Income Tax Appellate Tribunal - Agra
Surajn Bhan Agencies (P) Ltd., Agra vs Assessee on 31 July, 2012
IN THE INCOME TAX APPELLATE TRIBUNAL
AGRA BENCH, AGRA
BEFORE SHRI BHAVNESH SAINI, JUDICIAL MEMBER AND
SHRI A.L. GEHLOT, ACCOUNTANT MEMBER
ITA No.28/Agr/2012
Assessment Year: 2007-08
M/s Suraj Bhan Agencies (P) Ltd. vs. Dy. Commissioner of Income Tax,
19/9, Khatena Road, Circle 4(1), Agra.
Lohamandi, Agra.
(PAN: AABCS 9058 E)
ITA No.29/Agr/2012
Assessment Year: 2007-08
M/s Pee Cee Soap & vs. Dy. Commissioner of Income Tax,
Chemicals (P) Ltd., Circle 4(1), Agra.
G-10/8, Padamdeep Tower,
Sanjay Place, Agra.
(PAN: AAACP 7281 M)
(Appellants) (Respondent)
Appellants by : Shri Pankaj Gargh, Advocate
Respondent by : Shri Waseem Arshad, Sr. D.R.
Date of Hearing : 31.07.2012
Date of Pronouncement of order : 31.08.2012
ORDER
PER A.L. GEHLOT, ACCOUNTANT MEMBER:
These are appeals filed by two different assessees against two different orders dated 04.10.2011 and 02.09.2011 passed by the ld. CIT(A)-II, Agra for the A.Y. 2007-08 respectively.
2 ITA No.28 & 29/Agr/2012
A.Y. 2007-08.
2. The assessees has raised the following grounds in ITA No.28/Agr/2012 in the case of M/s. Suraj Bhan Agencies (P) Ltd. :-
"1. Because the Ld. CIT(A) has wrongly, illegally and arbitrarily confirmed the addition of Rs.16,73,022/- and Rs.18,34,474/- made by the Assessing Officer by applying the provision of section 40(a)(ia) of the Act. The Ld. CIT(A) has erred in rejecting the appellant's submission and in ignoring the facts of the case and the legal position.
2. Because considering the facts of the case and the submission made before the authorities below the provisions of TDS are not applicable on the payment of Rs.16,73,022/- and Rs.18,34,474/- and hence the Ld. CIT(A) has erred in confirming the Assessing Officer's observation in invoking the provisions of section 40(a)(ia) of the Act.
3. Because the Ld. CIT(A) while confirming the addition of Rs.16,73,022/- and Rs.18,34,474/- has erred in ignoring the legal position that section 40(a)(ia) of the Act is applicable only in the case where the amount is payable on the last day of previous year. All the payments as reimbursement of expenses has been made time to time during the year and no amount is payable on the last day of previous year. The addition on this ground is totally unwarranted and deserves to be deleted.
4. Because considering the facts of the case and the legal position the addition, as objected in the grounds of appeal mentioned above, made is wrong, bad in law and deserves to be deleted.
5. Because the Ld. CIT(A) has erred in not giving any specific finding on ground no.6 taken before him."
3. The assessees has raised the following grounds in ITA No.29/Agr/2012 in the case of M/s. Pee Cee Soap & Chemicals (P) Ltd. :-
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A.Y. 2007-08.
"1. Because the Ld. CIT(A) has wrongly, illegally and arbitrarily confirmed the addition of Rs.16,23,726/- made by the Assessing Officer by applying the provision of section 40(a)(ia) of the Act. The Ld. CIT(A) has erred in rejecting the appellant's submission and in ignoring the facts of the case and the legal position.
2. Because considering the facts of the case and the submission made before the authorities below the provisions of TDS are not applicable on the payment of Rs.16,23,726/- and hence the Ld. CIT(A) has erred in confirming the Assessing Officer's observation in invoking the provisions of section 40(a)(ia) of the Act.
3. Because the Ld. CIT(A) while confirming the addition of Rs.16,23,726/- has erred in ignoring the legal position that section 40(a)(ia) of the Act is applicable only in the case where the amount is payable on the last day of previous year. All the payments as reimbursement of expenses has been made time to time during the year and no amount is payable on the last day of previous year. The addition on this ground is totally unwarranted and deserves to be deleted.
4. Because considering the facts of the case and the legal position the addition, as objected in the grounds of appeal mentioned above, made is wrong, bad in law and deserves to be deleted.
5. Because the Ld. CIT(A) has erred in not giving any specific finding on ground no.5 taken before him.
6. Because the Ld. CIT(A) has erred in confirming the addition of Rs.79,124/- made by the Assessing Officer by invoking the provision of section 40A(3) of the Act ignoring/rejecting the appellant's submission and the facts of the case."
7. Because the Ld. CIT(A) has wrongly, illegally and arbitrarily confirmed the disallowance at Rs.10,00,000/- out of disallowance of Rs.14,79,431/- made by the Assessing Officer u/s 14A of the Income Tax Act.
8. Because while confirming the disallowance at Rs.10,00,000/- u/s 14A of the Act the Ld. CIT(A) has erred in ignoring the specific 4 ITA No.28 & 29/Agr/2012 A.Y. 2007-08.
submission made by the assessee company that section 14A of the Act is not applicable to the facts of the present case, considering the appellant's Reserve & Surplus, Loan given/taken and interest paid/received, etc.
9. Because the Ld. CIT(A) has erred in ignoring the specific submission and the legal position that interest received is much more than the interest paid and hence no disallowance out of interest paid u/s 14A of the Act can be sustained."
4. At the time of hearing before us, the ld. Representatives of the parties submitted that the grounds raised in both these appeals are based on identical set of facts, therefore, for the sake of convenience, both the appeals are decided by this common order.
5. As the grounds are based on identical set of facts, we, therefore, consider the facts of the case of M/s. Pee Cee Soap & Chemicals (P) Ltd. in ITA No.29/Agr/2012 which are as under :-
6. The brief facts relating to ground nos.1 to 5, which raise common issue, are that during the course of assessment proceedings the A.O. noticed that the assessee made payment of commission of Rs.6,89,999/- & Rs.9,33,727/- totaling to Rs.16,23,726/- to its consignee agents M/s. Deepali Marketing, Ahmedabad and M/s. Darshan Agencies, Ahmedabad respectively. However, the assessee did not deduct tax at source from the payment so made to the above consignee agents. On 5 ITA No.28 & 29/Agr/2012 A.Y. 2007-08.
being asked as to why the amount of Rs.16,23,726/- may not be disallowed under section 40(a)(ia) of the Income Tax Act, 1961 ('the Act' hereinafter), the assessee replied that both the aforesaid parties are its selling commission agents who render their services for conducting sales of the assessee's products. For this, the commission @ 4% is paid to them in addition to reimbursement of selling and redistribution expenses incurred by them on assessee's sales. The assessee has deducted tax at source on the payment of commission and since the payment of Rs.6,89,999/- and Rs.9,33,727/- (Rs.16,23,726) made to aforesaid consignee agents was towards reimbursement of expenses incurred by them on assessee's behalf, the tax at source was not deductible under the provisions of the Act. It was also contended that the consignee agents maintained day today details of such expenses which are duly debited by them in their accounts and at the month end they have credited the reimbursed amounts in the said account. Both the consignee agencies were produced before the A.O. who stated that they have received the reimbursement of delivery, distribution and selling expenses by filing copy of ledger account before the A.O. The A.O. was not satisfied with the explanation of the assessee on the following reasons :-
i) The expenses incurred have been allowed at the fixed rate of Rs.11/- per carton in lieu of services rendered by the Agents for effecting the sales irrespective of actual amount spent by the consignee. This led the A.O. to 6 ITA No.28 & 29/Agr/2012 A.Y. 2007-08.
observe that it was a fixed commission allowed to the dealers in the garb of redistribution expenses.
ii) No credit entry to the effect of reimbursement of expenses is available in the accounts of the consignee agents.
iii) In view of C.B.D.T. Circular No.715 dated 08.08.1995, there is no immunity in the Act to the assessee for not deducting the tax even on the amount of expenses reimbursed to the consignee agents.
iv) The payment made by employer to its employee/servant/agent will be either of salary or commission and since the said parties are not the salaried employees of the assessee, the payment so made to them shall be treated as commission and, as such, the assessee was legally obliged to deduct tax at source on the payment of Rs.16,23,726/- made to the consignee agents.
7. Before the CIT(A), reiterating the submissions made before the A.O., the assessee further submitted that the A.O. has recorded incorrect finding regarding payment of commission @ Rs/11/- per carton to its consignee agents. As a matter of fact, commission was paid @ 4% whereas, the payment made at Rs.11/- per 7 ITA No.28 & 29/Agr/2012 A.Y. 2007-08.
carton was towards redistribution and selling expenses for which the said agencies have maintained proper details in their accounts. The consignee agents in their statements nowhere stated that receipt of Rs.11/- per carton represents the commission. It was also submitted that expenses are incurred by the consignee agents from the sale amount collected by them and there always remained outstanding balances. It was also submitted that the A.O. has recorded incorrect finding of fact that no credit entry to the effect of reimbursement of expenses is available in their accounts. The copies of accounts of consignee agents filed before the A.O. were further submitted before the CIT(A) wherein the amounts as mentioned in the Assessment Order are duly credited to the accounts of the consignee agents. Lastly, it was contended that since the reimbursement of expenses incurred by consignee agents has been less than the actual expenses, there is no element of income in the hands of consignee agent and, therefore, the assessee is not required to deduct tax at source. Reliance was placed on the following decisions :-
i) HMS Real Estate P. Ltd., 325 ITR 71 (AAR). ii) ITAT, Delhi Bench in the case of ACIT vs. Grandprix Fab Ltd., 128 TTJ 60. iii) ITAT, Delhi Bench in the case of ITO vs. Dr. Willmar Schwabe India (P) Ltd., 3 SOT 71. (iv) ITAT, Jaipur Bench in the case of Jaipur Vidyut Vitran Nigam Ltd. vs. DCIT, 123 TTJ 888. 8 ITA No.28 & 29/Agr/2012 A.Y. 2007-08. (v) ITAT, Hyderabad Bench in the case of K. Srinivas Naidu vs. ACIT, 131 TTJ (UO) 17.
8. The CIT(A) confirmed the action of the A.O. on the ground that the payment of Rs.11/- per carton is not linked to the actual expenses incurred by the consignee agents. He observed that the contention of the assessee that the expenditure incurred by the agents is more than the amount paid to them is self defeating and in that eventuality it is not explained as to why the agents would have accepted lesser amount than that actually incurred by them. He, therefore, concluded that the payments made to the consignee agents in the garb of reimbursement of expenses was nothing but commission on which the assessee was legally obliged to deduct tax at source which he failed to do so.
9. At the outset, the ld. Authorised Representative submitted that the issue is covered by the order of I.T.A.T. Agra Bench in ITA No.434/Agr/2011 in the case of M/s. Pee Cee Cosma Sope Limited vide order dated 11.05.2012. The ld. Authorised Representative drew our attention on the relevant grounds of appeal of M/s. Pee Cee Cosma Sope Limited which are reproduced as under for ready reference:-
"1. Because the Ld. CIT(A) has wrongly, illegally and arbitrarily confirmed the addition of Rs.14,93,965/- made by the Assessing Officer by applying the provision of section 40(a)(ia) of the Act. The 9 ITA No.28 & 29/Agr/2012 A.Y. 2007-08.
Ld. CIT(A) has erred in rejecting the appellant's submission and in ignoring the facts of the case.
2. Because the Ld. CIT(A) while confirming the addition of Rs.14,93,965/- has erred in ignoring the legal position that section 40(a)(ia) is applicable only in the case where the amount is payable on the last day of previous year. All the payments as reimbursement of expenses has been made time to time during the year and n amount is payable on the last day of previous year. The addition on this ground is totally unwarranted and deserves to be deleted.
3. Because the Ld. CIT(A) has erred in not adjudicating ground no.5 taken before him."
10. The finding of I.T.A.T., Agra Bench in the said case pointed out by the ld. Authorised Representative from the said order at paragraph nos.5, 6 & 7 which are reproduced as under :-
"5. We have heard the ld. Representatives of the parties and records perused. The effective ground raised in the appeal relate to disallowance under section 40(a)(ia) of the Act, therefore, all supporting grounds of appeal are decided together. The Ld. Authorised Representative submitted that the issue is covered by the decision of I.T.A.T., Special Bench Visakhapatnam wherein it has been held that section 40a(ia) of the Act is applicable in respect of amount remained payable. There is no disallowance under section 40a(ia) of the Act with respect to payment which were actually paid during the Financial Year. In respect of ground no.2, the Ld. Authorised Representative has emphasized that there was no amount payable at the end of previous year. In ground no.3, the Ld. Authorised Representative submitted that the assessee raised the issue before the CIT(A) which has not been adjudicated. The ground no.5 taken before the CIT(A) which reads as under :-10 ITA No.28 & 29/Agr/2012
A.Y. 2007-08.
"5. Because without prejudice to the grounds as mentioned above section 40a(ia) is applicable only in the cases where the amount is payable on the last day of previous year. All the payments as reimbursement of expenses has been made time to time during the year and no amount is payable on the last day of previous year.
On this ground also the addition is wrong, illegal and deserves to be deleted."
6. The above ground no.5 raised before the CIT(A) is identical to the ground no.2 raised before us.
7. In the light of above discussion and after considering totality of the facts of the case, we find that factual verification is required in the light of decision of I.T.A.T. cited supra. We, therefore, think it proper to send this issue back to the file of the Assessing Officer with the direction to verify the facts of the case and decide the issue in accordance with the decision of I.T.A.T., Special Bench Visakhapatnam after providing opportunity of hearing to the assessee."
11. The ld. Departmental Representative did not dispute regarding the facts of the cases under consideration and the facts of the case in the case of M/s. Pee Cee Cosma Sope Limited.
12. We have heard the ld. Representatives of the parties and records perused. We notice that on identical set of facts, the issue has already been decided by I.T.A.T., Agra Bench in the case of M/s. Pee Cee Cosma Sope Limited in ITA No.434/Agr/2011 order dated 11.05.2012. Since the facts are identical, therefore, to maintain consistency, we follow the above order dated 11.05.2012 of I.T.A.T. 11 ITA No.28 & 29/Agr/2012 A.Y. 2007-08.
Agra Bench in the case of M/s. Pee Cee Cosma Sope Limited in ITA No.434/Agra/2011. In the light of that, the issue raised in ground nos.1 to 5 in ITA no.29/Agr/2009 in the case M/s. Pee Cee Soap & Chemicals (P) Limited and ground nos.1 to 5 in ITA No.28/Agr/2009 in the case of M/s. Suraj Bhan Agencies (P) Limited are decided accordingly with identical directions. The A.O. is directed accordingly.
13. Now we come to ground no.6 in ITA no.29/Agr/2009 in the case M/s. Pee Cee Soap & Chemicals (P) Limited. The brief facts relating to this ground are that during the year under consideration, the assessee had made payments to various transporters and issued TDS certificates to them, the details of which is mentioned at page 6 of the assessment order. As per AO the assessee had made payments in excess of Rs.20,000/- to some of the transporters in cash. The contention of the assessee was that every payment is less than Rs.20,000/-. Having examined the record, the AO did not accept the submission of the assessee stating that the assessee has made payment exceeding Rs.20,000/- at a time and the payments have been shown in fractions in order to mislead the revenue authorities. Instances of such payments have been given at page 7 & 8 of the assessment order. He, therefore, observed that the assessee has not been able to show as to why the payments were made in installments by splitting the same on a single day 12 ITA No.28 & 29/Agr/2012 A.Y. 2007-08.
particularly when the assessee had sufficient cash balance available with him on the relevant dates of payments. Considering all these facts and relying upon various decisions of Hon'ble M.P. High Court, Allahabad High Court and I.T.A.T., Agra Bench in the following cases, concluded that the assessee has split the payments made in cash exceeding to Rs.20,000/- to circumvent the provisions of section 40A(3) of the Act and therefore, disallowed Rs.79,124/- by invoking the provisions of section 40A(3) :-
i) Shri Radhika Prakashan (Raipur) Pvt. Ltd. vs. CIT, 257 ITR 675 (MP)
ii) Engineers & Agents, 5 ITD 606 (Allahabad)
iii) ITA No.465/Agr/2004 order dated 28.07.2007 in the case of Shri Laxman Singh Prop. BSA Sales Corporation, Agra.
14. The CIT(A) confirmed the addition observing that the payments made towards a single G.R. has been split in a single day to bring it below Rs.20,000/- and if the payment exceeding to Rs.20,000/- was made to same party in a single day, the amount should have been paid by account payee cheque/draft. He, therefore, concluded that the AO has rightly made disallowance u/s. 40A(3) of the Act.
13 ITA No.28 & 29/Agr/2012
A.Y. 2007-08.
15. We have heard the ld. Representatives of the parties and records perused. We find substance in the submission of the ld. Authorised Representative that when the payment is made in cash below Rs.20,000/- for separate bills, the disallowance is not warranted under section 40A(3) of the Act. The ld. Authorised Representative drew our attention at page no.52 of the assessee's Paper Book and submitted that out of the grand total Rs.3,95,630/- on which the A.O. has disallowed 20% out of which such separate bills below Rs.20,000/- are Rs.1,77,538/- roughly. Therefore, the assessee is entitled for the relief on that amount on account of disallowance under section 40A(3) of the Act. When the cash payment is below Rs.20,000/-, we are of the considered view that no disallowance is warranted on such payments. However, the contention of the ld. Authorised Representative and the details pointed out from page no.52 of the Paper Book is subject to verification. We, therefore, direct the A.O. to verify the fact that whether there are separate bills below Rs.20,000/- and recalculate the disallowance after allowing benefit of separate bills of below Rs.20,000/-, after providing opportunity of hearing to the assessee.
16. Now we come to ground nos.7 to 9 in ITA no.29/Agr/2009 in the case M/s. Pee Cee Soap & Chemicals (P) Limited which is in respect of disallowance of Rs.10,00,000/- under section 14A of the Act.
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A.Y. 2007-08.
17. The brief facts of the issue are that during the assessment proceedings the A.O. noticed that the assessee has made investment to M/s. Pee Cee Housing & Construction Limited and M/s. Pee Cee Cosma Sope Limited to the extent of Rs.5,07,07,200/- and Rs.24,33,582/- to earn exempt income. The A.O. invoked section 14A of the Act read with Rule 8D and made disallowance of Rs.14,79,431/-. The CIT(A) sustained the disallowance to the extent of Rs.10,00,000/- by rejecting the assessee's contention that no interest bearing funds have been invested to earn exempt income. However, the CIT(A) in principle agreed with the judgment of Bombay High Court in the case of Godrej and Boyce Manufacturing Co. vs. DCIT, 328 ITR 71 (Bombay) that rule 8D has to be applied prospectively and is applicable w.e.f. A.Y. 2008-09 but it does not mean that no disallowance is called for.
18. At the outset, the ld. Authorised Representative submitted that the issue is squarely covered by the order of I.T.A.T, Agra Bench in the case of M/s. Pee Cee Soaps & Chemicals (P) Ltd. i.e. the assessee's own case in ITA No.236/Agr/2011 for A.Y. 2006-07, order dated 20.04.2012. The relevant finding of I.T.A.T. in the said order is reproduced from paragraph nos.6, 7 & 8 as under of which copy is placed at page nos. 62 to 69 of the assessee's Paper Book :- 15 ITA No.28 & 29/Agr/2012
A.Y. 2007-08.
"6. We have heard the ld. Representatives of the parties and records perused. The Assessing Officer made out the case that section 14A of the Act read with rule 8D of which the effect is retrospective and applicable to Assessment Year 2006-07, the year under consideration. The Assessing Officer disallowed the amount calculated under Rule 8D of IT Rules. The CIT(A) did not agree with the view that Section 14A read with Rule 8D is applicable in the year under consideration following a judgement of Bombay High Court in the case of Godrej & Boyce Mfg. Co. Ltd., 234 CTR (Bombay) 1 wherein it has been held that rule 8D read with section 14A is applicable w.e.f. Assessment Year 2007-08.
7. The Ld. Representatives of parties admitted that the Revenue did not file any appeal against this finding of the CIT(A). Thus, the controversy relating to whether section 14A of the Act read with rule 8D is applicable in the year under consideration, Assessment Year 2006-07, or not became final as Revenue did not file any appeal against the order of CIT(A) wherein it has been held that section 14A read with rule 8D is applicable w.e.f. 2007-08. However, the presumption of the CIT(A) was that some borrowed funds have been diverted to investment in shares of which income is exempt. The Ld. Authorised Representative pointed out the position of share capital, reserve & surplus, unsecured loan etc. and loan given and investment in shares. The details which is pointed out from order of the CIT(A) at page no.2 reads as under :-
"Share Capital Rs.44,50,000/-
Reserve and Surplus Rs.12,59,74,541/-
Unsecured Loan NIL
Secured Loan:-
O.D. Limit Rs.2,52,72,561/-
Vehicle Loan Rs.15,50,588/- Rs.2,68,23,149/-
Loan given Rs.5,15,88,194/-
Interest received Rs.60,36,620/-
Interest paid Rs.34,81,490/-
Investment in shares Rs.5,28,01,422/-"
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A.Y. 2007-08.
8. After considering the totality of the facts of the case, the limited issue to be decided before us is whether the interest claim of the assessee is disallowable on the ground that the assessee has used the interest bearing borrowed funds in the investment of shares. The claim of interest on borrowed fund is allowable under section 36(1)(iii) of the Act. According to the said section 36(1)(iii) the amount of interest paid in respect of capital borrowed for the purpose of business or profession is allowable expenses so long as the amount borrowed is used in the business. The interest paid on such borrowing is an expenditure which is required to be deducted in the computation of the income from business. To examine the problem in cases where funds are pumped out of the business which are comprised of both type of funds i.e. borrowed as well as own funds, for non-business purpose. In all such cases where mixed funds are used for business and other than business purposes in such circumstances the I.T.A.T., Mumbai Bench in the case of ACIT vs. H.P. Shah & Co. ITA No.3694/M/2006 order dated 15.01.2009 held that there is no presumptions that money used for other purposes came out of borrowed funds. It can be said that interest free funds given on investment if are out of own funds, i.e. own capital and reserves is sufficient to cover such interest free investment. In that circumstances, it is presumed that the investment in interest free funds were out of own capital and reserves and under such circumstances, the Revenue cannot disallow interest claim of the assessee under section 36(1)(iii) of the Act. The Allahabad High Court in the case of CIT vs. Prem Heavy Engineering Works Pvt. Ltd., 285 ITR 554 (Alld.) wherein it has been held that if the assessee had adequate interest free funds by way of proprietary capital or by way of interest free deposits from customers, there is inference that borrowed funds are not diverted for non-business purposes. The Apex Court in the case of Munjal Sales Corporation vs. CIT(A) 298 ITR 298 wherein law laid down that interest free funds to sister concern out of own funds, the disallowance cannot be made under section 36(1)(iii) of the Act. The Ld. Authorised Representative relied upon various decisions of which gist has been filed but these decisions related to the invocation of section 14A of the Act. These cases have been decided by the Court/Bench considering the facts of respective cases. In the light of above discussions and judicial pronouncements noted above, if we consider the facts, we find that the assessee was having share capital of Rs.44,50,000/- and reserve and surplus of Rs.12,59,74,541/- out of 17 ITA No.28 & 29/Agr/2012 A.Y. 2007-08.
which the investment in shares was Rs.5,28,01,422/-. Thus, we find that the assessee was having sufficient own funds in the form of share capital and reserves to make investment in shares. Under the circumstances, no disallowance is required under section 36(1)(iii) of the Act. In the light of the fact, we do not agree with the finding the CIT(A) which is on presumption basis that borrowed funds has been diverted to investment in shares and that part of the order of CIT(A) is set side and delete the addition of Rs.8,00,000/- sustained by him.
19. The ld. Departmental Representative did not dispute as regards to the facts of the case under consideration and the facts of the case in earlier year i.e. 2006-07. Since the facts are identical, therefore, we follow the above order of I.T.A.T. in assessee's own case for A.Y. 2006-07. The A.O. is directed to calculate the disallowance, if any, in accordance with the above order of the I.T.A.T., keeping in mind that the assessee was having share capital of Rs.44,50,000/- and reserve and surplus of Rs.12,76,48,308/- as interest free fund available with the assessee. The A.O. is directed accordingly.
20. In the result, both the appeals of the assessees are allowed for statistical purposes.
(Order pronounced in the open Court)
Sd/- Sd/-
(BHAVNESH SAINI) (A.L. GEHLOT)
Judicial Member Accountant Member
PBN/*
18 ITA No.28 & 29/Agr/2012
A.Y. 2007-08.
Copy of the order forwarded to:
1. Appellant
2. Respondent
3. CIT (Appeals) concerned
4. CIT concerned
5. D.R., ITAT, Agra Bench, Agra
6. Guard File.
By Order
Sr. Private Secretary
Income-tax Appellate Tribunal, Agra
True Copy