, addresses, PAN numbers, confirmation etc. A.O noted that Assessee filed confirmation only in 2 cases namely in the case of Neela R. Shah and Ragni Choksi. A.O also noted that Assessee did not file the other details called for and therefore A.O concluded that Assessee has failed to satisfactorily explain the cash credit. He accordingly made addition of Rs. 14,95,000/- u/s. 68 as unexplained cash credit. Aggrieved by the order of A.O, Assessee carried the matter before CIT(A). CIT(A) deleted the addition made by A.O by holding as under:-
11.1 In respect of the additions of Rs. 14.95 lakhs u/s. 68 of the Act, it is seen that the appellant had vide reply dated 26.12.2007, had filed copies of account of the creditors and furnished their names/addresses/confirmations. The PAN of some creditors, the details of interest/paid and/or of repayments were also furnished vide letter dated 30.10.2007. The transactions were routed through bank(s). A number of decisions of examples reported in 301 ITR 298 (Raj), 251 ITR 263 (SC), 307 ITR 165 (Guj), 256 ITR 360, etc, were cited to state that outstanding liability of predecessor entity could not be fastened on the succeeding entity. Thus certain loans (listed at S. No. 1 to 3 and 5 to 7) were raised by M/s. Navratana Kausambi Association (NKA) and were transferred to the successor appellant. It is seen that the facts/details furnished by the appellant in respect of creditors were similar in A.Y. 97-98 7 ITA No 2143/AHD/09 & C.O No. 145/A/09 . A.Y. 2000-2001 as well. In similar facts of the appellant, the then CIT(A)-XI, in appellant's appeal for A.Y. 97- 98 had held in his order, dated 3.01.2005 in appeal No. CIT(A)-XI/112/01-02 that the addition made u/s. 68 was not sustainable. Considering the explanation/details furnished and following the order of CIT(A) in appellant's own appeal for A.Y. 97-98, the addition of Rs. 14.95 lakh u/s. 68 of the Act are deleted. The related ground of appeal is allowed.
11. Aggrieved by the order of CIT(A), Revenue is now in appeal before us.
12. Before us, ld. D.R. submitted that ld. CIT(A) has noted that Assessee had filed copies of the account of the creditors and furnished the names and addresses and confirmation and also the PAN of the same of the creditors against which he pointed to the findings of A.O where A.O has noted that Assessee had not filed the details called for by the A.O. He further submitted that on the details filed by the Assessee before Ld. CIT(A), Ld. CIT(A) did not call for any remand report from A.O. He further submitted that Ld. CIT(A) has noted that similar additions made in 1997-1998 were deleted by CIT(A) but against the order of Ld. CIT(A), the Revenue had preferred appeal before the Hon'ble ITAT.. Hon'ble ITAT vide order in ITA NO. 1114/A/2005 dated 11.09.2009 had remitted the matter to A.O to carry out independent investigation. He pointed to para 24 on page 13 of the aforesaid order. He therefore submitted that in the year under consideration also the matter may be remitted to the file of A.O with suitable directions. On the other hand, ld. A.R. reiterated the submissions made before CIT(A) and supported his order.
13. We have heard the rival submissions and perused the material on record. We find that A.O has noted that Assessee had received unsecured loans aggregating to Rs. 14,95,000/- from 9 parties but Assesse had not discharged the onus by proving the identity, capacity and genuineness of the transaction. We also find that addition u/s. 68 were also made in Assessee's case in 1997-98. (Though the parties were different form those from whom the Assessee had accepted deposits during the year.). The Co-ordinate Bench of Tribunal in that case i.e. for A.Y. 97-98 has remitted the matter to the file of Assessing Officer by noting down as under:-
8 ITA No 2143/AHD/09 & C.O No. 145/A/09 . A.Y. 2000-2001
24. On the other hand, the Learned Authorised Representative of the assessee drew our attention to page No.62 of its paper-book which is an account of AMP Investment on the letter-
had of the assessee. It showed the address of AMP Investment as 502, Panchkuva, Ahmedabad-2 and PAN AABFA7464 P. Then, at page No.63 of the paper-book, there was st information about Victoria Capital Ventures Ltd. It gave the address as Bharat House, 1 Floor, 104, Bombay Samachar Marg, Bombay-23 and. also some Numbers, such as, AAA - CV 3287- D/D,C.Cir(I)/l. This is also a copy of account of Victoria Capital Ventures Ltd. on the letter-head of Navratna Organisers & Developers Pvt. Ltd. At page No.68 of the paper book, is the copy of account of Yogesh Anubhai Shah (HUF) which shows the address of the party as 88, Lavanya Society Vasna, Ahmedabad-7. This is also on the letter-head of the assessee. Page Nos. 72 and 73 of the paper- book show account of Payal Yogesh Shah on the letter-head of the assessee and also address of that party. At page No.77 of the paper-book shows the account of Nilay Yogesh Shah on the letter-head of the assessee with the address of the party. The copies of account: show that money was transferred through cheque, i.e. though banking channels. It is not a case where no data is available for verification. The assertion of the Learned Authorised Representative of the assessee is that these documents were submitted to the Assessing Officer. In any case, we restore the matter to the file of Assessing Officer. The assessee will submit these documents before the Assessing Officer with complete details of the creditors, name of the bank through which money was transferred to the assessee and paid back by the assessee. The assessee will furnish these information so as to enable the Assessing Officer to carry out independent investigation. Initially, documents for establishing identity of the creditors, their creditworthiness and genuineness of the transactions will be submitted by the assessee for further verification by the Assessing Officer.
14. In the present case we find that Ld. CIT(A) has not given any finding with respect to the deposits received by the Assessee and further the depositers are different in both the assessment years i.e. A.Y. 2000-01 and A.Y. 97-98. But however we feel that in the interest of justice that the one more opportunity be granted to Assessee to furnish all the required details called for by the Assessing Officer so as to discharge the onus as required u/s. 68 of the Act. We therefore remit the issue to the file of Assessing Officer to decide the issue afresh as per law and after considering the submissions of Assessee. We also direct the Assessee to submit all the required details called for by the Assessing Officer promptly so as to enable the A.O to decide the issue. Further in case the Assessee fails to furnish the required details, the A.O shall be free to decide the matter on the basis of material on record. Needless to state that Assessing Officer shall grant adequate opportunity of hearing to Assessee. In the result, this ground of Revenue is allowed for statistical purposes.
Ground No. 3 is with respect to deletion of addition of Rs. 34,79,726/- on account of bogus and unexplained liability.
9 ITA No 2143/AHD/09 & C.O No. 145/A/09
. A.Y. 2000-2001
15. On perusing the Balance sheet, Assessing Officer noticed that there was increase in work in progress by Rs. 38,88,672/- and out of the total interest cost of Rs. 35,21,145/-, 90% of the interest amounting to Rs. 31,69,030/- was transferred to project cost. He also noticed that at the year end, the liability for goods increased by Rs. 41,99,368/- though Assessee has not shown purchases of goods in the Profit and Loss Account and further Assessee had also not filed any details to justify the liability. He was therefore of the view that since out total work in progress of Rs. 38,88,672/-, the interest component was Rs. 31,69,030/- there was no scope for increase in liability for goods amounting to Rs. 41,99,368/-. According to Assessing Officer, the increase in liability for goods could be only to the extent of Rs. 7,19,642/- (being the difference between the work in progress of Rs. 38,88,672/- and the interest component of Rs. 31,69,030/- transferred to work in progress.) and he therefore considered the balance liability of Rs. 34,79,726/- (being difference of liability for goods of Rs. 41,99,368/- and the liability of Rs. 7,19,642/- on account of interest) as unexplained bogus liability and added it to the income. Aggrieved by the order of Assessing Officer, Assessee carried the matter before Ld. CIT(A). Ld. CIT(A) after considering the submission, deleted the addition by holding as under:-
"12. In respect of the disallowance for unexplained liability, it has been pointed out that the name/break up of liabilities as on 31/3/1999 and 31/03/2000 had been furnished along with details of transactions. The liabilities arising out of purchases/expenses were vouched and books were audited. The expenses considered directly related to projects and debited to project account while expenses incurred in relation to business operations was debited to P & L Account. The Assessing Officer has not disproved the claim of the appellant that each liability was supported by documentary evidence as invoices, receipts of goods notes, freight bills, name/address/PAN of party and that it was business related and accounted for in books. The reasons for increase in liabilities and break up liabilities arising on account of sundry creditors, expenses and goods were furnished along with reply dated 26/02/2007, to the Assessing Officer. Thus the disallowance of Rs. 34,79,726/- made by the Assessing Officer is not based on proper appreciation of facts and it not supported by requisite evidence to the contrary. This disallowance is therefore unsustainable and is deleted.
10 ITA No 2143/AHD/09 & C.O No. 145/A/09 . A.Y. 2000-2001
16. Aggrieved by the order of Ld. CIT(A), Revenue is now in appeal before us.
Before us, ld. DR pointed to the findings of Assessing Officer and submitted that Assessee had not furnished any documentary evidence about the increasing liability and further CIT(A) also did not call for any remand report from Assessing Officer before deciding the issue. He therefore submitted that the matter may be remitted to A.O for verification. The ld. AR on the other hand reiterated the submissions made before AO and Ld. CIT(A) and further submitted that the books of accounts are audited by Chartered Accounts and he thus supported the order of Ld. CIT(A).
17. We have heard the rival submissions and perused the material on record. We find that AO while disallowing the liability for expenses has noted that Assessee did not furnish the necessary evidence and on the other hand ld. CIT(A) while deleting the addition has noted that AO has not disproved the claim of Assessee that each liability was supported by evidences and the reply was furnished before Assessing Officer. We further find that Ld CIT(A) has not called any remand report from Assessing Officer. Before us also, no details of the liability for expenses, except as shown in the Balance sheet was placed on record. In view of the aforesaid facts, we are of the view that the issue needs re-examination at the end of Ld. CIT(A) and therefore remit the matter to Ld. CIT(A) for him to record the findings about the liability and decide the issue as per law. Needless to state that Ld. CIT(A) shall grant adequate opportunity of hearing to both the parties. The Assessee is also directed to furnish all the required information called for deciding the issue promptly. Thus this ground of Revenue is allowed for statistical purpose.
Ground No. 4 is with respect to deletion of addition of Rs. 3,11,094 by applying net profit rate.
18. During the course of assessment proceedings, on verification of the accounts Assessing Officer noticed that on the total construction receipts of Rs.11
ITA No 2143/AHD/09 & C.O No. 145/A/09 . A.Y. 2000-2001 33,47,000/-, Assessee had shown net profit of Rs. 62,495/- which works out to 1.87% of receipts/WIP which according to Assessing Officer was quite low for the nature of business of Assessee. He therefore by applying the provisions of s. 44AD of the Act, estimated the profit @ 8% and worked out the net profit at Rs. 3,11,094 and made the addition. Aggrieved by the order of Assessing Officer, Assessee carried the matter before Ld. CIT(A). Ld. CIT(A) deleted the addition by holding as under:-
"13. In para 4 of this order the AO has noted that the construction receipts have been shown at Rs. 33.47 lakhs. While work-in-progress has increased by Rs. 38,88,672/- and so felt that receipts of Rs. 5,41,672/- were apparently suppressed further expenses of Rs. 30.75 lakhs, being general and administration in nature, have been debited to P & L Account. The Assessing Officer felt that reply of the assessee was the actual owner of the projects and so profit therefrom was attributable to it alone and sought explanation vide letter dated 23/11/2007. The Assessing Officer felt that reply of the assessee dated 30/10/2007 was contradictory and so books were unreliable. The Assessing Officer therefore invoked provisions of section 44AD and estimated net profit at Rs. 3,11,094/- i.e. @ 8% on receipts of Rs. 38.88 lakhs. The Assessing Officer has however, not pointed out which expense(s) are unrelated to business or to the projects alone. The Assessing Officer has not pointed out to any instance in which such an expense, debited to P & L Account was recovered from the project(s). The Assessing Officer has not brought on record any details/instances of unvouched expenses, and other defects in the books of account. The rejection of books of account, in similar facts was not upheld by the CIT(A) in respect to A.Y. 1997-98, in the aforementioned appeal order also. The appellant had furnished explanation to the Assessing Officer in his reply dated 30/10/2007 and 26/12/2007. Thus on a holistic consideration, the rejection of books of account and estimation of projects u/s. 44AD, cannot be upheld. The addition of Rs. 3,11,094/- is therefore deleted and related ground of appeal is allowed. "
19. Aggrieved by the order of Ld. CIT(A), Revenue is now in appeal before us.
Before us, Ld. DR relied on the order of Assessing Officer. On the other hand, ld. A.R. reiterated the submissions made before Assessing Officer and Ld. CIT(A). He thus supported the order of Ld. CIT(A).
12ITA No 2143/AHD/09 & C.O No. 145/A/09 . A.Y. 2000-2001
20. We have heard the rival submissions and perused the material on record. We find that Ld. CIT(A) while deleting the addition has noted that Assessing Officer has not brought any material on record of any details/instances of un-vouched expenses and not pointed any instance in which the expenses debited to Profit and Loss Account etc. was recovered from the project. He further noted that on similar facts for A.Y. 97-98, the rejection of books of accounts was not upheld by ld. CIT(A). Before us, Revenue was not brought any material to controvert the finding of Ld. CIT(A). We therefore find no reason to interfere with his order. Thus this ground of Revenue is dismissed.
21. Thus the appeal of Revenue is partly allowed for statistical purposes.
22. In the result, the appeal of Revenue is partly allowed for statistical purposes and the C.O. of Assessee is dismissed.
Order pronounced in Open Court on 27 - 08 - 2014.
Sd/- Sd/-
(MUKUL Kr. SHRAWAT) (ANIL CHATURVEDI)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Ahmedabad. TRUE COPY
Rajesh
Copy of the Order forwarded to:-
1. The Appellant.
2. The Respondent.
3. The CIT (Appeals) -
4. The CIT concerned.
5. The DR., ITAT, Ahmedabad.
6. Guard File.
By ORDER
Deputy/Asstt.Registrar
ITAT,Ahmedabad