Income Tax Appellate Tribunal - Ranchi
Sanwarmal Poddar, Kolkata vs Dcit, Dhanbad on 15 February, 2019
IN THE INCOME TAX APPELLATE TRIBUNAL RANCHI BENCH, RANCHI Before Shri S.S.Godara, Judicial Member and Dr. A.L. Saini, Accountant Member IT(SS)A No.36/Ran/2015 Assessment Year :2010-11 Sanwarmal Poddar V/s. DCIT, Central Circle, Chhaparia & Associates, Aayakar Bhawan, L.C. Chartered Accountants, 8, Road, 3 r d Floor, Room Camac Street, No.405-8, Dhanbad-
Shantiniketan Building, 826001
5 t h Floor, Room No.2,
Kolkata-700017
[P AN No. ADCPP 1457 F]
अपीलाथ /Appellant .. यथ /Respondent
अपीलाथ क ओर से/By Appellant Shri Devesh Poddar, Advocate
यथ क ओर से/By Respondent Shri Inderjit Singh, CIT-DR
सन
ु वाई क तार ख/Date of Hearing 09-01-2019
घोषणा क तार ख/Date of Pronouncement 15-02-2019
आदे श /O R D E R
PER BENCH:-
This assessee's appeal for assessment year 2010-11 arises against the Commissioner of Income Tax (Appeals)-3 Patna's order dated 28.08.2015 passed in case No.127/CIT(A)-3/PAT/2014-15 involving proceedings u/s 153A r.ws. 143(3) of the Income Tax Act, 1961; in short 'the Act'.
Heard both the parties. Case file perused
2. It transpires from the instant case file that both the lower authorities have added the alleged undisclosed trading purchase of Rs.92,29,434/- as the IT(SS)A No.36/Ran/2015 A.Y. 2010-11 Sanwarmal Poddar Vs. DCIT CC-Dhanbad Page 2 taxpayer's alleged undisclosed income in entirety. The CIT(A)'s detailed discussion to this effect reads as follows:-
"Brief facts: There was search and seizure action in the case of Poddar Group on 22.06.2011. The appellant is one of the directors of the said group. In response to notice u/s. 142(1), the appellant filed return of income showing total income at Rs.64,08,830/- which included Rs.60,00,000/- as additional income offered for taxation apart from regular income from business and other sources. The AO finalized the assessment at Rs.96,38,264/- making addition of Rs.32,29,434/- to the total income. This appeal is filed against this addition of Rs.32,49,434/-. Ground No.1 & 2: The appellant has raised objection to the treatment of entire undisclosed trading purchases of Rs.9229434/- as undisclosed income of the appellant as against Rs.60,00,000/- offered by the appellant as additional income.
Assessing Officer's contention During the assessment proceedings the AO found that the seized documents MKA-6 comprised of loose sheets wherein page No.14 of the loose sheets indicated total purchases transaction of Rs.60,57,680/- . This page also contained noting of sales transactions, although the sales were not commensurate with the total purchase transaction of Rs.60,57,680/-. The AO treated this amount as undisclosed investments in the hands of the appellant. Similarly, another seized document page No.1 of MKA-6 indicated purchase transactions worth Rs.31,71,764/- from Neetu Sinigh. This was also added by the AO as undisclosed purchases outside the books of account. Thus, total addition of Rs.92,29,434/- was treated as undisclosed purchases and after giving credit for Rs.60,00,000/- offered as additional income, Rs.32,29,434/- was added to the total income of the appellant.
Appellant's contention:
During the course of appellate proceedings, appellant contended that disclosure of additional of Rs.60,00,000/- was more than sufficient to cover the undisclosed capital infusion as well as profits from the transaction on the loose sheet seized by page No.1 & 14 of MKA-6. The gist of appellant's contentions are:
'The AO has added the aggregate undisclosed trading purchase to the total income of the assessee instead of adding earnings (difference between undisclosed sales- undisclosed purchases) from undisclosed trading activities during the year. The AO did not appreciate the fact that a business man does not make only purchase throughout the year without making sales and has failed to appreciate the concept of rotation turnover in any trading activity. It is worth mentioning that since no undisclosed books of account were found during search / survey and seized / impounded document MKA6 are only a bunch of loose documents (Refer Page 24-25 of Paper book 1) and not books of IT(SS)A No.36/Ran/2015 A.Y. 2010-11 Sanwarmal Poddar Vs. DCIT CC-Dhanbad Page 3 account. It implies that the documents on the basis of which inference were drawn by the assessee AO doesn't represent the complete set of records. Thus, while drawing any inference from the seized records, one has to practical to reach to a logical conclusion. The mere fact that no documents relating to undisclosed sales was found during search/survey does not mean that there were no sales outside books.
Thus, the Assessing Officer has erred in treating the entire undisclosed trading purchases of Rs.92,29,434/- as undisclosed income.
1) Submissions with respect to Ground no.2 In the instant case the appellant offered Rs.60,00,000/- as undisclosed income during the year which includes undisclosed capital infusion and earning from undisclosed trading activities during the year. But still the AO has added Rs.92,29,434/- to the total income of the assessee. The AO failed to appreciate the fact that a business man does not make only purchases and he must have made undisclosed sales during the year. The AO cannot ignore concept of rotation turnover in any trading activity.
Hon'ble High Court of Gujarat in the case of Commissioner of Income Tax vs. Bholanath Poly Fab (P) Ltd. [2013] 40 taxmann.com 494 (Gujarat) has held that entire purchases cannot be subject matter of additions and only the profit margin embedded in such purchases would be subject to tax. Thus it is submitted that the Assessing Officer has erred in treating undisclosed income at Rs.92,29,434/- as against Rs.60,00,000/- offered by the appellant.' Appellate finding and decision:
After going through the findings of the AO in the assessment order and appellant's submission during appellate proceedings, I find that the appellant has filed a paper book containing detailed submission and analysis of cash inflow and outflow year-wise for the whole group containing pages 1 to 214. At page No.24 of the paper book submitted by the appellant, it is found that for the financial year 2009-0-10, appellant had shown only cash outflow of Rs.31,71,754/- related to seized document pages No1. Of MKA-6 and cash outflow of Rs.60,57,680/- relate to seized document page No. 1o to 13 of MKA-6. This explanation of the appellant clearly indicate that the appellant has itself accepted that there was no sales and any cash inflow relating to total purchases worth Rs.92,29,434/- indicated by the seized documents. Therefore, there is no force in ape's contention that the total purchases should not have been taken as undisclosed income of the appellant. Hence, I am inclined to accept the Assessing Officer's view that the whole of purchases Rs.92,29,434/- should be treated as IT(SS)A No.36/Ran/2015 A.Y. 2010-11 Sanwarmal Poddar Vs. DCIT CC-Dhanbad Page 4 undisclosed investment on unaccounted purchases of the appellant. Therefore, the addition of Rs.32,29,434/- made by the AO is hereby confirmed."
3. We have heard rival contentions. There is hardly any dispute that both the learned lower authorities haves added assessee's entire trading purchase in wholesome as undisclosed. This tribunal's co-ordinate bench in M/s Subarna Rice Mill vs. ITO in ITA No.1781/Kol/2014 decided on 30.06.2015 (as upheld by hon'ble Calcutta high court's in corresponding tax appeal reported as (2018) Taxmann 509) holds that it is only the profit element embedded in such a case that needs to be assessed as income as follows:
"3. Briefly stated facts are that a survey u/s. 133 of the Act was carried out on the business premises of the assessee on 24.03.2010. The assessee firm is engaged in the business of rice milling. The assessee has disclosed purchase of paddy at Rs.3,45,62,335/- and sale of rice and bran at Rs.3,53,60, 711/-. It has disclosed gross profit at Rs.34,72,298/- and after claiming expenses disclosed net profit at Rs.14,33,482/-. During the course of survey while comparing the stock as per audited accounts and the stock register in Form No. IV the survey party noticed certain discrepancies i.e. undisclosed purchase of paddy at 37647.20 quintals, excess stock of rice at 581.15 quintals and undisclosed stock of bran at 45.52 quintals. The relevant calculations made by survey party as reproduced in the assessment order reads as under:
Determination of Closing Stock of Paddy (in Quintai) As per Audited Account As per Survey Findings Opening Stock as on 4545.20 Stock on the date of 43447.20 01.04.2009 survey 24.03.2010 Add: Purchase during the 36755.00 Add: Purchase-during 100.00 year 25.03.2010 to 31.03.2010 Total 41300.20 Total 43547.20 Less: Milling during the 35600.20 Less: Milling during 200.00 year 25.03.2010 to 31.03.2010 Closing Stock as on 5700.00 Closing Stock as on 43347.20 31.03.2010 31.03.2010 Undisclosed Purchase of Paddy = (43347.20 - 5700.00)= 37647.20 Quintal Determination of Closing stock of Rice (in Quintal) As per Audited Account As per Survey Findings Opening Stock as on Stock on the date of3760.00 01.04.2009 1513.58.20 survey 24.03.2010 Add: Production during the Add: Purchase during 136.00 year 24206.00 25.03.2010 to 31.03.2010 Total 25720.02 Total 3896.00 Less: Sale during the year 22545.17 Less: Sale during 140.00 25.03.2010 to 31.03.2010 Subama Rice Mill AY 2010-11 Closing Stock as on 3174.85 Closing Stock as on 3756.00 31.03.2010 31.03.2010 Excess Stock of Rice = (3756.00 - 3174.00) = 581.15 Quintal Determination of Closing Stock of Rice Bran (in Quintal) As per Audited Account As per Survey Findings Opening Stock as on 45.00 Stock on the date of 146.00 01.04.2009 survey 24.03.2010 Add: Production during the year 1780.01 Add: Purchase during 10.00 25.03.2010 to 31.03.2010 Total 1825.01 Total 156.00 Less: Sale during the year IT(SS)A No.36/Ran/2015 A.Y. 2010-11 Sanwarmal Poddar Vs. DCIT CC-Dhanbad Page 5 1714.53 Less: Sale during NIL 25.03.2010 to 31.03.2010 Closing Stock as on 31.03.20 110.48 Closing Stock as on 156.00 31.03.2010 Undisclosed Purchase of Bran = (156.00 - 110.48) = 45.52 Quintal The AO required the assessee to explain the discrepancy in respect to undisclosed purchase, excess stock of rice and undisclosed stock of bran. The assessee for the first time denied the excess stock of rice, undisclosed purchases and undisclosed stock of bran vide letter dated 11.12.2012 during the course of assessment proceedings. The AO treated the purchase of paddy at 38501.83 quintals as undisclosed investment and treated the income at Rs.3,85,01,830/-. Aggrieved, assessee preferred appeal before CIT(A).
4. The CIT(A) confirmed the action of the AO by confirming the addition by observing as under:
"19. In coming to a decision on unaccounted stock document marked SRM-5 is vital. In the inventory the item contributing maximum to value is paddy. As per Form-IV the stock of paddy is 5800 quintal. As per document marked SRM-5 the stock is 66892 bags i.e. 40135.20 quintal and physical inventory is 43447.20 quintal. Thus it can be seen that the physical inventory is in close proximity with a pre-existing evidence viz. document marked SRM-5 which establishes existence of stock over and above what is recorded in books of accounts. In assessment stage it was upto assessee to produce document marked SRM-5, give necessary explanation and establish that his regular books of accounts are true and correct. The known contents of document marked SRP-5 are not rebutted. Section 292(C)(1)(ii) stages in regard to books of accounts found during survey that "that the contents of such books of accounts and other documents are true." Since the contents of document marked SRM-5 are not rebutted, the onus which is on assessee, the evidence sands as a strong evidence against assessee. By not doing so he has not established that the stock inventory taken by Assessing Officer as incorrect.
20. In regard to capacity of godown, the Assessing Officer doing hearing submitted that the stock was not merely in godown but in open and temporary sheds. Keeping the findings and background in paragraph 18 and 19 I hold that the argument of Subarna Rice Mill AY 2010-11 appellant in this regard carries no weight since there are supportive evidences mainly document SRM-5 establishes existence of unaccounted stock.
21. In regard to FCI inspection, the fact that Assessing Officer has conducted a physical verification and prepared an inventory. The report of Assessing Officer is as under:
'The second point is regarding the books maintained by the assessee under D.C.F.&S/FCI guideline-Registers in Form-I, II, III and IV are maintained by the Rice Mills under D.C.F.&S/FCI guideline. As seen in the above point that there were different stocks noted, by the assessee firm itself, in the Form Registers (Register-IV) and in Paddy stock register SRM-5, as evident from survey statement (question no.8) However, for assessment purpose the stock considered are as per physical stock found for IT(SS)A No.36/Ran/2015 A.Y. 2010-11 Sanwarmal Poddar Vs. DCIT CC-Dhanbad Page 6 different items in the premises of the assessee on the day of survey."
No reasons are adduced as to why FCI inspector has to prevail over the physical verification made by Assessing Officer The manner and effort put in such certification by FCI is a fact not established by assessee. It is not proved that FCI inspector did take stock and no in mechanical manner where inspectors visit godown after another for periodic checking. Further the stock taken by Assessing Officer is legal and in accordance with provisions of Section 133A by a team. On the other hand the FCI inspector has merely signed a document prepared by assessee and there is no entry of having verified stock and found correct. Also on 24.03.2010, the day of survey, there was no entry of verification by an FCI Inspector.
22. In the final hearing the emphasis laid by appellant is that the evidence issued by Assessing Officer in farming assessment is on basis of confessional statement. He relied on the instruction of CBDT in F. No.286/21203-IT (lnv) dated 10.03.2003 with emphasis on line 2. The instruction under subject "Confession of additional income during the course of search & seizure and survey operation" reads as under:-
'Instances have come to the notice of the Board where assessees have claimed that they have been forced to confess the undisclosed income during the course of the search & seizure and survey operations. Such confessions, if not based upon credible evidence, are later retracted by the concerned assessees while filing returns of income in these circumstances, on confessions, during the course of search & seizure and survey operations do not serve any useful purpose. It is, therefore, advised that there should be focus and concentration on collection of evidence of income which leads to information on what has not been disclosed or is not likely to be disclosed before the Income Tax Departments. Similarly, while recording statement during the course of search it seizures and survey operations no attempt should be made to obtain confession as to the undisclosed income. Any action on the contrary shall be viewed adversely.
Further, in respect of pending assessment proceedings also, assessing officers should rely upon the evidences/materials gathered during the course of search/survey operations or thereafter while framing the relevant assessment orders.
23. The Authorised Representative also stated that SRM-5 never finds mention in assessment order and that he holds that SRM-5, 6 and 7 never existed and its recording in survey proceedings is part of confessional statement.
Subarna Rice Mill AY 2010-11
24. The matter is considered. The evidenced in possession of Assessing Officer has support of law. Statement recording during survey is permitted under section 133A(3 )(iii). Stock taking is permitted IT(SS)A No.36/Ran/2015 A.Y. 2010-11 Sanwarmal Poddar Vs. DCIT CC-Dhanbad Page 7 under section 133A(3)(ii). Placing marks of identification in documents like SRM-5 is permitted under section 133A(3)(i). Hence every evidence obtained by Assessing Officer is one that is legally obtained.
25. In regard to alleged confession, the remedy is available in form of retraction subject to fulfilling certain conditions spelt out in judicial decisions spelt out in paragraph 13 of this order. The matter is discussed in paragraph 13 of this order. The appellant hold that filing a return of income with book results tantamount to retraction and for this he relies on line 2 of CBDT instruction. Line 2 highlights the background of issue of instruction and not that filing of return of income in variation with statement tantamount to retraction. In fact the instruction is intended to discourage disclose of additional income not based on evidences. In the instant case there is no disclosure of additional income. Only permissible acts highlighted I preceding paragraph has been conducted by Assessing Officer. Hence the contents of F.No.286/2/2003-IT(Inv) is not applicable in the context of the case. It is added here that the Assessing Office who (A) had conducted survey, (B) recorded statement of 06.11.012 and completed assessment and (C) who had given report on 20.08.2014 are different and no bias can be attributed I their findings.
26. Another objection taken by Authorised Representative is that the Assessing Officer partly used figures in his books of accounts in determining unaccounted stock. The stock was taken on 24.03.2010. The Assessing Officer considered transactions in the period between date of survey and 31.03.2010 to make a comparison with the disclosed stock as on 31.03.2010. Comparison can and shall always be between likes. Hence the standardization was made by Assessing Officer. He can either work out figure as done by him to make standardized comparison as on 31.03.2010 or retro-work from the figures in the books of accounts to compute accounted stock as on 24.03.2010. He chose one of the options and such standardization exhibits fairness on part of Assessing Officer and there is no infirmity on any count. This objection therefore is not accepted.
27. The appellant also stated that the stock inventory of the magnitude cannot be taken in the limited time of 12 hours as weighing and determining the stock is a job of colossal magnitude. I find from the survey proceedings that weighing is not done but inventory of bags (except a small part in form of loose rice) is taken by counting the number of bags in the stack.
28. In pages 6 and 7 the case decisions relied upon by appellant is mentioned. The aspects of retraction and value of statement has been addressed in this order. The addition made by Assessing Officer is not exclusively based on statement and the statement is supported by document document marked SRM-5.
29. The appellant also stated that document marked SRM-5 finds no mention in assessment order and hence should not be considered ion the appeal stage. The contents of SRM-5 is part of assessment records and finds mention in the report of Assessing Officer dated 20.08.2014 which the appellant had opportunity to go through during appeal proceedings. The contents of SRM-5 ads support to the overall finding IT(SS)A No.36/Ran/2015 A.Y. 2010-11 Sanwarmal Poddar Vs. DCIT CC-Dhanbad Page 8 of the Assessing Officer. The evidence is a pre-existing one and by merely not mentioning the same explicitly in assessment order does not make it a document not part of the ongoing proceedings or vitiate the assessment order. In any case power of CIT(Appeals) is co- terminus with that of Assessing Officer and can be considered at appeal stge. Explanation I to section 251 reads "in disposing of an appeal, the Commissioner (Appeals) may consider and decide any matter arising out of the proceedings in which the order appealed against was passed, notwithstanding that such matter was not raised before the Commissioner (Appeals) Subarna Rice Mill AY 2010-11 by the appellant." The argument raised by appellant in this regard is also not accepted.
30. In the course of hearing on 20.08.20104, new evidence was filed. This is a copy of stock statement given before Oriental Bank of Commerce and is to justify the stock balance reported in Balance Sheet. This evidence comes in par with the nature of evidence with regard to FCI inspection relied on by appellant and a decision on the same is already made. As matter of fairness evidence on FCI was admitted and adjudicated. The statement given Oriental Bank of Commerce was in possession of assessee even during assessment proceedings, not produced. As no justification exists to be covered under rule 46A the evidence is ordinarily inadmissible. However the same is found to be a self- declaration and again no there is of entry of any independent verification. Therefore, even if admitted, the same does not help appellant in any manner.
31. In summary the facts are:-
a. Stock Inventory taken during survey is not faulty as alleged. b. There is material in possession of assessee viz document marked SRM-5, found during survey, but not produced when notice under section 131 was issued, establishing existence of unaccounted stock. c. Condition for a valid retraction not satisfied.
d. All legal and factual arguments are found to be inapplicable/validly rebutted by Assessing Officer and also in this order.
32. In view of discussion above, considering all aspects, I uphold the addition of Rs.3,85,01,830 to returned income made by Assessing Officer and dismiss the ground of appeal. The factors that guided in arriving at such a decision include (A) non production of documents marked SRM 5, 6 and 7 (last known possession is with assessee himself) during survey before Assessing Officer during as proceedings, (B) existence of supportive material viz document marked srm-5 (the contents of which are known and its existence is acknowledged as late as 6.11.2012) which establishes that the physical stock matched closely with stock recorded in the document, (C) presumption as per section 292C which is not rebutted. (D) no case is established that a confessional statement is taken during survey and (E) conditions for a valid retraction, if warranted, keeping in view the settled judicial position on the matter are not met. All above (A) to (E) and other points IT(SS)A No.36/Ran/2015 A.Y. 2010-11 Sanwarmal Poddar Vs. DCIT CC-Dhanbad Page 9 raised by appellant are adequately addressed in this order in preceding paragraphs."
5. We have heard rival submissions and gone through facts and circumstances of the case. We find that the assessee has not produced books of account before the AO or before CIT(A) during the course of assessment proceedings or appellate proceedings. The AO while framing assessment has gone through the audited accounts and the stock register maintained in Form No IV. He after computing closing stock of paddy treated the difference as undisclosed purchase of paddy at 37647.20 quintals. Similarly, the AO treated the excess undisclosed stock of bran at 45.5 quintals. The AO for computing these three differential items taken the closing stock as per audited accounts and closing stock and also added the total purchases and milled paddy and also the comparative stock found during the course Subama Rice Mill AY 2010-11 of survey as on the date of survey. The Ld. Counsel for the assessee before us clarified that the AO noted a fact that stock was not merely in god own but was in open temporary shed also. But he contested that this much stock cannot be weighed within one day because survey was concluded on that very date i.e. on 24.03.2010. Ld. Counsel for the assessee also produced a physical verification report as prepared by FCI while inspecting the stock of paddy. We find that the AO has never denied that the sales are not out of these unaccounted purchases. The sales made are accepted as it is. Once the sales are accepted, the entire undisclosed purchases cannot be added for computing the income of the assessee except by applying a profit rate i.e. gross profit as declared by assessee in regular books of account or the gross profit declared by other concerns in the similar trade. In view of the above facts and circumstances and particularly when the books of accounts were not produced by the assessee before the AO, the book results cannot be accepted and the same are to be rejected. In any case, the computation method of the AO for determining undisclosed purchases is taken through mathematical exercise. We find that the assessee maintaining the stock and production registers as per the guidelines of FCI, which are Form No. I to IV. The registers are regularly checked by FCI for the reasons that 40% of the production would have been sold to FCI as per Government order. The AO should have verified the closing stock in view of stock register maintained for the purposes of FCI. Even otherwise, this stock inventory of the magnitude of 43,447.20 quintals is impossible to be weighed and determine the closing stock within the time-limit of 12 hours, which was the period during which the Survey Party stayed in the business premises of the assessee. From the finding of survey, it is clear that weighing is not done but only counting of bags or inventory of bags is taken by the Survey Party counting the number of bags in the stacks. We find that the FCI Inspector has signed the stock register as on 31.03.2010 by mentioning the 5700 quintals of paddy, whereas the AO determined the stock as 43,347.20 quintals. The assessee has maintained stock register in Form No I, 11, III & IV under DCF&S/FCI guideline as maintained by the Rice Mill. Neither AO nor CIT(A) has cross-verified the registers maintained by assessee. In such circumstances, we direct the AO to recompute the income by applying gross profit rate on the unaccounted purchases, which are sold out. The Subarna Rice Mill AY 2010-11 assessee has disclosed the gross profit and comparative statement of turnover and IT(SS)A No.36/Ran/2015 A.Y. 2010-11 Sanwarmal Poddar Vs. DCIT CC-Dhanbad Page 10 gross profit filed during the course of hearing before us, which reads as under:-
Asstt. Year Turnover (Rs) G.P. (Rs) RATIO
2010-11 3,53,60,711.00 34,72,298.00 9.82%
2009-10 3,59,63,785.00 24,34,389.00 6.76%
2008-09 2,72,28,511.00 24,77,402.00 9.09%
2007-08 NIL NIL NIL
In view of the above gross profit declared by the assessee, we are of the view that these are undisclosed purchases as sold by the assessee and sale is admitted by the Revenue, a reasonable GP rate will be 10% for computing profit of the assessee. Accordingly, we direct the AO to recompute the income after deleting the addition made on account of undisclosed purchases but apply GP rate of 10% on the undisclosed purchases. The AO is directed accordingly."
Learned CIT-DR fails to dispute that assessee's disclosure having search amounting to ₹60 lac (supra) very well surpasses the profit element in the impugned trading purchases addition of ₹92.29 lac in issue. We therefore delete the impugned addition for this precise reason alone.
4. This assessee's appeal is allowed.
Order pronounced in accordance with Rule 34(4) of ITAT Rules by putting on Notice Board on 15/02/2019 Sd/- Sd/-
(लेखा सद य) ("या#यक सद य)
(Dr. A.L. Saini) (S.S.Godara)
(Accountant Member) (Judicial Member)
Ranchi,
*Dkp
$दनांकः- 15/02/2019 Ranchi ।
आदे श क त ल प अ े षत / Copy of Order Forwarded to:-
1. अपीलाथ /Appellant-Sanwarmal Poddar, Chhaparia & Associates, Chartered Accountants 8, Camac St, Shantiniketan Bldg. 5th Fl. R. No.2, Kolkat-17
2. यथ /Respondent-DCIT, Central Circle Aayakar Bhawan, L.C. Road,3rd Floor, Room No.405-8, Dhanbad-826001
3. संब0ं धत आयकर आय3 ु त / Concerned CIT Ranchi
4. आयकर आय3 ु त- अपील / CIT (A) Ranchi
5. 6वभागीय #त#न0ध, आयकर अपील य अ0धकरण, / DR, ITAT, Ranchi
6. गाड< फाइल / Guard file.
By order/आदे श से, /True Copy/ SR.PS, ITAT, RANCHI