Income Tax Appellate Tribunal - Ahmedabad
Deepak Manilal Patel, Ahmedabad vs Acit, Central Circle-2(1), Ahmedabad on 6 December, 2016
आयकर अपील
य अ धकरण, अहमदाबाद यायपीठ, अहमदाबाद ।
IN THE INCOME TAX APPELLATE TRIBUNAL
"D" BENCH, AHMEDABAD
BEFORE SHRI RAJPAL YADAV, JUDICIAL MEMBER
AND
SHRI PRADIPKUMAR KEDIA, ACCOUNTANT MEMBER
ITA No. and Appellant Respondent
Asstt.Year Vs
2410/Ahd/2011 Shri Jayesh Kantilal Patel The ACIT,
A.Y.2007-08 301/1, "Parshwa' Cent.Cir.2(1)
Opp: Rajpath Club Ahmedabad.
S.G. Road, Bodakdev
Ahmedabad 380 054.
PAN : ACDPP 8627 R
2411/Ahd/2011 Shri Deepak Manilal Patel Vs The ACIT,
A.Y.2007-08 301/1, "Parshwa' Cent.Cir.2(1)
Opp: Rajpath Club Ahmedabad.
S.G. Road, Bodakdev
Ahmedabad 380 054.
PAN : AAQPP 3324 H
2412/Ahd/2011 Shri Prakash Chandulal Patel Vs The ACIT,
A.Y.2007-08 301/1, "Parshwa' Cent.Cir.2(1)
Opp: Rajpath Club Ahmedabad.
S.G. Road, Bodakdev
Ahmedabad 380 054.
PAN : ACMPP 1947 K
2413/Ahd/2011 Shri Pranay Kantilal Patel Vs The ACIT,
A.Y.2007-08 301/1, "Parshwa' Cent.Cir.2(1)
Opp: Rajpath Club Ahmedabad.
S.G. Road, Bodakdev
Ahmedabad 380 054.
PAN : ACDPP 8720 B
अपीलाथ / (Appellant) यथ / (Respondent)
Assessee by : Shri Dhiren Shah, AR
Revenue by : Shri Rajesh Kumar Sinha,
CIT-DR
ु वाई क तार ख/ Date
सन of Hearing : 19/10/2016
ITA No.2411/Ahd/2011 & 3 Others
2
घोषणा क तार ख / Date of Pronouncement: 06/12/2016
आदे श/O RDER
PER SHRI RAJPAL YADAV, JUDICIAL MEMBER:
Present four appeals are directed at the instance of assessees against separate orders of ld.CIT(A)-III, Ahmedabad dated 2.8.2011 passed on the respective appeals of the assessees for Asstt.Years 2003-04 to 2009-10. The dispute pertaining to these present appeals relates to Asstt.Year 2007-08 only.
2. Sole grievance of each assessee is that the ld.CIT(A) has erred in confirming addition of Rs.3,18,750/- in the hands of each assessee. The facts and circumstances on all vital points are common. For the facility of reference, the ld.representatives have referred facts from the appeal of Shri Deepak Manilal Patel, therefore, we also take the facts from this case.
3. Brief facts of the case are that search under section 132 of the Income Tax Act, 1961 was carried out on 23.5.2008 in the Avirat - Adi group. Survey under section 133A was carried out at the premises of the assessees. During the course of operation various documents regarding investments in lands were seized. On verification of the same, it was found that these assessees along with other members of group have purchased land, and therefore, notice under section 153A of the Act was issued upon the assessees on 13.11.2009 requesting them to file returns. In response to the notice, assessees have filed their return on 31.12.2010. Short controversy in these appeals is to the effect that all these appellants have purchased land in Village Kerala, Tal-Bavla. According to the AO, statement of Shri Bhudaji Motiji Thakor and Shri Bhagaji Motiji Thakor, alleged vendors of the land at village Kerala were recorded under section 131 of the Income Tax Act. They have ITA No.2411/Ahd/2011 & 3 Others 3 disclosed that 21 bighas of land situated at village Kerala was sold at the rate of Rs.1,50,000/- per bigha, whereas in the sale deed this rate was not disclosed. Accordingly, the ld.AO formed an opinion that assessees have purchased the land by making cash payments over and above amounts stated in the sale deed. The ld.AO has issued a show cause notice dated 8.12.2010 which has been reproduced at page no.8 of the assessment order. This reads as under:
"Vide point No. 3 of this office letter dated 24/11/2010, you were informed that during the course of search operation certain documents were found and seized which shows that you alongwith four others have purchased 113.07 vighas of land of various survey numbers situated at Village- Bhayala and Kerala, Taluka- Bavla, Dist- Ahmedabad. Further during the course of assessment proceedings, for the A.Y.- 2007-08, in your group cases i.e in the case of M/s Advance WareHouse Projects, wherein you are a partner, it is seen that you along with other four members had purchased total 133.2824 vighas of land at village- Kerala and Bhayla of Taluka- Bavla during the period 1/4/2006 to 31/3/2007.i.e during the period relevant to A. Y. -2007-08. The details of such land purchased was intimated to you vide this office letter dated 24/11/2010. Purifier, you were intimated that during the post search investigation, statements of Shri Bhagaji M. Thakor and Shri Budhaji M. Thakor of l village-Kerala, Taluka - Bavla were recorded u/s. 131 of the I. T. Act on I 18/06/2008. These two persons has sold 21 Vigha of land situated at Kerala, Taluka- Bavla (Survey/Block No. 195 Paiki, 196 and 199 Paiki). In their statements they had stated on oath that they have sold the land @ 1,50,000/- per Vigha. Copy of the statements of above mentioned two farmers are enclosed herewith for your reference. From this fact it is clear that you had purchased the above mentioned land @ Rs. 1,50,000/- per Vigha whereas the purchase price shown in the respective purchase deed is less than the actual purchase price. To be very specific you had shown the cost of land at Rs. 58,06,500/- in the return of income filed for your partnership firm M/s Advance WareHouse Projects for purchase of 133.2824 bighas. As such, you were required to submit your explanation, by 06/12/2010, as to why the under statement of cost of purchase of should not be added to your total income as your unexplained investment in land. However, no reply has been received ITA No.2411/Ahd/2011 & 3 Others 4 so far. You are once again request to furnish your explanation as to why the below mentioned under statement of cost of purchase of land should not be added to your total u/s 69 of the I.TAct, 1961 on or before 17/12/2010, failing which the proportionate amount of Rs. 1 ,41,86,227/- will be added to your total income u/s. 69 of the I. T. Act, 1961.
I Land purchased during F. Y.2006-07 at 3,17,018 Sq. Mt.
Bhayla and Kerala village (317018/2378.5) i.e
133.2848 vighas
II Purchase price as per the farmers from Rs. 1,50,000/per
whom The said land was purchased vigha
III Total purchase cost/investment in land Rs. 1,99,92,727/-
IV Cost price shown in the books Rs. 58,06,500/-
V Unaccounted investment in land Rs. 1,41,86,227/-
4. Assesses have given reply to the show cause notice which is identical in all cases and reply given in the case of Deepak M. Patel has been reproduced in page no.10 of the assessment order. It reads as under:
"4.1.4 The assessee vide reply dated 19/12/2010 furnished his submission in respect of points raised as per para 2(i) and para 2(ii) of this office final show cause letter dated 08/12/2010. The assessee also filed a supplementary submission showing therein comparatitive sales instances of sale of land at village- bhayla, Kerala. The gist of the assessee's submission is reproduced as under:
1. (Sr.l(i)). In Para l(i), your honour has given the show case as to why the proportionate amount of Rs. 1,41,86,227/- under statement of cost of purchase of land should not be added to the total income u/s. 69 of the I.T. Act. In this regard, the assessee has to submit his rebuttal as under :-
a) That there was no search in the case of the assessee as well as no survey proceedings in the individual case of the assessee. The proceedings in assessee's case has been initiated u/s. 153C of the Act which has already been challenged by the assessee as there was no incriminating material and/or seized material has been brought on ITA No.2411/Ahd/2011 & 3 Others 5 record by your honour for the initiation of proceedings u/s. 153C of the Act.
b) That the survey proceedings u/s. 133A has been carried out at the business premises situated at 301/1, Parshwa Tower, Opp: Rajpath Club, S.G. Highway, Ahmedabad and during the course of survey proceedings, no incriminating material is been found and impounded by the survey officer in respect of purchase of land of is Survey Numbers situated at Bhayala and Kerala, Taluka Bavla, Dist.
Ahmedabad, has been purchased by me in the capacity of partner of M/s. Advance Warehouse Project for and on behalf of the firm as per the terms and conditions of the entered in to between partners and the firm M/s. Advance Warehouse Project and even the funds for the purchase of land has also been provided by the partnership firm M/s. Advance Warehouse Project. The land has also been treated as assets in the books of accounts of the partnership firm M/s. Advance Warehouse Project and the same has been duly reflected in the Balance Sheet of the firm.
Further, it is also to be taken note of that during the course of survey proceedings at the business premises situated at 301/1, Parshwa Tower, Opp: Rajpath Club, S.G. Highway, Ahmedabad, in the statement recorded of Shri Pranay K. Patel u/s. 131 of the Act, the Survey Officer has also not put any question in respect of the purchase of the aforesaid land of various survey numbers situated at Bhayala and Kerala, Taluka Bavla. Dist. Ahmedabad in respect of the alleged cash transactions observed in your show-cause letter dated 8-12-2010. In the statement recorded u/s. 131 of the Act of Shri Pranay K. Patel at the time of survey proceedings u/s. 133A of the Act, the Survey Officer has also not made any allegation as regards to any unaccounted cash payment in respect of purchase of the aforesaid different survey numbers land at Bhayala and Kerala, Taluka Bavla, Dist. Ahmedabad in the questions / answers recorded in the statement.
c) In your show cause letter dated 8-12-2010, your honour has relied upon the statement of Shri Bhagaji M. Thakor and Shri Budhaji M. Thakor of Village Kerala, Taluka Bavala which were receded u/s. 131 of the Act on 18/6/2008 during the post search investigation and the copy of which has also been provided to the assessee alongwith show cause letter dated 8-12-2010. The assessee has to submit that the ITA No.2411/Ahd/2011 & 3 Others 6 statements of aforesaid two farmers recorded on 18-6-2008 were not confronted to the assessee by the Investigation Department Officers.
d) Analysis of statement of Shri Bhaaaii M. Thakor and Shri Budhaii M. Thakor, departmental witnesses recorded u/s. 131 of the Act on 18- 06-2008.
i) That from verification of the statements, it reveals the fact that they have not stated/ mentioned the name of the assessee Shri Jayesh K. Patel and other Six co-owners namely Shri (i) Prakash Chandulal Patel, (ii) Deepakbhai M. Patel, (iii) Pranay K. Patel, (iv) Anil Sakarbhai Patel, (v) Kanubhai Maganlal Patel and (vi) Rajesh Kantilal Patel.
ii) That the farmer Shri Bhagaji M. Thakor and Shri Budhaji M. Thakor, departmental witness in their statements referred the names of two brokers. The assessee has to lot as your honour has not provided the statements of two brokers whose names been mentioned by Shri Bhagaji M. Thakor and Shri Budhaji M. Thakor in their statements, one can say that the officer of the investigation department has not carried out a proper enquiry and investigation in the matter by examining the brokers whose names have been stated by the farmer Shri Bhagaji M. Thakor and Shri Budhaji M. Thakor in their statements. Under the circumstances, your honour is requested to examine the two brokers whose names have been mentioned by the farmers in their statements.
iii) That after examination by your honour of the two brokers whose names have been mentioned by the farmers Shri Bhagaji M. Thakor and Shri Budhaji M. Thakor in their statements, your honour is requested to provide the statement of both brokers and also the opportunity of cross examination of both brokers."
iv) From the verification of the statements, it reveals the fact that there are no witness at the time of recording of statement of the farmers Shri Bhagaji M. Thakor and Shri Budhaji M. Thakor, departmental witnesses and therefore, the said statements do not have any validity as per the provisions of the Income Tax Act.
(v) The assessee has to request your honour to grant the opportunity of cross examination of Shri Bhagaji M. Thakor and Shri Budhaji M. Thakor, the departmental witnesses and it is contended that without ITA No.2411/Ahd/2011 & 3 Others 7 granting the opportunity of cross examination of Shri Bhagaji M. Thakor and Shri Budhaji M. Thakor, their statement cannot be used against the assessee as per the various judicial pronouncements.
vi) It is submitted that the allegation as regards consideration stated in the conveyance deed has been understated has to be established by your honour while bringing on record cogent material/evidences as well as by independent clinching evidences that the assessee has in fact paid actual amount over and above the sales consideration stated in the conveyance deed. As per the provisions of law the burden is on the department. The burden of proving that certain sales were effected while stating understatement of sales consideration in conveyance deed is on the department. It is not enough if the explanation offered by the assessee was not acceptable. In other words unless there is evidence/proof that more than what was stated in the conveyance deed was paid, no higher price can be taken to be the basis for computation of income. The onus is on the revenue, the inferences might be drawn in certain cases but to come to the conclusions that a particular higher amount, was in fact, paid must be based on such material from which such an irresistible conclusion follows. It is to be taken note of that the provisions of section 52 which has been now deleted from the I.T. Act 1961 the object of the section 52 was not to levy tax on perfectly bonafide transaction where full consideration on the transfer has been correctly disclosed in the conveyance deed. In support of the aforesaid submission, the assessee relies on the decision of the Hon'ble Supreme Court and various High Courts as under :
vii) Your honour has observed that during the period 1/4/06 to 31/3/07, total 133.2824 Vighas of land at village Kerala & Bhayla purchased and your honour has worked out invest in the land @ 1 50000 per vigha on the basis of statement of aforesaid two farmers recorded u/s.131 of the Act. Your honour has also observed that the aforesaid two farmers have sold 21 vighas of land at Kerala (Survey No./ Block No. 195 Paiki, 196 & 199 paiki). For other survey no./block no. of the land at Kerala & Bhayla, your honour has estimated value of investment by taking rate of Rs.150000/- per vigha on the basis of statement of aforesaid two farmers which tantamount to proposed addition on an estimation basis and without bringing on record any cogent material / evidences which is against the principle of law and provision of I.T.Act. The assessee has to submit that in respect of area of land of 112.28 Vighas of land purchased by assessee in the capacity ITA No.2411/Ahd/2011 & 3 Others 8 of partner of M/s.Advance Warehouse Project in the co-ownership along with other partners of the firm from other venders other than aforesaid two farmers, no adverse inference can be drawn on the basis of aforesaid two farmers' statements as Investigation department and your honour has not recorded the statement of other vendors / farmers and your honour and Investigation department has also not brought on record any comparative sales instances from the land revenue records and/or from government records in support of the allegation made by your honour."
5. The ld.AO was not satisfied with the explanation of the assessee. He accordingly made addition of Rs.17,73,278/- in the hands of each assessees. Conclusion drawn by the AO in para 4.1.18 is worth to note as under:
"4.1.8. Conclusion From the above narrated facts, considering the factual aspect as well as the legal aspect; the following two issues are very clear.
(1) The lands were purchased by the assessee and alongwith six others.
(2) The assessee had paid in cash his share of cost of purchase over and above the document cost as reflected in the books of account of the firm.
The total area of land purchased by the assessee alongwith six others is 317018 Sq. Mt. i.e. 133.2848 bighas, the total price of such purchases works out to Rs. 1,99,92,720/- [133.2848 X 150000]. The assessee has shown the purchase price of 133.2848 bighas of land at Rs. 58,06,500/- . Therefore, the unexplained investment made in land works out to Rs. 1,41,86,227/- [19992720 - 5806500] towards the irchase of land assessee alongwith six others. As per the purchase deed the assessee is having share in the land @ 12.50% i.e. first 1 to 4 of the purchasers mentioned in the deed having 50% shares. In other words the first four purchasers are (1) Deepak M. Patel, (2) Prakash C. Patel, (3) Jayesh K. Patel and (4) Pranay K. Patel and thus their share is in land is 12.50% each. Therefore, the assassee's 12.50% share of unexplained investment in land works out to Rs. 17,73,278/- which is added to the income of the assessee u/s. 69B of the I. T. Act, 1961. The penalty proceedings u/s. 271(1)( c) of the I.T. Act is initiated for concealment of income.
ITA No.2411/Ahd/2011 & 3 Others 9(Unexplained Investment in land u/s. 69B of Rs. 17,73,278/-)"
6. On appeal, the ld.CIT(A) has re-appreciated the facts. According to the ld.CIT(A), the total land purchased by these persons in these two villages was 133.2848 bighas. Out of this land, total land purchased from two persons viz. Shri Bhudaji Motiji Thakor and Shri Bhagaji Motiji Thakor was 21 bighas only. The AO has drawn inference of on-money payments qua total land on the basis of statement of these two persons. According to the ld.CIT(A), the AO was not possessing any evidence exhibiting the fact that the assessees have paid cash over and above the amounts stated in the sale deed. Accordingly, the ld.CIT(A) has deleted the additions made qua the land admeasuring 112.2848 bighas. Similarly, in other assessment years i.e. Asstt.Year 2008-09 and 2009-10, the AO has made additions qua the lands purchased from other farmers in these years. Thus, the additions have also been deleted. The Revenue has not challenged the order of the ld.CIT(A). In this way, ld.CIT(A) has scaled down the addition to Rs.3,18,750/- as against Rs.17,73,278/- made by the AO.
7. While impugning orders of the ld.CIT(A), the ld.counsel for the assessee contended that the statement of Shri Bhudaji Motiji Thakor and Shri Bhagaji Motiji Thakor was recorded by investigation team behind back of the assessee. The assessee has specifically requested for providing an opportunity to cross-examine. This request was not accepted and both these persons were not put to cross-examination. In order to substantiate their statements, the ld.AO has observed that cash components received by these were persons were used by them in depositing in their respective bank account with Punjab National Bank Branch, purchase of Hero Honda motor bike, LIC investments and renovation of wadi and construction of house. According to the ld.counsel for the assessee, the AO has alleged that Shri ITA No.2411/Ahd/2011 & 3 Others 10 Bhudaji Motiji Thakor has stated in his statement that he has deposited Rs.5 lakhs in his bank account with PNB. The account number is 0070000100117762. A perusal of this account would show that only a sum of Rs.50,000/- was deposited on 11.6.2007, whereas Motiji Thakor has deposited cash in his bank account after seven-half-months from the sale date. These two references in their statements were factually incorrect. Had the assessee been given an opportunity to cross-examine, these facts would have come out. The ld.counsel for the assessee contended that during the course of search/survey, the assessees were not put any such suggestion. Both farmers have given their affidavits retracting their statements given before the income- tax authorities. Thus, on the basis of their statement addition could not be made. He further relied upon the judgment of the Hon'ble Supreme Court in the case of Andaman Timber Industries Vs. Comm. Of Central Excise, (2015) 62 taxmann.com 3 (SC) wherein the Hon'ble Supreme Court has observed that if an opportunity to cross-examine was not given then those statements cannot be used as an evidence against the assessee. On the strength of this judgment, the ld.counsel for the assessee contended that statement of both persons, Shri Bhudaji Motiji Thakor and Shri Bhagaji Motiji Thakor ought to be excluded. He further relied upon the judgement of the Hon'ble Gujarat High Court in the case of CIT Vs. Ramanbhai B. Patel rendered in ITA No.207/2008 and other appeals for buttressing his contention. On the other hand, the ld.DR relied upon the orders of the Revenue authorities.
8. We have duly considered rival contentions and gone through the record carefully. The AO formed an opinion that assessees have paid money in cash to vendors for the purchase of land. According to him, the assessees have purchased the land by making payment in cash over and above the amounts stated in the sale deed. For buttressing this plea, he has been harping upon the ITA No.2411/Ahd/2011 & 3 Others 11 statement of two vendors viz. , Shri Bhudaji Motiji Thakor and Shri Bhagaji Motiji Thakor. It has been alleged that from these two farmers 21 bighas of land was purchased by the appellants. Apart from their statements, he made reference to other circumstantial evidence exhibiting expenditure incurred by the vendors. According to the AO, had they not received cash, they would not be in a position to meet this expenditure. He narrated six heads of expenditure viz. deposits in bank accounts, fixed deposits with PNB, purchase of Hero Honda bike, expenditure in marriage of daughter, investment in LIC and renovation of construction of house. The investment in LIC is of only Rs.1 lakhs. There is no quantification of expenditure in the marriage of daughter. It is a vague term. Similarly, the assessee has pointed out that deposits in the bank are not to the extent as mentioned by the AO. Similarly, in the accounts of Shri Bhudaji M. Thakor a sum of Rs.50,000/- only deposited. Shri Bhagaji M. Thakor has stated in his statement that he has deposited Rs.5.00 lakhs in the bank account with PNB whereas from the bank statement of Shri Bhagaji M. Thakore with PNB reproduced by the AO on page nos.27 and 8 of the assessment order, there is no deposits of Rs.5.00 lakhs. Apart from the above, circumstantial evidence for buttressing the main plea could be used if the main plea is an admissible evidence. Hon'ble Supreme Court in the case of Andaman Timber Industries (supra) has observed that if witness was not put to cross-examine then his statement cannot be used against affected party. In the present case also, the assesees have specifically requested the AO for providing an opportunity to cross- examination, which has been declined. The finding of the Hon'ble Supreme Court in this connection is worth to note. It reads as under:
"5. We have heard Mr. Kavin Gulati, learned senior counsel appearing for the assessee, and Mr. K. Radhakrishnan, learned senior counsel who appeared for the Revenue.ITA No.2411/Ahd/2011 & 3 Others 12
6. According to us, not allowing the assessee to cross-examine the witnesses by the Adjudicating Authority though the statements of those witnesses were made the basis of the impugned order is a serious flaw which makes the order nullity inasmuch as it amounted to violation of principles of natural justice because of which the assessee was adversely affected. It is to be borne in mind that the order of the Commissioner was based upon the statements given by the aforesaid two witnesses. Even when the assessee disputed the correctness of the statements and wanted to cross-examine, the Adjudicating Authority did not grant this opportunity to the assessee. It would be pertinent to note that in the impugned order passed by the Adjudicating Authority he has specifically mentioned that such an opportunity was sought by the assessee. However, no such opportunity was granted and the aforesaid plea is not even dealt with by the Adjudicating Authority. As far as the Tribunal is concerned, we find that rejection of this plea is totally untenable. The Tribunal has simply stated that cross- examination of the said dealers could not have brought out any material which would not be in possession of the appellant themselves to explain as to why their ex-factory prices remain static. It was not for the Tribunal to have guesswork as to for what purposes the appellant wanted to cross-examine those dealers and what extraction the appellant wanted from them.
7. As mentioned above, the appellant had contested the truthfulness of the statements of these two witnesses and wanted to discredit their testimony for which purpose it wanted to avail the opportunity of cross- examination. That apart, the Adjudicating Authority simply relied upon the price-list as maintained at the depot to determine the price for the purpose of levy of excise duty. Whether the goods were, in fact, sold to the said dealers/witnesses at the price which is mentioned in the price- list itself could be the subject matter of cross-examination. Therefore, it was not for the Adjudicating Authority to presuppose as to what could be the subject matter of the cross-examination and make the remarks as mentioned above. We may also point out that on an earlier occasion when the matter came before this Court in Civil Appeal No. 2216 of 2000, order dated 17.03.2005 was passed remitting the case back to the Tribunal with the directions to decide the appeal on merits giving its reasons for accepting or rejecting the submissions. .ITA No.2411/Ahd/2011 & 3 Others 13
8. In view the above, we are of the opinion that if the testimony of these two witnesses is discredited, there was no material with the Department on the basis of which it could justify its action, as the statement of the aforesaid two witnesses was the only basis of issuing the Show-Cause Notice."
9. The facts in hand are identical. Department has recorded statement of two persons behind the back of the assessees and he did not provide them an opportunity of cross-examination. Hence statement of these two persons are excluded, and if the statements are excluded then nothing would remain with the AO for bringing the point at home that the assessees have paid cash over and above the one as stated in the sale deed for making unexplained investment. Therefore, we allow all appeals and delete additions confirmed by the ld.CIT(A).
10. In the result, all appeals of the assessee are allowed. Order pronounced in the Court on 6th December, 2016 at Ahmedabad.
Sd/- Sd/- (PRADIPKUMAR KEDIA) (RAJPAL YADAV) ACCOUNTANT MEMBER JUDICIAL MEMBER ITA No.2411/Ahd/2011 & 3 Others 14 Ahmedabad; Dated 06/12/2016 आदे श क त!ल"प अ#े"षत/Copy of the Order forwarded to : 1. अपीलाथ / The Appellant 2. यथ / The Respondent. 3. संबं धत आयकर आयु!त / Concerned CIT 4. आयकर आयु!त(अपील) / The CIT(A) 5. $वभागीय 'त'न ध, आयकर अपील य अ धकरण / DR, ITAT, 6. गाड* फाईल / Guard file. आदे शानस/ ु ार BY ORDER, उप/सहायक पंजीकार ( Dy./Asstt.Registrar) आयकर अपील य अ धकरण, अहमदाबाद / ITAT, Ahmedabad 1. Date of dictation- 05-12-2016
2. Date on which the typed draft is placed before the Dictating Member 06.12.2016
3. Date on which the approved draft comes to the Sr.P.S./P.S. -
4. Date on which the fair order is placed before the Dictating Member for Pronouncement ....................
5. Date on which the file goes to the Bench Clerk .. : 6/12/2016
6. Date on which the file goes to the Head Clerk..................................
7. The date on which the file goes to the Assistant Registrar for signature on the order..........................
Date of Despatch of the Order..................