Income Tax Appellate Tribunal - Pune
Shree Someshwar Sk Ltd., Pune vs Dcit, Pune on 14 March, 2019
IN THE INCOME TAX APPELLATE TRIBUNAL
PUNE BENCH "B", PUNE
BEFORE SHRI R.S. SYAL, VICE PRESIDENT AND
SHRI PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER
Sl. ITA No./Co.No. Name of Appellant Name of Respondent Asst. Year
No.
Heard on 12-03-2019
1 308/PUN/2018 Majalgaon Sahakari ACIT, Circle-3, 2013-14
Sakhar Karkhana Ltd. Aurangabad
A/P. Sundarnagar,
Tal. Majalgaon, Dist
Beed - 431 131
PAN :AAABM0171G
2-4 985/PUN/2013 ACIT, Circle-2, Majalgaon Sahakari 2008-09
951/PUN/2014 Aurangabad Sakhar Karkhana Ltd. 2009-10
1252/PUN/2014 A/P. Sundarnagar, Tal. 2010-11
Majalgaon, Dist Beed -
431 131
PAN :AAABM0171G
5-6 1114/PUN/2012 ACIT, Circle-1, Shri Chhatrapati Shahu 2007-08
1115/PUN/2012 Kolhapur Sahakari Sakhar 2008-09
Karkhana Ltd.
Shrimant Jaysingrao
Ghatage Bhavan, Mal
Bunglow,
Tal. Kagal, Dist.
Kolhapur
PAN : AAAAS1032M
7-10 1419/PUN/2011 Loknete Balasaheb ACIT, Satara Circle, 1990-91
1420/PUN/2011 Desai Sahakari Satara 1995-96
1421/PUN/2011 Sakhar Karkhana 1998-99
1422/PUN/2011 Ltd., 2000-01
Daulatnagar, Marali,
Tal. Patan, Dist.
Satara
PAN :
AAAAB0362K
11-12 1682/PUN/2012 Loknete Balasaheb DCIT, Satara Circle, 2008-09
2607/PUN/2012 Desai Sahakari Satara 2009-10
Sakhar Karkhana
Ltd.,
Daulatnagar, Marali,
Tal. Patan, Dist.
Satara
PAN :
AAAAB0362K
2
SSK Group cases
13 2601/PUN/2012 Loknete Baburao Patil ITO, Ward-1(1), 2009-10
SSK Ltd., Solapur
P.O. Laxminagar,
Post. Angar, Dist.
Solapur
PAN : AAACL6834E
14 583/PUN/2011 PD. DR. Vithalrao ACIT (OSD), 1999-00
Vikhe Patil Sahakari Ahmednagar
Sakhar Karkhana
Ltd.,
At Post. Pravaranagar,
Tal. Rahata
Dist. Ahmednagar -
413712
PAN : AAAAP0848A
15 317/PUN/2016 ACIT, Latur Dr. Babasaheb 2011-12
Ambedkar Sahakari
Sakhar Karkhana Ltd.,
Arvindnagar,
A/P. Keshegaon,
Tal & Dist. Osmanabad
PAN : AAAAD0955E
16 446/PUN/2012 Gadhinglaj Taluka ITO, Ward-1(3), 2000-01
Sahakari Sakhar Ichalkaranji
Karkhana Ltd.,
Harli, Tal.
Gadhinglaj,
Dist. Kolhapur
PAN :
AAAAG0574A
17 1702/PUN/2012 Makai Sahakari ACIT, Circle-1, 2008-09
Sakhar Karkhana Solapur
Ltd.,
Bilarwadi (Jinti),
Tal. Karmala, Dist.
Solapur
PAN : AAAAS6100N
18 2123/PUN/2012 ACIT, Circle-2, Manganga Sah. Sakhar 2007-08
Sangli Karkhana Ltd.,
A/P. Sonarsiddhnagar,
Tal. Adpadi, Dist.
Sangli
PAN : AAAAM1794J
19-22 548/PUN/2011 Kadwa SSK Ltd., ACIT, Circle-1, 2002-03
640/PUN/2015 Rajaramnagar, Nashik 2010-11
641/PUN/2015 Materewadi, Dindori, DCIT, Circle-1, 2011-12
2556/PUN/2016 Nashik - 422 209 Nashik 2012-13
PAN : AAAAK1052F
3
SSK Group cases
23 -24 553/PUN/2011 JCIT (OSD), Circle-1, Kadwa SSK Ltd., 2002-03
1631/PUN/2011 Nashik Rajaramnagar, 1998-99
DCIT, Circle-1, Materewadi, Dindori,
Nashik Nashik - 422 209
PAN : AAAAK1052F
25-26 846/PUN/2012 DCIT, Circle-2, Rajarambapu Patil SSK 2007-08
847/PUN/2012 Sangli Ltd., 2008-09
Post. Sakharale,
Islampur, Tal. Walwa,
Dist. Sangli
PAN : AAAAR0790D
27 1837/PUN/2012 Rajarambapu Patil DCIT, Circle-2, 2009-10
SSK Ltd., Sangli
Post. Sakharale,
Islampur, Tal. Walwa,
Dist. Sangli
PAN :
AAAAR0790D
28 2608/PUN/2012 Kisanveer Satara SSK ITO, Ward-4, Satara 2009-10
Ltd.
Kisanveernagar,
Tal. Wai, Dist. Satara
PAN :AAAAK
0947M
29 1506/PUN/2014 ACIT, Ahmednagar Kopergaon Sahakari 2003-04
Circle, Ahmednagar Sakhar Karkhana Ltd.
Gautamnagar,
PO. Kolpewadi,
Tal. Kopergaon,
Dist. Ahmednagar
PAN : AAATT3070H
30-31 1645/PUN/2011 Kopergaon SSK Ltd. DCIT, Ahmednagar 1998-99
686/PUN/2014 Now known as Circle, Ahmednagar 2003-04
Karmaveer
Shankarrao Kale ACIT, Ahmednagar
Sahakari Sakhar Circle, Ahmednagar
Karkhana Ltd.,
PO. Kolpewadi,
Tal. Kopergaon,
Dist. Ahmednagar
PAN : AAATT3070H
32 1615/PUN/2012 Karmyogi DCIT, Circle-1(2), 2008-09
Shankarraoji Patil Pune
Sahakari Sakhar
Karkhana Ltd.,
A/P.Bhavaninagar,
Tal. Indapur,
Dist. Pune
PAN : AAAAI0225N
4
SSK Group cases
33-34 2139/PUN/2012 DCIT, Circle-1, Kumbhi Kasari 2006-07
2372/PUN/2012 Kolhapur Sahakari Sakhar 1989-90
Karkhana Ltd.,
Kuditre, Tal. Karveer,
Dist. Kolhapur
PAN : AAAAK0363M
35 1442/PUN/2012 ACIT, Circle-1, Sadashivrao Mandlik 2007-08
Kolhapur Kagal Taluka Sahakari
Sakhar Karkhana Ltd.,
A/P. Sadashiv Nagar,
Tal. Kagal,
Dist. Kolhapur
PAN : AAAAK1300Q
36-37 558/PUN/2012 DCIT, Pune Bhima Shankar 2007-08
559/PUN/2012 Sahakari Sakhar 2007-08
Karkhana Ltd.,
Dattatray Nagar,
Pargaon Tarphe,
Avasari Bk
Tal. Ambegaon,Dist.
Pune
PAN : AAAAB0949G
38 2268/PUN/2014 ACIT, Circle-14, Bhima Shankar 2008-09
Pune Sahakari Sakhar
Karkhana Ltd.,
A/P. Madhukarnagar
(Patas)
Tal. Daund, Dist. Pune
PAN : AAATB1781B
39 283/PUN/2012 Bhima Shankar ACIT, Circle-1(1), 2007-08
Sahakari Sakhar Pune
Karkhana Ltd.,
A/P. Dattatraynagar,
Tal. Ambegaon,
Dist. Pune
PAN :
AAAAB0949G
40 2276/PUN/2014 Bhima Sahakari DCIT-1(1), 2011-12
Sakhar Karkhana Pune
Ltd.,
A/P. Madhukarnagar
(Patas)
Tal. Daund, Dist.
Pune
PAN : AAATB1781B
5
SSK Group cases
41 1165/PUN/2016 Bhima Sahakari ITO, Ward-14(4), 2012-13
Sakhar Karkhana Pune
Ltd.,
A/P. Madhukarnagar
(Patas)
Tal. Daund,
Dist. Pune
PAN : AAATB1781B
42-44 1045/PUN/2013 Bhaurao Chavan ACIT, Circle-3, 2006-07
1046/PUN/2013 Sahakari Sakhar Nanded 2008-09
1047/PUN/2013 Karkhana Ltd., DCIT, Circle-3, 2009-10
Laxminagar, Nanded
Degaon-Yelegaon
Tal. Ardhpur,
Dist. Nanded
PAN :
AAAAB0959Q
45-47 1005/PUN/2013 DCIT, Circle-3, Dr. Babasaheb 2007-08
1006/PUN/2013 Nanded Ambedkar Co-op. 2008-09
1007/PUN/2013 Sugar Factory, 2009-10
Keshegaon, Dist.
Osmanabad
PAN : AAAAD0955E
48 1207/PUN/2011 ACIT, Circle-2, Shri Gajanan Sahakari 1999-00
Aurangabad Sakhar Karkhana Ltd.,
Sonaji Nagar, Rajuri,
Dist. Beed
PAN : 4003AX1809
49-50 1020/PUN/2013 DCIT, Circle-3, Jaishivshankar Sahakari 2007-08
1021/PUN/2013 Nanded Sakhar Karkhana Ltd., 2009-10
Shesh Nagar,
Manjari, Tal. Mukhed
Dist. Nanded
PAN : AABCJ0834F
51-52 538/PUN/2009 DCIT, Circle-2, Shri Chhatrapati 2006-07
374/PUN/2013 Kolhapur Rajaram Sahakari 2009-10
Sakhar Karkhana Ltd.,
S.No.69, E-Ward,
Kasaba Bawada,
Kolhapur
PAN : AAAAS4219A
53-54 65/PUN/2014 ACIT, Circle-2, Jai Bhavani Sahakari 2007-08
174/PUN/2012 Aurangabad Sakhar Karkhana Ltd., 1999-00
Shivaji nagar Gadhi,
Tal. Georai, Beed
PAN : AAAAJ0612L
6
SSK Group cases
55-56 2182/PUN/2012 Jawahar Shetkari DCIT, Ichalkaranji 2007-08
2183/PUN/2012 Sahakari Sakhar Circle, Ichalkaranji 2009-10
Karkhana Ltd.,
Hupari, Shri
Kallappanna
Awadenagar,Hupari-
Yalgud,
Tal. Hatkanangale,
Dist. Kolhapur -
416203
PAN : AAAAJ0571C
57-63 680/PUN/2011 Dr. Baburao Bapuji ACIT(OSD), 1999-00
1268/PUN/2011 Tanpure Sahakari Ahmednagar 1993-94
1269/PUN/2011 Sakhar Karkhana Ltd. DCIT, Ahmednagar 1994-95
850/PUN/2014 Shrishivajinagar, Circle, 2001-02
851/PUN/2014 Post. Rahuri Factory, Ahmednagar 2005-06
852/PUN/2014 Tal. Rahuri 2009-10
853/PUN/2014 Dist. Ahmednagar 2010-11
PAN : AAAAD1287F
64-65 994/PUN/2014 ACIT, Ahmednagar Dr. Baburao Bapuji 2001-02
995/PUN/2014 Circle, Tanpure Sahakari 2005-06
Ahmednagar Sakhar Karkhana Ltd.
Shrishivajinagar,
Post. Rahuri Factory,
Tal. Rahuri
Dist. Ahmednagar
PAN : AAAAD1287F
66 1272/PUN/2015 ACIT, Ahmednagar Shri Dnyaneshwar 2004-05
Circle,Ahmednagar Sahkari Sakhar
Karkhana Ltd.,
At Dnyaneshwar Nagar
Post Bhende,
Tal. Newasa
Dist. Ahmednagar -
414 605
PAN : AAAAS4092H
67-71 180/PUN/2011 Shri Dnyaneshwar DCIT, Ahmednagar 2001-02
181/PUN/2011 Sahkari Sakhar Circle, Ahmednagar 2000-01
182/PUN/2011 Karkhana Ltd., 1999-00
183/PUN/2011 At Dnyaneshwar ACIT (OSD) 1994-95
263/PUN/2012 Nagar Post Bhende, Ahmednagar Circle, 2007-08
Tal. Newasa Ahmednagar
Dist. Ahmednagar -
414 605 DCIT, Spl Range-2,
PAN : AAAAS4092H Aurangabad
7
SSK Group cases
72 265/PUN/2011 Ghodganga Sahakari ITO, Range-2, 1998-99
Sakhar Karkhana Pune
Ltd.,
Raosahebnagar,
Nhavare, Tal. Shirur,
Dist. Pune - 412211
PAN : AAAAG03561
73 763/PUN/2013 DCIT, Circle-1(2), Ghodganga Sahakari 1999-00
Pune Sakhar Karkhana Ltd.,
Raosahebnagar,
Nhavare, Tal. Shirur,
Dist. Pune - 412211
PAN : AAAAG03561
74 1168/PUN/2015 ACIT, Ahmednagar Kukadi Sahkari Sakhar 2011-12
Circle, Ahmednagar Karkhana Ltd.,
A/P. Pimpalgaon Pisa,
Tal. Shrigonda,
Dist. Ahmednagar-
413703
PAN : AAATK3702B
75-76 829/PUN/2015 Kukadi Sahkari ACIT, Ahmednagar 2011-12
2547/PUN/2012 Sakhar Karkhana Circle, Ahmednagar 2009-10
Ltd.,
A/P. Pimpalgaon Pisa,
Tal. Shrigonda,
Dist. Ahmednagar-
413703
PAN : AAATK3702B
77-79 262/PUN/2011 Purna SSK Ltd., ACIT, Special Range- 1998-99
129/PUN/2012 Basmatnagar, 2, 1999-00
128/PUN/2012 Dist. Hongoli-431512 Aurangabad 1994-95
PAN : AAAAP0899B DCIT, Special Range-
2,
Aurangabad
80-86 483/PUN/2014 ACIT, Circle-1, Purna Sahakari Sakhar 2006-07
1229/PUN/2013 Aurangabad Karkhana Ltd., 2007-08
1230/PUN/2013 Tq. Basmathnagar, 2008-09
1231/PUN/2013 Dist. Hingoli 2009-10
296/PUN/2012 PAN : AAAAP0899B 1999-00
297/PUN/2012 1994-95
573/PUN/2011 1998-99
87-90 488/PUN/2014 DCIT, Circle-3, Manjra Shetkari Sah. 2000-01
489/PUN/2014 Nanded Karkhana Ltd., 2002-03
490/PUN/2014 At Post. Vilas Nagar, 2006-07
1015/PUN/2013 Ta. Dist. Latur 2009-10
PAN : AAAAM1527D
8
SSK Group cases
91-92 1050/PUN/2013 Manjra Shetkari Sah. DCIT, Circle-3, 2008-09
1051/PUN/2013 Karkhana Ltd., Nanded 2009-10
At Post. Vilas Nagar,
Ta. Dist. Latur Jt. CIT, Spl. Range-3
PAN : Nanded
AAAAM1527D
93 1271/PUN/2012 The Malegaon DCIT, Circle-7, 2008-09
Sahakari Sakhar Pune
Karkhana Ltd.,
A/P. Shivanagar,
Tal. Baramati,
Dist. Pune
PAN : AAATT2982L
94 325/PUN/2016 ACIT, Circle-3, NSL Sugar Ltd. 2009-10
Aurangabad (Formerly Jay Mahesh
Sugar Industries Ltd.),
Pawarwadi,
Tq. Majalgaon,
Dist. Beed - 431 131
PAN : AACFJ7975R
95-96 1584/PUN/2014 Agasti Sahakari DCIT, Ahmednagar 2007-08
1585/PUN/2014 Sakhar Karkhana Circle, Ahmednagar 2008-09
Ltd.,
Post Akole,
Taluka Akole
Dist. Ahmednagar-
422601
PAN :AAAAA1262B
97-98 1666/PUN/2014 ACIT, Ahmednagar Agasti Sahakari Sakhar 2007-08
1667/PUN/2014 Circle, Ahmednagar Karkhana Ltd., 2008-09
A/P. Agastinagar
Taluka Akole
Dist. Ahmednagar-
422601
PAN :AAAAA1262B
Heard on 13-03-2019
99 2083/PUN/2012 Shri Pandurang ACIT, Circle-1, 2009-10
Sahakari Sakhar Solapur
Karkhana Ltd.,
A/P. Shreepur,
Tal. Malshiras,
Dist. Solapur
PAN : AAATS5264J
9
SSK Group cases
100 989/PUN/2013 DCIT, Circle-3, Shri Vithal Sahkari 2009-10
Nanded Sakhar Karkhana
Limited,
Omerga,
Dist. Osmanabad
PAN : AAAAS4776Q
101 2599/PUN/2012 Shree Shankar SSK ACIT, Circle-1, 2009-10
Ltd., Solapur
Sadashivnagar,
Tal. Malshiras
Dist. Solapur -
413111
PAN :AAAAS3735M
102 349/PUN/2011 Shirpur Shetkari JCIT, Spl. Range-1, 1997-98
Sahakari Sakhar Nashik
Karkhana Limited,
A/P. Shivajinagar,
Dahiwad,
Tal. Shirpur,
Dist. Dhule
PAN : AAAAS1058H
103 2598/PUN/2012 Sahakar Maharshi ACIT, Circle-1, 2009-10
Shankarrao Mohite Solapur
Patil SSK Ltd.,
Akluj,
Dist. Solapur -413118
PAN : AAAAS3736J
104-105 988/PUN/2014 The Sanjivani (Takil) DCIT, Ahmednagar 2007-08
989/PUN/2014 Sahakari Sakhar Ltd., Circle, Ahmednagar 2010-11
Sahajanandnagar,
Shingnapur, Tal.
Kopargaon, Dist.
Ahmednagar
PAN : AAAAT3291R
106 2605/PUN/2012 Vithalrao Shinde Patil ACIT, Circle-1, 2009-10
SSK. Ltd., Solapur
PO Gangamai Nagar,
Tal. Madha,
Dist. Solapur
PAN :AAAAM1644B
107 2457/PUN/2012 Shri Vithal Sahakari ACIT, Circle-1, 2009-10
Sakhar Karkhana Solapur
Ltd.,
A/P. Venunagar,
Gurusale,
Tal. Pandharpur,
Dist. Solapur
PAN : AAAAS3892H
10
SSK Group cases
108-111 575/PUN/2011 ACIT, Circle-3, Terna Shetkari 1999-00
96/PUN/2012 Nanded Sahakari Sakhar 2001-02
97/PUN/2012 Karkhana Ltd., 1995-96
98/PUN/2012 Terna Nagar, Dhoki, 1992-93
Dist. Osmanabad
112-113 2610/PUN/2016 Shri Vridheshwar ITO, Ward-4, 2012-13
2611/PUN/2016 Sahakari Sakhar Ahmednagar 2013-14
Karkhana Ltd.,
A.P. Adinathnagar,
Tal. Pathardi,
Dist. Ahmednagar-
414102
PAN : AABCV0782E
114 1117/PUN/2012 ACIT, Circle-1, Shri Dudhaganga 2008-09
Kolhapur Vedganga Sahakari
Sakhar Karkhana Ltd.,
A/P.Bidri,
Tal. Kagal,
Dist. Kolhapur
PAN : AAAAS3732N
115 90/PUN/2017 Dr. Babasaheb ACIT, Latur Circle, 2012-13
Ambedkar SSK Ltd., Latur
Arvindnagar,
Keshegaon,
Tal. & Dist.
Osmanabad-413506
PAN : AAAAD0955E
116 980/PUN/2013 ACIT, Circle-1, Vaidyanath Sant 2009-10
Aurangabad Eknath Sakhar Udyog,
At. Eknath Nagar,
Paithan Road,
Tq. Paithan,
Dist. Aurangabad
PAN : AAGFV6446H
117 735/PUN/2016 Vaidyanath Sant DCIT, Circle-1, 2012-13
Eknath Sakhar Aurangabad
Udyog,
C/o. Vaidyanath
Sahakari Sakhar
Karkhana
At Post. Pangri
Tal. Parli-431515
Dist. Beed
PAN : AAGFV6446H
11
SSK Group cases
118-119 1464/PUN/2009 ACIT, Circle-2, M/s. Vaidyanath 2006-07
984/PUN/2013 Aurangabad Sahakari Sakhar 2009-10
Karkhana Limited
At Pangri,
Tq. Parli (V),
Dist. Beed
PAN : AAAAV0304P
120 1223/PUN/2016 DCIT, Latur Circle, Vikas Sahakari Sakhar 2011-12
Latur Karkhana Limited
Vaishali Nagar,
Nivi, Tq. Latur,
Dist. Latur- 413531
PAN : AAAATV2893E
121 702/PUN/2012 Ajinkyatara Sahakari DCIT, Satara Circle, 2008-09
Sakhar Karkhana Satara
Limited
A/P. Shahunagar,
Shendra
Tal. & Dist. Satara
PAN : AAAAA0510E
122 1041/PUN/2015 Shri Sant Kurmadas ACIT, Circle-1, 2011-12
Sahakari Sakhar Solapur
Karkhana Limited,
Ganpatrao
Sathenagar, Padsali,
Tal. Madha,
Dist. Solapur-413208
PAN :AAAAS6020M
123 2145/PUN/2012 Shri Tatyasaheb Kore ACIT, Circle-1, 2009-10
Warana Sahakari Kolhapur
Sakhar Karkhana
Ltd.,
A/P. Warananagar,
Tal. Panhala,
Dist. Kolhapur-
416113
PAN :AAAAT3108M
124-126 2141/PUN/2012 DCIT, Circle-1, Shri Tatyasaheb Kore 2009-10
205/PUN/2012 Kolhapur Warana Sahakari 2007-08
599/PUN/2012 Sakhar Karkhana Ltd., 2008-09
ACIT, Circle-1, A/P. Warananagar,
Kolhapur Tal. Panhala,
Dist. Kolhapur-416113
PAN :AAAAT3108M
12
SSK Group cases
127-128 244/PUN/2013 ACIT, Circle-2, Vishwasrao Naik 2006-07
245/PUN/2013 Sangli Sahakari Sakhar 2009-10
Karkhana Ltd.,
A/P. Yashwantnagar,
Tal. Shirala,
Dist. Sangli
PAN : AAAAV0215B
129-130 2526/PUN/2012 Vishwasrao Naik DCIT, Circle-2, 2009-10
2604/PUN/2012 Sahakari Sakhar Sangli 2006-07
Karkhana Ltd.,
Yashwantnagar,
Chikhali, Tal. Shirala,
Dist. Sangli
PAN :AAAAV0215B
131-134 831/PUN/2014 The Shrigonda DCIT, Ahmednagar 2007-08
2455/PUN/2012 Sahakari Sakhar Circle, Ahmednagar 2009-10
903/PUN/2012 Karkhana Ltd., 2008-09
1174/PUN/2016 A/P. Shrigonda ACIT, Ahmednagar 2006-07
Factory, Circle, Ahmednagar
Tal. Shrigonda
Dist. Ahmednagar
PAN : AAAAS4091E
135-136 2595/PUN/2012 DCIT, Ahmednagar The Shrigonda 2009-10
1499/PUN/2016 Circle, Ahmednagar Sahakari Sakhar 2006-07
Karkhana Ltd.,
ACIT, Ahmednagar A/P. Shrigonda
Circle, Ahmednagar Factory,
Tal. Shrigonda
Dist. Ahmednagar
PAN : AAAAS4091E
137 264/PUN/2013 Sahyadri Sahakari ITO, Ward-1, 2009-10
Sakhar Karkhana Satara
Ltd.,
A/P. Yashwantnagar,
Tal. Karad,
Dist. Satara
PAN : AAAAS4070K
138 2597/PUN/2012 Shree Adinath SSK ACIT, Circle-1, 2009-10
Ltd., Satara
Bhalwani, Jeur,
Tal. Karmala,
Dist. Solapur
PAN :AAAAS4167M
139-140 1009/PUN/2013 ACIT, Circle-1, Samarth Sahakari 2008-09
1010/PUN/2013 Aurangabad Sakhar Karkhana Ltd., 2009-10
At. PO. Ankushnagar,
Ambad, Dist. Jalna
PAN : AADAS8482L
13
SSK Group cases
141-143 1024/PUN/2013 Samarth Sahakari ACIT, Circle-1, 2007-08
1025/PUN/2013 Sakhar Karkhana Aurangabad 2008-09
1026/PUN/2013 Ltd., 2009-10
At. PO. Ankushnagar,
Ambad, Dist. Jalna
PAN : AADAS8482L
144-146 1290/PUN/2012 Shree Someshwar DCIT, Circle-6, Pune 2007-08
1291/PUN/2012 SSK Ltd. 2008-09
CO 3/PUN/2016 Tal. Baramati, 2010-11
Dist. Pune -412306
PAN : AAAAS2034B
147 1171/PUN/2014 DCIT, Circle-6, Pune Shree Someshwar SSK 2010-11
Ltd. Someshwarnagar,
Tal. Baramati,
Dist. Pune -412306
PAN : AAAAS2034B
148-149 1686/PUN/2012 ACIT, Circle-3, Shetkari Sahakari 1992-93
1688/PUN/2012 Nanded Sakhar Karkhana Ltd., 1994-95
Swami Ramanand
Tirthnagar, Killari,
TQ. Ausa,
Dist. Latur
PAN : 40003-AT-1797
150 2609/PUN/2012 Sonhira Sahakari DCIT, Circle-1, 2009-10
Sakhar Karkhana Sangli
Ltd., Wangi, Tal.
Kadegaon,
Dist. Sangli-415305
PAN : AAATS7796R
151 1976/PUN/2012 ACIT, Circle-3(1), Shree Satpuda Tapi 1996-97
Dhule Parisar Sahakari Sakhar
Karkhana Ltd.,
P.O. Purushottam
Nagar,
Tal. Shahada,
Dist. Nandurbar
PAN : 40003-AV-1761
152 1694/PUN/2016 Shree Satpuda Tapi DCIT, Dhule Circle, 2012-13
Parisar Sahakari Dhule
Sakhar Karkhana
Ltd.,
P.O. Purushottam
Nagar,Tal. Shahada,
Dist. Nandurbar
PAN : 40003-AV-
1761
14
SSK Group cases
153 1493/PUN/2011 Siddheshwar Sahakari DCIT, Spl. Range-2, 1993-94
Sakhar Karkhana Aurangabad
Ltd.,
Silod, Maniknagar,
Tal. Silod,
Dist. Aurangabad
154 514/PUN/2017 M/s. Ashok Sahakari ITO, Ward-4, 2013-14
Sakhar Karkhana Ahmednagar
Ltd.,
A/P. Ashoknagar,
Tal. Shrirampur,
Dist. Ahmednagar
PAN : AACAA2410P
155-156 1289/PUN/2011 DCIT, Circle-1, Vasantrao Dada Patil 2007-08
1290/PUN/2011 Nashik SSK Ltd., 2008-09
At Post Vithewadi,
Post Lohner,
Tal. Deola,
Nashik
PAN : AAAAV0637K
157 1143/PUN/2015 ACIT, Ahmednagar Shri Jagdamba 1992-93
Circle, Ahmednagar Sahakari Sakhar
Karkhana Ltd.,
A/P. Rashin,
Tal. Karjat,
Dist. Ahmednagar
PAN : AAAAS3208H
158-160 2495/PUN/2012 Sahakar Maharshi ACIT, Circle-1, 2008-09
2496/PUN/2012 Bhausaheb Thorat Ahmednagar 2009-10
868/PUN/2014 Sahakari Sakhar 2010-11
Karkhana Ltd., DCIT, Ahmednagar
At Post Amrutnagar, Circle, Ahmednagar
Tal. Sangamner,
Dist. Ahmednagar
PAN : AAAAS3893G
161-162 2590/PUN/2012 DCIT, Ahmednagar Sahakar Maharshi 2008-09
2591/PUN/2012 Circle, Ahmednagar Bhausaheb Thorat 2009-10
Sahakari Sakhar
Karkhana Ltd.,
At Post Amrutnagar,
Tal. Sangamner,
Dist. Ahmednagar
PAN : AAAAS3893G
15
SSK Group cases
Assessee (s) Represented by Shri Pramod Shingte
Shri Prasanna Joshi
Shri K. Srinivasan
Shri M.K. Kulkarni
Shri Prateek Sandbhor
Shri Laxman R. Nawale (Employer)
Ms. Deepa Khare
None Appeared Sl.Nos. 16, 18, 35, 36 to 41, 48, 49 to 50, 51
to 52, 93, 94, 99, 114, 148 to 149 and 150
Revenue by Ms. Nandita Kanchan
Date (s) of hearing 12-03-2019 & 13-03-2019
Date of pronouncement 14-03-2019
आदेश / ORDER
PER BENCH :
This batch comprising of certain appeals by the assessees and the others by the Revenue relate to different assessment years captioned above. Since most of the appeals have at least one common issue, we are, therefore, disposing them off by this consolidated order for the sake of convenience.
2. Some of the appeals are recalled matters. Some of the appeals are time barred. We have gone through the reasons given for delay in the presentation of the such appeals, with which we are satisfied. As such, the delay in all such cases is condoned and the appeals are admitted for disposal on merits.
16
SSK Group cases I. EXCESSIVE SUGARCANE PRICE PAID
3. A common issue involved in almost all the appeals is on account of the addition made by the Assessing Officer (AO) towards of excessive sugarcane price paid to members as well as non-members of the respective assessees. On a representative basis, we are espousing the facts in the case of Majalgaon Sahakari Sakhar Karkhana Limited Vs. ACIT, Circle-3, Aurangabad - ITA No.308/PUN/2018 for the assessment year 2013-14. The assessee is engaged in the business of manufacturing of white sugar. During the course of assessment proceedings, the AO observed that the assessee paid excessive cane price, over and above the Fair and remunerative price (FRP) fixed by the Government, to its members as well as non-members. On being called upon to justify such deduction, the assessee gave certain explanation by submitting that such payment was solely and exclusively in connection with the business and the entire amount was deductible u/s.37(1) of the Income-tax Act, 1961 (hereinafter also called `the Act'). Relying on the judgment of Hon'ble Supreme Court in the case of DCIT Vs. Shri Satpuda Tapi Parisar S.S.K. Ltd. and others (2010) 326 ITR 402, the AO opined that the excessive price paid was in the nature of `distribution of profits' and hence not deductible. This is how, he computed the excessive cane price 17 SSK Group cases paid both to the members and non-members at Rs.22,02,95,387/- and made addition for the said sum. The ld. CIT(A) echoed the assessment order on this point.
4. Facts in all other cases qua this issue, in so far as the assessment proceedings are concerned, are mutatis mutandis similar. It is seen that in some cases, the addition got deleted, fully or partly by the ld. CIT(A), whilst in others the addition got sustained. This led to filing of the cross appeals both by the assessee as well as the Revenue before the Tribunal.
5. We have heard both the sides and gone through the relevant material on record. There is consensus ad idem between the rival parties that the issue of payment of excessive price on purchase of sugarcane by the assesses is no more res integra in view of the recent judgment of Hon'ble Supreme Court in CIT Vs. Tasgaon Taluka S.S.K. Ltd. (2019) 103 taxmann.com 57 (SC). The Hon'ble Apex Court, vide its judgment dated 05-03-2019, has elaborately dealt with this issue. It recorded the factual matrix that the assessee in that case purchased and crushed sugarcane and paid price for the purchase during crushing seasons 1996-97 and 1997- 98, firstly, at the time of purchase of sugarcane and then, later, as per the Mantri Committee advice. It further noted that the 18 SSK Group cases production of sugar is covered by the Essential Commodities Act, 1955 and the Government issued Sugar Cane (Control) Order, 1966, which deals with all aspects of production of sugarcane and sales thereof including the price to be paid to the cane growers. Clause 3 of the Sugar Cane (Control) Order, 1966 authorizes the Government to fix minimum sugarcane price. In addition, the additional sugarcane price is also payable as per clause 5A of the Control Order, 1966. The AO in that case concluded that the difference between the price paid as per clause 3 of the Control Order, 1966 determined by the Central Government and the price determined by the State Government under clause 5A of the Control Order, 1966, was in the nature of `distribution of profits' and hence not deductible as expenditure. He, therefore, made an addition for such sum paid to members as well as non-members. When the matter finally came up before the Hon'ble Apex Court, it noted that clause 5A was inserted in the year 1974 on the basis of the recommendations made by the Bhargava Commission, which recommended payment of additional price at the end of the season on 50:50 profit sharing basis between the growers and factories, to be worked out in accordance with the Second Schedule to the Control Order, 1966. Their Lordships noted that at the time when additional purchase price is determined/fixed under clause 5A, the 19 SSK Group cases accounts are settled and the particulars are provided by the concerned Co-operative Society as to what will be the expenditure and what will be the profit etc. Considering the fact that Statutory Minimum Price (SMP), determined under clause 3 of the Control Order, 1966, which is paid at the beginning of the season, is deductible in the entirety and the difference between SMP determined under clause 3 and SAP/additional purchase price determined under clause 5A, has an element of distribution of profit which cannot be allowed as deduction, the Hon'ble Supreme Court remitted the matter to the file of the AO for considering the modalities and manner in which SAP/additional purchase price/final price is decided. He has been directed to carry out an exercise of considering accounts/balance sheet and the material supplied to the State Government for the purpose of deciding/fixing the final price/additional purchase price/SAP under clause 5A of the Control Order, 1966 and thereafter determine as to what amount would form part of the distribution of profit and the other as deductible expenditure. The relevant findings of the Hon'ble Apex Court are reproduced as under:-
"9.4. ..... Therefore, to the extent of the component of profit which will be a part of the final determination of SAP and/or the final price/additional purchase price fixed under Clause 5A would certainly be and/or said to be an appropriation of profit. However, at the same time, the entire/whole amount of difference between the 20 SSK Group cases SMP and the SAP per se cannot be said to be an appropriation of profit. As observed hereinabove, only that part/component of profit, while determining the final price worked out/SAP/additional purchase price would be and/or can be said to be an appropriation of profit and for that an exercise is to be done by the assessing officer by calling upon the assessee to produce the statement of accounts, balance sheet and the material supplied to the State Government for the purpose of deciding/fixing the final price/additional purchase price/SAP under Clause 5A of the Control Order, 1966. Merely because the higher price is paid to both, members and non- members, qua the members, still the question would remain with respect to the distribution of profit/sharing of the profit. So far as the non-members are concerned, the same can be dealt with and/or considered applying Section 40A (2) of the Act, i.e., the assessing officer on the material on record has to determine whether the amount paid is excessive or unreasonable or not........ 9.5 Therefore, the assessing officer will have to take into account the manner in which the business works, the modalities and manner in which SAP/additional purchase price/final price are decided and to determine what amount would form part of the profit and after undertaking such an exercise whatever is the profit component is to be considered as sharing of profit/distribution of profit and the rest of the amount is to be considered as deductible as expenditure."
6. Both the sides are unanimously agreeable that the extant issue of deduction for payment of excessive price for purchase of sugarcane, raised in most of the appeals under consideration, is squarely covered by the aforesaid judgment of the Hon'ble Supreme Court. Respectfully following the precedent, we set- aside the impugned orders on this score and remit the matter to the file of the respective A.Os. for deciding it afresh as per law in consonance with the articulation of law by the Hon'ble Supreme Court in the aforenoted judgment. The AO would allow deduction for the price paid under clause 3 of the Sugar Cane (Control) 21 SSK Group cases Order, 1966 and then determine the component of distribution of profit embedded in the price paid under clause 5A, by considering the statement of accounts, balance sheet and other relevant material supplied to the State Government for the purpose of deciding/fixing the final price/additional purchase price/SAP under this clause. The amount relatable to the profit component or sharing of profit/distribution of profit paid by the assessee, which would be appropriation of income, will not be allowed as deduction, while the remaining amount, being a charge against the income, will be considered as deductible expenditure. At this stage, it is made clear that the distribution of profits can only be qua the payments made to the members. In so far as the non- members are concerned, the case will be considered afresh by the AO by applying the provisions of section 40A(2) of the Act, as has been held by the Hon'ble Supreme Court supra. Needless to say, the assessee will be allowed a reasonable opportunity of hearing by the AO in such fresh determination of the issue.
7. It is noted that in some of the appeals, the assessees have raised an alternate ground for allowing deduction u/s.80P in respect of the addition.
22
SSK Group cases
8. The ld. ARs, in some of the cases, which were represented by them, were fair enough not to press such ground as it is only an alternate ground and having become infructuous in view of the restoration of the matter to the AO. No argument was advanced in support of such ground in other cases, even where the ld. ARs participated in proceedings before the Tribunal. Therefore, the said alternate ground in all such cases is dismissed.
9. Apart from the above issue, which is common in almost all the appeals in this batch, there are certain appeals having other issues also. We will take up such issues one by one. II. ADDITION FOR SUGAR GIVEN TO MEMBERS AT CONCESSIONAL RATES - [Appeals in which Krishna Sahakari Sakhar Karkhana Limited (SC) not considered by lower authorities ]
10. In some of the appeals, there is another issue of giving sugar to members at concessional rates. Such ground is against the disallowance on account of price difference on certain quantity of sugar given to the members at concessional rate.
11. Having heard both the sides and gone through the relevant material on record, it is observed that the AO made addition of the 23 SSK Group cases difference between the market price and the concessional price at which sugar (final product) was given to farmers and cane growers. In this regard, it is observed that this issue has been considered by the Hon'ble Supreme Court in the case of CIT Vs. Krishna Sahakari Sakhar Karkhana Limited (2012) 27 taxmann.com 162 (SC). Vide judgment dated 25-09-2012, the Hon'ble Supreme Court noticed that the difference between the average price of sugar sold in the market and the price of sugar sold by the assessee to its members at concessional rate was taxed by the Department under the head "Appropriation of profit". The Hon'ble Summit Court remitted the matter to the CIT(A) for considering, inter alia,:
"whether the abovementioned practice of selling sugar at concessional rate has become the practice or custom in the Co- operative sugar industry?; and whether any Resolution has been passed by the State Government supporting the practice?; The CIT(A) would also consider on what basis the quantity of the final product, i.e. sugar, is being fixed for sale to farmers/cane growers/Members each year on month-to-month basis, apart from others from Diwali?" The issue under consideration can be decided by an appropriate lower authority only on the touchstone of the relevant factors noted in the above judgment. In our considered opinion, it would be just and fair if the impugned orders 24 SSK Group cases on this score are set aside and the matter is restored to the file of AOs, instead of to the CITs(A), for fresh consideration as to whether the difference between the average price of sugar sold in the market and that sold to members at concessional rate is appropriation of profit or not, in the light of the directions given by the Hon'ble Supreme Court in the case of Krishna Sahakari Sakhar Karkhana Limited (supra). Restoration to the AO is necessitated because, following the judgment of the Hon'ble Apex Court in the case of Tasgaon Taluka S.S.K. Ltd. (supra), we have remitted the issue of payment of excessive price to the file of AO, and as such, the instant issue cannot be sent to ld. CIT(A) as it would amount to simultaneously sending one part of the same assessment order to the AO and other to the CIT(A), which is not appropriate. We order accordingly.
III. DISALLOWANCE OF CONTRIBUTION TO AREA DEVELOPMENT FUND
12. Another issue in some of the appeals is against the deletion/confirmation of disallowance made by the AO on account of Area Development Fund.
13. Having heard both the sides and gone through the relevant material on record, it is seen that similar issue came up for 25 SSK Group cases consideration before the Hon'ble Supreme Court in the case of Siddheshwar Sahakari Sakhar Karkhana Limited Vs. CIT and others (2004) 270 ITR 1 (SC). In that case, the Hon'ble Supreme Court observed in para 44 that the receipts in the form of Area Development Fund always remained with the assessee. It also noted the contention of the assessee in para 45 that the realisations made towards the Area Development Fund were impressed with the specific legal obligation to spend the money for specified purposes which were unrelated to the business of the sugar factory and hence, could not be treated as income of the assessee. Eventually, the Hon'ble Supreme Court remitted the matter back for fresh determination. It is noticed that in the appeals under consideration, the ld. CITs(A) have not considered the impact of the judgment of the Hon'ble Supreme Court in Siddheshwar Sahakari Sakhar Karkhana Limited (supra) and decided the issue without taking note of the factors directed to be considered in the aforenoted case. In view of the above decision of Hon'ble Supreme Court, we set-aside such impugned orders and remit the matter to the file of the respective AOs for deciding the issue afresh in conformity with the guidelines laid down by the Hon'ble Apex Court in the above judgment.
26
SSK Group cases
IV. DISALLOWANCE FOR LATE DEPOSIT OF
EMPLOYEES' SHARE IN EPF ETC.
14. Another issue in some of the appeals is against the confirmation of disallowance for delayed deposit of ESI / EPF employees' share. During the course of assessment proceedings, it was noticed that the assessee belatedly deposited the amount of employees' contribution towards EPF and ESI. The details of due dates and actual payments have been set out in the respective assessment orders. The AO, therefore, made such disallowance, which came to be affirmed in the first appeal.
15. We have heard the rival submissions and perused the relevant material on record. It is found that the issue raised herein is no more res integra. The Hon'ble Apex Court in the case of CIT v. Alom Extrusions Limited (2009) 319 ITR 306 (SC) has held that the amendment to first proviso and omission of the second proviso to section 43B by the Finance Act, 2003, is retrospective. The Hon'ble Delhi High Court in the case of CIT v. Aimil Limited (2010) 321 ITR 508 (Delhi) has allowed deduction in respect of employees' share when the amount was paid before the due date.
When we consider these two judgments, it is manifested that both the employer's and employees' contribution are allowable as 27 SSK Group cases deduction if these are deposited albeit belatedly under the respective Acts, but before the due date of filing of return u/s 139(1) of the Act.
16. It is seen as an admitted position that the assessees in such cases deposited the employees' contribution towards EPF and ESIC before the due date u/s 139(1) of the Act. Respectfully following the aforenoted judgment of the Hon'ble Delhi High Court, we order for the deletion of the addition sustained in the first appeals on account of late deposit of employees' contribution to the Provident fund.
V. PROVISION FOR VASANTDADA SUGAR INSTITUTE (VSI) CONTRIBUTION :
17. Another issue raised in some of the appeals is against the confirmation of disallowance of contribution to Vasantdada Sugar Institute (VSI). The AO observed that the assessee made provision for Vasantdada Sugar Institute (VSI) contribution and claimed weighted deduction at 125% u/s.35(1)(ii) of the Act. The said amount was not paid to the institute. The same being only in the nature of provision, the AO did not allow deduction u/s.35(1)(ii). The ld. CIT(A) decided this issue in favour of the assessee by following an order passed by the Pune Benches of the 28 SSK Group cases Tribunal in the case of Bhima S.S.K. Ltd. (ITA No.1414/PUN/2000).
18. We have heard both the sides and gone through the relevant material on record. It is found that the ld. CIT(A) has determined this issue in favour of the assessee by following the order passed by the Pune Benches of the Tribunal in the case of Bhima S.S.K. Ltd. (supra). No material has been placed on record to show that this order of the Tribunal has been reversed or modified in any manner by the Hon'ble High Court. Respectfully following the precedent, we decide this issue in favour of the assessee. VI. CONTRIBUTION TO CHIEF MINISTER RELIEF FUND :
19. Another issue raised in some of the appeals is against the confirmation of addition on account of contribution made to Chief Minister Relief Fund.
20. The assessee contributed certain amount in the Chief Minister Relief Fund and claimed deduction for the same in its Profit and loss account. The AO observed that this fund established by the State Government is covered u/s.80G(iiihf) of the Act and, as such, the contribution is deductible at 50% of the aggregate of the sums specified. He, therefore, disallowed the amount, which action came to be countenanced in the first appeal. 29
SSK Group cases
21. We have heard both the sides and gone through the relevant material on record. There is no dispute that the assessee did make contribution to the Chief Minister Relief Fund. As against the assessee claiming the entire amount as deduction in its Profit and loss account, the AO opined that the said contribution was eligible for deduction u/s. 80G(iiihf) of the Act at the rate of 50% along with other qualifying sums. The ld. CIT(A) sustained the entire addition overlooking the fact that deduction u/s.80G(iiihf) was not allowed by the AO on such contribution in the computation of total income. Under these circumstances, we cannot uphold the disallowance of the entire amount claimed as deduction by the assessee in its Profit and loss account. Approving the additions made, we remit the matter to the file of the AO for granting the deduction u/s.80G(iiihf) as per law after allowing a reasonable opportunity of hearing to the assessee.
VII. KHODKI CHARGES
22. Another issue raised in some of the appeals is against non- granting of deduction towards payment of Khodki charges. On being called upon to justify such deduction, the assessee submitted that this payment was made as per the order of the Director of Sugar. It was further explained that at the time of harvesting, the 30 SSK Group cases harvesting labour cut more part of the upper side of the crop and therefore, to compensate loss in weight to the grower, the said Khodki charges were paid to the farmers. The AO was not satisfied with the explanation tendered on behalf of the assessee. He noted that the Commissioner of Sugar, on behalf of Government of Maharashtra, was issuing directions for payment of Khodki charges only on the basis of proposal sent by the respective assessees. The ld. CIT(A) deleted the addition by relying on the judgment of Hon'ble Bombay High Court in CIT Vs. Manjara Shetkari SSK Ltd. and others (2008) 301 ITR 191 (Bom.), against which the Revenue has come up in appeal before the Tribunal.
23. We have heard both the sides and gone through the relevant material on record. It is seen that Khodki charges were incurred as per the directions of the Director of Sugar to compensate for the farmers' loss for unevenly cutting of cane sugar at the time of harvesting. This issue came up for consideration before the Special Bench of the Tribunal in DCIT Vs. Manjara Shetkari SSK Ltd. (2004) 85 TTJ (Mum.)(SB) 369, which granted deduction for said expenses. On further appeal by the Revenue to the Hon'ble Bombay High Court, their Lordships in the aforenoted case approved the view taken by the Tribunal allowing deduction for payment of such Khodki charges. The ld. CIT(A) has recorded 31 SSK Group cases that the SLP filed by the Department in the case of Jadamba SSK Ltd., on similar issue, has been dismissed by the Hon'ble Supreme Court on 23-03-2009. In view of the fact that Khodki charges have been held as deductible by the Hon'ble jurisdictional High Court and the recent judgment of Hon'ble Supreme Court in Tasgaon Taluka Sahakari Sakhar Karkhana Ltd. (supra) does not cover Khodki charges, we hold that this issue needs to be decided in favour of the assessee.
VIII. DEDUCTION u/s.80P ON INTEREST AND DIVIDEND
24. In some of the appeals the issue of deduction under section 80P of the Act on interest and dividend income is also involved. The assessee claimed deduction u/s.80P(2)(d) of the Act on interest and dividend received from Co-operative Society on Savings Bank accounts. The AO did not allow such deduction. The ld. CIT(A) overturned the assessment order on this point and granted deduction. The Revenue is aggrieved by such allowing of deduction.
25. We have heard both the sides and gone through the relevant material on record. Relevant part of section 80P reads as under : -
"80P. (1) Where, in the case of an assessee being a co-operative society, the gross total income includes any income referred to in sub- section (2), there shall be deducted, in accordance with and subject to 32 SSK Group cases the provisions of this section, the sums specified in sub-section (2), in computing the total income of the assessee.
(2) The sums referred to in sub-section (1) shall be the following, namely :--
(a) to (c)
(d) in respect of any income by way of interest or dividends derived by the cooperative society from its investments with any other co-
operative society, the whole of such income; ........"
26. A cursory look of the above provision deciphers that any amount of interest or dividend derived by a Co-operative Society from its investments with any other Co-operative Society, is deductible under clause (d) of section 80P(2) of the Act. The ld. CIT(A) has given a categorical finding that assessee is a Co- operative Society and the Co-operative Bank from which the above-mentioned income was earned, is also a Co-operative Society duly registered under Maharashtra Cooperative Societies Act. This contention has not been controverted by the ld. DR with any cogent material or evidence. Thus, it is seen that the case of the assessee is fully covered u/s.80P(2)(d) of the Act. Reliance of the AO on the provisions of sub-section (4) of section 80P is misplaced. Such provision states that : ` The provisions of this section shall not apply in relation to any co-operative bank other than a primary agricultural credit society or a primary co-operative agricultural and rural development bank.' As the assessee under 33 SSK Group cases consideration is not a Co-operative Bank, the mandate of sub- section (4) does not extend to it. We, therefore, approve the view taken by the ld. CIT(A) in granting deduction u/s.80P(2)(d) of the Act in respect of interest and dividend income earned by the assessee on such facts.
27. In the result, all the appeals are fully/partly allowed for statistical purposes.
Order pronounced in the Open Court on 14th March, 2019.
Sd/- Sd/-
(PARTHA SARATHI CHAUDHURY) (R.S.SYAL)
JUDICIAL MEMBER VICE PRESIDENT
पुणे Pune; दनांक Dated : 14th March, 2019
सतीश
आदेश क ितिलिप अ िे षत/Copy
षत of the Order is forwarded to:
1. अपीलाथ / The Appellant;
2. यथ / The Respondent;
3. The CIT(A) concerned
4. The CIT concerned
5. िवभागीय ितिनिध, आयकर अपीलीय अिधकरण, पुणे "बी" / DR 'B', ITAT, Pune;
6. गाड फाईल / Guard file.
आदेशानुसार/ ार BY ORDER, // True Copy // Senior Private Secretary आयकर अपीलीय अिधकरण ,पुणे / ITAT, Pune 34 SSK Group cases Date
1. Draft dictated on 12-03-2019 Sr.PS
2. Draft placed before author 14-03-2019 Sr.PS
3. Draft proposed & placed JM before the second member
4. Draft discussed/approved JM by Second Member.
5. Approved Draft comes to Sr.PS the Sr.PS/PS
6. Kept for pronouncement on Sr.PS
7. Date of uploading order Sr.PS
8. File sent to the Bench Clerk Sr.PS
9. Date on which file goes to the Head Clerk
10. Date on which file goes to the A.R.
11. Date of dispatch of Order.
*