Income Tax Appellate Tribunal - Raipur
Sujata Sardar, Ambikapur, Surguja vs Income Tax Officer, Ward-1, Ambikapur, ... on 4 September, 2024
आयकर अपील य अ धकरण यायपीठ "एक-सद य" मामला रायपुर म
IN THE INCOME TAX APPELLATE TRIBUNAL
RAIPUR BENCH "SMC", RAIPUR
ी रवीश सूद, या यक सद य के सम
BEFORE SHRI RAVISH SOOD, JUDICIAL MEMBER
आयकर अपील सं. / ITA No. 98/RPR/2024
नधारण वष / Assessment Year : 2014-15
Smt. Sujata Sardar
Subhash Nagar, Bhagwanpur,
Sarguja, Ambikapur-497 001 (C.G.)
PAN: DMEPS4574N
.......अपीलाथ / Appellant
बनाम / V/s.
The Income Tax Officer,
Ward-1, Ambikapur (C.G.)
...... यथ / Respondent
Assessee by : Shri S.R. Rao, Advocate
Revenue by : Dr. Priyanka Patel, Sr. DR
सुनवाई क तार ख / Date of Hearing : 28.08.2024
घोषणा क तार ख / Date of Pronouncement : 04.09.2024
2
Sujata Sardar Vs. ITO, Ward-1, Ambikapur
ITA No. 98/RPR/2023
आदे श / ORDER
PER RAVISH SOOD, JM:
The present appeal filed by the assessee is directed against the order passed by the Commissioner of Income-Tax (Appeals), National Faceless Appeal Center (NFAC), Delhi, dated 31.01.2024, which in turn arises from the order passed by the A.O under Sec. 144/147 of the Income-tax Act, 1961 (in short 'the Act') dated 28.11.2019 for the assessment year 2014-15. The assessee has assailed the impugned order on the following grounds of appeal:
"1) On the facts and in the circumstances of the case and in law, the Ld. Commissioner of Income-tax (Appeals) has erred in confirming the action initiating re-assessment proceedings u/s.147 of the Income-tax Act,1961 without fulfilling all the conditions required under the Act.
2) On the facts and in the circumstances of the case and in law, the Ld. Assessing Officer has erred in making Rs.36,68,940/- as unexplained Bank Deposit in her bank account with SBI.
3) The impugned order is bad in law and on facts.
4) The appellant reserves the right to addition, after or omit all or any of the grounds of appeal in the interest of justice."
Also the assessee has filed an additional ground of appeal which reads as under:
"In the facts and circumstances of the case and in law, the Ld. Commissioner of Income Tax (Appeals), NFAC, New Delhi had erred in dismissing the appeal by invoking provisions of sec. 249(3) of the Income Tax Act, 1961 on the grounds of delay without issuing any deficiency memo before invoking said provisions of the Act."3
Sujata Sardar Vs. ITO, Ward-1, Ambikapur ITA No. 98/RPR/2023
2. Succinctly stated, the A.O based on information that though the assessee had made cash deposits of Rs.36,68,942/- during the subject year in her bank account but had not filed her return of income, initiated proceedings u/s. 147 of the Act. Notice u/s. 148 of the Act, dated 27.03.2019 was issued to the assessee.
3. As the assessee despite having been afforded sufficient opportunities by the A.O had failed to participate in the assessment proceedings, therefore, the latter was constrained to proceed with and frame the assessment to the best of his judgment u/s. 144 of the Act. Accordingly, the A.O treating the entire amount of cash deposit of Rs.36,68,942/- (supra) as the income of the assessee from unexplained sources, assessed her income vide his order passed u/ss. 144/147 of the Act, dated 28.11.2019 at Rs.36,68,940/-.
4. Aggrieved the assessee carried the matter in appeal before the CIT(Appeals). Ostensibly, as the assessee's appeal was filed beyond the stipulated time period and was not supported by any application seeking condonation of the delay therein involved, therefore, the CIT(Appeals) dismissed the appeal in limine by observing as under:
"Findings
5. This is a case where an appeal is sought to be preferred after an inordinate delay of 504 days beyond the time limit prescribed under sub section (2) of section 249 of the Act. In this context, it 4 Sujata Sardar Vs. ITO, Ward-1, Ambikapur ITA No. 98/RPR/2023 is pertinent to refer to the relevant provisions which read as under:-
Form of appeal and limitation
249.(2) The appeal shall be presented with in thirty days of the following date, that is to say,--(a) where the appeal is under section 248, the date of payment of the tax, or
(b) Where the appeal relates to any assessment or penalty, the date of service of the notice of demand relating to the assessment or penalty:
Provided that, where an application has been made under section 146 for reopening an assessment, the period from the date on which the application is made to the date on which the order passed on the application is served on the assessee shall be excluded.
Provided further that where an application has been made under sub-section (1) of section 270AA, the period beginning from the date on which the application is made, to the date on which the order rejecting the application is served on the assessee, shall be excluded, or (C) in any other case, the date on which intimation of the order sought to be appealed against is served.
(2A) Notwithstanding anything contained in sub-section (2), where an order has been made under section 201 on or after the 1st day of October, 1998 but before the 1st day of June, 2000 and the assessee in default has not presented any appeal within the time specified in that sub-section, he may present such appeal before the 1st day of July, 2000.
(3) The Commissioner (Appeals) may admit an appeal after the expiration of the said period if he is satisfied that the appellant had sufficient cause for not presenting it within that period.
5.1 It is pertinent to note here that the delay may be condoned and the appeal may be admitted under section 249 (3) only if the appellant could successfully demonstrate that it had "sufficient cause" for not presenting the appeal within the stipulated period of thirty days. The exercise of discretion in matters of limitation, such as by way of condoning the delay under section 249 (3) of the Act, has to be carried out within the meaning of "sufficient cause", as referred to in Section 5 of The Limitation Act, 1963. The general rule of law of limitation is that an extension of prescribed period shall not be granted, unless the appellant 5 Sujata Sardar Vs. ITO, Ward-1, Ambikapur ITA No. 98/RPR/2023 satisfies the court that he had " sufficient cause" for not presenting the appeal within the prescribed period. The onus of establishing "sufficient cause" lies on the appellant, as clearly laid down in various judicial pronouncements.
5.2 Hon'ble Supreme Court, in the case of Perumon Bhagvathy Devaswom, Perinadu Village Vs. Bhargavi Amma(Dead) by LRs, (2008) (8 SCC 321), has enunciated certain principles which are applicable while considering applications for condonation of delay, under Section 5 of imitation Act. These principles may be summarized as follows:-
(i) The words "sufficient cause", as appearing in Section 5 of Limitation Act, should receive a liberal construction when the delay is not on account of any dilatory tactics, want of bonafides, deliberate in action or negligence on the part of the applicant/appellant, in order to advance substantial justice. The words "sufficient cause for not making the application within the period of limitation" should be understood and applied in a reasonable, pragmatic, practical and liberal manner, depending upon the facts and circumstances of the case.
(ii) The decisive factor in condonation of delay is not the length of delay but sufficiency of a satisfactory explanation.
(iii) The degree of leniency to be shown by a court depends on the nature of application and facts and circumstances of the case. For example, courts view delays in making applications in a pending appeal more leniently than delays in the institution of an appeal. The courts view applications relating to lawyer's lapses more leniently than applications relating to litigant's lapses.
(iv) Want of 'diligence' or 'inaction' can be attributed to an applicant/appellant only when something, required to be done by him, is not done. When nothing is required to be done, courts do not expect the applicant/appellant to be diligent. Where an appeal is admitted by the High Court and is not expected to be listed for final hearing for a few years, an appellant is not expected to visit the court regularly to ascertain the current position but await information from his counsel about the listing of the appeal.
5.3 To quote their lordships 'decision verbatim in the case cited supra:-
"13 The words "sufficient cause for not making the application within the period of limitation" should be understood and applied in a reasonable, pragmatic, practical and liberal manner, 6 Sujata Sardar Vs. ITO, Ward-1, Ambikapur ITA No. 98/RPR/2023 depending upon the facts and circumstances of the case, and the type of case. The words "sufficient cause" in Section 5 of the Limitation Act should receive a liberal construction so as to advance substantial justice, when the delay is not on account of any dilatory tactics, want of bona fides, deliberate inaction or negligence on the part of the appellant."
5.4 The aforesaid view was reiterated in the case of Balwant Singh (Dead) Vs. Jagdish Singh, (2010) (8 SCC 685), where in the Court has held as under:-
"25. We may state that even if the term "sufficient cause" has to receive liberal construction, it must squarely fall withini,pe concept of reasonable time and proper conduct of the party concerned. The purpose of introducing liberal construction normally is to introduce the concept of "reasonableness" as it is understood in its general connotation.
26. The law of limitation is a substantive law and has definite consequences on the right and obligation of a party to arise. These principles should be adhered to and applied appropriately depending on the facts and circumstances of a given case. Once a valuable right has accrued in favour of one party as a result of the failure of the other party to explain the delay by showing sufficient cause and its own conduct, it will be unreasonable to take away that right on the mere asking of the applicant, particularly when the delay is directly a result of negligence, default or inaction of that party. Justice must be done to both parties equally. Then alone the ends of justice can be achieved. If a party has been thoroughly negligent in implementing its rights and remedies, it will be equally unfair to deprive the other party of a valuable right that has accrued to it in law as a result of his acting vigilantly."
5.5 The Courts in the abovementioned cases have highlighted upon the importance introducing the concept of "reasonableness" while giving the clause "sufficient cause" a liberal interpretation. In furtherance of the same, the Courts has cautioned regarding the necessity of distinguishing cases where delay is of few days, as against the cases where the delay is inordinate as it might accrue to the prejudice of the rights of the other party. In such cases, where there exists inordinate delay and the same is attributable to the party's inaction and negligence, the Courts have to take a strict approach so as to protect the substantial rights of the parties.
5.6 In the case of Ornate Traders Private Limited Vs I.T.O. (Order dated 29.08.2008 arising out of ITA No 1814 of 2008), the 7 Sujata Sardar Vs. ITO, Ward-1, Ambikapur ITA No. 98/RPR/2023 Division bench of Hon'ble Bombay High Court have emphasized the need for reasonableness and hence, the actions which can be condoned by the court should fall within the scope of normal human conduct or normal conduct of a litigant. The Bombay High Court has further observed that while Section 5 of the Limitation Act is being interpreted liberally, it cannot be so liberally that it is without any justification, since condonation of delay in a mechanical or routine manner will jeopardize the legislative intent behind Section 5.
5.7 The Hon'ble Supreme Court in the case of Shiv Dass Vs. Union of India (UOI) & Ors., (AIR 2007 SC 1330) their discretion that the High Courts, while exercising powers under Article 226, should consider delay or lapses and, refuse to invoke its extraordinary powers if it is found that the applicant had neglected/omitted to assert its rights in a timely manner; so however, thon has to be exercised judicially and reasonably. 5.8 The Hon'ble Supreme Court, in a recent judgment in the case of University of Delhi Vs Union of India & Ors., in its order dated 17.12.2019 arising out of Civil Appeal No. 9488 of 2019, has refused to condone delay by holding that:-
"27....the entire explanation as noted above, depict the casual approach, unmindful of the law of limitation despite being aware of the position of law. That apart when there is such a long delay and there is no proper explanation, lapses would also come into play while noticing as to the manner in which a party has proceeded before filing an appeal.
28. In the matter of condonation of delay and lapses, the well accepted position is also that the accrued right of the opposite party cannot be lightly dealt with."
5.9 In the case of Vedabai alias Vaijayanatabai Baburao Patil v. Shantaram Baburao Patil Smt. Vedabai (2002) (122 Taxman
114) (SC), the Hon'ble Apex Court, while disposing appeal, has concluded that a distinction has to be made between inordinate delay and a case where the delay is of few days and the court has to exercise discretion on facts of each case. The relevant portion of the judgment is reproduced as under,-
"In exercising discretion u/s.5 of the Limitation Act, 1963, to condone delay for sufficient cause in not preferring an appeal or other application within the period prescribed, courts should adopt a pragmatic approach. A distinction must be made between a distinction mu case where the delay is in ordinate and a case where the delay is of a few days. Whereas in the former consideration of prejudice to the other side will be a relevant 8 Sujata Sardar Vs. ITO, Ward-1, Ambikapur ITA No. 98/RPR/2023 factor and calls for a more cautious approach, in the later case no such consideration may arise and such a case deserves liberal approach. No hard and fast rule can be laid down in this regard. The court has to exercise its discretion on the facts of each case keeping in mind that in construing the expression "sufficient cause" the principle of advancing substantial justice is of prime importance. The expression "sufficient cause" should receive a liberal construction."
5.10 From the above decisions it becomes clear that in the case of condonation of delay, where the appeal was filed beyond the limitation of period, the courts are empowered to condone the delay, provided that the appellant can prove his claim of inability to file appeal within the prescribed period. Litigant must be able to demonstrate that there was "sufficient cause" which obstructed his action to file appeal, beyond the prescribed time limit."
5.11 The law of limitation is found upon the maxims Interest Reipublicae Ut Sit Finis Litium" i.e. litigation must come to an end in the interest of society as a whole, and "vigilantibus non dormientibus subveniunt" i.e. the law assists those that are vigilant with their rights, and not those that sleep thereupon. The law of limitation in India identifies the need for limiting litigation by striking a balance between the interests of the state and the litigant.
5.12 The Single Judge bench of the Hon'ble Madras High Court, while exercising writ jurisdiction in Kathiravan Pipes Pvt. Ltd., Vs CESTAT, (2007) (5 STR 9) (Mad.) has observed that the period of limitation prescribed is not for destruction of a statutory right but only to give finality without protracting the matter endlessly. 5.13 In the present case, the appellant has not adduced any reasonable cause which prevented it from filing the appeal within the prescribed period of thirty days. It has filed the present appeal after an inordinate delay of more than two months. Unless and until it is demonstrated that there was sufficient cause that prevented the appellant from exercising its legal remedy of filing appeal within that prescribed period of thirty days, the delay thereafter cannot be condoned without there being compelling grounds, as Laid down by the Hon'ble Courts.
5.14 On the given facts of the case, it is clear that the statutory right to appeal which was vested with the appellant has not been exercised within the stipulated time under section 249(2). Thus, 9 Sujata Sardar Vs. ITO, Ward-1, Ambikapur ITA No. 98/RPR/2023 this is clearly case of lapses, which are directly the result of deliberate inaction on the part of the appellant. 5.15 This is not a case of change in law which is beneficial to the appellant and hence the delay in seeking such remedy may be condoned in the furtherance of substantial justice. Therefore, there is no denial or destruction of a statutory right in this case, by adhering to the prescribed period of limitation as otherwise it will only lead to protract the matter endlessly and will undoubtedly render the legislative scheme and e and intention behind the concerned provision otiose as held by Supreme Court in the case of Hon'ble Assistant Commissioner(CT) LTU, Kakinada & Ors. Vs M/s Glaxo Smith Kline Consumer Health Care Limited (2020) (36 G.S.T.L. 305).
5.16 Hon'ble High Court of Punjab and Haryana, in the case of CIT Vs Ram Mohan Kabra (2002) (257 ITR 773) (Punjab & Haryana)has upheld the decision of Tribunal, in declining the condonation of delay of five days only, with the following ratio:-
"3. The provisions relating to prescription of limitation in every statute must not be construed so liberally that it would have the effect of taking away the benefit accruing to the other party in a mechanical manner. Where the Legislature spells out a period of limitation and provides for power to condone the delay as well, there such delay can be condoned only for sufficient and good reasons supported by cogent and proper evidence. Now it is a settled principle of law that the provisions relating to specified period of limitation must be applied with their rigour and effective consequences."
5.17 Hon'ble High Court of Allahabad, in the case of Sital Prasad Vs CIT (1991) (187 ITR 135) (Allahabad) has upheld the decision of lower appellate authorities, in declining the condonation of delay of about three months, where the condonation was sought on grounds of an accident and fracture, but no medical certificate was filed in support.
5.18 Hon'ble Supreme Court, in the case of P K Ramchandran Vs State of Kerala (AIR 1998 SC 2276) has held that law of limitation may harshly effect a particular party, but it has to be applied with all its rigour when the statute so prescribes, and the Courts have no power to extend the period of limitation on equitable grounds. The same view has been reiterated by the Hon'ble Apex Court in the case of Lachhman Das Arora Vs Ganeshi Lal (1999) (8 SCC 532).
5.19 Hon'ble Delhi High Court, in the case of Hindustan Coca- Cola Marketing (P) Ltd. Vs M/s I. P. Arts Society (RFA No 10 Sujata Sardar Vs. ITO, Ward-1, Ambikapur ITA No. 98/RPR/2023 333/2011 dated 06.07.2011) (Delhi) has held that that total negligence and inaction on part of the party cannot be condoned, as the issue of condonation of delay is case and facts specific.
6. On the facts and circumstances of the case, and in view of the position of law applicable on the given facts, I am satisfied that the appeal has not been presented within the period prescribed under section249(2) of the Act, i.e. thirty days from the date of service of the notice of demand relating to the assessment order. I am also satisfied that the appellant has not been able to show any "sufficient cause" for not presenting the appeal within the said prescribed period, within the meaning of section 249(3) of the Act, read with section 5 of The Limitation Act. The application seeking condonation of delay in presenting the appeal is hereby rejected. Accordingly, the appeal is not admitted for adjudication on merits.
7. In the result, the present appeal is dismissed in limine."
5. The assessee being aggrieved with the order of the CIT(Appeals) has carried the matter in appeal before the tribunal.
6. I have heard the Ld. Authorized Representatives of both the parties, perused the orders of the lower authorities and material available on record as well as considered the judicial pronouncements that have been pressed into service by the Ld. AR to drive home his contentions.
7. Shri S.R. Rao, Ld. Authorized Representative (for short 'AR') for the assessee at the threshold submitted that the CIT(Appeals) had based on his perverse observations dismissed the appeal in limine. The Ld. AR submitted that as the assessment order was received by the assessee on 23.06.2021, therefore, it was incorrect on the part of the CIT(Appeals) to reckon the period of limitation from 28.11.2019, i.e. the date on which the 11 Sujata Sardar Vs. ITO, Ward-1, Ambikapur ITA No. 98/RPR/2023 impugned order was passed, and observe that a delay of 504 days was involved in filing of the appeal. The Ld. AR on being confronted with the fact that the assessee in "Form 35" had herself mentioned the date of service of order/notice of demand as 28.11.2019 submitted that the same was inadvertently so mentioned by her. Apart from that, the Ld. AR submitted that even otherwise the CIT(Appeals)'s office had failed to point out the defeciency in the appeal, i.e. absence of application seeking condonation of delay and had summarily proceeded with and dismissed the appeal. The Ld. AR submitted that as the assessee for no fault on her part had remained divested of an opportunity to prosecute the appeal before the first appellate authority, therefore, the matter, in all fairness, be restored to his file with a direction to re-adjudicate the same. Also, the assessee had placed on record an "affidavit" dated 31.05.2024, wherein she had deposed that the order of assessment passed u/ss. 144/147 of the Act, dated 28.11.2019 was made available on her only as on 23.06.2021. For the sake of clarity, the contents of the "affidavit" dated 31.05.2024 is culled out as under:
12
Sujata Sardar Vs. ITO, Ward-1, Ambikapur ITA No. 98/RPR/2023
8. The Ld. AR submitted that the assessee has a prima-facie good case on merits. Elaborating on his contention, the Ld. AR submitted that the subject cash deposits in assessee's bank account during the year under consideration were partly sourced out of the sale proceeds of a property, viz. agricultural land situated at Vill: Subhash Nagar, Khasra No.212/4 that was inherited by the assessee from her father and sold by her vide a 13 Sujata Sardar Vs. ITO, Ward-1, Ambikapur ITA No. 98/RPR/2023 registered sale deed dated 21.05.2013. The Ld. AR in support of his aforesaid contention had drawn our attention to the copy of the sale deed, Page 21 to 32 of APB.
9. Per contra, the Ld. Departmental Representative (for short 'DR') relied on the orders of the lower authorities. As the assessee in the course of hearing of the appeal had averred that the order passed u/ss. 147/144 of the Act dated 28.11.2019 was served upon her on 23.06.2021, therefore, the Ld. DR was directed to verify the factual position. In compliance, Dr. Priyanka Patel, Ld. Sr. DR on the next date of hearing had placed on record "extract" of a "dispatch register". The Ld. DR referring to Sr. No.3436 of the "dispatch register", fairly admitted that though the order passed u/ss.144/147 of the Act, dated 28.11.2019 was despatched by the A.O through registered/speed post but the same thereafter was returned unserved. The Ld. DR on being queried as to whether any attempt was thereafter made by the department to serve the aforesaid order on the assessee, submitted that nothing could be gathered from the record.
10. I have thoughtfully considered the facts involved in the present appeal in the backdrop of the contentions advanced by the Ld. Authorized Representatives of both the parties. Admittedly, it is a matter of fact borne from record that the assessee's appeal was dismissed in limine by the Ld. CIT(Appeals), for the reason that though the same involved a delay of 504 14 Sujata Sardar Vs. ITO, Ward-1, Ambikapur ITA No. 98/RPR/2023 days but no application seeking condonation of the same was filed by the assessee. At the threshold, I may herein observe that the aforesaid observation of the CIT(Appeals) is in itself found to be contradictory.
Although the CIT(Appeals) had at Page 3 of his order had observed that there was a delay of 504 days involved in filing of the present appeal by the assessee but she had not filed any application seeking condonation of the same, but thereafter, at Page 14, Para 6, he had observed that the application seeking condonation of delay involved in filing of the present appeal is rejected. I am unable to comprehend that if the assessee had not filed any application seeking condonation of delay involved in filing of the present appeal as observed by the CIT(Appeals), then, how could he, thereafter, reject her application seeking condonation of delay? Accordingly, the fact as to whether or not the assessee had filed any application seeking condonation of delay involved in filing of the appeal cannot be gathered from the order of the CIT(Appeals).
11. Apart from that, I am of the view that the Ld. AR's claim that as the impugned order u/ss. 144/147 of the Act, dated 28.11.2019 was received by the assessee only as on 23.03.2021 (endorsement of which is found in the body of the assessment order), therefore, there was a delay of 24 days involved in filing of the appeal could not have been summarily discarded. I, say so, for the reason that the fact that the order passed by the A.O u/ss. 144/147 of the Act, dated 28.11.2019 was served upon the assessee 15 Sujata Sardar Vs. ITO, Ward-1, Ambikapur ITA No. 98/RPR/2023 cannot be gathered from the "dispatch register" (extract) as had been placed on record by the Ld. DR. As observed by me hereinabove, the Ld. DR referring to the aforesaid "dispatch register" (extract), had stated that as per Sr. No.3436, the aforesaid order was returned unserved by the postal authority. Also, it is stated by her that the fact that as to whether the impugned order was thereafter served upon the assessee cannot be gathered from the record.
12. Considering the aforesaid facts, I am of the view that not only the order of the CIT(Appeals) suffers from a contradictory observation, but also, the fact that the delay involved in filing of the appeal, if reckoned from the date of 23.06.2021 i.e. the date of service of order works out at 24 days. At the same time, I find that the assessee had failed to file an application seeking condonation of the delay involved in filing of the appeal before the CIT(Appeals) which is indispensably required for triggering the latter's discretion as contemplated under sub-section (3) of Section 249 of the Act. I am of the view that considering the totality of the facts involved in the present appeal, i.e. (i) contradictory observation of the CIT(Appeals) as regards the filing/non-filing of the application seeking condonation of delay by the assessee; and (ii) the incorrect calculation of the period of delay by losing sight of the date on which the order of the assessment u/ss. 144/147 of the Act dated 28.11.2019 was actually served upon the assessee for the first time; the matter in all fairness requires to be restored 16 Sujata Sardar Vs. ITO, Ward-1, Ambikapur ITA No. 98/RPR/2023 to the file of the CIT(Appeals). Needless to say, the CIT(Appeals) shall in the course of the set aside proceedings on an application filed by the assessee seeking condonation of the delay originally involved in filing of the appeal, if so advised, shall consider the same as per Section 249(3) of the Act. Also, considering the fact that the assessee had filed before me an "affidavit", dated 31.05.2024 deposing that the order of assessment passed u/ss.144/147 of the Act dated 28.11.2019 was received by her only as on 23.06.2021, the CIT(Appeals) is directed to verify the correctness of the said claim in course of the set aside proceedings.
13. Before parting, I may herein observe that as the matter is restored to the file of the CIT(Appeals), therefore, the latter shall remain at a liberty to exercise his discretion as to whether or not the delay involved in filing of the appeal merits to be condoned. Thus, Grounds of appeal Nos.1 to 3 and additional ground of appeal raised by the assessee are allowed for statistical purposes in terms of the aforesaid observations.
14. In the result, appeal of the assessee is allowed for statistical purposes in terms of the aforesaid observations.
Order pronounced in open court on 04th day of September, 2024.
Sd/-
(रवीश सूद /RAVISH SOOD) या यक सद य/JUDICIAL MEMBER रायपुर/ RAIPUR ; दनांक / Dated : 04th September, 2024. 17
Sujata Sardar Vs. ITO, Ward-1, Ambikapur ITA No. 98/RPR/2023 ***SB, Sr. PS आदे श क त ल प अ े षत / Copy of the Order forwarded to :
1. अपीलाथ / The Appellant.
2. यथ / The Respondent.
3. The CIT(Appeals)-1, Raipur (C.G)
4. The Pr. CIT-1, Raipur (C.G)
5. वभागीय त न ध, आयकर अपील य अ धकरण,रायपुर बच, रायपुर / DR, ITAT, Raipur Bench, Raipur.
6. गाड फ़ाइल / Guard File.
आदे शानुसार / BY ORDER, // True Copy // Senior Private Secretary आयकर अपील य अ धकरण, रायपुर / ITAT, Raipur.