Income Tax Appellate Tribunal - Ahmedabad
Ashokkumar H.Kothari, Surat vs Assessee on 16 January, 2015
आयकर अपीलीय अिधकरण,
अिधकरण, अहमदाबाद Ûयायपीठ 'डȣ
डȣ'
डȣ अहमदाबाद।
अहमदाबाद।
IN THE INCOME TAX APPELLATE TRIBUNAL
"D" BENCH, AHMEDABAD
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BEFORE SHRI G.C. GUPTA, VICE PRESIDENT AND
SHRI N.S. SAINI, ACCOUNTANT MEMBER
आयकर अपील सं./
./ ITA No. 386/Ahd/2009
िनधा[रण वष[/Assessment Year: 2005-06
Ashokkumar H. Kothari,
Prop. B. Ashokkumar & Co., Vs The ITO,
12, Shakti Chambers, Ward-6(1),
Raghunathpura, Surat Surat
PAN : ADGPK 1858 H
आयकर अपील सं./
./ ITA No. 2800/Ahd/2010
िनधा[रण वष[/Assessment Year: 2005-06
The ITO, Ashokkumar H. Kothari,
Ward-6(1), Vs Surat
Surat PAN : ADGPK 1858 H
अपीलाथȸ/
अपीलाथȸ/ (Appellant) ू×यथȸ
यथȸ/
थȸ/ (Respondent)
Assessee(s) by : Shri M.K. Patel, AR
Revenue by : Shri B.L. Yadav, Sr. DR.
सुनवाई कȧ तारȣख/
/ D at e o f H e ari n g : 1 7 / 1 2 /2 01 4
घोषणा कȧ तारȣख /Dat e o f Pro n o u n c em e n t : 1 6 /0 1 /2 01 5
आदे श/O R D E R
PER SHRI N.S. SAINI, ACCOUNTANT MEMBER:
The appeal in ITA No. 386/Ahd/2009 is the appeal filed by the Assessee against the order of the Commissioner of Income-tax (Appeals)-IV, Surat dated 28.11.2008 for Assessment Year 2005-06 and the appeal in ITA No.2800/Ahd/2010 is the appeal filed by the ITA Nos 386/Ahd/2009 & 2800/Ahd/2010
- Ashokkumar H. Kothari
- AY 2005-06 -2- Revenue against the order of the Commissioner of Income-tax (Appeals)-IV, Surat dated 02.07.2010 for Assessment Year 2005-06.
2. Ground No.1 of the assessee's appeal reads as under:-
1. On the facts and in the circumstances of the case as well as law on the subject, the learned Commissioner of Income Tax (Appeals) has erred confirming the action of the Assessing Officer in making addition of Rs.18,40,177/- on account of under valuation of closing stock.
3. The brief facts of the case are that the Assessing Officer observed that the assessee has shown gross profit of 0.023% of the total turnover of more than Rs.146 crores against GP of 0.21% on a turnover of Rs.150 crores in the immediately preceding year. When the Assessing Officer required the assessee to justify the fall in GP, the assessee has stated that this was because of exchange rate difference expenses and if this was considered as directly related to purchases, the ratio of GP would be better than the earlier year. The Assessing Officer further required the assessee to produce five top suppliers to verify the purchases claimed by the assessee but the same was not done. The Assessing Officer was also not satisfied by the explanation of the assessee that the reason for fall in GP was because of exchange rate difference. The Assessing Officer further observed that the closing stock of polished diamonds was valued at lower price than rough diamonds. The closing stock was shown at 1240.08 carats @ Rs.1481 per carat whereas the closing stock of rough diamond was taken at approximately Rs.2900/- per carat. When required to justify, the assessee submitted copies of purchase bills of polished diamonds dated 24.04.2005 in which the polished diamonds were purchased @ Rs.2965 per carat from one Lucky Star and it was stated that some of the diamonds purchased were of inferior quality and hence could not be sold during the year and were ITA Nos 386/Ahd/2009 & 2800/Ahd/2010
- Ashokkumar H. Kothari
- AY 2005-06 -3- subsequently sold @ 1483 per carat on 04.04.2008 which was why the rate of closing stock for the year was taken at the market price. The Assessing Officer required the assessee to produce the principle persons of seller parties which was not done. The Assessing Officer, therefore, was of the view that the closing stock of polished diamonds was undervalued and adopted the value at Rs.2965/- per carats being the cost price at according to the assessee and made an addition of Rs.18,40,177/- on this account.
4. On appeal before the CIT(A), the assessee submitted that the valuation of closing stock of polished diamonds was made on account of its sale value on 04.04.2008. He also submitted that the comparison of valuation of rough with polished diamonds was not fair since valuation of rough was based on its potential future value after manufacture whereas polished diamonds were valued at the market rate. It was further submitted that the Assessing Officer's action in asking the appellant to produce the principal partners of seller parties was not correct since the sale proceeds had taken place in the subsequent year and the confirmation of the buyer party has already been furnished before the Assessing Officer.
5. The CIT(A), after considering the submissions made by the assessee, confirmed the addition of Rs.18,40,177/- made by the Assessing Officer, by observing as under:-
"I have considered the submissions and gone through the details. It is seen that there is a drastic fall in the GP rate compared to last year. The reason advanced by the appellant that the fall was due to exchange rate valuation is without any basis. The exchange rate valuation would be there in the immediately preceding year also and even if this variation is taken as a part of purchase price, it would not the sufficient in reducing GP to 1/10th of that of preceding year. Further, the appellant's argument that the closing stock was valued at the sales made subsequently on 04.04.2008 is also not supported ITA Nos 386/Ahd/2009 & 2800/Ahd/2010
- Ashokkumar H. Kothari
- AY 2005-06 -4- by any evidence. The appellant has also not been able to produce the principle persons of the concerns to whom the said stock was sold. It is also not proved by any documents or evidence that it was the same lot of diamonds which was sold on 04.04.2008. It is again very strange to note that the rough diamond have been valued at almost double the price of polished diamonds. I also do not accept the explanation that the rough diamonds had higher value because of the potential future value of polished diamonds which could be made from such rough diamonds. The appellant has not been able to prove the selling price of closing stock which he claimed as inferior nor could there be any justification in claiming that the polished diamonds purchased at a higher value were sold at the lower value. The appellant is in the diamond business for a long time having a turn over of approximately Rs.150 crores and it is not expected of such an experienced dealer to purchase polished diamonds at a higher rate than the market value. In view of this, I am of the considered view that the AO's action in valuing the closing stock of polished diamonds at the rate at which rough diamonds were valued, is in order and addition on this account is confirmed."
6. The Departmental Representative supported the orders of the lower authorities, whereas the Authorized Representative of the assessee reiterated the submissions made before the Assessing Officer and the CIT(A).
7. We have heard the rival submissions and perused the orders of the lower authorities and material available on record. In the instant case, the Assessing Officer observed that the assessee has valued closing stock of polished diamonds of 1240.08 carats @ Rs.1481.08 per carat and valued the same at Rs.18,36,660/-. The Assessing Officer observed that the assessee purchased finished diamonds @ Rs.2965 per carat and therefore, valued the closing stock of 1240.08 carats @ Rs.2965 per carat and thus, arrived at their value at Rs.36,76,837/-. Thus, the difference of Rs.18,40,177/- was added to the income of the assessee on the ground of undervaluation of closing stock.
ITA Nos 386/Ahd/2009 & 2800/Ahd/2010
- Ashokkumar H. Kothari
- AY 2005-06 -5-
8. On appeal, the CIT(A) confirmed the action of the Assessing Officer.
9. Before us, the Authorized Representative of the assessee explained that the assessee during the year under consideration was engaged in the business of rough diamonds and selling the same after polishing the same as well as in trading of finished diamonds. He further contended that the closing stock of 1240.08 carat of diamonds were defective diamonds which were actually sold on 04.04.2005 to M/s. Priya Gems vide invoice No.BAK/LP/APR/03 /2005-06 dated 04.04.2005 for Rs.18,39,039/-; therefore, the same was valued as on 31.03.2005 at Rs.18,36,660/-. He further pointed out that the method of valuation of closing stock was cost or market value whichever is less. He placed a copy of invoice at page No.25 of the paper-book and certified that the same was filed before the Assessing Officer and the CIT(A). He also submitted that the purchaser was not in his control and therefore, simply because the assessee could not produce the purchaser before the Department, an adverse view there from cannot be taken against the assessee.
10. The Departmental Representative supported the orders of the lower authorities.
11. We find that that the Departmental Representative could not dispute the certification of the assessee to the effect that the relevant sale invoice was filed before both the lower authorities.
12. We find from the above sale bill that the rough diamonds of 1240.08 carat was sold on 04.04.2005 for Rs.18,39,039/-. Thus, as the consistent method of valuation of closing stock was cost or market value whichever is less, the assessee valued 1240.08 carat of ITA Nos 386/Ahd/2009 & 2800/Ahd/2010
- Ashokkumar H. Kothari
- AY 2005-06 -6- diamonds at its market value of Rs.18,36,660/-. We find that no material was brought on record by the Revenue to show that the rough diamonds of 1240.08 carat was not sold on 04.04.2005 for Rs.18,39,039/- and the same in fact was sold at a higher value. We find that it is not stated by the Departmental Representative that the name and address of the parties to whom diamonds in question were sold was not submitted before the lower authorities. In the above circumstances, in our considered view, the addition of Rs.18,40,177/- made on account of undervaluation of closing stock is not sustainable. We, therefore, delete the addition of Rs.18,40,177/- and allow this ground of appeal of the assessee.
13. Ground No.2 of the assessee's appeal reads as under:-
2. On the facts and in the circumstances of the case as well as law on the subject, the learned Commissioner of Income Tax (Appeals) has erred confirming the action of the Assessing Officer in making addition of Rs.9,03,387/- on account of low Gross Profit.
14. The brief facts of the case are that the Assessing Officer estimated the GP at the same rate as in the preceding year i.e. 0.21% as against 0.023% shown by the assessee on turnover Rs.1,46,55,24,662/- of the year under consideration and therefore, the GP worked out to Rs.30,77,602/- as against the GP of Rs.3,34,038/- shown by the assessee. The Assessing Officer worked out the difference in GP at Rs.27,43,564/-. Since the addition on account of under valuation of closing stock has already been made by him at Rs.18,40,177/-, he restricted the addition on account of low GP at Rs.9,03,387/- (Rs.27,43,564/- - Rs.18,40,177/-) and added the same to the income of the assessee.
15. On appeal before the CIT(A), the Authorized Representative of the assessee submitted that the books of accounts of the assessee ITA Nos 386/Ahd/2009 & 2800/Ahd/2010
- Ashokkumar H. Kothari
- AY 2005-06 -7- were audited and no defects were found in the said books by the Assessing Officer. He further submitted that the only reason for rejecting the books by the Assessing Officer was on account of fall in GP which was not correct. He also relied on various judicial decision in support of his claim that fall in GP would not be a reason for invoking provisions of section 145(3) of the Act.
16. The CIT(A), after considering the submissions of the Authorized Representative of the assessee, confirmed the addition of Rs.9,03,387/- made by the Assessing Officer on account of low GP, by observing as under:-
"I have considered the submissions. It is seen that the major reason for rejection books of account is under valuation of closing stock and non appearance of the principle persons of the purchased parties of rough diamonds. Further, the genuineness of rates at which the diamonds were claimed to have been sold has also not been established. These facts in my view are sufficient to warrant invocation of provisions of section 145(3) of the Act. The AO's action in rejecting the book results and estimating profit at the same rate as per last year is therefore in order and addition on this account is confirmed."
17. The Departmental Representative supported the orders of the lower authorities, whereas the Authorized Representative of the assessee reiterated the submissions made before the Assessing Officer and the CIT(A).
18. We have heard the rival submissions and perused the orders of the lower authorities and material available on record. The Assessing Officer observed that the gross profit disclosed by the assessee comes to 0.023% of sales. The Assessing Officer observed that the gross profit of the assessee in the immediately preceding year was 0.21%. According to the Assessing Officer, the assessee explained the loss due to exchange rate fluctuation as the main cause of ITA Nos 386/Ahd/2009 & 2800/Ahd/2010
- Ashokkumar H. Kothari
- AY 2005-06 -8- fantastic reduction in the gross profit rate which is not acceptable. Further, the assessee could not produce suppliers of diamond for verification. Therefore, in absence of production of suppliers of diamonds, the purchases claimed by the assessee are not verifiable. He, therefore, rejected the book result and estimated the Gross Profit of the assessee @ 0.21% which worked out to Rs.27,43,564/-. He thereafter allowed telescoping of addition of Rs.18,40,177/- made on account of undervaluation of closing stock and therefore, added Rs.9,03,387/- to the income of the assessee.
19. On appeal, the CIT(A) confirmed the action of the Assessing Officer.
20. We find that the only explanation of the assessee for fall in gross profit rate was that the assessee has incurred foreign exchange fluctuation loss of Rs.37,06,513/- and if the same is removed from the expenditure side of the trading account, then the gross profit of the assessee would work out to 0.27% which is better than the gross profit rate of 0.21% shown in the immediately preceding year. We find that this argument of the Authorized Representative of the assessee is fallacious, because the assessee has filed copy of Trading and P&L Account at page Nos.12 and 13 of the paper-book from which it is observed that the foreign exchange difference has been debited in the Profit & Loss Account by the assessee and not in the Trading Account. Thus, in working out the gross profit at 0.023%, the foreign exchange difference is not considered by the assessee. Therefore, we do not find any infirmity in the orders of the lower authorities in estimating Gross Profit of the assessee @ 0.21% at Rs.27,43,564/-. We have, while deciding the Ground No.1 of the appeal above, held that the addition made in respect of undervaluation of closing stock is not sustainable. Thus, the ITA Nos 386/Ahd/2009 & 2800/Ahd/2010
- Ashokkumar H. Kothari
- AY 2005-06 -9- assessee is not entitled for benefit of telescoping and consequentially, the addition of Rs.27,43,564/- on account of low Gross Profit is sustained. Thus, this ground of appeal of the assessee is dismissed and the Assessing Officer is directed to withdraw the benefit of telescoping.
21. Ground No.3 of the assessee's appeal reads as under:-
3. On the facts and in the circumstances of the case as well as law on the subject, the learned Commissioner of the Income Tax (Appeals) has erred confirming the action of the Assessing Officer in disallowing 20% foreign travelling, conveyance and telephone expenses aggregating to Rs.10,92,036/-.
22. The brief facts of the case are that the Assessing Officer observed, during the course of assessment proceedings, that the assessee has neither produced any proper document nor has shown any expenses which were rendered wholly and exclusively for the purposes of business of the assessee. He also observed that the assessee has failed to correlate all expenses with sale or purchase transactions. Therefore, the Assessing Officer disallowed a sum of Rs.10,92,036/- out of foreign traveling expenses, conveyance expenses, office expenses, telephone expenses, travelling expenses etc. claimed by the assessee.
23. On appeal, the CIT(A) confirmed the disallowance of Rs.10,92,036/- made by the Assessing Officer by following his earlier order passed in assessee's own case for Assessment Year 2004-05.
24. The Departmental Representative supported the orders of the lower authorities, whereas the Authorized Representative of the assessee reiterated the submissions made before the Assessing Officer and the CIT(A).
ITA Nos 386/Ahd/2009 & 2800/Ahd/2010
- Ashokkumar H. Kothari
- AY 2005-06
- 10 -
25. We have heard the rival submissions and perused the orders of the lower authorities and material available on record. In the instant case, disallowance of Rs.10,92,036/- was made by the Assessing Officer out of expenses incurred under the head "office expenses, conveyance expenses, telephone expenses, travelling expenses, brokerage and foreign travelling expenses".
26. Before us, the Authorized Representative of the assessee pointed out that the disallowance was made on ad-hoc basis. However, the Authorized Representative of the assessee was fair to concede that on similar facts, disallowance of Rs.10 lacs was confirmed by the Tribunal in the case of assessee in the immediately preceding year. As the facts and circumstances of the year under consideration are similar to the facts and circumstances of the immediately preceding year, and the disallowance made in the year is in tune with the amount of disallowance confirmed by the Tribunal in the immediately preceding year; therefore, we do not find any good reason to interfere with the orders of the lower authorities. Therefore, this ground of appeal of the assessee is dismissed.
27. Ground No.4 of the assessee's appeal reads as under:-
4. On the facts and in the circumstances of the case as well as law on the subject, the learned Commissioner of the Income Tax (Appeals) has erred confirming the action of the Assessing Officer in disallowing brokerage expenses of Rs.2,74,787/- u/s 40(a)(ia).
28. The brief facts of the case are that the Assessing Officer observed that the assessee paid brokerage charges for purchase and sales of diamonds and deducted TDS in the months of January & February, 2005 but the same was deposited in the Government account only on 02.04.2005. Therefore, the Assessing Officer held ITA Nos 386/Ahd/2009 & 2800/Ahd/2010
- Ashokkumar H. Kothari
- AY 2005-06
- 11 -
that the assessee was in default and made disallowance on entire expenditure.
29. On appeal before the CIT(A), the assessee has submitted that the total TDS made on brokerage in the month of January & February, 2005 was deposited in the Government account on 02.04.2005 but as per the amended provision of section 40(a)(ia) of the Act, the due date for depositing the TDS was specified in section 139(1) of the Act for filing the return of income.
30. The CIT(A), after considering the submissions of the assessee, held as under:-
"I have considered the submissions but I am not inclined to agree with the appellant. As per the amended provision, if the tax is deducted in the last month of the previous year, only then it can be deposited in the Govt. a/c. up to the date of filing the return. However, in any other case, it has to be deposited on or before the last date of the previous year. In this case, the tax has been deducted in the months of January & February and the same should have been deposited in Govt. a/c. on or before 31.03.2005. That being the case, the appellant's claim is without any merits and this ground fails."
31. The Departmental Representative supported the orders of the lower authorities, whereas the Authorized Representative of the assessee reiterated the submissions made before the Assessing Officer and the CIT(A).
32. We have heard the rival submissions and perused the orders of the lower authorities and material available on record. In the instant case, the undisputed facts are the assessee deducted brokerage charges from the purchase and sales of diamonds for the month of January and February 2005, from which payments TDS was deducted by the assessee and the same was deposited to the credit of the ITA Nos 386/Ahd/2009 & 2800/Ahd/2010
- Ashokkumar H. Kothari
- AY 2005-06
- 12 -
Central Government on 02.04.2005. The Assessing Officer disallowed the deduction for the entire brokerage of Rs.2,74,787/- by invoking the provisions of section 40(a)(ia) of the Act on the ground that the TDS was not deposited before the end of the financial year and the same was confirmed in appeal by the CIT(A).
33. We find that the Hon'ble Gujarat High Court in the case of CIT vs. B.M.S. Projects P. Ltd., (2014) 361 ITR 195 (Guj.), has held that "where payments were made to sub-contractors for the period from April 2004-February 2005 on which TDS has been paid on 24.05.2005, no disallowance of the expenditure claimed could be made u/s 40(a)(ia) of the Act as the payments were made by the assessee before the due date of filing of return of income u/s 139(1) of the Act, as the amendment made by Finance Act, 2010 with effect from 1st April 2010 was retrospective in operation." Therefore, we delete the disallowance of Rs.2,74,787/- and allow this ground of appeal of the assessee.
34. In the appeal of the Revenue, the sole ground of appeal taken by the Revenue reads as under:-
On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the penalty of Rs.9,28,617/- levied u/s 271(1)(c) of the Act for concealment of income by way of furnishing inaccurate particulars of income in respect of on account of closing stock and gross profit.
35. We have heard the rival submissions and perused the orders of the lower authorities and material available on record. The Assessing Officer levied penalty u/s 271(1)(c) of Rs.9,28,617/- in respect of addition of Rs.18,40,177/- made in assessment on account of undervaluation of closing stock and in respect of addition of Rs.9,03,387/- made on account of low Goss Profit.
ITA Nos 386/Ahd/2009 & 2800/Ahd/2010
- Ashokkumar H. Kothari
- AY 2005-06
- 13 -
36. On appeal, the CIT(A) deleted the above levy of penalty by observing as under:-
"I have carefully considered both the position. I have also gone through the various documentary evidences furnished by the AR as also the assessment order and appellate order. A combined reading of the assessment order and the penalty order shows that the penalty was levied by the AO on the estimation of GP which prima facie did not represent any concealment of income or the furnishing of any inaccurate particulars. Regarding penalty on undervaluation of closing stock, the assessee had failed to produce so called buyer in person before AO for verification. On the other hand he had filed all the other evidence like name and address of the party, copy of sale bills as well as confirmation of the buyer. The AO on his side may called for details by issuing notice u/s 133(6) or may issue summons to verify the same which he failed to do so. Applying my mind to the issue I am of the opinion that mere failure on the part of the assessee regarding unable to produce buyer for verification before AO cannot be considered as concealment.
Further, in the light of Hon'ble Supreme Court's recent judgment in case of Reliance Petro Products Pvt. Ltd. (322 ITR
158) which clearly indicates that penalty can be levied by the AO only once he prove that the assessee has concealed the particulars of income or has furnished inaccurate particulars of income at the time of filling the return of income or any submissions thereafter (whether willful or otherwise). Mere making of the claim, which is not sustainable in law, by itself, will not amount to furnish inaccurate particulars regarding income of the assessee. Such claim made in the return of income cannot amount to furnish of inaccurate particulars.
Unless there is finding that any details supplied by the assessee in its return of income were found to be incorrect or erroneous or false, there is no question of levying penalty u/s 271 (1) (c). If the contentions of the revenue are accepted, then in case of every return where claim is not accepted by the AO for any reason, the assessee will invite penalty u/s 271(l)(c). That is clearly not intendment of the Legislature.
I have examined the various correspondences of the AR with the AO. These correspondences clearly show that the Assessee had furnished all the books of account, along with supporting bills/vouchers, the names and addresses of the parties from ITA Nos 386/Ahd/2009 & 2800/Ahd/2010
- Ashokkumar H. Kothari
- AY 2005-06
- 14 -
whom purchase were made and a detailed break-up of the expenses, the AR had submitted the reasons for decrease in GP along with copies of the bills and books of accounts. All these correspondence clearly show that the records and details which are essential for the AO to ascertain the correctness of the claimed of the Assessee, were all available with the AO. Therefore, the non-furnishing of certain details or unable to present the buyer in person could not be ground for levying penalty.
Thus fact of the matter that the claim of the assessee has been disregarded with the main reason of non production of buyer before AO. Similarly the details available on record have been chosen to be ignored while ascertaining the genuineness of the claim of the assessee. For a moment let us assume that the assessee was not ABLE TO produce the so called buyer and seller. Will that alone render the claim of the assessee liable to rejection is the point that requires consideration. Can the available material on record lend any credence to the appellant's claim is to be considered. My firm view that the absence of persons for whatever reason cannot directly result in concealment on the part of the Assessee or furnishing inaccurate particular of income.
Hence I delete the penalty of Rs.9,28,617. In the result this appeal is allowed."
37. The Departmental Representative relied upon the order of the Assessing Officer and contended that the CIT(A) was not justified in deleting the penalty u/s 271(1)(c) of the Act.
38. On the other hand, the Authorized Representative of the assessee supported the order of the CIT(A).
39. We find that no specific error in the finding of the CIT(A) could be pointed out by the Revenue. In the instant case, the addition was made because of the inability of the assessee to substantiate its claim by producing the seller and purchaser. We find that no positive material could be brought on record by the Revenue to show that any particular of income furnished in the Return was incorrect or any ITA Nos 386/Ahd/2009 & 2800/Ahd/2010
- Ashokkumar H. Kothari
- AY 2005-06
- 15 -
income actually earned was undisclosed. In the above facts, we find no good reason to interfere with the conclusion as arrived at by the CIT(A). Therefore, the appeal of the Revenue is dismissed.
40. In the result, appeal of the assessee is partly allowed, whereas the appeal of the Revenue is dismissed.
Order pronounced in the Court on Friday, the 16th of January, 2015 at Ahmedabad.
Sd/- Sd/-
(G.C. GUPTA) ( N.S. SAINI)
VICE PRESIDENT ACCOUNTANT MEMBER
Ahmedabad; Dated 16/01/2015
*Biju T, PS
आदे श कȧ ूितिलǒप अमेǒषत/Copy
षत of the Order forwarded to :
1. अपीलाथȸ / The Appellant
2. ू×यथȸ / The Respondent.
3. संबंिधत आयकर आयुƠ / Concerned CIT
4. आयकर आयुƠ(अपील) / The CIT(A)- IV, Surat
5. ǒवभागीय ूितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad
6. गाड[ फाईल / Guard file.
आदे शानुसार/ BY ORDER, //TRUE COPY// उप/सहायक पंजीकार (Dy./Asstt.Registrar) उप/ आयकर अपीलीय अिधकरण, अिधकरण, अहमदाबाद / ITAT, Ahmedabad