Income Tax Appellate Tribunal - Delhi
Rainbow Promoters Pvt. Ltd., New Delhi vs Acit, New Delhi on 15 February, 2022
IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH 'F', NEW DELHI
Before Sh. Amit Shukla, Judicial Member
Dr. B. R. R. Kumar, Accountant Member
(Through Video Conferencing)
ITA No. 766/Del/2015 : Asstt. Year : 2006-07
ITA No. 1745/Del/2013 : Asstt. Year : 2007-08
M/s Rainbow Promoters (P) Ltd., Vs ACIT,
M-11, Middle Circle, Connaught Central Circle-23,
Circus, New Delhi-110001 New Delhi
(APPELLANT) (RESPONDENT)
PAN No. AAACR5368R
ITA No. 1678/Del/2013 : Asstt. Year : 2007-08
ACIT, Vs M/s Rainbow Promoters (P) Ltd.,
Central Circle-23, M-11, Middle Circle, Connaught
New Delhi Circus, New Delhi-110001
(APPELLANT) (RESPONDENT)
PAN No. AAACR5368R
Assessee by : Sh. Piyush Kaushik, FCA &
Sh. Ajay Bhagwani, FCA
Revenue by : Sh. T. Kipgen, CIT DR
Date of Hearing: 25.11.2021 Date of Pronouncement: 15.02.2022
ORDER
Per Dr. B. R. R. Kumar, Accountant Member:
The present appeals have been filed by the Revenue and the assessee against the orders of the ld. CIT(A)-XXXIII, New Delhi dated 18.12.2012 and 30.10.2014.
2 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015Rainbow Promoters (P) Ltd.
ITA No. 766/Del/2015 : A.Y. 2006-07 (Assessee)2. The brief facts of the case are that the assessee is a part of the BPTP group and engaged in the business of land aggregation and consolidation. A search u/s 132 of the Income Tax Act, 1961 was conducted on the BPTP group and some other companies on 07.12.2010. Assessment in the case of the assessee is completed u/s 153A.
3. Against the order of the ld. CIT(A) in Appeal no.165/13- 14/1316 dated 31.10.2016 appeals were filed by department as well as by assesse. The appeal of the revenue was dismissed due to low tax effect in ITA No.506/Del/2015 vide order dated 24.09.2019.
4. Ground nos. 1, 2, 2.1, 2.2, 2.3 and 4 are not pressed. The only effective ground remains relates to disallowance u/s 40A(3) of Rs.5,31,124/- u/s 40A(3).
5. The assessee has purchased land and paid part of amount in cash. The cash paid is recorded in books of accounts of assesseee. The assessee has entered into collaboration agreement with M/s Countrywide Promoters Pvt. Ltd. Pursuant to which assigned development rights in land are assigned by assessee in favour of M/s Countrywide Promoters Pvt. Ltd. The assessee has received reimbursement of cost of land along with some fees for collaboration charges in lieu of assignment of development rights in land assigned to M/s Countrywide Promoters Pvt. Ltd.
3 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015Rainbow Promoters (P) Ltd.
6. In respect of cash payments made of Rs.26,55,623/- for acquiring land, the Assessing Officer invoked provision of Section 40A(3) and disallowed 20% amounting to Rs.5,31,124/.
7. Aggrieved the assessee filed appeal before the ld. CIT(A), who confirmed the disallowance. Being aggrieved, the assesse is in appeal before us.
8. During the course of assessment proceedings, the AO noticed that the assessee company has acquired various land from farmers and on perusal of the details of payment made by the assessee company for acquiring the land from farmers, it has been noted that assessee has made part payment of total sale consideration in cash of Rs.26,55,623/-. As the above sum was paid in cash, the AO noted that it is in contravention of provisions of section 40A (3) of the act. The assessee explained that entire expenditure was incurred for the purchase of land which was reimbursed by Countrywide Promoters private limited. The above expenditure on account of cost of land and other expenses is not debited in the profit and loss account and no expenditure incurred on purchase in cash was debited or claimed by the assessee as deduction through computation. The assessee has submitted that it is the reimbursement of the cost for the purchase of land as per the collaboration agreement. The learned assessing officer rejected the contention of the assessee. He held that above payment has been made in contravention of the provisions of section 40A (3) and is not covered by the exceptions referred to in rule 6DD of the income tax rules 1962. He therefore disallowed 20% of the above cash payment and the same was confirmed by CIT(A).
4 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015Rainbow Promoters (P) Ltd.
9. The ld. AR submitted that the issue in question is fully covered in favour of the assessee by the order of the Co- ordinate Bench of ITAT in case of Westland Developers Pvt. Ltd. in ITA No.1752/Del/2013 vide order dated 22.08.2014 for the AY 2006-07. He further submitted that this order of the Tribunal has been accepted by the Department and no appeal has been filed before the Hon'ble High Court. It was also submitted that on identical facts the order of the Westland Developers Pvt. Ltd. (supra) is followed in various cases of group companies wherein it has been held that if the expenditure has not been debited to the profit and loss account but is reimbursed by the another company, there is no claim made by the assessee as an expenditure as none of these expenditure has entered into the profit and loss account, therefore the provisions of section 40A (3) of the income tax act does not apply to the same. The assessee submitted compilation of such 38 orders passed by the coordinate benches on identical facts and circumstances in various group companies of BPTP group where addition made on account of disallowance made u/s 40A(3) is deleted following the decision in case of Westland supra
10. We have considered submissions made by the parties and perused the material made available on record. In Westland Developers Pvt. Ltd. (supra) on identical facts it was held in para 10.10 at page 29 of Tribunal order as under:
"10.10. Accordingly on a consideration of the peculiar facts and circumstances of the case and the judgments relied upon considering the relevant provision of the Act namely Section 40A(3), we hold for the detailed reasons given hereinabove that 5 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015 Rainbow Promoters (P) Ltd.
Section 40A(3) of the Act has been wrongly invoked as admittedly no expenses relatable to the addition has been claimed and the assesse has successfully demonstrated that the payment were reimbursement made by CWPPL. Accordingly Ground No.4 is allowed."
11. The ld. CIT DR heavily relied on the order of AO and CIT(A) and submitted that these may be followed.
12. Heard the arguments of both the parties and perused the material available on record.
13. Undoubtedly, the issue is decided by the coordinate benches in 38 cases of the group concerns where the identical disallowance under section 40A (3) of the income tax act has been deleted. On perusal of the most of the decisions, it is found that the coordinate benches have followed the decision passed by the coordinate bench in ITA No. 1752/Del/2013 dated 22.08.2014 in case of M/s West Land Developers Private Limited vs. Assistant Commissioner Of Income Tax. The learned departmental representative could not show us any reason or fresh material that why should we deviate from the orders of the coordinate benches. Even otherwise, judicial discipline, rule of consistency and rule of precedence requires that unless those orders are upset, same should be followed. Therefore respectfully following the decision of the coordinate benches, we direct the learned assessing officer to delete the disallowance as under section 40A (3) of the act of Rs.5,31,124/-. Accordingly, ground No.3 and 3.1 of the appeal of the assesse is allowed.
6 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015Rainbow Promoters (P) Ltd.
14. In the result, appeal of the assesse is allowed.
ITA No. 1745/Del/2013 : A.Y. : 2007-08 (Assessee)15. The grounds are as under:
"2. That without prejudice, on the facts and circumstances of the case and in law, the CIT(A) erred in upholding the action of the Assessing Officer in relying upon the material seized in the case of search on M/s BPTP group of cases despite:-
i) that such material had no nexus/relevance with the case of the appellant and,
ii) that, the CIT(A) himself holding that such material did not belong to the appellant.
3. That on the facts and circumstances of the case and in law the CIT(A) erred in holding to quote, 'that seized documents definitely prove that interest is paid on PDC' despite i. that the seized record on the basis of which above finding was given, even according to his own finding by the CIT(A), did not belong to the appellant and, ii. that no enquiries were made from any of the alleged recipients of the interest and none was confronted with relevant document(s).
3.1 That the finding of the CIT(A) is based on mere surmises and conjectures without proof and corroboration by independent evidence.
7 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015Rainbow Promoters (P) Ltd.
3.2 That without prejudice the CIT(A) erred in upholding the addition of interest for the period for which PDC's were extended.
3.3 That without prejudice the CIT(A) erred in not quantifying the addition and instead giving ambiguous directions to compute the interest after six months from the date of sale."
ITA No. 1678/Del/2013 : A.Y. 2007-08 (Revenue)16. The grounds are as under:
"1. On the facts and in the circumstances of the case, CIT(A) has erred in deleting the addition of Rs.7832133/- out of total addition of Rs.12533522/- made by the Assessing Officer on account of interest on PDCs paid out of books of account.
2. On the facts and in the circumstances of the case, the CIT(A) has erred in deleting the addition of Rs.1,40,90,457/- made by the Assessing Officer in view of the provisions of Section 37(1) of the Income Tax Act, 1961 on account of additional payment in violation of Stamp Duty Act, 1899"
3. On the facts and in the circumstances of the case, the CIT(A) has erred in deleting the addition of Rs.4,58,000/- made by the Assessing Officer in view of the provision of Section 2(22)(e) of the Income Tax Act, 1961 on account of deemed dividend."
8 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015Rainbow Promoters (P) Ltd.
17. Ground of Appeal No. 2 & 3 of the assessee and Ground of No. 1 of Revenue which are on the same issue on account of interest paid in cash outside the books of account on Post Dated Cheques (PDCs).
18. During the course of search on BPTP group on 15.11.2007, certain documents were found and seized. As per these seized documents, the Assessing Officer held that BPTP and its group companies were purchasing land by making some part payment at the time of execution and registration of sale deeds and balance payment was made through PDCs and for the period in between from the date of sale deed to the date of encashment of PDCs, interest in cash at the rate of 1.25% p.m. was being paid in cash to vendors of land outside the books of accounts.
19. In this case, assessment was completed u/s 143(3). No search was conducted on the assessee which is evident from the fact that assessment in this case is completed u/s 143(3).In the search on BPTP Ltd., certain documents were seized which belong to BPTP Ltd. and some of its group companies. However, out of seized documents, no document belonged to the assessee were found and seized as provisions of Section 153C are not invoked in case of assessee.
20. The ld. AR, at the outset of hearing, stated that issue of addition on account of interest paid on PDCs in cash outside books of accounts is fully covered by the decision of Hon'ble ITAT in case of M/s Green Valley Tower Pvt. Ltd in ITA No.1750/Del/2013 and in case of Countrywide Promoters Pvt. Ltd. In ITA no.6343/Del/13 & 6304/Del/13 dated 04/05/21 for 9 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015 Rainbow Promoters (P) Ltd.
the AY 2007-08 under absolutely identical facts which are group companies of BPTP. The finding contained in para 9 of order in ITA no.1750/Del/2013 in case of M/s Green Valley Tower Pvt. Ltd. is reproduced as under:
"9.0 Coming to assesse e's appe al for AY 2007- 08, it is see n that in the assessment order, lots o f seized documents are mentio ned while making the addition in respect of inte rest paid on post dated cheques. Howeve r, nowhe re has the AO stated that these seized documents belo nged to the assesse e. The Ld. CIT (A ) has analyse d all these seized documents and has given a catego rical finding that none of the seized documents mentioned in assessment order belo ng to the assessee. I t is clear from this that the AO has used documents which belonged to other assessee for making the addition in the hands of assesse e. Further, the A O has neithe r called any of the vendo rs o f land nor reco rded any statement to arrive at the co rrect facts. Under such circumstances, question arises as to whe the r additions can be made in abse nce of any document/s or any adverse statement/s simply on the basis o f suspicion and assumption that the assessee might have also paid interest on po st dated cheques given towards purchase of land. This issue is settle d by the co-ordinate bench in case of Westland Developers Pvt. Ltd. in ITA no. 1757/ Del/ 2013 vide orde r dated 23.11.2015 where in it was held by the Tribunal that in abse nce of any cogent, de finite material which belonged to the assessee or any e vidence de monstrating the payment of intere st by the assessee on PDCs, reaso ns recorde d for initiation of pro ceedings u/s 147 were not in consonance with law having been based on mere suppositions, surmises and extrapolatio n of material seized. The be nch completely discarded the argument of AO and Ld. CIT (A) of common management and the assessee belonging to the same group and held that it cannot be equated with existence of incriminating se ized m aterial belonging to the assessee.10 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015
Rainbow Promoters (P) Ltd.
In this case also , there is no se ize d document fo und which be longs to the assessee and it is so confirm ed by the Ld. CIT (A) also in his order. No statement of any vendors of land is recorded by the AO. Statement o f Shri Cho ttu Ram is re ferre d to although the assessee has denie d to have purchased any land from Shri Chottu Ram. The statement of Shri Chottu Ram was no t eve n pro vide d to the assessee. In our view, the stateme nt of Shri Cho ttu Ram cannot be made as the basis for taking adverse inference without the assessee even having bee n confro nte d with it. Reliance is placed on the judgment of the Hon'ble Supreme Court in M/s A ndaman Timber Industries vs. Co mmissioner o f Central Excise wherein it was held that orde r becomes null if based merely on statement of witness without al lowing oppo rtunity to cross examine them. None of the vendo rs o f land and the alleged re cipients of interest paid by the assessee were examined by A O who would have confirmed of having receive d any such inte rest. It is the basic principle of law that unless there is a corroborative e vidence , no additio n can be made in an assessment. Reliance is placed on the judgment o f the Hon'ble Supreme Court in case of Dhakeshwari Cotto n Mills Ltd. vs. CIT 26 ITR 775(S C), Omar Salay Mohd. Salay vs. CIT37 ITR 151 (SC) and Lalchand Bhagat Ambica Ram vs. CIT 37 ITR 288 (S C) whe rein it is held by the Hon' ble Supreme Court that there must be something more than mere suspicion in support of an assessment and mere suspicion cannot take the place for the purpose o f passing an order of assessment.
9.0.1 The issue of the allege d payment of inte rest by the assessee is covered by the judgment o f the Hon'ble J urisdictional (Delhi) High Court in case of CIT vs. Lubtec India Ltd. re ported in 311 ITR 175 (Delhi) (2009) wherein it was held by the Hon'ble De lhi High Court that whe re there was no thing to show that e xpenditure in question was in fact incurred by assessee and assesesee had denie d having 11 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015 Rainbow Promoters (P) Ltd.
incurre d expenditure and had contended that it did not have that kind o f money, no addition on acco unt of such expenditure could be made to assessee' s income. The issue of allege d payment of interest by the assessee is also cove red by the decisio n o f Ho n'ble Delhi High Court in the case of CIT vs. Ved Prakash Choudhary reporte d in 169 taxman 130(De lhi) (2008) wherein the additio n was deleted as there was no co rro borative e vidence to show that there was in fact transfe r of money. Accordingly, considering the facts o f the case and judicial prono unce ments as discusse d above , the Ground nos.2 & 3 relating to additio n confirmed by the Ld. CIT(A) in respect o f interest paid o n post- date d cheques o utside the books is delete d."
21. Apart from decision of Co-ordinate Bench of ITAT, the issue of PDC interest as contested in assesse's appeal is also squarely covered in assessee's favour in case of another group company in ACIT vs. M/s Countrywide Promoters Pvt. Ltd. in cross appeals for AY 2007-08 in ITA No. 6343/Del/13 & 6304/Del/13 dated 04.05.2021 wherein by following the decision of Green Valley Tower (supra) similar addition on account of interest paid on PDCs in cash outside books of account was deleted.
22. The ld. CIT DR heavily relied on the order of AO and submitted that during the course of search lot of seized documents of several other assessee were found and seized which shows payment of interest on PDCs. Accordingly, as this company also belong to same group might have paid interest on PDCs. Accordingly, order of AO may be followed.
23. Heard the arguments of both the parties and perused the material available on record.
12 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015Rainbow Promoters (P) Ltd.
24. Undoubtedly, the issue is decided by the coordinate benches in cases of the group concerns where the identical addition made on account of PDCs Interest has been deleted on similar facts. The ld. DR was unable to bring on record any fresh evidence or material to show us any valid and justifiable reason to deviate from the earlier orders of the coordinate benches as discussed above. The judicial discipline, rule of consistency and rule of precedence requires that unless those orders on same facts in case of other group companies are upset or facts are different or any fresh material or any evidence is brought on record to deviate from earlier decisions, same should be followed. Therefore respectfully following the decision of the coordinate benches, we direct the learned assessing officer to delete the whole addition on account of PDC Interest of Rs.1,25,33,522/-.
25. Accordingly, Ground of Appeal No.2 and 3 in respect of appeal of the assesse is allowed and Ground of Appeal No.1 of the Revenue is dismissed.
26. Ground of Appeal No.2 of Revenue in respect of addition on account of disallowance of Additional Payment made by the Assessing Officer of Rs.1,40,90,457/- in view of the provisions of Section 37(1) of the Income Tax Act, 1961 on the basis of violation of Stamp Duty Act, 1899.
27. Additional payment is payment made to the seller of land or any of his relative or any other party post registration of sale deed to avoid litigation and to take peaceful possession etc. The Assessing Officer made disallowance of Additional payment 13 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015 Rainbow Promoters (P) Ltd.
made by the assessee of Rs.1,40,90,457/- that it is hit by Explanation to Section 37 of IT Act as there is violation of provision of Stamp Duty Act. The assessee challenged this before the ld. CIT(A) that the deduction in respect of Additional payment having not been claimed by the appellant, no disallowance could be made. The ld. CIT(A) did not accept this contention viz., that the assessee having not claimed the deduction, no disallowance could be made. The assessee also took plea that there is no violation of provisions of stamp duty Act as payment of Additional Payment is subsequent to registration of sale deed. Thus, provisions of Section 37(1) or its explanation are not applicable to instant case. The ld. CIT(A) gave his finding in para 6.3.7 and held that there is no violation of provisions of Stamp Duty Act and provisions of Explanation to Section 37(1) of Income Tax Act, 1961 are not applicable in instant case. He however, gave certain directions to quantify the disallowance to be made. As per these directions while giving appeal effect the whole disallowance of Rs.1,40,90,457/- was deleted.
28. The ld. AR submitted that the issue in question is fully covered in favour of the assessee by the order of the Co- ordinate Bench of ITAT in case of Westland Developers Pvt. Ltd in ITA No.1752/Del/2013 vide order dated 22.08.2014 for the AY 2006-07. He further submitted that this order of the Tribunal has been accepted by the Department and no appeal has been filed before the Hon'ble High Court. It was also submitted that on identical facts the order of the Westland Developers Pvt. Ltd. (supra) is followed in more than 30 cases of group companies wherein it has been held that there can be no disallowance in 14 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015 Rainbow Promoters (P) Ltd.
respect of additional payment if no deduction was claimed either by debiting to Profit and Loss account or through computation. The assessee submitted compilation of 30 orders passed by various Co-ordinate Benches on identical facts and circumstances in various group companies of BPTP group where addition made on account of disallowance of additional payment made by the assessing officer was deleted following the decision in case of Westland Developers Pvt. Ltd (supra).
29. The ld. AR submitted that similar issue is also decided by Hon'ble jurisdictional Delhi High Court in case of another group company viz. Vasundara Promoters Pvt. Ltd in ITA No.211/2018 vide order dated 14.05.2018. The Hon'ble High Court held as under which is reproduced as:
"The second question of law urge d is with respe ct to the payment of Rs.1,05,86,958/- made by the asse ssee to the farme r/owners of the agricultural land from whom the land was purchase d. It is contended by the Re venue that the ITAT ought no t to have go ne by the fact that the amount was route d from the books of account and included in the principle loss or that separate amount was used for that purpose. It was submitted that the amounts in fact co nstituted flagrant violatio n of law in as much as the pro visions of the Stamp Act and other connected laws we re sought to be evaded by the sale deed. This Court is of the opinion that the broad interpretation o f the Explanation to Se ction 37( 1) of the Act given by the Revenue is in the circumstance s of this case not we ll founded. The o ther submission is that the such amount has to be take n as falling within the mischie f o f the said pro vision, in our opinio n, is an inco rrect premise . It is not every alleged vio lation o f law, but such violation as results in a pe nal co nsequence . determined by that law, which is 15 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015 Rainbow Promoters (P) Ltd.
attracted by Section 37(1) . The other interpretation would confer jurisdictio n on matte rs beyo nd the Income Tax Act. The re venue authorities do not have such powers. Revenue Autho rity argued that this is to decide what constitutes infraction of other provisions o f law. No question o f law arises, the re fore , o n this issue "
30. The ld. CIT DR heavily relied on the order of AO and submitted that it may be followed.
31. Heard the arguments of both the parties and perused the material available on record.
32. Undoubtedly, the issue is decided by the Co-ordinate Benches in almost 30 cases of the group concerns. Further, the appeal of department stands dismissed by Hon'ble Delhi High Court in case of one of Group Company of assessee on identical facts in case of Vasundhra Promoters Pvt. Ltd. (supra) wherein the identical addition made on account of disallowance of additional payment has been dismissed. Considering most of the decisions of ITAT, it is found that Co-ordinate Benches have followed the decisions of ITAT in ITA No. 1752/del/2013 dated 22.08.2014 in the case of M/s West Land Developers Pvt. Ltd. vs. ACIT. The ld. CIT DR could not show us any reason or fresh material that why earlier decisions of the coordinate benches should not be followed. Considering judicial discipline, rule of consistency and rule of precedence which requires that unless those orders are upset or reversed at later stage or something fresh is brought on record which necessitate for different view to be taken however which is not the case, earlier decisions of coordinate benches should be followed. Therefore respectfully following the decision of the coordinate benches and Hon'ble 16 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015 Rainbow Promoters (P) Ltd.
Delhi High Court decision on this issue, Ground No. 2 of the Revenue's appeal is dismissed.
33. Ground No. 3 of Revenue appeal in respect of addition of Rs.4,58,000/- made by the AO on account of deemed dividend under section 2(22)(e) of the Income Tax Act, 1961 in respect of amounts received by the assessee from some of its group company where Mr. Kabul Chawla held substantial shareholding in assessee as well as payer companies.
34. The ld. AR submitted that the assessee is not a share holder of companies who paid loan / advance to the assessee which is treated as deemed dividend by the AO. As dividend is to be received by shareholders only and considering the fact that the assessee is not shareholder of payer group companies who paid loan / advance to the assessee, amount received cannot be treated as deemed dividend in the hands of the assessee. This issue is squarely covered by the decision of the Hon'ble High Court of Delhi in CIT vs. M/s Ankitech Pvt. Ltd. 11 Taxmann.com 100 (Delhi) vide order dated 11.5.2011 wherein also on similar facts, similar addition made on account of deemed dividend in the hands of non-shareholders was deleted.
35. The ld. CIT DR requested that order of AO on this issue should be followed.
36. We have gone through submission of ld. AR as well as ld. CIT DR on this issue. As the assessee is not share holder of payer group companies who paid loan / advance to the assessee and considering the legal position that dividend is to be received by shareholder only, the amount received by the 17 ITA Nos. 1678 & 1745/Del/2013 ITA No. 766/Del/2015 Rainbow Promoters (P) Ltd.
assesse is not to be treated as deemed dividend in the hands of assesse. Moreover, this view is fully supported by decision of the Hon'ble Delhi High Court in case of CIT vs. M/s Ankitech Pvt. Ltd.
37. Accordingly, this ground of appeal no. 3 in respect of addition on account of deemed dividend raised by the Revenue is dismissed.
38. In the result, the appeals of the Revenue are dismissed and the appeal of the assessee is allowed.
Order Pronounced in the Open Court on 15/02/2022.
Sd/- Sd/-
(Amit Shukla) (Dr. B. R. R. Kumar)
Judicial Member Accountant Member
Dated: 15/02/2022
*Subodh Kumar, Sr. PS*
Copy forwarded to:
1. Appellant
2. Respondent
3. CIT
4. CIT(Appeals)
5. DR: ITAT
ASSISTANT REGISTRAR