Income Tax Appellate Tribunal - Pune
Chordya Kalpana Manoj, Nashik vs Assessee on 10 January, 2012
1
ITA No. 562 to 564/PN/2007
Chordiya group
B.P 1-4-1995 to 27-2-2001
IN THE INCOME TAX APPELLATE TRIBUNAL
Pune Bench A, Pune
Before Shri Shailendra Kumar Yadav, Judicial Member
and Shri G.S. Pannu, Accountant Member
I.T.A. No.562/PN/2007
Block period: 1.4.1995 to 27.2.2001
Chordiya Manoj Shantilal, HUF, ... Appellant
1 & 2 Gitashree Apartment,
Canada Corner, Nashik-5
P No.AABHC 0669 Q
Vs.
ACIT, Cent.Circle-3, ... Respondent
Nasik
I.T.A. No.563/PN/2007
Block period: 1.4.1995 to 27.2.2001
Shri Chordiya Mahesh Shantilal, ... Appellant
1 & 2 Gitashree Apartment,
Canada Corner, Nashik-5
P No.ACTPC 2037 Q
Vs.
ACIT, Cent.Circle-3, ... Respondent
Nasik
I.T.A. No.564/PN/2007
Block period: 1.4.1995 to 27.2.2001
Mrs Chordiya Kalpana Manoj, ... Appellant
1 & 2 Gitashree Apartment,
Canada Corner, nashik-5
P No.ADPPC 3098 Q
Vs.
ACIT, Cent.Circle-3, ... Respondent
Nasik
Appellant by: Shri Kishore P Rodke
Respondent by: Shri Hareswar Sharma
Date of hearing: 10-1-2012
Date of pronouncement: 24-1-2012
2
ITA No. 562 to 564/PN/2007
Chordiya group
B.P 1-4-1995 to 27-2-2001
ORDER
PER BENCH These appeals filed by the different assesses of same group arise out of the order u/s.158BC r.w.s. 143(3) of the I.T. Act for the block period 1.4.1995 to 27.12.2001 so there are being disposed off by common order.
2. In the case of Chordiya M. Shantilal in ITA No. 562/PN/2007 the assessee has raised the following grounds.
"1. On the basis of facts and in the circumstances of the case, the CIT(a)-1, Nashik is not justified in not giving the benefit of telescoping of income against the investment on the basis that returned income and assessed income is the same.
2. On the basis of facts and in the circumstances of the case, the CIT(A) is not justified in confirming the addition of Rs.66,100 as undisclosed income on account of investment in FDRs/RDs.
3. On the basis of facts and in the circumstances of the case, the CIT(A) is not justified in confirming the addition of Rs.8,900 as undisclosed income on account of error & omissions.
4. On the basis of facts and in the circumstances of the case, the CIT(A) is not justified in confirming levy of interest charged u/s.158BFA(1) of the Act."
3. In the course of block assessment proceedings, the Assessing Officer noticed that the assessee has made investment in FDRs in the name of his daughter Miss Sejal Chordiya of Rs.7,000 in United Western Bank and Rs. 25,000 in NAMCO Bank and Rs.25,000 in the name of Akshay Chordiya in NAMCO Bank. He also noticed that there is a recurring account for Rs.3000 per month in the name of Miss Sejal Manoj Chordiya, which was opened on 15.7.2000 and the date of maturity was 17.7.2001. The total amount deposited in the recurring account was Rs.9100. Thus, the AO calculated the total amount of investment in FDRs and 3 ITA No. 562 to 564/PN/2007 Chordiya group B.P 1-4-1995 to 27-2-2001 recurring account at Rs.66,100/-. Since the assessee failed to explain the source of deposits, the AO treated the same amount as unexplained income for the block period.
3.1 In appeal before the CIT(A), the assessee contended that the AO has not correlated the fixed deposit amount of Rs.57,000 with the seized material, therefore, the addition is not justified. The CIT(A) called for a remand report from the Assessing Officer and after considering the same, inter alia, observed that the assessee has not brought into light any corroborative materials to nullify the findings of the AO to substantiate the investments made in FDRs and recurring deposit account; the onus to substantiate the same is on the assessee and not on the department. The CIT(A) also was of the opinion that the assessee has not brought on record any material as to how the said addition violated any specific provisions of the I.T.Act. Accordingly, the order of the CIT(A) was upheld. Aggrieved, the assessee is in appeal before us.
3.2 After hearing both the sides and having perused the material on record, we find that we find that the CIT(A) called for a remand report. The assessee has not brought out anything on record to nullify the finding of the Assessing Officer in the assessment proceedings. The onus to substantiate the claim was on the assessee and not on the department. The assessee has not brought out any material as to how the addition was made in the specific provision of the Act. The assessee has not objected to the addition made by the Assessing Officer and confirmed by the CIT(A) by cogent reasons. So the order of the CIT(A) on the issue needs no interference at our hands. The same is upheld.
4. The next issue is with regard to addition of Rs.8,900 on account of errors & omissions.
4ITA No. 562 to 564/PN/2007 Chordiya group B.P 1-4-1995 to 27-2-2001 4.1 In the course of assessment proceedings, the AO noticed that the assessee has shown the undisclosed income of Rs.6,62,597 on account of errors and omissions claimed to be in respect of cash deposits in the bank accounts of the family members as under:
i) Mahesh S.Chordiya : Rs.2,91,123
ii) Mrs Sunderbai S.Chordiya: Rs.1,24,100
iii) Mrs Kalpana M.Chordiya : Rs.1,72,374
---------------
Rs.5,87,597
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4.2 The AO after taking into consideration the amount of Rs.6,53,697 (Rs.5,87,597 family deposits in bank + Rs.66,100 as FDRs and recurring deposit) observed that the balance amount i.e. Rs.8,900 (Rs.6,53,697 - Rs.5,87,597) is without any investments or discrepancies and the assessee has not filed any details about the same. In view of this, the AO treated Rs.8,900 as undisclosed income. The action of the AO was upheld by the CIT(A) same has been opposed before us. Having considered the rival contentions and having perused the material on record, we find no infirmity in the order of the CIT(A) to interfere. The addition has been made on the basis of details furnished by the assessee. We, accordingly, uphold the order of the CIT(A).
5. The next ground is against levy of interest charged under section 158BFA(1) of the Act.
5.1 After hearing both the sides, we find that the due date of filing the return was 15.6.2002 and at the request of the assessee, the date was extended for another period of 20 days by the Assessing Officer. The assessee has filed the return of income on 1.7.2002. In view of this, we are of the view that the extended date shall replace the earlier date specified or period specified in the said notice for filing the return. We also find that in similar issue in the case of Shri Chordiya Manoj Shantilal in ITA No.130/PN/2007 vide order 5 ITA No. 562 to 564/PN/2007 Chordiya group B.P 1-4-1995 to 27-2-2001 dated 31.8.2010, this Tribunal has reversed the order of the CIT(A) and allowed the ground taken by the assessee. Consistent with the decision of the Tribunal and also considering the fact that the assessee has filed the return as per time allowed by the AO, no interest is required to be levied in this case. We accordingly, reverse the order of the CIT(A) and allow the ground taken by the assessee. In the result, this appeal is partly allowed as indicated above.
ITA No.563/PN/2007:6. The assessee has raised the following grounds in this appeal:
"1. On the basis of facts and in the circumstances of the case the CIT(A)1, Nashik is not justified in confirming the stand of the AO in respect of refund of advance received Rs. 85,870/- as unproved credit thereby resulting into addition of the same as undisclosed income.
2.On. the basis of facts and in the circumstances of the case the CIT(A), Nashik is not justified in confirming the stand of the AO in respect of sale of car by the appellant for Rs. 1,24,800/- as unproved thereby :resulting into addition of the same as undisclosed income.
3. On the basis of facts and in the circumstances of the case the CIT(A)1, Nashik is not justified in confirming the stand of the AO in respect of refund of advances given of Rs. 30,000/- as unproved credit thereby resulting into addition of the same as undisclosed income.
4. On the basis of facts and in the circumstances of the case the CIT(A)1, Nashik is not justified in confirming the stand of the AO in respect of sale of tankar by the appellant for Rs. 2,65,359/- as unproved thereby :resulting into addition of the same as undisclosed income.
5. On the basis of facts and in the circumstances of the case the CIT(A)1, Nashik: is not justified in confirming the addition of Rs. 58,925 as undisclosed income on account of investment in shares of M/ s. Baffin Engineering Projects Ltd.
6. On the basis of facts and in the circumstances of the case the CIT(A)1, Nashik is not justified in confirming the addition of Rs. 75,000 as undisclosed income on account of unexplained 6 ITA No. 562 to 564/PN/2007 Chordiya group B.P 1-4-1995 to 27-2-2001 cash deposits
7. On the basis of facts and in the circumstances of the case the CIT(A)1, Nashik is not justified in confirming the addition of Rs. 59,1001.,..-/ as undisclosed income on account of investment in FDRs/ RDs
8.On the basis of facts and in the circumstances of the case the CITA)1, Nashik is not justified in confirming the addition of Rs. 85,000/- as / undisclosed income on account of error .& omissions.
9. On the basis of facts and in the circumstances of the case the CIT(A)L Nashik is not justified in confirming levy of interest charged U/s. 158BFA(
1) of the Act."
7. Grounds No.1 to 4 were not pressed, therefore, the same are dismissed as not pressed.
8. Next issue is with regards to addition of Rs. 58,925/-. The Assessing Officer made an addition of Rs.58,025 on account of unexplained investment in shares of M/s. Baffins Engg. Projects Ltd., on the ground that the investment was shown by the assessee in the balance sheet as on 31.3.2001 prepared after the date of search and filed along with the revised returns of A.Y.2001-02 which was filed on 21.2.2002. The action of the AO was confirmed by the CIT(A). The same has been opposed before. On the other hand, the learned DR supported the orders of authorities below.
9. After hearing both the sides, we find that there was a deposit of Rs. 8,38,218/- on 10-10-2011 in his having S.B. A/c No. 9131 with United Western Bank and the same was subjected to inquiry during the course of search/post search and assessment proceedings. During the course of recording a statement u/s 131 on 131 on 25-2-2002, the assessee admitted that he purchased the shares of M/s Baffins Engineering Projects Ltd. The assessee himself admitted in letter dated 10-2-2005 that the balance sheet as enclosed with return of income was absolutely wrong as the contents of the same are undisputedly wrong. After this was 7 ITA No. 562 to 564/PN/2007 Chordiya group B.P 1-4-1995 to 27-2-2001 found immaterial that the assessee could explain the same with support of fund flow statement and revised balance sheet prepared after the date of search. There is nothing on record to suggest that shares are declared in the returns due and filed by the assessee before the date of search and not after that. It is for the assessee to declare the actual facts in the original balance sheet and other documents thereof and not for the department to dig it and accept the revised balance sheet and other materials thereof prepared and filed after the date of search action. The fund flow statements prepared and filed by the assessee after the date of search cannot be construed as evidence in the block assessment proceedings. The same are not consistent with the returns filed before the date of search nor based on any entries in the seized documents apart from the fact that the assessee could not substantiate the correctness of the said fund flow statements with the support of any independent and corroborative evidences. In the light of this, the CIT(A) was justified in upholding the action of the Assessing Officer which needs no interference from our side. We uphold the same.
10. The next issue is with regards to the addition of Rs. 75,000/- as undisclosed income on account of unexplained cash deposits. The facts in brief are that the cash deposits in the savings bank a/c No. 9131 of the assessee with United Western Bank Ltd., could not be substantiated by the assessee with the production of the relevant persons, with support of contemporary evidences, entries in the seized materials, etc. These cash deposits have come to light as a result of action u/s 132 and inquiries conducted thereafter. The Assessing Officer has dealt with this issue in para 3.8 of his order. The CIT(A) having called the remand report and considering the submissions made on behalf of the assessee observed that finding the Assessing Officer in the block assessment order are not null and void. Disclosure of the bank account to the department does not give any immunity to the assessee/assessee from its scrutiny and 8 ITA No. 562 to 564/PN/2007 Chordiya group B.P 1-4-1995 to 27-2-2001 resultant consequences. The assessee himself admitted that there were errors in the original balance sheets which necessitated filing of revised balance sheets. The stand of the assessee has been that the cash deposits of Rs. 7,52,708/- in his bank account were made out of the undisclosed fund of Rs. 6,77,708/- of the family members of the assessee depicts the inability of the assessee to substantiate his initial stand that the cash deposits were made out of business income, refund of advances, withdrawals, salary etc. It shows that the assessee failed to substantiate his claim with regard to the addition in question and the same was rightly upheld by the CIT(A) which needs no interference. We uphold the same.
11. The next issue is with regards to addition of Rs. 59,100/- as undisclosed income. The Assessing Officer found that the assessee has made investment in FDRs and RDs in the name of Miss Ridhi chordiya and Master Akash Chordiya, daughter and son of the assessee. Rs. 25,000/- each in NAMCO Bank. Further, the page no. 101 to 105 of bundle No. 45, there is a recurring account No. 7A0117/738213 for Rs. 3,000/- per month in the name of Miss Ridhi Mahesh Chordiya, which was opened on 15-7-2000 and maturity date was 17-7-2001. The total amount deposited in the said recurring account is Rs.9,100/-. Thus the total investments made in the FDR and recurring deposits worked out to Rs.59,100/-. During the course of assessment proceedings, the assessee was asked to explain the source of these deposits and recurring account. The assessee has failed to prove the investments made in the above FDRs and RDs. Accordingly, the addition was made and the matter was carried before the first appellate authority who confirmed the same. Same has been opposed before us.
12. After hearing both the parties and perusing the material on record, we find that the CIT() having considered the remand report and rejoinder proceedings, found that no fresh materials have been brought on record either by the Assessing Officer or the assessee.
9ITA No. 562 to 564/PN/2007 Chordiya group B.P 1-4-1995 to 27-2-2001 The onus was on the assessee to establish the source of funds for such investment. The statements of affairs and/or the fund flow statements by themselves are not the evidence. It was for the assessee to substantiate the entries in the statements of affairs and/or the fund flow statement. In fact, the assessee could not substantiate the claim with regards to fund with cogent reasons. Accordingly, the CIT(A) was justified in upholding the addition in question. The same needs no interference from our side.
13. The next issue is with regards to addition of Rs. 85000/- on account of errors and omissions. According to the Assessing Officer, the assessee himself declared in the block return as undisclosed income a sum of Rs. 85,000/- and the narration thereof was furnished by the assessee vide his representative's letter dated 4-11-2003 as "contingencies, Errors and Omissions, if any". It was also a fact that the assessee has, for the reasons best known to him withheld the details of capitalisation of the undisclosed income of Rs. 85,000/- shown in the block return. The onus was on the assessee to substantiate the contents of the return including the income returned. Accordingly, the addition was made. In appeal, the CIT(A) observed that the Assessing Officer has not made any addition as alleged by the assessee. What the Assessing Officer has done is simply accepting the amount declared in the block return under the assessee's own narration or breakup "contingencies, Errors and Omissions, if any". Under these facts and circumstances of the case, the CIT(A) was justified in not interfering the admissions position given by the assessee. The same needs no interference from our side.
14. The next issue is with regards to leviability of interest u/s 158BFA(1) of the Act. Similar issue came up for consideration before us in the case of Chordiya M. Shantilal for A.Y. 2002-03 and for the detailed reasoning given in preceding paragraph of this order, this issue is decided in favour of the assessee.
10ITA No. 562 to 564/PN/2007 Chordiya group B.P 1-4-1995 to 27-2-2001 ITA No.564/PN/2007
15. The grounds raised in this appeal are as under:
1. On the basis of facts and in the circumstances of the case the CIT(A)I Nashik is not justified in confirming the addition of Rs. 19,032 as undisclosed income on account of investment for purchase of agricultura1 land in S.No. 111/2/1.
2 On the basis of facts and in the circumstances of the case the CIT(A)I Nashik is not justified in confirming the addition of Rs. 58,495 as undisclosed income on account of investment in shares of M/s. Baffin Engineering Projects Ltd.
3 On the basis of facts and in the circumstances of the case the CIT(A)1. Nashik is not justified in confirming the addition of Rs. 50,192/- as undisclosed income on account of error & omissions.
4 On the basis of facts and in the circumstances of the case the CIT(A)1, Nashik is not justified in confirming the addition of Rs. 1,91,315/- in bank as undisclosed income on account of unexplained cash deposits 5 On the basis of facts and in the circumstances of the case the CIT(A)1, Nashik is not justified in confirming levy of interest charged U/s. 158BFA( 1) of the Act.
16. The first issue is with regards to addition of Rs. 19,032/- (Rs. 17,500 + 1,432) on account of unexplained payments made in respect of purchase of land at S.No. 111/211, Gangapur, Nasik. The Assessing Officer has adduced the following reasons for coming to the conclusion that an amount of Rs. 19,032/- is taxable as undisclosed income of the assessee for the block period.
"8.1 The assessee has purchased agricultural land in survey No. 111/2/1, Gangapur jointly along with two other persons namely Mrs Arati Mahesh Chyordiya and smt Girjabai Kawde for the consideration of Rs. 4,11,000/-. The assessee has shown her share of Rs. 1,48,000/- as investment. As per loose paper bundle no. A-1 pages no. 77 to 87 is the purchase deed dated 30-3-1999. As per this deed the assessee has 11 ITA No. 562 to 564/PN/2007 Chordiya group B.P 1-4-1995 to 27-2-2001 incurred stamp duty of Rs. 33,360/- and registration fees of Rs. 4,236/-. Hence, total consideration works out to Rs. 4,48,596/-. The assessee's 1/3rd share works out to Rs. 1,49,532/-. Hence, assessee has shown an investment of Rs. 1,532/- less in the said property. Therefore, an amount of Rs. 1,532/- is treated as assessee's undisclosed income for the A.Y. 1999-00 for the block period. As per this purchase deed agreement, it has been mentioned in the deed that purchaser has paid an amount of Rs. 3,11,000/- in cash from time to time. During the course of assessment proceedings, the assessee was asked to explain the source of cash payment made for purchase of this land from time to time. The assessee has explained that she has paid an amount of Rs. 1,30,500/- by cheque to Shri M.P. Kale from the United Western Bank on 18-11-1998. However, balance amount of Rs. 17,500/- paid by the assessee in cash is not explained. Therefore, an amount of Rs. 17,500/- is treated as undisclosed income for the A.Y. 1999-00 for the block period. Hence total undisclosed income on account of purchase of agricultural land at Gangapur works out to Rs. 19,032/- and same is treated as undisclosed income of the assessee for the block period."
The action of the Assessing Officer was confirmed by the CIT(A). Same has been opposed before us.
16.1 We find that on the basis of seized material, the assessee's share in the purchase of land at Gangapur, Nasik bearing S.No. 111/2/1 is Rs. 1,49,532/- inclusive of stamp duty and registration fees. The said investment of Rs. 1,49,532/- was made by the assessee by cheque partly by cheque and party by cash. These facts are not disputed by the assessee. The records show that the assessee failed to substantiate the said cash payments with the support of corroborative evidence showing cash on hand on the relevant dates. The appearance of the said investment in the statement of affairs and/or fund flow statements cannot be the conclusive evidence in respect of the said cash payments. The onus is on the assessee to 12 ITA No. 562 to 564/PN/2007 Chordiya group B.P 1-4-1995 to 27-2-2001 substantiate the entries in the statements of affairs and/or the fund flow statements. The disclosure of agricultural income cannot itself justify the cash payments. In facts and circumstances, the CIT(A) was justified in confirming the addition made by the Assessing Officer on account of such cash investment. The same needs no interference from our side.
17. The next issue is with regards to addition of Rs. 58,495/- being investment in shares of M/s Baffins Engg. Projects Ltd. The addition of Rs. 58,495/- represents the investments made by the assessee in purchase of shares of M/s. Baffins Engg. Projects Ltd. The Assessing Officer has dealt with this in detail vide para 8.3 of the block assessment order. The learned DR supported the order of the CIT(A).
17.1 We find that the issue of depositing cheque of Rs. 8,45,045/- on 10-10-2011 in S.B. a/c No. 9598 of the assessee with United Western Bank, Nasik was subjected to inquiry during the course of search and assessment proceedings. The material on records show that the assessee purchased and sold the said shares but the transactions of purchases and sales of shares were not stated by her. The records also revealed that even during the course of assessment proceedings, the assessee failed to substantiate that the returns filed with the department on or before the date of search contained the details of the said shares. The assessee herself admitted vide her letter dated 10-2-2005 that "the balance sheet as enclosed with the return of income was absolutely wrong as the contents of the same were also undoubtedly wrong and the contents of the same were also undoubtedly wrong. It was immaterial that the assessee could explain the same with 13 ITA No. 562 to 564/PN/2007 Chordiya group B.P 1-4-1995 to 27-2-2001 the support of the fund flow statement and revised balance sheet prepared after the date of search. What was material is that as to whether the details of the purchases/sales of the said shares were declared in the returns due and filed by the assessee before the date of search and not after that. The fund flow statements prepared and filed by the assessee after the date of search could not be construed as a plinth for the block assessment proceedings as the same are neither consistent with the returns filed before the date of search nor based on any entries in the seized materials, apart from the fact that the assessee could not substantiate the correctness of the said fund flow statements with the support of independent and corroborative evidence. In the light of these facts and circumstances, the CIT(A) was justified in upholding the addition of Rs. 58,495/-. The same needs no interference from our side. We uphold the same.
18. The next issue is with regards to addition of Rs. 50,192/- on account of errors and omissions. The facts are that the assessee herself declared in the block return as undisclosed income of a sum of Rs. 50,192/- and the narration thereof was furnished by the assessee vide her representative's letter dated 14-11-2003 as "contingencies, errors and omissions, if any". The assessee for the reasons best known to her, withheld the details of capitalization of the undisclosed income of Rs. 50,192/- shown in the block return. The assessee could substantiate her claim with cogent reasons. The Assessing has simply accepted the amount declared in the block return under the assessee's own narration or break up. In the facts and circumstances therefore, the CIT(A) was justified in sustaining the addition made by the Assessing Officer which needs no interference from our side.
14ITA No. 562 to 564/PN/2007 Chordiya group B.P 1-4-1995 to 27-2-2001
19. The next issue is with regards to addition of Rs. 1,91,315/- on accounts of unexplained cash deposits in western United Bank and Madhura Bank. The Assessing Officer has dealt with this issue in para 8.5 of his order and made the addition of this amount. The last portion of the Assessing Officer's order is reproduced as under:
"Subsequently, the assessee has claimed that out of the above unexplained cash deposits of Rs. 3,63,689/- in her bank accounts were made out of the undisclosed fund of Rs. 1,72,374/- of Shri Manoj S. Chordiya (HUF) and the said amount is offered by the said person as his undisclosed income in his block returns. The confirmation of Mr. Manoj S. Chordiya (HUF) is filed. Hence the assessee requested that the amount of Rs. 1,72,374/- should not be taxed s her undisclosed income and therefore, the remaining amount of Rs. 1,91,315/- is taxed as her undisclosed income. The assessee's claim is accepted and accordingly the balance amount of cash deposits of Rs. 1,91,315/- are taxed as undisclosed income of the assessee for the block period"
19.1 This issue has also been the subject matter of remand report and rejoinder proceedings. We find that the deposits have come to light as a result of search action and resultant verification of the bank accounts of the assessee. It is also seen from the records that the balance sheets filed before the search have subsequently revised by the assessee and the assessee herself admitted in her submissions the revised balance sheets were the true balance sheets. The revised balance sheets and the fund flow statements prepared and filed by the assessee after the date of search action cannot by themselves be conclusive evidence in relation to the financial aspects of the assessee unless they have been substantiated with the support of documentary evidence, which the assessee failed to do. Further, the balance sheets filed before the 15 ITA No. 562 to 564/PN/2007 Chordiya group B.P 1-4-1995 to 27-2-2001 date of search did not contain the details of loans advanced by the assessee. The assessee could not substantiate her claim with cogent reasons. In the facts and circumstances of the case, we do not find any infirmity in the order of the CIT(A) in confirming the action of the Assessing Officer.
20. The next issue is with regards to levy of interest u/s 158BFA(1) of the Act. Similar issue came up for consideration before this Bench of the Tribunal in the case of Chordiya Manoj Shantilal in ITA No. 562/PN/2007 and for the reasons mentioned in preceding paragraphs, this issue is decided in favour of the assessee.
21. In the result, all the appeals of the assesses are partly allowed as indicated above.
Decision pronounced in the open court on 24th January 2012.
Sd/- sd/-
(G.S. PANNU) (SHAILENDRA KUMAR YADAV)
Accountant Member Judicial Member
Pune dated the 24th January 2012
Ankam
Copy of the order is forwarded to :
1. The Appellant
2. The Respondent
3. The CIT(A)-I Nasik
4. The CIT - I Nasik
5. The D.R, ITAT Pune Bench, Pune
6. Guard File
By order
Assistant Registrar
Income Tax Appellate Tribunal