Income Tax Appellate Tribunal - Delhi
Acit, New Delhi vs M/S. Poonam Hassija Neha Hassija, New ... on 4 May, 2018
IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCHES: BENCH "F" NEW DELHI
BEFORE SRI R.K.PANDA, ACCOUNTANT MEMBER
AND
SMT. BEENA A PILLAI, JUDICIAL MEMBER
ITA No. 4320/Del/2011
A.Y. 2008-09
ITA No. 5545/Del/2012
A.Y. 2009-10
ITA No. 3429/Del/2014
A.Y. 2010-11
ACIT, Circle-27(1) vs. Poonam Hassija Neha Hassija
Room no.218, D Block 45, Community Centre
Vikas Bhawan Naraina Phase I
New Delhi New Delhi
PAN: AAJFP 3787 C
(Appellant) (Respondent)
Revenue by: Sh.Atiq Ahmad, Sr.D.R.
Assessee by: Sh. M.P.Rastogi, Adv.
Date of hearing: 05.02.2018
Date of Pronouncement: 04.05.2018
ORDER
PER BEENA A PILLAI, JUDICIAL MEMBER
Present appeals have been filed by revenue against order dated 14/07/11, 29/08/12 and 14/03/14 passed by Ld. CIT (A)-24, New Delhi for Assessment Years 2008-09, 2009-10 and 2010-11 respectively on the following grounds of appeal:
ITA no. 4320/Del/2011(A.Y:2008-09) On the facts and circumstances of the case and in law CIT(A) has erred in-
(i) Directing the AO to treat the hiring receipts of Rs. 17,35,852/-
under the head 'income from business or profession' as against 'income from house property'
(ii) Deleting the disallowances amounting to Rs.22,85,644/- made on account of bank charges, hiring charges for generator, maintenance 1 charge, security charges and depreciation.
(iii) Deleting the disallowance of Rs. 44,14,909/- on account of interest paid.
(iv) Deleting the disallowance made on account of salary and staff welfare.
(v) Directing the AO to treat the loan of Rs.2.60 crores as liability of firm, instead of that of the partners and allow interest paid thereon amounting to Rs.33,59,700/- u/s 24 of the Act.
(vi) Deleting the addition of Rs.1,92,670/- made on account of difference in cost construction.
(vii) Directing the AO to allow depreciation of Rs.14,97,977/- instead of Rs.9,51,526/- which is actually allowable.
The appellant craves the right to add, alter or amend any other ground(s) of appeal.
ITA no. 5545/Del/2012 (A.Y.:2009-10) On the facts and circumstances of the case and in law CIT(A) has erred in-
(i) Directing the AO to treat the hiring receipts of Rs. 88,94,880/-
under the head 'income from business or profession' as against 'income from house property'.
(ii) Deleting the disallowances amounting to Rs.22,20,000/- made on account of bank charges, hiring charges for generator, maintenance charge, security charges and depreciation.
(iii) Deleting the disallowance of Rs. 35,30,299/- on account of interest paid.
(iv) Deleting the disallowance made on account of salary of Rs.9,48,000/-.
(v) Directing the AO to treat the loan of Rs.2.60 crores as liability of firm, instead of that of the partners and allow interest paid thereon amounting to Rs.35,30,299/-.
(vi) Directing the AO to allow depreciation of Rs.41,96,294/-.
The appellant craves the right to add, alter or amend any other ground(s) of appeal.
ITA No. 3429/Del/2014(A.Y.: 2010-11):On the facts and circumstances of the case and in law CIT(A) has erred in-
1. Deleting the addition of Rs. 38,49,066/- while accepting the books of account and original profit which was rejected by the AO u/s 145 on the basis of bogus sale purchase.
2. Deleting the addition of Rs. 35,34,826/- being purchase made from related party M/s ishaan Construction which was treated as sham transaction.
3. Deleting the addition of Rs. 13,25,456/- being purchase made from 2 related party M/s Daksh Enterprises which was treated as sham transaction.
4. Directing the AO to treat the hiring receipts of Rs. 1,02,38,400/- as income from business as against income from House Property.
5. Deleting the disallowances of en-block expenses of salaries, hiring charges for generator, maintenance charges, security charges and depreciation.
6. Deleting the disallowance of Rs. 31,32,592/-on account of interest paid.
7. The appellant craves the right to add, alter or amend any other ground(s) of appeal.
2. Ld.AR submits that, issues involved in all three Assessment Years are common. We are therefore disposing of these appeals by way of common order.
3. Brief facts of the case are as under:
For sake of convenience, facts relevant for assessment year 2008- 09 are being considered.
3.1. It was observed by Ld.AO that two ladies namely Smt. Poonam Hassija and Smt. Neha Hassija joined together, to constitute a Partnership firm, in the name and style M/s Poonam Hassija Neha Hassija, (being the assessee before us). Assessee purchased piece of land at D7, Info City, Gurgaon on 22/12/06, for a sum of Rs.1,62,02,000/- and started construction of building, with the intention to let it out on rent. 3.2. Asessee filed its return of income on 11/08/09 declaring total income of Rs.6,630/-. Ld.AO observed that during the year under consideration assessee earned rental income, interest income and also income from business of trading in road safety equipment. Ld.AO observed that during the year, assessee received rent of Rs.82,04,148/- but had offered only Rs.27,26,065/-as income for the year under consideration.3
3.3. A survey was carried out on 12/11/10 as an aid to ongoing scrutiny assessment proceedings for the year under consideration. It was observed by survey team that the property, minus furniture and fixtures have been sold during April 2010, and that no business activity of the firm were carried out at the said address.
3.4. During the assessment proceedings assessee submitted that loan of Rs.2.60 crores was obtained from ICICI bank to finance the project. It was submitted that this loan was provided by the bank subject to the security by including themselves, their respective husbands and the residential property owned by them along with their husband and also a family-owned company namely M/s CBM Industries as co-borrowers.
3.5. Assessee further submitted that on receipt of loan from bank, construction was completed in August,2007 and the firm negotiated with M/s Hughes Systique India Pvt. Ltd. to let out constructed building on rent. At the request of M/s Hughes Systique India Pvt. Ltd., (hereinafter called M/s Hughes Systique) assessee provided air-conditioners, generators, fit outs, furniture and other interior fittings on hire from its own source. Assessee negotiated separate agreement for hiring of equipments with M/s Hughes Systique. Thus assessee entered into an agreement for renting of building admeasuring total area of 10,000 sq.ft. on the 2nd floor and part of basement with M/s Hughes on 07/08/07 for monthly rental of Rs.4 lakhs, and a separate agreement for hiring of equipments, gadgets, furniture and fittings etc. on 08/08/07.
It was submitted that later on M/s Hughes Systique took the balance portion of 2820 sq.ft. from assessee.
43.6. During the course of assessment proceedings Ld.AO concluded that in the partnership deed entered into between the two partners, land at D-7, Info city, Gurgaon and buildings thereon was taken as asset of the firm, but loan of Rs. 2.60 crores taken from ICICI bank for the purposes of construction of building was not taken as the liability of the firm since it was not specifically mentioned in the partnership deed and since it is not only contained in the names of both the ladies but also their respective husbands and the family company as surety. 3.7. Ld.AO also concluded that hiring of furniture, fixtures, interiors, power backup equipments etc. was not separate business venture, but was an integral part of the rental agreement and was supposed to be taxed as 'income from house property' and not under the head 'business income'. 3.8. Ld.AO thus computed income received by letting off of equipments as 'income from house property' and this allowance was made in respect of interest expenditure amounting to Rs.33,59,700/-, depreciation amounting to Rs.20,44,726/-. 3.9. Aggrieved by the order of Ld. AO, assessee preferred appeal before Ld. CIT (A). Ld. CIT (A) deleted all the additions made by Ld. AO and allowed the appeal of assessee.
4. Aggrieved by the order of Ld. CIT (A) revenue is in appeal before us now.
5. Ground No. (i) Ld.Sr.DR placed reliance upon the order passed by Ld.AO. 5.1. Ld. AR submitted that there were separate agreement for letting off of building and furniture fittings, power equipments for which rents were separately received by assessee. The terms and 5 conditions for both agreements were different and were related to subject of agreement. He submitted that Assessing Officer has merely relied on particular Clause, that too in the Preamble of building rental agreement, which talks of renewal and existence of both agreements. Ld.AR submitted that this Clause was specifically inserted to safeguard interest of assessee. Ld.AR placing reliance on Hon'ble Supreme Court in case of Chennai Properties & Investments Ltd. vs. CIT reported in 373 ITR 673 (2015) (SC), submitted that under the Income Tax Act, income from letting out of property is to be taxed under section 22 and income from hire charges of furniture, equipments etc. is to be taxed either under section 28 or under section 56, depending upon the facts but certainly it cannot be section 22. However in a case where there are composite agreement entered into for the purposes of letting of building and furniture equipments then effort would have to be made to segregate the amount allocable to rental of building and for hire charges of furniture, fixtures and fittings etc. In the present case Ld.AO has clubbed together separate agreement to make it a composite agreement. 5.2. We have perused the submissions advanced by both the sides in the light of the records placed before us. 5.3. The lease agreement for renting of building as well as hiring of furniture, fixtures are placed at page 24-75 of paper book. It is observed from the paper book at page 76 the details of lease deed and hiring agreement in respect of the property at D-7, Info city, Gurgaon with M/s Hughes Systique India Pvt.Ltd. which is as under:
6 75.4. It has been submitted by Ld. AR that at the time of finalisation for assessment year under consideration, returns for assessment year 2009-10 and 2010-11were filed by assessee and it was very well within the knowledge of Ld. AO regarding sale of building. It was verifiable that assessee had declared the income derived from lease of building and hiring of equipment separately in those subsequent Assessment Years. It was contended that Assessing Officer was aware of the fact that assessee sold building during Financial Year 2010-11, and declared long term capital gain on it, and that assessee had not sold furniture, ACs, equipments etc., and continued to get hire/service charges for them.
5.5. He placed reliance on observations of Ld.CIT(A), which is as under:
"4.3. I have carefully considered the arguments given by the Assessing Officer as well as the justifications given by the appellant in furtherance of their respective points of views. I have also considered carefully the authorities cited by either party in their favour. I am of the considered opinion that the hire charges of furniture, fixtures, equipments, air conditioning and interior items, which are the subject matter of a separate agreement, cannot be termed mere amenities and cannot, therefore, be subject to tax under the head house property. What goes in favour of the appellant are the facts that in succeeding years also, such hire charges are treated as business income. Moreover, once the property is sold in the F.Y. 2010-11, the appellant continues to recover hire charges and treats the same as business income. I am also of the view that the judgement of the Hon'ble Delhi High Court 8 in the case of K L Puri (HUF) (supra) is squarely applicable to the facts of the case of the appellant. In view of the above and respectfully following the judgement of the Hon'ble Delhi High Court mentioned above, it is hereby held that the hire charges received by the appellant by hiring of equipments, furniture, fixtures, air conditioning and interior items is to be subjected to tax under the head "business income" and correspondingly, all the expenses claimed by the appellant as a consequence, shall be allowed as legitimate expenses, since, all such expenses are fully vouched and the AO has not pointed out any defect in the books of account of the appellant. Accordingly, the appellant gets a relief of Rs. 17,32,852/- (to be taxed as business income) and Rs.22,85,644.12 (as related expenses mentioned in para 2.2 of the assessment order).
5.6. Admittedly in preceding Assessment Year as is observed from assessment order passed for Assessment Year 2007-08 placed at page 77-79 in the paper book-II, Ld.A.O. in reassessment proceedings has not disputed the nature of income earned by assessee. Further at page 80 of paper book -II computation for year ending 31/03/11 has been placed, wherein rent received from hire of equipments have been shown as income from business. Assessee has sold the building during Financial Year 2010-11, but was continuing to receive hire charges from furniture, equipments etc. Thus it is clear that rent received from lease of building was independent of rent received from hire of furniture and fittings. Further on perusal of partnership deed, it is observed that one of the object was to purchase, sell and give on lease properties developed by assessee.9
Considering the totality of facts the intention of assessee was to continue renting furniture and fixtures to lessee, which has been admitted to be income from business in the preceding assessment year by the authorities below.
5.7. Under such circumstances following rule of consistency, we do not find any infirmity in the observations of Ld.CIT(A) in treating the hiring receipt amounting to Rs.17,35,852/-under the head 'income from business'. Accordingly this ground raised by revenue stands dismissed.
6. Ground number (ii) This ground has been raised by revenue in deleting disallowance amounting to Rs. 22,85,644/-being bank charges, hiring charges for generator, maintenance charges, security charges and depreciation.
6.1. Ld. DR submitted that expenses like maintenance charges cannot be relatable to the business carried out by assessee and therefore is not eligible for deduction.
6.2. On the contrary Ld.AR submitted that bank charges, hiring charges, maintenance and security charges are directly linked with the rental activity carried out by assessee. It was submitted that on the equipments, depreciation claimed by assessee has also been disallowed. It has been submitted by Ld. AR that Assessing Officer has not disputed the fact that equipment given on hire by assessee has been purchased on which depreciation has been claimed, except for generator.
6.3. We have perused the submissions advanced by both the sides in the light of the records placed before us.
106.4. While deciding ground number (i) hereinabove, we have already held that the income received by assessee from hiring of equipments has to be treated as 'business income'. It is an admitted fact that except for generator, rest of the equipments have been purchased by assessee and form part of block of assets. Under these circumstances, the depreciation claimed by assessee on these equipments would be allowable. In respect of the other items like maintenance charges, security charges, assessee is already claiming standard deduction u/s 24 at 30% which subsumes all such misc. expenses in so far as the property building is concerned under the head 'income from house property'. We cannot appreciate the fact that these charges could be allocated to the rental income earned by assessee against hire of furniture fittings as all the maintenance charges are borne by the lessee. In so far as bank charges are concerned, ld.A.O. shall verify if it could be attributed to earning of rental income from hiring of furniture fittings. In the event the bank charges could be attributed to earning of rental income from furniture fittings, the same may be allowed as 'business expenditure'. Assessee is directed to provide all details in respect of the same to the satisfaction of Ld.AO for proper verification as per law. 6.5. We, therefore, modify the findings of Ld.CIT(A) regarding claim of expenditure as discussed above.
Accordingly this ground raised by revenue stands partly allowed for statistical purposes.
7. Ground number (iii) This ground has been raised by revenue against deleting the disallowance of Rs.44,14,909/- on account of interest paid.
117.1. Ld. DR placed reliance upon the observations of Ld. AO. 7.2. On the contrary Ld. AR submitted that the interest income has been disallowed on the premise that the rental income earned by assessee would be treated as 'income from other sources'.
7.3. We have perused the submissions advanced by both the sides in the light of the records placed before us. 7.4. It is observed from the records that during the year assessee has paid interest amounting to Rs.70,41,337/-. Assessee had also received interest amounting to Rs.26,26,428/- from certain income that was temporarily advanced to different parties. Ld.AO disallowed the net interest paid which was reflected in the profit and loss account. It has been submitted before the authorities below that interest was payable on the borrowings which was utilised for purchase of land, construction of property and acquisition of furniture, fittings and equipments etc. and accordingly assessee bifurcated sum of Rs.44,14,909/- into two parts being Rs.25,92,505/- being allocable towards the building and accordingly reduced from income from house property and the balance of Rs.18,22,404/- was allocated towards furniture, fixtures, equipment and was reduced from the business income earned from hiring out of such furniture, fixtures etc. Ld.AO disallowed the entire interest income claimed by assessee. Ld.CIT (A) deleted the disallowance made by Ld. AO. In our considered opinion the interest expenditure that is attributable towards the purchase of furniture, fixtures and fittings should be an allowable expenses in the hands of assessee. Assessee is accordingly directed to provide the 12 bifurcation of the interest expenses that is allocable towards the construction of building as well as towards purchase of furniture, fixtures, equipments and fittings. Ld.A.O. shall then consider the claim of assessee as per law.
7.5. Accordingly this ground raised by revenue stands partly allowed for statistical purposes.
8. Ground number (iv) This ground has been raised by revenue against deleting the disallowance made on account of salary and staff welfare. 8.1. Ld. DR placed reliance upon the order of Ld. AO.
8.2. On the contrary Ld.AR placed reliance upon the observations of Ld. CIT (A).
8.3. We have perused the submissions advanced by both the sides in the light of the records placed before us. 8.4. On perusal of the observations by Ld.CIT(A) in conjectures with the records placed before us, we are of the considered opinion that the rental income earned by assessee from hire of furniture, fittings has been allowed to be treated as 'business expenditure', which do not require to engage any employee since all the maintenance of such furniture, fixtures and fittings are being taken care by lessee as per agreements placed in the paper book. Further it is observed that assessee during the year has earned income from house property and rental income from hire of furniture, fixtures being income from business. Assessee is already claiming standard deduction u/s 24 at 30% which subsumes all such misc. expenses in so far as the property building is concerned under the head 'income from house 13 property'. We cannot appreciate the fact that these charges could be allocated to the rental income earned by assessee against hire of furniture fittings as all the maintenance charges are borne by the lessee.
8.5. Accordingly this ground raised by revenue stands allowed.
9. Ground number (v) This ground has been raised by revenue against treating the loan of Rs.2.60 crores as a liability of the firm.
9.1. Ld. DR placed reliance upon order of Ld. AO.
9.2. On the contrary Ld.AR placed reliance upon observations of Ld. CIT (A).
9.3. It is observed that Ld. CIT(A) decided the issue as under:
"4.7. As regards ground no. 5, the AO had disallowed an amount of Rs.33,59,700/- as interest u/s. 24 of the Act, due on the loan of Rs.2.60 crores from ICICI Bank, since she considered this loan as a personal liability of the five co-applicants. Since, it has already been determined in para 4.5 of this order that the loan of Rs.2.60 crores should be considered as a liability of the appellant firm, as it had been accepted as such in the balance sheet for A.Y. 2007- 08, this addition stands automatically deleted."
9.4. From the paper book, it is observed that the loan has been taken by assessee for the purposes of construction which has been admittedly obtained by providing security of family members. Admittedly the entire fund has been utilised for the purposes of construction of building as well as acquiring furniture aid fittings for the purpose of earning rental income and 14 consistently assessee has been reflecting the said loan in the balance sheet in the preceding A.Ys which has not been disputed by revenue. Further, assessee declared in its hands the rental income received from building as 'income from house property' and rent received from hiring of furniture and fittings as 'income from business'.
9.5. We, therefore, do not see any reason to interfere with the observations of Ld.CIT(A). Accordingly this ground raised by revenue stands dismissed.
10. Ground number (vi) This ground has been raised by revenue against disallowance being deleted on account of difference in the cost of construction. Ld.DR submitted that there was a difference in the cost of construction amounting to Rs.1,92,670/- shown by the appellant in the books of accounts and as determined by the DVO. 10.1. On the contrary Ld.AR submitted that reference for valuation of the construction was made to the DVO, Jaipur has estimated the construction cost at Rs.4,44,21,764/- whereas as per the regular books of accounts maintained by assessee value of construction was Rs.4,42,29,094/-. It was submitted that assessee had maintained regular books of accounts of construction of building and has also maintained all the vouchers and bills which were produced before Ld. AO and no fault has been observed by her.
10.2. We have perused the submissions advanced by both the sides in the light of the records placed before us. We agree with the submissions advanced by Ld.AR that Ld. AO has not found any fault in the bills and vouchers produced by assessee in 15 support of the construction cost but has merely relied upon the DVO's report. There has been neither any instance placed on record regarding any infirmity in the books of accounts nor there is any observations regarding the same by her. 10.3. Under such circumstances, we do not find any reason to differ with the observations of Ld. CIT (A) and accordingly the same is upheld.
10.4. Accordingly this ground raised by revenue stands dismissed.
11. Ground number (vii) This ground has been raised by revenue against depreciation being allowed at Rs.14,97,977/-instead of Rs.9,51,526/-. Ld.DR placed reliance upon the order of Ld. AO.
11.1. On the contrary Ld.AR placed reliance upon the orders of Ld. CIT (A).
11.2. We have perused the submissions advanced by both the sides in the light of the records placed before us. It is observed that Ld. CIT (A) granted relief to assessee by observing as under:
"4.10 The next ground of appeal relates to claim of depreciation. The appellant while filing its return of income had wrongly calculated the depreciation on furniture and fixtures at Rs.9,51,526/-. This was, as per the appellant a clerical mistake and the correct figure of depreciation was Rs. 14,97,977/-. This calculation mistake was detected by the appellant during the assessment proceedings and a claim for the same was made before the AO. However, declined to allow the depreciation as per law on the basis of the decision of the Hon'ble Supreme Court in the case of Goetze (India) Ttd. Vs. CIT 284 ITR 323 (SC). However, the appellant claimed that the ratio of this judgement of the Hon'ble Supreme Court did not apply to the appellant for the 16 simple reason that the Apex Court had held in the case of Goetze (supra) that an assessee will have to revise his return to claim a deduction as AO cannot make any adjustment in the return of income under the provisions of the Act. However, the case of the appellant was that it had already made a claim in its return of income, although, the claim was wrongly calculated. It was not as if the appellant had made no claim at all and therefore, was entitled to a deduction only on revision of return. In the case of CIT Vs. Mahalakshmi Textile Mills Ltd. (1967) 66 ITR 710 (SC), the Hon'ble Supreme Court has held that "all questions, whether of law or of facts, which relate to the assessment of the assessee may be raised before the Tribunal. If for reasons recorded by the departmental authorities in respect of a contention raised by the assessee, grant of relief to him on another ground is justified, it would be open to the departmental authorities and the Tribunal, and indeed they would be under a duty, to grant that relief. The right of the assessee to relief is not restricted to the plea raised by him." It is thus, apparent, that the AO is under an obligation to bring the correct amount of income to tax. If, the appellant has made a wrong claim, it is the duty of the Assessing Officer to allow the correct claim as per law as a deduction. The decision of the Hon'ble Supreme Court in the case of Goetze (supra) is not applicable in the case of the appellant since it is not making a new claim but is revising correctly the claim it has already made in the return of income. Therefore, the AO is directed to allow the correct amount of depreciation on furniture and fixtures at Rs.
14,97,977/-)"
11.3. On perusal of the above, we do not find any reason to interfere with the same and accordingly the same is upheld. 11.4. Accordingly this ground raised by revenue stands dismissed.
12. In the result appeal filed by revenue for assessment year 2008-09 stands partly allowed.17
13. Assessment year 2009-10 Both the parties submit that issues are identical and stands squarely covered by the decision taken for assessment year 2008-
09. It has been submitted that issues raised herein are similar to ground nos. (i) (ii) (iii) (iv) and (vii) as raised in Assessment Year 2008-09. Both the parties reiterated identical arguments in respect of the grounds herein.
We have perused the submissions advanced by both the sides in the light of records placed before us.
We observe that since the issues are similar to those raised by Revenue in Assessment Year 2008-09 and that they have been dealt with herein above while deciding grounds for Assessment Year 2008-09, for the sake of brevity the same are not reproduced herein. We refer to submissions advanced by both the sides in respect of the grounds raised herein and rely upon our observations in respect of the relevant grounds for Assessment Year 2008-09.
13.1. Following the observations made out by us for Assessment Year 2008-09 in respect of the relevant grounds, we partly allow the grounds raised by revenue for the Assessment Year under consideration.
13.2. In the result, appeal for A.Y. 2009-10 stands partly allowed.
14. Assessment year 2010-11 Both the parties submitted that ground No. 4, 5, 6 raised in the present appeal by revenue are squarely covered by the grounds 18 raised for assessment year 2008-09 (being ground no.(i) (ii) (iii) &
(iv) and for Assessment Year 2009-10 (being ground No. 1, 2 and
3). Respectfully following the same we partly allow ground No. 6 in the present appeal and dismiss ground No. 4 and 5.
14.1. Insofar as ground No. 1, 2, 3 are concerned, it has been submitted that this issue needs re-verification by Ld. AO as he has not carried out proper verification in respect of the genuineness of the transactions. Ld.AR has not opposed to the submissions by Ld. DR.
14.2. We have perused the relevant materials placed on record as well as observations recorded by the authorities below. We are in agreement with the submissions advanced by both the sides that this issue needs to be revisited by Assessing Officer and a thorough verification is to be conducted in this regard. Assessee is therefore directed to provide all relevant information/produce relevant personnel for purposes of examination in respect of the transactions with Ishan Constructions and Ravinder Nath Dharam, to the satisfaction of Ld. AO. Assessee shall also produce all the relevant companies from home sale and purchase of road safety equipments have been effectuated. In respect of the same assessee is directed to produce all the 19 records/registers/bills and vouchers/Ledger accounts. Assessing officer shall then verify all the materials filed by assessee as per law and establish the genuineness and validity of the transactions in order to arrive at correct decision.
14.3. Accordingly appeal filed by revenue for the relevant assessment year stands partly allowed for statistical purposes.
Order pronounced in the Open Court on 04th May, 2018.
Sd/- Sd/-
(R.K.PANDA) (BEENA A PILLAI)
ACCOUNTANT MEMBER JUDICIAL MEMBER
Dt. 04th May, 2018
*mv
Copy forwarded to: -
1. Appellant
2. Respondent
3. CIT
4. CIT(A)
5. DR, ITAT
- TRUE COPY -
By Order,
ASSISTANT REGISTRAR
ITAT Delhi Benches
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