Income Tax Appellate Tribunal - Pune
Hemraj S. Mundada, Pune vs Assessee on 5 December, 2013
IN THE INCOME TAX APPELLATE TRIBUNAL
PUNE BENCH "A", PUNE
Before Shri Shailendra Kumar Yadav, Judicial Member,
and Shri R.K. Panda, Accountant Member.
ITA.No.1328/PN/2009
(Assessment Year 2006-07)
Hemraj S. Mundada,
16/1, Parvati Chambers,
Karve Road, Pune - 411038
PAN No.AAXPM1636D .. Appellant
Vs.
Addl.CIT, Range-3, Pune .. Respondent
Assessee by : Shri Sunil Pathak
Revenue by : Shri P.L. Pathade
Date of Hearing : 05-12-2013
Date of Pronouncement : 03-02-2014
ORDER
PER R.K. PANDA, AM:
This appeal filed by the assessee is directed against the order dated 22-09-2009 of the CIT(A)-II, Pune relating to Assessment Year 2006-07.
2. Facts of the case, in brief, are that the assessee is a partnership firm engaged in the business of Builders/Promoters and Developers. It filed its return of income on 30-10-2007 declaring total income of Rs.1,23,11,186/-. During the course of assessment proceedings the AO noted that the assessee during the year has shown sales from 2 Projects "Leela Garden" and "Hill View Residency" the income from which has been claimed as deduction u/s.80IB(10). He has also shown sales from 3 projects namely, Anandvan, Gulmohar and Vrindavan Commercial complex, the profit from which has been offered to tax. The AO examined the various details furnished by the assessee from time to time during the course of assessment proceedings. He observed that the 2 2 projects "Leela Garden" and "Hill View Residency" are not qualified for deduction u/s.80IB(10) for the reasons that the completion certificates are not available and that some residential units in "Leela Garden" are over 1500 sq.ft. He referred both the projects to the Registered Valuer who reported that out of the total 81 flats in "Leela Garden" 25 flats are having area of more than 1500 sq.ft. and final completion certificate has not been issued. In respect of "Hill View Residency" he reported that although the flats are less than 1500 sq.ft. , however, only part completion certificate has been obtained and completion certificates of Buildings D and E are not obtained.
2.1 In view of the above the AO asked the assessee to explain as to why the deduction u/s.80IB(10) claimed by the assessee on the profit of the above 2 projects should not be disallowed. The assessee submitted that the project "Leela Garden" fulfils both the criteria regarding the commencement and completion because the part completion certificate issued by the PMC is practically not part completion but full completion. As regards the objection on the ground that some of the flats in the projects are having area of more than 1500 sq.ft., the assessee referred to the decision of the Hon'ble Supreme Court in the case of Bajaj Tempo Vs. CIT reported in 196 ITR 188 (SC) according to which the taxing statute granting incentives for promoting the growth and development should be considered liberally so as to help the growth and development and therefore the proposed disallowance of the claim u/s.80IB(10) amounting to Rs.4,90,97,649/- should be dropped. As regards the project "Hill View Residency" is concerned it was argued that the final completion certificate in respect of Buildings D and E is not issued. 3 Relying on various decisions it was submitted that proportionate allowance of deduction should be allowed to the assessee on the projects which are completed and for which completion certificate has been issued by competent authority.
3. However, the AO was not fully satisfied with the explanation given by the assessee. He noted that the claim of the assessee regarding completion in respect of project "Leela Garden" is accepted because the PMC vide its letter dated 19-12-2008 has clarified that the project is complete and the part completion certificate issued on 12-05-2006 should be treated as final completion certificate. However, as regards the claim of the assessee for giving proportionate allowance of the deduction, the AO noted that there is no such provision in the Income Tax Act, 1961 which allows proportionate deduction. According to her, for claiming deduction u/s. 80IB(10), the project should satisfy all the conditions cumulatively.
3.1 As regards the decision of the Hon'ble Supreme Court in the case of Bajaj Tempo (Supra) relied on by the assessee she noted that it is true that a liberal view has to be taken in construing the provisions of the Act which are beneficial to the assessee but liberal view does not mean going against the spirit or intent of the law. Since the assessee has not fulfilled all the conditions prescribed u/s.80IB(10) in respect of "Leela Garden"
the AO disallowed the claim of deduction of Rs.4,90,97,647/- claimed u/s.80IB(10).4
3.2 As regards the claim of deduction u/s.80IB(10) in respect of the project "Hill View Residency" is concerned, the AO noted that the assessee himself has admitted that the final completion certificate in respect of Buildings D and E has not been issued. Rejecting the claim of proportionate deduction for the part of the project for which part completion certificate has been issued and holding that there is no provision of proportionate allowance in the Act, the AO disallowed the claim of deduction u/s.80IB(10) amounting to Rs.81,71,409/- in respect of the project "Hill View Residency". In appeal the Ld.CIT(A) upheld the action of the AO.
4. Aggrieved with such order of the CIT(A) the assessee is in appeal before us with the following grounds :
"1. On the facts and the circumstances of the case, the Ld.CIT(A)-II, Pune, has erred in confirming the addition of Rs.4,90,97,647/- made by the Ld. Addl.CIT, Range-3, Pune, disallowing the claim of deduction made by the assessee u/s.80IB(10) of Income Tax Act, 1961 on the ground that the entire project of Leela Garden is not eligible for deduction u/s.80IB(10) as some of the floats having built up area more than 1500 sft.
2. On the facts and the circumstances of the case, the Ld.CIT(A)-II, Pune, has erred in confirming the addition of Rs.71,71,409/- made by the Ld. Addl.CIT, Range-3, Pune, disallowing the claim of deduction made by the assessee u/s.80IB(10) of the Income Tax Act, 1961 on the ground that the entire project of Hill View Residency is not completed in the year under appeal.
It is, therefore, considering the intent of incentive provisions of law, humbly prayed that the addition of Rs.81,71,409/- be deleted and claim of deduction u/s.80IB(10) be allowed in full as the profit has been made out on "Completion Contract Method" which is followed consistently by the assessee"
5. The Ld. Counsel for the assessee strongly opposed the order of the CIT(A). Referring to Page 6 of the Paper Book he submitted that out of the total 83 flats in the project "Leela Garden" 61 flats are having area less than 1500 sq.ft. and only 22 flats are having area of more than 1500 5 sq.ft. Referring to page 21 & 22 of the Paper book he submitted that the assessee has claimed deduction only in respect of those flats whose built up area was less than 1500 sq.ft. Referring to the decision of the Pune Bench of the Tribunal in the case of M/s. Rahul Construction Co. Vs. ITO vide ITA No.1250/PN/2009 and ITA No.707/PN/2010 order dated 30-03-2012 for A.Y. 2006-07 and 2007-08 and the decision of the Mumbai Bench of the Tribunal in the case of Mudhit Madanlal Gupta Vs. ACIT reported in 51 DTR 217 he submitted that assessee is entitled to proportionate deduction. He submitted that following the decision of the Hon'ble Calcutta High Court in the case of Bengal Ambuja Housing Development and various other decisions the Coordinate Benches of the Tribunal are allowing proportionate deduction to the assessees. He accordingly submitted that for the project "Leela Garden" proportionate deduction should be allowed to the assessee in respect of 61 flats. 5.1 So far as the claim of deduction in respect of project "Hill View Residency" is concerned he referred to page 2 of the Paper book and submitted that the said project was commenced on 24-04-2002. Referring to page 1 of the Paper book he submitted that the total area of the project "Hill View Residency" at Varje is 6858.96 sq.mtrs. He submitted that out of the total 5 Buildings, i.e. A to E, he submitted that Buildings A, B, C, and E are completed before 31-03-2008 and Building D is not complete before 31-03-2008. He submitted that the assessee has claimed deduction u/s.80IB(10) in respect of profits from Buildings A, B, C and E. Referring to page 4 of the paper book he submitted that completion certificate for Buildings A, B and C has been obtained on 13- 01-2005. Referring to page 5 of the paper book he submitted that 6 completion certificate in respect of Building E has been obtained on 07- 11-2007. He submitted that the assessee has obtained completion certificate for Building D on 23-07-2008. He submitted that during the impugned assessment year the assessee had completed Buildings A, B, C and E and had profits received only from Buildings A, B and C. Further, the total built up area of Buildings A, B, C and E are 5102.83 sq. mtrs. Referring to the decision of the Pune Bench of the Tribunal in the case of Runwal Multihousing vide ITA Nos. 1015 to 1017/PN/2011 order dated 27-11-2012 for A.Yrs. 2003-04 to 2005-06, decision in the case of M/s. Rahul Construction Co. Vs. ITO vide ITA No.1250/PN/2009 and ITA No.707/PN/2010 order dated 30-03-2012 for A.Y. 2006-07 and 2007-08 and the decision of the Mumbai Bench of the Tribunal in the case of Mudhit Madanlal Gupta reported in 51 DTR 217 he submitted that deduction u/s.80IB(10) should be allowed in respect of 4 buildings. Referring to the decision of Hon'ble Bombay High Court in the case of Vandana Properties vide ITA No.3633/PN/2009 and ITA No.4361/PN/2010 order dated 28-03-2012, (a copy of which is placed at paper book at pages 64 to 79) he submitted that in view of the ratio of decision of the jurisdictional High Court, the assessee is entitled to deduction u/s.80IB(10) in respect of the Buildings, A, B, C and E for which the completion certificate has been obtained by the assessee before 31-03-2008.
5.2 The Ld. Counsel for the assessee also relied on the following decisions :
"1. DCIT Vs. Brigade Enterprises (P) Ltd. reported in 119 TTJ 269 (Bang).
2. DCIT Vs. Aditya Developers - ITA No.791& 792/PN/2008 order dated 30-01-2012.7
3. CIT Vs. Vandana Properties in ITA No.3633/2009 and ITA No.4361/2010 order dated 28-03-2012.
4. Bengal Ambuja Housing Development Ltd. Vs. DCIT-ITA No.1595/Kol/05 order dated 24-03-2006.
5. Magarpatta Township Development & Construction Co. Vs. DCIT-ITA No.822/PN/2011 and ITA No.04/PN/2012 order dated 18-09-2012.
6. CIT Vs. Arun Excello Foundations Pvt. Ltd. reported in 212 Taxman 342 (Madras).
7. Suresh L. Wadhwa (HUF)- ITA No.4743/Mum/2009 order dated 31- 12- 2012.
8. Siddhivinayak Kohinoor Venture Vs. Addl. CIT-ITA Nos.1112 & 1527/PN/2011 order dated 31-10-2013."
6. The Ld. Departmental Representative on the other hand heavily relied on the order of the CIT(A). He submitted that in the case of "Leela Garden" project out of 83 flats only 61 flats conformed to the area prescribed u/s.80IB(10), i.e. less than 1500 sq.ft. whereas in case of 22 flats the area is more than 1500 sq.ft. Similarly, in the case of the project "Hill View Residency" the assessee has not received the completion certificate in respect of Buildings D and E before the statutory date of 31- 03-2008. He submitted that the Act does not allow for proportionate disallowance and for obtaining the benefit of deduction u/s.80IB(10) the assessee has to fulfil all the conditions cumulatively. He submitted that the various decisions relied on by the Ld. Counsel for the assessee are distinguishable and not applicable to the facts of the present case. Since the assessee has not fulfilled all the conditions prescribed u/s.80IB(10) for both the projects, therefore, he submitted that the order of the Ld.CIT(A) being in consonance with the statutory provisions of section 80IB(10), the same should be upheld.
7. We have considered rival arguments made by both the sides, perused the orders of the Assessing Officer and the CIT(A) and the Paper Book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find in the instant case the 8 Assessing Officer disallowed the claim of deduction u/s.80IB(10) in the projects "Leela Garden" and "Hill View Residency" on the ground that the assessee has not fulfilled all the conditions prescribed u/s.80IB(10). 7.1 So far as the denial of deduction u/s.80IB(10) in respect of the housing project "Leela Garden" is concerned, we find the assessee has obtained the completion certificate before the statutory due date and the grievance of the Revenue is that out of 83 flats only 61 flats conform to the area of less than 1500 sq.ft. and in case of 22 flats the area exceeds 1500 sq.ft. It is the case of the assessee that he has claimed proportionate deduction in respect of 61 flats only and has not claimed deduction u/s.80IB(10) in respect of the 22 flats where the area of each flat exceeds 1500 sq.ft. It is the case of the revenue that there is no such case for proportionate deduction u/s.80IB(10) and each flat in the project should be less than 1500 sq.ft. The area of proportionate deduction u/s.80IB(10) where some of the flats exceed the prescribed limit of 1500 sq.ft. has been favourably decided by the Tribunal in various cases following the decision of the Hon'ble Calcutta High Court in the case of Bengal Ambuja Housing Development Ltd. We find the Kolkata Bench of the Tribunal in the aforesaid case vide ITA No.1295/Kol/05 order dated 24- 03-2006 for the A.Y. 2002-03 has allowed the claim of pro-rata deduction u/s.80IB(10) in respect of units having individual area of less than 1500 sq.ft. When the Revenue challenged the order of the Tribunal the Hon'ble High Court confirmed the order of the Tribunal vide its order dated 05-01-2007 and the appeal filed by the Revenue has been dismissed.
97.2 We find the Pune Bench of the Tribunal in the case of D.S. Kulkarni Developers Ltd. and various other cases has upheld similar proposition following the aforesaid precedents. The Coordinate Benches of the Tribunal are consistently taking the view that deduction u/s.80IB(10) has to be allowed on proportionate basis with reference to the qualified residential units and that the assessee would not be denied claim of deduction u/s.80IB(10) of the Act, in entirety, if some of its residential units were of built up area exceeding the limit prescribed in clause (c) to section 80IB(10) of the Act.
7.3 Since in the instant case the assessee has obtained the completion certificate before 31-03-2008 and out of the 83 flats the assessee has claimed deduction u/s.80IB(10) in respect of 61 flats where the built up area is less than 1500 sq.ft. and has not claimed the deduction u/s.80IB(10) in respect of 22 flats where the built up area exceeds 1500 sq.ft., therefore, following the consistent view of the Coordinate Benches of the Tribunal we hold that the assessee is entitled to deduction u/s.80IB(10) in respect of the 61 flats of the housing project "Leela Garden".
7.4 So far as the denial of deduction u/s.80IB(10) in respect of the "Hill View Residency" is concerned we find out of the 5 Buildings, i.e. A,B,C,D and E, the assessee has obtained completion certificate in respect of Buildings A, B, C and E before 31-03-2008. Thus, out of the 5 Buildings, the assessee was able to obtain completion certificates for 4 Buildings and therefore it is the case of the assessee that the deduction u/s.80IB(10) should be allowed in respect of the 4 Buildings. It is the 10 case of the Revenue that since the completion certificate for Building D has not been obtained before 31-03-2008, therefore, deduction u/s.80IB(10) should not be allowed.
7.5 We find the Coordinate Bench of the Tribunal in the case of Runwal Multihousing Pvt. Ltd., (Supra) has observed as under :
"21. So far as the second grievance of the Revenue that Building Nos. B and F are not constructed and therefore the project has not been completed as per the approved plan, we find the buildings A, C, D, E and the 17 row houses are constructed on a plot area of more than 1 acre, none of the flats/row houses is beyond 1500 sq.ft. and the completion thereof has been over before 31-03-2008 in view of our findings above.
21.1 We find the Pune Bench of the Tribunal in the case of M/s. Rahul construction Co. Vs. ITO - ITA No.1250/PN/2009 and ITA No.707/PN/2010 order dated 30-03-2012 has held as under :
"8. Considering the above submission, and having gone through the orders of the authorities below, material available on record and the decisions relied upon, we find that the issue involved is as to whether the assessee had completed the housing project within the prescribed time limit since the date of first approval of the project by the PMC.
9. To decide the above issue, it is necessary to decide firstly as to what would be first date of approval of the housing project by the PMC to compute the time limit prescribed for completion of the project to take benefit of deduction u/s. 80 IB (10) of the Act. There is no dispute on some material facts that out of 16 buildings in the housing project of the assessee only 11 buildings were completed within the prescribed time limit upto 31st March 2008. The lay out plan in respect of entire complex was sanctioned by PMC vide order No. DPO/45/D/646 dated 3.4.2003 and the building plan was sanctioned vide Commencement Certificate No. 4269 dt. 29.4.2003. Admittedly, the term "housing project" has not been defined in the Income Tax Act but in the context of deduction u/s. 80IB(10) an Explanation has been provided below clause (a) to sub-section (10) to Section 80 IB. For a ready reference, the said Explanation is being reproduced hereunder :
(i) in a case where the approval in respect of the housing project is obtained more than once, such housing project shall be deemed to have been approved on the date on which the building plan of such housing project is first approved by the local authority.
(ii) the date of completion of construction of the housing project shall be taken to be the date on which the completion 11 certificate in respect of such housing project is issued by the local authority."
The very reading of above Explanation (i), it makes clear that for the eligibility of the deduction provided u/s. 80 IB (10) of the Act, the date on which building plan of such housing project has been firstly approved by the local authority will be treated as approval in respect of the housing project. When we read Explanation (ii) with Explanation (i) it makes clear that completion of construction of such building plan first approved by the local authority will be taken the date of completion of construction of such building plan when completion certificate has been issued by the local authority. In other words, in clause (i) of the Explanation, it has been made clear that would be the housing project, first approval of which, by the local authority would be taken as starting point of the Housing Project and in clause No. (ii), it has been made clear that what would be the Completion Certificate in respect of such housing project issued by local authority to compute the prescribed time limit for verification of eligibility of assessee for the claimed deduction. In view of the above explanation, we find substance in the contention of the ld. A.R. that approval of the housing project and approval of building plan are two different concepts. The Bangalore Bench of the Tribunal in the case of DCIT Vs. Brigade Enterprises (P) Ltd. (Supra) has held that plan for development is only a work order and not final plan sanctioned by the local authority. For any project, there could not have been a plan without submission of the detailed building plans, by the architect and what requisite details required to be submitted for approval of the building plans by the local authority. In the case of Saroj Sales Organization Vs. ITO (Supra), before Mumbai Bench, almost similar facts as before us were there. The commencement certificate in respect of six wings in Block 'N' was separately received by the assessee and all the flats in Block were less than 1000 sq.ft. It was held by the Tribunal that it is not upon to the revenue to include block 'BC' as part of block 'N' just to deny relief to the assessee u/s. 80 IB(10). The Tribunal observed that Block "BC" was meant for higher strata of the Society had been kept separately by assessee in all the respect, assessee had not claimed relief u/s. 80IB in respect of Block "BC" . In the case of Mudhit Madanlal Gupta Vs. ACIT (Supra ) before the Mumbai Bench, it has been held that the housing project does not necessarily have to be various group of buildings constructed on that particular land, but it can also be a particular building or any building which is part of a large project. It has been further held that whatever portion of the housing project is otherwise found to be eligible has to be considered as a housing project for the purpose of deduction u/s. 80 IB (10) of the Act. Similar view has been expressed by Mumbai Bench of the Tribunal in the case of Vandana Properties Vs. ACIT (Supra).
12
10. In view of above discussion, we come to the conclusion that for verification of eligibility of benefit claimed u/s. 80 IB (10) of the Act by the assessee on buildings A1 to A5 in "Atul Nagar"
and buildings B1 to B6 in "Rahul Nisarg Co-Operative Housing Society Ltd.", the assessing authority has to verify as to when the building plans for these buildings were firstly approved by the local authority and taking the said date of approval a starting point, he has to verify as to whether these buildings were completed within the prescribed time limit i.e. 31st March 2008 on the basis of the Completion Certificate in respect of such housing project issued by the PMC. When we examine the facts of the present case under the above background, we find that the authorities below have not disputed the fact furnished in this regard by the assessee that under the project "Atul Nagar"
consisting of buildings A1 to A5, the first building plan for A type was approved by the PMC on 29.4.2003 vide Commencement Certificate No. 4269 (page No. 4 of the paper book). However, actual construction of A type building was executed as per the revised plan vide No. C.C. 4101/27/6/2003 (PAGE No. 5 of the paper book). The size of the plot on which the A type building i.e. A1 to A6 have been constructed is 1,39,466 sq.ft. The project A type building i.e. A1 to A5 consists of 360 residential units and the construction has been completed between 10.1.2005 to 31.8.2005 (page Nos. 6 to 9 of paper book). The authorities below have also not disputed this material fact that residential units has a maximum built up area of 1500 sq.ft. Likewise, these material facts that B Group buildings in "Rahul Nisarg Co-operative Housing Society Ltd.," have been constructed on land area of 138203 sq.ft., has not been denied by the authorities below. They have also not denied these material facts that the first building plan was sanctioned on 29.4.2003 vide Commencement Certificate No. 4269 issued by the PMC (Page No. 16 of the Paper Book). The other material facts like actual construction was executed as per the revised plan sanction on 20th March 2004 vide CC No. 2225 (page No. 17), the project consists of 396 flats and construction of these flats have been completed on 14.7.2006 as per the Completion Certificate issued by the PMC (Page Nos. 13 to 18 of paper book) are not in dispute. The authorities below have also not denied that built up area of each of these flats does not exceed 1500 sq.ft. It is also not in dispute that both the projects are entirely a residential project and there is no commercial area therein. Under the above circumstances, we are of the view that the assessee is very much entitled to the claimed deduction u/s. 80 IB (10) of the Act on the buildings A1 to A5 in "Atul Nagar" and buildings B1 to B6 in "Rahul Nisarg Co-operative Housing Society Ltd." The issue is therefore decided in favour of the assessee. We thus while setting aside the orders of the authorities below on the issue, direct the A.O to allow the claimed deduction u/s. 80 IB(10) in question. The related grounds are accordingly allowed." 21.2 We find that Bangalore Bench of the ITAT in the case of Dy.CIT Vs. Brigade Enterprises (P) Ltd. [119 TTJ 269 (Bang.)] has observed as under:
13
Deduction under S.80IB - Income from developing and building housing project - Different units of a group project - where some of the residential units in a bigger housing project, treated independently, are eligible for relief under s.80IB(10), relief should be given pro rata and should not be denied by treating the bigger project as a single unit, more so, when assessee obtained all sanctions, permissions and certificates for such eligible units separately - Assessee undertook a development project in an area of
22 acres 19 guntas consisting of 5 residential blocks, row houses, oak tree place, a club, a community centre, a school and a park and claimed deduction under s. 80IB(10) in respect of two residential units only which if taken separately, were eligible for the relief - AO treated the entire project as a single unit and denied relief under s.80IB(10) in entirety - CIT(A) allowed relief under s. 80IB(10) treating the said two units as independent units - Justified - Material on record showed that the various local authorities duly inspected the plot and sanctioned plan for each of the blocks separately - Group housing approval was approval of a master plan as a concept - Further, the use of the words "residential units" in cl.(c) of s.80IB(10) means that deduction should be computed unit- wise - Therefore, if a particular unit satisfies the condition of s.80IB, the assessee is entitled for deduction and it should be denied in respect of those units only which do not satisfy the conditions - Again, the accounting principles would also mandate recognition of profits from each unit separately".
21.3 In view of the above decisions, we are of the considered opinion that whatever portion completed by the assessee which satisfies the conditions prescribed u/s.80IB(10) is eligible for deduction. The various decisions relied on by the revenue are distinguishable and not applicable to the facts of the present case. We accordingly hold that the assessee is eligible for deduction u/s.80IB(10) in respect of building No. A,C,D, E and the 17 row houses. The grounds raised by the assessee on this issue are accordingly allowed.
22. In the result, the appeal filed by the assessee is partly-allowed." 7.6 Similar view has been taken by the Coordinate Benches of the Tribunal in various other decisions relied on by Ld. Counsel for the assessee. Since in the instant case the assessee has claimed deduction u/s.80IB(10) in respect of Buildings A, B, C on which profit has been earned on sale of units and the completion certificate has been obtained before the statutory date and none of the units in the above building is in excess 1500 sq.ft., therefore, following the decision of the Coordinate Bench of the Tribunal in the case of Runwal Multihousing Pvt. Ltd., (Supra) and various other decisions we hold that the assessee is entitled 14 to deduction u/s. 80IB(10) in respect of buildings A, B and C of the project "Hill View Residency".
7.7 In view of the above discussion, we set-aside the order of the CIT(A) and direct the Assessing Officer to allow the claim of deduction u/s.80IB(10) in respect of the housing projects "Leela Garden" and "Hill View Residency". The grounds raised by the assessee are accordingly allowed.
8. In the result, the appeal filed by the assessee is allowed.
Pronounced in the Open Court on 03-02-2014.
Sd/- Sd/-
(SHAILENDRA KUMAR YADAV ) ( R.K. PANDA )
JUDICIAL MEMBER ACCOUNTANT MEMBER
satish
Pune, dated 3rd February 2014
Copy of the order is forwarded to:
1. The Assessee
2. The Department
3. The CIT(A)-II, Pune
4. The CIT-II, Pune
5. The DR "A" Bench, Pune.
6. Guard File
By Order
// True Copy //
Senior Private Secretary,
Income Tax Appellate Tribunal, Pune