Income Tax Appellate Tribunal - Chandigarh
Acit,Circle--2(1), Chandigarh vs Csj Infrastructure Pvt.Ltd, ... on 28 May, 2025
आयकर अपील य अ धकरण,च डीगढ़ यायपीठ, च डीगढ़
IN THE INCOME TAX APPELLATE TRIBUNAL
DIVISION BENCH, 'B' CHANDIGARH
BEFORE SHRI RAJPAL YADAV, VICE PRESIDENT AND
SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER
आयकर अपील सं./ ITA No. 131,132 /CHD/2020
नधारण वष / A.Y.: 2014-15, 2015-16,
M/s CSJ Infrastructure Pvt.Ltd., The ACIT,
C/o C.A. Ajay Kumar Jain, Vs Circle 2(1),
SCO 80-81, 4th Floor, Sector 17-C, Chandigarh.
Chandigarh.
थायी लेखा सं./PAN NO: AACCC8021G
अपीलाथ /Appellant यथ /Respondent
आयकर अपील सं./ ITA No. 146, 147/CHD/2020
नधारण वष / A.Y.: 2014-15, 2015-16,
The ACIT, Vs M/s CSJ Infrastructure Pvt. Ltd.,
Circle 2(1), C/o C.A. Ajay Kumar Jain,
Chandigarh. SCO 80-81, 4th Floor, Sector 17-C,
Chandigarh.
थायी लेखा सं./PAN NO: AACCC8021G
अपीलाथ /Appellant यथ /Respondent
Assessee by : Shri Ajay Jain, CA
Revenue by : Shri Manav Bansal, CIT, DR
Date of Hearing : 19.05.2025
Date of Pronouncement : 28.05.2025
PHYSICAL HEARING
ORDER
PER RAJPAL YADAV, VP The ld. CIT(A)-I Chandigarh has decided two appeals of the assessee f or assessment year 2014-15 and 2015-16 by ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 2 a common order dated 27.10.2019. This order has been impugned by the assessee as well as Revenue. Thus, the present four cross-appeals are being clubbed for deciding them by this common order.
ITA 131/CHD/2020 (A.Y. 2014-15)
2. We first take appeal of the assessee for assessment year 2014-15. The assessee has taken six grounds of appeal but its gr ievance revolves around a s ingle iss ue, namely, as to how profit on sale of four shops is required to be determined with the help of Section 43CA of the Income Tax Act, 1961.
3. The brief facts are that assessee company has purchased 20.16 acres of industrial land from M/s Pfizer Ltd. in Chandigarh. The company has obtained approval from Chandigarh Housing Board (CHB) vide letter No. CHB/CEO/land-use/2006/4855 dated 26.03.2007 for conversion of land from industrial use. It was required to pay Conversion Fee of Rs.1,85,45,47,440/-. Out of above conversion fees, 10% was to be paid as down payment and remaining over a period of nine years in equated annual instalments with interest at 8.25%. The assessee has ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 3 developed a shopping mall over this land. It has entered into an Agreement for sale of shops A-501, 502 and 503, B-408 and
409. The Agreem ent to Sell for unit No. 501 to 503 was executed on 25.01.2011. The schedule of paym ent was decided as under :
PAYMENT PLANT At the Tim e of Booking 25 % of Sale Pri ce 30.04.2 011 15 % of Sale Pri ce On 31.07.201 1 15 % of Sale Pri ce On 31.10.201 1 15 % of Sale Pri ce On 31.01.201 2 15 % of Sale Pri ce On Intim ation for Posses sion 15 % of Sale P rice + Stamp Duty & R egi strati on Charges 3.1 The Vendee has made a payment of Rs.2,60,00,000/- vide cheque No. 023655 on 25.01.2011. There was some dispute between the assessee and the vendee and ultimately Sale Deed was executed during the Accounting Year relevant to assessment year 2014-15. The ld. AO has confronted the assessee qua Section 43CA. The stand of the AO was that Section 43CA is equivalent to Section 50C of the Income Tax Act. Under Section 50C, full sale consider ation implied u/s ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 4 48 of the Incom e Tax Act will be deemed equivalent to the amount on which Stamp Duty was charged by the Stamp Duty Authority for the purpose of registering the Sale Deed.
Sim ilarly, for selling stock-in-trade in a Real Est ate company, the value at which stamp duty is being levied, would be deem ed full sale consideration of the alleged land/building. Thus, AO was of the view that the full sale consideration is to be equated according to the value adopted by the valuation authority for charging the stamp duty. The ld. AO, accordingly, made additions to the total income of the assessee. The assessee has declared a loss of Rs.65,92,02,520/- in this year which has been reduced to Rs.30,98,19,874/-.
4. Dissatisfied with the above, assessee carr ied the matter in appeal before the CIT(A). The ld. CIT(A) made a reference to the DVO for determining the Fair Market Value of the property as contemplat ed u/s 43CA of the Income Tax Act. The ld. CIT(A) has upheld the addition on the basis of the DVOs report and such addition has been confirmed partly.
ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 5
5. Before us, ld. counsel for the assessee raised many fold of contentions. In his first fold of contention, it was submitted that assessee agreed to sell for office units on 25.01.2011 and 27.01.2011. At that point of time, Section 43CA was not in picture, hence, no addit ion ought to be made with the help of Section 43CA.
5.1 In next fold of contention, he submitted that as per sub-clause (3) and (4) of Section 43CA, the Stamp Duty Valuation as applicable on the date of agreement is required to be adopted by the AO instead of the duty available on the date of Sale Deed. In the year 2011, there was no collectorate rates available for collecting the Stamp Duty, hence, the deaming f iction provided u/s 43CA fails. For butressing his proposition, he drew our attention to the Valuation Report where ld. DVO him self did not adopt the collectorate rate and rather made an observation that adopting collectorate rate to work out Fair Market Value of the subjected property may not be appropriate in this case. In view of the evidence produced by the assessee, moreover, collectorate rates available are for commercial space and not specifically for office space.
ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 6 According to the DVO, the general trend available, commercial space such as shop, malls etc. are considered as compar ed to the office space. In other wor ds, ld. DVO has not made reference to any collectorate rate in the DVO's Report. 5.2 In his next fold of subm ission, it has been contended that assessee has received an interest of Rs.6.19 Cr from the vendees for the period during which a dispute remained between the parties. Thus, this interest is part and parcel of the sale consideration. In other words, the sale proceeds is also revenue receipt for the assessee because it has sold stock-in-trade and this inter est income would also partake character of business receipt. Therefore, if bot h these amounts are being added together, then the difference between the sale proceeds disclosed by the assessee vis-à-vis one determined by the DVO is less than 6.51% and the assessee is protected by proviso attached to Section 43CA sub- clause (1). This proviso contemplates that if value is more than 110%, only them addition is to be made. The working made by the ld. counsel for the assessee read as under :
"7. Further , Total C onsi der atio n = Sales Consideration + Interest.
= 28. 82 crore + 6.19 crore
= 35. 01 crore
ITA No.131, 132, 146,147/CHD/2020
A.Y.2014-15 & 2015-16
7
FMV as per DVO report = 37.45 crore
Difference = 2.44 crore
Deviation i.e. = 6.51%
As th e deviatio n between Fair Mar ket Value & Sales Consideration received, is l ess than 10% Marginal Relief provided u/s 50C.
6. The ld. CIT DR, on the other hand, r elie d upon orders of Revenue Authorities. He submitted that Section 43CA is applicable because Sale Deed has been registered during the Accounting Year relevant to Financial Year 2014-15. The only benefit available to the assessee is sub-clause (3) and (4) of Section 43CA. In other words, at the most, collectorate rate deter mining the Stamp Duty valuation on 25.01.2011 could be considered but it cannot be said that Section 43CA is not applicable.
7. We have duly considered the rival contentions and gone through the record car efully. Section 43CA has a direct bearing on the controversy in hand, therefore, we deem it appropriate to take note of this Section, which r ead as under :
Special pr ovision for full value of consideration for transfer of ass ets other than capital assets in certain cases.
43CA. (1)Where the consideration received or a ccru ing as a result of the t ransfer by an assessee of an asset (other than a capital asset), being land or buildi ng or both, is less than th e value a dopt ed o r ass essed or assessable by any authority of a State Gover nment fo r the purpose of payment of stamp dut y in respect of such transfer, the value so ad opted or ass essed or assessable shall, f or t he pur poses ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 8 of co mputing pr ofits an d gains f ro m transf er of such a sset, be deemed to b e the full val ue of the consid eration received or accruing as a result of such transfer.
[Provided that wher e the value adopted or assessed or assessab le by the authority for the purpose of payment of stamp duty does n ot exceed one h undred and ten per cent of the consideration recei ved or accruing as a result of the transfer, the consideration so recei ved or accruing as a result of the transfer shall, for the purposes of co mputing profits and gains from transfer of such asset, be d eemed to be t he full value of the con sideration [Provided further t hat i n ca se of transfer of an a sset, being a residential unit, the provisions of this pr oviso shall ha ve th e effect as if for th e words "one hundred and ten per cent", the words "one hundred an d twenty per cent" had b een substituted, if the following conditions are satisfi ed, namely:--
(i)the transfer of such residential unit takes pla ce during the perio d beginni ng fr om the 1 2th day of November, 2020 and ending o n the 30th day of June, 2021;
(ii)such transfer is by wa y of first time allotment of the residential unit to any p erson; and
(iii)th e consideratio n received or accruing as a result of such transfer does not exceed two crore rupees.] (2) The provisi ons of sub-section (2) and sub-section (3) of sectio n 50C shall, so fa r as may be, apply in relation to determination of the value a dopted or assessed or as sessable under sub-section (1).
(3) Where th e date of agreement fixing the value of consideratio n for transfer of the as set an d the date of registration of su ch transfe r of asset are not t he same, th e value ref erred to in sub-section (1) may be taken as the value ass essable by any authority of a State Government for the purpose of payment of stamp d uty in res pect of such transfer on the date of the agreement.
(4) The provisions of sub -s ection (3) shall apply only in a case where the amount of consid eration or a part thereof has been received [by way of an account payee cheq ue or an account payee bank draft or by use of electronic clearing s ystem through a bank account] [o r through such other elect roni c mode as may be prescribed] on or before the date of agreement for transfer of the asset.] [Explanation -For the purposes of this Section, 'residential unit' means an ind ependent housing unit with separate facilities fo r living, cooking and sanitary requirement, distinctly separated from other resid ential unit within the building, which is directly ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 9 accessible from an outer door or throu gh an interior door in a shared hallway and not by w alking thr ough the living space of another household.]"
7.1 A per usal of this Section would indicate t hat it is param etria to Section 50C of the Incom e Tax Act. It contemplates that where the consideration received or accruing as a result of the transfer by an assessee of an asset, other than a capital asset, being land or building or both, is less than the value adopted or assessed by the Stamp Duty Authority for the purpose of charging Stamp Duty, then such valuation would be deemed as full sale consideration for transfer of such asset. For example, if capital asset is being transferred, then Section 50C will be applicable and in all other cases, Section 43CA would be applicable. However, proviso appended to this Section would further provide that if a reference to the DVO is being made and the value so deter mined by the DVO or by the Stamp Duty Valuation Authority is at valuation of 110%, only then such value would be deem ed as f ull sale consideration. In other words, a tolerance band of 10% is being provided. For example, an assessee has disclosed Rs.100/- as co nsideration received for transfer of the asset and Stamp Duty Valuation Authority has ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 10 deter mined that value by Rs.110/-, then value of the assessee need not to be disturbed. Sub-clause (3) fur ther provides that if the Deed of Agreem ent fixing the value of consideration for transfer of asset and the date of regis tration of such transfer of asset are not the same, then value referred in sub-section (1) of Section 43CA may be taken as the value assessable by any authority of State Government for the purpose of payment of Stamp Duty in respect of such transfer on the date of agreement. In other words, the valuat ion taken on the date of agreement is to be adopted. But, sub-clause (4) puts a condition that paym ent in furtherance of Sale Agreement is to be m ade by banking channel.
7.2 In the present case, Sale Agreem ent was executed on 25.01.2011. Payment was made through account payee cheque and such payments have been made according to the schedule reproduced above. The balance, which was not paid due to the dispute, the vendee has paid the interest. Therefore, the appointed date in this case is 25.01.2011 and the collectorate rate for charging the stamp duty on that day ought to have been adopted. Neither the AO nor the DVO could ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 11 lay their hands on the correct rate of stamp valuation authority on that day. Thus, the value declared by the assessee in the Sale Deed on which stamp duty has been paid is to be construed as the correct value and no addition was required to be made
8. Apart from that, if we looked at from another angle also, we find that alleged inter est charged by the as sessee from the vendee would partake character of sale proceeds because it is an interes t on delayed realization of sale proceeds for registration of the Sale Deed. We have seen this aspect while computing the profit eligible for grant of 80-I wherein it has been held that if sale proceeds are realized late by the assessee and interest is being charged on those sale proceeds, then interest would par-take character of business income upon whom 80-I would be applicable. [ 283 ITR 402 (Hon'ble Gujrat High Court] Nirma Industry and 284 ITR 389 Ind Swiss Jewel (Hon'ble Bombay HC)]. Thus, if this interest is being included in the alleged sale consideration disclosed by the assessee, which we have taken note W hile making r eference to the argum ent of ld. counsel for the assessee, t hen the ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 12 difference of valuation between the sale proceeds determined by the DVO vis-à-vis one adopted by t he assessee is less than 10%. He nce, no addition is r equired to be made on that account also. I n other words, assessee has disclosed sale consideration at Rs.28. 82 Cr. It has charged interest at Rs.6.19 Cr. Total comes to Rs.35.01 Cr. The DVO has deter mined Fair Mar ket Value of the asset at Rs.37.45 Cr. The difference is Rs.2.44 Cr which is less than 10%. Hence, on that ground also, no addition could be made. We are fortified by the or der of the ITAT in assessee's own case for assessment year 2017-18 (ITA No. 73/CHD/2024). This appeal has been decided on 06.08.2024.
9. In view of the above discussion, we ar e of the view that no addition required to be made in the hands of the assessee as per Section 43CA of the Income Tax Act. The additions made by the AO and conf irm ed by the CIT(A) are deleted.
10. In the result, appeal of the assessee for assessment year 2014-15 is allowed.
11. The additions in 2014-15 are also made on the same line, but with a little variance, however, after getting DVO's report, ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 13 AO has passed an rectification order on 23.05.2019 u/s 154 of the I ncome Tax Act. The last paragraph of the AO's order giving effect reads as under :
"2.4 Thus, the order u/s 143(3) is hereby r ectified and the r evised calculation/re-computation of income is as under:-
"Therefore, by taking the values as determined by the DVO vide dated 04.04.2019, a rectification of Rs.11,41,70,333/- is made.
Loss as per Return (-)Rs. 29,36,93,695/-
Add:-
Addition as per para 2.5 of Rs. 11,51,83,469/- A.O. dated 17.12.2018 Reduction of addition made Rs. 11,41,70,333/- Rs. 10,13,136/- as per DVO report Addition u/s 36(1)(iii) as per Rs.3,39,82,642/- order u/s 143(3) dated 17.12.2018 Loss to be carried forward (-) Rs.25,86,97,917/-
Total Addition Rs. 3,49,95,778/-
Loss of Rs. 25,86,9 7,917/- shall b e carried forward . Issue necessary forms, charg e int erest as per law. The penalty pr oceedings u/s 271(1)(c) of the I.T. Act are being initiated separ ately fo r furnishing i naccurate particulars of income.
Ass essed. Issue demand notice.
(Abhinav Ag nihotri ) Asstt. Commissioner of Income T ax, Circle- 2(1), Chandigarh 11.1 A perusal of the above would indicate that the difference in the value for the purpose of deemed sale consideration is Rs.10,13,136/-. It's diff erence is less than 10% of the total sale consideration disclosed by the assessee vis-à-vis ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 14 deter mined by the DVO, therefore, as per first proviso of Section 43(1), addition does not call for. Accordingly, this addition is also deleted and we allow the appeal of the assessee.
12. Now we proceed to take both the appeals of the Revenue together. The Revenue has taken four grounds of appeal in each assessment year. Its grievance revolves around a single issue, namely, CIT(A) has erred in deleting the addition of Rs.4,91,74,146/- and Rs.3,39,82,642/- made on account of treating the interest expenses paid on conversion char ges to Chandigarh Adm inistration for change of land user as revenue expenditure. As observed earlier, assessee has purchased 20.16 acres of industrial land from M/s Pfizer Ltd. The assessee company has obtained approval from Chandigarh Housing Board. It was r equired to pay Conversion Fees of Rs.185.45 Cr, ten percent was to be paid as down payment and remaining over a period of nine years on equated annual instalments with interest @ 8.25%. The assessee company has paid Rs.18,54,54,744/- as down payment on 17.03.2007 and balance was payable in nine equated annual instalments ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 15 together with interest, comm encing from March 26, 2008. The assessee has treated the interest pertaining to the constr uction period as pr e-operative expenditure till Completion Certificate of Mall, office and service building was granted. It has capitalized the alleged interest as per proviso to Section 36(1)(iii) of the Income Tax Act. When the Shopping Mall is put to use, then interest expenditure has been claimed as a revenue expenditure. The AO did not allow the claim of the assessee, however, on appeal, CIT(A) has allowed such claim. The discussion made by the CIT(A) in para 5.2 read as under :
"5.2 Held : I have perused t he order of the Assessin g Officer and examined the reply of the assessee. Brief Facts of the case are that the appellant comp any has purchased 20.16 a cres of industrial land from M/s Pfizer Limited in Chandigarh. It h as obtained approval from Chandigarh Hous ing Board (CHB ) vid e lett er No.C HB/CEO/Land Use/2006/4855 dated 26.03 200 7 for conversion of land from Industrial use. The conversion fee of Rs. 1,85,45,47,440 /- is payable by way of 10% of co nvers ion f ee as dow n paymen t and remaining over a peri od of 9 yea rs in equated in annual installments togeth er with Interest @8.25% p.a. It has paid Rs . 18,54,54 ,7'441- as down pa yment on March 17, 20 07 and balance of Rs. 1,66,90,92,696/- is pa yable in nin e equated annual inst allments together with Int erest commen cing from March 26, 2008. It has capitaliz ed the con version f ee payable as cost of land creating a deferred conversion f ee liability. The i nterest pertaining to the constructi on period was trea ted as pr e-oper ative expenditure till Compl etion Certificate of Mall Office & Service Building and Capitalization a s per proviso t o section 3 6(1)(iii ) of the Act. Meaning th ereby the company has capital ized the interest upto 15-03-2013 i.e. till the date o n w hich asset was put to us e. Int erest upto 14-03-2013 after getting C ompletion Certificate on 22-01 -2 013 w as ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 16 capitaliz ed as pre-operative expenses as p er pro viso to section 36(1)(iii ) and w.e.f. 15.03.2013 was clai med as revenu e expenditure as per s ection 3 6(1)(iii) of A ct being assets put to use. This position was accepted by the AO in the ass essment mad e u/s 143(3) of the Act f or AY 20 13-14. In th e presen t finan cial year, int erest on conversion f ee was Rs.5,69,00,665/- ,out of t his Rs.4,91,7 4,146/- pertains to A ssets p ut to use (Mall, Office & Service buil ding) is claimed as revenue expenditure as per s ection 36(1)(iii) of Act and Rs.77,26,519/- pertains to Hot el Buildin g was capitali zed under pre-operative expenditur e as per pro viso to section 36(1)(iii) of Act. AO has held that even interest expendit ure incurred towards payment of conversion fee paid by the appellant woul d give enduring ben efit in all th e subsequent years and has treated the s ame as capital expenditure.
5.2.1. In 2 005 the C handigarh Administr ation notified that th e business on the industrial site s hould be the sa me for whi ch t he site had b een allott ed. If otherwise then the l and use should be changed from indust rial activity for commercial activity. This issue of interest paid on install ment of CLU Charges has also come fo r adjudication at diff erent judicial forum. The Hon 'b le ITAT, Cha ndigarh Ben ch in the case of S anjay Dah uja vs. AC IT in IT A Nos. 95 & 96/Chd/2017 has held that th e payment of interest on conversion char ges after la nd was first put to use for conducting commercial activities shall not form part of th e actual cost of such l and. The Hon'ble IT AT Delhi Ben ch 'E' i n the cas e of Deputy Director of Income Tax v. Mi cron Instru ments (P ) Ltd T20151 38 ITR (T) 2 42 (Delhi Tri.) has taken the same view on ident ical facts. Moreover, my pred ecessor, recently in the case of Sh. Vijay Passi ITA No.2 55/15-16 for AY 2013 -14 dated 07.02.2017 has taken t he same view by ho ldin g as under:
4.5 Th e facts of this case are identical to th e fa cts of th e case of M/s Micr on Instruments (supra). The a pp ellant h as been runni ng the business since long and Cha ndigarh Admi nistration came out with a scheme for payment of conversion charges for change of lan d use fro m industrial to co mmercial vide which th e appellant was required to pay charg es as per notifi cati on in Septemb er 2005. Th e appellant capitalized the conversion charges and claimed the i nterest payment as revenue exp ense. The 'chara cter of the expense has to be construed from t he nature of the transact ion . The Ld. CIT(A), Cha ndigarh in the case of M/s Leela Mercantile (supra) has discussed that th e interest would part akes th e chara cter of th e prin cipal amo unt. It would have been the case if the business of th e appellant w as yet to commence. If any exp ense in cluding interest i s incurred for acquisi tion of a n ew asset, it h as ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 17 to be capitaliz ed till the asset has b een put to use or th e busines s is yet to commence and t hereafter (aft er it is put to use or business h as commenced) t reated as a revenu e expense. In this case, it is pertinent to note that th e busines s of the appellant of th e app ellant is in existen ce and r unning. Ther efore, interest payment would be a revenue expense. Hence, the addition mad e by the Assessing Officer is deleted and ground o f appeal No. 2 is allowed."
5.2.2. The facts of the instant case ar e identical and the asset in questio n had been put to use, there is no occasio n to treat inter est as capital expenditure. AO is directed to delete the additi on. The Grou nd of App eal No.1 is allowed."
13. With the assistance of ld. Representative, we have gone through the r ecord carefully. It is pertinent to note that asset in the case of the assessee was put to use on 14.03.2013. Till the Shopping Mall was under construction and asset was not put to use, assessee has capitalized this expenditure but the asset has been put to use. As per Section 36(1)(iii) of the Act, it is allowable as a revenue expenditure. The ld. CIT(A) has made an elaborate discussion in the finding extracted supra. It has followed the order of the ITAT in the case of Vijay Passi ITA No.255/2015-16. The ld. CIT(A) has also r eferr ed other judgements in the above finding (paragraph 5.2.1). Thus, we find that view taken by the ld. CIT(A) is in consonance with the proposition laid down by the ITAT as well as in consonance to Section 36(1)(iii) of the Income Tax Act. No interference is ITA No.131, 132, 146,147/CHD/2020 A.Y.2014-15 & 2015-16 18 called for. Accordingly, the appeals of the Revenue are dismissed in both t he years.
14. In the r esult, both the appeals of the assessee are allowed and that of the Revenue are dismissed.
O r d e r p ro n o un ced o n 28 . 0 5. 2 02 5 .
Sd/- Sd/-
(KRINWANT SAHAY) (RAJPAL YADAV)
ACCOUNTANT MEMBER VICE PRESIDENT
"Poonam"
आदे श क त ल प अ े षत/ Copy of the order forwarded to :
1. अपीलाथ / The Appellant
2. यथ / The Respondent
3. आयकर आयु त/ CIT
4. वभागीय त न ध, आयकर अपील य आ धकरण, च डीगढ़/ DR, ITAT, CHANDIGARH
5. गाड फाईल/ Guard File
आदे शानस
ु ार/ By order,
सहायक पंजीकार/ Assistant Registrar