Income Tax Appellate Tribunal - Pune
R L Gold Pvt. Ltd.,, Jalgaon vs Deputy Commissioner Of Income-Tax,, on 17 February, 2017
आयकर अपील य अ धकरण "बी" यायपीठ पण
ु े म ।
IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH, PUNE
ी अ नल चतव
ु द
, लेखा सद#य, एवं ी &वकास अव#थी, या यक सद#य के सम( ।
BEFORE SHRI ANIL CHATURVEDI, AM AND SHRI VIKAS AWASTHY, JM
आयकर अपील सं. / ITA No. 1695/PUN/2014
नधा*रण वष* / Assessment Year : 2009-10
The Dy. Commissioner of Income Tax,
Circle - 1, Old Bhikamchand Jain Market,
Jalgaon - 425001 (Maharashtra)
.......अपीलाथ / Appellant
बनाम/Vs.
R.L. Gold Pvt. Ltd.,
169, Balaji Peth,
Jalgaon - 425001
PAN : AABCG5201D
...... यथ / Respondent
आयकर अपील सं. / ITA No. 1702/PUN/2014
नधा*रण वष* / Assessment Year : 2009-10
R.L. Gold Pvt. Ltd.,
169, Balaji Peth, Johari Bazar,
Jalgaon - 425001
PAN : AABCG5201D
.......अपीलाथ / Appellant
बनाम/Vs.
The Dy. Commissioner of Income Tax,
Circle - 1, Income Tax Office, Jalgaon
...... यथ / Respondent
Assessee by : Shri Sunil Pathak
Revenue by : Shri Ajay Dhoke
सन
ु वाई क तार ख / Date of Hearing : 14-02-2017
घोषणा क तार ख / Date of Pronouncement : 17-02-2017
2
ITA Nos. 1695 & 1702/PUN/2014, A.Y. 2009-10
आदे श / ORDER
PER VIKAS AWASTHY, JM :
These cross appeals by the Revenue and the assessee are directed against the order of Commissioner of Income Tax (Appeals)-II, Nashik dated 30-06-2014 for the assessment year 2009-10.
2. The brief facts of the case as emanating from records are: The assessee company is engaged in the business of trading in gold and silver ornaments, as well as sale and purchase of bullion. The assessee company is one of the concerns of Rajmal Lakhichand Group, Jalgaon. The assessee filed its return of income for the assessment year 2009-10 on 01-09-2009 declaring loss of `19,29,942/-. The deemed income of the assessee u/s. 115 JB of the Income Tax Act, 1961 (hereinafter referred to as "the Act") was shown as `1,60,79,481/-. The case of the assessee was selected for scrutiny under CASS and accordingly first notice u/s. 143(2) was served on the assessee on 21-08-2010. During the course of assessment proceedings the Assessing Officer found various defects in the books of the assessee and hence, rejected the books of account. The Assessing Officer invoked the provisions of section 145 to complete the assessment. The Assessing Officer made certain additions/disallowances including addition on account of low Gross Profit `86,14,243/- and disallowance of `41,94,060/- u/s. 40A(2)(b) of the Act.
Aggrieved by the assessment order dated 27-12-2011, the assessee filed appeal before the Commissioner of Income Tax (Appeals) challenging the additions/disallowances made during assessment. The Commissioner of Income Tax (Appeals) vide impugned order restricted the disallowances made u/s. 40A(2)(b) to `14,54,869/- and deleted the 3 ITA Nos. 1695 & 1702/PUN/2014, A.Y. 2009-10 entire addition on account of low Gross Profit. Now, the assessee, as well as the Revenue are in appeal against the findings of Commissioner of Income Tax (Appeals).
3. The Revenue has assailed the order of Commissioner of Income Tax (Appeals) by raising following grounds of appeal :
1. "On the facts and in the circumstances of the case and in law, the Ld. CIT(A)-II, Nashik has erred in deleting the Gross Profit Addition considering that there is no justification for rejection of accounts without appreciating the various defects as pointed out by the Assessing Officer in the Assessment Order.
2. On the facts and in the circumstances of the case and in law, the Ld. CIT(A)-II, Nashik has erred in deleting the additions being diversion of profits on a/c of purchases made from associate concern at a higher rate.
3. On the facts and in the circumstances of the case and in law, the order of the Ld. CIT(A)-II, Nashik be cancelled on the above issues and that of the A.O. be restored."
The assessee in its appeal has assailed addition of `27,39,191/- u/s. 40A(2)(b) of the Act. The assessee has raised as many as 6 grounds, however, all the grounds are in respect of the sole issue relating to addition made u/s. 40A(2)(b) of the Act.
4. Shri Sunil Pathak appearing on behalf of the assessee submitted that the assessee purchased gold ornaments and bullion from its sister concerns. Apart from that the assessee purchased gold ornaments from third parties and bullion from bank at Mumbai. The gold rates in Mumbai market and in the local Jalgaon Market are different. There are various factors for difference in rates, transportation of gold from Mumbai to Jalgaon is one of the key factors for difference in rates between Jalgaon market and Mumbai Market. The ld. AR submitted that the Assessing Officer has made addition u/s. 40A(2)(b) of the Act 4 ITA Nos. 1695 & 1702/PUN/2014, A.Y. 2009-10 by taking average of gold rates in the year. Gold rates fluctuate every day, sometimes there is fluctuation of rates on the same day itself. The ld. AR draws our attention to the instances of purchase of bullion and gold ornaments from sister concerns and other parties. The ld. AR referred to table at pages 156 and 157 of the paper book. The ld. AR contended that the rates of bullion in the Mumbai Market are sometimes more and at times less than the rates in Jalgaon, therefore, there is difference in the rates paid by the assessee to its sister concerns. The assessee made payment for purchase of bullion as per Mumbai rates. Referring to chart at page 156 in respect of purchase of bullion from sister concerns, the ld. AR submitted that a perusal of transactions would show that the assessee has paid excess payment to its sister concerns on five occasion and on one occasion the payment made is less than the market rate in Jalgaon. The ld. AR referred to page 157 of the paper book to show the instances of purchase of gold ornaments from its sister concern. The ld. AR pointed that the payments have been made to its sister concern at the rate prevalent in Jalgaon gold market. The ld. AR submitted that a perusal of transactions would show that the assessee has made payment to its sister concern at rate less than the rate prevalent in the Mumbai gold market. Therefore, it is not a case where the assessee has always made payment to its sister concerns at higher rate. The ld. AR submitted that the Assessing Officer while making disallowance u/s. 40A(2)(b) has erred in averaging gold rates on yearly basis. In first appeal, the Commissioner of Income Tax (Appeals) has observed that the Assessing Officer has committed error in taking the average rate in entire year. The Commissioner of Income Tax (Appeals) has accepted the contention of the assessee that local Jalgaon rates should be applied for comparison in respect of purchase of gold, bullion as well as 5 ITA Nos. 1695 & 1702/PUN/2014, A.Y. 2009-10 ornaments. The Commissioner of Income Tax (Appeals) while restricting the addition has only considered those transactions where the assessee has made payment at the rate higher than the local Jalgaon rates and has ignored the purchase instances where the payments have been made by the assessee at a lower rate. The ld. AR submitted that if aggregate of the payments for purchase of bullion and gold ornaments from its sister concern is considered, it would reveal that the assessee has made payment less than the market rate to its sister concerns.
4.1 The ld. AR further pointed that the similar issue had come up before the Tribunal in the case of assessee's sister concern M/s. Rajmal Lakhichand Vs. JCIT in ITA Nos. 532 & 663/PN/2013 for the assessment year 2009-10 decided on 16-01-2015. The Department had also filed cross appeal in ITA No. 607/PN/2013. The Tribunal held that the method of taking average price of a year is not the correct method to determine the reasonableness of the amount paid for purchasing the bullion from sister concerns. The Tribunal deleted the addition made u/s. 40A(2)(b) of the Act in respect of purchase of bullion from sister concerns/related entities. The ld. AR pointed that the case of the assessee is identical, therefore, the addition made u/s. 40A(2)(b) deserves to be deleted.
4.2 The ld. AR further submitted that the gross profit of the assessee during the period relevant to the assessment year under appeal is much higher than the gross profit in earlier year. The gross profit of the assessee in assessment year 2007-08 was 1.04%, whereas the gross profit in assessment year under appeal is 2.96%. No gross profit addition has been made by the Revenue in the subsequent assessment 6 ITA Nos. 1695 & 1702/PUN/2014, A.Y. 2009-10 years i.e. assessment years 2010-11, 2011-12 and 2012-13. In support of his submissions the ld. AR referred to assessment orders passed u/s. 143(3) of the Act for assessment years 2010-11, 2011-12 and 2012-13 at pages 296 to 347 of the paper book. The ld. AR contended that the assessee is maintaining proper books of account which are duly audited. The assessee is also maintaining stock register. The Assessing Officer without pointing any material defect in the books of the assessee during the assessment proceedings has rejected the books of account in an arbitrary manner. The ld. AR supported the findings of Commissioner of Income Tax (Appeals) in deleting the addition made by Assessing Officer on account of low gross profit.
5. On the other hand Shri Ajay Dhoke representing the Department vehemently supported the assessment order. The Commissioner of Income Tax (Appeals) has erred in holding that the Assessing Officer has not appreciated the nature of assessee's business where prices fluctuate not only daily but even many times during a day. The Assessing Officer while finalizing the assessment has elaborately noted down each and every issue and after recording proper and valid reasons based on substantive evidence has made additions/disallowances. The Assessing Officer after pointing out material defects in para 14 of the assessment order has invoked the provisions of section 145(3) of the Act and rejected the trading results disclosed by the assessee. In view of the defects pointed by the Assessing Officer the book results of the assessee cannot be accepted to be true and correct. Further, the tax effect (notional) involved is more than the prescribed limit. 5.1 During the assessment proceedings the Assessing Officer has observed that there are many inter party transactions within the group 7 ITA Nos. 1695 & 1702/PUN/2014, A.Y. 2009-10 such as purchase, sale as well as payment of interest on loans and charging of interest etc. In the case of purchase of bullion from sister concerns the assessee had paid `1426.83/- per gram as against `1390.04/- per gram to other parties particularly the Bank. Thus, the assessee has paid `36.79/- in excess to the sister concerns. No reasons whatsoever have been given by the assessee for making excess payment to sister concerns for purchase of bullion. The Assessing Officer has rightly made disallowance of `41,94,060/- u/s. 40A(2)(b) of the Act. During the First Appellate Proceedings the assessee had furnished additional evidence in the form of newspaper cuttings. The remand report was sought from the Assessing Officer. The Assessing Officer had objected to furnish of additional evidence. Even after furnishing of additional evidence the assessee could not prove genuineness of the transactions with the sister concerns. The Commissioner of Income Tax (Appeals) has erred in placing reliance on the gold rates mentioned in the newspaper cuttings and restricting the disallowance to `27,39,191/-.
5.2 The ld. DR furnished copies of newspaper articles to show how gold prices are determined in Indian Market and the instances of gold rates (bullion) on specified days when the assessee had made certain transactions for purchase of bullion from its sister concerns. The ld. DR pointed that a perusal of the rates furnished by him and when compared with the rates given by assessee would reveal that the rates given by the assessee are higher. The ld. DR raised suspicion over the gold rates furnished by the assessee. The ld. DR prayed for reversing the findings of Commissioner of Income Tax (Appeals) on this issue and restoring the order of Assessing Officer.
8
ITA Nos. 1695 & 1702/PUN/2014, A.Y. 2009-10
6. We have heard the submissions made by the representatives of rival sides and have perused the orders of the authorities below. The solitary issue raised by the assessee in its appeal is against sustaining addition to the extent of `27,39,191/- u/s. 40A(2)(b) of the Act, whereas the Department in its appeal has challenged the findings of Commissioner of Income Tax (Appeals) in deleting the gross profit addition and restricting the disallowance made u/s. 40A(2)(b) of the Act. The Department has also assailed the findings of Commissioner of Income Tax (Appeals) in accepting the books of account of the assessee.
7. The first issue raised in the appeal by the Department is with respect to reversing the findings of Assessing Officer rejecting the books of account of the assessee. A perusal of the assessment order shows that the Assessing Officer has pointed following defects in the books of the assessee :
i. "Inclusion of stock claimed to be belonging to associate concern.
ii. Non availability of details of ornament making charges, hence for valuing closing stock, no justification for added manufacturing expenses.
iii. Failure on part of the assessee to prove conclusively the movement of goods from one location to other.
iv. Genuineness of paid labour charges for want of necessary records maintained by concerned labours.
v. Inability of the labours to furnish the details of case wise labour charges received by them.
vi. Non maintenance of record related to purchase of copper / alloy either by assessee or by labours.
vii. Non availability of record related to itemwise, purity wise details of ornaments manufacturing and sold during the year.
viii. Failure on part of the assessee to explain satisfactorily the defects pointed out vide various show cause letters."9
ITA Nos. 1695 & 1702/PUN/2014, A.Y. 2009-10
8. The Commissioner of Income Tax (Appeals) discarded the defects pointed by the Assessing Officer for rejecting the books of account. The assessee is engaged in the business of sale and purchase of gold ornaments and bullion. Keeping in view the nature of business of assessee it would be difficult to maintain stock in respect of each item separately. Undisputedly, the assessee has maintained stock register as per weight. The day-to-day stock register maintained by the assessee is not disputed by the Assessing Officer. The Commissioner of Income Tax (Appeals) has pointed that in the earlier assessment years and the subsequent assessment years no addition has been made in scrutiny assessments, rejecting the books of account, although, the facts in the assessment year under appeal as well as preceding and succeeding assessment years are same. The Commissioner of Income Tax (Appeals) while rejecting the defects has given detailed reasons. The ld. DR has not been able to controvert the detailed reasoned findings of Commissioner of Income Tax (Appeals) in deleting the addition of `86,14243/-. We concur with the findings of Commissioner of Income Tax (Appeals) on this issue. The defects pointed by the Assessing Officer are trivial and some are even non-existent. On account of such inconsequential defects the audited books of the assessee cannot be rejected. We do not find any merit in the ground No. 1 raised by the Department, accordingly the same is dismissed.
9. In ground No. 2, the Department has assailed the findings of Commissioner of Income Tax (Appeals) in deleting the additions made on account of purchases made by assessee from its associate concerns. The assessee has also assailed the order of Commissioner of Income Tax (Appeals) in sustaining the addition to the extent of `27,39,191/- u/s. 40A(2)(b) of the Act. The Assessing Officer had made disallowance 10 ITA Nos. 1695 & 1702/PUN/2014, A.Y. 2009-10 of `41,94,060/- u/s. 40A(2)(b) in respect of gold, ornaments and bullion purchased by the assessee from its sister concerns. In first appeal, the Commissioner of Income Tax (Appeals) restricted the addition to `27,39,191/-. We find that identical issue was raised before the Tribunal in the case of M/s. Rajmal Lakhichand Vs. JCIT in ITA Nos. 532 & 663/PN/2013 for assessment year 2009-10 and in the cross appeal by the Department in ITA No. 607/PN/2013. The Tribunal vide order dated 16-01-2015 deleted the entire addition u/s. 40A(2)(b) of the Act. The relevant extract of the order of Co-ordinate Bench in the said case is reproduced here-in-below :
"8.27 We now deal with the applicability of the provisions of section 40A(2)(b) of the Act. In this case, the assessee has entered into the transactions with the group entities. Hence, prima-facie the proposition are applicable. There is no dispute about this legal position but the core question is whether the assessee has paid excess price than the market rate to the related parties or to the sister concerns for the purchase of the bullion (99.50-standard gold). As per the argument of the Ld. Counsel for the assessee, even if there is a marginal difference in the market price of the Mumbai and the Jalgaon but that prices are covered in the transportation and delivery. The assessee has filed a chart at pages 42 to 55 of paper book No.1 in which assessee has given names of the sister concerns, gold weight, rate paid, total value, sales, Jalgaon rate on the same day and the Mumbai rate. As per the said chart on 09-04-2008 for the standard gold- (99.50), the assessee has paid Rs.12400/10 gms when the Jalgaon rate was Rs.11805/10 gms. Hence, there is a difference of Rs.595/- . So assessee has made excess payment. The assessee has also given examples on 03-05- 208 and 06-05-2008, as per the chart compared to the even local market the assessee has made the payment in excess of the local market rates. Immediately thereafter assessee has given the sample examples on 08-05-2008, 26-05-2008 in respect of the gold purchases from sister concerns R.L. Gold Pvt. Ltd., Rajmal Lakhichand and sons, Rajmal Lakhichand Jewellers Pvt. Ltd., Manraj Jewellers Pvt. Ltd., etc. As per the figures given by the assessee, the assessee has paid the price which is less than the market rate. On the perusal of the said chart, we find that on some occasions, on some dates, there is excess payments and on some dates, there is lesser payment. As per the transactions given in the chart, it is seen that if we consider the total transactions in a year, i.e. purchase of the bullion from 11 ITA Nos. 1695 & 1702/PUN/2014, A.Y. 2009-10 the sister concerns, it is seen that the assessee has paid less amount to the extent of Rs.1,01,14,553/- if we go with the theory of the AO, i.e., comparing the local market rate of Jalgaon and rates declared by the Mumbai Bullion Association. So far as the AO is concerned, he has adopted the short cut method without understanding the trading in the bullion and fluctuations in the market in the prices and worked out the average rate by comparing the same transaction on same dates and accordingly worked out the alleged difference. In our opinion, the approach of the AO is totally erroneous as he has totally discarded the trading in the bullion that takes place. He has also not considered the statement of the assessee that there are variations and fluctuations in the bullion market and even in the intra day transactions rate can be changed and sometimes rates may be stable and rates may swing like a wind.
8.28 When the matter reached before the Ld.CIT(A) though he did not agree with the approach of the AO but he also made the same mistake. He has again gone on the average method adopted by the AO. In this case it is also considered by the assessee that many of the intra entity transactions are not correct or fictitious and that is also clear even from the chart and figures given by the Ld.CIT(A) in his order in respect of the transactions between the assessee and intra group entities. Another aspect to be considered here is that assessee is a very old firm in the gold market but in the preceding two years span the turnover of the assessee has exceeded 11.5 times from 82.55 crores in A.Y. 2007-08 to 955.78 crores in A.Y. 2009- 10. The assessee has given the justification of the same. Fictitious transactions were shown for inflating the turnover of the assessee. The argument of the Ld. Counsel for the assessee is that it was done to facilitate to obtain the finance. It is pertinent to note here that assessee has filed the chart showing the loans availed by the assessee and other group concerns, which is placed at pages 711 to 714 of the paper book. The assessee was enjoying the CC limit of Rs.5.56 crores. At the same time, the other group concerns/sister concerns were enjoying the CC limit of Rs.52.81 crores. The assessee has also filed a letter dated 25-04-2008 of the SBI (page 712 of paper book) in which one of the group concerns M/s. R.L. Gold Pvt. Ltd. has obtained a gold loan under the domestic jewellery industry scheme from the SBI to the extent of 30 kg. It also supports the case of the assessee that with the meager cash credit limit of Rs.5 crore the assessee by no stretch of imagination can reach to the turnover of Rs.955 crore. As per the statistics given by the Ld.CIT(A) in his order, it is seen that there is high frequency of transactions between the assessee and intra group entities. Even in some of the cases bullion is purchased and sold either on the same date 12 ITA Nos. 1695 & 1702/PUN/2014, A.Y. 2009-10 or immediately on the next day. If the assessee has not earned any income, then can it be taxed is another question. For invoking the provisions of section 40A(2)(b) the AO has to establish that the payment made to the related party is not reasonable at all considering the local market conditions. In our opinion both the authorities below have not at all considered the local conditions of the gold market. The method of average price of the year in our opinion is not the correct method to determine the reasonableness of the amount paid for purchasing the bullion from the sister concerns for the reasons narrated herein above that there is variation in the price of the bullion. We also find from the chart filed by the assessee that the assessee has paid lesser price in some cases as compared to the local market and Mumbai market to the sister concerns. But that is not considered by both the authorities below. When the average price method is adopted, then where ever there is a lesser price paid that is also to be considered and not the excess price only. In our opinion, the average price method adopted by both the authorities is totally erroneous considering the market conditions of the bullion.
8.29 xxxxxxxxxx 8.30 xxxxxxxxxx 8.31 xxxxxxxxxx 8.32 We also find that again while making the addition in respect of sale of ornaments to the group concerns/sister concerns, both the authorities below have adopted the comparison formula based on the sale of ornaments to the unrelated parties and sale of ornaments to the related parties. It is stated that if the average price is taken then the assessee has charged Rs.10,350/10 gms on the sale to the sister concerns as against the average price of Rs.13,906/10 gms charged to the third parties/unrelated parties on the sale of gold ornaments. The AO has worked out the difference of Rs.40.96/gm but the Ld.CIT(A) has worked out the difference at Rs.55.60/gm. The Ld.CIT(A) has also observed that unlike section 40A(2)(b) of the I.T. Act, there is no provision even if there is a sale at lower price comparing with the prevailing market prices of the commodity or goods. In our opinion as far as the issue of ornaments is concerned, approach of both the authorities below adopting the average price formula is not correct. As far as the ornaments are concerned, the price may vary from design to design, from item to item, from purity of gold etc. In case of the ornaments normally the sales are made from the 916 tounch (22 karat). The ornaments may be of 18karat, 20 karat and 21 karat also. We cannot take the average price of the ornaments to the entire sale of the year as different factors are also involved as mentioned 13 ITA Nos. 1695 & 1702/PUN/2014, A.Y. 2009-10 above which changes the price of the ornaments. Moreover, there may be variation in the labour charges also. Hence, we do not agree with the average price formula adopted by both the authorities below for making the addition of Rs.12,01,63,323/- on alleged selling of the ornaments to the sister concerns at lower price than the price charged to the unrelated parties.
8.33 xxxxxxxxxx 8.34 xxxxxxxxxx 8.35 In the light of our above discussion, we are of the opinion that approach of both the authorities below is not correct for making high pitch additions in the hands of the assessee by invoking provisions of section 40A(2)(b) and for alleged selling of the ornaments to the related entities at a lower price. As per the financial accounts of the assessee, the GP worked out at 1.13%. The possibility of purchasing the bullion and ornaments from the group entities at a higher price cannot be ruled out even though there is no strict proof against the assessee. Even the exercise done by both the authorities below is not based on any scientific method. We therefore are of the opinion that adoption of GP rate of 1.20% as against 1.13% disclosed by the assessee will meet the ends of justice. We hold and direct accordingly. We accordingly set-aside the order of the Ld.CIT(A) and direct the AO to work out the GP @1.20% on the total sale of Rs.955,78,81,767/- as per audited accounts. After reducing the GP declared by the assessee at Rs.10,79,15,449/-, the balance GP is to be added to the total income of the assessee. This covers the grounds on the addition made by invoking provisions of section 40A(2)(b), i.e. purchase of bullion from the sister concerns/related entities by paying higher price as well as sale of the ornaments at lower price. Accordingly, the relevant grounds taken by the assessee are partly allowed and the grounds of appeal No. 1 and 2 by the Revenue are dismissed."
10. We find that the facts in the case of the assessee are identical. The disallowance u/s. 40A(2)(b) has been made for identical reasons in the case of assessee. Following the order of Co-ordinate Bench we hold that the method of averaging price on yearly basis followed by the authorities below is erroneous. The authorities below have failed to take into consideration the instances where the assessee has made payment to its sister concerns at a price less than the market price. A 14 ITA Nos. 1695 & 1702/PUN/2014, A.Y. 2009-10 perusal of Chart at pages 156 and 157 of the paper book shows that there are several instances where the assessee has made payment for purchase of gold jewellery at a price less than the market rate. Under such circumstances, no addition u/s. 40A(2)(b) is warranted. Accordingly, ground No. 2 raised in the appeal by the Department is dismissed and sole issue raised by the assessee in ground Nos. 1 to 5 of the appeal is allowed.
11. In the result, the appeal of the Revenue is dismissed and the appeal of the assessee is allowed.
Order pronounced on Friday, the 17th day of February, 2017.
Sd/- Sd/-
(अ नल चतुव द / Anil Chaturvedi) ( वकास अव!थी / Vikas Awasthy)
लेखा सद!य / ACCOUNTANT MEMBER #या यक सद!य / JUDICIAL MEMBER
पुणे / Pune; $दनांक / Dated : 17th February, 2017
RK
आदे श क- . त/ल&प अ0े&षत / Copy of the Order forwarded to :
1. अपीलाथ / The Appellant.
2. यथ / The Respondent.
3. आयकर आय' ु त (अपील) / The CIT(A)-II, Nashik
4. आयकर आय' ु त / The CIT-II, Nashik
5. वभागीय त न,ध, आयकर अपील य अ,धकरण, "बी" ब/च, पण ु े / DR, ITAT, "B" Bench, Pune.
6. गाड1 फ़ाइल / Guard File.
//स या पत त // True Copy//
आदे शानुसार / BY ORDER,
सहायक पंजीकार / Assistant Registrar,
आयकर अपील य अ,धकरण, पुणे / ITAT, Pune