AADI REAL ESTATE DEVELOPERS PRIVATE LIMITED ,AHMEDABAD V. THE ITO, WARD-1(1)(1), AHMEDABAD

ITA 928/AHD/2023

AI Insights

The case involves Aadi Real Estate Developers Private Limited, which appealed against the order of the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi. The appeal was related to the reassessment for the Assessment Year 2012-13, where the assessee's income was assessed significantly higher due to alleged undisclosed income from dummy companies and unexplained investments in immovable property. The Tribunal found that the delay in filing the appeal was due to the negligence of the assessee's accountant and tax advisor, not the assessee itself. Consequently, the Tribunal decided to condone the delay and remand the case for a fresh assessment.

• Counselvise Citation: [2024] 140 COUNSELVISE.COM (IT) 472282 (ITAT-AHMEDABAD)
• Duration Of Justice: 11 month(s) 3 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 25-10-2024
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: B
• Next Hearing Date: 16-10-2024
• Assessment Year: 2012-2013
• Appeal Filed On: 21-11-2023
• Other Referred Cases: N. Balakrishnan Vs. M. Krishnamurthy, Esha Bhattacharjee Vs. Raghunathpur Nafar Academy, Rarefield Engineers (Pvt.) Ltd.
• Laws Referred To: Income-tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: V. NANDAKUMAR
• Assessee Lawyers: DEEPAK SHAH
• Keywords: Condonation of delay; Set aside; Opportunity of being heard; Reassessment proceedings; Unexplained investment; Period of limitation; Principle of natural justice
• Section: 250; 68

Judgement Text

" आयकर अपीलीय अिधकरण, अहमदाबाद \u0011ायपीठ ‘B’ अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE MRS. ANNAPURNA GUPTA, ACCOUNTANT MEMBER AND SHRI T.R. SENTHIL KUMAR, JUDICIAL MEMBER ITA No. 928/Ahd/2023 िनधा\u0005रण वष\u0005/Assessment Year: 2012-13 Aadi Real Estate Developers Private Limited, 402, Sheel Complex, Mayur Colony, Mithakhali, Navrangpura, Ahmedabad-380009 PAN : AAJCA 1796 R Vs. Income Tax Officer, Ward 1(1)(1), Ahmedabad अपीलाथ\u0007 अपीलाथ\u0007 अपीलाथ\u0007 अपीलाथ\u0007/ (Appellant) \b\t \b\t \b\t \b\t यथ\u0007 यथ\u0007 यथ\u0007 यथ\u0007/ (Respondent) Assessee by : Shri Deepak Shah, AR Revenue by : Shri V. Nandakumar, CIT-DR सुनवाई क\u0002 तारीख/Date of Hearing : 16.10.2024 घोषणा क\u0002 तारीख /Date of Pronouncement: 25.10.2024 आदेश आदेश आदेश आदेश/O R D E R PER ANNAPURNA GUPTA, ACCOUNTANT MEMBER: Present appeal has been filed by the assessee against order of the learned Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as \"CIT(A)\" for short] dated 25.05.2022 passed under Section 250 of the Income-tax Act, 1961 [hereinafter referred to as \"the Act\" for short], for the Assessment Year (AY) 2012-13. 2. The brief facts relating to the case are that the assessee is a Private Limited Company and had filed ‘Nil’ return of income for the impugned assessment year, i.e. AY 2012-13. Subsequently, on information received from DDIT (Inv.), Unit-1 (3), Ahmedabad, by the Assessing Officer that the assessee was a beneficiary of accommodation entry taken through dummy companies run and controlled by one Jignesh Shah, which information was revealed consequent to search action conducted on Jignesh Shah, the case of the 2 ITA No. 928/Ahd/2023 Aadi Real Estate Developers Pvt Ltd Vs. ITO AY : 2012-13 assessee was reopened. The Assessing Officer was of the belief that the assessee had taken accommodation entry to the tune of Rs.4,73,20,000/- from dummy concerns managed and controlled by Jignesh Shah. The Assessing Officer was also in possession of information from the AIR that the assessee had purchased immovable property for a consideration of Rs.6.75 crores; therefore, during the reassessment proceedings, the assessee was asked to prove the genuineness of the transactions entered into by it with the alleged dummy companies of Shri Jignesh Shah amounting to Rs.4,73,20,000/- and was also asked to explain the source of investment in the property purchased amounting to Rs.6.75 crores during the year. The proceedings were largely unrepresented by the assessee, except for one reply filed at the fag end of the proceedings on 30.11.2019. The order was subsequently passed on 04.12.2019. The assessee submitted the transactions with the alleged dummy companies of Shri Jignesh Shah to be genuine. The said companies were identified as Amar Textile, Kavita Enterprise, Riddi Siddhi Marketing. As for the purchase of immovable properties amounting to Rs.6.75 crores, the source of same was attributed to money borrowed from the directors, shareholders and investors of the company being (i) Bhavik Parikh Rs.2,88,65,000/-, (ii) Amar Remedies Ltd Rs.3,00,00,000/-, (iii) Chinubhai Virchan Rs.75,00,000/- and (iv) Taraben Chinubhai Rs.75,00,000/- - totaling of all Rs.7,38,65,000/-. 3. The Assessing Officer considered the reply of the assessee, but treated it as unacceptable noting that the assessee had only submitted the ledger account of the transactions carried out with the alleged dummy companies of Shri Jignesh Shah, without any evidences being filed proving the genuineness of the same. He, therefore, held that the assessee company had failed to prove the basic credentials to satisfy the provisions of Section 68 of the Act. He accordingly held the amount received from the alleged dummy concerns of 3 ITA No. 928/Ahd/2023 Aadi Real Estate Developers Pvt Ltd Vs. ITO AY : 2012-13 Shri Jignesh Shah amounting to Rs.4,73,20,000/- as undisclosed income of the assessee. 4. Further, with respect to the source of purchase of immovable property of Rs.6,75,00,000/-, the Assessing Officer again noted that no evidence proving the genuineness of the loans from which the purchase was sourced, was filed by the assessee. The entire amount of loans taken by the assessee accordingly of Rs.7,38,65,000/-, therefore, was treated as undisclosed credit and added to the income of the assessee in terms of Section 68 of the Act. 5. Thus, as against ‘Nil” income returned by the assessee/loss returned of (-) Rs.28,260/-, additions of Rs.4,73,20,000/- and Rs.7,38,65,000/- were made to the income of the assessee resulting in the income being assessed to the tune of Rs.12,11,56,740/-. 6. The matter was carried in appeal before the ld. CIT(A) who in turn confirmed the addition made by the Assessing Officer. 7. Aggrieved by the order of the ld. CIT(A), the assessee has come up in appeal before us raising following grounds:- “1. Order u/s 147/148 is bad in Law. 2. Additions of Rs. 4,73,20,000 for unexplained transactions 3. Additions of Rs. 7,38,65,000 for unexplained Investments 4. Additions against natural justice and Arbitrary and highly excessive 5. Initiation of penalty u/s 272(c) is erroneously done.” 8. At the outset itself, it was noted that the present appeal was delayed for filing by 485 days. The ld. Counsel for the assessee filed an affidavit before us of the Director of the assessee-company Shri Vishal Mukeshkumar Shah outlining therein the reason leading to the delay in the filing of the present 4 ITA No. 928/Ahd/2023 Aadi Real Estate Developers Pvt Ltd Vs. ITO AY : 2012-13 appeal before us by 485 days. The contents of the same are reproduced hereunder:- “Subject Application for Condonation of Delay in filing the aforesaid appeal before the ITAT, I,Vishal Mukeshkumar Shah, director of the applicant, do solemnly affirm on oath that whatever is stated in the below paras is true to the best of my information: 1. That the impugned order of the CIT(A) was passed on 25-05-2022 and was received via email on 26-05-2022 which was operated by our accountant. However, he left the job without informing the management regarding receipt of the said order. We came to know regarding the receipt of such order only on 15-07-2022 and the same was sent to our tax advisor Niranjan Jain & Co. for filing further appeal before the ITAT. Mr. Niranjan Jain is also tax advisor to other member of our group. Therefore, we were under bonafide impression that he will look into the matter and do the needful. Upon verification, it was found that he too did not file the appeal and upon confrontation, he returned the file back to us on or around 06-11-2023. 3. Thereafter, we approached another Chartered Accountant namely C.N. Shah for filing the present appeal who filed it on 21-11-2023. It is because of the above bonafide reasons that a delay of 485 days has occurred in filing the present appeal. 4. The applicant submits that the delay caused is not because of any malafide or negligence on the part of the applicant but because of the inaction/inadvertence of the accountant and tax advisor as mentioned above. The applicant has a good case on merits of the matter and hence the appeal be decided on merits rather than on technical grounds. Therefore, it is kindly requested that the delay of 485 in filing the present appeal be condoned.” 9. Referring to the above, the ld. Counsel for the assessee contended before us that there was no laxity attributable to the assessee for the delay. That, in fact, the delay occurred on account of the lapses on the part of the accountant and the professional engaged by the assessee for filing of appeal. He pointed out that the accountant, who was handling all financial matters of the assessee-company, left the job without informing the management 5 ITA No. 928/Ahd/2023 Aadi Real Estate Developers Pvt Ltd Vs. ITO AY : 2012-13 regarding the receipt of the order which was received via email on 26.05.2022. That, when the management came to know of the order two months later on 15.07.2022, they immediately sent it to their tax advisor Niranjan Jain & Co. for filing appeal before the ITAT. It was also pointed out that Mr. Niranjan Jain was also a tax advisor to other members of assessee-group. That, therefore, the management of the assessee-company was under the bonafide belief that he would look into the matter and do the needful, but the tax professional returned the file back to them after more than a year on 06.11.2023. That, thereafter, they approached another Chartered Accountant for filing the present appeal who accordingly filed it immediately thereafter on 21.11.2023 resulting in a delay of 485 days in filing the present appeal. 10. Ld. Counsel for the assessee contended that the delay needed to be condoned since the delay could not be attributed to the assessee, but to the negligence on the part of the professional engaged by it for the said purpose. That the assessee should not be made to suffer for the negligent act of the professionals which he had engaged for carrying out the necessary professional work of filing appeal before the ITAT. That, the assessee bonafidely had believed the professional to carry out their duties once the necessary documents were handed over to them, to take remedial action by filing appeal. That, assessee’s diligence in pursuing the matter by filing appeal to the ITAT is established by the fact that it promptly engaged professionals to take necessary action of filing appeal to the ITAT against order passed by Ld.CIT(A). The negligence of the professional, therefore, cannot be treated as negligence of the assessee and the assessee should not be punished for the negligence of the professional engaged by it. The ld. Counsel for the assessee further contended that, considering the fact that the addition made in its case is many folds the income returned by it i.e. while the assessee 6 ITA No. 928/Ahd/2023 Aadi Real Estate Developers Pvt Ltd Vs. ITO AY : 2012-13 had returned ‘Nil” income/loss return, the addition was to the tune of approximately Rs.12 crores, the principles of public policy and equity demanded advancing substantial justice, and therefore the assessee’s appeal should not be dismissed at the threshold itself for mere technicalities but be admitted for hearing. 11. Ld. DR, on the other hand, countered by saying that the assessee has not filed any evidence to prove the negligence on the part of its professional, and therefore, the explanation of the assessee for the delay cannot be accepted, and therefore he pleaded that the application for condonation of delay in filing the appeal needs to be rejected and the appeal of the assessee be dismissed as non-maintainable. 12. To this, the ld. Counsel for the assessee countered by stating that all facts leading to the delay have been stated on oath by the Director of the assessee-company. That, no professional would come forward and admit his negligence in any manner. Therefore, the genuineness of the assessee’s explanation cannot be doubted for non-furnishing of any evidence which is virtually impossible for the assessee to produce. 13. We have heard the contentions of both the parties and we are of the view that it is a fit case for condoning the delay of 485 days in filing of the appeal before us. Undoubtedly, as per the contentions of the ld. Counsel for the assessee, duly supported by the affidavit of the Director of the assessee- company, the delay is attributable to the negligence on the part of the professional engaged by it for filing of appeal. Though the ld. DR has contended that no evidence of the negligence of the professional has been filed by the assessee, we agree with the ld. Counsel for the assessee that the fact that the Director of the assessee-company has stated so on oath suffices. 7 ITA No. 928/Ahd/2023 Aadi Real Estate Developers Pvt Ltd Vs. ITO AY : 2012-13 Therefore, the argument of the ld. DR that since the reasons for delay are not duly evidenced needs to be rejected. We agree with the ld. Counsel for the assessee that no assessee should be punished for the negligence of the professional engaged by it – more particularly in the facts of the present case where the addition made is to the tune of Rs.12 crores (approx.), we find that grave injustice would be meted if his appeal is dismissed without hearing. 14. The Hon’ble Madras High Court in the case of Rarefield Engineers (Pvt.) Ltd., [2023] 156 taxmann.com 643 (Madras) has held that the question of limitation is not based on technical consideration, but is on the principles of public policy and equity, and the substantial justice is paramount consideration and pivotal for deciding the issue of condonation of delay. The Hon’ble High Court in the said judgment referred to the decision of the Hon’ble Apex Court in the case of N. Balakrishnan Vs. M. Krishnamurthy, [1998(7) SCC 123], wherein, the Hon’ble Supreme Court had observed that limitation fixed for approaching the Court is not because on the expiry of such time a bad cause would transform into a good cause. That, rules of limitation are not meant to destroy the rights of parties, but only to see that parties do not resort to dilatory tactics, but seek their remedy promptly. The law of limitation fixes a lifespan for such legal remedy for the redress of the legal injury so suffered. The condonation of delay is a matter of discretion of the Court and Section 5 of the Limitation Act does not say that such discretion can be exercised only if the delay is within a certain limit. Length of delay is no matter, acceptability of the explanation is the only criterion. When there is reasonable ground to think that the delay was occasioned, the same should be condoned. There is no presumption that delay in approaching the court is always deliberate. The words 'sufficient cause\" under Section 5 of the Limitation Act should receive a liberal construction so as to advance substantial justice. 8 ITA No. 928/Ahd/2023 Aadi Real Estate Developers Pvt Ltd Vs. ITO AY : 2012-13 15. The Hon’ble Madras High Court also took note of the decision of the Hon’ble Apex Court in the case of Esha Bhattacharjee Vs. Raghunathpur Nafar Academy [2013] (12) SCC 649, wherein the Hon'ble Supreme Court has culled out the principles applicable to an application for condonation of delay, which is reiterated of what was stated by the Hon’ble Apex Court in the case of N. Balakrishnan Vs. M. Krishnamurthy (supra). Taking note of the above, and also of the fact that no litigant ordinarily stands to benefit by instituting a proceeding beyond time, the Hon’ble Court held that the question of limitation is to be based on the principles of public policy and equity, and the substantial justice is paramount consideration and pivotal. The relevant findings of the Hon’ble Court at paragraph Nos. 6 to 8 of its order are as under:- “6. The dispute raised by the appellant is with respect to addition of Rs.23,40,000/- towards unsecured loans in terms of section 68 of the Act. It is an admitted fact that the appellant has not furnished the required documentary evidence to substantiate their claim before the assessing authority as well as the appellate authority. The appellant preferred the further appeal before the Tribunal, with a delay of 380 days i.e., beyond the period of limitation. By the order dated 19.10.2022, the Tribunal rejected the condonation of delay petition as the reasons offered by the appellant were not bona fide and consequently, dismissed the appeal as not maintainable. 7. At this juncture, it is pertinent to refer to the following decisions, in regard to the condonation of delay: (i)N. Balakrishnan v. M. Krishnamurthy, [1998(7) SCC 123], wherein, it was observed by the Hon'ble Supreme Court as follows: “The primary function of a court is to adjudicate the dispute between the parties and to advance substantial justice. The time-limit fixed for approaching the Court in different situations is not because on the expiry of such time a bad cause would transform into a good cause. Rules of limitation are not meant to destroy the rights of parties. They are meant to see that parties do not resort to dilatory tactics, but seek their remedy promptly. The object of providing a legal remedy is to repair the damage caused by reason of legal injury. The law of limitation fixes a lifespan for such legal remedy for the redress of the legal injury 9 ITA No. 928/Ahd/2023 Aadi Real Estate Developers Pvt Ltd Vs. ITO AY : 2012-13 so suffered. The law of limitation is thus founded on public policy. It is enshrined in the maxim interest reipublicae up sit finis litium (it is for the general welfare that a period be put to litigation). Rules of limitation are not meant to destroy the rights of the parties. They are meant to see that parties do not meant to dilatory tactics but seek their remedy promptly. The idea is that every legal remedy must be kept alive for a legislatively fixed period of time. Condonation of delay is a matter of discretion of the Court. Section 5 of the Limitation Act does not say that such discretion can be exercised only if the delay is within a certain limit. Length of delay is no matter, acceptability of the explanation is the only criterion. Sometimes delay of the shortest range may be uncondonable due to a want of acceptable explanation whereas in certain other case, delay of a very long range can be condoned as the explanation thereof is satisfactory. In every case of delay, there can be some lapse on the part of the litigant concerned. That alone is not enough to turn down his plea and to shut the door against him. If the explanation does not smack of mala fides or it is not put forth as part of a dilatory strategy, the court must show utmost consideration to the suitor. But when there is reasonable ground to think that the delay was occasioned by the party deliberately to gain time, then the court should lean against acceptance of the explanation. A court knows that refusal to condone delay would result in foreclosing a suitor from putting forth his cause. There is no presumption that delay in approaching the court is always deliberate. The words 'sufficient cause\" under Section 5 of the Limitation Act should receive a liberal construction so as to advance substantial justice.” (ii)In Esha Bhattacharjee v. Raghunathpur Nafar Academy [2013 (12) SCC 649], the Hon'ble Supreme Court has culled out the principles applicable to an application for condonation of delay and the same are profitably reproduced hereunder: “i) There should be a liberal, pragmatic, justice- oriented, non- pedantic approach while dealing with an application for condonation of delay, for the courts are not supposed to legalise injustice but are obliged to remove injustice. ii) The terms “sufficient cause” should be understood in their proper spirit, philosophy and purpose regard being had to the fact that these terms are basically elastic and are to be applied in proper perspective to the obtaining fact- situation. 10 ITA No. 928/Ahd/2023 Aadi Real Estate Developers Pvt Ltd Vs. ITO AY : 2012-13 iii) Substantial justice being paramount and pivotal the technical considerations should not be given undue and uncalled for emphasis. iv) No presumption can be attached to deliberate causation of delay but, gross negligence on the part of the counsel or litigant is to be taken note of. v) Lack of bona fides imputable to a party seeking condonation of delay is a significant and relevant fact. vi) It is to be kept in mind that adherence to strict proof should not affect public justice and cause public mischief because the courts are required to be vigilant so that in the ultimate eventuate there is no real failure of justice. vii) The concept of liberal approach has to encapsule the conception of reasonableness and it cannot be allowed a totally unfettered free play. viii) There is a distinction between inordinate delay and a delay of short duration or few days, for to the former doctrine of prejudice is attracted whereas to the latter it may not be attracted. That apart, the first one warrants strict approach whereas the second calls for a liberal delineation. ix) The conduct, behaviour and attitude of a party relating to its inaction or negligence are relevant factors to be taken into consideration. It is so as the fundamental principle is that the courts are required to weigh the scale of balance of justice in respect of both parties and the said principle cannot be given a total go by in the name of liberal approach. x) If the explanation offered is concocted or the grounds urged in the application are fanciful, the courts should be vigilant not to expose the other side unnecessarily to face such a litigation. xi) It is to be borne in mind that no one gets away with fraud, misrepresentation or interpolation by taking recourse to the technicalities of law of limitation. xii) The entire gamut of facts are to be carefully scrutinized and the approach should be based on the paradigm of judicial discretion which is founded on objective reasoning and not on individual perception. xiii) The State or a public body or an entity representing a collective cause should be given some acceptable latitude.” 11 ITA No. 928/Ahd/2023 Aadi Real Estate Developers Pvt Ltd Vs. ITO AY : 2012-13 (iii)It is also useful to extract paragraph Nos.14 and 17 of the judgment of this court in Tamilnadu Mercantile Bank Ltd., Vs. Appellate Authority, [(1990) 1 LLN 457], which read as under: “14.We are unable to agree with the reasoning of the learned Judge that no litigant ordinarily stands to benefit by instituting a proceeding beyond time. It is common knowledge that by delaying a matter, evidence relating to the matter in dispute may disappear and very often the party concerned may think that preserving the relevant records would be unnecessary in view of the fact that there was no further proceeding. If a litigant chooses to approach the Court long after the time prescribed under the relevant provisions of the law, he cannot say that no prejudice would be caused to the other side by the delay being condoned. The other side would have in all probability destroyed the records thinking that the records would not be relevant as there was no further proceeding in the matter. Hence to view a matter of condonation of delay with a presupposition that no prejudice will be caused by the condonation of delay to the respondent in that application will be fallacious. In our view, each case has to be decided on the facts and circumstances of the case. Length of the delay is a relevant matter to be taken into account while considering whether the delay should be condoned or not. It is not open to any litigant to fix his own period of limitation for instituting proceedings for which law has prescribed period of limitation.” “17.... Once it is held that a party has lost his right to have the matter considered on merits because of his own inaction for a long time, it cannot be presumed to be non- deliberate delay, and in such circumstances of the case, he cannot be heard to plead that substantial justice deserved to be preferred as against technical considerations. We are of the view that the question of limitation is not merely a technical consideration. Rules of limitation are based on principles of sound public policy and principles of equity. It is a litigant liable to have a Damocles' sword hanging over his head indefinitely for a period to be determined at the whims and fancies of the opponent.” Thus, the legal position discernible from the aforesaid decisions is that the question of limitation is not based on technical consideration, but is on the principles of public policy and equity; and the substantial justice is paramount consideration and pivotal. 8.Therefore, considering the facts and circumstances of the case and taking note of the submissions made by the learned counsel on either side, the order dated 19.10.2022 passed by the Income Tax Appellate Tribunal, Chennai, is set aside and the delay in filing the appeal is condoned. Consequently, the matter is remanded to the Tribunal, which shall entertain the appeal and decide the same, 12 ITA No. 928/Ahd/2023 Aadi Real Estate Developers Pvt Ltd Vs. ITO AY : 2012-13 on merits and in accordance with law. The appellant shall place all the materials for consideration before the Tribunal within a period of four weeks from the date of receipt of a copy of this judgment, failing which, the Tribunal shall decide the matter on the basis of available materials, without granting further adjournments.” 16. We find that the ratio laid down by the Hon’ble High Court in the case of Rarefield Engineers (Pvt.) Ltd. (supra)squarely applies in the facts of the present case. The assessee has adduced sufficient cause before us for the delay. The assessee has suffered with many fold addition to its income having returned loss while the income assessed is approximately Rs.12 crores. We have also noted from the order of the ld. CIT(A) that, though the assessee had filed evidences in support of the grounds raised before it, the ld. CIT(A) summarily rejected them as not sufficient to prove the case of the assessee without affording any further opportunity to the assessee. Therefore, considered from all perspectives as noted above, for advancing substantial justice to the assessee, the delay, we hold, is condoned and the appeal of the assessee is admitted for hearing. 17. Having held so, we find that the assessee has not been given sufficient opportunity of being heard even by the ld. CIT(A). Before us, ld. Counsel for the assessee has submitted documents which apparently prove the genuineness of all the amounts received by it from the alleged dummy companies of Shri Jignesh Shah, as also the loans taken by it for financing the purchase of the immovable property during the year; on account of both of which addition was made to the income of the assessee. Ld. Counsel for the assessee pleaded that it is in possession of all evidences to prove the genuineness of all of the above, and therefore requested that an opportunity be given to the assessee to prove its case. Taking note of the same, in the interest of justice, we restore the issue back to the Assessing Officer for de novo 13 ITA No. 928/Ahd/2023 Aadi Real Estate Developers Pvt Ltd Vs. ITO AY : 2012-13 consideration of all the issues raised in the appeal with the direction to the Assessing Officer to give due opportunity of hearing to the assessee. The assessee is free to furnish all evidences and explanation that it seeks to place reliance in support of its case. Accordingly, the appeal of the assessee is allowed for statistical purposes. 18. In effect, the appeal of the assessee is allowed for statistical purposes. Order pronounced in the open Court on 25/10/2024 at Ahmedabad. Sd/- Sd/- (T.R. SENTHIL KUMAR) JUDICIAL MEMBER (ANNAPURNA GUPTA) ACCOUNTANT MEMBER Ahmedabad; Dated 25/10/2024 **bt आदेश आदेश आदेश आदेश क\u0002 क\u0002 क\u0002 क\u0002 \u0003ितिलिप \u0003ितिलिप \u0003ितिलिप \u0003ितिलिप अ\tेिषत अ\tेिषत अ\tेिषत अ\tेिषत/Copy of the Order forwarded to : 1. अपीलाथ\u000f अपीलाथ\u000f अपीलाथ\u000f अपीलाथ\u000f / The Appellant 2. \u0003\u0010यथ\u000f \u0003\u0010यथ\u000f \u0003\u0010यथ\u000f \u0003\u0010यथ\u000f / The Respondent. 3. संबंिधत संबंिधत संबंिधत संबंिधत आयकर आयकर आयकर आयकर आयु\u0014 आयु\u0014 आयु\u0014 आयु\u0014 / Concerned CIT 4. आयकर आयकर आयकर आयकर आयु\u0014 आयु\u0014 आयु\u0014 आयु\u0014 ) अपील अपील अपील अपील ( / The CIT(A)- 5. िवभागीय िवभागीय िवभागीय िवभागीय \u0003ितिनिध \u0003ितिनिध \u0003ितिनिध \u0003ितिनिध , आयकर आयकर आयकर आयकर अपीलीय अपीलीय अपीलीय अपीलीय अिधकरण अिधकरण अिधकरण अिधकरण , /DR,ITAT, Ahmedabad, 6. गाड\u0019 गाड\u0019 गाड\u0019 गाड\u0019 फाईल फाईल फाईल फाईल /Guard file. आदेशानुसार आदेशानुसार आदेशानुसार आदेशानुसार/ BY ORDER, TRUE COPY सहायक सहायक सहायक सहायक पंजीकार पंजीकार पंजीकार पंजीकार (Asstt. Registrar) आयकर आयकर आयकर आयकर अपीलीय अपीलीय अपीलीय अपीलीय अिधकरण अिधकरण अिधकरण अिधकरण ITAT, Ahmedabad 1. Date of dictation …………18/10.2024 1. Date on which the typed draft is placed before the Dictating Member :..… 21.10.2024… 2. Other Member……24.10.2024….………….. 3. Date on which the approved draft comes to the Sr.P.S./P.S…24.10.2024…… 4. Date on which the fair order is placed before the Dictating Member for pronouncement…25.10.2024… 5. Date on which the fair order comes back to the Sr.P.S./P.S……25.10.2024….……… 6. Date on which the file goes to the Bench Clerk……25.10.2024….…… 7. Date on which the file goes to the Head Clerk……. 8. The date on which the file goes to the Assistant Registrar for signature on the order………… 9. Date of Despatch of the Order……………… "