Income Tax Appellate Tribunal - Chandigarh
Surya Telecom Pvt. Ltd.,, Panchkula vs Department Of Income Tax
Author: G.S.Pannu
Bench: G.S.Pannu
IN THE INCOME TAX APPELLATE TRIBUNAL
CHANDIGARH BENCHES 'A' CHANDIGARH
BEFORE SHRI G.S.PANNU, ACCOUNTANT MEMBER
AND MS SUSHMA CHOWLA, JUDICIAL MEMBER
ITA No. 182/Chd/2010
Assessment Year: 2006-07
The DC IT, V M/s Surya Telecom Pvt. Ltd,
Panchkula Circle, Panchkula
Panchkula
PAN: AAHCS 3041 F
(Appellant) (Respondent)
Appellant By : Smt. Jai Shree Sharma
Respondent By: Shri Ajay J agga
ORDER
PER SUSHMA CHOWLA, JM
The appeal by the revenue is against the order of C IT(A), Panchkula dated 30.11.2009 relating to assessment year 2006-07 against the order passed under section 143(3) of the I.T. Act.
2. The Revenue has raised the following grounds of appeal:-
(i) Whether on the fact and in the circumstances of the case, the Ld. CIT(A) was justified in holding that the assessee is entitled to deduction u/s 80IC of the Income Tax Act, 1961 despite the fact that the Assessing Officer in the assessment order has clearly held that the assessee is not engaged in the process of manufacturing and is merely engaged in the supply of furnished goods of government agencies.
(ii) Whether on the fact and in the circumstances of the case, the Ld. CIT(A) is justified in deleting the addition of Rs. 9,32,258/- on account of depreciation disallowed despite the fact that the assessee has failed to prove with evidences the existence of machinery and such 2 machinery was used for manufacturing or production during the year under consideration.
3 The first issue raised in the present appeal is against the allowabilit y of claim of deduction u/s 80 IC of IT Act.
4 The brief facts of the case are that the assessee was engaged in the business of suppl ying communication equipment mainl y to Govt agencies. The assessee was operating from two units - one at Panchkula and second at Parwanoo. The assessee was claiming deduction u/s 80 IC of IT Act against profits of the Parwanoo unit since Assessment Year 2004-05. The assessee was allowed deduction u/s 80 IC of IT Act relating to Assessment Years 2004-05 and 2005-06. However, the said deduction was denied by Assessing Officer in Assessment Year 2006-07. The reasons for denial of the said deduction in the year under appeal were the observations of the Assessing Officer pursuant to the visit to the Parwanoo unit, during the conduct of assessment proceedings. The Assessing Officer has mentioned that the business of the assessee was of manufacturing of communication equipments which includes manufacturing of transceivers, power suppl y and other accessories. The Assessing Officer had observed the transceiver which the assessee manufactures was a device that transmits and receives analog or digital signals. It comprises of three main parts - a transmitter, a receiver and a oscillator generator. The components as per Assessing Officer were highl y integrated circuit boards made by highl y professional and skilled technicians. These circuit boards are then arranged in a fixed manner and are fixed in the outer body cover. Once the transceiver is manufactured then it is to be customized for use of the customers because each customer has a pre-set frequency allotted by the Government. The 3 Assessing Officer noted that all these steps are integral part of the manufacturing process of transceiver sets. The Assessing Officer further observed that the other component claimed to have been manufactured by the assessee is the power suppl y which regulates the suppl y of power to the equipments. The essential components are the electronic circuits of which the common circuit is the PCB. As per Assessing Officer to manufacture a power suppl y, a unit has to first write a PCB which is the work of highl y skilled and professional technicians and then on these PCBs transformers, resistors, capacitors, voltage regulators etc. have to be laid. Lastl y the entire circuit is put into the required covering or equipment and then the product is tested for use. The Assessing Officer on her visit to factory premises on 8.12.2008 observed that the factory unit was located in one large room on the first floor of the premises and not more than 7 to 8 workers were engaged at the unit. Further, the Assessing Officer noted that no machine was being used and onl y two drilling machines along with stabilizers and testers were present there and no manufacturing was being carried. Statement of two of the workers at factory unit were recorded in which they stated that no manufacturing was taking place. They admitted that material was being purchased in raw condition and then loading the PC Programmes and software to adjust various parameter was carried on. As regards power suppl y equipment, they stated that assessee purchases readymade PCBs and final setting of voltage and final testing of power suppl y is done. The Assessing Officer found the consumption of electricit y at Rs. 24,429/= for a total turnover of Rs. 5.92 crore too low to justify production in comparison with consumption of electricit y at Panchkula Unit. The Assessing Officer also took photographs of the activit y at the Unit and observed that transceiver, power suppl y and other accessories are purchased in a finished stage and 4 onl y programming and testing of transceiver is done as per requirements of customers. The raw material needed for manufacturing the highl y sophisticated products were not found available at the factory premises and onl y finished goods purchased from outside were found lying at the premises. The Assessing Officer thus held that assessee was not carrying on manufacturing activities at Parwanoo Unit but was doing basic activit y and carrying out trading activit y. The Assessing Officer compared the activities carried on by the assessee at its two units and on basis of various parameters at Page 22 of assessment order observed that expenses booked at Parwanoo unit are much less than those booked at Panchkula Unit. As per the Assessing Officer the assessee had reduced expenses at Parwanoo Unit to claim higher deduction u/s 80 IC of IT Act. The Assessing Officer also noted the transfer of raw material stock of Rs. 2.25 crore from Panchkula Unit to Parwanoo Unit, which in turn was utilized at Parwanoo Unit. The assessee was thus held to be not eligible for claim of deduction u/s 80 IC of IT Act. The contentions of the assessee that it was on the verge of closure of business and its turnover had decreased from Rs. 601.03 Lacs in Financial Year 2005-06 to Rs. 65.46 Lacs in Financial Year 2007-08 and consequent thereof shifting of machinery from Parwanoo unit to Panchkula unit and less labour force at the unit were not accepted. The assessee also contended that because of lack of orders, there was no manufacturing activit y on the date of visit of Assessing Officer on 8.12.2008. The Assessing Officer rejecting the contentions of the assessee held that assessee was not engaged in manufacturing activities. The Assessing Officer also held that the registration with various departments does not entitle the assessee to claim of deduction u/s 80 IC of IT Act. The Assessing Officer held that the assessee had tried to cover its claim as per Serial No. 13 of Part-C of 5 14 t h Schedule under Section 80 IC(2) of the Act. The Assessing Officer rejected the books of accounts u/s 145 of IT Act and also disallowed the claim of deduction u/s 80 IC of the Act. The Assessing Officer further observed that the assessee had shown value of plant & machinery in the Parwanoo unit at Rs. 29,98,881/- and had claimed depreciation at Rs. 9,32,258/-. In the absence of any machinery found at the factory premises on the dates of inspection, the claim of depreciation of Rs. 932,258/- was disallowed by the Assessing Officer.
5 The Ld. A.R. for the assessee made elaborate written submission s before the Ld. CIT(A), which are reproduced in Para 3 at page 6 to 17 of the appellate order. The Ld. C IT(A) in para 5.1 at Pg: 18 of the appellate order has summarized the contentions of Ld. A.R. for the assessee as under:
"The counsel for the appellant on the other hand has argued that the appellant's activity clearly falls in Sr No. 13 of Part- C of 14 t h Schedule as per section 80IC(2)(ii) of IT Act. The Ld. Counsel argued that the appellant is registered with Industries Department Parwanoo, Central Excise Department, Shimla. Sales Tax Department of HP and Directorate of Quality Insurance of DGS&D Department of Govt of India. The appellant is also registered with Ministry of Communication, Govt. of India. As regards, the transceiver sets, the Counsel argued that the appellant has carried out the third activity of frequency synthesization which the most relevant activity without which the equipment can not be sold and which amounts to manufacture. The Ld. Counsel argued that the Assessing Officer herself admitted that the third activity has been carried out by the appellant and this activity is an integral part of manufacturing process of the transceivers but has held that the appellant is not carrying out manufacturing activity. The counsel argued that as regards manufacturing of transmitters and manufacturing of receivers, these components were imported and cannot be manufactured by the appellant since they are highly technical and sophisticated items. Similarly, for the power supply equipment the appellant has carried out the activity of laying of transformers, registers etc., which is an integral part of manufacturing process as admitted by the Assessing Officer in the assessment order. The counsel further argued that the number of workers working during inspection has been mentioned as 7 to 8 by the Assessing Officer but the 6 inspection was carried out in Financial Year 2008-09. The Counsel argued that section 80 IC does not impose any restriction on the minimum number of workers and moreover, the Assessing Officer has based her opinion on the basis of wages register for Financial Year 2008-09 when the work was substantially reduced and the Assessing Officer has ignored the salary and wages register for the Financial Year 2005-06 which was produced before her. Regarding adequacy of the machinery, the Counsel argued that the machinery found during inspection is hi-tech and is sufficient for carrying out the job of the appellant and moreover, the machinery was substantially reduced in Financial Year 2008-09 since the appellant was having few orders. The. Counsel strongly argued that the word manufacture includes assembly also and placed reliance on the decisions in the case of CIT Bombay V Telco, 68 ITR 325 and Aspinwall V. CIT, 251 ITR 323 (S.C) and some other case laws. Finally the Ld. Counsel argued that for the Assessment Year 2004-05 and 2005-06 the claim of deduction has been allowed by the department u/s `143(3) of the IT Act and as per rule of consistency the deduction should be allowed this year also."
6. The C IT(A) thus held as under:-
"On careful consideration of the above facts and submissions, I find that the disallowance of the deduction u/s 80IC has been made by the Assessing Officer on the ground that complete manufacturing activity with regard to transceiver sets and power supply has not been carried out by the appellant. In the case of transceiver sets only one activity out of three activities has been carried out and in the case of power supply one activity out of two has been carried out. The Assessing Officer further mentioned that the number of workers employed by the appellant at the time of inspection was 7 to 8 and bare minimum machinery was lying in the factory premises at Parwanoo. The understanding of the Assessing Officer with regard to manufacturing of transceiver sets is that all the three activities should have been carried out for manufacture to take place and for power supply both the activities should have been carried out. The Ld. Counsel for the appellant has argued that the transmitters and the receiver are hi-tech parts which are imported and cannot be manufactured by the appellant and the activity of frequency synthesization and assembly itself amounts to manufacture or production. The Ld. Ld. Counsel for the assessee has placed reliance on the decision in the case of CIT Bombay V Telco, 68 ITR 325 and Aspinwall V CIT, 251 ITR 323 (S.C). Similar is the position with regard to the power supply in which the Ld. Counsel argued that the writing of the PCBs is again a very hi-tech job and the appellant cannot manufacture the same and the activity of laying the transformers, resistors is itself manufacturing activity. I find force in the arguments of the Ld. Counsel that the activities carried out by the appellant amount to 7 manufacture/production as required for the purposes of Section 80IC. It is not necessary that for manufacture to be complete transmitters, receivers and PCBs should also be manufactured by the appellant. The Assessing Officer has held that the appellant is not carrying out manufacturing activity on the wrong presumption that for the activity to be complete all the steps should be performed by the appellant. It is therefore, held that the activity of the appellant of frequency synthesization for transceiver sets and the activity of lying of transformers, resistors etc. for power supply equipment amounts to manufacturing activity and the appellant is entitled to deduction u/s 80 IC of the IT Act. The decision in the case of CIT Bombay V Telco, 68 ITR 325 and Aspinwall V CIT, 251 ITR 323 (S.C) relied upon by the Counsel are applicable."
7. The Ld. C IT(A) with regard to other points raised by Assessing Officer observed as under:-
"With regard to the other grounds taken by the Assessing Officer for disallowing the deduction being the number of workers being only 7 to 8 and bare minimum machinery lying at the premises of the appellant which show that manufacturing activity is not being carried out, I find force in the argument of the Ld. Counsel for the assessee that this factual situation was on the date of inspection which was carried out in Financial Year 2008-09 and it cannot be applied to the Financial Year 2005-06 in view of the fact that the business activity of the appellant was reduced considerably due to lack of orders. The records with regard to the number of workers during Financial Year 2005-06 and the machinery used during that period was produced before the Assessing Officer who has ignored the same. The Counsel further argued that there is no stipulated of minimum number of workers u/s 80IC of the IT Act. I further find force in the argument of the Counsel that though the principle of Resjudicata does not apply in income proceedings, yet rule of consistency does not apply. The Counsel has rightly placed reliance in the case of Radhasoami Satsung V CIT (1992) 193 ITR 321 (S.C) and H.A. Shah V CIT (1956) 30 ITR 618 (Bom). In view of the arguments of the Counsel the Assessing Officer is not justified in rejecting the claim of the appellant u/s 80IC of the IT Act. The addition made by the Assessing Officer is ordered to be deleted."
8. The CIT(A) in view of transfer of stock from Panchkula unit to Parwanoo unit gave the following direction:-
8
"However, I find that the Assessing Officer has mentioned in the assessment order that the appellant has transferred stock from its Panchkula unit to Parwanoo unit and has shown very little amount of expenses in the Parwanoo unit. The transfer of stock is of the value of Rs. 2,25,45,879/-. The Assessing Officer did not examine the stock transfer from the view of sub-section 9 of Section 80IA which is applicable to Section 80IC which relates to transfer of goods from one unit to other of an assessee other than at market rate because the Assessing Officer has totally disallowed the deduction u/s 80IC of the IT Act. Since, the deduction has now been allowed, the Assessing Officer is directed to examine the applicability of sub-section 9 of the Section 80IA in this case and take necessary action. This ground of appeal is allowed."
9. The Ld. C IT(A) also allowed the claim of depreciation on plant and machinery accepting the plea of assessee of transfer of assets to Panchkula unit and list of fixed assets and investment being accepted in earlier years. The assessee had claimed depreciation on plant & machinery at Parwanoo Unit at Rs. 3,10,275/- and not Rs. 9,32,258/- as disallowed by the Assessing Officer.
10 The Ld. D.R. for the revenue placing reliance on the order of the Assessing Officer pointed that the assessee had imported the parts and assembled them and such activit y is not manufacture. The low consumption of electricit y at factory premises proves no manufacturing activit y being carried on. The Ld. D.R. for the revenue relied on the case of V.M. Salgaocar Bros (P) Ltd V. C IT (1996) 217 ITR 849 (Kar) for the proposition that improving of marketabilit y was not held to be manufacture. The Ld. A.R. for the assessee placed reliance on the order of CIT(A) and the written submissions furnished before the Ld. C IT(A) and pointed out similar claim of deduction u/s 80IC of the Act was allowed in earlier years and the same is to be allowed during the years. Reliance was placed on:-
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1 ITO V. Arihant Tiles & Marbles (P) Ltd (2010) 186 Taxman 439 (S.C)
2. CIT-V, New Delhi V. Oracle Software India Ltd (2010) 187 Taxman 275 (S.C) 3 M/s Girnar Industries, 39/4, CSEZ V. C IT, ITA No. 100 of 2009 of Hon'ble High Court of Kerala at Ernakulam
11. We have heard the rival contentions and perused the record. The assessee was carrying on the business of suppl y of communication equipment to Govt. agencies. The claim of the assessee was that it was carrying on manufacturing activities. The assessee had two units and in respect of income from Panchkula unit, no deduction was claimed but in respect of income from Parwanoo unit, deduction u/s 80 IC of the Act was claimed. The Parwanoo unit was established in the earlier years. The unit was established in the States of Himachal Pradesh because of the incentives notified for the States of Uttrananchal and Himachal Pradesh. The copy of Notification No. 1(1) 2001-NER dated 7.1.2003 notifying the package of incentives for the states of Uttaranchal and Himachal Pradesh are placed at page No. 20 of the paper book (Annexure B). The claim of assessee is that the manufacturing activit y being carried out by it is covered as per Item No. 13 under Part C of 14 t h Schedule referred under Section 80IC(2) of IT Act which talks of "Information and Communication Technology Industry, Computer Hardware, Call Centres".
12. The assessee had furnished on record copy of Registration of the assessee with Industries Department for manufacturing / assembl y 10 activities as at pages 21 to 29 of the paper book (Annexure C). Further, the assessee has submitted copy of registration of the assessee with the Central Excise Department as 'manufacturer' at page 30 of the paper book (Annexure -D), Copy of registration of the assessee with Sales Tax Department for manufacturing / assembl y of product at pages 31-32 (Annexure E). In addition, the assessee also furnished on record the copy of the registration of the assessee with the Directorate of Qualit y Insurance DGS&D Department of Govt. of India as a manufacturer at pages 33 to 38 (Annexure F) and copy of Technical qualification Certificate of Staff (Skilled staff) at page 39 of the paper book (Annexure-G). The assessee had established the Unit in State of Himachal Pradesh and products manufactured being covered by 14 t h Schedule, the eligibilit y of the Unit for deduction u/s 80IC of the Act was claimed by the assessee.
13. The plea of the assessee that after the requisite registrations being allowed by the different Departments, the manufacturing activit y being carried on by the industrial understanding stands proved. We are of the view that in order to start is manufacturing activit y, the assessee needs registration / approval from different departments to establish its unit for carrying on the manufacturing activities. The Unit being registered with various authorities onl y establishes the intention of the assessee to start its manufacturing activit y. Whether the activit y carried on by the assessee is manufacturing, entitling it to the benefit of deduction u/s 80IC of the Act, is altogether a different aspect to be decided independent of Registration.
14. Now, coming to the manufacturing process undertaken by the assessee, we find that the assessee claims to have manufactured 11 transceiver sets, power suppl y equipments and other equipments during the year. To manufacture transceiver sets, three basic components / activities are required i.e a) transmitter b) a receiver and c) frequency s ynthesization. Admittedl y, the assessee is not carrying out the first two activities i.e. the manufacturing of transmitter and receiver. The assessee is purchasing the said components from different places including from its Panchkula unit, but the third activit y is being performed at the Parwanoo Unit. Under the third activity, the assessee sets the pre-set frequency allotted to a particular government agency by the Govt. of India in order to facilitate the use of the said equipment for securit y / Defence purposes by various government agencies, to whom the assessee is making the supplies. The Assessing Officer on a visit to the Parwanoo Unit admits that the fact of the carrying on of the third activit y at the premises of the assessee. The activit y carried on by the assessee is the integral part of activit y making the components saleble as a transceiver sets. In the absence of the same, the two components i.e. transmitter and receiver cannot be used as transceiver set. The assessee by the said activit y of frequency s ynthesization modulates changes in the basic components i.e. transmitters and receiver, for its ultimate use as a transceiver sets by the various Govt. Agencies, who are the end users of the same. To avail the benefit of claim of deduction u/s 80IC of the Act, it is not the requirement of law that each step of manufacturing is to be carried on the assessee itself. The claim of assessee in the present facts and circumstances is onl y in respect of the 3 r d step of frequenc y s ynthesization, and not the manufacture of the two items which are subjected to frequency s ynthesization. The activit y carried on by the assessee is the integral part of manufacturing transceiver sets and is 'manufacture' entitling the assessee to benefit of deduction u/s 80IC of 12 the Act. In respect of the second item manufacture by the assessee i.e. power suppl y equipment, two basic activities are required i.e. a) Writing a printed circuit board (PCB), and (b) Laying of transformers, resistors, capacitors, heat sink assembl y, voltage regulator, switches etc. on fixed principles of electronic engineering. The Assessing Officer admits in para 1 on page 9 of the assessment that the above said activities are integral part of the manufacturing process of power suppl y equipment and the two have to be carried out before the product is in a condition for use. The Assessing Officer further mentioned that writing of PCB has not been carried out by the assessee and onl y the laying of transformers, registers etc. has been carried out. The second activit y, undertaken by the assessee transforms the PCBs into Power Suppl y Equipments and is marketable to end user. The said activit y is considered by the Assessing Officer to be the integral part of manufacturing process and admittedl y the assessee is carrying on the second activit y. Once, it has been found that the assessee is carrying out the integral part of manufacturing process, the contention of the assessee that it is involved in manufacturing activities stands proved.
15. For claiming deduction u/s 80IC of the Act, the basic condition is that the gross total income should include profits and gains from any business undertaken by the undertaking or enterprise, which is engaged in the manufacture or production of any article or thing, not being any article or thing specified in the 13 t h Schedule. In the facts of the present case before us, where the assessee was carrying on one of the activities of manufacturing process, which itself is manufacturing and merel y because the assessee was not carrying on the other activities envisaged by the Assessing Officer, does not disentitle 13 the assessee from the claim of deduction u/s 80IC of the Act. The activities being carried out by the assessee for the manufacturing of transceiver set and power suppl y equipment makes the product marketable for its ultimate use by the government agencies to whom supplies are being made by the assessee, entitles the assessee to the claim of the deduction u/s 80IC of the Act. We confirm the order of the CIT(A) in this regard.
16. The second aspect of the issue for denial of deduction to the assessee was the presence of 7 to 8 workers during inspection of the Parwanoo Unit. The said inspection was carried out during the course of assessment proceedings during the financial year 2008-09 and the explanation of the assessee was that because of lack of orders, there was no manufacturing activities and hence lesser number of workers on the date of inspection. The assessee had produced for verification during the assessment proceedings, the salary and wages register relating to the financial year 2005-06 under which salary was paid to skilled persons and other wagers. The qualification certificates of the persons in the salary register were also produced before the Assessing Officer. The copies of the same have been produced before the CIT(A) and the CIT(A) has recorded a finding that the record with regard to the number of workers during financial year 2005-06 and machinery used during that period was produced before the Assessing Officer, who has ignored the same. Admittedl y, business activit y of the assessee had reduced considerabl y due to lack to order in financial year 2008-09 and the factual situation on the date of inspection cannot be applied for looking at the results shown in the year under appeal. The assessee has also pointed out that no deduction u/s 80IC of the Act has been claimed from Assessment Year 14 2007-08. Further, there is no stipulation of minimum numbers of workers u/s 80IC of the Act. The DR for the Revenue has failed to point out anything contrary to the findings of the CIT(A). The assessee had claimed deduction u/s 80IC of the Act in Assessment Year 2004-05 and 2005-06 and the same were allowed to the assessee vide orders passed u/s 143 (3) of the Income Tax Act. Though the principle of res judicata does not appl y to the Income Tax proceedings, yet the rule of consistency demands that under similar situations, the claim of the assessee be not disturbed. In the entiret y of the facts and circumstances referred by us in the paras herein above, we uphold the order of C IT(A) in allowing the claim of deduction u/s 80IC of the Act in respect of the profits of Parwanoo Unit. We also confirm the order of C IT(A) in directing the Assessing Officer to examining the applicabilit y of section 80 IA(9) of the Act in respect of transfer of stock of Rs. 2,25,45,879/- from the Panchkula unit to Parwanoo Unit. Accordingl y, the ground No.1 raised by the Revenue is dismissed.
17. The learned DR for the Revenue had placed reliance on the ratio laid down by the V.M. Salgaocar Bros (P) Ltd V. C IT (1996) (supra) for the proposition that improving marketabilit y of article does not constitute manufacture or production. The test of marketabilit y stands approved by the ratio laid down by the Hon'ble Apex Court in India Cine Agencies Vs. CIT [(2009) 308 ITR 98 (SC) ] and Computer Graphics Ltd Vs. CIT [308 ITR 98 (SC)]. The Hon'ble Supreme Court had reversed the ratio laid down by the Madras High Court in Computer Graphics Ltd Vs. ACIT [308 ITR 96 (Mad)], wherein it was held that the activit y of converting jumbo rolls into marketable small sizes could not be regarded as a manufacturing activity and the assessee was not entitled to the benefit of 15 section 80-IB of the Act as had been already decided in the assessee's own case in the earlier year. The reliance by the learned DR thus stands reversed.
18. The second issue raised by the Revenue is against the allowance of depreciation. The Assessing Officer while computing the income of the assessee had disallowed depreciation of Rs. 9,32,258/- as on the date of inspection, no machinery was found at the Parwanoo Unit except the drill machines and testers. The explanation of the assessee that it had shifted its machinery from Parwanoo Unit to Panchkula Unit in view of lack of orders and lesser production, was rejected in a summary manner. Before the C IT(A), the assessee had filed the copy of depreciation chart, copy of which is also furnished before us. The contention of the assessee was that the depreciation at Parwanoo Unit was claimed at Rs. 3,10,275/- onl y. Further, the investment made in the plant and machinery was accepted in the preceding year and depreciation was allowed to the assessee. The said machineries in later years were transferred to the Panchkula unit due to lack of manufacturing activities at Parwanoo Unit establishes the existence of the plant and machinery and consequentl y the claim of depreciation is to be allowed. We uphold the order of CIT(A) in allowing the claim of the assessee and deleting the addition of Rs. 9,32,258/-. The ground No.2 raised by the Revenue is thus dismissed.
19. In the result, appeal of the revenue is dismissed.
Order Pronounced in the Open Court on this 30 t h day of August,2010.
Sd/- Sd/-
(G.S.PANNU) (SUSHMA CHOWLA)
ACCOUNTANT MEMBER JUDICIAL MEMBER
Dated : 30 t h August, 2010
16
Rkk
Copy to:
1. The Appellant
2. The Respondent
3. The CIT
4. The CIT(A)
5. The DR