Income Tax Appellate Tribunal - Delhi
M/S. Mry Auto Components Ltd., Gurgaon vs Ito, New Delhi on 15 September, 2017
IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCHES "E" : DELHI
BEFORE SHRI BHAVNESH SAINI, JUDICIAL MEMBER
AND
SHRI O.P. KANT, ACCOUNTANT MEMBER
ITA.No.2418/Del./2014
Assessment Year 2003-2004
M/s. MRY Auto Components
Ltd., 1221, Sector-21, Near The Income Tax Officer
Village & Post Office, vs. Ward No.6(1)
Dundahera, Gurgaon New Delhi.
122001. PAN AAECM2164Q
(Appellant) (Respondent)
For Assessee : Shri Salil Kapoor, Advocate.
For Revenue : Ms. Shweta Nakra Datta, Sr.D.R
Date of Hearing : 29.08.2017
Date of Pronouncement : 15.09.2017
ORDER
PER BHAVNESH SAINI, J.M.
This appeal by assessee has been directed against the order of the Ld. CIT(A)-9, New Delhi, dated 20th February, 2014 for the A.Y. 2003-2004, challenging the reopening of the assessment under section 148 of the I.T. Act, 1961 and addition of Rs.27,54,000 on account of share application money and commission expenditure. 2
ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
2. Briefly the facts of the case are that information was received from Investigation Wing of Department to the effect that the assessee was a beneficiary in accommodation entry racket being run by certain persons. It had reportedly received certain accommodation entries during the year under assessment. The assessee is registered in Delhi and as per the alphabetical jurisdiction in the case of corporate assessee, the jurisdiction over the assessee lies with the Ward of the A.O. The information was considered and notice under section 148 was issued on 26th March, 2010 after duly recording the reasons as required by provisions of law. The details regarding address of the assessee-company and its Directors were obtained from the Official website of the Ministry of Corporate Affairs. Assessee filed letter dated 30.11.2010, filed a return declaring NIL income in response to notice under section 148 of the Act along with copy of the balance sheet. The reasons recorded on issuance of notice under section 148 were provided to the assessee vide letter dated 30th October, 2010 which are reproduced in the assessment order as under :
3
ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
"...The Investigation wing of the Income Tax Department had unearthed a huge money laundering mechanism wherein it was established that bogus accommodation entities were being provided/taken. These accommodation entries are received in lieu of payment of cash of equivalent amount plus commission thereon to the entry operator. For obvious reasons, these cash transactions are not routed through the books of account of the assessee. In this case, information has been received from Directorate of Income Tax, (Investigation), New Delhi that during the relevant assessment year, this assessee had received the following cheque amount(s) in nature of accommodation entry :
Value of Instrument Date on Name of Bank Branch A/c. no.
entry No. by which account from of entry entry
taken which entry holder of which giving giving
entry taken entry entry bank account
taken giving given
account
300375 13. Mar-03 Rahul SB Darya 50082
Finlease Patiala Ganj
P. Ltd.,
300315 26-Mar-03 Kuldeep SBBJ NRR 24624
Textiles
(P) Ltd.,
400415 27-Mar-03 Division SBBJ NRR 24620
Trading
Pvt. Ltd.,
4
ITA.No.2418/Del./2014 M/s. MRY Auto
Components Ltd., Dundahera, Gurgaon.
Therefore, I have reason to believe that an income of Rs.10,01,105/- plus commission @ 2% thereon amounting to Rs.20,022/- totaling to Rs.10,21,127/- has escaped assessment during the assessment year. On the basis of this information, I have reason to believe that the incomes described above have escaped assessment and the case is fit for issuing. Notice u/s 148 of Income Tax Act, 1961."
2.1. The A.O. noted that assessee has not filed any objections to the validity of the notice issued under section 148 of the Act. The assessee informed the A.O. that it has had no transaction with M/s. Kuldeep Textiles (P) Ltd., as noted in the reasons. The assessee filed details to show that addition to the amounts mentioned above from Rahul Finlease P. Ltd., and Division Trading Pvt. Ltd., it had received money allegedly towards share capital from the three other companies as well. The total amount of money received from these entities towards share capital is noted at page-3 of the assessment order totaling to Rs.27 lakhs from five parties. The A.O. after discussion made addition of Rs.27 lakhs to the income of the assessee company under section 68 of the I.T. Act and also 5 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
disallowed Rs.54,000 being commission paid for taking these accommodation entries. Income of the assessee was computed at Rs.27,54,000. The assessee challenged the reopening of the assessment as well as addition on merit before the Ld. CIT(A). However, the Ld. CIT(A), dismissed the appeal of assessee.
3. Learned Counsel for the Assessee submitted that the issue is covered in favour of the assessee by the recent Judgment of the Hon'ble Delhi High Court in the case of Pr. CIT vs. Meenakshi Overseas Pvt. Ltd., reported in 395 ITR 677 (Del.). He has also relied upon the decision of the Hon'ble Bombay High Court in the case of General Electoral Trust vs. ITO 289 CTR 284 (Bom.) on the proposition that non-filing of the return of income does not ipso-facto give jurisdiction to reopen the assessment. He has also relied upon the decision of ITAT, Delhi 'G' Bench, in the case of Mrs. Sonia Choudhary vs. ITO, Ward-47(1), New Delhi dated 07th October, 2016, ITA.Nos.2036 & 2037/Del./2010, in which on the identical reasons for reopening of the assessment, the re-assessment proceedings have been quashed. Learned Counsel for the Assessee, therefore, 6 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
submitted that reopening of the assessment may be quashed in this case.
4. The Ld. D.R. on the other hand, relied upon the orders of the authorities below.
5. We have considered the rival submissions. The Hon'ble Delhi High Court in its recent decision in the case of Pr. CIT vs. Meenakshi Overseas Pvt. Ltd., (supra), in paras 19 to 38 held as under :
"19. A perusal of the reasons as recorded by the AO reveals that there are three parts to it. In the first part, the AO has reproduced the precise information he has received from the Investigation Wing of the Revenue. This information is in the form of details of the amount of credit received, the payer, the payee, their respective banks, and the cheque number. This information by itself cannot be said to be tangible material.
20. Coming to the second part, this tells us what the AO did with the information so received. He says: "The information so received has been gone through." One would have expected 7 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
him to point out what he found when he went through the information. In other words, what in such information led him to form the belief that income escaped assessment. But this is absent. He straightaway records the conclusion that "the above said instruments are in the nature of accommodation entry which the Assessee had taken after paying unaccounted cash to the accommodation entry given (sic giver)". The AO adds that the said accommodation was "a known entry operator" the source being "the report of the Investigation Wing".
21. The third and last part contains the conclusion drawn by the AO that in view of these facts, "the alleged transaction is not the bonafide one. Therefore, I have reason to be believe that an income of Rs.5,00,000 has escaped assessment in the AY 2004-05 due to the failure on the part of the Assessee to disclose fully and truly all material facts necessary for its assessment... "
22. As rightly pointed out by the ITAT, the 'reasons to believe' are not in fact reasons but only conclusions, one after the other. The expression 'accommodation entry' is used to describe the information set out without explaining the basis for arriving 8 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
at such a conclusion. The statement that the said entry was given to the Assessee on his paying "unaccounted cash" is another conclusion the basis for which is not disclosed. Who is the accommodation entry giver is not mentioned. How he can be said to be "a known entry operator" is even more mysterious. Clearly the source for all these conclusions, one after the other, is the Investigation report of the DIT. Nothing from that report is set out to enable the reader to appreciate how the conclusions flow therefrom.
23. Thus, the crucial link between the information made available to the AO and the formation of belief is absent. The reasons must be self evident, they must speak for themselves. The tangible material which forms the basis for the belief that income has escaped assessment must be evident from a reading of the reasons. The entire material need not be set out. However, something therein which is critical to the formation of the belief must be referred to. Otherwise the link goes missing.
24. The reopening of assessment under Section 147 is a potent power not to be lightly exercised. It certainly cannot be 9 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
invoked casually or mechanically. The heart of the provision is the formation of belief by the AO that income has escaped assessment. The reasons so recorded have to be based on some tangible material and that should be evident from reading the reasons. It cannot be supplied subsequently either during the proceedings when objections to the reopening are considered or even during the assessment proceedings that follow. This is the bare minimum mandatory requirement of the first part of Section 147 (1) of the Act.
25. At this stage it requires to be noted that since the original assessment was processed under Section 143 (1) of the Act, and not Section 143 (3) of the Act, the proviso to Section 147will not apply. In other words, even though the reopening in the present case was after the expiry of four years from the end of the relevant AY, it was not necessary for the AO to show that there was any failure to disclose fully or truly all material facts necessary for the assessment.
26. The first part of Section 147 (1) of the Act requires the AO to have "reasons to believe" that any income chargeable to tax 10 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
has escaped assessment. It is thus formation of reason to believe that is subject matter of examination. The AO being a quasi judicial authority is expected to arrive at a subjective satisfaction independently on an objective criteria. While the report of the Investigation Wing might constitute the material on the basis of which he forms the reasons to believe the process of arriving at such satisfaction cannot be a mere repetition of the report of investigation. The recording of reasons to believe and not reasons to suspect is the pre- condition to the assumption of jurisdiction under Section 147 of the Act. The reasons to believe must demonstrate link between the tangible material and the formation of the belief or the reason to believe that income has escaped assessment.
27. Each case obviously turns on its own facts and no two cases are identical. However, there have been a large number of cases explaining the legal requirement that requires to be satisfied by the AO for a valid assumption of jurisdiction under Section 147 of the Act to reopen a past assessment. 11
ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
28.1. In Signature Hotels Pvt. Ltd. v. Income Tax Officer (supra), the reasons for reopening as recorded by the AO in a proforma and placed before the CIT for approval read thus:
"11. Reasons for the belief that income has escaped assessment.- Information is received from the DIT (Inv.-1), New Delhi that the assessee has introduced money amounting to Rs. 5 lakh during the F.Y. 2002-03 relating to A.Y. 2003-04. Details are contained in Annexure. As per information amount received is nothing but accommodation entry and assessee is a beneficiary."
28.2. The Annexure to the said proforma gave the Name of the Beneficiary, the value of entry taken, the number of the instrument by which entry was taken, the date on which the entry was taken, Name of the account holder of the bank from which the cheque was issued, the account number and so on. 28.3. Analysing the above reasons together with the annexure, the Court observed:
"14. The first sentence of the reasons states that information had been received from Director of Income-Tax (Investigation) that the petitioner had introduced money amounting to Rs. 5 lacs 12 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
during financial year 2002-03 as per the details given in Annexure. The said Annexure, reproduced above, relates to a cheque received by the petitioner on 9th October, 2002 from Swetu Stone PV from the bank and the account number mentioned therein. The last sentence records that as per the information, the amount received was nothing but an accommodation entry and the assessee was the beneficiary.
15. The aforesaid reasons do not satisfy the requirements of Section 147 of the Act. The reasons and the information referred to is extremely scanty and vague. There is no reference to any document or statement, except Annexure, which has been quoted above. Annexure cannot be regarded as a material or evidence that prima facie shows or establishes nexus or link which discloses escapement of income. Annexure is not a pointer and does not indicate escapement of income. Further, it is apparent that the Assessing Officer did not apply his own mind to the information and examine the basis and material of the information. The Assessing Officer accepted the plea on the basis of vague information in a mechanical manner. The Commissioner also acted on the same basis by mechanically giving his approval. The reasons recorded reflect that the Assessing Officer did not independently apply his mind to the information received from the Director of Income-Tax 13 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
(Investigation) and arrive at a belief whether or not any income had escaped assessment."
28.4. The Court in Signature Hotels Pvt. Ltd. v. Income Tax Officer (supra) quashed the proceedings under Section 148 of the Act. The facts in the present case are more or less similar. The present case is therefore covered against the Revenue by the aforementioned decision.
29.1. The above decision can be contrasted with the decision in AGR Investment v. Additional Commissioner of Income Tax (supra), where the 'reasons to believe' read as under:
"Certain investigations were carried out by the Directorate of Investigation, Jhandewalan, New Delhi in respect of the bogus/accommodation entries provided by certain individuals/companies. The name of the assessee figures as one of the beneficiaries of these alleged bogus transactions given by the Directorate after making the necessary enquiries. In the said information, it has been inter-alia reported as under:
"Entries are broadly taken for two purposes: 14
ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
1. To plough back unaccounted black money for the purpose of business or for personal needs such as purchase of assets etc., in the form of gifts, share application money, loans etc.
2. To inflate expense in the trading and profit and loss account so as to reduce the real profits and thereby pay less taxes. It has been revealed that the following entries have been received by the assessee:...."
29.2. The details of six entries were then set out in the above 'reasons'. These included name of the beneficiary, the beneficiary's bank, value of the entry taken, instrument number, date, name of the account in which entry was taken and the account from where the entry was given the details of those banks. The reasons then recorded:
"The transactions involving Rs. 27,00,000/-, mentioned in the manner above, constitutes fresh information in respect of the assessee as a beneficiary of bogus accommodation entries provided to it and represents the undisclosed income/income from other sources of the assessee company, which has not been offered to tax by the assessee till its return filed.
On the basis of this new information, I have reason to believe that the income of Rs.27,00,000/- has escaped assessment as defined 15 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
by section 147 of the Income Tax Act. Therefore, this is a fit case for the issuance of the notice under section 148."
29.3. The Court was not inclined to interfere in the above circumstances in exercise of its writ jurisdiction to quash the proceedings. A careful perusal of the above reasons reveals that the AO does not merely reproduce the information but takes the effort of revealing what is contained in the investigation report specific to the Assessee. Importantly he notes that the information obtained was 'fresh' and had not been offered by the Assessee till its return pursuant to the notice issued to it was filed. This is a crucial factor that went into the formation of the belief. In the present case, however, the AO has made no effort to set out the portion of the investigation report which contains the information specific to the Assessee. He does not also examine the return already filed to ascertain if the entry has been disclosed therein.
30.1. In Commissioner of Income Tax, New Delhi v. Highgain Finvest (P) Limited (2007) 164 Taxman 142 (Del) relied upon by Mr. Chaudhary, the reasons to believe read as under: 16
ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
"It has been informed by the Additional Director of Income Tax (Investigation), Unit VII, New Delhi vide letter No. 138 dated 8th April 2003 that this company was involved in the giving and taking bogus entries/ transactions during the financial year 1996-97, as per the deposition made before them by Shri Sanjay Rastogi, CA during a survey operation conducted at his office premises by the Investigation Wing. The particulars of some of the transaction of this nature are as under:
Date Particulars of cheque Debit Amt. Credit Amt 18.11.96 305002 5,00,000 Through the Bank Account No. CA 4266 of M/s. Mehram Exports Pvt. Ltd. in the PNB, New Rohtak Road, New Delhi. Note: It is noted that there might be more such entries apart from the above.
The return of income for the assessment year 1997-98 was filed by the Assessee on 4th March 1998 which was accepted under Section 143 (1) at the declared income of Rs. 4,200. In view of these facts, I have reason to believe that the amount of such transactions particularly that of Rs. 5,00,000 (as mentioned above) has escaped the assessment within the 17 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
meaning of the proviso to Section 147 and clause (b) to the Explanation 2 of this section.
Submitted to the Additional CIT, Range -12, New Delhi for approval to issue notice under Section 148 for the assessment year 1997-98, if approved."
30.2. The AO was not merely reproducing the information received from the investigation but took the effort of referring to the deposition made during the survey by the Chartered Accountant that the Assessee company was involved in the giving and taking of bogus entries. The AO thus indicated what the tangible material was which enabled him to form the reasons to believe that income has escaped assessment. It was in those circumstances that in the case, the Court came to the conclusion that there was prima facie material for the AO to come to the conclusion that the Assessee had not made a full and true disclosure of all the material facts relevant for the assessment.
31. In Commissioner of Income Tax v. G&G Pharma (supra) there was a similar instance of reopening of 18 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
assessment by the AO based on the information received from the DIT (I). There again the details of the entry provided were set out in the 'reasons to believe'. However, the Court found that the AO had not made any effort to discuss the material on the basis of which he formed prima facie view that income had escaped assessment. The Court held that the basic requirement of Section 147 of the Act that the AO should apply his mind in order to form reasons to believe that income had escaped assessment had not been fulfilled. Likewise in CIT-4 v. Independent Media P. Limited (supra) the Court in similar circumstances invalidated the initiation of the proceedings to reopen the assessment under Section 147 of the Act.
32. In Oriental Insurance Company Limited v.
Commissioner of Income Tax 378 ITR 421 (Del) it was held that "therefore, even if it is assumed that, in fact, the Assessee's income has escaped assessment, the AO would have no jurisdiction to assess the same if his reasons to believe were not based on any cogent material. In absence of the jurisdictional pre- condition being met to reopen the assessment, the question of 19 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
assessing or reassessing income under Section 147 of the Act would not arise."
33. In Rustagi Engineering Udyog (P) Limited (supra), it was held that "...the impugned notices must also be set aside as the AO had no reason to believe that the income of the Assessee for the relevant assessment years had escaped assessment. Concededly, the AO had no tangible material in regard to any of the transactions pertaining to the relevant assessment years. Although the AO may have entertained a suspicion that the Assessee's income has escaped assessment, such suspicion could not form the basis of initiating proceedings under Section 147 of the Act. A reason to believe - not reason to suspect - is the precondition for exercise of jurisdiction under Section 147 of the Act. "
34. Recently in Agya Ram v. CIT (supra), it was emphasized that the reasons to believe "should have a link with an objective fact in the form of information or materials on record..." It was further emphasized that "mere allegation in reasons cannot be treated equivalent to material in eyes of law.20
ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
Mere receipt of information from any source would not by itself tantamount to reason to believe that income chargeable to tax has escaped assessments."
35. In the decision of this Court dated 16th March 2016 in W.P. (C) No. 9659 of 2015 (Rajiv Agarwal v. CIT) it was emphasized that "even in cases where the AO comes across certain unverified information, it is necessary for him to take further steps, make inquiries and garner further material and if such material indicates that income of an Assessee has escaped assessment, form a belief that income of the Assessee has escaped assessment."
36. In the present case, as already noticed, the reasons to believe contain not the reasons but the conclusions of the AO one after the other. There is no independent application of mind by the AO to the tangible material which forms the basis of the reasons to believe that income has escaped assessment. The conclusions of the AO are at best a reproduction of the conclusion in the investigation report. Indeed it is a 'borrowed satisfaction'. The reasons fail to demonstrate the link between the tangible 21 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
material and the formation of the reason to believe that income has escaped assessment.
37. For the aforementioned reasons, the Court is satisfied that in the facts and circumstances of the case, no error has been committed by the ITAT in the impugned order in concluding that the initiation of the proceedings under Section 147/148 of the Act to reopen the assessments for the AYs in question does not satisfy the requirement of law.
38. The question framed is answered in the negative, i.e., in favour of the Assessee and against the Revenue. The appeal is, accordingly, dismissed but with no orders as to costs". 5.1. In this case, the reasons for reopening are also reproduced in the judgment of the Hon'ble Delhi High Court in which similarly information has been received from Director of Income Tax (Investigation), New Delhi that assessee has received amount of Rs.5 lakhs. The A.O. on going through the information found that it is an accommodation entry and reopened the assessment. In the instant case under appeal, the A.O. has reproduced the precise information 22 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
he has received from Investigation Wing of the Revenue and reproduced the same in the reasons recorded under section 148 of the I.T. Act. This information shows that assessee has received the amount of credit through banking channels by mentioning names of the parties and cheque nos. with amount. This information by itself cannot be said to be tangible material. The A.O. has not gone through the details of these information and has not even applied his mind and merely concluded that he has reason to believe that income chargeable to tax has escaped assessment. The reason to believe are therefore, not in fact reasons but only conclusion of the A.O. The expression "accommodation entry" is used to describe the information set-out without explaining the basis for arriving at such conclusion. In the case of Meenakshi Overseas Pvt. Ltd., (supra), the A.O. in the reasons has even mentioned that he has gone through the information so received which is lacking in the instant case. The A.O. being a quasi-judicial authority is expected to arrive at a subjective satisfaction independently on an objective criteria. The A.O. however, merely repeated the report of Investigation Wing in the reasons and formed his belief that income chargeable to tax has 23 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
escaped assessment without arriving at his satisfaction. The reason to believe contain no reason but the conclusion of A.O. without any basis. Thus, there is no independent application of mind by the A.O. to the report of Investigation Wing which form the basis for reasons to believe that income has escaped assessment. The conclusion of the A.O. in the reason are at best reproduction of conclusion of the Investigation report. It is borrowed satisfaction not permissible in law. The reasons fail to demonstrate the link between the alleged tangible material and the formation of the reason to believe that income has escaped assessment. The issue is therefore, identical in the present appeal as has been considered and decided by the Hon'ble Delhi High Court in the case of Meenakshi Overseas Pvt. Ltd., (supra). The issue is therefore, covered in favour of the assessee by the judgment of Hon'ble Delhi High Court in the case of Meenakshi Overseas Pvt. Ltd., (supra).
5.2. The Hon'ble Bombay High Court in the case of General Electoral Trust vs., ITO (supra) held as under :
"Non-filing of return of income and/or not obtaining of PAN does not ipso facto give jurisdiction to reopen an assessment under 24 ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
section 147/148, prima facie jurisdiction even in case of non- filing of the return of income, to issue notice of reopening notice is a reasonable belief of the Assessing Officer that income chargeable to tax has escaped assessment."
5.3. The Learned Counsel for the Assessee also relied upon the order of ITAT, Delhi "G" Bench in the case of Mrs. Sonia Choudhary vs. ITO (supra), in which on identical facts the reopening of the assessment have been quashed.
5.4. In view of the above, reopening of assessment in the facts and circumstances of the case are not justified and have to be quashed.
6. Considering the facts and circumstances of the case, in the light of above discussion and decision of the Hon'ble Delhi High Court in the case of Meenakshi Overseas Pvt. Ltd., (supra), we set aside the orders of the authorities below and quash the reopening of the assessment under section 147/148 of the I.T. Act. Resultantly, the entire additions of Rs.27,54,000 are deleted. Since the reopening of the assessment is quashed, therefore, there is no need to decide the addition on merit.
25
ITA.No.2418/Del./2014 M/s. MRY Auto Components Ltd., Dundahera, Gurgaon.
7. In the result, appeal of the assessee is allowed.
Order pronounced in the open Court.
Sd/- Sd/-
(O.P. KANT) (BHAVNESH SAINI)
ACCOUNTANT MEMBER JUDICIAL MEMBER
Delhi, Dated 15th September, 2017
VBP/-
Copy to
1. The appellant
2. The respondent
3. CIT(A) concerned
4. CIT concerned
5. D.R. ITAT 'E' Bench, Delhi
6. Guard File.
// By order //
Asst. Registrar : ITAT Delhi Benches :
Delhi.