Income Tax Appellate Tribunal - Chandigarh
City Clinic (P) Ltd., Chandigarh vs Assessee on 15 May, 2013
IN THE INCOME TAX APPELLATE TRIBUNAL
CHANDIGARH BENCHES 'A'CHANDIGARH
B E F O R E S H R I T . R . S O O D , AC C O U NT A N T M E M B E R
A N D M S S U S H M A C H OW LA , J U D IC IA L M E M B E R
I T A N o . 11 5 7 / Ch d / 2 0 1 2
A s s e s s m e n t Y e a r : 2 00 9 - 1 0
A C IT , V M / s C i t yC l i n i c (P ) Lt d . ,
Circle 4(1), S C O 4 7 - 49 ,
C h a n d i ga r h . Sector 34-A,
C h a n d i ga r h .
P A N N o . A A B C C - 78 0 0 N
&
C O N o . 5 0/ C h d / 2 012
In IT A 1 1 5 7 / C h d / 2 01 2
M / s C i t y C l i n i c (P ) Lt d . , V A C IT ,
S C O 4 7 - 49 , Circle 4(1),
Sector 34-A, C h a n d i ga r h .
C h a n d i ga r h .
(Appellant) (Respondent)
D e p a r t m e n t b y: S h r i J . S . N a ga r
A s s e s s e e B y : S h r i P a r i k s hi t A gga r w a l
Date of Hearing : 15.05.2013
D a t e o f P r o n o u n c e m e n t : 2 2. 0 5 . 2 0 13
ORDER
PE R S U S H M A C H O W L A , J M T h e r e v e n u e h a s f i l e d t h e a p p e a l a ga i n s t t h e o r d e r o f C IT ( A ) , d a t e d 1 4 . 0 8 . 2 0 12 r e l a t i n g t o a s s e s s m e n t ye a r 2 0 0 9 - 1 0 a ga i n s t t h e o r d e r p a s s e d u n d e r s e c t i o n 1 4 3 ( 3) / 1 4 7 o f t h e I. T . A c t , 1 9 6 1 a n d t h e a s s es s e e h a s f i l e d C . O . a ga i n s t t h e a pp e a l o f t h e r e v e n u e .
2. T h e r e v e n u e h a s r a i s e d f o l l o wi n g G r o u n d s o f A p p e a l :
1. On the facts and circumstances of the case and in law, the ld. CIT(A) has erred in allowing appeal of the assessee without appreciating the facts of the case.2
2. On the facts and in the circumstances of the case and, in law the Ld. CIT(A) has erred in deleting the addition of Rs.6,76,000/- made by the Assessing Officer u/s 36(l)(iii) of the Income-tax Act, 1961
3. On the facts and in the circumstances of the case and, in law the Ld. CIT(A) has erred in deleting the addition of Rs. 16,04,409/- made by the Assessing Officer on account of Bad Debts written off.
4. On the facts and in the circumstances of the case and, in law the Ld. CIT(A) has erred in deleting the addition of Rs.37,57,930/- made by the Assessing Officer by treating 'Repair & Maintenance' expenditure as 'Capital Expenditure'
5. It is prayed that the order of the Ld. CIT (A) be set aside and that of the Assessing Officer may be restored.
6. The appellant craves leave to add or amend any grounds of appeal before the appeal is heard or is disposed off.
3. In C . O . , t h e a s s e s s ee h a s r a i s e d t h e f ol l o w i n g gr o u n d s :
1. On the facts and in the circumstances of the case and in law, the Worthy CIT(A) in Appeal No. 699/11-12 dated 20.01.2012 has erred in passing that order n contravention of the provisions of Section 250(6) of the Income Tax Act, 1961, to the extent of not allowing the ground no. 5 raised before him.
2. That the Worthy CIT(A) has erred in not allowing the ground that the Ld. AO has erred in making addition of Rs. 5,46,000/- by erroneously invoking the provisions of Sec 36(l)(iii) of the Act even when the said addition is against the facts, circumstances and legal position of the case.
3. That the respondent does not agree with the grounds of appeal raised by the appellant and the order of Worthy CIT(A), in relation thereto, may be sustained.
4. That the respondent craves leave for any addition, deletion or amendment in the grounds of cross-objections on or before the same is heard or disposed off.
4. B o t h t h e a p p e a l o f t h e r e v e n u e a n d C .O . f i l e d b y t h e a s s e s s e e w e r e h e a r d t o ge t h e r a n d a r e b e i n g d i s p o s e d o f b y t h e c o n s o l i d a t e d o r d e r . I T A 1 1 5 7/ C h d / 20 12
5. Ground No.1 raised by the revenue is general in nature and hence the s a m e i s di s m i s s e d .
6. G r o u n d N o . 2 r a i s e d b y t h e r e v e n u e i s a ga i n s t t h e d e l et i o n o f a d d i t i o n o f R s . 6, 7 6 , 0 00 / - . H o w e v e r , f r o m t h e p e r u s a l o f t h e a pp e l l a t e o r d e r , w e f i n d t h at t h e A O ha d d i s a l l o w e d R s . 6, 7 6 , 0 0 0/ - u / s 3 6 ( 1 )( i i i ) o f t h e A c t . T h e a s s e s s e e a c c e p t e d t h e a d d i t i o n of R s . 1 , 3 0 , 00 0 / - a nd o n l y a p p e a l e d a ga i n s t t h e a d d i t i o n o f R s . 5 ,4 6 , 0 0 0/ - . T h e C IT ( A p p e a l s ) v i d e p a r a 6 t o 6 .3 3 h a d c o n f i r m e d t h e a d d i t i o n o f R s . 5 ,4 6 , 00 0 / - a ga i n s t w h i c h t h e a s s e s s e e h a s f i l e d C . O . In t h e e n t i r e t y o f t h e a b o v es a i d f a c t s a n d c i r c um s t a n c e s , gr o u n d No.2 raised by the revenue is infructuous. Ground No.2 raised by the r e v e n u e i s , t h us , di s m i s s e d .
7. The issue in Ground No.3 raised by the revenue is against the deletion of addition of Rs.16,04,409/- on account of bad debts written off.
8. The brief facts relating to the issue are that the assessee, during the year under consideration, had debited a sum of Rs.16,04,409/- on account of bad debts written off. The AO during the course of assessment proceedings, show caused the assessee to explain the same with documentary evidence in support of the efforts made to recover the said bad debts. The assessee explained that despite best of its efforts, it could not recover the amount from Ex-Serviceman Health Scheme ( in short ECHS ) in respect of certain patients, till the end of the year and the same were written off as bad debts. The AO noted that the assessee had furnished list of bad and doubtful debts written off to the tune of Rs.13,40,452/-, without any documentary evidence. Reliance was placed on the ratio laid down in South India Surgical Company Ltd. V ACIT 287 ITR 62 (Mad), Dhall Enterprises & Engineers (P) Ltd. V CIT 295 ITR 481 (Guj), the Hon'ble Court held that the assessee was suppl ying goods to Govt. Departments and in lieu non payment due to paucit y of allocated budget, do not amount to bad debts. The AO held, "In this view, it is clear that the Govt. account can not be treated as bad debt. So the claim of the assessee bad debt written off in respect of ECHS is not tenable and is rejected." The AO, accordingl y, disallowed bad debts and made an addition of Rs.16,04,409/-.
9. Before the CIT(Appeals), the assessee furnished complete details in respect of bad debts by way of written submissions which are incorporated in para 7.2 at pages 7 to 9 of the appellate order. The repl y of the assessee was 4 forwarded to the AO, who in turn submitted his report which is reproduced under para 7.2.1 at page 9 of the appellate order. The repl y of the assessee in rejoinder is reproduced in para 7.2.2 at page 10 of the appellate order. Further plea of the assessee was that out of the said bad debts written off during the year under consideration, sum of Rs.519,544/- was recovered in the financial year 2010-2011 which had been offered to tax u/s 41 of the IT Act. The CIT(Appeals) vide para 7.3 held as under :
"7.3 I have considered the submission of the Ld. Counsel, the report of the Assessing Officer and the appellant's reply on the report. It is seen that the bad debts written off basically pertain to claims filed with ECHS. According to the Assessing Officer, the claims were probably rejected by ECHS authorities by raising objections regarding authenticity of claims. As per the report of the Assessing Officer, no efforts were made by the appellant to recover the amount and the appellant had not taken recourse to all possible legal means. The view of the Assessing Officer that all possible steps had not been taken to recover the amount is not correct because the appellant has been able to recover a substantial amount of Rs. 5,19,544/- in F.Y. 2010-11, which was offered as income u/s 41 of the Act. Moreover, the Assessing Officer cannot question the authenticity of the claims made to ECHS in the absence of any evidence to this effect. If the Assessing Officer felt that the claims made to ECHS were not genuine, he should have made enquiries in this regard. In my considered view, on the facts and circumstances of the appellant's case, the claim made on account of bad debts written off is correct and is to be allowed. The addition made on this account is accordingly deleted. Ground of appeal No.6 is allowed."
10. Revenue is in appeal against the said order of the CIT(Appeals). The Ld. DR for the revenue stated that the said amount was due from the Government Body and there is no question of any bad debts in respect thereof. The ld. AR for the assessee, however, pointed out that it is not the case where the recovery could not be made from ECHS but it is a case where the expenditure incurred on patients covered by ECHS have been rejected by ECHS. The ld. AR for the assessee drew our attention to the bill of patient 5 No.1 of Rs.519,544/- placed at page 240 of the Paper Book. Our attention was further drawn to the rejection letter placed at pages 57 & 58 of the Paper Book. It was further pointed out by ld. AR for the assessee that the said amount was recovered in the later years and the same was offered to tax. In respect of the second claim of bad debt written off of Rs.660,067/- it was pointed out that the said claim, till date has not been settled and the amount has not been recovered despite best efforts by the assessee. Our attention was drawn to series of correspondence between the assessee and ECHS with regard to the recovery of the said amount placed at pages 65-68 of the Paper Book and other documents. The balance expenditure of Rs.4,24,798/- was claimed to be bad debt on account of pett y amounts not received from ECHS against bills of various patients.
11. We have heard the rival contentions and perused the record. The issue arising vide ground No.3 is in relation to the claim of bad debts written off. The expenditure of Rs.16,04,409/- comprised of bad debt of Rs.519,544/- of the patient Nachattar Singh and Rs.660,067/- of the patient Shri Jagir Singh and other pett y claims of bad debt of Rs.424,798/-. The assessee is running a hospital and it provided medical services to the various patients and the claim was filed with ECHS in respect of such patients who are covered under the scheme of ECHS, which is an association of Ex-Serviceman Employees (Retirees of the Armed Forces), who in turn contribute towards the corpus of the organization. As per the explanation of the assessee, out of this corpus, the association assures free medical facilities to such member employees. The said scheme is also financed by the Govt. of India, but is neither direct Government organization nor Government Guaranted Scheme. However, in respect of Shri Nachattar Singh, the claim was rejected by ECHS, as is evident from the documents placed at pages 57-58 of the Paper Book. However, the said amount was reimbursed to the assessee in financial year 2010-11 which 6 has been offered to tax by the assessee in the said year. The said amount of Rs.519,544/- had been written off as bad debt during the year as all efforts to recover the said amount had failed. In view of the amended provisions of the Act, we find merit in the claim of the assessee in respect of bad debt written off. We are in conformit y with the order of C IT(Appeals) in this regard.
12. The second bad debt of Rs.660,067/- relates to patient Shri Jagir Singh, who in turn is also covered by ECHS. The medical services were rendered by the assessee to the said patient. However, the claim filed with ECHS for recovery of the amounts spent on the said patient was rejected by ECHS and as per the statement of the assessee during the course of hearing the said amount, till date has not been recovered by the assessee from ECHS. In the totalit y of facts and circumstances of the case, we find merit in the claim of the assessee in respect of the said claim of bad debt of Rs.660,067/- which admittedl y has been written off by the assessee in its books of account during the year under consideration. We uphold the order of CIT(Appeals) in this regard.
13. The balance claim of bad debt written off relates to petty amounts written off in respect of claims of various patients, not being allowed full y b y ECHS. As per the written submissions filed by the assessee before the CIT(Appeals), the amount ranges between Rs.136/- to Rs.27,829/- patient- wise, which as per the assessee have been written off in its books of account. The write off of the bad debts is an accepted position and in view of the amended provisions of section 36(1)(vii) read with section 36(2) of the Act, where certain amount has been declared as income of the assessee in the year itself or in any earlier years and where the recovery of the said amount has become bad, then said amount once written off as irrecoverable in the books of account is to be allowed as deduction on account of bad debt written off u/s 36(1)(vii) sub-section 36(2) of the Act. Thus, we uphold the order of the 7 CIT(Appeals) in allowing the claim of the assessee at Rs.424,798/-. The ground No.3 raised by the revenue is dismissed.
14. The issue in ground No.4 raised by the revenue is against the deletion of addition of Rs.33,57,932/- made out of 'repairs and maintenance' holding the same to be capital expenditure. The brief facts relating to the issue are that during the year under consideration, the assessee had debited a sum of Rs.44,21,093/- under the head 'repairs and maintenance' on account of the under mentioned expenditure:
Repair & Maintenance (Cath LAB) 560092.00
Repair & Maintenance (AC Plant) 634518.00
Repair & Maintenance (Medical Equipment) 763565.00
Repair & Maintenance (Building) 1415013.00
Repair & Maintenance (Gas Plant) 1047905.00
Total 4421093.00
15. The AO observed that, 'A bare perusal of the same shows that the above expenditure are not Revenue in nature but are Capital Expenditure. The huge expenses on this shows that these Repair and Maintenance expenses are increasing value of assets, so in this reference this expenses can not be Revenue Expenses. Since, these are Capital in nature the same is not allowed as revenue expenditure and depreciation @ 15 % at Rs 6,63,163/- on this amount of Rs. 44,21,093/- is allowed and the balance amount of Rs. 37,57,930/- will be added to the income of the assessee being of capital expenditure".
16. Before CIT(Appeals), the assessee vide its written submissions, furnished complete break-up of the repair and maintenance expenditure booked by it under different heads which is reproduced under para 8.2 at pages 11 to 14 of the appellate order. The AO in his remand report observed that the stand of the assessee that major part of the expenditure was Annual Maintenance Contract (AMC charges) seemed to be an after thought as the assessee had not 8 furnished the relevant documents during assessment proceedings. The assessee in rejoinder pointed out that the findings of the AO were incorrect as during the assessment proceedings, assessee was not confronted with the adverse opinion that the expenses in question were capital in nature. Further, it was stressed by the assessee before the C IT(Appeals) that complete records and vouchers of AMC charges were produced before the AO during the assessment proceedings. The CIT(Appeals) took note of the fact that the AO had not confronted the assessee with his proposal to disallow the expenditure as capital expenditure. The claim of the assessee was allowed by the CIT(Appeals) as major part of the impugned expenditure was on account of annual maintenance contracts and the balance expenditure is backed by vouchers. Expenditure being on account of repair and maintenance was held to be revenue in nature by the CIT(Appeals).
17. The revenue is in appeal against the said order of the CIT(Appeals) and has raised ground No.4 in this regard. The Ld. DR for the revenue placed reliance on the order of the AO. The Ld. AR for the assessee placed reliance on the summary of expenses claimed under the head 'repair and maintenance' placed at page 71A of the Paper Book and also referred to the copies of various bills placed in the Paper Book in respect of the relevant invoices raised in relation to the repair and maintenance expenditure.
18. We have heard the rival contentions and perused the record. The assessee during the year under consideration had booked expenditure of Rs.44,21,093/-. The head-wise details of repair and maintenance expenditure were as under :
Repair & Maintenance (Cath LAB) 560092.00
Repair & Maintenance (AC Plant) 634518.00
Repair & Maintenance (Medical Equipment) 763565.00
Repair & Maintenance (Building) 1415013.00
Repair & Maintenance (Gas Plant) 1047905.00
Total 4421093.00
9
19. The perusal of the tabulated details at page 71A of the Paper Book reflects that out of the total expenditure incurred by the assessee under various sub-heads on account of repair and maintenance, certain expenditure was on account of AMC charges paid and the balance was on account of various expenditures incurred by the assessee under various sub-heads. Now, coming to the expenditure booked by the assessee head-wise, it transpires that the assessee has booked a sum of Rs.560,092/- on account of repair and maintenance of cathlab, out of which the AMC charges were to the tune of Rs.420,367/- and in the balance expenditure booked was replacement of motor-drive of Rs.139,725/-. The assessee has placed on record the bill in respect thereof at page 73 of the Paper Book. The AMC charges being expenditure incurred for the upkeep of the equipment which as per the assessee WDV was Rs.82.35 crores, merits to be allowed at the outset. Further, the perusal of the bill placed at page 73 of the Paper Book in relation to replacement of motor-drive totals to Rs.139,725/- and the perusal of the same reflects it to be an expenditure on repairs and maintenance which is revenue in nature. Thus, we hold that the said expenditure is allowable as revenue expenditure in the hands of the assessee totaling Rs.560,092/-.
20. The next sub-head of expenditure is repairs and maintenance of AC Plant totaling Rs.634,518/-, out of which AMC charges totaling Rs.218,784/- and the balance expenditure is on account of repair and overhauling of cooling, oil and motors of AHUs amounting to Rs.209,570/- and welding, re-installation of AHUs totaling Rs.201,954/- in turn totaling Rs.411,524/-. The copies of the relevant bills are placed at pages 85 and 87 of the Paper Book. A perusal of the said bills reflects the nature of the expenditure to be in relation to repair and maintenance and not for purchase of any new asset. The AMC charges, as held in para above, are to be allowed as repair and maintenance expenditure. 10 Accordingl y, the expenditure totaling Rs.634,518/- is to be allowed as revenue expenditure in the hands of the assessee.
21. The next sub-head is repair and maintenance of medical equipment, totaling Rs.763,565/- which included AMC charges of Rs.122,616/-, which are to be allowed as revenue expenditure in the hands of the assessee. Further, the assessee had purchased electro lifting five sectional operation theatre table for Rs.119,350/- which is capital asset purchased by the assessee. Hence the said expenditure is capital in nature and is not to be allowed as deduction. The assessee had further incurred expenditure of Rs.2,00,000/- on repair and upgradation of X-ray machine geometer and bill in respect thereof is placed at page 97 of the Paper Book. The expenditure being for the purpose of repair and maintenance is to be allowed as revenue expenditure. Further, the assessee has booked pett y expenses totaling Rs.321,599/- under the said head which are day-today expenditure of repair and maintenance incurred by the assessee in the course of running the hospital and the same are to be allowed as revenue expenditure.
22. Further, the assessee has booked expenditure of Rs.14,15,013/- under the head 'repair and maintenance of building' which included expenditure of Rs.67,483/- on purchase of tiles, Rs.5,75,000/- on water-proofing of hospital roof and further pett y expenses of Rs.772,530/- on day-today basis. As pointed out in the paras herein above, the assessee is running hospital and the expenditure is required to be incurred for the maintenance of the said building and the perusal of the details furnished by the assessee reflects the nature of the expenses to be 'repair and maintenance' and consequentl y, the total expenditure incurred on day-today basis totaling Rs.772,530/- merits to be allowed as revenue expenditure. Further, the expenditure on purchase of tiles totaling Rs.67,483/- cannot be held to be capital in nature, keeping in view the hospital building. Further, the expenditure incurred on water-proofing of 11 hospital roof at Rs.5,75,000/- does not bring into existence any asset of enduring nature and consequentl y, the same is to be allowed as an expenditure under the head 'repair and maintenance'.
23. The next item of 'repair and maintenance' was of gas plant totaling Rs.10,47,905/- which included AMC charges of Rs.215,400/- which merits to be allowed in view of our decision in paras herein above. The balance expenditure included repair, maintenance and shifting of gas plant of Rs.3,50,000/- and repair and maintenance and upgradation of gas plant of Rs.3,55,000/-. The total WDV value of the asset is Rs.1,18,519/- as shown b y the assessee in the chart placed at page 71A of the Paper Book. The assessee has placed on record the bills at pages 222 and 223 and in view of the fact that the total WDV of the equipment was Rs.1,18,519/-, the expenditure of Rs.7,05,000/- is held to be capital in nature and the same is not to be allowed as an expenditure. The assessee has further booked pett y expenses of Rs.127,505/- under the head 'repair and maintenance of gas plant which merits to be allowed as revenue expenditure.
24. In view of our decision in paras herein above, out of total expenditure of Rs.44,21,093/-, expenditure of Rs.119,350/- under sub-head 'repair and maintenance of medical equipment' and Rs.7,05,000/- under sub-head 'repair and maintenance of gas plant are held to be capital expenditure and the balance expenditure is held to be revenue in nature. In view thereof, we modify the order of CIT(Appeals) and disallow a sum of Rs.8,24,350/- holding the same to be capital expenditure. However, the AO is directed to allow depreciation @ 15% on the said addition of Rs.8,24,350/- and the balance is to be added as income of the assessee. The balance expenditure is allowed as revenue expenditure. The ground No.4 is, thus, partl y allowed.
12C.O. 50/Chd/112
25. The onl y issue raised in the CO filed by the assessee is against the disallowance u/s 36(1)(iii) of the Act at Rs.546,000/-.
26. The brief facts relating to the issue raised in the CO are that during the course of assessment proceedings, the AO noted that the assessee had paid interest of Rs.1.25 crores on secured/unsecured loans and on the other side, had advanced sum of Rs.95,60,000/- during the year under consideration on which no interest was received. The explanation of the assessee with regard to the aforesaid advances was that a sum of Rs.45,50,000/- was for the plot of land on which the hospital was constructed. In the repl y submitted before the AO, it was claimed by the assessee that the said plot of land was purchased more than 15 years ago in the name of the Directors and the hospital was constructed thereon and the cost of the building was reflected in the fixed assets of the assessee. Further, it was submitted by the assessee that as it was enjoying all the benefits of land and indirectl y owned the land, no interest was charged from the advances and even no rent was charged by the Directors against the said plot of land. In respect of the other two loans of Rs.30 lacs given for the acquisition of Nursing Hospital and Rs.20 lacs to Mrs. Parvinder Kaur, the claim was that the said advance was made for commercial exigency. The AO rejecting the claim of the assessee disallowed interest @ 12% P.A. on such advances. On the advance of Rs.45,50,000/-, interest of Rs.5,46,000/- was disallowed and on the balance advance totaling Rs.50,00,000/- proportionate interest relating to the period of loan totaling Rs.1,30,000/- was disallowed.
27. The assessee did not file any appeal against the said disallowance of Rs.1,30,000/- before CIT(Appeals) and onl y issue raised was against the disallowance of Rs.5,46,000/-. The CIT(Appeals) upheld the said 13 disallowance and the assessee is in appeal against the same by way of the present C.O.
28. The Ld. AR for the assessee pointed out that the said plot of land on which the hospital was constructed and is being run by the assessee, was purchased in the financial year 1992-93 out of its own funds. It was stressed by ld. AR for the assessee that no interest bearing funds were utilized for investment in the plot of land. The allotment of the site for hospital was made in the name of the Directors and hence, the amount was advanced to the said directors in order to avail the benefit of purchasing the said plot of land and building of the hospital was constructed by the assessee from its own funds. It was further stressed by the ld. AR for the assessee that the provisions of proviso to section 36(1)(iii) were introduced w.e.f. 1.4.2004 and were not applicable to the facts of the case. The ld. DR for the revenue placed reliance on the order of the AO in para 4.2 and C IT(Appeals).
29. We have heard rival submissions and have carefull y perused the entire record.
30. The assessee is admittedl y running a hospital and has reflected income from running of the hospital during the year under consideration. The assessee had advanced sum of Rs.45,50,000/- to its directors for investment in the purchase of plot of land. The assessee constructed the building of the hospital on the said site and the said building is reflected in the list of fixed assets of the assessee. The said building of the hospital was constructed more than 15 years ago. The claim of the assessee in this regard was that the said investment was made out of own funds and no part of the funds were utilized for making the said investment in the plot of land. The revenue has failed to controvert the same and in the totalit y of the facts and circumstances of the case, we find no merit in the aforesaid disallowance 14 made u/s 36(1)(iii) of the Act. The assessee company was enjoying the benefits of the said plot of land on which the building was constructed against which no rent or charges were being paid by the assessee to its directors and the investment had been made for the purpose of carrying on the business. We find no merit in disallowing any part of the interest expenditure being relatable to such advances made by the assessee for the purchase of plot of land. Reversing the order of the C IT(Appeals), we delete the addition of Rs.5,46,000/-. The Cross Objections raised by the assessee are, thus, allowed.
31. In the result, appeal of the revenue is partl y allowed and the Cross Objections of the assessee are allowed.
O r d e r P r o n o u n c e d i n t h e O p e n C o u r t on t h i s 2 2 n d d a y o f M a y, 2 0 1 3 .
Sd/- Sd/-
( T.R.SOOD) (S U S H M A CH O W L A )
A C C O U N T A NT M E M B E R J U D I C I A L M E MB E R
Dated : 2 2 n d M a y, 2 0 1 3
Poonam
Copy to:
1. The Appellant
2. The R e s p o n d e nt
3. The C IT
4. The C IT (A )
5. The DR
By Order
Assistant Registrar, ITAT, Chandigarh