Income Tax Appellate Tribunal - Amritsar
Punjab Institute Of Medical Sciences, ... vs Assessee on 29 September, 2015
IN THE INCOME TAX APPELLATE TRIBUNAL
AMRITSAR BENCH, AMRITSAR
(BEFORE SHRI A.D. JAIN, JM & SHRI T.R. MEENA AM)
ITA No. 740/Asr/2013
Assessment Year: ..................
M/s Punjab Institute of Medical Vs. Commissioner of
Sciences, Garha Road, Jalandhar Income Tax-II,
Jalandhar.
PAN No.: AAABP 0193 P
Appellant Respondent
Assessee by: Shri Padam Bahl &
Shri Vipul Arora (CA)
Revenue by: Shri Tarsem Lal (DR)
Date of Hearing: 24/08/2015
Date of Pronouncement: 29/09/2015
ORDER
PER: T.R. MEENA, A.M. This is an appeal filed by the assessee arises against the order dated 24/10/2013 passed by the ld. C.I.T.-II, Jalandhar. The effective grounds of appeal are as under:-
1. That the learned Commissioner of Income Tax, Jalandhar has grossly erred, both in law and on facts while cancelling registration granted U/s 12A.
2. The learned Commissioner of Income Tax, Jalandhar has failed to appreciate the power to cancel 2 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT registration in respect of registration granted U/s 12A was brought on the statute w.e.f. 01/06/2010 prospectively in Section 12AA(3) and the cancellation made w.e.f. assessment year 2004-05 is invalid and illegal in the eyes of law.
3. That learned CIT-II, Jalandhar has erred in relying upon rejection of application of the appellant U/s 10(23)(c)(vi) by Worthy Chief Commissioner of Income Tax, Ludhiana and in not appreciating that the rejection cannot have any bearing on its registration U/s 12(A)(a) of the Income Tax Act, 1961 as the two provisions are applicable in different spheres.
4. That the show cause notice dated 04/06/2013 issued by Commissioner of Income Tax, Jalandhar is vague inasmuch as it does not mention the years in which the activities of the Trust were allegedly not genuine and the same wee not carried out as per the objects of the Trust.
5. That the order passed by the learned Commissioner of Income Tax, Jalandhar cancelling the registration retrospectively from assessment year 2004-05 has been passed with the sole objective of supporting the appeal of the department for assessment year 2006- 07 before the Hon'ble ITAT, Amritsar Bench, Amritsar.
6. a) That the learned Commissioner of Income Tax, Jalandhar has failed to appreciate that the tripartite concession agreement was done by the appellant and Government of Punjab with 3 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT Charitable Society registered under Section 12AA of the Income Tax Act, 1961.
b) That the Learned Commissioner of Income Tax, Jalandhar has also failed to appreciate that the tripartite concession agreement was done in a transparent manner and it was in furtherance of the objects of the Society.
c) That the Commissioner of Income Tax, Jalandhar has failed to appreciate that the tripartite concession agreement for Development of Punjab Institute of Medical Sciences under Public Private Partnership Format was executed on 28th August, 2009 whereas the registration U/s 12A(a) has been cancelled w.e.f. assessment year 2004-05.
d) That the learned CIT-II, Jalandhar has also failed to appreciate that the terms of the concession agreement contained and fixed the fees structures to be charged from patients in Hospital and from students of the Medical College and to provide predetermined standard of infrastructure as laid down by the appellant in furtherance of its objects.
e) That the learned CIT-II, Jalandhar has failed to appreciate that the appellant had already established the Punjab Institute of Medical Sciences and the concession agreement was entered into to administer and manage its affairs in a better manner.
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ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT
f) That the learned CIT-II, Jalandhar has wrongly inferred that the appellant was a lessor without appreciating the fact that the appellant has laid down all the policies, terms and conditions of running the hospital and medical college under the concession agreement and that four out of five members of steering committee were from appellant and Government of Punjab.
7. That the learned CIT-II, Jalandhar further failed to appreciate that the appellant has undertaken charitable projects for furtherance of its objects which include upgradation of different medical colleges, setting up of cancer diagnostic treatment centres, drug de-addiction centres in Punjab and had applied an amount of Rs. 78.67 crore till 22/11/2012 towards the same.
8. That the CIT-II, Jalandhar has grossly erred in not appreciating that the society had complied with the provisions of Section 11(2) and applied set apart funds in furtherance of its objects within the stipulated time.
9. That the CIT-II, Jalandhar has failed to appreciate that assessments for assessment years 2003-04, 2004-05, 2008-09 and 2010-11 were made U/s 143(3) of Income Tax Act, 1961 and Assessing Officers has held the society to be genuine & carrying out its activities in furtherance of its objects in all these years.
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ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT
10. That the impugned order U/s 12AA(3) passed by the learned Commissioner of Income Tax, Jalandhar in the case of appellant is patently invalid, contrary to provision of law, contrary to all canons of natural justice and is void an initio.
11. That the appellant craves leave to alter/modify grounds of appeal at the time of hearing."
2. Grounds No. 3, 6(c), 6(d), 6(e), 6(f) and 7 of the appeal are not pressed, therefore, the same are dismissed as not pressed.
3. All the remaining grounds of appeal are against cancellation of registration in respect of registration granted U/s 12A of the Income Tax Act, 1961 (hereinafter referred as the Act) by the C.I.T., Jalandhar. The brief facts of the case are that the assessee society was granted registration No. 12AA of the Act w.e.f. 06/04/1994 vide order dated 20/05/1994 passed by the then Commissioner of Income Tax, Jalandhar. The main objects of the Society are as under:-
a) To establish and carry on the administration and management of Punjab Institute of Medical Sciences, Jalandhar.
b) To set up, establish, promote, manage or associate with, any other Institution or Centre in the State of Punjab devoted to education, training, research and 6 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT related infrastructure in various branches of health sciences and working for the advancement of scientific knowledge aimed at enhancing the quality of patient care.
In assessee's case, the Chief Commissioner of Income Tax, Ludhiana vide his order F. No. CCIT/Ldh./10(23C)(vi)/193/2012- 13/1613 dated 23/07/2012 has rejected the application made by the Punjab Institute of Medical Science (PIMS) Society, Jalandhar for grant of exemption U/s 10 (23C)(vi) of the Act. The ld CIT, Jalandhar observed that the assessee society has already leased out the project to M/s NRI Academy of Sciences & others for an upfront consideration of Rs. 131 crores and a further charge of 5% of the upfront consideration shall be charged from the lessee from the 8th years of the date of acceptance of the award by the lessee. Thus, the assessee society is basically a lessor which has leased the building and land to the lessee i.e. the NRI Academy of Sciences, which is running the hospital. Further NRI Academy of Sciences is managing the administration of hospital. The Doctors and the Paramedical staff alongwith the administrative staff are employed for the lessee i.e. NRI Academy of Sciences. Also the lessee has made the upfront payment to the lessor for the lease of 7 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT land and the building. As the hospital is being run and managed by the lessee, the lesser i.e. the assessee cannot claim of running and managing the hospital and further claim exemption U/s 10(23C)(vi). Also that the receipts of assessee society are not from the reception and treatment of persons suffering from diseased but only from the interest on FDRs which has been earned from the sale proceeds of land (through PUDA). Also there is no expenditure incurred by the assessee's society on the day to day running of the hospital like salary to doctors, paramedical staff etc. So the assessee society nowhere qualifies for the claim of exemption U/s 10(23C)(vi) as it is neither running a hospital nor is receiving any patients for treatment of any disease. He further observed that the assessee society was having surplus in excess of 15% of its gross receipt from F.Y. 31/03/2007 to 31/03/2011. The assessee concern has earned systematic profits regularly since last many years. As shall be seen further in the order, regularly profits have been earned in all the years by the institution. Also accumulated surplus has been invested in FDRs the amount of which has steadily increased over the years. This shows that the intention of the 8 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT institution is to earn profits without applying the surpluses available for philanthropic purposes. The ld CIT further observed that the assessee has also violated provisions of Section 11(5) of the Act during certain years. In assessment year 2006-07,the Assessing Officer has held that the society has not applied any part of its income of the year for charitable purposes and therefore it does not qualify for exemption U/s11 of the Act. However, the ld CIT(A) has held that the society is eligible for exemption U/s 11(I)
(a)once it is registered U/s 12AA.The society had made investment of Rs. 6.5 crores in the modes prescribed U/s 11(5) of the Act. In view thereof, the society has leased out its infrastructure to M/s NRI Academy of Sciences for 99 years. The assessee filed copy of concession agreement under PPF mode and also filed written reply before the ld CIT, which has been reproduced by him at pages 4 to 7 of his order. The DCIT, ITAT, Amritsar also made request to the CIT for cancellation of registration U/s 12AA(3) vide letter No. 289 dated 07/01/2012, which has been reproduced at page No. 8-9 of the impugned order. Further a letter had been received from the office of DCIT, ITAT, Amritsar vide letter dated 13/05/2013, which 9 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT has been also reproduced on page 10 and 11 of the order. The ld CIT issued detailed show cause notice for cancellation of registration U/s 12AA(3) of the Act, which is also reproduced on pages 11to 13 of the CIT order. The assessee filed reply before the ld CIT, Jalandhar, which has also been reproduced on pages 13 to 15 of the order. After considering the show cause notice as well as submissions of the assessee, the ld CIT held that application filed U/s 10(23C)(vi) of the Act has already been rejected by the Chief Commissioner of Income Tax, Ludhiana with detailed reasoning. The ld CIT reproduced Section 12AA and held that the assessee society is basically a lesser, which has leased building and land to the lessee i.e. M/s NRI Academy of Sciences, who is running the hospital. M/s NRI Academy of Sciences is maintaining the administration of the hospital. The Doctors and the Paramedical staff are employed for the lessee i.e. NRI Academy of Sciences. The lessee also had made the upfront payment to the lessor for the lease of land and the building. The receipts of assessee society are not from the reception and treatment of persons suffering from diseased but only from the interest on FDRs which had been 10 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT earned from the sale proceeds of land (through PUDA). There is no expenditure incurred by the assessee's society on the day to day running of the hospital like salary to doctors, paramedical staff etc. The surplus earned has been tabulated as under:-
F.Y. %age of surplus 31/03/2011 94.59 31/03/2010 99.78 31/03/2009 71.87 31/03/2008 81.36 31/03/2007 77.78
The assessee concerned had earned systematic profits regularly since last many years. Regular profits have been earned in all years by the institution and the accumulated surplus had been invested in FDRs the amount in which has steadily increased over the year. This shows that the intention of the institution is to earn profits without applying the surpluses available for philanthropic purposes. The facts of investment are not verifiable from the balance sheet for the year ending 31/3/2011 where no such investment/movement of funds are visible The investment till the year ending 31/3/2011 is only in FDRs. It proves that the status of assessee society is more of a funding/landing body rather than a hospital. He relied on the decision in the case of D.R. Ranka 11 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT Charitable Trust Vs DIT (Exem.) (ITAT Bangalore) reported at 3ITR 151 wherein it is held that Trust establish for carrying out medical and educational activities constructing building and letting it out to the educational institution not part of charitable activity therefore denial of renewal of registration U/s 12AA is justified. He further observed that moreover, the only object as per clause 3(i) of the Memorandum of Association for which the assessee society had been created is to establish and to carry on the administration and management of Punjab Institute of Medical Sciences, Jalandhar. Since the said institute has never been run by the assessee society and is being presently run by PIMS Medical & Education Charitable Society, Garha Road, Jalandhar under the tripartite concession agreement in the PPP mode. Therefore, the assessee society is not entitled for registration granted under section 12AA(3) as the assessee society is not existing and working for the object for which it was created as per its Memorandum of Association. The ld CIT-II, Jalandhar was satisfied with the fact that the activities of the assessee society are not genuine, therefore, he cancelled the assessee's society registration w.e.f. A.Y. 2004-05. 12
ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT
4. Being aggrieved by the order of ld CIT-II, Jalandhar, the assessee carried the matter before us. The ld AR of the assessee has submitted that the assessee society is registered under the Societies Registration Act, 1860 on 10th October, 1994 and reiterated the arguments made before the ld CIT that the ld CIT can cancel the registration if the activities of such Trust or institution are not genuine, the activities of such Trust or institution are not being carried out with in accordance with the objects of the Trust or institution. The society is registered with the object of start a hospital and medical college in the same name at Jalandhar. The objects of the society are as under:-
a) To establish and to carry on the administration and management of Punjab Institute of Medical Sciences, Jalandhar.
b) To set up, establish, promote, manage or associate with, any other Institution or Centre in the State of Punjab devoted to education, training, research and related infrastructure in various branches of health sciences and working for the advancement of scientific knowledge aimed at enhancing the quality of patient care.
He further argued that in financial year 2009-10, the PIMS was established. Thereafter notice of commencement was issued on 13 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT 04/6/2010 to the PIMS Medical & Education Charitable (PMEC) Society being concessionaire and the hospital was started functioning since then. The medical college also starts from academic session 2011-12. Even since PIMS society is functioning as concessioning authority as per Concession Agreement. The society to set up, establish, promote, manage or associate with, any other institution or centre in the State of Punjab devoted to education, training, research and related infrastructure in various branches of health sciences and working for the advancement of scientific knowledge aimed at enhancing the quality of patient care. The society has undertaken government hospitals and medical universities/colleges as per object at various placed in the State of Punjab. In financial year 2005-06 the governing body held various meetings to look for best suited model for running the institute. On the advice of Govt. of India, the PPP model was finalized in 2007-08. RFP document was prepared in July 2008 with a minimum reserve price of Rs. 120 crore by PIDB. A suitable private partner M/s NRI of academy of sciences and others consortium which later formed PIMS Medical and Education 14 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT charitable society was finalized for PPP model at upfront consideration of Rs. 131 crores and annual concession fees of 5% of the upfront consideration payable from the 8th year from the proposal acceptance date. Concession agreement was signed by the parties on 28/08/2009. The handing over of the main building was completed to the concessionaire in February, 2010. The payment amounting to Rs. 6 crores was received in A.Y. 2009-10, 61.23 crores in A.Y. 2010-11 and 47.42 crores in A.Y. 2011-12. The PIMS had amended by adding a new object in October, 2009 i.e. to set up, establish, promote, manage, associate with any other institution or centre in the State of Punjab devoted to education, training, research and related infrastructure in various branches of health sciences and working for the advancement of scientific knowledge aided at enhancing the quality of patient care. He further argued that power to cancel registration in respect of registration granted U/s 12A was brought on the statute w.e.f. 01/6/2010 prospectively in Section 12AA(3) and hence the cancellation made w.e.f. assessment year 2004-05 is invalid and illegal in the eyes of law. He relied on the following decisions: 15
ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT
(i) Agra Development Authority Vs. CIT, ITAT Agra Bench (2013) 35 CCH 230.
(ii) MCA Vs. Director of Income Tax (2013) 153 TTJ (Mumbai) 166.
(iii) Kapoor Educational Society Vs. CIT (2010) 134 TTJ (Lucknow) 250.
(iv) Ajit Education Trust Vs. CIT (2010) 134 TTJ (Ahd)
483.
(v) Director of Income Tax Vs. Mool Chand Khairati Ram Trust (2011) 339 ITR (Delhi) 622.
(vi) Laxman Public School Society Vs. Deputy Director of Income Tax (2012) 31 CCH 092 Del Trib.
(vii) Director of Income Tax (Exemption) Vs N.H. Kapadia Education Trust (2012) 74 DTR (Ahd) (Trib) 233. The ld AR further argued that as per CBDT circular No. 01/2011, the amendment made in Section 12AA(1)(b) was to apply from A.Y. 2011-12 and subsequent year. He further drawn our attention on page No. 5 of the paper book and argued that the Hon'ble ITAT Mumbai Bench held that Sub-Section (3) was introduced in the statute books only with effect from 01/06/2010 i.e. its function shall only be prospective and it cannot be applied retrospectively. Similar view has also held by the various Hon'ble ITATs in above cited subject, therefore, order passed by the ld CIT-II, Jalandhar is 16 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT required to be set aside. There is no bearing on the cancellation of registration passed by the ld CIT that CCIT has rejected the assessee's application U/s 10(23C)(vi) of the Act for which he also relied on the following case laws:-
(i) Sunbeam English School Society Vs. CIT (2011) 139 TTJ(All) 81.
(ii) CIT Vs Rao Bahadur Calavala Cumman Chetty Charities (1982) 135 ITR 485 (Mad).
The ld CIT has not given clear cut finding on non-genuine activities of the assessee society and there was no show cause notice to the assessee for withdrawal of registration w.e.f. A.Y. 2004-05 for which he relied on the decision in the case of Kalinga Institute of Industrial Technology Vs. CIT & Anr. (2011) 336 ITR 389 wherein it has been held by the Hon'ble High Court that the CIT should have clear cut satisfaction of the circumstances for exercise of such power. The ld CIT also considered in passing the order U/s 12AA that appeal for A.Y. 2006-07 was pending before the Hon'ble ITAT, Amritsar. Tripartite concession agreement was done by the appellant and the Government of Punjab with a charitable society registered U/s 12AA of the Act. He has drawn out attention on the 17 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT copy of Memorandum of Association of PIMS Medical & Education Charitable Society (Concessionaire) at page Nos. 323 to 341 of the paper book and also registration U/s 12AA of the Act. It is further argued that concession agreement on PPP mode was done on the recommendation of Government of India, the copy of letter received from Government of India suggesting PPP mode and relevant correspondence are also placed in the paper book for consideration of Bench. There was new clause in the objects of the society was also added. The AR further argued that the assessee has complied the provisions of Section 11(2) and applied set apart funds in furtherance of its objects within stipulated time. The ld CIT had not pointed out any defect in the computation made by the assessee society at the time of hearing but he has taken figures from the income and expenditure account for which he has drawn our attention on page Nos. 31 to 58 of the paper book and prayed to set aside the order of the ld CIT-II, Jalandhar.
5. At the outset, the ld Sr.DR has vehemently supported the order of the ld CIT and submitted a written reply on the case laws 18 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT referred by the assessee and argued that the case laws referred by the assessee before the Hon'ble Bench are per in-curium as a very vital issue has been missed in all these judgments. The amendment U/s 12AA(3) was made by the Finance Act, 2010, which has been explained by the CBDT vide circular No. 1/2011 dated 06/4/2011. If the Trust's activity is found non-genuine or its activities are not in accordance with the objects for which such Trust was established, the registration granted U/s 12AA can be cancelled by the ld CIT after providing reasonable opportunity of being heard to the Trust. The power of Commissioner of Income Tax for cancellation of registration is inherent and flows from the authority of granting registration. However, judicial rulings in some cases had held that the Commissioner does not have power to cancel the registration, which was obtained earlier by any Trust or Institution under the provisions of Section 12AA as it is not specifically mentioned in Section 12AA of the Act. Therefore, Section 12AA had been amended to provide that the Commissioner can also cancel the registration obtained U/s 12A as it stood bare amendment by Finance Act as it is not specifically mentioned in 19 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT Section 12AA. It is further argued that intention of amendment of Section 12AA was not brought to the notice of above mentioned Tribunals and the Hon'ble Delhi High Court, if the amended provision would make applicable w.e.f. 01/6/2010, it means that the CIT cannot cancel the registration granted prior to his date, which makes the amendment as redundant. Therefore, the above judgments are per in-curium and same should not be followed. He further relied on the decision in the case of Lalit Hosiery & ors. Vs. Union of India & ors. 221 CTR (P&H) 692 on surcharge on block assessment tax and amendment made in statute. The interpretation of the statute has to be done as such as manner as may further cause of the Legislation and manner. The interpretation has been made in the decision of Hon'ble ITAT and Hon'ble Delhi High Court clearly are not supportive of the intendment of the enactment which came to be ignored in the above judgments and as such the above judgments are patently per in-curium and thus not to be followed. The Hon'ble ITAT has upheld the order of the ld CIT, Jalandhar for cancellation of registration in case of Ram Saram Dass Kihori Lal Charitable Trust 20 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT vide its order in ITA No. 33/Asr/2009 dated 26/06/2009. It is further submitted that the Hon'ble ITAT had dismissed the appeal of the assessee for assessment year 2006-07 and allowed the appeal of the department by holding that the assessee is not engaged in any charitable activity as per its stated object in ITA No. 504/Asr/2009 and ITA No. 515/Asr/2009 dated 31/12/2013 wherein the Hon'ble ITAT has held that the assessee had not proved its case for seeking exemption U/s 11 of the Act by producing any details of expenditure incurred to the assessee- Trust on various activities undertaken to achieve its objects the revenue authorities as well as before us till the closing of hearing present appeals. The assessee had never undertaken any activities in furtherance of its stated objects. The assessee had leased the building and the land to the lease i.e. the NRI Academy of Science which managed the administration of the hospital and the all doctors and para medical staff was employed by the NRI Academy of Science (lessee). The lessee had made the upfront payment to the lessor for the lease of land and building and since the hospital was being run and managed by the lessee i.e. M/s NRI Academy of 21 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT Science. It is clear that the assessee done nothing to be eligible for registration U/s 12A and it should be cancelled. The ld CIT has not taken basis of application rejected U/s 10(23C)(vi) of the Act for cancellation of registration but he had verified the activities performed by the assessee society. He further placed reliance on the decision in the case of D.R. Ranka Charitable Trust Vs DIT (Exem.) (ITAT Bangalore) (supra) wherein constructed building and income was let out on rent and the Hon'ble Bangalore ITAT held that there is no charitable activity of the Trust. Therefore, he prayed to confirm the order of the ld CIT-II, Jalandhar.
6. We have heard the rival contentions of both the parties and perused the material available on the record. The ld CIT-II, Jalandhar passed order U/s 12AA of the Act on 24/10/2013 w.e.f. A.Y. 2004-05 but in Section 12AA(3), the amendment was made by the Finance Act, 2010, which was effective prospectively as clarified by the CBDT as well as various ITATs. The case laws relied by the AR of the assessee also support the case of the assessee, therefore, from A.Y. 2004-05, the cancellation is out of jurisdiction. The Hon'ble Delhi High Court in the case of Director of 22 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT Income Tax (Exemption) Vs. Mool Chand Khairati Ram Trust (2011)339 ITR 622 (Delhi) has held that power of cancellation of registration obtained U/s 12A came to be incorporated by way of amendment introduced in Section 12AA(3) by the Finance Act, 2010 w.e.f. 1st June, 2010. The Director of the Income Tax was, therefore, no justified in cancelling the registration U/s 12AA(3) w.e.f. December 2002-03 vide his order dated 30th June, 2009.
Similar view has also held by the various ITATs as referred above, therefore, we set aside the order of the ld CIT-II, Jalandhar. Hence, this appeal of the assessee is allowed.
7. In the result, the appeal of the assessee is allowed.
Order pronounced in the open court on 29. 09.2015.
Sd/- Sd/-
(A.D. JAIN) (T. R. MEENA)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Dated:29th September, 2015
*Ranjan
Copy of the order forwarded to:
1. The Appellant- M/s Punjab Institute of Medical Sciences, Jalandhar.
2. The Respondent- The CIT-II, Jalandhar.
3. The CIT 23 ITA 740/Asr/2013 M/s Punjab Institute of Medical Sciences Vs. CIT
4. The CIT(A)
5. The DR, ITAT, Amritsar.
6. Guard File (ITA No. 740/Asr/2013).
By order (Assistant Registrar) ITAT, Amritsar Bench: Amritsar.