Income Tax Appellate Tribunal - Ahmedabad
Rina Dyeing & Printing Works, Surat vs Assessee on 18 June, 2012
1 ITA No 3529/Ahd/2008
ITA 1417/Ahd/2009
A.Yrs 2005-06 & 2006-07.
IN THE INCOME TAX APPELLATE TRIBUNAL "D "BENCH, AHMEDABAD
(BEFORE SHRI MUKUL KR.SHRAWAT JM & SHRI ANIL CHATURVEDI A.M.)
I.T.A. No.3529/AHD/2008.
(Assessment Year: 2005 -06 )
M/s. Rina Dyeing & Printing Vs. Income Tax Officer,
Works, Lal Darwaja, Ward 9(3),
Vasta Devdi Road, Aayakar Bhavan,
Surat. Majura Gate,
Surat.
(Appellant) (Respondent)
I.T.A. No.1417/AHD/2009.
(Assessment Year: 2006-07)
M/s. Rina Dyeing & Printing Vs. Income Tax Officer,
Works, Lal Darwaja, Ward 9(3),
Vasta Devdi Road, Aayakar Bhavan,
Surat. Majura Gate,
Surat.
(Appellant) (Respondent)
PAN: AADFR1092E
Appellant by : Mr. Sakar Sharma.
Respondent by : Mr. B.L. Yadav, Sr. D.R.
आदे श)/ORDER
(आदे Date of hearing : 18-6-2012 Date of Pronouncement : 31-7-2012 PER: SHRI ANIL CHATURVEDI, ACCOUNTANT MEMBER.
2 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
These two appeals are filed by the assessee against the order of Ld. CIT (A)-V, Surat dated 28-8-2008 and dated 31-3-2009 for the assessment years 2005-06 and 2006-07 respectively.
ITA No.3529/AHD/2008 (A.Y. 2005-06)2. The assessee is a partnership firm engaged in the business of Dyeing, Printing and finishing labour work. The assessee filed its return of income declaring total income at Rs.84,283/-.The case was taken up for scrutiny. Order u/s. 143(3) was passed on 24-12-2007 and the income was determined at Rs.43,56,500/- after making various additions/ disallowances. Aggrieved by the order, the assessee preferred appeal before the CIT (A). CIT (A) partially allowed the appeal of assessee and therefore now the assessee is in appeal before us.
3 The first ground of appeal is with respect to the sustaining disallowance of transport and octroi charges amounting to Rs.5,80,537/- by invoking provisions of Section 40(a) (ia) of the Act r.w.s. 194C of the Act.
4. During the course of assessment proceedings, the A.O. noticed that the assessee has paid transport charges to M/s. Alpesh Roadways & others without deducting TDS u/s.194C of the Act. The assessee's submission was that upto 1-10-2004 the assessee was not liable to deduct tax u/s. 194C since the payment was not in excess of Rs.20,000/- to a single person. After 1-10-2004 the law was amended to provide the deduction of TDS was to be made only when the credit value of contract 3 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
exceeds Rs.50,000/- in a Financial Year. The assessee further submitted that section 40(a)(ia) is only applicable in respect of TDS defaults if the amount is payable. If the amount is actually paid and tax is not deducted as required by section 194C r.w.s. 40(a)(ia) is not applicable. In the case of assessee since the whole of the amount was paid as on 31st March, 2005 and there was no amount payable on that date, the provisions of Sec. 40(a)(ia) were not applicable and therefore, there should be no disallowance. The A.O. did not agree with the contention of the assessee. He was of the view that since the assessee has paid the transport charges without deducting TDS, provisions of sec. 40(a)(ia) are applicable. He accordingly held that the assessee has committed default by violating the provisions of Sec.201 he accordingly disallowed Rs.5,80,537/- u/s. 40(a)(ia) of the Act. Assessee carried the matter before CIT (A). CIT (A) gave partial relief to the assessee. And therefore, the assessee is now in appeal before us.
5. Before us it was submitted that the assessee requires lignite which is transported from coal mines of G.M.D.C. situated at Rajpipla, Bharuch and other places to assessee's factory premises in Surat. For the transportation of coal from the mines assessee requires trucks for its transportation and for that assessee appointed an agent M/s. Ankesh & Co. who arranges fior the trucks directly from truck drivers or truck owners. Ankesh & Co., Surat charges fixed commission per truck from the assessee for providing such services on which assessee deducted TDS u/s. 194H.The freight charges including the reimbursement of expenses such as Octroi, Weighing charges, hamali and other charges were paid by the assessee directly to 4 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
truck driver /owner at the time of delivery of coal at the assessee's factory premises. It was submitted that the assessee has neither any agreement nor any contract either in written or verbal with any party or any truck drivers. The assessee further submitted that the freight payments were made to various truck drivers/owners and not to any transporter.
6. The Ld. A.R. submitted that it had made payments for the transportation of goods. The transporter had not issued bill in their names. They only send assessee the consignment notes. Further the payment is to be made to Truck Driver only when the goods are delivered to the assessee. As the transporter had not issued bill in the name of the concern, therefore, at the time of making the payments, the assessee is not aware as to who is the final recipient of the money. The assessee is supposed to make the payment first in cash thereafter, the truck is unloaded. The Ld. A.R. further submitted that upto 1-10-2004 the assessee was not liable to deduct tax u/s. 194C, since none of the payment exceeded Rs.20,000/- to a single person. With respect to the payment made after 1-10-2004 it was stated that provisions of section 40(a)(ia) can be invoked only in respect of TDS default if the amount is payable as on last day of the year. In the case of assessee since the amount is actually paid before year end and though tax is not deducted, provisions of 40(a)(ia) are not applicable For this proposition the assessee relied on the decision of Special Bench of the Tribunal in the case of Merilyn Shipping. Thus the L.D. A.R. urged that the disallowance made u/s. 40(a)(ia) be deleted.
5 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
7. On the other hands, Ld. D.R. submitted that the amended provision requires the tax to be deducted u/s. 194C in case when the contract payment exceeds Rs.50,000/- in a Financial Year. It was further stated that the requirement of tax is with respect to aggregate payment and not with respect to each payment and each truck. The Ld. D.R. submitted that since the assessee has not deducted TDS, the disallowance u/s. 40(a)(ia) was rightly made by the A.O. He accordingly relied on the order of the Assessing Officer and CIT (A).
8. We have heard the rival contentions, perused the material on record. On perusing the records we find that there is nothing on record to show that the assessee has paid the entire sum of transportation charges before 31st March,2005 and there is nothing payable as on 31st March, 2005.We also find that the allowability of deduction u/s. 40(a)(ia) has not been examined by the A.O. in the light of decision of Special Bench in the case of Merilyn Shipping (supra). We are therefore, of the view that the issue needs to be examined in light of the decision of Special Bench (supra). We therefore, feel that in the interest of justice the matter should be remitted back to the file of A.O. so that he can verify as to whether the entire amount has been paid before year end or any amount is outstanding at the end of the year and allow the deduction as per the provisions of the law and in the light of decision of Merilyn Shipping (supra). Thus this ground is allowed for statistical purpose.
9. The second ground of appeal is with respect to sustaining disallowance of wages amounting to Rs.1,38,073/-.
6 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
10. On verification of the wage register, the A.O. noticed that the assessee has made payment of wages aggregating to Rs.13,95,731/-.The assessee produced computerized wages register and on its scrutiny the A.O. noticed that there were certain entries in the wages register without revenue stamp and signature of the recipient. A.O. also noticed that the expenses on wages were on higher side as compared to last year and the corresponding turnover. He was thus of the view that the assessee has inflated expenditure on wages. He accordingly disallowed 20% of the wages amounting to Rs.2,79,146/-.Aggrieved by the decision, assessee carried the matter in appeal before CIT (A).
11. The submissions made by the assessee before CIT (A) were not found convincing by CIT (A) and he agreed with the finding of the A.O. However, he directed that the disallowance be restricted to 10% as against 20% made by the A.O. Aggrieved by the order of CIT (A), the assessee is now in appeal before us.
12. Before us, the Ld. A.R. submitted that the A.O. has made disallowance on the basis of presumption. He has compared the expenditure of wages with that of previous year and its corresponding turnover. The A.O. had not pointed out any specific defect in the wages register and had also not rejected the books of accounts. The Ld. A. R. placed on record the submission made before the CIT (A) wherein it was stated that in A.Y. 2004-05 wages expenditure were Rs.18,45,726/- and the turnover was Rs.1,89,59,946/- while in the assessment year under appeal, 7 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
the wages was Rs.13,95,731/- and corresponding turnover was Rs.2,18,85,012/-. It was thus submitted that contrary to the finding of A.O. the expenditure had decreased and the turnover has increased. It was further submitted that the assessee has deducted P.F. and ESIC from the wages of the employees and paid to the concerned Govt. department. The Ld. A.R. thus urged that the disallowance made by the A.O. be deleted.
13. The Ld. D.R. on the other hand relied on the order of the A.O.
14. We have heard rival contentions, perused the material on record. We observe that the A.O. had not pin pointed any defect in wage register. He has merely disallowed the payment for the reason that there were no signatures of the recipient on revenue stamp in the wage register. He has further presumed that the assessee has inflated expenses on wages without pin pointing to any specific instance. We are of the view that unless and until any specific instance of bogus/wrong claim has been pointed out, no disallowance on adhoc basis can be made. In the present case, the addition has been made only on the basis of estimate and without any concrete material on hand. In these circumstances we feel that the disallowance is uncalled for. We accordingly delete the addition made. Thus this ground of assessee is accepted.
15. The third ground of appeal is with respect to addition of Rs.65,877/- in respect of valuation of closing stock.
8 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
16. A.O. observed that the assessee had not shown any closing stock for work in progress in its P & L account. During the course of assessment proceedings the assessee was asked to furnish a working of closing stock of work-in-progress. The assessee furnished its work as under:-
Date Meters Cost/Mtr. Value %age as on Value in Rs 31-3-05 2-4-05 8084.25 5.25 42,442 50% 21,221 3-4-05 2761.25 5.25 14,497 30% 4,349 4-4-05 2229.75 5.25 11,706 20% 2,341 TOTAL 68,645 27,911 The working of work in progress submitted by assessee was not found reasonable and was therefore not accepted by A.O. He worked out the closing stock of work in progress in the following manner:-
"The assessee has processed grey cloth on an average of 503770 Mtrs. Per month / 26 days working basis. Thus, the average production of cloth per day works out to 19375 Mts. It is common knowledge that to complete a circle of process in textile processing unit, it takes at least five days. Therefore, a lot of grey cloth put to [process on first day comes out on the 6th day, duly processed. Therefore, it can be presumed that the assessee must have five days work-in-process as on 31-3-2005.This work out to 19375 x 5 days =96878 meters. The average cost of processing charges per meter works out at Rs.3.60. Considering the various stages of process, it would be reasonable to adopt 50% i.e. Rs.1.80 per meter for arriving at value of work-in-process. Therefore, the closing stock of work in process in this case is worked out at Rs.1,74,380/- (96878 meters x 1.80). Accordingly an amount of Rs.1,74,380/- is added to the total income of the assessee."
9 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
17. He accordingly added Rs.1,74,380/- to the total income of the assessee.
18. Aggrieved with the addition made by A.O. the assessee carried the matter in appeal before the CIT (A).
19. Before CIT (A), the assessee submitted that the A.O. has grossly erred in estimating the work in progress. It was submitted by the assessee that the process period was of 3 days as against process period of 5 days presumed by the A.O. The assessee submitted the working based on which the average cost of work in process worked out to Rs.1.12 per meter as against Rs.1.80 per meter considered by the A.O. CIT (A) held that since the A.O. had not given any working for arriving at the cost of Rs.3.60 per meter the working made by A.O. cannot be accepted but however, he directed that the disallowance be made on the basis of Rs.1.12 per meter as submitted by the assessee as against the basis of Rs.3.60 per meter. Accordingly, the disallowance made by the A.O. was restricted to Rs.1,08,503/-. Aggrieved by the order of CIT (A) the assessee is now in appeal before us.
20. Before us, the Ld. A.R. submitted that it does the job of Dyeing and Printing on job charges basis in which the grey cloth is supplied by the customers and therefore the cost of cloth should not be considered while calculating work in process. It was further submitted that while valuing closing stock it had already considered the cost of various ingredients like 10 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
colour, chemical etc. He thus urged that the addition made by the A.O. and partly sustained by CIT (A) be deleted.
21. On the other hand the Ld. D.R. relied on the order of A.O.
22. We have heard the rival submissions and perused the material on record. The factual position is that the assessee had not considered stock of work in process while valuing the closing stock. The assessee before us has submitted that it does the job of dyeing and printing on job work charges and while valuing the closing stock, the stock of WIP is already included. Based on the submissions made before CIT (A), CIT (A) has granted partial relief. Before us, the Ld. A.R. has given a general statement that closing stock is inclusive of WIP. He has not pin-pointed the working of valuation of closing stock which would show that valuation of work in process is also included in it. He has also not been in a position to demonstrate as to what was the break up of own material and that received for processing on job work basis. In view of these facts we find no reason to interfere with the order of CIT (A). We thus reject this ground of appeal of assessee.
23. Fourth ground is regarding disallowance of labour charges amounting to Rs.21,72,430/- by invoking the provisions of section 40(a)(ia) of the Act.
24. The A.O. observed that the assessee has paid Rs.21,72.430/- to its sister concern, Hatex Prints towards job charges and deducted tax at source. It was noticed by him that though the tax was deducted the same 11 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
was not deposited into the Govt. account within the prescribed time limit and he accordingly held that explanation given by the assessee is not tenable and provisions of section 200(1) of the I.T. Act are mandatory and since the tax was not paid within prescribed time, the whole expenditure was disallowed u/s. 40(a)(ia). Aggrieved by the decision of A.O. the assessee carried the matter in appeal before the CIT (A).
25. Before CIT (A), the assessee submitted that the assessee had paid job charges of Rs.21,72,430/- and had deducted tax at source of Rs.17,728/- at the year end i.e. on 31-3-2005 and the same was deposited in to the Govt. account on 24-5-2005.Accordingly it had complied with the requirements of the Act and therefore, no disallowance u/s. 40(a)(ia) was called for.
26. CIT (A) did not agree with the contentions of the assessee and upheld the order of the A.O. by holding as under :-
" I have gone through the contention of the appellant and do not find any merit in its case. It is not in dispute that the said Hatex had carried out labour job through out the year and that as claimed he had passed the year end entry just to avoid the rigor of provisions of section 40(a)(ia) which nothing but after thought and not in accordance with the provisions of section 200(1) or for that matter 194C not is acceptable in accounting parlance since accounts should be maintained on day to day basis and hence where the work was carried out on regular basis the amount should have been credited from time to time and that merely by passing entry on 31-3-2005 appellant does not absolve himself from the liability of deductibility and payment thereof in accordance with the aforesaid provisions. Further merely because the said Hatex Prints was allowed lower deduction of tax also does not absolve the appellant from deduction 12 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
of tax and payment thereof. In the instant case the A.O. has clearly pointed out that the appellant had not paid the tax deducted at source in accordance with the provisions of section 200(1) of the Act and therefore I do not find any merit in the appellant's case. However in view of the amended provisions of section 40(a)(ia) the A.O. is directed to recomputed the disallowance in respect of deduction made in the month of March and remittance is made within time allowed u/s. 139(1) of the Act."
27. Aggrieved by the order of CIT (A), assessee is now in appeal before us.
28. Before us, Ld. A.R. submitted that the assessee has credited the party's account on 31st March, 2005 and accordingly the TDS was deducted. The TDS deducted was paid on 24-5-2005 i.e. before the due date of filing of the return. The only reason for disallowing the payment was that the TDS was not paid to the Account of Govt. within the prescribed time limit specified in sec. 200(1) of the Act. It was submitted that since the assessee has deposited the TDS to the account of Govt before filing of return, no disallowance u/s. 40(a)(ia) is called for. He also relied on the decision of Calcutta High Court in the case of Virgin Creation in GA No.3200/2011 dated 23-11-2011 where the Hon'ble High Court has held that provisions of section 40(a)(ia) are retrospective in nature. He also relied on the decision of Ahmedabad Tribunal in the case of Alpha Projects Society Pvt. Ltd. The Ld. A.R. therefore, urged that since the amount of TDS has been paid before the due date of filing of the return, the addition made by the A.O. be deleted.
29. The Ld. D.R. on the other hand relied on the order of A.O. 13 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
30. We have heard the rival contentions, perused the material on record. The factual matrix of the case is that the assessee has credited the amount on 31-3-2005 and tax was also deducted on that date. The TDS of RS.17,728/- was deposited in the Govt. account on 24-5-2005 i.e. before the date of filing of the return. (return was filed on 29-10-2005.) The co- ordinate Bench in the case of Alpha Projects Society Pvt. Ltd., in ITA No.2869/Ahd/2011 dated 23-3-2012, following the decision of Hon'ble Calcutta High Court in the case of Virgin Creation (supra) has held that there can be no disallowance u/s. 40(a)(ia) if the TDS is paid to the account of Govt. before the date of filing of return. Respectfully following the decision of Hon'ble Calcutta High Court and the decision of Co-ordinate Bench in the case of Alpha Projects Society Pvt. Ltd., we are of the view that since the TDS has been paid to the account of Govt. before filing of return of income, no disallowance is called for. We accordingly direct the deletion of the addition made by the A.O. This ground of appeal is therefore allowed.
31. Fifth ground is with respect to addition of Rs.4,33,130/- on account of inflated purchases.
32. During the course of verification of purchase register the A.O. noticed that the total purchases has been shown at Rs. 95,21,043/- whereas in the return of income total purchases was Rs.99,54,173/-. Before A.O. the Accountant of assessee also confirmed the entries. The A.O. was of the view that assessee had inflated purchases to the tune of 14 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
Rs.4,33,130/-. A.O. also noticed that as compared to the earlier years there has been increase in purchases but no corresponding figure was noticed in the receipts of job charges. The assessee's contention that the difference was due to the totaling mistake was not accepted by the A.O. He treated the difference of Rs.4,33,130/- as inflated purchases and added to the total income. Against the addition made by A.O., the assessee carried the matter in appeal before the CIT (A).
33. Before CIT (A), the assessee submitted that upto Diwali accounts were maintained manually and thereafter it was computerized and the journal entries relating to manual accounts were passed in the computerized accounting system at the year end. The assessee submitted that the purchase register was maintained for filing its Sales Tax return. In the purchase register the assessee had recorded all the items as per the Sales Tax requirements and hence monthly and quarterly figures were summarised for filing the Sales Tax return, but the individual entries for all the purchases, payments of labour charges were made in the regular books of accounts and all the purchase invoices were checked by the auditor and the final account was drawn with the help cash book and general ledger. The purchase register was a supplementary register for Sales Tax purpose giving information about the Sales tax. CIT (A) agreed with the contentions of assessee. He also held that it was duty of the A.O. to verify the truth rather than attaching weight to earlier statement of Accountant. He therefore directed the A.O. to verify the reconciliation and delete the addition if found correct.
15 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
34 Before us the Ld. A.R. submitted that there was mistake in calculation. The purchase as per the return of income was correct and need no alteration.
35. On the other hand the Ld. D.R. relied on the order of A.O.
36. We have heard the rival contentions, perused the material on record. The factual position is that difference of Rs.4,33,130/- was observed in the purchase register and the A.O. made addition on the basis of the difference and the statement of Accountant of assessee. It is undisputed fact that the books of accounts of the assessee are audited by the auditors. CIT (A) had primarily agreed with the contention of the A.R. and therefore directed the A.O. verify the reconciliation and delete the addition if the assessee's contention was found correct. We find no infirmity in the directions of CIT (A) to the A.O. to verify and then delete if the assessee's contention is found correct. In view of these facts, we find that no interference is called for in the order of the CIT (A). This ground of the assessee is therefore dismissed.
37. In the result appeal of the assessee is partly allowed.
I.T.A. NO.1417/AHD/2009 - A.Y. 2006-07.
38. In this appeal assessee has taken the ground regarding sustaining disallowance of transport and octroi charges amounting to Rs.30,73,023/- by invoking the provisions of Section 40(a)(ia) of the Act.
16 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
39. A.O. on verification of P & L account noticed that assessee has debited "Noor and Octroi" of Rs.31,14,974/-.The A.O. noticed that it included expenses incurred towards hamali / octroi / kanta service tax aggregating to Rs.2,41,951/- and the rest of the amount (net) of Rs.30,73,023/- was towards freight expenses. The assessee submitted that entire amount of Rs.30,73,023/- was paid to M/s. Ankesh & Co., who on commission basis arranges for trucks for transportation. The assessee submitted that it had deducted TDS on commission payment to Ankesh & Co. As far as payment of freight charges, it was submitted that as there was no privity of contract between the assessee and truck drivers, no TDS was required to be deducted. It was further submitted that the assessee had paid entire freight charges before 31-3-2006 and nothing was payable on 31-3-2006 and therefore provisions of sec. 40(a)(ia) was not applicable. The A.O. did not accept the contention of assessee and held that since the assessee has not deducted TDS while making payment to transporters u/s. 194C the expenditure is not allowable and he accordingly involved and made addition of 40(a)(ia) of Rs.30,73,023/-. The assessee carried the matter before CIT (A). CIT (A) did not accept the contention of assessee and upheld the disallowance made by A.O. The assessee is therefore, now in appeal before us.
40. Before us, it was contended by assessee that the assessee had already paid freight charges and no sum was payable as on 31-3-2006 and therefore, provisions of sec. 40 (a)(ia) are not applicable and therefore no disallowance is called for. For this proposition he relied on the decision of 17 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
Merilyn Shipping (supra). On the other hand, the Ld. D.R. relied on the order of A.O.
41. We have heard the rival contentions and perused the material on record. Before us, the Ld. A.R. has submitted that the assessee has already paid freight charges before 31-3-2006 and there was no sum payable as on 31-3-2006.T his factual position has not been controverted by Revenue. We find that Special Bench of Vishakhapatanam in the case of Merilyn Shipping has held as under :-
" The provisions of section 40(a)(ia) of the Act are applicable only to the amounts of expenditure which are payable as on the date 31st March of every year and it cannot be invoked to disallow which had been actually paid during the previous year, without deductiuon of TDS".
42. In the present case, since there is no sum payable as on 31-3-2006, following the decision of Special Bench in the case of Merilyn Shipping (supra) we delete the addition made by A.O. Accordingly, this ground of assessee is allowed.
43. Thus the appeal of the assessee is allowed.
18 ITA No 3529/Ahd/2008 ITA 1417/Ahd/2009 A.Yrs 2005-06 & 2006-07.
44. In the result, appeal for A.Y. 2005-06 is partly allowed and appeal for A.Y. 2006-07 is allowed.
Order pronounced in Open Court on 31- 7 - 2012.
Sd/- Sd/-
(MUKUL KUMAR SHRAWAT) (ANIL CHATURVEDI)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Ahmedabad.
S.A.Patki.
Copy of the Order forwarded to:-
1. The Appellant.
2. The Respondent.
3. The CIT (Appeals)-V, Surat.
4. The CIT concerned.
5. The DR., ITAT, Ahmedabad.
6. Guard File.
By ORDER
Deputy/Asstt.Registrar
ITAT,Ahmedabad.
1.Date of dictation 12 - 7 -2012
2.Date on which the typed draft is placed before the Dictating 17-23 / 7 / 2012 Member................Other Member................
3.Date on which the approved draft comes to the Sr.P.S./P.S 30 - 7 -2012.
4.Date on which the fair order is placed before the Dictating Member for pronouncement 31 - 7 -2012
5.Date on which the fair order comes back to the Sr.P.S./P.S 31 - 7 -2012
6.Date on which the file goes to the Bench Clerk 31 - 7 -2012.
7.Date on which the file goes to the Head Clerk.............
8.The date on which the file goes to the Asstt. Registrar for signature on the order........................
9.Date of Despatch of the Order.................