Income Tax Appellate Tribunal - Mumbai
Smira Charitable Trust, Mumbai vs Assessee
आयकर अपील य अ धकरण "E" यायपीठ मुंबई म।
IN THE INCOME TAX APPELLATE TRIBUNAL "E" BENCH, MUMBAI
ी बी. आर. म ल, या यक सद य एवं ी डी. क णाकर रावु, लेखा सद य के सम ।
BEFORE SHRI B.R. MITTAL, JM AND SHRI D. KARUNAKARA RAO, AM
आयकर अपील सं./I.T.A. No.7101/M/2012
( नधारण वष / Assessment Year:2012-2013)
Samria Ch arit able Trust, बनाम/ DI T (E),
2E, Cou rt Chambers, 35 New Vs. 6 t h Fl oor, Pi ramal Ch amber s,
Ma ri ne Lines, Mumba i - 400020. Pa rel, Mumb ai - 40 0 012.
थायी ले खा सं . / PAN :A ALTS 4318 L
(अपीलाथ /Appellant) .. ( यथ / Respondent)
अपीलाथ क ओर से / Assessee by : Shri R.S. Samira, AR
यथ क ओर से/ Revenue by : Shri Manoj Kumarm, DR
सन
ु वाई क तार ख /Date of Hearing : 20.5.2 01 3
घोषणा क तार ख /Date of Pr onouncement : 5.6.20 13
आदे श / O R D E R
PER D. KARUNAKARA RAO, AM:
This appeal filed by the assessee on 27.11.2012 is against the order of DIT (Exemption), Mumbai dated 27.9.2012 for the assessment year 2012-2013.
2. In this appeal, assessee raised the following grounds which read as under:
"1. On the facts and in the circumstances of the case, the DIT (E), Mumbai has erred in rejecting the application of appellant Trust for registration u/s 12A / 12AA vide his order dated 27th September, 2012 u/s 12AA(1)(b)(ii) read with section 12A of the Income Tax Act, 1961 on the ground that the Trust's object clause contained the words "tutorial and coaching classes" which according to his are essentially commercial in nature, such order being totally bad in law, unjustified, unreasonable, arbitrary , factually and legally incorrect and is liable to be an should be set aside and your appellant Trust be granted registration u/s 12A / 12AA.
2. On the facts and in the circumstances of the case, the DIT (A), Mumbai has further erred in stating that there is no binding legal obligation under the terms of the Trust deed on the trustees to apply the income / Trust funds solely for charitable purposes which is factually and legally incorrect in view of clause - 7 of Trust Dee, which is liable to be and should be set aside."2
3. Briefly stated relevant facts of the case are that the assessee is a Trust and filed an application for registration u/s 12AA of the Act on 21.3.2012. The Trust was constituted by indenture of Trust Deed dated 29.12.2011. The Trust was registered with the Charity Commissioner, Mumbai on 20.3.2012. From the papers filed, DIT (E) noticed that the Trust Deed vide Clause-7(b)(1) provides for objects for establishing and management of Tutorials / Coaching Classes and the same constitutes the commercial activity and the provisions of section 2(15) of the Act do not apply. In respect of the same, assessee filed an identical letter dated 27.9.2012 stating that the object of conducting Tutorials / Coaching classes is not the primary or main object of the trust and it is an extended one and the expression "Tutorials / Coaching classes" had to be read in that context of academics and the main object ie establish, set up, acquire, run, operate, maintain and manage schools (ie pre-primary, primary and secondary), colleges. Assessee also mentioned that establishing and management of tutorials / coaching classes is not a commercial activity and prayed for granting of registration u/s 12A of the Act. DIT (E) considered the same and rejected the registration for the reasons given in para 3 and 4 of his order dated 27.9.2012, which read as follows.
"I have considered the submission of the appellant carefully, but the same is not acceptable. Establishing and running coaching classes or tutorials is essentially commercial in nature irrespective of whether these are for the purpose of academies. Thus, the object of the trust in running coaching classes / tutorials will not fall within the meaning of 'education' as contemplated in section 2(15) of the Act. Reliance is place in this regard on the judgment of the Hon'ble Supreme Court in the case of Sole Trustees, Lok Shikshana Trust vs. CIT 101 ITR 234 (SC). Further, there is no binding legal obligation under the terms of the Trust Deed on the Trustees to apply the income / trust funds solely for charitable purposes.
4. Thus, in view of mixed objects coupled with binding legal obligation, I am unable to satisfy myself about the charitable character of objects of the trust which is a condition precedent for grant of registration. was the applicant trust has failed to comply with the mandatory requirements prescribed u/s 12AA read with Rule 17A, its application for grant of registration is rejected."
3.1. Aggrieved with the same, assessee filed the present appeal before the Tribunal raising the grounds mentioned above.
34. During the proceedings before us, Shri Adhar R Samria, the Managing Trustee of the assessee appeared personally and explained the facts of the case that this is the first year of the Trust's operation and the assessee has not started implementing the objects of the Trust. Further, referring to the objection of the DIT (E), Mr. Adhar R Samria mentioned that the object of Clause-7(b)(1) refers "to establish, set up, acquire, run, operate, maintain and manage schools ( ie pre-primary, primary and secondary), colleges, academies including tutorial or coaching classes". In this regard, he mentioned that assessee has not established any such establishments for the purpose of providing tutorial or coaching classes, which is considered to be a commercial activity. Further, he mentioned that education is a very broad term which includes providing tutorials and coaching classes also. In this regard, he relied on various decisions which are as under:
(i) NSHM Academy vs. CIT [2912] 18 ITR (Trib) 244 (Kolkata)
(ii) Oxford Academy for Career Development vs. CCIT [2009] 315 ITR 382 (All)
(iii) The Institute of Chartered Accountants of India (ICAI) vs. DIT (E) ITA No. 1853/Del/2010
(iv) DIT (E), Delhi vs. ICAI (HC decision for above ITAT decision) ITA No.869/2011, dt 19.9.2011
(v) Tishir Shiksha Prasar Samiti vs. CIT Gwalior [2012] 52 SOT 146 (Agra) (URO)
(vi) Heart Care Management vs. DIT (E), New Delhi [2012] 52 SOT 277 (Del)
(vii) Sole Trustee, Loka shikshana Trust vs. CIT Mysore [1975] 101 ITR 234
4.1. He also mentioned that the Hon'ble Supreme Court judgment in the case of Lok Shikshana Trust vs. CIT (supra) relied upon by the DIT (E), is distinguishable on facts as it relates to the publishing of the news papers whether it falls in the boundaries of the expression "education".
5. On the other hand, Ld DR opposed vehemently and mentioned that the assessee's object also include establishing and managing of tutorial / coaching classes which is held to be a commercial activity. He also mentioned that tutorial / coaching classes may be a part of education for the fact that such activity implies 'commercial activity' which bars the assessee from being charitable in nature when such objects are undisputedly adopted by the Trust as its objects. In this regard, Ld DR relied on the decision of the Hon'ble Utarakahand High Court in the case of CIT vs. National Institute of Aeronautical Engineering Educational Society [2009] 184 Taxman 264 (Uttarakhand). Para 10 to 11 of the said judgment are relevant in this regard. Further, Ld DR also filed a copy of the order of the Cochin Bench of the Tribunal in the case of M. Star Charitable Society vs. CIT [2013] 142 4 ITD 153 (Coch.) for the proposition that "where the taxpayer is conducting coaching classes, it cannot be treated as charitable institution and, thus taxpayer is not eligible for registration as charitable institution under section 12AA of the Act". The Tribunal observed when the assessee was not running any institute for systematic schooling and only coaching classes are conducted by the taxpayer, it would not come within the meaning of education as per the section 2(15) of the Act.
6. We have heard both the parties and perused the order of the DIT (E) and the copies of the judgments placed before us. We need to adjudicate here if the DIT(E) has rightly rejected the request for Registration u/s 12AA of the Act, when the assessee has conducting tutorial and coaching classes as an object. It is an undisputed fact that the assessee has not yet commenced the conducting of such tutorials or coaching classes if any till date and earned any receipts on this account as this is the first year of operation of the Trust. We shall have to give a finding on if such activity of conducting tutorials or coaching classes by the trust amounts to 'commercial activity' or not as the assessee has taken such a stand that it is not. For adjudicating the same, we proceed to analyse the existing provision in the Act as well as the judgmental law on the issue under discussion. In the light of the said legal position, we shall also examine the specific facts and issues pertaining to present case. To start with, we shall take up the legal position on the topic.
7. For this said purpose, we have perused the meaning of the expression 'charitable purpose' as provided in the provisions of section 2(15) of the Act and the same as it stands today reads as under:
"Section 2(15): "charitable purpose" includes relief of the poor, education, medical relief, preservation of environment (including watersheds, forests and wildlife) and preservation of monuments or places or objects of artistic or historic interest, and the advancement of any other object of general public utility:
Provided that the advancement of any other object of general public utility shall not be a charitable purpose, if it involves the carrying on of any activity in the nature of trade, commerce or business, or any activity of rendering any service in relation to any trade, commerce or business, for a cess or fee or any other consideration, irrespective of the nature of use or application, or retention, of the income from such activity:5
Provided further that the first proviso shall not apply if the aggregate value of the receipts from the activities referred to therein is twenty-five lakh rupees or less in the previous year;
Section 2(15) has been amended from time to time. The provisions of the second proviso was not the statute originally. The same was brought into statute by the Finance Act 2010 with retrospective application and further, the limit of Rs 10 lakhs was increased to RS 25 lakhs by the Finance Act 2012. Otherwise, the list of 'charitable purposes' includes the "education purposes"
and however, in view of the first proviso to section 2(15), the same shall cease to be 'charitable purpose, (i) if it involves the carrying on of any activity in the nature of trade, commerce or business' or (ii) if it involves the carrying on of any activity of rendering any service in relation to any trade, commerce or business, for a cess or fee or any other consideration, irrespective of the nature of use or application, or retention, of the income from such activity'. However, as per the second proviso to said clause 2(15) of the Act, if the aggregate value of the receipts from the activities referred to therein is twenty-five lakh rupees or less in the previous year, the educational activities of the trust are still considered as "charitable" purpose. This is the legal position as on date. This limit of 25 lakhs is operational from 1.4.2012. In other words, if the aggregate receipts of the trust out of the educational activities, which are in the nature of trade, commerce or business, are within the said limits ie Rs 10 lakhs from 1.4.2009 to 1.4.2012 (Finance Act 2010) and Rs 25 lakhs w e f 1.4.2012 (Finance Act, 2011), the assessee-trust with educational objects still enjoys charitable nature. Thus, in principle, the education for commercial purpose does not constitute 'non charitable purpose' within the meaning of the amended provisions of section 2(15) of the Act. The plain reading of these provisions suggest that the education purpose is charitable or not is now turn over dependent. In other words, it depends on the quantity of the aggregate receipts of the trust. Therefore, the DIT (A) cannot reject the claim of the assessee straight away on the ground of 'commercial nature' without 6 examining the quantity of the aggregate receipts of the assessee-trust. The DIT(E) made mistake of quoting the judgment of apex court in the case of Loka Shikshana Trust v. CIT [1975] 101 ITR 234 (SC), which was pronounced based on pre-amended provisions of section 2(15) of the Act. Present trust is constituted vide Trust Deed dated 29.12.2011 and therefore, the newly inserted second proviso applies to it.
8. Now we shall take the nature of the controversial object of trust vide Clause- 7(b)(1)of the Trust. The said clause reads read as follows,-
"to establish, set up, acquire, run, operate, maintain and manage schools ( ie pre- primary, primary and secondary), colleges, academies including tutorial or coaching classes".
From the plain reading of the above object, it is evident that the assessee's primary object is essentially 'to establish, set up, acquire, run, operate, maintain and manage schools (pre-primary, primary and secondary), colleges, academies'. In addition, 'tutorial or coaching classes' is also included as its activities. Considering the language used in the said object, we cannot hold that the primary object of the trust is to conduct tutorials or coaching classes only. In our interpretation, the main object is for establishing, running, managing etc of the schools, colleges and academics. We have already stated above that the assessee is yet to establish, set up, acquire, operate or maintain or manage schools, colleges, academics including tutorials or coaching classes.
9. We shall now examine the judgmental laws filed by the parties before us. First, we shall take up the Apex court's judgment in the case of Lok Shikshana Trust, supra relied upon by the DIT(E), Mumbai and of course it pertains to pre- amended period ie prior to 1.4.2009. In fact, this judgment was intensively discussed by the Tribunal of Cochin Bench while adjudicating the appeal of M. Star Charitable Society (32 Taxmann.com 239). This decision is relevant for the proposition that the 'taxpayer conducting coaching institute cannot be treated and registered as a charitable institution'. Thus, the said decisions dealt with the meaning of the expression "education" and it is the finding of the said judgments 7 that "all kinds of acquiring knowledge will not come within the meaning of education. What education connotes in section 2(15) of the Act is a processing of a training and developing of knowledge, skills, the mind and character of the students by normal schooling". It is the opinion of the judicial pronouncements that mere imparting knowledge to the students by mere coaching classes which also provides knowledge cannot fall within the meaning of education as provided u/s 2(15) of the Act. The expression "education" should be understood which is imparted by normal education by way of regular and systematic instructions.
9.1. In this regard, we have perused the Tribunal's decision in the case of M. Star Charitable Society (supra) and find para 4 to 7 is relevant in this regard and the same read as follows.
"4. We have considered the rival submissions on either side and also perused the material available on record. Admittedly, the taxpayer is running coaching classes. The taxpayer is not doing any other activity. The question arises for consideration is whether conducting coaching classes for the students would fall within the meaning of "education" as provided in section 2(15) of the Act. The Apex Court had an occasion to consider the provisions of section 2(15) of the Act in Sole Trustee, Loka Shikshana Trust v. CIT [1975] 101 ITR 234 (SC). After considering the provisions of sections 2(15) of the Act, the Apex Court found that all kinds of acquiring knowledge will not come within the meaning of "education". What "education". connotes in section 2(15) is the processing of training and developing the knowledge, skill, mind and character of students by normal schooling. In fact, the Apex Court has observed as follows at page 241 of the ITR:
"The sense in which the word "education" has been used in section 2(15) is the systematic instruction, schooling or training given to the young is preparation for the work of life. It also connotes the whole course of scholastic instruction which a person has received. The word "education" has not been used in that wide and extended sense, according to which every acquisition of further knowledge constitutes education. According to this wide and extended sense, travelling is education, because as a travelling you acquire fresh knowledge. Likewise, if you read newspapers and magazines, see pictures, visit art galleries, museums and zoos, you thereby add to your knowledge. Again, when you grow up and have dealings with other people, some of whom are not straight, you learn by experience and thus add to your knowledge of the ways of the world. If you are not careful, your wallet is liable to be stolen or you are liable to be cheated by some unscrupulous person. The thief who removes your wallet and the swindler who cheats you teach you a lesson and in the process make you wiser though poorer. If you visit a night club, you get acquainted with and add to your knowledge about some of the not much revealed realities and mysteries of life. All this in a way is education in the great school of life. But that is not the sense in which the word "education" is used in clause (15) of section 2. What education connotes in that clause is the process of training and developing the knowledge, skill, mind and character of students by normal schooling."
5. From the above judgment of the Apex Court it would be abundantly clear that there should be a systematic instruction to the students by way of normal schooling. Mere coaching classes may provide some kind of knowledge to the students. But that kind of acquisition of knowledge through coaching classes cannot fall within the meaning of "education" as provided in section 2(15) of the Act. As the Apex Court observed, one may acquire knowledge in the course of travelling; during the course of reading newspaper; etc. But that kind of knowledge cannot fall 8 within the term "education" as provided in section 2(15) of the Act. There should be a normal schooling by way of regular and systematic instruction.
6. The Patna High Court in the case of Bihar Institute of Mining And Mine Surveying v. CIT [1994] 208 ITR 608/76 Taxman 455 held that mere conducting of classes for open university/distance education cannot be construed as charitable activity within the meaning of section 2(15) of the Act. The Patna High Court, after considering the judgment of the Apex Court in CIT v. Andhra Chamber of Commerce [1965] 55 ITR 722 (SC) and in the case of CIT v. Sole Trustee, Loka Shikshana Trust [1970] 77 ITR 61 (Mys) has observed as follows at page 615 of the ITR:
"It is true that by reason of the Finance Act, 1983, the question as to whether any charitable institution is being run with a profit motive or not has lost its relevant. However, the word "charitable" prefixing the word "institution" has to be given its full effect. It appears that one of the principal projects of the petitioner's institution has the object of coaching and preparing the students for appearing in various examinations conducted by the Board of Mining Examination and/or MI(1) section (a)(b) and the said coaching of students in an institute is not, in our opinion, an imparting of education which can be said to be a process of training and developing knowledge and character of students by normal schooling. A coaching institute cannot be said to be an institution where normal schooling is done. The definition of "charitable purpose" is inclusive and not exhaustive."
7. It is further seen that the Gujarat High Court also had an occasion to consider identical issue in the case of Saurashtra Education Foundation v. CIT [2005] 273 ITR 139 (Guj). The Gujarat High Court found that all kinds of education would not fall within the meaning of section 2(15) of the Act. The training, instruction, etc. would result in grant of a diploma or degree by a university or a governmental agency. In the case before us, admittedly, the taxpayer is conducting coaching classes. Therefore, it cannot be treated as a charitable institution as provided in section 2(15) of the Act. This Tribunal is of the opinion that the taxpayer is not eligible for registration u/s 12AA of the Act. Accordingly, the order of the lower authority is confirmed."
9.2. Thus the Tribunal, Cochin Bench had the benefit of the amended provisions and it is held that the assessee-coaching centre is not a charitable institution. Thus, the assessee's argument that the activity of conducting 'coaching classes' per se constitutes charitable one is not correct. Therefore, there is need for considering and analyzing various facts before coming to that conclusion. Conducting 'tutorials or coaching classes' for certain some students of the formal school or formal colleges to meet out their difficulties in the classes , which are also commonly described as coaching classes, cannot be treated on par with the coaching classes conducted by coaching centers in today's commercial world. Of course, one has to apply the provisions of second proviso to section 2(15) of the Act too.
9.3. Further, we have also gone through the judgment of the Hon'ble Uttarakhand High Court in the case of CIT vs. National Institute of Aeronautical Engg. Educational Society (supra) which is popular for the proposition that mere imparting education for earning of the profits cannot be said as a charitable activity and the registration u/s 12AA of the Act cannot be granted to the institution which is engaged in mere 9 trade and commerce in the name of education. Para 10 to 12 of the said judgment are relevant in this regard and the same read as under:
"10. Section 12AA of the Act provides the procedure for registration. Clause (a) of sub-section (1) of section 12AA empowers the Commissioner of Income-tax to call for such documents or information from the trust or institution as he thinks necessary in order to satisfy himself about the genuineness of the activities of the trust or institution and may also make such inquiries, as he may deem necessary in this behalf. The said provision in section 12AA makes it clear that the Commissioner of Income-tax is not supposed to allow registration with blind eyes. In the present case, the Commissioner of Income-tax has considered the relevant papers before him, which included the income and expenditure accounts of the previous years after the society got registered with the Assistant Registrar, Firms, Societies and Chits. The Commissioner of Income-tax, after considering the record before him, has observed that the society (present respondent) is charging substantial fees from the students and making huge profits.
11. After considering the submissions of the learned counsel for the parties, we are of the view that mere imparting education for primary purpose of earning profits cannot be said to be a charitable activity. We are of the firm view that, in the expression " charitable purpose" , " charity" is the soul of the expression. Mere trade or commerce in the name of education cannot be said to be a charitable purpose. And the Commissioner Income-tax has to satisfy himself as provided under section 12AA of the Act before allowing the registration. The question of law stands answered.
12. For the reasons as discussed above, the appeal is allowed. The impugned order dated August 12, 2005, passed by the Income-tax Appellate Tribunal, Delhi Bench " D" , New Delhi in I. T. A. No. 4278/Del/2004, is hereby set aside. The order dated September 14, 2004, passed by the Commissioner of Income-tax, Dehradun, is restored."
10. Other aspect which is directly relevant for examination relates to denial of registration u/s 12AA of the Act before the Trust starts realizing its objects. It is undisputed fact that the assessee-trust filed an application for registration u/s 12AA of the Act on 21.3.2012. The Trust was constituted by indenture of Trust Deed dated 29.12.2011 and it was registered with the Charity Commissioner, Mumbai on 20.3.2012. It is also an undisputed fact that the Trust has not applied or appropriated its funds of its objects till date. Thus, in our opinion, it is premature to decide or conclude on the question of application or appropriation of funds for the trust as the trust has not yet established any such academic or educational institutions or necessary infrastructure. Therefore, the question of exceeding of the aggregate receipts of 25 lakhs in violation of the provisions of the second proviso to section 2(15) of the Act, does not arise. As such, it is settled law that the denial of registration u/s 12AA of the Act is not proper when the trust is yet 10 to start its educational activities. The DIT(E) should cross these legal hurdles before he resorts to the denial. When the assessee-trust has have reported any receipts from the educational activities, ie objects of the trust, in our opinion, it is premature to conclude on the commercial nature of the educational activities of the trust.
10.1 Further, we have also perused the assessee's letter dated 27.9.2012, wherein there is a prayer from the assessee for "an opportunity of personal hearing" for sorting out the issues raised by the DIT (E). Assessee has not got invitation of the DIT(E) in this regard.
11. To conclude, we have hitherto discussed the (i) existing provisions relating to the 'charitable purposes'; (ii) analysed the educational object of the assessee in general and the object of conducting of 'tutorial or coaching' as an ancillary or included object of the trust; (iii) judgmental law on the meaning of the expression 'education' and the activities of a conducting the coaching centre/classes etc. It is noted that in the context of the provisions of section 2(15) of the Act, the expression 'education' should be understood as formal education by way of formal school or colleges or universities etc. The 'commercial centres' are not be treated on par with such formally established educational methods/systems. We have also anlysed as to how the amended provisions of the second proviso to section 2(15) of the Act were not considered in the said judgment and how the amended provisions differ substantially. These provision in present form accommodate commercial education if the aggregate of the receipts is less than Rs 25 lakhs. This makes lot of difference to the present assessee, who is make a beginning in translating the objects into reality. The trust, which is instituted vide the Trust Deed dated 29.12.2011 and recognized by the Charity Commissioner in March 2012, seeks registration u/s 12AA of the IT Act vide its application 21.3.2012, is yet to raise funds from the donors and therefore, yet to establish the requisite infrastructure ie construction of the school/college buildings, recruiting of the teaching personnel etc to be in tune with the educational objects of the trust. DIT(E) denied registration sole on the ground of extended and inclusive object of "tutorial or coaching classes". Therefore, in principle, the said denial of registration at this phase of the trust activities is not 11 proper. Further, it is undisputed that the "education" should refers to a formal education by virtue of schools, colleges, universities and it is the core object of the assessee as seen from Clause 7 of the trust deed. Education has different shades and all kinds of education are not covered by the provisions of section 2(15) of the Act. The education for the purpose of earning profits, imparting knowledge, which is required for getting employment are not covered by the said provisions. Applying the said principles to the facts of the present case, we find that the assessee is yet to commence its activities. As on date, there is neither institution nor any coaching classes conducted by the assessee as stated by the Managing Trustee at Bar. These facts were not properly communicated by the assessee to the DIT (E), probably for this purpose, the assessee wanted an opportunity of being heard by the DIT (E) before the crucial decision was taken against the assessee ie by the rejection of registration u/s 12AA of the Act. Further, we do not have details of financial statements to know the donations pattern, fee structures, quantity of receipts if any, whether any institutions have commenced or not, any establishments are made, any schools are running etc. The application of the assessee and the order of DIT (E) are deficient to that extent. Therefore, we are of the opinion that the matter should re-visit the DIT (E) for examining the basic facts narrated above. Accordingly, the grounds raised before us in the appeal are set aside to the DIT (E) for examining the issues afresh in the light of the above discussion and the law in force.
12. In the result, the appeal of the assessee is allowed for statistical purposes.
Order pronounced in the open court on 5.6.2013
आदे श क घोषणा खुले यायालय म दनांकः 5.6.2013को क गई
Sd/- Sd/-
(B.R. MITTAL) (D. KARUNAKARA RAO)
या यक सद य / JUDICIAL MEMBER लेखा सद य / ACCOUNTANT MEMBER
मुंबई Mumbai; दनांक Dated 5. 6.2013
व. न.स./ OKK , Sr. PS
12
आदे श क त ल प अ े षत/Copy
षत of the Order forwarded to :
1. अपीलाथ / The Appellant
2. यथ / The Respondent.
3. आयकर आयु (अपील) / The CIT(A)-
4. आयकर आयु / CIT
5. वभागीय त न ध, आयकर अपील य अ धकरण, मंब
ु ई / DR,
ITAT, Mumbai
6. गाड फाईल / Guard file.
स या पत त //True Copy//
ार/ BY ORDER,
आदे शानुसार
उप/सहायक
उप सहायक पंजीकार (Dy./Asstt. Registrar)
आयकर अपील य अ धकरण,
धकरण मुंबई / ITAT, Mumbai