Income Tax Appellate Tribunal - Indore
Shri Dinash Chand Dave, Indore vs Ito-W,2(2), Indore on 26 July, 2019
आयकर अपील य अ धकरण, इ दौर यायपीठ, इ दौर
IN THE INCOME TAX APPELLATE TRIBUNAL
INDORE BENCH, INDORE
BEFORE HON'BLE KUL BHARAT, JUDICIAL MEMBER
AND
HON'BLE MANISH BORAD, ACCOUNTANT MEMBER
WTA No.12/Ind/2018
Assessment Year: 2007-08
Shri Dinesh Chand Dave,
368, Golden Plaza, Bada ITO-2(2)
बनाम/
Sarafa, Indore Indore
Vs.
(Appellant) (Revenue)
PAN:AERPD0755J
Appellant by Shri K.C. Agrawal, CA
Revenue by Smt. Ashima Gupta, CIT-DR
Date of Hearing: 22.07.2019
Date of Pronouncement: 26.07.2019
आदे श / O R D E R
PER MANISH BORAD, A.M:
This appeal by Assessee pertaining to A.Y. 2007-08 is directed against the order of Ld. Commissioner of Income Tax(Appeals)-III, Indore, (in short 'CIT(A)'), dated 28.08.2018 which is arising out of the order u/s 16(3)r.w.s. 17 of the Wealth Tax Act (hereinafter called as the 'Act') Shri Dinesh Chand Dave WTANo.12/Ind/2018 framed on 23.11.2012 by Wealth Tax Officer 2(2) Indore. The assessee has raised following grounds of appeal:
"1. On the facts and in the circumstances of the case the Learned Commissioner Wealth Tax (Appeals) has erred in sustaining the addition made of Rs.4,91,38,518/- made on account of cash in hand shown as on 31.03.2007 by treating the same as taxable wealth u/s 2(ea)(vi) of the Act, which is not a wealth and thus, the order so passed is without jurisdiction, illegal, wrong and bad in law.
2. On the facts and in the circumstances of the case the Learned Commissioner Wealth Tax (Appeals) has erred in not allowing the debts owned as against the assessed wealth so upheld, which is otherwise allowable and thus, the order so passed is without jurisdiction, illegal, wrong and bad in law."
2. Briefly stated facts as culled out from the records are that the assessee is an individual running business of trading of bullion under the sole proprietorship concern M/s. Kargil Bullion. He also derives income from trading/commission work of gold/silver trading on MCX/NCDEX. Income of Rs.2,88,410/- declared in the return of income filed on 21.08.2007 and the same was assessed u/s 143(3) of the Act vide order dated 17.12.2009.
3. During the course of assessment proceedings u/s 143(3) of the Act, Ld. AO while examining the audited financial statement of the proprietorship concern M/s Kargil Bullion noticed that there was 'cash in hand' of Rs.4,91,38,518/-
2Shri Dinesh Chand Dave WTANo.12/Ind/2018 as on 31.03.2007. As the assessee is an individual entity, Ld. AO applying the provision of u/s 2(ea)(vi) of the Wealth Tax Act held that the cash in excess of Rs.50,000/- is liable to be included in the total wealth of the assessee and subject to wealth tax. In the submissions filed by the assessee, it was contended that the alleged cash was received from sale at fag end of the closing of the financial year and in the first week of April, 2007, the alleged amount stands duly deposited in the bank. Ld. AO, however was not convinced with the submissions and he added the cash in hand of Rs.4,91,38,518/- to the wealth disclosed by the assessee at Rs.2,00,000/- in the wealth tax return filed on 04.10.2012.
4. Aggrieved assessee preferred an appeal before the ld. CIT(A) but failed to succeed as Ld. CIT(A) dismissed the assessee's appeal following the judgment of Hon'ble Kerala High Court in the case of A.A. Salam in WTA (1) of 2009 as well as another judgment of Hon'ble High Court of Kerala in CIT vs. Smt. K.R. Ushasree (2010) 229 CTR 52 (Ker). Ld. CIT(A) also observed that the assessee failed to file any proof to show that the cash in hand on 31.03.2007 was deposited in the bank account in the first week of April, 2007.
3Shri Dinesh Chand Dave WTANo.12/Ind/2018
5. Aggrieved assessee is in appeal before the Tribunal. Ld. counsel for the assessee contended that the alleged cash in hand was purely business asset and its form part of the cash in hand shown in the audited balance sheet of the proprietorship concern M/s Kargil Bullion.
6. He also submitted that without prejudice to the submissions that the alleged asset is a business asset exempt from levy of wealth tax, Ld. AO failed to appreciate that only the 'net wealth' is liable to be taxed since the debts and other liabilities are required to be deducted from the assets. Following written submissions were filed by the assessee.
1. First of all we would like to invite your kind attention to relevant provisions under the Wealth Tax Act and Income Tax Act, are being reproduced here:-
Under the Wealth Tax Act :-
a) "2(ea) "assets", in relation to the assessment year commencing on the 1st day of April, 1993, or any subsequent years, means-
(i)......
(ii)......
(iii).....
(iv).....
(v)......
(vi) Cash in hand, in excess of fifty thousand rupees, of individuals and hindu undivided families and in the case of other persons any amount not recorded in the books of account."
The said provision is introduced through Finance Bill, 1992, wherein the necessity to introduce such provision is 4 Shri Dinesh Chand Dave WTANo.12/Ind/2018 explained in the Memorandum explaining the provisions of Finance Bill 1992, which is reproduced hereunder :-
"With a view to stimulating investment in productive assets, it is proposed to abolish wealth-tax on all assets except certain specified assets. The term "asset" will include guest houses and residential houses including farm houses within twenty-five kilometers from the local limits of any municipality (whether known as a municipality, municipal corporation, notified area committee, town area committee, town committee or by any other name) or a cantonment board but does not include a house which has been allotted by a company to an employee, or an officer, or a director who is in the whole-time employment, having a gross annual salary of less than two lakh rupees. It will also not include a house for residential purposes, which forms part of stock-in-trade. Further, it will include motor cars other than those used in the business of running them on hire, jewelry, bullion (other than used as stock-in-trade) ; yachts and boats and aircrafts (other than those used for commercial purposes), cash in hand excess of Rs. 50,000 held by individuals or HUF's and in the case of any other person any amount not recorded in the books of account and urban land. Only those debts which have been secured on, or which has been incurred in, relation to the aforementioned assets will be allowed as a deduction in the computation of net wealth. Further, in order to prevent tax avoidance, it is proposed that wealth of a minor will be clubbed with the wealth of that parent whose net wealth (excluding the assets of the minor) is greater. It is proposed to introduce a section 35HA in the Wealth Tax Act to provide for the person who would be held responsible in the case of any offence by a company."
b) "Section 44AA(1) Every person carrying on legal, medical, engineering or architectural decoration or the profession of accountancy or technical consultancy or interior decoration or any other profession of accountancy as is notified by the Board in the Official Gazette shall keep and maintain such books of account and other documents as may enable the 5 Shri Dinesh Chand Dave WTANo.12/Ind/2018 [assessing] officer to compute his total income in accordance with the provision of this Act.
(2)Every person carrying on business or profession [not being a profession referred to in sub-section (1) ] shall,-
(i) if his income from business or profession exceeds [one lakh twenty] thousand rupees or his total sales, turnover or gross receipts, as the case may be, in business or profession exceed or exceeds [ten lakh] rupees in any one of the three years immediately preceding the previous year; or
(ii) .......
(iii).......
(iv).......
keep and maintain such books of account and other documents as may enable the [Assessing] Officer to compute his total income in accordance with the provisions of this Act."
2. From the reading of the above provisions it is clear that only specified persons covered under section 44AA are required to keep and maintain books of accounts and other documents as may enable the Assessing Officer to compute total income. Thus, the assessee by virtue of section 44AA maintaining regular books of accounts and the cash in hand so shown is properly reflected in such books of accounts. And accordingly, in view of the provisions of section 2(ea), the same is not liable for wealth tax. That the wordings are very clear that in the case of Individuals and HUF in excess of Rs.50,000/- and in other cases any amount not recorded in books of accounts. Please note that in the cases of other than Individuals/HUF i.e. Firm, AOP, Companies etc. are subject to audit and mostly for business purposes. Whereas in the case of Individuals/HUF, where books are not mandatory where source of income may be other than business. In such case an adhoc exemption of Rs.50,000/- is provided. However, where books of accounts are mandatory, cash in hand is out of purview of the provisions of Wealth Tax Act.
Similarly, in section 2(ea) of the Wealth Tax Act, the assets like motor car, jewellery, bullion or furniture which are held by the assessees either for the use of the business or running 6 Shri Dinesh Chand Dave WTANo.12/Ind/2018 them on hire or as stock-in-trade are excluded from the ambit of "asset". Even in the case of yachts, boats and aircrafts which are used for commercial purposes are also excluded from the definition of "asset". It is necessary while interpreting clause (vi) which specifically deals with the treatment to be given in respect of cash in hand, the entire definition of "asset" as it was brought on the statute book. It is submitted that no discrimination can be made in respect of the productive and non-productive assets as per the category of the assessees and hence, the proper construction of clause
(vi) in case of an individual and HUF should be if the cash in hand is not recorded in the books of account in excess of Rs.50,000/- then it will be non-productive asset. But, if the cash in hand is recorded in the books of account whether the assessee is individual, HUF or company, then it is not an asset for the purpose of charging section of Wealth Tax Act. In this case, it is not disputed that cash in hand which is treated as an asset for the purpose of Wealth Tax Act is duly recorded in the books of account of the assessee. Moreover, as per the provisions of section 3 which is a charging section of the Wealth Tax Act, three categories of assessees are liable for the wealth-tax i.e. (i) individual, (ii) HUF and (iii) company, and hence, it was not difficult for the legislature to make a specific reference of "the company" as such instead of using the word "persons".
We further submit that the assessee is engaged in the bullion business he has availed of the credit facilities from the parties. That the sales realization is a part and parcel of the commercial transactions of the apppellant. Now, a question may be raised as to why only for individual and HUF the basic exemption of Rs.50,000/- is given if it is not the cash in hand recorded in the books of account and why it is not so in case of company, the answer is very simple. As far as the companies are concerned, there is statutory requirement under the company law and as per the provisions of the Companies Act, a company cannot keep the cash without recording the same in the books of account, but there is no statute controlling the individuals and HUFs like Companies Act specifying that every individual and HUF must record the 7 Shri Dinesh Chand Dave WTANo.12/Ind/2018 cash in hand in the books of account. Moreover, every individual and HUF is not expected to engage in the commercial activity like business or trade. We therefore, submit that the cash in hand which is reflected in the balance sheet and duly recorded in the books of account is not an asset within the meaning of section 2(ea) of the Act, even in the case of an individual and HUF. Since, the cash in hand is duly recorded in the books of account by the assessee, who is an individual and thus, the cash being commercial asset is exempted from Wealth Tax. We also invite your kind attention that wealth-tax is charged on the specific valuation date. That, amount credited in bank accounts are not included in the definition of "asset". Thus, in presuming one day immediately preceding the date of valuation, would have deposited cash in bank accounts and immediately next day i.e. first day of after valuation date, would have withdrawn the same, then such cash could not have been liable for the wealth-tax and it is much more easier for the individuals and HUFs. Though as per the general principles of interpretation where the wordings of a statute are plain, precise and unambiguous, the intention of the legislature is to be gathered from the language of the statute itself and no help of external aid should be taken, but when the statute is not exhaustive or where its language is ambiguous, uncertain, clouded or susceptible of more than one meaning, then certainly the external aid can be taken for finding out the legislative intent.
Moreover, if two interpretations are possible then the interpretation in favour of the assessee should be preferred as held by the Hon'ble Supreme Court in the case of CIT v. Vegetable Products Ltd. (1973) 88 ITR 192 (SC). Further, your honour's kind attention is invited to Finance Bill, 1992, it is quite clear that the intention of the legislature was not to impose wealth tax on any productive assets. In the present case the cash in hand is forming part of business asset, which is generated out of sale of gold/silver bullion and regularly been deposited in bank account of the assessee. The cash in hand shown at Rs.4,91,38,518/- as on 31.03.2007 has been deposited in the business bank 8 Shri Dinesh Chand Dave WTANo.12/Ind/2018 account of the assessee in next three working days (copy of bank statement is enclosed), as 31.03.2007 was Saturday and half day for banking and 1st and 2nd April, 2007 were holidays and bank yearly closing days. Thus, it is kindly requested that the cash in hand so shown in business of the assessee is not chargeable to wealth tax and hence, the same may please be treated as exempted as claimed. That THE observation of the learned CIT(A) that no details of deposits of cash subsequently were filed, is not correct. It is submitted that all such details were filed to support the contention that the cash in hand as on 31.03.2007 was deposited on next working days. Please refer page no._____ of paper book.
3. Without prejudice to above further it is submitted that the capital of the assesee as on 31.03.2007 was at Rs.28,49,939/-, which is represented by various assets like Fixed Assets, Investments, Sundry Debtors, Deposits and Cash/Bank Balance and remaining assets are represented by Unsecured Loans, Deposits and Sundry Creditors. The details of Balance Sheet as on 31.03.2007 is as under:-
LIABLITIES AMOUNT ASSETS AMOUNT
Capital 2849939 Fixed Assets 41792
Unsecured
Loans 30750000 Investments 143508
Sundry
Creditors 33154013 Deposits 53000
Other
Liablities 70786 Sundry Debtors 1424036
Bank Balance 16023884
Cash in hand 49138518
Total 66824738 Total 66824738
9
Shri Dinesh Chand Dave
WTANo.12/Ind/2018
It is a general principle that the chargeable wealth cannot be more than the capital of the assessee except where the assets having chargeable value more than the amount of value as per books. That in the instant case the amount of capital is Rs.28,49,939/-. Further, there is no assets in the Balance Sheet having more value reflected in books. Thus, under any circumstances chargeable wealth can never be more than Rs.28,49,939/-. This position is valid where there is no liability or debt. In the case of debts, representing assets shall be governed by the provisions of section 2(m) of the Wealth Tax Act. The said section is reproduced hereunder :-
Section 2(m) 'net wealth' means the amount by which the aggregate value computed in accordance with the provisions of this Act of all the assets, wherever located, belonging to the assessee on the valuation date, including assets required to be included in his net wealth as on that date under this Act, is in excess of the aggregate value of all the debts owed by the assessee on the valuation date which have been incurred in relation to the said assets;
Thus, in the instant case sundry creditors and unsecured loans are representing cash and bank balance. In such circumstances, liabilities are more than the amount of cash in hand and thus, not liable for charge of Wealth Tax. Even though if proportionate capital / liabilities are appropriated towards assets then also cash in hand, being chargeable asset within the meaning of section 2(ea) derived at Rs.20,95,628/- (49138518 X 2849939 / 66824738), which is below the limit chargeable to tax.
In view of the above it is therefore, prayed that the addition so made of cash in hand as on 31.03.207 as asset be deleted.
7. Learned Departmental Representative (Ld. DR) supported the following finding of both the lower authorities.10
Shri Dinesh Chand Dave WTANo.12/Ind/2018 Observation of the ld. AO • The submission given by the assessee has been perused I have also perused the notes given in the computation of wealth stating that (1) "the assessee is having cash in hand as on 31.03.2007 at Rs.4,83,76,696/- in his proprietorship concern M/s Kargil Bullion, Indore, which is productive/business asset and in view of the provisions of wealth tax act, the same is not liable to assessed as assets, as the same is recorded in the books of accounts. (2) that the cash in hand being business assets represented by debts, which are much more than the amount of cash in hand and hence, not chargeable as assets." The aforesaid contentions of the assessee is not tenable as cash in hand, in excess of Rs. 50,000/- held by the individual assessee and HUFs forms part of assets under section 2(ea)(vi) of the Wealth Tax Act and any cash in hand for other persons, namely, companies, not recorded in the books of accounts is an asset [CIT Vs. Smt. K.R Ushashree (2010) 229 CTR 52 (KER.)] The provisions of section 2(ea)(vi) states that-
"(ea) "assets" in relation to the assessment year commencing on the 1st day of April, 1993m or any subsequent year, means
(i).............................
...............................
(vi) cash in hands, in excess of fifty thousand rupees, of individuals and hindu undivided families and in the case of other persons any amount not recorded in the books of account.
• From the forgoing discussion, it is apparent that Cash in hand excluded from "assets" for individual assessee is only Rs.50,000/- and any amount held as Cash in hand in excess of Rs.50,000/- is an asset falling under the above defination clause. Considering the entire facts of the case and submission made by the assessee, cash in hand held by the assessee to the extent of Rs.4,91,38,518/- as on 11 Shri Dinesh Chand Dave WTANo.12/Ind/2018 the last moment of the valuation date (31st March) is treated as asset u/s 2(ea)(vi) of the Wealth Tax Act.
8. Observation of the Ld. CIT(A)
3. I have gone through the appellant contentions and the order passed u/s 16(3) r.w.s. 17 of the Wealth Tax Act. It is seen that the appellant has made the same submission in the appeal proceedings as were made before the Wealth Tax Officer in the assessment proceedings. The appellant's main contentions is that the cash in hand of rs.4,91,38,518/- is not taxable in view of the provisions of section 2(ea)(vi) of the Wealth Tax Act and that the cash in hand belongs to proprietary concern, M/s Kargil Bullion and has been deposited in the bank account on the next working days. The Assessing Officer did not accept the assessee's contention and relied on the decision of Kerala High Court in CIT vs. Smt.K.R. Ushasree (2010) 229 CTR 52 (Ker). 3.1. It is seen that similar view have been taken by the Kerala High Court in the case of A.A.Salam in WTA (1) of 2009 wherein it has been held as under :
The question....................Section 2(ea)(vi) of the Act. 3.2. Further, the appellant has not submitted any proof to show that the cash in hand on 31/03/2007 was deposited in the bank account on 03/04/2007, 04/04/2007 and 05/04/2007 and what was deposited on these dates was not out of the cash sales made from 01/04/2007 to 05/04/2007.
3.3. In view of the above, the cash in hand of Rs.4,91,38,518/- held by the appellant on 31/03/2007 is treated as an assets u/s 2(ea)(vi) of the Wealth Tax Act.
9. We have heard the rival contentions and perused the record placed before us. The only grievance of the assessee raised in this wealth tax appeal is against the finding of Ld. CIT(A) treating the cash in hand held by the assessee in his 12 Shri Dinesh Chand Dave WTANo.12/Ind/2018 sole proprietorship concern M/s Kargil Bullion as a taxable asset liable for wealth tax.
10. We observe that the assessee is into business of trading in Bullion and runs sole proprietorship concern M/s Kargil Bullion. Books of accounts are regularly maintained and the financial statements are audited. In the balance sheet placed at page 7 of the paper book, cash and bank balance is shown at Rs.6,51,62,401.97/- and its bifurcation is given of page 8 showing that other than the bank balance.
The assessee was having cash in hand at Jalgaon, at Rs.7,61,822/- and cash in hand at Indore at Rs.4,83,76,696/-. The total cash in hand as on 31.03.2007 in books of Kargil Bullion stood at Rs.4,91,38,518/-.
11. As far as, the issue that whether the alleged amount is a business asset or not, there is hardly any dispute on the part of the Revenue Authorities that the alleged cash in hand is a part of the business asset of M/s Kargil Bullion. The bone of contention is with regard to the definition of "asset" provided in section 2(ea) of the Wealth Tax Act. In section 2(ea)(vi) of the wealth tax Act as reproduced in the submission given by the assessee in the preceding paras it reads that "cash in hand, in excess of fifty thousand 13 Shri Dinesh Chand Dave WTANo.12/Ind/2018 rupees, of individuals and hindu undivided families and in the case of other persons any amount not recorded in the books of account." Both the lower authorities have taken common view that the assessee being individual and cash in hand as on the last date of the financial year is in excess of Rs.50,000/-. The excess amount of cash is liable to be included in the wealth of the assessee. Both the lower authorities have relied on the judgment of Hon'ble Kerala High Court in the case of CIT vs. Smt. K.R. Ushasree (supra) .
12. So far as, the fact that the impugned cash in hand is a part of business asset of the assessee company, there is no dispute and the similar set of facts where the cash in hand in the form of business asset held by individual person were subjected to wealth tax, Coordinate Bench Kolkata in the case of Surendra Pal Singh vs. DCWT(I.T.A.T. Kolkata) in WTANo.01/Kol/2017 order dated 08.11.2017 held that cash in hand referred to in Section 2(ea)(vi) of the Act represents only the personal cash of the assessee emanating from his personal balance sheet. It nowhere contemplates the inclusion of cash which is held as business asset. We find that the Kolkata Tribunal has given 14 Shri Dinesh Chand Dave WTANo.12/Ind/2018 the above decision after considering the judgment of Hon'ble Kerala High Court in the case of CIT vs. Smt. K.R. Ushasree (supra),observing as follows:
5.We have heard the rival submissions. We find that the assessee had submitted a statement showing computation of global value of assessee's business at Rs. 9,47,580/- as per procedure laid down in Schedule III Rule 14 of the Rules for determining the value of assets. The Ld. CWTA however rejected this argument of the assessee relying on the decision of the Hon'ble Kerala High Court in the case of CIT vs. Smt. K.R. Ushasree reported in 332 ITR 75 (Ker). We find that the Hon'ble Kerala High Court rejected the contention of the assessee that so far as businessman are concerned, cash in hand was an eligible asset and therefore, it was not covered by Section 2(ea)(vi) of the Act. However, we find from the perusal of the said judgment of the Hon'ble Kerala High Court, the assessee therein, never argued for application of global valuation of the business in terms of Rule 14 Schedule III of the Rules for determining the value of assets. It is an admitted fact that cash in hand in the sum of Rs. 48,81,761/- in the instant case represents the cash belonging to the proprietary concern of the assessee and hence it is a business asset for the assessee. The said cash along with other eligible business asset had to be subjected to valuation for the purpose of Wealth Tax Act only in terms of Rule 14 Schedule III of the Rules. Hence we find that the assessee had rightly included the said cash of Rs.
48,81,761/- as part of his workings under global valuation of the business asset in terms of Schedule III Rule 14 of the Rules. We also find that the reliance placed by the Ld. AR on the decision of Co-ordinate Bench of this Tribunal in the case of Bimal Kr. Singh vs. DCWT, Circle-44, Kolkata in WTA No. 13/Kol/2010 for assessment year 2006-07 dated 20.07.2011 is directly on this point wherein it was held that the cash balance generated out of cash sales would be treated as business asset and as such business asset shall not be treated as cash in hand within the meaning of Section 2(ea)(vi) of the Act. The ratio laid down in this decision is squarely applicable 15 Shri Dinesh Chand Dave WTANo.12/Ind/2018 to the facts of the instant case. In our considered opinion, we hold that cash in hand referred to in Section 2(ea)(vi) of the Act represents only the personal cash of the assessee emanating from his personal balance sheet. It nowhere contemplated the inclusion of cash which is held as business asset. If it is so held, then the purpose of valuation method prescribed in Schedule III Rule 14 of the Rule would become redundant. Admittedly, the cash in hand of Rs. 48,81,761/- represents the cash belonging to the business of the assessee and thereby partakes the character of a business asset.
6. In view of these findings and in the facts and circumstances of the case, we have no hesitation in directing the Ld. AO to delete the addition made in the sum of Rs. 48,81,761/- from the value of net wealth representing business cash. Accordingly, the grounds 1 to 4 raised by the assessee are allowed.
13. We, therefore, in the given facts and circumstances of the case and respectfully following the decision of Coordinate Bench of I.T.A.T., Kolkata Bench, are of the considered view that both the lower authorities erred in including the business asset i.e. cash in hand of Rs.4,91,38,518/- as wealth of the assessee. Ld. CIT(A) failed to appreciate that the alleged cash was part of regular cash in hand maintained by the assessee for the business purpose and due to the holiday on the last date of financial year and on the 1st & 2nd April of the subsequent financial year, the cash received by the assessee on account of sale of gold at Noida and Agra branch on 30.03.2007 & 31.03.2007 remained as cash in hand which 16 Shri Dinesh Chand Dave WTANo.12/Ind/2018 was subsequently, deposited in parts in the bank account on 3rd April 2007 & 4th April 2007 and 5th April 2007. As a result of which cash in hand as on 30.04.2007 was only Rs.13,230/-. Therefore, the alleged amount being held by the assessee as a business asset in the capacity as proprietor of business concern M/s Kargil Bullion the same is not liable to be included as assets in the wealth of the assessee for the purpose of levying wealth tax. Thus, ground no.1 of the assessee's appeal is allowed.
14. Apropos ground No.2, we find that same being alternate claim needs no adjudication, as it will be merely academic in nature since we have already allowed the ground no.1 of the assessee's appeal.
15. In the result, appeal of the assessee is allowed.
Order was pronounced in the open court on 26 .07.2019.
Sd/- Sd/-
(KUL BHARAT) (MANISH BORAD)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Indore; दनांक Dated : 26/07/2019
ctàxÄ? P.S/. न.स.
17
Shri Dinesh Chand Dave
WTANo.12/Ind/2018
Copy to: Assessee/AO/Pr. CIT/ CIT (A)/ITAT (DR)/Guard file.
By order Assistant Registrar 18