Income Tax Appellate Tribunal - Ahmedabad
Msk Projects (India) Ltd., Baroda vs Assessee on 7 August, 2009
IN THE INCOME_TAX APPELLATE TRIBUNAL "D" BENCH,
AHMEDABAD
BEFORE SHRI D.C.AGRAWAL AND SHRI T.K.SHARMA
ITA No.3518/Ahd/2004
(Assessment Year : 2001-02)
M/s MSK Projects (India) Ltd., Vs. ACIT, Cen.Cir. 1(2)
707-708, Stefling Centre, Ahmedabad.
R.C.Dutt Road,
Baroda.
(Appellant) (Respondent)
ITA No.44/Ahd/2005
(Assessment Year : 2001-02)
ACIT, Cen.Cir. 1(2) Vs. M/s MSK Projects (India) Ltd.,
Ahmedabad. 707-708, Stefling Centre,
R.C.Dutt Road,
Baroda.
(Appellant) (Respondent)
Appellant by : Shri S.N.Soparkar, A.R.with
Ms. Urvashi Shodhan, A.R.
Respondent by : Shri A.K.Saroha, Sr. D.R.
(आदे श)/ORDER
)/
PER AGRAWAL, AM:
These are two appeals - one filed by the assessee and another filed by the Revenue against the order of ld.CIT(A) passed on 29.10.2004.
2. The assessee has raised the following grounds in Its appeal:
1. Ld, CIT(A) has erred in law and on facts in confirming the action of A.O. in incorrectly determining the quantum of deduction us 80IA of the Act. Ld. CIT(A) has further erred in confirming the action of AO in reducing the profits of the project eligible for claiming deduction u/s 80IA of the Act by Rs.40,07,841/- being the interest expenditure when no 2 borrowed funds in respect of the said interest expenditure was utilized for the said project.
2. Alternative and without prejudice, Id. CIT(A) has erred in law and on facts in not appreciating that the appellant was having sufficient interest free funds so as not to call for any such reduction of interest expenditure from the profits of the eligible project.
3. Ld. CIT(A) has erred in law and on facts in confirming the action of AO in disallowing interest of Rs.24,57.083/- by erroneously applying provisions of S. 14A of the Act.
4. The learned CIT( A) has erred in law and on facts in confirming the action of A.O. in disallowing 5% out of the gift articles amounting to Rs.7,467/- and 5% out of the staff welfare expenses.
5. The learned CIT(A) has erred in law and on facts in confirming the action of AO in restricting the claim of depreciation @ 10% as against eligible rate of 25% on the office equipments.
6. The learned CIT(A) has erred in law and on facts in confirming the action of AO in not allowing entire claim of membership and subscription allowable business expenditure.
7. Both the lower authorities have erred in law and on facts in not considering and grossly ignoring various explanations, submissions and evidences placed on record by the appellant in its proper perspective and further erred in not appreciating the view point of the appellant. This action of both the lower authorities is in clear breach of Principles of Natural Justice and therefore deserves to be quashed.
8. Levy of interest u s 234A/B/C of the Act is not justified.
9. Initiation of penalty proceedings u/s 271(1 )(c) of the Act are not justified.
3. As against, the Revenue has raised the following ground in its appeal:
1. The CIT(A) has erred in law and on facts in directing to restrict the addition of 26,83,6187- made on account of 3 disallowance of interest expenses in view of the provisions of section 14A and section 36(l)(iii) of the I.T Act to Rs.
24,57,083/-.
2. The CIT(A) has erred in law and on facts in directing to delete the addition of Rs. 2,07,305/- made on account of disallowance of telephone expenses attributable to personal and non-business use.
3. The CIT(A) has erred in law and on facts in directing to delete the addition of Rs. 10070/- made on account of disallowance of conveyance expenses attributable to personal and non-business use.
4. The CIT(A) has erred in law and on facts in directing to restrict the addition of Rs. 37,776/- made on account of disallowance of depreciation on air conditioner to Rs. 15110/-
5. On the facts and in the circumstances of the case and in law, the CIT(A) ought to have upheld the order of the AO.
6. It is therefore prayed that the order of the CIT(A) be set aside and that of the AO be restored to the above extent.
4. The facts of the case are that the assessee is engaged in the business of construction as well as in the development of Infrastructure Project. The first issue relates to confirming addition of Rs.40,07,841/- on account of interest expenses debited in Construction Division though the funds relating thereto are alleged to be utilized in Infrastructure Division. The issue has been discussed by the Assessing Officer in para 2 to 2.5 of his assessment order and by the ld. CIT(A) in para 2 of her order. The Assessing Officer noted that the assessee has debited a sum of Rs.84.63 lacs as financial charges in the Construction Division whereas an amount of Rs.66.11 lacs of financial charges are debited in the Infrastructure Division. The profits shown in the Infrastructure Division are subject to deduction u/s 80IA of the Act at 100%. Therefore, profits from Infrastructure Division are not taxable. The Assessing Officer noted that, in the Construction Division, balances recoverable from Infrastructure 4 Division for last three years were as under:
"PARTICULARS OF AMOUNT O/S RECEIVABLE FROM INFRASTRUC DIVISION AS RECORDED IN THEBOOKS OF CONSTRUCTION DIVISION"
Year Closing Max. amount o/s Date
balance(Rs.) during the year (Rs.)
31.3.99 66,43,341 66,43,341 31.3.99
31.3.00 2,72, 98,401 5, 02, 72, 572 28.1.00
31.3.01 97,37,524 3,84,81, 967 11.7.00
Thus, during this year maximum amount transferred by Construction Division to Infrastructure Division amounted to Rs.3,84,81,967/-(as on 11.7.2000)whereas the closing balance was Rs.97,37,524/- as on 31.3.2001. The Construction Division has claimed interest in the financial year 1999-2000 and 2000-01 as under:
Interest paid to/on 99-2090 2000-01
Interest on Term Loan for 14 22 119 14 74 668
Ditrchase o1 machine
Overdraft Ac. with bunks 220 567 5,95 520
SDL Interest on FDR(Constn) 5,70,739 11,58,010
Bills/Cheques discounting 1149341 . 2958959
(Constn.) division
MSK Finance 13 404
Bank Charges 5 05 660 8 80 946
Commission on Bank 12 62 771 13 81 522
Guarantee
5
Total 51,31,197 84,62,829
5. After perusing the balance sheet, the Assessing Officer inferred that the assessee has transferred funds from Construction Division to Infrastructure Division and thereby claimed interest in Construction Division and allowed higher deduction u/s 80IA by increasing higher profits in Infrastructure Division. The Assessing Officer noted that the assessee had borrowed funds prior to the commencement of Infrastructure Project but the said borrowing had increased and consequential interest burden had also increased due to transfer of interest bearing funds to the Infrastructure Division from the Construction Division. It was pointed out to the Assessing Officer that as on 1.4.2000 Infrastructure Division had credit balance of Rs.2,72,82,356/- which had fluctuated during the year and which increased to Rs.3,84,81,967/- as on 11.7.2000. But, Assessing Officer, held that interest bearing funds were transferred from Construction Division to Infrastructure Division. He calculated interest at a rate of 16.2% and worked out that a sum of Rs.40,07,841/- is the interest burden which should have pertained to Infrastructure Division but debited to Construction Division.
5. Before the ld. CIT(A) it was submitted that the assessee had its own funds on which no interest was paid. The cash surplus available in the beginning of the financial year 1999-2000 was as high as Rs.472 lacs, cash during the year was Rs. 104 lacs, non-interest bearing funds due from sundry creditors amounted to Rs.209 lacs, subsidies and borrowings for Infrastructure Division amounting to Rs.780 lacs and thus total funds available were Rs.1565 lacs whereas the project cost of Infrastructure Division was only Rs.11.81 lacs. He then pointed out to the detail of interest payment and submitted to the ld. CIT(A) that it had used the borrowings for the business of Construction Division as funds are 6 locked therein. It was only overdraft account which was available for alleged diversion on which only interest of Rs.5,95,320/- has been paid. The Assessing Officer has not established any nexus between the borrowings and their utilization for investment in the Infrastructure Division. It was also submitted that the assessee has substantial interest free funds in the form of share capital and reserves and it could transfer the funds to the Infrastructure Division out of such interest free funds.
6. The ld. CIT(A) considered the arguments of the assessee but held that the assessee has not proved that money lent to Infrastructure Division came from interest free funds. Actual state of affairs were not shown from flow of funds. She held that large sums of funds were transferred to Infrastructure Division and this has led to borrowing by Construction Division on which interest has been paid. She accordingly dismissed the ground of appeal of the assessee.
7. Against this, the ld. A.R. for the assessee submitted that situation remained the same as in the earlier year where no such disallowance was made. Secondly, no additional funds are transferred this year and finally the assessee had sufficient interest free funds of its own out of which it could transfer funds to Infrastructure Division. It cannot be presumed that transfer of funds to Infrastructure Division were only out of interest bearing funds borrowed by Construction Division. In fact, the ld. A.R. referred to the decision of Hon'ble High Court of Bombay in the case of CIT v. Reliance Utilities and Power Ltd. (2009) 178 Taxman 135 (Bom.) for the proposition that if interest free funds generated or are available with the assessee which are sufficient to meet the investment then presumption will arise that investments were made out of interest free funds. The ld. A.R. then drew our attention to page 2 of his paper book which showed a share capital of Rs.6.10 crores and surplus of 2.7 crores 7 in Construction Division and further a subsidy of Rs. 3 lacs in Infrastructure Division. Thus, according to him, presumption will go in favour of the assessee that advances to Infrastructure Division were given out of interest free funds. The ld. A.R. then referred to the several decisions of different courts in support of this proposition as under:
1. CIT v. Tin Box Co. (2003)260 ITR 637(Del.)
2. CIT v. Radio Khetan Ltd. (2005) 274 ITR 354(All.)
3. CIT v. Prem Heavy Engineering Work Pvt. Ltd.
(2006) 285 ITR 554
4. CIT v. Britannia Industries Ltd. (2006)280 ITR 525
5. R.D. Joshi & Co. v. CIT (2001)251 ITR 332
6. Torrent Financial v. ACIT (2001)73 ITJ 624 ITA No.1402/Ahd/1995 I.T.A.T. Ahmedabad "A" Bench
7. Munjal Sales Corporation v. CIT (2008) 290 ITR 298 (SC) He also submitted that the decision of Hon'ble Punjab & Haryana High Court in S.A. Builders 269 ITR 535 on which the ld. CIT(A) has relied has not been approved by the Hon'ble Supreme Court.
8. Against this, the ld. D.R. submitted the following arguments:
1. In response to the fact pointed out that Department had accepted lending of surplus funds to the infrastructure division without charging interest in the earlier years, DR argued that AO in assessment order has mentioned that -"For earlier years, the necessary remedial measures to disallow interest expenses relating to infrastructure project is being taken separately." On inquiry from the bench, Id. DR was not able to affirm whether after passing the order on 31/03/2004 for the year under consideration any action was taken till date to disallow interest expenses for the earlier years.
2. In response to the argument advocated that sufficient interest free funds were available with the assessee to advance funds to infrastructure division, Id. DR argued that the infrastructure division and regular business of the assessee were 2 distinct entities and when funds are mixed, 8 interest expense on the funds of regular business deployed in infrastructure division was not an allowable expense. He further argued that working out actual profit of the infrastructure division is finding of facts, a notional entry would not amount to actual profit and some interest must be paid to outside parties that ought to be disallowed.
3. Ld. DR further argued that advancing funds to any other business of the assessee is kind of service only and will attract provision of sec. 80IA (8), which enumerates that for the purpose of deduction under the section the services rendered to be valued at market price while computing profits/gains of business.
4. Ld. DR referred to provisions of sec. 80AB stressing that income attributable to infrastructure division has to be derived from the project.
9. Further, the ld. D.R. submitted that onus for proving that advances to Infrastructure Division have gone out of interest free funds of Construction Division is on the assessee. If the assessee had so much of interest free funds available then there was no need for it to borrow funds and pay interest thereon. Normal presumption would arise that if the assessee has interest free funds then it will first square up the loan to avoid burden of interest. But, the fact is that the assessee has continued to make the payment of interest and interest burden has substantially increased this year. It was Rs.51.31 lacs in the financial year 1999-2000 which has increased to 84.62 lacs clearing indicating that the assessee has borrowed interest bearing funds and transferred to Infrastructure Division and interest burden has been claimed in the Construction Division. Regarding decision of the Hon'ble Bombay High Court the ld.
D.R. submitted that first it has to be established that interest free funds are available with the assessee for applying the decision of Hon'ble 9 Bombay High Court. In the present case, the funds of the assessee are locked in fixed assets and they are not available. The assessee has not discharged the onus to prove that interest free funds alone were given to Infrastructure Division.
10. Ld. A.R. replied to the arguments of the ld. D.R. as under:
1. No remedial action is taken by the Department. This would mean that in the earlier years no disallowance of interest has been made. The case would then be covered by 192 ITR 165 (Karn.), M. Ravji's case (ITAT Unreported) as also 198 ITR 298 (SC).
2. Bombay High Court judgment of 'Reliance Utilities and Power Limited deals with precisely the same issue and lays down principles which squarely apply to the facts of this case. On facts there is no dispute that interest on the funds borrowed for respective activities is charged to respective divisions and the only controversy is as regards the funds of Construction division transferred to Infrastructure division- whether they were interest bearing funds.
3. providing of "services". In any case when an assessee like the present one starts the new project of infrastructure, it would be impossible to assume that the same was done without inflow of own funds which would not bear any interest.
On facts the assessee, a limited company, had huge funds (Rs.8.5 crore) in construction business- capital + reserves. The funds have gone to infrastructure division out of the said surplus funds. Therefore notional interest cannot be debited to the infrastructure project.
4. Again no dispute - but the question is whether the profits can be reduced by charging expenditure not incurred by the assessee? Again answer is NO.
11. We have considered the rival submissions and perused the material 10 on record. In our considered view, the onus for establishing that it was interest free funds which were given to Infrastructure Division is on the assessee. Merely because balance sheet indicated that the assessee had share capital reserve, it could not be said that it had actually interest free liquid funds to be transferred to Infrastructure Division. There is no dispute with the proposition that where the assessee has interest free funds available then transfer to sister concern or to a source even whose income is exempt can come out of such interest free funds but this has to be shown by the assessee. A fund flow statement showing interest bearing funds and, their utilization has to be given thereby proving that interest bearing funds were utilized for the business of Construction Division and were not transferred to Infrastructure Division. In this regard we may notice that Assessing Officer has not taken any action for disallowing interest in Construction Division in earlier years even though there were interest bearing funds borrowed by the assessee and interest thereon was paid. If no interest payment by Construction Division has been disallowed for transfer of funds from Construction Division to Infrastructure Division then, it is presumed that transfer of funds in earlier years was out of interest free funds and to that extent payment of interest this year cannot be disallowed. Following the rule of consistency, as described in 1. CIT v. H.P.Cotton Textiles Mills Ltd. (2009) 311 ITR 436 (P&H); 2. CIT v. Malborough Polychem. Pvt. Ltd. (2009) 309 ITR 43 (Raj.); 3.CIT v. Moonlight Builders and Developers (2008) 307 ITR 197 (Del.) and others., we hold that the A.O. should not disallow interest in respect of the funds already considered in earlier Assessment Years. The assessee has transferred fresh funds this year to the extent of Rs.3,84,81,967/- less Rs.2,72,98,401 = Rs.1,61,83,566/-. It has to be shown by the assessee that these funds were transferred out of interest free funds and to that extent liquid interest free funds were available with him. He has to show nexus. He has to show that no interest bearing funds 11 were transferred to Infrastructure Division. We, therefore, restore the matter to the file of the Assessing Officer to give an opportunity to the assessee to show that interest bearing funds were not utilized for investing into Infrastructure Division this year thereby clearly creating an inference that it was interest free funds which were given to Infrastructure Division. In any case, it is only to the extent of interest bearing funds are proved to have gone to Infrastructure Division the interest relatable to such transfer of interest bearing funds this year to Infrastructure Division will alone to be considered for disallowance in Construction Division.
12. As a result, this ground is allowed for statistical purposes.
13. Ground No.2 relates to ground No.1 and, therefore, it does not require adjudication.
14. Ground No.3 relates to disallowance of interest of Rs.24,57,083/- u/s 14A of the I.T.Act on the ground that interest bearing funds have been invested in shares, income from whom are exempt. The facts are described by the ld. CIT(A) in para 3 of her order. It is noted by the Assessing Officer that a sum of Rs.1.65 crores were utilized in investment in shares. This investment was made in the financial year 1999-2000 and continued this year as well. It was submitted by the assessee that no interest has been incurred as investment was made out of interest free funds. The Assessing Officer did not agree and disallowed proportionate interest amounting to Rs.26,83,618/-. The ld. CIT(A) considered the arguments of the assessee and held that investment in the Nutan Nagrik Sahkari Bank, Baroda Bank Ltd., Baroda Co-op. Bank Ltd., Sindh Co-op. Bank Ltd., Sardar Sarovar Nigam Ltd., totaling to Rs.13,94,071/- were incurred in the course of business and, therefore, she allowed a relief of 12 Rs.2,26,535/- and confirmed the addition of Rs.24,57,083/-. The assessee is in appeal against the addition confirmed whereas the Revenue is in appeal against relief allowed.
15. The ld. A.R. submitted that investment in shares were made in earlier year and there are fresh investments. The Revenue has allowed in earlier year the claim of interest and have not invoked section 14A for disallowing any part of interest attributable to investment of funds in shares. Since facts have not changed, the revenue should have followed the same decision and should not have resorted to disallowance. The decision of Assessing Officer in earlier year in not disallowing any part of the interest would mean that no interest bearing funds have been invested in shares. According to ld. A.R. the assessee had sufficient interest free funds in earlier year out of which investment in shares were made. He referred to his argument about availability of interest free funds raised by him in respect of ground Nos. 1 and 2. The ld. CIT(A) has followed the decision of Punjab & Haryana High Court in S.A. Builders 269 ITR 535 which is no longer a good law and it has been overruled by the Hon'ble Supreme Court in the case of Munjal Sales Corporation v. CIT (2008) 290 ITR 298(SC).
16. Against this, the ld. D.R. submitted that onus is on the assessee to prove that investment in shares had come out of interest free funds. He submitted that decision of Hon'ble Supreme Court in Munjal Sales Corporation (supra) was on the issue that for claiming interest on borrowed funds it has to be shown that money was borrowed for the purposes of business. In the present case, the business of the assessee is not in trading in shares. It is engaged in the construction activities, therefore, it cannot be presumed that interest bearing funds were not utilized for investing in shares.
1317. We have heard the rival submissions and perused the material on record. For deciding the present issue, the main relevant factor is that the assessee has not made any investment in shares in the current year. The Assessing Officer had found following investments in shares and admittedly they were in earlier years.
Particulars of investments As on As on :
31.3.00 31.3.01
Amount (Rs) Amount
, (Rs)
Quoted
Minar Trading Services Ltd 74,000 74,000
Sarv Shakti Synthetics Ltd 15,000 15,000
Corporation Bank 128,000 128,000
Myraj Consultancy Ltd 300,000 300,000
Unquoted
Nutan Nagarik Sahakari Bank 4,800 4,800
Baroda Peoples Co-op Bank Ltd 376,521 376,521
Baroda City Co-op. Bank Ltd 3,150 3,150
Classic Organisers Pvt. Ltd 10,000 10,000
Emsons Textiles pvt Ltd 50,000 50,000
Sindh Mercantile Co-op. Bank Ltd 9,600 9,600
MSK Projects India (JV) Ltd 13793,000 13793,000
MSK Projects India (JV) Ltd Pref. 750,000 750,000
Shares
Investment in Govt. Security
14
Indira Vikas patra 500.00 500.00
Sardar Sarovar Narmada Nigam 1000,000 1000,000
Ltd
16514,571 16514,571
Thus, no fresh investment has been made this year. There is no reason to take a different view than what ld. A.R. has submitted that once the Assessing Officer has allowed a claim in earlier year then it is presumed that he was satisfied that investment in shares were made out of interest free funds and, therefore, there was no case for disallowance of any interest burden u/s 14A. The Hon'ble Punjab & Haryana High Court in CIT v. H.T.Cotton Textiles Mills Ltd. (2009) 311 ITR 436 (P&H), Hon'ble Rajasthan High Court in CIT v. Malborough Polychem. Pvt. Ltd. (2009) 309 ITR 43 (Raj.), and Hon'ble Delhi High Court in CIT v. Moonlight Builder and Developers (2008) 307 ITR 197 (Del.) and many others, it has been held that for the sake of consistency and for the purposes of finality in litigation including the litigation arrived out of fiscal statutes, earlier decision on the same question should not be reopened unless some fresh facts are found in the subsequent year. Accordingly, where no disallowance is made u/s 14A in earlier years then there being no fresh investment in shares, no disallowance of interest in the current year is called for.
18. As a result, this ground of assessee is allowed.
19. Ground No.4 relates to disallowance out of gift articles. The Assessing Officer disallowed a sum of Rs.14,934/- which was reduced by the ld. CIT(A) to Rs.7467/-. After hearing the parties, we are of the view that no interference is called for in the order of the ld. CIT(A). She has restricted the disallowance to 5% on the ground that expenditure on 15 crockery item, silver gift items and jugs are not open to verification. We do not find any infirmity in this view and, therefore, her order is confirmed.
20. The fifth ground is not pressed and therefore is rejected.
21. The sixth ground relates to claim of expenses on membership of club. The ld. Assessing Officer disallowed a sum of Rs.25,105/- out of which the ld. CIT(A) confirmed a part of the expenses on the ground that a specific contribution in the name of company and subscription in the name of the company would alone be permissible expenditure. The ld. A.R. submitted that even the club membership in individual name would be allowable expenses as purpose of the business remained the common factor in both the situations i.e. there is no difference in business purpose of the company one in a case having membership in the name of the company and other having membership in the name of individual. He referred to a decision of Hon'ble Gujarat High Court in Gujarat State Export Corporation Ltd. v. CIT (1994) 209 ITR 649 (Guj.) and of Hon'ble Madras High Court in CIT v. Sundaram Industries (1999) 240 ITR 335 (Madras) for the proposition that club membership are allowable expenditure. The ld. D.R. on the other hand, relied on the order of authorities below.
22. After considering the rival submissions we are of the view that the issue is covered by the decision of the Hon'ble Gujarat High Court in Gujarat Export Corporation (supra), as such, additions so retained by the ld. CIT(A) is deleted. This ground of assessee is allowed.
23. Ground No.7 is general in nature and does not require specific adjudication and, therefore, is rejected.
1624. Ground No.8 relates to charging of interest u/s 234A/B/C. The same is consequential and will depend upon assessed income. This ground is accordingly allowed for statistical purposes.
25. Ground No.9 is about initiation of penalty u/s 271(1)(c ). It is premature and, therefore, rejected.
Departmental Appeal:
26. In departmental appeal the first ground relating to deletion of addition of interest of Rs.2,26,535/-.
27. In assessee's appeal this issue has been raised in ground No.3. We have held therein that following the principle of consistency, department ought not to have made any disallowance u/s 14A this year. Accordingly, we have allowed the appeal of the assessee. As a result, this ground of the revenue does not survive and is rejected.
28. Ground No.2 relates to disallowance on account of telephone expenses attributable to personal and non-business use. The ld. CIT(A) has considered this issue in paragraph 5 of her order. The issue is covered by the decision of the Hon'ble Gujarat High Court in Sayaji Iron and Steel Ltd. reported in 253 ITR 749. Accordingly, there is no infirmity in the order of ld. CIT(A), accordingly, the same is confirmed. This ground of revenue is, therefore, rejected.
29. Ground No.4 relates to disallowance out of depreciation which was restricted to Rs.15,110/- as against addition of Rs.37,776/- made by the Assessing Officer. The ld. CIT(A) allowed the claim of the assessee at 25% as against 10% applied by the Assessing Officer following the 17 decision of jurisdictional High Court in Tarun Chemicals Ltd. 151 ITR 75. Since, the issue has been decided by the ld. CIT(A) on the basis of decision of Hon'ble Gujarat High Court, we do not find any infirmity in her order. Accordingly, this ground is also rejected.
30. Ground Nos. 5 and 6 are general in nature and require no adjudication, they are also rejected.
31. As a result, appeal filed by the revenue is dismissed. The order was pronounced in the open court on 07.08.2009.
Sd/- Sd/-
(T.K.SHARMA) (D.C.AGRAWAL)
JUDICIAL MEMBER ACCOUNTANT MEMBER
AHMEDABAD, DATED: 07.8.2009
PSP*
Copy to:
(1) The assessee
(2) The Assessing Officer
(3) The CIT(A) concerned,
(4) The CIT, concerned,
(5) The DR, ITAT, Ahmedabad,
(6) Guard File.
BY ORDER
//True Copy//
ASSTT. REGISTRAR/ DEPUTY REGISTRAR
ITAT, AHMEDABAD BENCHES
AHMEDABAD.