Income Tax Appellate Tribunal - Ahmedabad
Nanavati Motors, Surat vs Department Of Income Tax on 30 September, 2010
IN THE INCOME TAX APPELLATE TRIBUNAL
AHMEDABAD BENCH " B "
Before Shri MUKUL Kr. SHRAWAT, JUDICIAL MEMBER and
Shri N.S. SAINI, ACCOUNTANT MEMBER
Date of hearing : 27/08/2010 drafted on: 30/09/2010
1. ITA No.968/AHD/2007 - A.Y. 2003-04
2. ITA No.1029/AHD/2007 - A.Y. 2003-04
1. Asst.CIT Vs.
1. M/s.Nanavati Motors
Circle-6, Surat Nr. Rajhans Cinema
Opp. Reliance Tower
Piplod Main Road
Surat
2. M/s.Nanavati 2. The ITO Ward-4(1)
Motors, Surat Surat
PAN/GIR No. : AACFN 1015 G
(APPELLANTS) .. (RESPONDENTS)
Assessee by : Shri J.P. Shah, A.R.
Revenue by : Shri K.Madhusudan, D.R.
ORDER
PER SHRI MUKUL Kr. SHRAWAT, JUDICIAL MEMBER :
For Assessment Year 2003-04, these are cross appeals by the Revenue as well as by the Assessee arising from the order of CIT(A)-IV, dated 26/12/2006. For the sake of convenience, these two appeals are consolidated and hereby decided by this common order.
(A) Revenue's appeal ; ITA No.968/Ahd/2007
2. Ground No.1 reads as under:-
ITA Nos.968/Ahd/2007 (By Revenue)& ITA No.1029/Ahd/2007 (By Assessee) Asst.Year - 2003-04 -2- "1.On the facts and in the circumstances of the case and in law the CIT(A), Surat has erred in deleting the addition of 1,88,575/-
u/s.41(1) of the I.T.Act."
2.1. A liability in the name of M/s.Jayesh Trading Company was reflected in the books of account. The Assessing Officer has issued a notice which remained un-served on the said party. Thereafter, following the history of Assessment Year 2002-03 in assessee's own case he had made the addition. When the matter reached before the Learned CIT(Appeals), he has also followed the judgement of 2002-03 of his predecessor and deleted the addition. Now the Revenue is in appeal before us, however it has been placed on record that the Respected Co-ordinate Bench "B" Ahmedabad in ITA No.1609/Ahd/2006 (Assessment Year 2002-03) in appeal of ACIT vs. M/s.Nanavati Motors vide order dated 23/04/2010 vide paragraph Nos.6 and 7 has upheld the verdict of Learned CIT(Appeals) in the following terms:-
"6. The next issue in this appeal of the Revenue is against the order of CIT(A) in making addition on account of cessation of liability u/s.41(1) of the Act amounting to Rs.2,23,400/-.
7. After hearing the rival contentions and going through the facts of the case, we find that the Assessing Officer has added this on account of liabilities shown by the assessee as outstanding in balances under the head other liabilities and the Assessing Officer in order to verify the genuineness issued notice u/s.133(6) of the Act, to these parties but the assessee could not furnish the changes of address and in the absence of verification, the AO treated the liability as non-existent and made the addition u/s.41(1) of the Act. The CIT(A) allowed the claim of the assessee by giving following finding:-
" I have considered the submissions and I am inclined to agree with the appellant on this account. The said liability is still ITA Nos.968/Ahd/2007 (By Revenue) & ITA No.1029/Ahd/2007 (By Assessee) Asst.Year - 2003-04 -3- outstanding in the books of the appellant and the AO has not brought any material on record in this regard to disallow the said claim. Unless it is proved beyond doubt that the liability ceased to exist, no addition u/s.41(1) an be made. In view of this, the same is directed to be deleted."
We find from the facts of the case and argument of both the sides that the assessee has business dealing with the said parties during the year i.e., 2002-03 and liability of the said parties still continued and even the Assessing Officer has not found that the assessee has written off this liability and it is very much outstanding in the books of account in the name of these parties. Until and unless, the liability has been written off, the AO cannot make addition by invocation of Section 41(1) of the Act. Accordingly, we are in full agreement with the order of CIT(A) and this issue of the Revenue's appeal is dismissed."
3. Since a view has already been taken by a Co-ordinate Bench, therefore, we find no reason to take any other view but to follow the same. In the result, this ground of the Revenue is dismissed.
4. Ground No.2 reads as under:-
"2. On the facts and in the circumstances of the case and in law, the Ld. Learned CIT(Appeals) has erred in deleting the addition of 1,19,823/- made on account of Capital Expenditure. "
4.1. It was observed by the Assessing Officer that though furniture repair expenditure was incurred, but there were no labour expenses for furniture repair. Against the said disallowance when the matter reached before the Learned CIT(Appeals), it was pointed out that the said issue had also arisen in Assessment Year 2002-03 which was decided by the then Learned CIT(Appeals) in assessee's favour. Following the past history, for this year as well, the Learned CIT(Appeals) has allowed the claim. Now the Revenue is before us in appeal, however, it is informed ITA Nos.968/Ahd/2007 (By Revenue) & ITA No.1029/Ahd/2007 (By Assessee) Asst.Year - 2003-04 -4- that for Assessment Year 2002-03, the Revenue was in appeal before the Tribunal and as per the order cited supra vide paragraph Nos. 4 & 5, the issue was decided in assessee's favour, which is reproduced below:-
"4. The next issue in this appeal of the Revenue against the order of CIT(A) deleting the addition made by the Assessing Officer on account of disallowance of revenue expenditure treating the same as capital expenditure amounting to Rs.5,50,730/-.
5. After hearing the rival contentions and going through the case records we find that the Assessing Officer disallowed building repair expenses at Rs.3,41,603/-, furniture repairing expenses at Rs.1,18,376/- and machinery repair expenses at Rs.1,13,750/- by holding the same as capital in nature by stating the reason that the expenses were related to purchase of goods as wood, granite, tiles, cement hardware items and architect fee and purchase of new sofa set, other assets and purchase some equipments of car repairs, labour expenses. The AO treated the expenditure as capital in nature and disallowed. Aggrieved, assessee preferred appeal before CIT(A). The CIT(A) on these items has allowed the claim of the assessee by giving following findings in page-10:-
"I have considered the submissions and perused the details and I am inclined to agree with the appellant on this account. Looking into the local expenditure and high cost of material and labour, it is not possible to create a new building by incurring an expenditure of Rs.3.41 lakhs only. I, therefore, hold that no new asset has come into existence and therefore the expenditure is in the nature of current repairs and is fully allowable. Addition on this account is, therefore, directed to be deleted. However, the AO is also directed to withdraw depreciation if allowed on capitalization of the said expenditure.
The next ground of appeal is regarding disallowance of furniture repairing expenses on the ground that most of it was for new sofas and other assets and the same was in the nature of capital expenditure. However, a perusal of ledger account of this expenditure shows that most of the bills are below Rs.10,000/- ranging from Rs.1,200/- to Rs.5,690/-. The only heavy bills are in respect of payment to the carpenters and workers. There could possibly be no asset of enduring benefit coming into existence by spending such small amounts. There ITA Nos.968/Ahd/2007 (By Revenue) & ITA No.1029/Ahd/2007 (By Assessee) Asst.Year - 2003-04 -5- is no justification of eating the same as capital expenditure and addition on this account is directed to be deleted. The AO is also directed to withdraw the depreciation allowed on such capitalization.
I have considered the submissions. It is seen that the Hon'ble Gujarat High Court in the case of Addl. CIT /s. Desai Bros 108 ITR 14 has held that even replacement of the petrol engine by a diesel engine would not bring into existence a new asset and was allowable as current repairs. The Hon'ble Calcutta High Court in CIT Vs. R.P. Kejliwal 76 Taxman 124 has held that replacement of parts of a machine, even if such replacement was more than cost of the machine itself, would qualify for deduction as revenue expenditure. In the appellant's case, since no new asset has come into existence, the expenditure is fully allowable as revenue expenses and addition on this account is directed to be deleted. However, the AO shall also withdraw depreciation allowed on capitalization of such expenditure."
We find that the nature of expenditure as discussed above are as wood, granite, tiles, cement hardware items and architect fee and purchase of new sofa set itself prove that these are for repair and renovation of building, repair of furniture and repair of car and in no way it can be called as capital in nature and accordingly the same is held to the revenue in nature and the order of CIT(A) does not call for any inference and we uphold the same. This issue of the Revenue's appeal is dismissed."
5. Since in the past a view has already taken against the Revenue, therefore, following the same for this year as well this ground of the Revenue is dismissed.
6. Ground No.3 reads as under:
"3. On the facts and in the circumstances of the case and in law, the Ld. CIT(Appeals) has erred in deleting the addition of `34,19,725/-."ITA Nos.968/Ahd/2007 (By Revenue)
& ITA No.1029/Ahd/2007 (By Assessee) Asst.Year - 2003-04 -6- 6.1. In respect of the discount expenses, the Ld. Learned CIT(Appeals) has mentioned that for Assessment Year 2002-03 his predecessor has decided the issue in favour of the assessee. In that year, the Revenue had gone in appeal and the Respected Co-ordinate Bench has decided the matter in favour of the assessee vide paragraph No.3; reproduced below:-
"2. The first issue in this of Revenue is against the order of CIT(A) deleting the addition made by the Assessing Officer on account of bogus commission amounting to Rs.15,82,238/-.
3. At the outset Ld. Sr. Counsel for the assessee, Shri J.P. Shah that the issue is squarely covered by the decision of this Tribunal in assessee's own case for assessment year 2001-02, wherein the Tribunal in ITA No.2979/Ahd/2009 dated 18-01-2010 has dismissed Revenue's appeal exactly on same facts vide para-5 as under:-
"5. In view of the above facts that the assessee being a dealer of motor car has allowed discount to the customers as well as commission, i.e. short payment account, sale of value of cars and for this the assessee has produced all sale bills, copy of all ledger a/c. of such customers which prove that in the cases of customers initially the customer's accounts were debited with full sale value of cars and with the help of ledger a/c it was shown that the customers though the full sale value of the cars were debited in the customer's a/c, the concerned customer paid lesser amount by cheques/draft and the balance amount in the customer's accounts were transferred to the commission expense/discount a/c. The assessee before the lower authorities have produced the ledger a/c. and the copy of sale bills along with books of account and even now they have filed these details. The fact is that the discount and commission, i.e. short payment is made by the customers and this can be easily verified from the books of account. Accordingly, CIT(A) has rightly deleted the addition as ITA Nos.968/Ahd/2007 (By Revenue) & ITA No.1029/Ahd/2007 (By Assessee) Asst.Year - 2003-04 -7- narrated above and we confirm the same. This issue of the Revenue's appeal is dismissed."
Ld. SR-DR, Smt. Neeta Shah on the other hand heavily relied on the assessment order. We find that the commission and discount paid to the clients by the assessee on account of cars purchased by the clients on the selling price of cars and completer details like name, address, model of car purchased, selling price of cars and details on discount allowed were submitted before lower authorities and even now before us. The assessee has enclosed the entire details in assessee's paper book. We are of the view that the figures of discount prima facie establishes that the discount given by the dealer to the customers, each of commission and discount are quite reasonable and represents the usual customer's discount given by the dealers on sale of cars to the customers. As the issue is squarely covered in assessee's own case, exactly on similar facts, which is narrated by the Assessing Officer in his assessment order that this commission expense and issue bears the same facts in assessment year 2001-02 and relevant para-5.8 of Assessing Officer's order, which reads as under:-
"5.8 It is also pertinent to mention here that in the assessee's own case, 1the Ld. CIT(A)-IV, Surat has confirmed the addition of Rs.36,12,553/- made out of commission expenses in the A.Y 2001-02 and dismissed the appeal of the assessee. The facts and circumstances of the case in both the year are similar."
The facts being exactly identical as admitted by Revenue, we dismiss this issue of the Revenue's appeal."
7. It is pertinent to mention that in the past as well i.e. for Assessment Year 2001-02 ITAT Ahmedabad Bench "D" in ITA No.2979/Ahd/2009 vide an order dated 18/01/2010 has held that the fact being the amount of discount and commission were paid to the customer or short payment ITA Nos.968/Ahd/2007 (By Revenue) & ITA No.1029/Ahd/2007 (By Assessee) Asst.Year - 2003-04 -8- was received by the customers and that could be easily verified from the books of account, hence rightly deleted by the first appellate authority.
8. In view of these two decisions since the Respected Co-ordinate Benches have consistently taken decision in favour of the assessee in assessee's own case, therefore we find no reason to take any other view but to follow the same. Accordingly, this ground as well of the Revenue is dismissed
9. Ground No.4 reads as under:
"4. On the facts and in the circumstances of the case and in law, the Ld. CIT(Appeals) has erred in deleting the addition of Rs.6,24,343/- made on account of Capital Expenditure for renovation of buil1ding."
9.1. There was a claim in respect of building repair which was held by the Assessing Officer as an expenditure of capital in nature. When the issue was carried before the first appellate authority, he has followed his predecessor's order for Assessment Year 2002-03 and allowed the claim. Now before us, the aforementioned decision of this very assessee for Assessment Year 2002-03 is placed wherein Revenue's ground was dismissed. In identical manner, the ground in respect of the furniture expenditure was dismissed. Considering the items of the expenditure, the Tribunal has held that the nature of expenditure itself proves that those were repairs and renovation of building. Accordingly, allowed the claim. For the year under consideration, we hereby follow the past history of the case since nothing new or contrary to the facts of the past ITA Nos.968/Ahd/2007 (By Revenue) & ITA No.1029/Ahd/2007 (By Assessee) Asst.Year - 2003-04 -9- having placed by the Revenue. Accordingly, this ground of the Revenue fails.
10. Rest of the grounds are general in nature need no independent adjudication.
11. In the result, Revenue's appeal is dismissed.
(B) Assessee's Appeal; i.e. ITA No.1029/Ahd/2007.
12. Ground No.1 reads as under:
"1) The learned Com of Income Tax (Appeals) has erred in law and on facts in confirming the disallowance of Depreciation claimed on Demo Car to the tune of to Rs.99,770/-."
12.1. There was a claim of depreciation of Rs.99,770/- in respect of a Demo Car which was stated to be purchased at fag end of the Financial Year, i.e. On 31/03/2003. However, it has also been noted that the Car was discharged on that very day i.e. on 31/03/2003 at 1.12p.m. from Hyundai Company at Chennai. The Assessing Officer was of the view that the Car was in transit and not available at the business premise of the assessee at Surat, therefore, not used for the purpose of the business, hence, not entitled for the claim of depreciation. On the other hand, the contention of the assessee was that the Car was purchased on that day and the ownership was transferred to the assessee. It has also been pleaded that the delivery has also been taken on that very day. It has also been argued that the Demo Car was actually put to use being transferred ITA Nos.968/Ahd/2007 (By Revenue) & ITA No.1029/Ahd/2007 (By Assessee) Asst.Year - 2003-04
- 10 -
from the company's go-down, however, the Revenue has taken a view that merely the impugned Car was in transit therefore could not be available at assessee's business premises, as a result depreciation was disallowed. The first appellate authority has affirmed the action of the Assessing Officer. On examination of the facts of the case and the surrounding circumstances, once the admitted factual position is that the Demo Car was purchased on 31/03/2003 and as per the copy of invoice the Insurance and Freight charges have also been paid and the appellant has later on got the Car registered in its name, we are of the view that the Car in question was actually put to use by the assessee, hence, entitled for the claim of depreciation. This ground of the assessee is allowed.
13. Ground No.2 reads as under:
"2) The learned Com of Income Tax (Appeals) has erred in law and on facts in confirming the disallowance of RTO Tax and Octroi Expenses incurred on Demo cars purchased during the year to the tune of to Rs.3,01,838/- treating the same to be of capital expenditure."
13.1. Almost on identical manner, it was observed by the Assessing Officer that the appellant had purchased seven Demo Cars and paid TRO tax of Rs.2,89,020/- and Octroi of Rs.12,663/- on the same date. As per Assessing Officer, the expenditure was capital expenditure, hence not allowable. On the other hand, the explanation of the assessee was that the Demo Cars were required to be disposed of within a period of nine months, hence, the expenditure was in the nature of Revenue Expenditure. Before the first appellate authority, a middle path was adopted by the assessee and conveyed that he had no objection if the ITA Nos.968/Ahd/2007 (By Revenue) & ITA No.1029/Ahd/2007 (By Assessee) Asst.Year - 2003-04
- 11 -
amount in question be allowed to be utilized so that the depreciation could be claimed. The Learned CIT(Appeals) has accepted the assessee's request following the decision of ITAT Ahmedabad Bench in the case of Pushpanjali Dyeing & Printing Mills vs. JCIT reported as 72 TTJ 887 (Ahd.) and the ground was dismissed.
14. After hearing both the sides, we are of the view that no specific reason emerges from the order of the first appellate authority as to why this ground was not contested before him. Once we have held hereinabove that the assessee was entitled for the demonstration on Demo Car, therefore, in the like manner once the Demo Car's delivery was taken over and also put to use then naturally RTO tax, Octroi, etc. were mandatory to be paid, therefore, these two expenditure can be held Revenue expenditure. Without incurring this expenditure, the asset in question could not be used by the assessee. Hence, circumstances of the case, thus warrant to allow the claim. We hold accordingly. This ground of the assessee is allowed.
15. Ground Nos.3 & 4 read as under:
"3) The learned Com of income Tax (Appeals) has erred in law and on facts in confirming disallowance of Rs.1,00,000/- of impact fees paid to SMC."
"4) Without prejudice to the above ground, the Learned Commissioner of Income Tax (Appeals) has erred in law and on facts in not allowing depreciation on the said sum of Rs.1,00,000/-
being the impact fee paid to Surat Municipal Corporation."
ITA Nos.968/Ahd/2007 (By Revenue)& ITA No.1029/Ahd/2007 (By Assessee) Asst.Year - 2003-04
- 12 -
15.1. The observation of the Assessing Officer was that a sum of Rs.1 lac paid on account of impact fees to Municipal Corporation was in the nature of penalty, therefore, not allowable as an expenditure. The explanation of the assessee was that the said fees was paid to Surat Municipal Corporation for change in nature of usage of basement. It was informed that the change was from parking to work-shop usage. There was an another change that the ground-floor was changed from work-shop to office usage. It was contested that the amount in question was not in the nature of penalty. Against this disallowance, the matter was carried before the first appellate authority, who was of the view that the Impact Fee levied by the Corporation was a penalty for performing an activity which was otherwise prohibited by law. The claim of the assessee was dismissed.
16. We have heard both the sides. We have perused the facts of the case in the light of the decision of Respected Co-ordinate Bench Mumbai in the case of Kaira Can Co.Ltd. vs. DCIT reported as 32 DTR 485 (Mum.)[Tri.]. On perusal of the explanation to section 37(1), if an expenditure is incurred which is either an offence or prohibited by the law, then should not be allowed. In the present case, the impact fee does not appear to be levied in respect of any breach or violation of law. However, it appears that a facility was provided by the Municipal Corporation to the building owners to change the usage of the property. Moreover, the term "fees" itself do not demonstrate that prima-facie it ITA Nos.968/Ahd/2007 (By Revenue) & ITA No.1029/Ahd/2007 (By Assessee) Asst.Year - 2003-04
- 13 -
was a levy of "penalty". How and why it was considered by the Revenue an infraction of law did not borne out from the facts of the case. In view of this, we hereby direct to allow the claim.
17. Ground No.5 reads as under:-
"5) The learned Commissioner of income Tax (Appeals) has erred in law and on facts in confirming disallowance of 1/10th out of Telephone and Mobile Phone Expenses to the tune of Rs.57,255/-
on account of alleged use for non-business purposes."
17.1. Ground No.5 has not been pressed and, therefore, the same is dismissed.
18. Ground No.6 reads as under:-
"6) The learned Commissioner of income Tax (Appeals) has erred in law and on facts in confirming addition of Rs.2,50,000/- in respect of advance received from customer for car booking."
18.1. A sum of Rs.2,50,000/- was stated to have been received from one Shri Balwantsingh Himmatsingh Gohil. The amount was claimed to have been paid for booking of Santro Car. It was said to be an advance, however, facts have revealed that no car at all was sold to him. It has also been noted that the said party was not assessed to tax. The Assessing Officer has made the addition and the first appellate authority has affirmed the same. On hearing both the sides the issue appears to be simple and to be decided in terms of the provisions of section 68 of the I.T.Act. There is no evidence that the amount in question was received as an advance for booking of a Car. In the absence of all, ITA Nos.968/Ahd/2007 (By Revenue) & ITA No.1029/Ahd/2007 (By Assessee) Asst.Year - 2003-04
- 14 -
such a crucial evidence, the deposit of Rs.2,50,000/- was nothing but a cash credit in the books of account, therefore, has to be dealt with as per the provisions of section 68 of the I.T.Act. A substantial question was raised by the Revenue authorities that why this amount was received in cash? Otherwise the standard practice was to receive a cheque or a draft. In the absence of any convincing as well as an authentic document, or any corroborative evidence, we are not convinced with the explanation offered, therefore, hereby uphold the view taken by the authorities below. This ground is, therefore, dismissed.
19. Ground No.7 reads as under:-
"7) The learned Commissioner of income Tax (Appeals) has erred in law and on facts in confirming the disallowance of claim for advertisement expenditure of Rs.1,65,000/- over and above the advertisement expenditure claimed during the year under consideration."
19.1. An expenditure towards advertisement was disallowed. The facts have revealed that a credit entry of this amount was made by debiting the advertisement agency account for the accounting period ended on 31/03/2002. It has also been noticed that the Car Manufacturing Co. had reimbursed the assessee by making direct payment to the advertisement agency. The first appellate authority has held that once an adequate effect has been given for Assessment Year 2002-03, however, no consequential action was taken by the assessee for the year under consideration, therefore, the claim cannot be allowed. It has also been noted by the Learned CIT(Appeals) that so far no claim has been made by the assessee by filing a revised return.
ITA Nos.968/Ahd/2007 (By Revenue)& ITA No.1029/Ahd/2007 (By Assessee) Asst.Year - 2003-04
- 15 -
20. After hearing both the sides, it appears that the assessee has moved a petition during the course of assessment proceedings vide letter dated 23/03/2006 asking the Assessing Officer to allow a deduction of Rs.1,65,000/- towards advertisement expenditure, over and above, the amount claimed as per Profit & Loss Account. It has also revealed as also accepted by the Learned CIT(Appeals) that for Assessment Year 2002-03, once it was noticed that the Hyundai Company has reimbursed the advertisement expenditure, then in that year, the claim was revised. Now before us, it is contested that an entry was made in the advertisement account of the current year by crediting the advertisement account and debiting the said advertisement agency. These facts are to be investigated afresh and if it is not a case of double deduction and if the expenditure is genuine and exclusively meant for the purpose of the business, then the same is allowable as per law. With these directions, we restore this ground back to the stage of the Assessing Officer to be decided de novo as per law.
21. Ground No.8 reads as under:
"8) The learned Commissioner of income Tax (Appeals) has erred in law and facts in confirming the disallowance of claim for the set off of unabsorbed depreciation to the tune of Rs.6,93,368/-."
21.1. In respect of this ground, the first appellate authority, has made a very cryptic observation that the unabsorbed depreciation of Rs.6,93,368/- pertained to Assessment Year 1999-2000. According to him, the said claim was never made in the past for Assessment Years ITA Nos.968/Ahd/2007 (By Revenue) & ITA No.1029/Ahd/2007 (By Assessee) Asst.Year - 2003-04
- 16 -
2000-01 to 2003-04. In his opinion, at this stage, for Assessment Year 2003-04 it could not be allowed. On perusal of the Assessment Order it was found that no discussion about the disallowance was made. This was one of the major objection of this Appellant that without assigning any reason the AO had disallowed the claim. Facts as narrated before us have revealed that the unabsorbed depreciation was related to the assessment year 1999-2000, however inadvertently it was forgotten in that year . Now it is contended that the mistake came to the notice while finalizing the Income Tax return for the year under consideration. All these facts being not narrated before the AO and the veracity has to be examined on the basis of the assessment record of the assessee and then to be allowed as per law if prescribe , therefore natural justice demands to restore this issue back to AO to be decided afresh as per law. This ground of the assessee may be treated as allowed only for statistical purpose.
22. In the result Revenues Appeal is dismissed while the assessee's appeal is partly allowed as per the terms protanto.
Order signed, dated and pronounced in the Court on 08/ 10 /2010.
Sd/- Sd/-
( N.S. SAINI ) ( MUKUL Kr. SHRAWAT )
ACCOUNTANT MEMBER JUDICIAL MEMBER
Ahmedabad; Dated 08/ 10 /2010
T.C. NAIR, Sr. PS
ITA Nos.968/Ahd/2007 (By Revenue)
& ITA No.1029/Ahd/2007 (By Assessee)
Asst.Year - 2003-04
- 17 -
Copy of the Order forwarded to :
1. The Assessee.
2. The Department.
3. The CIT Concerned
4. The ld. CIT(Appeals)-IV, Surat
5. The DR, Ahmedabad Bench
6. The Guard File.
BY ORDER,
स×याǒपत ूित //True Copy//
(Dy./Asstt.Registrar), ITAT, Ahmedabad
1. Date of dictation....................... 30/09/2010
2. Date on which the typed draft is placed before the Dictating Member 07/10/2010.................. Other Member.....................
3. Date on which the approved draft comes to the Sr.P.S./P.S.................
4. Date on which the fair order is placed before the Dictating Member for pronouncement......
5. Date on which the fair order comes back to the Sr.P.S./P.S...................
6. Date on which the file goes to the Bench Clerk.................................
7. Date on which the file goes to the Head Clerk..................................
8. The date on which the file goes to the Assistant Registrar for signature on the order..........................
9. Date of Despatch of the Order..................