Income Tax Appellate Tribunal - Amritsar
Sh Sri Gyan Vikas Kendra, Jalandhar vs The Assistant Commissioner Of Income ... on 31 August, 2017
IN THE INCOME TAX APPELLATE TRIBUNAL
AMRITSAR BENCH; AMRITSAR
BEFORE SH. T.S. KAPOOR, ACCOUNTANT MEMBER AND
SH. N.K.CHOUDHRY, JUDICIAL MEMBER
I.T.A No.110(Asr)/2017
Assessment Year:2014-15
Sri Sri Gyan Vikas Kendra, Vs. Asst. CIT,
64, Old Jawahar Market, Centralized Processing Cell,
Jalandhar. Ghaziabad.
PAN:AADTS -5371E
(Appellant) (Respondent)
Appellant by: Sh. A.P. Singh (Ld. C.A)
Respondent by: Sh. Rahul Dhawan (Ld. D.R)
Date of hearing:30.08.2017
Date of pronouncement:31.08.2017
ORDER
PER N.K.CHOUDHRY:
The instant appeal has been filed by the assessee, by feeling aggrieved against the order dated 08.12.2016 passed by the Ld. CIT- 2, Jalandhar in appeal No.166/15-16, for Asst. Year: 2014-15.
2. The assessee has raised the following grounds of appeal.
"1. That the order of the CIT (Appeals) is against the law & facts of the case.
2. That the CIT (Appeals) had gravely erred in law & facts of the case in sustaining the order of the Assistant Commissioner Of Income Tax (Centralized processing Cell-TDS)
3. That the CIT (Appeals ) had gravely erred in upholding the order of Assistant Commissioner Of Income Tax (Centralized processing Cell-TDS) who had levied late filing fee u/s 234E in the hands of the assessee and raised a demand of Rs.1,71,000/-2 ITA No.110 (Asr)/2017
Asst. Year: 2014-15
4. That the CIT (Appeals) while sustaining the demand of Rs.1,71,000/- so raised by the Assistant Commissioner Of Income Tax (Centralized processing Cell- TDS) on account of late filing fee had misconceived the facts of the case in light of the settled position of law.
5. Any other ground of appeal as may be allowed to be raised at the time of hearing of the appeal."
3. The brief facts of the case are as under:
The assessee is a "charitable Society" duly registered with the 'Registration of Societies Act & also u/s 12A of the Income Tax Act. The assessee deducted TDS on certain payments & duly deposited along with interest on which there is no dispute. The assessee filed TDS return for the Asst. Year:2014-15 which was delayed & while processing the TDS return U/S 200A by the centralized processing cell
-TDS Ghaziabad, levied the Late filing fee of Rs.1,71,000/- u/s 234E of the Income Tax Act 1961 vide intimation dated 20/11/2015 & against which the 1st appeal was preferred before the Ld. CIT(A), who was pleased to justify, imposing the late filing fee of Rs.1,71,000/- U/s 234(e) of the I.T. Act by holding as under:
"4.2 I have gone through the submissions made in this regard and material brought on record and find that a late filing fee Rs.1,71,000/- has been imposed by the ACIT (CPC) on account of delay in filing of TDS return for Q1 of F.Y. 2013- 2014. The appellant has merely reproduced the provisions of section 200A of the IT Act along with the provisions of section 234E of the I.T. Act. The appellant has further relied upon the decision of Hon'ble ITAT, Amritsar Bench in the case of SIBIA HEALTHCARE (Pvt.) Ltd. in ITA No.90(Asr)/2015 along with other decisions of Hon'ble ITAT Chennai Bench on this issue.
3 ITA No.110 (Asr)/2017Asst. Year: 2014-15 4.3 Having considered the submissions made in this regard, I find that Hon'ble ITAT, Amritsar Bench has decided in the case SIBIA HEALTHCARE (P) Ltd. in ITA No.90(Asr)/2015 that additional fee cannot be charged in respect of order passed before 01.06.2015. However, in this case I find that TDS Return has been filed on 17.11.2015 and processing of TDS Return has been done on 20.11.2015, which is much after the date of 01.06.2015. Therefore, the decision of Hon'ble ITAT would not be applicable in the present factual circumstances of the case.
4.4 Accordingly, I hold that in the present facts of the case, ACIT (CPC) was justified in imposing the late filing fee of Rs.1,71,000/- 234E of the I.T. Act and confirmed the same."
4. Feeling aggrieved against the order passed by the Ld. CIT(A), the assessee preferred the instant appeal which is under consideration.
5. It was argued by the Ld. Counsel of the assessee that the Ld. Assessing Officer (CPC-TDS) has grossly erred in law in levying late filing fee of Rs.1,71,000/- and raising the demand u/s 200A of the Act. It was further submitted by the Ld. AR that up to 31st May, 2015 there was no enabling provision in the Act for raising a demand in respect of levy of fees u/s 234E of the Act, however, after 31st May, 2015 levy of late filing fee u/s 234E was introduced by Finance Bill, 2015.
In the instant case, the TDS return for Quarter ending 30th June, 2013 was due to be filed on or before 15.07.2013, but admittedly the return was filed on 17.11.2015 i.e., delayed by 855 days on which the due interest was paid before the filing of TDS return and the TDS return was processed by CPC (TDS) on 19.11.2015 u/s 200A of the Act 4 ITA No.110 (Asr)/2017 Asst. Year: 2014-15 and while processing and issuing the intimation of TDS return u/s 200A of the IT Act, the CPC-(TDS) levied late filing fee u/s 234E @ Rs.200/- for 855 days i.e. Rs.1,71,000/- i.e.,(Rs.200 x 855 days) from the period 15.07.2013 to 17.11.2015 i.e. period of delay in filing the TDS return. It was further argued that amendment in sec. 200A was brought by the Finance Act, 2015 only and prior to that there was no enabling provision in the 'Act' for raising a demand in respect of levy of fees under Sec.234E.
The Ld. AR also relied upon the judgment passed by the Co- ordination Bench of ITA, Amritsar in the case of Sibia Healthcare Pvt. Limited Vs. DCIT(TDS) ITA No.90(Asr)/2015 dated 09.06.2015 and argued that the aforesaid judgment squarely covered the case of the instant assessee as well as. The Hon'ble ITAT Amritsar Bench in the said case, in the absence of enabling provision u/s 200A deleted the fee levied u/s 234E.
It was also submitted by the Ld. AR that amendment in the Finance Act,2015 which came to be effective w.e.f., 1st June, 2015 cannot be treated as retrospective in nature because it is well settled law as well as fundamental right of the citizen which is prescribed under Article20(1) of the Indian Constitution, 1949 , which provides that the person cannot be subjected to penalty greater than that which might have been inflicted under the law in force at the time of the commencement of the offence. The assessee has also prepared the chart and finally submitted that the assessee is not disputing the liability of default from 1st June, 2015 to 17th Nov., 2015, however, the late fee for the period from 15th July, 2013 to 31st May, 2015 cannot be levied. Hence, the same is liable to be deleted.
5 ITA No.110 (Asr)/2017Asst. Year: 2014-15
6. On the contrary, it was argued by Ld. DR that admittedly in the instant case, due date of return was 15th July, 2013, however, the same was filed only on 17th Nov. 2015 and thereafter, order u/s 234E was intimation u/s 200A of the I.T. Act was given on 20th Nov.2015, therefore, the late fee has to be levied from the due date of return and up to the date of filing of regular statement. Hence, the order passed by the Ld. CIT(A) cannot be faulted because the matter pertains to the period after 1st July, 2015 when the provision of late fee enabled.
7. We have gone through with the facts and circumstances of the case, for the sake of convenience and brevity, we feel it appropriate to reproduce the statutory provision prior to 1st June, 2015.
STATUTORY PROVISIONS PRIOR TO AMENDMENT
(BEFORE 01.06.2015)
The Provisions of Sec 234E of the Act, which was inserted by the Finance Act 2012 and was brought into effect from 1.07.2012, are as follows:-
234 F. Fee for defaults in furnishing statements
ii) Without prejudice to the provisions of the Act, where a person fails to deliver or cause to he delivered a statement within the prescribed in sub -section (3) of section 200 or the proviso to subsection (3) of Sec. 206C, he shall be liable to pay, by way of fee, a sum of two hundred rupees for every day during which the failure continues.
( 2) The amount of fee referred in sub-section (1) shall not exceed the amount of tax deductible or collectible, as the case may be.
(3) The amount of fee referred to in sub-section (1) shall be paid before delivering or causing to be delivered a statement in accordance with sub-section (3) of section 200 or the proviso to sub-section(3) of section 206C.
6 ITA No.110 (Asr)/2017Asst. Year: 2014-15 (4) The provisions of this section shall apply to a statement referred to in sub-section (3) of section 200 or the proviso to sub-section(3) of section 206C which is to be delivered or caused to be delivered for tax deducted at source or tax collected at source, as the case may on or after the Is' day of July,2012 The statutory provisions of Section 200A which was inserted by the Finance Act 2009 with effect from 1st April 2010 are as follows:
200A(1)) where a statement of lax deduction at source or a correction statement has been made by a person deducting any sum (hereinafter referred to in this section as deduction) a person deducting under section 20, such statement shall be processed in the following manner , namely:-
(a)) The sums deductible under this chapter shall be computed after making the following Adjustment namely
(i) Any arithmetical error in the statement ;or
(ii) An incorrect claim .apparent from any information in the statement ;
(b) The interest, if any .shall be computed on the basis of the sums deductible as computed in the statement;
(c) The sum payable by ,or the amount of refund due to, the deductor shall be determined after adjustment of amount computed under clause (b) against any amount paid under section 200 and section 201 and any amount paid otherwise by way of tax or interest;
(d) An intimation shall he prepared or generated and sent to the deduct or specifying the sum determined to be payable by, or the amount of refund due to ,him under clause (c) and
(e) the amount of refund due to the deductor in pursuance of the determination under (e) shall be granted to the deductor.
Provided that no intimation under this sub -section shall be sent after the expiry of on. from the end of the financial year in which the statement is filed.
7 ITA No.110 (Asr)/2017Asst. Year: 2014-15 Explanation - For the purposes of this sub-section, "an incorrect claim apparent from any information in the statement "shall mean a claim, on the basis of an entry in the statement.
(i) Of an item ,which is inconsistent with another entry oj the same or some other item such statement;
(ii) In respect of rate of deduction of tax at source ,where such rate is not in accordance with the provisions of this act;
(2 for the purposes of processing of statements under sub
-section (1) the board may make a scheme for centralized processing of statements of tax deducted as source to expeditiously determine the tax payable by , or the refund due to , the deductor as required under the said sub-section.
The Assessing Officer cannot make any adjustment other than the one prescribed above in section 200A of the Act. By Finance Act, 2015, with effect from 01.06.2015, the parliament amended section 200A by substituting sub-section (1) of clauses (c) to (e).
STATUTORY PROVISIONS AFTER 01.06.2015:-
The amendments made in section 200A by the Finance Act, 2015 are as under:
"In section 200A of the income tax Act, in sub-section (1), for clauses (c) the following clauses shall be substituted with effect from the 1 st day of June ,2015 namely "(c) The fee, if any, shall be computed with the provisions of section 234E;
(d) The sum payable by, or the amount of refund due to, the deductor shall be determined after adjustment of the amount computed under clause (b) and clause (c) against any amount paid under section 200 or section 201 or section 234E and any amount paid otherwise by way of tax or interest or fee;
(f) An intimation shall be prepared or generated and sent to the deductor specifying the sum determined to be payable by, or the amount of refund due to, him under clause (d):8 ITA No.110 (Asr)/2017
Asst. Year: 2014-15
(g) The amount of refund due to the deductor in pursuance of the determination under clause (d) shall be granted to the deductor."
From the conjoint reading of the provisions prior and post to 01 st June 2015, it is obvious that prior to 01.06.2015, there was no enabling provision in section 200A of the Act for making adjustment in respect of the statement filed by the assesses with regard to tax deducted at source by levying fee under section 234E of the A c t . The parliament for the first time enabled the assessing officer to make adjustment by levying fee under Section 234E of the Act with effect from 01.06.2015.
The similar controversy was also dealt with, by the Co-ordination Bench in the case of Sibia Healthcare Pvt. Limited Vs. DCIT(TDS) (supra) , by holding as under:
"10. In view of the above discussions, in our considered view, the adjustment in respect of levy of fees under s. 234E was indeed beyond the scope of permissible adjustments contemplated under s. 200A. This intimation is an appealable order under s. 246A(a), and, therefore, the CIT (A) ought to have examined legality of the adjustment made under this intimation in the light of the scope of the s. 200A. Learned CIT(A) has not done so. He has justified the levy of fees on the basis of the provisions of s. 234E. That is not the issue here. The issue is whether such a levy could be effected in the course of intimation under s. 200A. The answer is clearly in negative. No other provision enabling a demand in respect of this levy has been pointed out to us and it is thus an admitted position that in the absence of the enabling provision under s. 200A, no such levy could be effected.
As intimation under s. 200A, raising a demand or directing a refund to the tax deductor, can only be passed within one year from the end of the financial year within which 9 ITA No.110 (Asr)/2017 Asst. Year: 2014-15 the related TDS statement is filed, and as the related TDS statement was filed on 19th Feb., 2014, such a levy could only have been made at best within 31st March, 2015. That time has already elapsed and the defect is thus not curable even at this stage.
In view of these discussions, as also bearing in mind entirety of the case, the impugned levy of fees under s. 234E is unsustainable in law. We, therefore, uphold the grievance of the assessee and delete the impugned levy of fee under s. 234E of the Act. The assessee gets the relief accordingly."
Let us to consider mandate of the constitution of India as enshrined in Article20 (1) " No person shall be convicted of any offence except for violation of law in force at the time of commencing of the Act charged as an offence, not be subjected to penalty greater than which might have been inflicted under the law in force at the time of the commencement of the offence"
Ordinarily, a legislature has power to make prospective laws, but Art.20 of the Indian Constitution, 1950 provides certain safeguards to the persons accused of crime and so Art. 20(1) of the Indian constitution imposes a limitation on the law making power of the constitution. It prohibits the legislature to make retrospective criminal laws however it does not prohibit a civil liability retrospectively i.e. with effect from a past date. So a tax can be imposed retrospectively. Clause (1) of the Article 20 of the Indian Constitution guarantees rights against ex-post facto laws. It provides that " no person shall be convicted of any offence except for violation of a law in force at the time of the commission of the act charged as an offence, nor be subjected to a penalty greater than that which might have been inflicted under the law in force at the time of the commission of the offence." The American Constitution also constitutes a similar provision 10 ITA No.110 (Asr)/2017 Asst. Year: 2014-15 prohibiting ex-post facto laws both by the Central and State legislatures.
Let us to consider the meaning of prospective and retrospective:-
The dictionary meaning of the word prospective with reference to statutes shows that it is concerned with or applying the laws in future or at least from the date of commencement of the statute. Whereas the word retrospective when used with reference to an enactment may mean:
1. Effecting an existing contract or
2. Reopening of the past, closed and completed transactions, or
3. Affecting accrued rights and remedies, or
4. Affecting procedure.
The retrospective operation of an enactment may mean one thing and its affecting the rights of parties another. Normally, an enactment is prospective in nature. It does not affect that which has gone, or completed and closed up already. Ordinarily, the presumption with respect to an enactment is that, unless there is something in it to show that it means otherwise, it deals with future contingencies, and does not annul or affect existing rights and liabilities or vested rights, or obligations already acquired under some provisions of law although its effect is that it does not affect an existing right as well. If an enactment expressly provides that it should be deemed to have come into effect from a past date, it is retrospective in nature. It then operates to affect existing rights and obligations, and is construed to take away, impair or curtail, a vested right which had been acquired under some existing law. If an enactment is intended to be 11 ITA No.110 (Asr)/2017 Asst. Year: 2014-15 retrospective in operation, and also in effect, the legislature must expressly, and in clear and unequivocal language, say so, in the enactment itself. A retrospective operation is not given to a statute, so as to impair an existing right or obligation, otherwise than as regards matters of procedure unless that effect cannot be avoided without doing violence to the language of the enactment. If the enactment is expressed in a language which is capable of either interpretation, it ought to be construed prospectively.
The Special Bench of the Delhi Tribunal, in the ITO New Delhi vs Ekta Promoters Private Ltd case, [(2008) 117 TTJ Delhi 289] while considering , whether the levy of interest under Section 234D of the Act from June 1, 2003, will have retrospective application to case, observed that " the I-T department sought to levy interest under Section 234D for assessment years (AYs) 1998-99 to 2000-2001 by issuing notices under Section 148 of the Act. The company contested the levy and the CIT (Appeals) held that interest under Section 234D could not be charged for AYs before June 1, 2003. The department took the matter to the Tribunal. The Special Bench of the Tribunal held that levy of interest under Section 234 can be applied only from AYs 2004-2005 onwards and not for the earlier years.
The Bench reasoned that "there is no dispute to the proposition that a court cannot read anything into a statutory provision which is plain and unambiguous. A statute is the edict of the legislature. The language employed in a statute is determinative of the legislative intent and according to the first and primary rule of construction, the intention of the legislation must be found in the words used by the legislature itself and the function of the court is only to interpret the law and the court cannot legislate. If a provision of law is misused and subjected to the abuse of the process of law, it is for the legislature to amend, modify or repeal it, if deemed necessary.
"Legislative causus omissus cannot be supplied by judicial interpretative course. Thus, on the basis of argument that legislature 12 ITA No.110 (Asr)/2017 Asst. Year: 2014-15 has brought this provision just to fill the lacuna in the law and therefore these provisions should be construed retrospective cannot be accepted more particularly when these provisions have been inserted on the statute with effect from June 1, 2003, and not with retrospective effect. The legislature has specifically mentioned the date of applicability, that is, June 1, 2003, and the legislator was not incompetent to make retrospective provision, if it was so intended. Therefore, merely on the basis of interpretation, retrospective effect cannot be given to the provisions of Section 234D."
Accordingly, levy on interest under Section 234D of the Act would apply prospectively from AY 2004-05 onwards.
In the instant case, The Finance Act of 2015 made it abundantly clear that it shall be effective from June 1, 2015. It is also settled law that penal laws cannot generally have retrospective operation.
In the Maxwell's Interpretation of Statutes, 12th Edn. the statement of law relating to its operation is stated as:
"Perhaps no rule of construction is more firmly established than thus - that a retrospective operation is not to be given to a statute so as to impair an existing right or obligation, otherwise than as regards matters of procedure, unless that effect cannot be avoided without doing violence to the language of the enactment. If the enactment is expressed in language which is fairly capable of either interpretation, it ought to be construed as prospective only. The rule has, in fact, two aspects, for it, "involves another and subordinate rule, to the effect that a statute is not to be construed so as to have a greater retrospective operation than its language renders necessary".
The rule of beneficial construction requires that ex-post facto law should be applied to reduce the rigorous sentence of the previous law on the same subject. Such a law is not affected by Article 20(1). The principle is based upon the legal maxim "Salus Populi Est Suprema Lex" which means the welfare of the people is the supreme for the law. It is inspired by principles of justice, equity and good conscience.
13 ITA No.110 (Asr)/2017Asst. Year: 2014-15 In Garikapati Veeraya v. N. Subbiah Choudhry, [1957 AIR 540], The Apex Court laid down as under:
"The golden rule of construction is that, in the absence of anything in the enactment to show that it is to have retrospective operation, it cannot be so construed as to have the effect of altering the law applicable to a claim in litigation at the time when the Act was passed."
In Ratan Lal Vs. State of Punjab, {AIR 1965 SC 444} " A boy of 16 years was convicted for committing an offence of house-trespass and outraging the modesty of a girl aged 7 years. The magistrate sentenced him for six months rigorous imprisonment and also imposed fine. After the judgment of magistrate, the Probation of Offenders Act, 1958 came into force. It provided that a person below 21 years of age should not ordinarily be sentenced to imprisonment. The Supreme Court by a majority of 2 to 1 held that the rule of beneficial interpretation required that ex-post facto could be applied to reduce the punishment. So an ex-post facto law which beneficial to the accused is not prohibited by clause (1) of Article 20.
In K. S. Paripoornan v. State of Kerala, (1992) 1 SCC 684.
The Apex Court while considering the effect of amendment in the Land Acquisition Act in pending proceedings held in Para 47 thereof as:
"In the instant case we are concerned with the application of the provisions of Sub-sec. (1-A) of S.23 as introduced by the Amending Act to acquisition proceedings which were pending on the date of commencement of the Amending Act. In relation pending proceedings, the approach of the Courts in England is that the same are unaffected by the changes in the law so far as they relate to the determination of the substantive rights and in the absence of a clear indication of a contrary intention in an amending enactment, the substantive rights of the parties to an action 14 ITA No.110 (Asr)/2017 Asst. Year: 2014-15 fall to be determined by the law as it existed when the fiction was commenced and this is so whether the law is change before the hearing of the case at the first instance or while an appeal is pending".
In State of M.P. and another, Verus G.S. Dall & Flour Mills, (AIR 1991 SC 772), The Apex Court in Para 21 of the judgment the Apex Court has observed that:
"the notification of 3/71187 amending the 1981 notification with retrospective effect so as to exclude what may be described in brief as 'traditional industries' though, like Rule 14 of the deferment rules, the exclusion extends' even to certain other non-traditional units operating in certain situations. Though this notification purports to be retrospective, it cannot be given such effect for a simple reason. We have held that the 1981 notification clearly envisages no exclusion of any industry which fulfils the terms of the notification from availing of the exemption granted under it. In view of this interpretation, the 1987 amendment has the effect of rescinding the exemption granted by the 1981 notification in respect of the industries mentioned by it. S. 12 is clear that, while a notification under it."
In Hitendra Vishnu Thakur Versus State of Maharashtra, 1994 SCC (4) 602, Ambit and scope of an amending Act and its retrospective operation considered as:
"(i) A statute which affects substantive rights is presumed to be prospective in operation unless made retrospective, either expressly or by necessary intendment, whereas a statute which merely affects procedure, unless such a construction is textually impossible, is presumed to be retrospective in its application, should not be given an extended meaning and should be strictly confined to its clearly defined limits.
(ii) Law relating to forum and limitation is procedural in nature, whereas law relating to right of action and right of appeal even though remedial is substantive in nature.
(iii) Every litigant has a vested right in substantive law but no such right exists in procedural law.15 ITA No.110 (Asr)/2017
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(iv) A procedural statute should not generally speaking be applied retrospectively where the result would be to create new disabilities or obligations or to impose new duties in respect of transactions already accomplished.
(v) A statute which not only changes the procedure but also creates new rights and liabilities shall be construed to be prospective in Operation unless otherwise provided, either expressly or by necessary implication."
From the perusal of the Article 20(1) of The Constitution of India, judgments (supra) and on the aforesaid consideration and observation, we are inclined to held that the cardinal principle of construction of a statute is that every statute is prima-facie a prospective "unless it is expressly or by necessary implication made to have retrospective operation". When a procedural law is considered it is always retroactive i.e. came into effect from past date so the question of retrospective operation shall arise in substantive laws only. Considering the meaning of retrospective and retroactive laws, only substantive civil laws can be operated retrospectively if the statute specifically prescribes it or there exists large interest of the public as whole otherwise all statutes shall be operated retroactively, in the instant case as the Finance act 2015 introduced the enabling provision for imposing of late filing fees u/s 234E which was brought by the amendment for the charges to sec. 200A w.e.f 1st June, 2015 therefore the same are to be prospective only and cannot be made effective as retrospective .
As the Ld. AR has drawn our attention to chart filed in the Paper Book page -9 which is reproduced herein below.
16 ITA No.110 (Asr)/2017Asst. Year: 2014-15 Continuing default (855 days) [From due date of return i.e. 15.07.2013 to 17.11.2015, total period of default (Delay) is 855 days.] Due date of Return 15.07.2013 Provision of section 200A Amended from 01.06.2015.
[Period] [Period] 01.06.2015 to
17.11.2015]
15.07.2013 to 31.05.2015
DEFAULT PERIOD
No DEFAULT PERIOD
-----Post Amendment Period-----
------Pre amendment period------ (200 days)
(685 days) Default Admitted by the Appellant
On the aforesaid analyzation, consideration and observation we are of the considered opinion that the late fee u/s 234E cannot be charged of period from 15 July, 2013 to 31st May, 2015 which comes to 685 days in the instant case relates to prior of amendment , therefore, the late fee as levied by the Revenue Authority is liable to be deleted and further as the assessee has bonafidely acceded to pay the late fee for the default period i.e. of the post Amendment period from 1st June, 2015 to 17th Nov. 2015 which comes to 200 days, hence, we direct the revenue authority to reduce the late fee for the period qua pre Amendment period i.e. up to 31st May, 2015.
8. In view of the aforesaid direction the appeal of the assessee is partly allowed for statistical purposes.
Order pronounced in the open Court on 31.08.2017.
Sd/- Sd/-
(T. S. KAPOOR) (N.K.CHOUDHRY)
ACCOUNTANT MEMBER JUDICIAL MEMBER
Dated:31.08.2017.
/PK/ Ps.
17 ITA No.110 (Asr)/2017
Asst. Year: 2014-15
Copy of the order forwarded to:
(1) The Assessee:
(2) The
(3) The CIT(A),
(4) The CIT,
(5) The SR DR, I.T.A.T.,
True copy
By order