Income Tax Appellate Tribunal - Lucknow
Dy. Commissioner Of Income Tax, Lucknow vs M/S Technical Associates Ltd., Lucknow on 13 February, 2018
IN THE INCOME TAX APPELLATE TRIBUNAL
LUCKNOW BENCH"B", LUCKNOW
BEFORE SHRI. T.S. KAPOOR, ACCOUNTANT MEMBER
AND SHRI PARTHA SARATHI CHAUDHURY,JUDICIAL MEMBER
ITA No.672/LKW/2016
Assessment Year:2013-14
Dy. CIT v. M/s Technical Associates Ltd.
Range 6 8th K.M. RSM Marg,
Lucknow Faizabad Road, Ismailganj
Lucknow
TAN/PAN:AABCT7365F
(Appellant) (Respondent)
Appellant by: Shri Rajiv Kumar, D.R.
Respondent by: Shri Rohit Bhalla, FCA
Date of hearing: 07 02 2018
Date of pronouncement: 13 02 2018
ORDER
PER T.S.KAPOOR, A.M:
This appeal preferred by the Revenue arises out of the order of the ld. CIT(A)-II, Lucknow dated 10/10/2016 on the following grounds of appeal:-
1. The Commissioner of Income Tax (Appeals), Lucknow has erred in law and on facts of the case in deleting the addition of Rs.89,11,890/- made on account of Imported Raw material Purchase ignoring the fact that the assessee is following mercantile system of accounting and the purchase of raw material of Rs.89,11,890/- pertains to A.Y. 2012-13 and further assessee has failed to prove that the purchase has not been booked in A.Y. 2012-13.
2. The Commissioner of Income Tax (Appeal) has erred in law and on facts of the case in deleting the addition of ITA No.672/LKW/2016 Page 2 of 15 Rs.1,34,23,661/- ignoring the fact that the provisions of Rule 46A of the I.T. Rules, 1962 provides that the additional evidence should be admitted only when the assessee was prevented by sufficient cause from producing the evidence which he was called upon to produce by the Assessing Officer.
3. The Commissioner of Income-tax (Appeal) has erred in law and on facts of the case in deleting the addition of Rs.1,34,23,661/- ignoring the decisions of Hon'ble Allahabad High Court in the case of Bimal Kumar Anant Kumar Vs.CIT[2009] 288 ITR 278 (All) and Gujrat High Court decision in the case of N.B. Surti Family Trust Vs. CIT(2007) 288 ITR 523 (Guj.) relating to Rule 46A of I.T. Rules 1962.
4. That the appellant craves leave to add or amend any one or more of the grounds of appeals, as stated above, as and when need to do so arises with the prior permission of the Court.
2. The facts in this case are that for assessment year 2013-14 assessee filed its return of income showing total income at Rs.4,62,66,240/-. The assessment was completed on an income of Rs.5,84,19,654/- by making various additions vide order passed under section 143(3) of the Act.
3. Ground No.1 raised by the Revenue relates to deletion of addition of Rs.89,11,890/- made on account of imported raw material purchase.
4. In this regard, the findings of the Assessing Officer as has been reproduced by the ld. CIT(A) in his order is reproduced hereunder for the sake of ready reference:-
"The assessee was further show caused to produce purchase bills of imported raw material and amounting to Rs.89,11,890/-. The assessee vide submission dated 10.03.2016 submitted purchase ITA No.672/LKW/2016 Page 3 of 15 bill of Rs.89,11,890/- on examination of above bill of Rs.89,11,890/-, it is noticed that the purchase invoice no. E12.7038 is dated 25.02.2012 and Shipment date is 25.02.2012. Hence it relates to Assessment Year 2012-13. The assessee gave explanation that the shipment was received in April 2012 and hence taken is purchase of A.Y. 2013-14. The assessee was further asked to prove with books of accounts that above purchase of Rs.89,11,890/- has not been taken in AY 2012-13. The assessee did not furnished books of accounts to prove his contention. The assessee is following mercantile system of accounting hence it was mandatory for him to account for the purchase in relevant assessment year. Further is purchase ledger submitted by assessee every purchase has to be entered whether imported or not. The assessee has not entered above purchase is his Purchase Ledger. Also, the assessee could not prove that the above purchase was not booked in assessment year 2012-13, therefore assessee contention is rejected and amount of Rs.89,11,890/- is added to the income of the assessee."
5. The assessee filed written submission before the ld. CIT(A), which is reproduced hereunder:-
"Disallowance of Purchase of Imported Raw Material Rs.89,11,890/-:
In the ordinary course of business, the appellant company imports Prim CRGO Electrical Steels Coils, being basic raw material for best results of the transformers manufactured.
The purchase order was made in financial year 2011-12, Indent No 7038 dtd 03.02.2012 to M/s The Stainless Steel Corporation, 16, Nun Street, Wilmington, NC 28401, USA, bill enclosed at pages 131 and the material was dispatched by the vendor vide shipment dtd 25.02.2012 received in India on 10.04.2012 as per the Bill of Entry, available in departmental records having been filed vide reply, enclosed at pages 129 -130.
The copy of the Commercial Invoice aggregating to Rs.89,11,890/- was filed before the AO in scrutiny proceedings ITA No.672/LKW/2016 Page 4 of 15 vide reply dtd 10.03.2016 along with Bill of Entry dtd 10.04.2012 as annexure 1A and IB to the reply mentioned supra, reference to pages 153 -160 for bills of international shipping business offering whose container shipping services were got rendered for import and customs clearance are all dated 10.04.2012 falling in the relevant assessment year 2013-14.
Since the raw material was received and consumed in the financial year 2012-13, expenditure was booked during the relevant assessment year under consideration.
The Ld. A.O. failed to appreciate that accounts of the assessee company, which is a public limited company, are subjected to audit both under the Companies Act, 1956, as well as, under the Income Tax Act, 1961 under section 44AB, which envisages rather mandates expenditure to be accounted for in the books of accounts only for the relevant financial year. Any deviations from the method of accounting or any expenditure of the previous year or subsequent year has to be stated so in the 'notes to accounts' or 'significant accounting policies in the audit report. No such mention has been made by the auditor. No adverse comment had been made by the statutory auditors in their 'Independent Auditors Report'(pages 40 - 43 ), nor in the tax audit report. The 'significant accounting polices' and 'recognition of income and expenditure' annexed to the audit report by the auditor specifically mentions that applicable accounting principles applicable in India and accounting standard issued by ICAI and relevant provisions of the Companies Act, 1956 have been followed and all revenues, expenses, assets and liabilities have been accounted for on accrual basis. Since there was no adverse comment of the auditor, observation of the ld. A.O. that the expenditure would have been charged to revenue in A.Y. 2012-13 is highly inappropriate and based on guess work.
The trading results of the appellant company were accepted by the Ld. AO. It is pertinent to state that since the raw material in question was imported, the same could not have been acquired without payment of customs duty. The Ld A.O. has ignored the Bill of Entry dtd 10.04.2012 filed as annexure 1A to the reply dtd ITA No.672/LKW/2016 Page 5 of 15 10.03.2016, and presumed irrelevant status that the appellant company would have booked the expenditure in the year ending 31.03.2012 and again in the year ending 31.03.2013.
It shall be pertinent to state that on the date of hearing, viz 10.03.2016, the A.O. had demanded the production of books of accounts and supporting vouchers for the preceding assessment year 2012-13, for which the counsel had then declined that they are not available immediately and shall take some time for them to be produced. It was also reiterated that in the case for AY 2012-13 detailed scrutiny proceedings had already taken place and all relevant details regarding purchases of raw material were already available in the records of the Department which were readily available for cross verification. Details of imported and indigenous raw material purchases for A.Y. 2012-13 are enclosed along with complete detailed account of imported and indigenous raw material purchases for assessment year 2013-14.
It was also reiterated that books of accounts of A.Y. 2013-14, the previous year scrutiny and supporting vouchers have been brought for verification. The books of accounts an supporting vouchers for AY. 2012-13 had either been called for by the assessing officer for verification, nor they have been brought for perusal of the Ld. A.O. and any consequential disallowance is unjustified and illegal, as also because it is made without any opportunity.
The disallowance is based on presumptions and surmises, not based on any material on record, ignoring the bill of entry dated 10.04.2012 which pertains to the relevant assessment year, ignoring the quantitative details filed and on record, ignoring the audited books of accounts.
Hence the disallowance being based on presumption and surmise and on suspicion, the Ld. AO had made disallowance which is arbitrary, unjustified and against the principles of the natural justice and equity and be deleted."
6. The above submissions of the assessee were forwarded to the Assessing Officer for examination and for submitting his report. The Assessing Officer submitted the remand report. Apart from partly ITA No.672/LKW/2016 Page 6 of 15 commenting on the submissions of the assessee, the Assessing Officer has objected to the admission of the submissions of the assessee under rule 46A of the rules. Copy of the remand report was provided to the assessee for comments. The assessee had filed written comments, the gist of which, as appearing in the order of the ld. CIT(A), is as under:-
"Kindly refer to the Remand Report submitted by the Ld. Deputy Commissioner of Income Tax, Range 6, Lucknow dated 02.08.2016 to your Honor in the above mentioned case. In this regard it is to state that the assessee was prevented with sufficient and reasonable cause from producing before the Assessing Officer the evidence which was called upon to be produced in the regular assessment proceedings, neither was sufficient opportunity provided to the appellant assessee in scrutiny proceedings for opportunity for production of books of accounts, hence the remand proceedings was prayed by the appellant assessee company.
On the date of hearing on 10.03.2016, on being directed to produce the supporting bills for verification from the ledger account, it was urged by the counsel that the supporting bills. Vouchers of the Raw Material Purchase (Tax Paid) A/c. could be produced at a short adjournment in the next week, as certain bills were at the Sitarganj, Uttranchal factory.
However, the Id. AO passed the order in haste, although the case was to get time barred on 31.03.2016, without verifying for the required details, without affording reasonable opportunity, and passed a hasty order, disallowing the entire expenditure. The order so passed is not only highly unjustified, but also against the principles of natural justice and equity.
In the remand proceedings, the Ld. AO vide notice u/s. 142(1) of the ITA dated 04.05.2016 ( ann. 532 - 533 ) to furnish 'all books of accounts including stock register and bills and vouchers for AY 2013-14' which was duly complied with in entirety on 23.05.2016 including all original vouchers. The appellant assessee company duly submitted details in the format enclosed as Annexures enclosed (ann. 534 - 541) along with requisite books of accounts ITA No.672/LKW/2016 Page 7 of 15 and bills / vouchers. Again vide notice dated 17.07.2016 in F No. DCIT/R-6/Lko/Technical Associates/2016-17/512 (ann. 542) the Ld. Assessing Officer directed as under:
The above notice categorically clarifies that the relevant records were produced, examined and verified to the satisfaction of the Ld. AO subject to the examination in the above format. The required details were again furnished along with books of accounts and supporting bill / vouchers which were again thoroughly checked by the Ld. A O along with the Inspector on 29.07.2016 filed a/w the directed format( ann. 543 - 550). The Ld. AO also examined the TDS challans for the job work with reference to the TDS returns filed by the assessee company and the certificates issued in respect thereto. In the remand report the Ld. AO has again reiterated that The Ld. AO has omitted to observe that the statements submitted that there were aggregate entries amounting to Rs.7,66,833/-
(ann. 541). The appellant assessee having established the fact that these job work expenses have been incurred wholly, exclusively and necessarily for the purpose of manufacture of transformers, no contrary fact having been established in remand proceedings, the disallowance is illegal. Once the expenditure is incurred for the purpose of the business, the supporting bills and veracity having been examined, no contrary finding made by the Ld. AO., your Honor is humbly prayed to delete the twin disallowances of Rs.89,11,890/- and Rs.1,34,23,661/-.
4(4)(i) I have examined the facts and circumstances of the case. I have considered the findings of the Assessing Officer and the submissions of the appellant. I have also considered the remand report and the comments of the appellant thereon. At the outset I find that the AO has objected to the evidences filed by the appellant during the appellate proceedings by making a reference to Rule 46A. I find that during the course of assessment proceedings the AO required the assessee to file certain details. On the date of hearing on 10.03.2016, on being directed to produce the supporting bills for verification from the ledger account, it was urged by the authorized representative that the supporting bills/ vouchers of the Raw Material Purchase could be ITA No.672/LKW/2016 Page 8 of 15 produced at a short adjournment in the next week, as certain bills were at the Sitarganj factory. The AO it appears did not allow the appellant sufficient opportunity and therefore the case of the appellant squarely falls within the ambit of Rule 46A(4).
4(4)(ii) Nevertheless, as per Rule 46A the additional evidence if filed may be admitted and once if the additional evidence is admitted, an opportunity has to be given to the AO. It is for the AO to avail or not to avail the opportunity. It is the discretion of the AO. The AO cannot sit on judgment as to whether the additional evidence admitted was justified or not. Reference be made to the decision of MM Muthwappavs CIT (1962) 46 ITR 1107, 1122 (Madras). Further, reliance is placed on the judgment of Hon'ble Delhi High Court in the case of CIT vs. Virgin Securities and Credits (P) Ltd. Reported at 332 ITR 396 Delhi, wherein it was held that -
"Held, dismissing the appeal, (i) that before admitting the additional evidence the Commissioner (Appeal) had obtained a remand report from the AO. The additional evidence was crucial to the disposal for the appeal and had a direct bearing on the quantum of the claim made by the assessee. Rule 46A of the Income Tax Rules, 1962, permits the Commissioner (Appeals) to admit additional evidences if he finds that the same is crucial for disposal of the appeal."
The objections of the AO are therefore unjust as proper adequate opportunity has to be allowed to the appellant in the interest of justice."
7. The ld. CIT(A), after considering the written submissions of the assessee and the assessment order, held as under:-
4(5) I find that the appellant is engaged in the manufacture and sale of transformers. The appellant company imports Prim CRGO Electrical Steels Coils, the basic raw material of the transformers manufactured. The appellant company placed a ITA No.672/LKW/2016 Page 9 of 15 purchase order in financial year 2011-2012, Indent No 7038/ dated 8/2/2012 to M/s The Stainless Steel Corporation, 16, Nun Street, Wilmington, NC 28401. The material was dispatched by the vendor vide shipment dated 25.02.2012, which was received in India on 10.04.2012 as per the Bill of Entry, copy of which has been filed at pages 129 - 130 of the paper book. The copy of the Commercial Invoice aggregating to Rs. 89,11,890/- was filed before the AO in scrutiny proceedings vide reply dated 10.03.2016 along with Bill of Entry dated 10.04.2012. The bills of international shipping whose container were used for import and customs clearance are all dated 10.04.2012 falling in the relevant assessment year 2013-2014 under consideration. The AO disallowed the purchases of Rs. 89,11,8907- as the concerned date of the bill i.e. 25.02.2012 did not fall in the financial year 2012-2013 relevant to the assessment year 2013-2014 under consideration.
4(6) The first point to note is that the material supplied by the bill for Rs.89,11,890/-was imported and as per customs clearances the same was received in financial year 2012-2013 under consideration on id.04.2012. The same could not have been accounted for in the earlier years in absence of corresponding stock. The items corresponding to purchases of Rs. 89,11,890/- were received during the year under consideration and have been taken in purchase in the year under consideration and used in manufacture in the year under consideration and the sales of the manufactured item is shown in the year under consideration. The second point to note is that the AO has not rejected the books of accounts. The appellant has maintained the books of accounts which have been audited. These were produced before the AO for examination. The AO has not found any discrepancy Therein, which means that the books of accounts are correct and complete within the meaning of section 145 of the Act Thirdly, the actual receipt of goods is very important for determining the genuineness of the purchases. If the assessee has maintained day-to-day stock register of the goods and the goods in such register are recorded and the correctness or genuineness of the stock register is not doubted, then, it would be improper to doubt the genuineness of the purchases itself. Again, the Assessing ITA No.672/LKW/2016 Page 10 of 15 Officer has accepted the sales made by the assessee and if that be so, it would indicate that the assessee must have made purchases, otherwise it would not be possible for the assessee to make the sales.
4(7) The appellant has filed complete details of purchases, bills of entry, customs clearances, genuineness of which has not been doubted by the AO. Thus, the gamut of evidence i.e. proper books of account, due recording of purchase, maintenance of quantitative stock register, payment to the trade creditors by way of banking channels and Assessing Officer's no objection on opening and closing stock go to demonstrate that the purchases were genuine. They have been disallowed merely on suspicions, conjectures and surmises without adhering to the principle of natural justice. Reliance is placed on the decision in Nemi Chand Kothari Vs. CIT (2003) 264 ITR 254 (Gau.) for the proposition that where the account books of the assessee are not rejected the addition cannot be made and the payments having been made through account payee cheques which has not been controverted by the Assessing Officer, cannot be disallowed. Reliance is also placed on the decision of Gujrat High Court in the case of Yunus Haji Ibrahim Fazalwala v. Income-tax Officer [2016] 70 taxmann.com 93 (Gujarat) that in absence of the AO having rejected the books of accounts, the purchases could not have been disallowed.
4(8) In view of the examination above I find that the purchases of Rs. 89,11,890/- are genuine and the corresponding material was received during the year under consideration and has accordingly been accounted in the current assessment year 2013-2014. The purchases are entered in the books of accounts which have been audited and produced before the AO, who has not found any discrepancy. In view of the above corresponding sales having been accepted by the AO the disallowance of purchases is not justified. The addition of Rs. 89,11,890/- made by the AO is deleted giving relief to the appellant."
8. We have perused the case records and we find that the first appellate authority has examined the issue and found purchases of ITA No.672/LKW/2016 Page 11 of 15 imported raw material amounting to Rs.89,11,890/- to be genuine and corresponding material was received during the year under consideration and accordingly he held that it should be accounted for in the current assessment year i.e. 2013-14. The purchases are entered in the books of account which are audited and produced before the Assessing Officer who has also not found any discrepancy therein. We, therefore, find no infirmity with the findings of the ld. CIT(A) and accordingly the relief granted to the assessee on this issue is sustained.
9. The next grounds relates to the deletion of addition of Rs.1,34,23,661/-.
10. The findings of the Assessing Officer on this issue, as recorded in the order of the ld. CIT(A), are as under:-
The assessee submitted list of "Raw material purchase (Tax Paid)"
claimed at Rs. 1,34,23, 661/-. On examination of list, it is noticed that assessee has not mentioned name of the party from whom purchases were made and descriptions of items purchased and voucher numbers. The assessee was asked to produce purchase bills along with books of accounts to verify his claim. The assessee stated that books of accounts and purchase bills of Sitarganj unit are not present at Lucknow office. In the absence of purchase bills and books of accounts the assessee contention could not be verified. Further it could also be not verified whether purchases were paid through cheque. Further, all the purchaser should be shown in the purchase ledger accounts but above purchase are not shown in Purchase Ledger. In-view of above facts, the assessee contention is rejected and "Raw material Purchase (Tax Paid)" claimed at Rs.1,34,23,661/- is disallowed and added to the income of assessee.
11. Before the ld. CIT(A), assessee has filed written submission which, for the sake of ready reference, is reproduced hereunder:-
ITA No.672/LKW/2016 Page 12 of 15"The Ld. Assessing Officer has erred in law and on facts in disallowing entire 'Raw Material Purchase ( Tax Paid ) at Rs.1,34,23,661/- as the same are completely vouched and amenable for complete verification.
The disallowance made at Rs.1,34,23,661/- for 'Raw Material Purchase ( Tax Paid ) was totally unwarranted as complete books of account and vouchers had been produced from time to time during assessment proceedings. The accounting for purchases had been made to suit for the VAT assessment proceedings as detailed here under:
Copy account of Raw Material Purchase (Tax Paid) was filed, page 143 to 149, in the course of assessment proceedings and each and every expense is fully vouched and substantiated and the same are being produced before your honors.
Complete details of imported and indigenous raw material purchases for A.Y. 2012-13 were filed vide reply dated 27.01.2015 copy of reply at page 177 of this paper book, summary annexed at pages!79 - 181, are enclosed along with detailed account of imported and indigenous raw material purchases for A.Y. 2013-
14. The Ld. A.O. failed to appreciate that accounts of the assessee company, which is a public limited company, are subjected to audit both under the Companies Act, 1956 / 2013, as well as, under the Income Tax Act, 1961 under section 44AB which envisages rather mandates expenditure to be accounted for in the books of accounts only for the relevant financial year duly supported by bill /voucher. No adverse comment had been made by the statutory auditors in their independent Auditors Report, nor in the tax audit report. The significant accounting policies and recognition of income and expenditure annexed to the audit report by the auditor specifically mentions that applicable accounting principles applicable in India and accounting standard ITA No.672/LKW/2016 Page 13 of 15 issued by ICAI and relevant provisions of the Companies Act, 1956 have been followed and all revenues, expenses, assets and liabilities have been accounted for on accrual basis. Since there was no adverse comment of the auditor, observation of the Ld. A.O. that the expenditure would have been charged to revenue in A.Y. 2012-13 is highly inappropriate and based on guess work.
On the date of hearing on 10.03.2016, on being directed to produce the supporting bills for verification from the ledger account, it was urged by the counsel that the supporting bills / vouchers of the Raw Material Purchase (Tax Paid ) A/c. could be produced at a short adjournment in the next week, as certain bills were at the Sitarganj, Uttranchal factory, but the Ld. AO passed the order in haste, although the case was to get time barred on 31.03.2016, without calling for the required details, without affording reasonable opportunity, and passed a hasty order, disallowing the entire expenditure, which is not only highly unjustified, but also against the principles of natural justice and equity.
Detailed account stating the date of raw material purchase, mode of payment cash / cheque through journal, name of party, nature of expenditure, bill no, bill date, etc. are being filed before your honors to justify the claim at pages 134 - 142 of this paper book. All supporting bills vouchers can be produced before you honor, on demand, to justify the claim. The trading results of the appellant company were accepted by the Ld. A.O. Looking to the facts and circumstances of the case, the disallowance being made on presumption, surmise and on suspicion, the disallowance by Ld. AO having been made which is arbitrary, unjustified and against the principles of the natural justice and equity, deserves to be deleted.
12. The ld. CIT(A) after considering the written submissions and the assessment order, held as under:-
5(4) I have examined the facts and circumstances of the case. I have considered the findings of the Assessing Officer and the ITA No.672/LKW/2016 Page 14 of 15 submissions of the appellant. I have also considered the remand report and the comments of the appellant thereon. I find that in the profit and loss account for the financial year ending on 31.03.2013 the purchases have been shown at Rs.92,11,54,362/-
in note-19 of the audited profit and loss account. The breakup of the same is submitted as under:-
As per Purchase Register (to avail Cenvat Credit ) Rs. 88,75,69,874/-
Freight Rs.1,02,95,968/-
Imported Raw Material Rs.98,64,859/-
Raw Material Purchase (Tax Paid ) Rs.1,34,23,661/-
Total Rs.92,11,54,362/-
5(5) The purchase tax paid by the appellant for Rs.1,34,23,661/- is therefore duly accounted for in the books of accounts which have been audited and produced before the AO, who has not found any discrepancy therein. The complete ledger for the purchase tax paid was filed before the AO. The appellant is dealing in Excisable goods and excise returns were filed before the AO. RG registers are maintained and therefore entire purchases are duly recorded. The expenditure has been claimed on the basis of payment the voucher of which are maintained and duly recorded in the books of accounts. The AO has not rejected the books of accounts as discussed in detail above and therefore the books of accounts are correct and complete. Under the circumstances, disallowance of Raw Material Purchase (Tax Paid) of Rs.1,34,23,661/- is not sustainable and is deleted giving relief to the appellant."
13. We have perused the case records, analysed the facts & circumstances of the case and we find from the profit & loss account for the financial year ending on 31/3/2013 that the purchases have been shown at Rs.92,11,54,362/- in Note-19 of the audited profit & loss account. In the breakup given, the raw material purchase (tax paid) is at Rs.1,34,23,661/-. The purchase (tax paid) by the assessee was, therefore, duly accounted for in the books of account, which have been ITA No.672/LKW/2016 Page 15 of 15 audited and produced before the Assessing Officer and the Assessing Officer has not found any discrepancy therein. We also observe that complete ledger for the purchase tax paid was filed before the Assessing Officer. The assessee is dealing in excisable goods and excise returns were also filed before the Assessing Officer. RG registers are maintained and, therefore, the entire purchases are duly recorded. The expenses are claimed on the basis of payment, the voucher of which are maintained and duly recorded in the books of account. The Assessing Officer has not rejected the books of account and the ld. CIT(A) provided relief after examining and analyzing these facts. We do not find any infirmity in the order of the ld. CIT(A) on this issue. We, therefore, sustain the relief granted by the ld. CIT(A) to the assessee on this issue. Accordingly ground No.2 raised by the Revenue is also dismissed.
14. In the result, appeal of the Revenue is dismissed.
Order pronounced in the open Court on 13/02/2018.
Sd/- Sd/-
[PARTHA SARATHI CHAUDHURY] [T.S. KAPOOR]
JUDICIAL MEMBER ACCOUNTANT MEMBER
DATED:13th February, 2018
JJ:0702
Copy forwarded to:
1. Appellant
2. Respondent
3. CIT(A)
4. CIT
5. DR