Income Tax Appellate Tribunal - Panji
The Deputy Commissioner Of Income Tax, ... vs Sh. Lakhwinder Singh,, Gurdaspur on 11 October, 2017
IN THE INCOME TAX APPELLATE TRIBUNAL
AMRITSAR BENCH; AMRITSAR.
BEFORE SH. T. S. KAPOOR, ACCOUNTANT MEMBER
AND SH. N. K. CHOUDHRY, JUDICIAL MEMBER
I.T.A No. 564/(Asr)/2014
Assessment Year: 2007-08
PAN: ACLPS4296F
Sh. Lakhwinder Singh, Vs. Addl. C. I. T.,
1, Tung House, Vill. Tun, Range-IV,
P. O. Hayat Nagar, Gurdaspur. Pathankot.
(Appellant) (Respondent)
I.T.A No. 472/(Asr)/2016
Assessment Year: 2012-13
PAN: ACLPS4296F
Addl. C. I. T., Vs. Sh. Lakhwinder Singh,
Range-IV, 1, Tung House, Vill. Tun,
Pathankot. P. O. Hayat Nagar, Gurdaspur.
(Appellant) (Respondent)
Appellant by : Sh. P. N. Arora (Adv.)
Respondent by: Sh. Rahul Dhawan (D. R.)
Date of Hearing: 16.08.2017
Date of Pronouncement: 11.10.2017
ORDER
PER T. S. KAPOOR (AM):
These are two appeals filed by assessee as well as by revenue against the separate orders of Ld. CIT(A), Amritsar dated 05.02.2014 for Asst. Years: 2007-08 dated 28.06.2016 for Asst. Year: 2012-13. These were heard together and therefore for the sake of convenience, a common and consolidated order is being passed.
2. The grounds of appeal taken by assessee in ITA No. 564 Asr/2014 are reproduced below:
2 ITA No. 564(Asr)/2014 &
ITA No. 472(Asr)/2016 Asstt. Year: 2007-08 & 2012-13 "1. That the order of the Assessing Officer as well as the order of the Ld. CIT (Appeals) are both against the facts of the case and untenable in law.
2. That the Ld. CIT (Appeals) has grossly erred in confirming the order of the Ld. AO without appreciating the facts and applying his mind.
3. That the authorities below did not appreciate that the provisions of section 44AD of the Income-Tax Act, 1961, were not at all applicable to the present facts of the case. The authorities below did not appreciate that the books of accounts were duly maintained in due course of business and were duly audited under section 44 AB of the Income-Tax Act, 1961, and the authorities below have grossly erred in ignoring the books of accounts. The rate of profit as shown should have been accepted.
4. That the Ld AO was not justified in applying rate of 8% on the gross receipts of Rs. 5,93,05,783/- . The Ld. AO has not justified in rejecting the books of accounts where the books of accounts are duly maintained and audited. The Ld. AO had no cogent material for rejecting the books of accounts. The assesse was prevented by reasonable cause for his inability to furnish certain bills because the same having been misplaced. Accordingly the Ld.CIT (Appeals) has grossly erred in confirming the rate of 8% applied by the Ld. AO.
Alternatively the rate is very high and excessive.
5. That the Ld. AO has grossly erred in not allowing the depreciation claim at Rs.5,35,779/-from the estimated profit. The Ld. CIT(Appeals) has failed to appreciate in view of the Board Circular and various judicial pronouncements that depreciation is allowable-even--, after the rejection of books of accounts and estimation of net profit.
6. That the authorities below should have reduced the material supplied by the Government from the total receipts for computing the Net Profit at the applied rates.
7. That the Ld. AO has grossly erred in making the separate addition of Rs.24,13,230/- shown as Miscellaneous Income which comprises of Contract receipts shown as Miscellaneous income due to their exact nature not being known at the time of audit of accounts. No separate addition is possible after rejection of books of accounts. Alternatively, only Net Profit rate should have been applied on this income after rejection of books of accounts.
8. Any other ground of appeal which may be urged at the time of hearing of the appeal."
3 ITA No. 564(Asr)/2014 &
ITA No. 472(Asr)/2016 Asstt. Year: 2007-08 & 2012-13 Grounds of appeal taken by revenue in ITA No. 472/Asr/2016 are reproduced below:
"(i) On fact and law the Ld. Commissioner of Income Tax (Appeals)-
II, Amritsar has erred in applying net profit at rate of 8% and further allowing separate deduction of depreciation against net profit 10% (after taking in to the consideration of depreciation) reasonable applied by the AO after rejecting the books of account under section 145(3) on the basis of various cogent and specific reasons.
(ii) The CIT (A) is not right in deleting the above addition which is not as per the settled law including the following judgment of the SC. Kachwala Gems VS JCIT 288 ITR 10 (SC ) as per which it is held that that since cogent reasons were given by the A. O for rejecting the accounts there was no reasons to take a different view. It is well settled that in a best judgment assessment there is always a certain degree of guesswork. No doubt the authorities concerned should try to make an honest and fair estimate of the income even in a best judgment assessment, and should not act totally arbitrarily, but there is necessarily some amount of guesswork involved in a best judgment assessment, and it is the assessee himself who is to blame as he did not submit proper accounts. In our opinion there was no arbitrariness in the present case on the part of the IT authorities. Thus, there is no force in this appeal, and it is dismissed accordingly.
It was held that since cogent reasons had been given by Assessing Office for rejecting the accounts, there was no reason to take a different view.
(iii) On the facts and law, the Ld. Commissioner of Income Tax (Appeals)-II, Amritsar has erred in applying net profit rate of 8% and further allowing separate deduction of depreciation against net profit of 10%(after taking in to consideration of depreciation) reasonable applied by the AO after rejecting the books of account under section 145(3) after pinpointing specific defects in the books of account.
(iv) On the facts and law, the Ld. Commissioner of Income Tax (Appeals)-II, Amritsar has erred in allowing separate deduction of depreciation, when deleted further separate addition(disallowance of interest payment without deduction of tax) by holding that once books of account rejected, there is no scope for further separate disallowance of depreciation.
(v) On the facts and law, the Ld. Commissioner of Income Tax (Appeals)-II, Amritsar has erred in deleting the addition of Rs.3,35,784/- on account of non deduction of TDS on interest paid to M/s Shree Ram Transport Co. Ltd. The Ld. Commissioner of 4 ITA No. 564(Asr)/2014 & ITA No. 472(Asr)/2016 Asstt. Year: 2007-08 & 2012-13 Income Tax (Appeals)-II, Amritsar has not appreciating the order of the A.O. and ignoring the facts of the case.
(vi) On the facts and circumstances of the case, the order of the Learned Commissioner of Income-Tax (Appeals), Amritsar be vacated and that of the Assessing Officer be restored.
(vii) Appellant craves leave to amend or add any or more grounds of appeal."
3. At the outset, the Ld. AR submitted that there is a delay of 122 days in filing the appeal by assessee and which had occurred due to the fact that the order of Ld. CIT(A) was served on peon of the assesses and he forgot to handover the same to assessee. It was submitted that assessee came to know about the dismissal of appeal by Ld. CIT(A) only when the demand notice was served. The Ld. AR submitted that assessee has filed affidavit affirming the above facts and therefore it was prayed that in the interest of substantial justice the delay may be condoned.
4. The Ld. DR had no objection to condonation of delay. Therefore delay was condoned and Ld. AR was directed to proceed with his arguments.
5. The Ld. AR submitted that he will not be pressing ground no. 7 of assessee's appeal therefore ground no. 7 in assessee's appeal be dismissed as not pressed.
As regards the other grounds of appeal, the Ld. AR submitted that Assessing Officer after rejecting the books of accounts of the assessee applied a net profit rate of 8% to the gross receipts for estimation of the income of assessee which is highly excessive and further submitted that 5 ITA No. 564(Asr)/2014 & ITA No. 472(Asr)/2016 Asstt. Year: 2007-08 & 2012-13 in assessee's own case in assessment year 2011-12, the Hon'ble Bench under similar facts and circumstances has reduced the rate of net profit to 6.51% on gross receipts. The Ld. AR submitted that nature of the business of assessee is the same and therefore it was prayed that the net profit rate of 6.51% be applied to the assessee as was applied in the case of assessee himself during assessment year 2011-12.
As regards the disallowance of claim of depreciation the Ld. AR submitted that as per various judicial pronouncements and board circular, the depreciation is allowable even after estimation of net profit and in this respect the Ld. AR again relied on assessee's case in assessment year 2011-12 where the Hon'ble Bench of ITAT vide order dated 19.10.2016 had dismissed the appeal of revenue in which Ld. CIT(A) had allowed claim of depreciation.
6. The Ld. DR on the other hand heavily placed his reliance on the order of authorities below.
As regards the appeal filed by revenue, the Ld. DR submitted that Assessing Officer had rightly applied 10% of rate for estimation of income which the Ld. CIT(A) had wrongly reduced to 8%. The Ld. DR further submitted that the action of Ld. CIT(A) for further giving relief to the assessee on account of depreciation out of estimated profit is also not correct. The Ld. DR further submitted that Ld. CIT(A) has erred in deleting the addition of Rs.3,35,784/- which the Assessing Officer had 6 ITA No. 564(Asr)/2014 & ITA No. 472(Asr)/2016 Asstt. Year: 2007-08 & 2012-13 made on account of non deduction of TDS on interest paid to M/s Shri Ram Transport Co. Ltd.
7. The Ld. AR on the other hand submitted that Hon'ble ITAT in the case of assessee itself in assessment year 2011-12 has applied net profit rate of 6.51% and Ld. CIT(A) has applied 8% of rate of profit which is higher than the rate as upheld by Hon'ble ITAT.
As regards the allowing of depreciation out of estimated income, the Ld. AR submitted that this point of assessee was again covered in favour of assessee by the order of Tribunal in assessment year 2011-12 and moreover CIT(A) had not allowed depreciation and that is why the assessee has taken thier grievance in his grounds of appeal.
As regards non deduction of TDS from interest payment to Shri Ram Transport Co. Ltd., the Ld. AR submitted since the income of the assessee was estimated and therefore no disallowance u/s 40 (a)(ia) was warranted as was held in the case of J.S. Construction in ITA No. 63/Asr/2016 which the Amritsar Bench has followed in the case of assessee itself in Asst. Year: 2010-11.
In view of the above it was submitted that the appeal filed by revenue is liable to be dismissed.
8. We have heard the rival parties and have gone though the material placed on record. We first take up the appeal filed by assessee. We find that books of accounts were rejected and Assessing Officer had applied a 7 ITA No. 564(Asr)/2014 & ITA No. 472(Asr)/2016 Asstt. Year: 2007-08 & 2012-13 net of profit of 10% on gross receipts and which the Ld. CIT(A) has reduced to 8%. We find that in the case of assessee itself in assessment year 2011-12, the rate of NP was accepted at 6.51%. The Hon'ble Tribunal had passed a detailed order in this respect and has held this rate to be applied for estimation the income of assessee. We find that there is no change in the business of the assessee and therefore an application of different rate is not justified. The findings of the Hon'ble Tribunal as contained vide order dated 19.10.2016 are reproduced below:
"14. We have heard the rival contentions in the light of the material placed on record. We find that it is a fact that the assessee did not produce complete vouchers of purchases and labour charges during assessment proceedings and therefore, the action of the AO in rejecting the books of account is justified and the ld. CIT(A) has also upheld the rejection of books of account. Now, after rejection of books of account, the AO is bound to estimate the income of the assessee in a best manner from the available material and keeping in view the past history of the assessee. And from history of other persons engaged in similar trade. It is an undisputed fact that the assessee had declared net profit rate of 5.34% in the assessment year 2009-10, 5.21% in the assessment year 2010-11 and 5.51% in the assessment year under consideration. The net profit rate declared by the assessee is progressive despite of the fact that the turnover of the assessee has also increased. The Hon'ble Punjab & Haryana High Court, in the case of Telelinks vs. CIT, Bathinda, had laid down the following criteria for determination of net income in the cases, where books of account of the assessee are rejected:
1) Past tax history of the assessee
2) Assessment orders passed by and accepted by the
Department.
3) The nature of assessee's business
4) An appraisal of the value of the contract
5) Prevailing economic conditions vis-à-vis the assessee's
business
6) The price of raw-material and labour etc.
8 ITA No. 564(Asr)/2014 &
ITA No. 472(Asr)/2016
Asstt. Year: 2007-08 & 2012-13
7) The rise in price index as notified by the Central Government
from time to time
8. The assessments of other assessees engaged in similar business We find that the past history of the assessee indicates that the assessee had been earning net profit rate in the range of 5.21% to 5.34%, whereas in the present year, the assessee declared net profit rate at 5.51%. Therefore, the present rate of net profit declared by the assessee is in line with the earlier years. We further find that the earlier years returns has been accepted by the department and therefore, there is no reason why the similar rather increased rate of net profit should not have been accepted by the Authorities below, especially keeping in view the fact that the assessee is engaged in same kind of activities as was in the earlier year. The ld. counsel has relied upon a number of case laws noted above in this order, wherein the Tribunal had held the net profit rate of 5% to be reasonable keeping in view the past history of the assessee. For the sake of convenience, the finding of the Tribunal in ITA No.58/Asr/2012 in the case of Mohan Singh Contractor are reproduced below:
"5.1. As regards the estimation of income, the AO has applied Net Profit rate of 8% and has relied upon the decision of the Hon'ble Punjab & Haryana High Court, in the case of CIT, Hissar vs. Prabhat Kumar Contractor, Sirsa, in ITA No.293 of 2008 dated 14.11.2008. The AO has not brought out the facts on record of the case of CIT, Hissar vs. Prabhat Kumar Contractor, Sirsa (supra), as to how the facts in that case are identical to the facts of the present case. The assessee has been declaring Net Profit rate of 3.87% in the preceding year at a turnover of Rs.1,32,26,714/-, which has been accepted by the department There is no dispute to this fact. Keeping in view the past history of the present case of the assessee and facts and circumstances of the present case a Net Profit rate of 5% if applied to the contract receipts declared by the assessee will meet both ends of justice. The AO is directed to act accordingly. The orders of both the authorities below are modified accordingly. Thus, the grounds of the assessee are partly allowed."
15. Similarly, the Tribunal in ITA No.366/Asr/2010, vide order dated 30/04/2012, in the case of Surinder Pal Nayyar Contractors, has held the rate of 5% to be reasonable by holding as under:
"9. We have heard both the parties and perused materials available with us. We have also thoroughly gone through the orders passed by the Revenue authorities on the issue raised by the Department as well as by the assessee. It is a matter of record that the assessee has filed the original return on 30.10.2008 by declaring loss of Rs.4,40,514/- but subsequently the assessee has also filed revised return on 08.12.2008 by declaring loss of Rs.4,17,515/- as mentioned by the AO at page 1. It is also a matter of record that after considering the documentary evidence filed by the assessee as well as reply to the notice dated 28.11.2008, the AO applied provisions of section 145(3) of the Act in the case of the 9 ITA No. 564(Asr)/2014 & ITA No. 472(Asr)/2016 Asstt. Year: 2007-08 & 2012-13 assessee because the assessee has not filed some documentary evidence in original before the AO. Therefore, we are of the opinion that the AO as well as the ld. first appellate authority has rightly applied the provisions of section 145(3) in the case of the assessee. Secondly, as regards the benefit of carried forward losses, keeping in view the revised return filed by the assessee after due date, we are of the view that the assessee is not entitled for any carried forward losses as discussed by the AO and upheld by the ld. first appellate authority. As regards to the application of net profit rate at 5% after allowing depreciation and interest to the partners of assessee's turnover as against 8% applied by the AO, it is a matter of fact that the AO has not given any reasonable explanation while applying 8% net profit rate on the assessee's gross receipts for the assessment year under reference. The income assessed in the assessment year 2001-02 in assessee's case was apparently 3.6% of its net receipts. But in the present assessment year, the AO has pointed out various defects in the assessment order. The Ld. CIT(A) considering all the defects pointed out by the AO and finally, validly and reasonably determined the net profit rate at 5% after allowing depreciation and interest to the partners on the assessee's turnover. Keeping in view the facts and circumstances of the present case, we are of the considered opinion that the ld. first appellate authority has rightly applied net profit rate of 5% after allowing depreciation and interest to the partners on assessee's turn over as against 8% applied by the A.O. We uphold the impugned order by dismissing the appeal filed by the Department as well as C.O. filed by the assessee."
16. The Tribunal vide its order dated 21.01.2016, in ITA No.483/Asr/2013, in the case of Satish Aggarwal & Co., after taking into account the factors noted by the Hon'ble Punjab & Haryana High Court in Telelinks vs. CIT, Bathinda, has also held the rate of 5% to be reasonable, by holding as under:
"12. As demonstrated by learned AR the past and subsequent profit margins remained less than 5% and the activities of the assessee remained same, therefore, we uphold the application of 5% net profit rate."
17. However, it is also a fact that in case of non submission of complete vouchers and purchase invoices to the assessing authority, there is always a chance of understating the profits. The acceptance of profits declared by the assessee at the same figure without verification of purchase invoices and vouchers cannot be equated with a case where complete vouchers and books had been submitted. Though, the assessee in earlier years had declared net profit rate ranging from 5.21% to 5.34% and the department had accepted the same, therefore, it may be a case that in those years, the assessee had filed complete vouchers and purchase invoices. Therefore to equate a person who maintains complete vouches and books of account with a person who does not maintain complete books of account is not justified. There should be some deterrent so as to induce a person to maintain proper books of accounts. In view of 10 ITA No. 564(Asr)/2014 & ITA No. 472(Asr)/2016 Asstt. Year: 2007-08 & 2012-13 the above, we are of the opinion that though keeping in view the past history of the assessee, the rate of net profit rate declared at 5.51% should have been accepted but to create a deterrent to maintain books of accounts, the ld. CIT(A) has rightly applied a higher Net Profit ratio. The ld. CIT(A) has applied 8% rate of net profit, which is quite high when compared to the actual rate of net profit earned by the assessee in the earlier years. The books of accounts of the assessee has been audited u/s 44AB of the Act and it cannot be assumed that the books of accounts were not supported by vouchers. The assessee in this case has produced photocopies of purchase bills and therefore, the ld. CIT(A) has rightly distinguished the case laws relied on by the Assessing Officer. Therefore, keeping in view all facts & circumstances and keeping in view a balanced view, we deem it appropriate that a 1% higher rate of net profit would have served the ends of justice. In view of the above, we direct the AO to calculate the profits of the assessee by applying net profit rate of 6.51% on the gross receipts."
In view of the above we direct the Assessing Officer to apply a rate of 6.51% for estimation the income of assessee. In view of the above ground no. 1 to 4 are partly allowed.
As regards the ground no. 5 regarding claim of depreciation against the estimated income we find that this issue is also covered in favour of assessee by the order of Tribunal in the case of assessee itself wherein the Hon'ble Tribunal vide its order dated 19.10.2016 had held as under:
"18. As regards the grievance of the Revenue that the depreciation should not have been allowed, we find that the department vide Circular No. 29D, dated 31.08.1965 (placed at APB 34) has directed that where the books of the account are rejected and profits are estimated, depreciation allowance should be given. For the sake of convenience, para-2 of said Circular is reproduced as under:
"2. The Board consider that where it is proposed to estimate the profit and the prescribed particulars have been furnished by the assessee, the depreciation allowance should be separately worked out. In all such cases the gross profit should be estimated and the deductions and allowances including the depreciation allowance should be separately deducted from the gross profit. If it is considered that the net profit should be estimated it should be 11 ITA No. 564(Asr)/2014 & ITA No. 472(Asr)/2016 Asstt. Year: 2007-08 & 2012-13 estimated subject to the allowance for depreciation and the depreciation allowance should be deducted therefrom."
19. We further find that the Hon'ble Punjab & Haryana High Court in the case of Lali Construction Co. (supra) has held that where the assessee gives information required under section 32 of the Act regarding claim of depreciation, the AO is bound to allow the claim of depreciation. The findings of the Hon'ble Court are reproduced below:
"Taking up the first point, the matter is no longer res integra. The Division Benches of this Court in Commissioner of Income Tax v. Chopra Bros. India (P) Limited (2001) 252 ITR 412 and Girdhari Lal v. Commissioner of Income Tax(2002) 256 ITR 318 while considering the aforesaid issue, in view of the circular issued by the Board, had held in a case where the assessee makes a specific claim for depreciation and gives the information as required u/s 32 of the Act, the Assessing Officer is bound to take the claim of the assessee into consideration. Following the aforesaid judgments, it is held that the assessee is entitled to deduction on account of depreciation from receipts while applying net profit rate on the gross receipts."
In view of the above, the ld. CIT(A) has rightly allowed the claim of depreciation out of net profit worked out by applying net profit rate." Therefore following the above we allow ground no. 5 of assessee's appeal and ground no. 7 has already been withdrawn by assessee and therefore the same is dismissed as not pressed. In view of the above the appeal filed by assessee is partly allowed.
Now coming to the appeal filed by revenue, we find that the grievance of revenue is reduction of application of net profit rate from 10% to 8% whereas we find that during assessment year 2011-12 in the case of assessee himself, the Hon'ble Tribunal vide order dated 19.10.2016 had reduced the net profit rate from 8% to 6.51%. The said order of the Tribunal has already been reproduced in the present order and therefore the grievance of revenue in reducing net profit rate from 12 ITA No. 564(Asr)/2014 & ITA No. 472(Asr)/2016 Asstt. Year: 2007-08 & 2012-13 10% to 8% is not justified and in view of the above ground nos. 1 to 3 are dismissed.
As regards allowing of separate deduction of depreciation out of estimated income, we find that this issue is also covered in favour of assessee where the Hon'ble Tribunal in the case of assessee himself vide order dated 19.10.2016 has also upheld that depreciation is to be allowed out estimated income. The relevant finding of the Tribunal has already been reproduced in the case of assessee and moreover Ld. CIT(A) has not allowed this depreciation. Therefore this ground of revenue is misplaced. In view of the above, ground no. 4 is also dismissed.
As regards ground no. 5 we find that this issue is also covered in favour of assessee by the order of Tribunal dated 19.10.2016 wherein the Hon'ble Tribunal had held that once the profits of the assessee has been estimated after rejection of books of accounts, no separate addition was warranted. The findings of the Hon'ble Tribunal are contained in para 24 to 25. For the sake of completeness, the findings of the order of Tribunal are reproduced below:
"24. As regards the disallowance under section 40(a)(ia) of the Act, We find that since the income of the assessee has been worked out on estimation, therefore, no further disallowance was warranted, as held by the ITAT, Amritsar Bench in the case of J.S. Grover Constructions, in ITA No.63/Asr/2016, vide order dated 26.08.2016, as under:
"9.1 In third ground of appeal the department has relied upon the decision of Supreme Court of India in the case of Kachawala Junks vs JCIT reported in 288 ITR 10. A copy of the judgment is placed at Page No. 98 to 100 of the paper-book which supports the case of the assessee rather the case of the department. Thus this ground of appeal may also be dismissed. As far as the fourth ground of 13 ITA No. 564(Asr)/2014 & ITA No. 472(Asr)/2016 Asstt. Year: 2007-08 & 2012-13 appeal is concerned, it is also liable to be rejected once the rate of profit is applied no further disallowance or addition can be made. This view finds support from the following judgments:-
i) Decision of Jharkhand High Court in the case of Amitabh Construction (P) Ltd vs. Addl. CIT reported in 335 ITR 523.
(Refer page no 101 to 104 of paper book).
ii) Decision of Kerala High Court in the case of Samurai Techno Trading Co Ltd vs. CIT reported in 197 Taxman 144. (Refer page no 105 to 109 of paper book)
iii) Decision of Andhra Pradesh High Court in the case of Maddi Sudarsanam Oils Mills vs CIT reported in 37 ITR 369 which was followed in the case of Indwell Constructions vs CIT reported in 232 ITR 776. (Refer page no 110 to 112 of paper book)
iv) Decision of Allahabad High Court in the case of CIT vs. Banwarilal Bansidhar reported in 229 ITR 229 in which it was held no disallowance can be made u/s 40(a)(iii) where GP rate is applied. (Refer page no 113 to 115 of paper book)
v) Decision of ITAT, Amritsar Bench, in the case of Smt. Balbir Kaur vs. ITO in ITA No. 151(ASR)/2016, order dated 23/05/2016 relating to AY 2004-05."
25. Therefore, respectfully following the aforesaid decision of the Tribunal in the case of J.S. Grover Constructions, dated 26.08.2016 (supra), we allow this ground of appeal of the assessee." Therefore following the above judicial precedents ground no. 5 is also rejected and therefore the appeal filed by revenue is dismissed.
9. In nutshell, the appeal filed by assessee is partly allowed whereas the appeal filed by revenue is dismissed.
Order pronounced in the open court on 11.10.2017 Sd/- Sd/-
(N. K. CHOUDHRY) (T. S. KAPOOR)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Dated: 11.10.2017.
/GP/Sr. Ps.
14 ITA No. 564(Asr)/2014 &
ITA No. 472(Asr)/2016
Asstt. Year: 2007-08 & 2012-13
Copy of the order forwarded to:
(1) The Assessee:
(2) The
(3) The CIT(A),
(4) The CIT,
(5) The SR DR, I.T.A.T.,
True copy
By Order