Income Tax Appellate Tribunal - Delhi
First Flexipack Corporation, New Delhi vs Assessee
I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 &
609/Del/2012
IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH "B", NEW DELHI
BEFORE SHRI I.C. SUDHIR, JUDICIAL MEMBER
AND
SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER
I.T.A. No. 5056/Del/2010
A.Y. 2006-07
M/s First Flexipack vs. Dy. Commissioner of
Corporation, Income Tax, Circle-
305, 3rd floor, Bahnot 18, New Delhi
Corner, Pamposh
Enclave,
Greater Kailash-I,
New Delhi - 110 048
(PAN: AABFF0837D)
I.T.A. No. 4013/Del/2011
A.Y. 2007-08
Asstt. Commissioner Vs. M/s First Flexipack
of Income Tax, Circle- Corporation,
18, Room No. 327, 305, 3rd floor, Bahnot
ARA Centre, E-2, Corner, Pamposh
Jhandewalan Extn., Enclave,
New Delhi - 110 055 Greater Kailash-I,
New Delhi - 110 048
(PAN: AABFF0837D)
I.T.A.NO. 609/DEL/2012
A.Y. 2008-09
Asstt. Commissioner Vs. M/s First Flexipack
of Income Tax, Circle- Corporation,
18, Room No. 327, 305, 3rd floor, Bahnot
ARA Centre, E-2, Corner, Pamposh
Jhandewalan Extn., Enclave,
Greater Kailash-I,
New Delhi - 110 055
New Delhi - 110 048
(Appellant) (PAN: AABFF0837D)
(Respondent)
1
I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 &
609/Del/2012
Assessee by : Sh. Suresh Anantharaman, FCA
Department by : Ms. Nidhi Srivastava, Sr. D.R.
ORDER
PER SHAMIM YAHYA: AM These appeals by the Revenue and Assessee emanate out of order of the Ld. CIT(A) for the respective assessment years. Since the issues are common and the appeals were heard together and these are being consolidated by this common order for the sake of convenience
2. The issue raised in ITA No. 5056/Del/2010 (A.Y. 2006-07) in the Assessee's appeal read as under:-
i) The lower authority has erred in not allowing deduction of Rs. 2,04,42,410/- being the sum of CENVAT credit availed as eligible profit u/s. 80-IB.
ii)(a) The lower authority has erred in not allowing deduction of Rs. 13,709.67 being the VAT Remission credit availed as eligible profit u/s. 80-
IB.
(b) Without prejudice to the above, the lower authority has wrongly taken the figure of Rs. 1,92,000/- as VAT Remission in place of actual figure of Rs. 13,790.67.
iii) Without prejudice to the above, the lower authority has erred in not treating the amount of Rs. 2,04,42,410/- towards CENVAT credit as Capital Subsidy.
2I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012
iv) Without prejudice to the above, the lower authority has erred in not treating the amount of Rs. 13,790.67 towards VAT remission as capital subsidy.
v) The assessee craves its right to add, alter, withdraw, modify or delete any of the grounds of appeal.
3. The grounds raised in ITA No. 4013/Del/2011 (A.Y. 2007-08) in the Revenue's appeal read as under:-
i) On the facts and in the circumstances of the case, the Ld. CIT(A) has erred in law and on facts in deleting the disallowance of Rs. 91,94,880/- u/s. 80-IB on account of Self Cenvat Credit availment.
ii) On the facts and in the circumstances of the case, the Ld. CIT(A) has erred in law and on facts in holding that Excide Duty refund is a capital receipt in nature and not liable to tax.
iii) The order of the ld. CIT(A) is erroneous and is not tenable on facts and in law.
iv) The appellant craves leave to add, alter or amend any / all of the grounds of appeal before or during the course of the hearing of the appeal.
4. The grounds raised in ITA No. 609/Del/2012 (A.Y. 2008-09) in the Revenue's appeal read as under:-
3I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012
i) On the facts and in the circumstances of the case, the Ld. CIT(A) has erred in law and on facts in deleting the disallowance of Rs. 1,16,78,452/- u/s. 80-IB on account of Self Cenvat Credit Availment.
ii) On the facts and in the circumstances of the case, the Ld. CIT(A) has erred in law and on facts in holding that Excide Duty refund is a capital receipt in nature and not liable to tax.
iii) The order of the ld. CIT(A) is erroneous and is not tenable on facts and in law.
iv) The appellant craves leave to add, alter or amend any / all of the grounds of appeal before or during the course of the hearing of the appeal.
5. In this case the assessee is a manufacturing partnership firm engaged in the business of manufacturing flexible packaging material mainly used in FMCG industries for packing finished goods. The assessee filed its return of income for A.Y. 2006-07 declaring taxable income at Rs. 2,93,310/- after claiming deduction of Rs. 10,07,74,881/- u/s. 80-IB of the I.T. Act. In the assessment u/s. 143(3), the Assessing Officer enhanced the returned income by disallowing a sum of Rs. 2,04,42,410/- on account of Cenvat Credit Availment and VAT remission of Rs. 1,92,000/- out of the deduction u/s. 80IB. The AO noted from the profit and loss account of the units that the assessee has credited an amount of Rs. 2,04,42,410/- on account of Cenvat credit to Jammu unit as well as VAT remission amounting to Rs. 1,92,000/-. The Assessing Officer held that the credits on account of excise duty refund and VAT remissions were not eligible for deduction 4 I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012 u/s. 80-IB as the same were not the income derived from the industrial undertaking. As per the Assessing Officer, the Cenvat Credit and VAT remissions cannot be said to be profits or gains derived from the industrial undertaking as its immediate and proximate source is not the industrial undertaking but the excise poly for the refund of excise duty.
6. Similar disallowances were also made by the Assessing Officer for asstt. year 2007-08 and 2008-09. For asstt. year 2006-07 the Ld. CIT(A) affirmed the action of the Assesisng Officer. For asstt. year 2007-08 and 2008-09 Ld. CIT(A) deleted the addition by holding that assessee was entitled to deduction u/s. 80-IB on account of Cenvat Credit Availment. Furthermore, Ld. CIT(A) allowed the addition ground of the assessee that excise duty refund was a capital in nature and not taxable to tax.
7. Against the above order the Assessee in appeal for asstt. year 2006-07 and Revenue is in appeal for asstt. year 2007-08 & 2008-09 before us.
8. Since the issues are analogical, we are adjudicating the issue with reference to the facts and figures of the Asstt. 2007-08.
9. The assessee has received refund of excise duty paid by it, from the Excise authorities. The Government of India, Ministry of Commerce and Industry and Department of Industrial Policy and Promotion vide its Office Memo dated 14.6.2002 has formulated a special package of incentives for the development of industries in the State of J&K. Such office Memorandum states that the special package for the State of J&K is on the same lines which were earlier formulated by the Government of India for the North Eastern states notified vide OM NO.
5I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012 EA/1/2/96-IPD dated 24th December, 1997. With a view to accelerate industrial development in the State of J&K, the package of incentives was introduced and made applicable to the industrial undertakings specifying certain conditions and put up in the State of J&K. One of the incentives made is 100% excise duty exemption for a period of ten years from the date of commencement of commercial production by the industrial undertakings. The Assessing Officer disallowed the assessee relief u/s. 80-IB and amount received on account of Cenvat Credit alongwith VAT remission by holding that the impugned amount cannot be construed as profit or gains derived from the industrial undertaking. In this regard, submissions of the assessee before the Ld. CIT(A) can be gainfully referred as under:-
"It was inter alia pointed out by the appellant that this issue of granting deduction u/s 80 IB on refund of excise duty had also arisen before Hon'ble Delhi High Court in the case of CIT vs. Dharampal Premchand (2009) 221 CTR 133 where the Court held the refund of excise duty has a direct nexus with manufacturing activity and therefore such refund is an income derived from industrial undertaking eligible for relief under S. 80-IB. It was also submitted by the appellant that the Special Leave petition filed by the Revenue against the judgment of Delhi High Court in Dharampal Premchand Ltd. dealing with the issue of refund of excise duty u/s 80-IB of the IT Act has also been dismissed by the Supreme Court (2010 T[OL 18-SC-IT).
Regarding the applicability of the ratio of the decision of Hon'ble Supreme Court in the latest case of Liberty India 6 I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012 Ltd. 317 ITR 218 assessee made detailed submissions distinguishing the judgment of the Delhi High Court in Dharampal Premchand Ltd. with the judgment of the Supreme Court in the case of Libel1y India Ltd .. The submissions of the assessee are as under:
"1. Your Honour, the judgement given by the Hon'bIe Supreme Court in the case of Liberty India vs. Commissioner of Income Tax (2oo9) 317 ITR 218 (SC) is on the issue whether Duty Draw Back / DEPB allowed u/s. 75 of the Custom Act, i962 are incentive, profit or profit derived from eligible business u/s. 80-IB.
The Hon'hle Supreme Court in this regard, held as under:
"DEPB / Duty Drawback are incentives, which flow from the schemes framed by the Central Government or from Section 75 of the Customs Act, 1962. Incentive profits are not profits derived from eligible business under section 80-IB : they belong to the category of ancillary profits of such undertaking. Profits derived by way of incentives such as DEPB / Duty drawback cannot be credited against the cost of manufacture of goods debited in the profit and loss account and they do not fall within the expression "profits derived from industrial Undertaking " under section 80-IB."
Before going into detailed analysis of the judgment of Hon'ble Supreme Court, it is important to go into certain observation of Hon'ble Supreme court to understand the whole concept of Duty drawback and DEPB as well as the 7 I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012 contention of Hon'ble Supreme Court' in the said judgment (Liberty India).
At Para 12, Page No. 231 of ITR -
"12. In this batch of civil appeals we are concerned with admissibility of the amounts of duty drawback and DEPB for deduction under section 80-IB.
16. DEPB is an incentive. It is given under the Duty Exemption Remission Scheme. Essentially, it is an export incentive. No doubt, the object behind DEPB is to neutralize the incidence of customs duty payment on the import content of export product. Under DEPB, an exporter may apply for credit as a percentage of the FOB value of exports made in Feely convertible currency. Credit is available only against the export product and at rates specified by the DGFT for import of raw materials, components, etc., DEPB credit under the Scheme has to be calculated by taking into account the deemed import content the export product as per basic customs duty and special additional duty payable on such deemed imports. Therefore, in our view, DEPB/Duty drawback are incentives, which flow from the schemes framed by Central Government or from Section 75 of the Customs Act, 1962, hence, incentives profits are not profits derived from the eligible business under section 80- IB. They belong to the category of ancillary profits of such undertakings.
17. The next question is - what is duty drawback? Section 75 of the Customs Act, 1962 and section 37 of the Central 8 I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012 Excise Act, 1944, empower the Government of India to provide for repayment o{ customs duty and excise duty paid by an assessee. The refund is of the average amount of duty paid on materials q/ any particular class or description of goods used in the manufacture of export goods of specified class. The Rules do not envisage a refund of an amount arithmetically equal to customs duty or Central Excise Duty actually paid by an individual importer-cum- manufacturer. Sub-section (2) of section 75 of the Customs Act requires the amount the drawback to be determined on a consideration of all the circumstances prevalent in the particular trade and also based on the facts situation relevant in respect of each of various classes of goods imported. Basically. the source of the duty drawback receipt lies in Section 75 of the Customs Act and Section 37 of the Central Excise Act.
18. Analyzing the concept of remission of duty drawback and DEPB, we are satisfied that the remission of duty is on account of the statutory / policy provisions in the Customs Act/ Scheme (s) framed by the Government of India. In the circumstances, we hold that profits derived by way of such incentives do not fall within the expression "profits derived from industrial undertaking" in section 80-IB "
It has been submitted that the judgment of Hon'ble Supreme Court in the case of Liberty India (Supra) as stated by Hon'ble Supreme Court itself is applicable only on Duty Drawback and DEPB incentives available under the export 9 I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012 promotion policy of Government of India. It does not cover the issue of Cenvat Credit/ Refund available to the manufacturer under a separate notification issued by Excise authorities to Industrial Unit set up in the state of Jammu & Kashmir. That Cenvat Credit / Duty Drawback is allowed to the manufacturer of goods. This manufacturing facility should be in the State of Jammu & Kashmir. The Cenvat Credit is allowed only to the manufacturer and not to traders or other activities of the assessee even the same are being conducted by the specified unit. It is only on a condition when excisable goods are manufactured by new industrial undertaking. In the case of Cenvat Credit, the manufacturing of goods by undertaking is a pre-condition.
That it is also important to note that excise duty is available only on manufacture and is payable on removable of goods from the manufactory, Duty Drawback or DEPB is allowed only on export. It is allowable to any exporter, irrespective of facts whether he is manufacturing or not, meaning thereby that even if the exporter is not a manufacturer; the incentive in tile form of Duty drawback / DEPB will be allowed. Hence, it is a very pivotal difference between DEPB/ Duty Drawback and Cenvat Credit that in the case of Duty drawback / DEPB, it is not necessary that the exporter should be a manufacturer also but in the case of cenvat credit / refund; this is a pre-condition that the claimant (assessee) must be a manufacturer and manufacturing the same goods on which the Cenvat Credit is given. As can be observed from Para No. 16 & 17 of the judgment of Hon'ble 10 I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012 Supreme Court (Supra), DEPB is allowed as a percentage of FOB Value of export, which is made in freely convertible currency and duty drawback is a refund of ail average amount of duty payable on raw material of any particular class or description in the manufacture of export of goods.
These observations of the Hon'ble Supreme Court had two fold meaning one the duty drawback or DEPB is not the refund of the duty paid by the exporter but the deemed refund on the basis of a percentage of value of goods exported by the exporter, who may be a trader also but in the case of Cenvat Credit, it is allowed only of the amount, which is paid by the manufacturer as excise duty on manufacture of goods that too only to the manufacturing unit and not any trader. Secondly, in the case of DEPB and Duty Drawback, there is no precondition that the goods are to be manufactured by any specified undertaking by the claimant of DEPB or Duty Drawback but in the case of Cenvat credit, it is a pre-condition that goods are to be manufactured by the specified undertaking and excise duty is paid on such manufactured goods by the same industrial undertaking.
That it may kindly be observed that before the claim of DEPB / Duty Drawback, the most proximate event is export, whereas in case of Cenvat Credit / refund, the most proximate event is the manufacture, hence manufacturing is an in-extricable event for claim of cenvat credit /refund. It is the refund of same excise duty, which is paid by the 11 I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012 undertaking in cash. This payment of excise duty is on manufacture of goods by the eligible undertaking and is subsequently refunded.
In view of the above, it may kindly be observed that the facts of the appellant's case are entirely different from the facts in the case of Libel1y India Ltd."
It was further argued that the Appellant's case is basically covered by the judgment of Hon 'ble Delhi High Court in the case of Dharampal Premchand [Supra]' It was also submitted on behalf of the appellant that the only difference is that the case of Dharampal Premchand is covered by the notification applicable for North East. whereas the case of Appellant is covered by notification issued for the State of Jammu & Kashmir. The appellant has also submitted a detailed chart comparing the notifications of both the States and placed at Page No. 83 of the Paper Book. It is the contention of the appellant that since both the notification are para materia, therefore, the case of appellant is squarely covered by the judgment of Hon'ble Delhi High Court in the case of Dharmpal Premchand.
The main submission of the appellant on the applicability of Dharampal Premchand are reproduced here below :
The Hon'ble Delhi High Court after considering notification as well as the tactual position had observed as under:
"18 - As stated above, the notifications clearly mandate from excise duty is available only if the industrial activity 12 I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012 carried out by the assessee either in a new industrial undertaking in which installed capacity is increased by at least by 25%. It is thus clear that in the first notification, i.e. 32/1999 the exemption is area specific, while in the second notification, i.e. 33/1999 the exemption is specific to goods as referred to in the schedule appended to the said notification. It is thus clear that the exemption is directly relatable to industrial undertaking manufacturing goods, which are otherwise exigible to duty. The exemption is available either under Notification No. 32/1999 or under Notification No. 33/1999 dependent on where the unit is located or the type of goods manufactured by an assessee as specified in the relevant notification.
19 - To our mind, the procedure for granting of exemption is, as indicated above, that the, assessee in the first instance, pays the excise duty from its current account. The statement with respect to clearances mad, is submitted with the concerned Central Excise Authorities by the 7th of the succeeding month. The Central excise authorities after verifying the claim of the assessee are required to grant refund or excise duty paid from the current account during the month under consideration to the manufacturer / assessee by the 15th of the succeeding month. The notification further provided that in the event it was not possible for the concerned authorities to verify the claim for refund of excise duty then it had to be made on provisional basis.13
I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012
20. In these circumstances, the submissions of the learned counsel for the Revenue is that there is no direct nexus between refund of excise duty paid or that the refund of excise duty paid was dependent on the said notification is, to say the least, completely untenable."
10. Considering the above, CIT(A) has decided the issue as under:-
"I have carefully considered the submissions of the Appellant. From the perusal of the Industrial Policy announced by the Central Government for the state of Jammu & Kashmir read with the notification issued by the excise department in the state of Jammu & Kashmir, it is found that the concession given in the form of Excise Duty Refund is a production linked incentive. It is also seen that the judgment of Hon'ble Supreme Court in the case of Liberty India Ltd. is on the issue as to whether duty draw back and DEPB could be said to be profit derived from the business of the industrial undertaking u/s 80 IB of the Act. It has been observed by the Supreme Court in this case that Duty Drawback/DEPB was given to encourage export and cannot be said to be inextricably linked with the manufacturing activity. The excise duty refund in the case of the appellant is however directly linked with the manufacturing activity and is production linked incentive, which arises out of manufacturing activity of Appellant's Industrial Undertaking at Jammu. Such excise duty refund is therefore, a first degree source of receipt linked with the manufacturing activity of the undertaking. Hence it is 14 I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012 derived from the business of the industrial undertaking and falls within the parameters laid clown in Section 80IB of the IT Act.
While on the issue I have gone through the findings of my predecessor in appellant's case for AY 2006-07 in Appeal No: 427/08-09 dated 07.09.10, wherein my learned predecessor has disallowed the appellant's claim for allowing 80-IB deduction on Excise Duty refund (self Cenvat Credit). On relying upon the observation of Honourable Supreme Court in case of Liberty India Ltd. (supra) viz. "for the purpose of AS-2, Cenvat Credits should not be included in the case of purchase of inventories" & that the said decision is applicable to the facts of appellant's case too. It is however noted from the Notification No, 56/2002 of Central Excise dated 14.11,02 that the exemption contained in the notification is subject to the condition that the manufacturer first utilizes whole of the Cenvat Credit (this arises out of purchase of raw material) available to him on the last day of the month meaning thereby that no excise duty refund is eligible to the appellant till such time there remains "unutilized Cenvat Credit" available to his account. It is only when excise duty is additionally paid by the appellant, after exhausting the available Cenvat Credit that this excise duty paid is subsequently refunded to the appellant. Thus this refund is therefore directly relatable to carrying out of manufacturing activities.15
I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012 This being the factual matrix related to excise duty refund. I respectfully disagree with the above findings of my predecessor and hold that the payment of Central Excise Duty has a direct nexus with the manufacturing activity and as a natural corollary the refund of the very same Central Excise Duty also has to be held as having a direct nexus with the manufacturing activity. In fact any issue of refund of Central Excise Duty would not arise in the absence of any manufacturing carried out in the industrial undertaking. Therefore, there is an inextricable link between the manufacturing activity and payment of Central Excise Duty and its consequent refund.
Hon'ble Delhi High Court in the case· of Dharampal Premchand (Supra) had clearly distinguished the nature of income by way of Duty Draw Back / DEPB and Cenvat Credit / Refund. Therefore, respectfully following the judgment of Hon'ble Delhi High Court in the case of Dharampal Premchand (SLP filed by revenue has been dismissed by the Supreme Court -20 I 0 TIOL,-18 SC-lT), which makes a distinction between the treatment to be given to Excise Duty Refund and Duty Draw Back/DEPB, the AO is directed to treat excise duty refund as profit derived from the business of the Industrial Undertaking, while computing the 16 I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012 eligible deduction u/s. 80-IB of the Income Tax Act, of the appellant's Jammu Unit. "
11. Against the above order Revenue has filed the appeal.
12. We have heard both the counsel and perused the records. Ld. Counsel of the assessee submitted that the issue is covered in favour of the assessee by the decision of the Jurisdictional High Court in the case of Dharampal Premchand (2009) 221 CTR 133 where the Court held the refund of excise duty has a direct nexus with manufacturing activity and therefore such refund is an income derived from industrial undertaking eligible for relief u/s.80-IB. He further submitted that the decision of the Hon'ble Apex Court in the case of Liberty India Ltd. 317 ITR 218 (Supra) is not applicable. He further claimed that the decision of the Dharampal (Supra) came after the Liberty India pronouncement by the Apex Court. He further submitted that the issue has to be decided in favour of the assessee in as much as the impugned amount is capital receipt.
13. Ld. Departmental Representative on the other hand relied upon the order of the Assessing Officer and the Ld. CIT(A)'s order for the asstt. year 2006-07. However, she could not controvert the assessee's submissions that the issue is covered in favour of the assessee by the 17 I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012 decision of the Hon'ble Jurisdictional High Court in the case of Dharampal Premchand (Supra).
14. We have carefully considered the submissions and perused the records. We find ourselves in agreement with the finding of the Ld. CIT(A) that the issue is covered in favour of the assessee by the decision of the Hon'ble Jurisdictional High Court in the case of Dharampal Premchand 221 CTR 133. In this case the Hon'ble Court has held that the refund of excise duty has a direct nexus with manufacturing activity and therefore such refund is an income derived from industrial undertaking eligible for relief under section 80-IB. We further agree with the contention that Hon'ble Apex Court decision in the case of Liberty India Ltd. 317 ITR 218 is not applicable. This has been discussed in detail in preceding paragraphs. Under the circumstances, we hold that the refund of excise duty is an income derived from the industrial undertaking. Hence, the assessee is eligible for relief u/s. 80-IB on these amounts.
15. It is also noted that for the asstt year 2007-08 and 2008-09 the ld. CIT(A) has allowed the additional ground of the assessee that the issue has to be decided in favour of the assessee in as much as the impugned amount is capital receipt. However, we find that we have already held hereinabove that the assessee is eligible for deduction u/s. 80-IB on the impugned amounts and the decision of the Hon'ble Jurisdictional High Court in the case of Dharamchand Premchand (Supra) is squarely applicable. Hence, we find that the adjudication on 18 I.T.A. NOS. 5056/DEL/2010, 4013/Del/2011 & 609/Del/2012 the issue as to whether the impugned amount is capital receipt or not is only of academic interest, hence, we are not dealing with the same.
16. In the result, the appeal filed by the assessee for the asstt. year 2006-07 is allowed and both the revenue's appeals for the asstt.
years 2007-08 & 2008-09 stand dismissed.
Order pronounced in the Open Court on 03/1/2014.
Sd/- Sd/-
[I.C. SUDHIR]
SUDHIR] [SHAMIM YAHYA]
JUDICIAL MEMBER ACCOUNTANT MEMBER
Date 03/1/2014
"SRBHATNAGAR"
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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