BAHRA FOUNDATION,MOHALI V. CIT(EXEMPTIONS), CHANDIGARH

ITA 556/CHANDI/2025

AI Insights

The case involves Bahra Foundation appealing against the decisions of the Commissioner of Income Tax (Exemptions), Chandigarh, which denied the Trust registration under section 12A(1)(ac)(iii) and approval under section 80G of the Income Tax Act, 1961. The Trust argued that its objectives and activities, including the distribution of educational materials, were genuine and aligned with charitable purposes. The CIT (E) had rejected the application on grounds that the Trust was merely an extension of an existing institution and did not independently carry out charitable activities benefiting the public at large. The Tribunal, after reviewing the objectives of the Trust and the evidence provided, concluded that the Trust's activities were indeed charitable and distinct, warranting the grant of registration and approval.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 845957 (ITAT-CHANDIGARH)
• Duration Of Justice: 11 month(s) 7 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 23-03-2026
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: Chandigarh
• Assessment Year: 2025-2026
• Appeal Filed On: 16-04-2025
• Other Referred Cases: DIT(E) Vs Meenakshi Amma Endowment Trust, CIT Vs IILM Foundation Academy, CIT Vs BKK Memorial Trust, CIT Vs Baba Kartar Singh Dukki Educational Trust
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: MANAV BANSAL
• Assessee Lawyers: HARRY RIKHY
• Keywords: Set aside; Opportunity of being heard; Gift; Charitable institution
• Section: 11; 12AA; 12A; 12; 80G

Judgement Text

"आयकर अपीलȣय अͬधकरण,चÖडीगढ़ Ûयायपीठ, चÖडीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH, ‘A’ CHANDIGARH BEFORE SHRI RAJPAL YADAV, VICE PRESIDENT AND SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER आयकर अपील सं./ ITA No.555 & 556/CHD/2025 Ǔनधा[रण वष[ / Assessment Year: 2025-26 Bahra Foundation, SCO 2475-2476, Sector 22-C, Chandigarh. Vs The CIT (Exemptions), Chandigarh. èथायी लेखा सं./PAN NO: AAFTB2555A अपीलाथȸ/Appellant Ĥ×यथȸ/Respondent Assessee by : Shri Harry Rikhy, Advocate Revenue by : Shri Manav Bansal, CIT, DR Date of Hearing : 26.02.2026 Date of Pronouncement : 23.03.2026 PHYSICAL HEARING O R D E R PER RAJPAL YADAV, VP The present two appeals are directed at the instance of the assessee against the separate orders of ld. Commissioner of Income Tax (Exemptions) [in short ‘the CIT (E)’] dated 24.03.2025 vide which registration u/s 12A(1)(ac)(iii) and approval u/s 80G(5) of the Income Tax Act, 1961 have been denied to the assessee. Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 2 2. The grievance of the assessee is that the ld. CIT (E) has erred in not granting registration u/s 12A(1)(ac)(iii) as well as approval u/s 80G of the Act to the assessee Trust. 3. The brief facts of the case are that assessee Trust came into existence on 20.07.2023. We will be referring its aims and objects in the later part of this order. It has applied for grant of provisional registration u/s 12A(1)(ac)(vi) of the Income Tax Act. This application was processed and an order in Form No. 10AC has been issued to the assessee on 21.03.2024 vide which a provisional registration was granted to the assessee from assessment year 2024-25 to assessment year 2026-27. This provisional registration was granted subject to the following conditions : a. Any income derived from property held under trust, wholly or in part for charitable or religious purposes, shall not be applied, other than for the objects of the trust or institution. b. The trust or institution shall not have income from profits and gains of business which is not incidental to the attainment of its objectives. c. Separate books of account shall be maintained by such trust or institution in respect of the business which is incidental to the attainment of its objectives. d. The trust or institution shall not apply any part of its income from the property held under a trust for private religious purposes, which does not enure for the benefit of the public. e. The trust or institution established for charitable purpose created or established after the commencement of this Act, shall not apply any part Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 3 of its income for the benefit of any particular religious community or caste. f. No non-genuine activity shall be earned out by the trust or institution. g. No such activity shall be carried on by the trust or institution which is not in accordance with all or any of the conditions subject to which it was registered. h. The trust or institution shall comply with the requirement of any other law, as referred to in item (B) of sub-clause (i) of clause (b) of sub- section (1) of section 12AB. i. The form for registration in form No 1 OA has been duly filled in by providing all the information or documents and no false or incorrect information or documents have been provided. j. The trust or institution shall apply for registration within 6 months of commencement of the, activities or at least 6 months prior to the expiry of period of provisional registration, whichever is earlier. k. Where the trustor institution has. adopted or undertaken modifications of the objects which do not conform to the conditions of registration, the trust or institution shall make an application in the prescribed form and manner to- the Principal Commissioner or Commissioner, for registration of the trust or institution, within a period of thirty days from the date of the said adoption or modification. Name and Designation of the Principal Commissioner Registration Granting Authority of Income Tax (Digitally signed) 4. A perusal of Scheme to grant registration, it would reveal that if a Trust or a Society came into existence after the new Scheme introduced by Finance Act, 2020 w.e.f. 01.04.2021, then such Institution would be required to obtain provisional registration as contemplated in Section 12A(1)(ac). After getting the provisional registration, the Trust has to apply for grant of a regular registration as per Section 12A(1)(ac) sub-clause (iii) which contemplates that Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 4 where the Trust or Institution has been provisionally registered u/s 12AB atleast six months prior to expiry of period of the provisional registration or within six months of commencement of its activities, whichever is earlier, in other words, on fulfilment of the above two incidents, assessee has to apply for grant of regular registration. The assessee has filed an application for grant of registration u/s 12A(1)(ac)(iii). Such application has been placed on record on page 17 of the Paper Book. It has been examined by the ld. CIT (E) and thereafter rejected by way of the impugned order. 5. The ld. counsel for the assessee while impugning the order of ld. CIT (E) submitted that ld. CIT (E) did not appreciate the aims and objects of the assessee society in right perspective, rather rejected the prayer of the assessee in a summary manner without assigning any specific reason. The finding of the ld. CIT (E) is that this society is an extension of existing Charitable Institution and therefore, it is not entitled for fresh registration. He drew our attention towards the Trustee Deed where Aims and Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 5 Objects are being provided. He also took us through the record and submitted that assessee Trust has purchased books which were distributed amongst the students. The Invoices of such purchase of books are available on page No. 46 to 49. On page No. 50 to 56, photo copies of the photos taken at the time of distribution of books are being placed on the record. Thereafter, ld. counsel for the assessee has placed on record a number of judgements, namely; i) DIT(E) Vs Meenakshi Amma Endowment Trust 329 CTR 594 ii) CIT Vs IILM Foundation Academy 290 CTR 583 (P&H HC) iii) CIT Vs BKK Memorial Trust 256 CTR 424 (P&H HC) iv) CIT Vs Baba Kartar Singh Dukki Educational Trust 221 Taxman 493 (P&H) 5.1 On the strength of these judgements, it was demonstrated by the ld. counsel for the assessee that satisfaction regarding the genuineness of activities of the Trust is to be seen at the stage for application of income which is yet to arrive. At this stage, only objectives are yet to be seen. Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 6 6. On the other hand, ld. CIT DR took us through paragraph No. 3.2 of the impugned order and submitted that assessee failed to demonstrate any activity carried out by it independently except distribution of books. Such books have been alleged to have been distributed at the premises of Rayat Bahra University. Therefore, ld.CIT (E) has rightly inferred that it is just an extension of existing Trust, namely Rayat Bahra University. 7. We have duly considered the rival contentions and gone through the record carefully. Section 12A(1)(ac) and Section 12AB(1) have direct bearing on the controversy, therefore, we deem it appropriate to take note of these two provisions, which read as under : 12A(1) The provision of Section 11 and 12 shall not apply in relation to the income of any Trust or Institution unless the following conditions are fulfilled : a) x x x aa) x x x ab) x x x ac) notwithstanding anything contained in clauses (a) to (ab), the person in receipt of the income has made an application in the prescribed form and manner to the Principal Commissioner or Commissioner, for registration of the trust or institution, —(i)where the trust or institution is registered under section 12A [as it stood immediately before its amendment by the Finance (No. 2) Act, 1996 (33 of 1996)] or under section 12AA [as it stood immediately before its amendment by the Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 7 Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (38 of 2020)], within three months from the first day of April, 2021; (ii)where the trust or institution is registered under section 12AB and the period of the said registration is due to expire, at least six months prior to expiry of the said period; (iii)where the trust or institution has been provisionally registered under section 12AB, at least six months prior to expiry of period of the provisional registration or within six months of commencement of its activities, whichever is earlier; (iv)where registration of the trust or institution has become inoperative due to the first proviso to sub-section (7) of section 11, at least six months prior to the commencement of the assessment year from which the said registration is sought to be made operative; (v)where the trust or institution has adopted or undertaken modifications of the objects which do not conform to the conditions of registration, within a period of thirty days from the date of the said adoption or modification; (vi)in any other case, where activities of the trust or institution have – (A) not commenced, at least one month prior to the commencement of the previous year relevant to the assessment year from which the said registration is sought; (B) commenced and no income or part thereof of the said trustor institution has been excluded from the total income on account of applicability of sub-clause (iv) or sub-clause (v) or sub-clause (vi) or sub-clause (via) of clause (23C) of Section 10, or Section 11 or Section 12, for any previous year ending on or before the date of such application, at any time after the commencement of such activities and such trust or institution is registered under Section 12AB;] x x x 12AB. [Procedure for fresh registration. Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 8 12AB.(1)The Principal Commissioner or Commissioner, on receipt of an application made under clause (ac) of sub-section (1) of section 12A, shall,— (a)where the application is made under sub-clause (i) of the said clause, pass an order in writing registering the trust or institution for a period of five years; (b)where the application is made under sub-clause (ii) or sub-clause (iii) or sub-clause (iv) or sub-clause (v) or item (B) of sub-clause (vi) of the said clause,- (i)call for such documents or information from the trust or institution or make such inquiries as he thinks necessary in order to satisfy himself about— (A)the genuineness of activities of the trust or institution; and (B)the compliance of such requirements of any other law for the time being in force by the trust or institution as are material for the purpose of achieving its objects; (ii)after satisfying himself about the objects of the trust or institution and the genuineness of its activities under item (A) and compliance of the requirements under item (B), of sub-clause (i),— (A)pass an order in writing registering the trust or institution for a period of five years; or (B)if he is not so satisfied, pass an order in writing- (I) in a case referred to in sub-clause (ii) or sub- clause (iii) or sub-clause (v) of clause (ac) of sub- section (1) of Section 12A rejecting such application and also cancelling its registration ; (II) in a case referred to in sub-clause (iv) or in item (B) of sub-clause (vi) of sub-section (1) of Section 12A, rejecting such application, after affording a reasonable opportunity of being heard; (c) where the application is made under item (A) of sub-clause (vi) of the said clause or the application is made under sub-clause (vi) of the said clause, as it stood immediately before its amendment vide the Finance Act, Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 9 2023, pass an order in writing provisionally registering the trust or institution for a period of three years from the assessment year from which the registration is sought, and send a copy of such order to the trust or institution. x x x 8. A perusal of the above clauses would indicate that by way of Finance Act, 2020 w.e.f. 01.04.2021, a new Scheme of Registration has been provided. It is evident from reading of Section 12A(1)(ac)(i) to (vi) of the Act that in order to claim benefit of Section 11 and 12, if any Trust or Institution is in receipt of income, it has to file an application in the prescribed form and manner to the Pr. Commissioner or Commissioner for registration of the Trust or Institution. Sub-clause (i) to (vi) of Section 12A(1)(ac) further provided different conditions on whose fulfilment, application is to be made. In the present case, application has been filed under Section 12A(1)(ac)(iii). It is pertinent to note that if a Trust was in existence prior to this new Scheme of registration, then it has to apply under sub- clause (1) within three months from the 1st day of April, 2021. If the Trust or Institution has been registered u/s 12AB, then atleast six months prior to the expiry of the said period. Registration u/s 12AB has been contemplated Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 10 under the new Scheme w.e.f. 01.04.2021. Similarly, a new Trust which has come into existence after 01.04.2021 and has applied for registration, which was granted provisionally registration, would require to apply for a regular registration which will be granted u/s 12A(1)(ac)(iii) for a period of five years. There is no dispute in the present case that assessee has applied for grant of regular registration u/s 12A(1)(ac)(iii) of the Act. 9. Section 12AB of the Act further provides the procedure for grant of the fresh registration. A perusal of the above provision would indicate that if an application is being made under sub-clause (1) of Section 12A(1)(ac), then ld. Pr. Commissioner or the Commissioner would pass an order in writing registering the Trust or Institution for a period of five years but where application is being made for grant of registration u/s 12A(1)(ac) sub-clause (ii) to (vi), then ld. Commissioner would call for such documents or information from the Trust or Institution or make such enquiry as he thinks necessary in order to satisfy himself about ; a) The genuineness of activities of the Trust or Institution, Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 11 b) The compliance of such requirements of any other law for the time being in force by the Trust or Institution as are material for the purpose of achieving its objectives. Thus, primary requirement would be to find out whether activities of the Trust are genuine and it has fulfilled the requirements of any other law for the time being in force. In other words, objectives of the assessee Trust should be genuine and that it is not engaged in any unlawful activities or failed to comply with other laws of the country. 9.1 On satisfaction of above conditions, ld. Pr. Commissioner or Commissioner would pass an order in writing registering the Trust or Institution for a period of five years and if not satisfied, then pass an order in writing rejecting such application. Before rejecting the application, a reasonable opportunity of being heard is to be provided. 9.2 In the present case, as observed earlier, application is being made u/s 12A(1)(ac) sub-clause (iii). The objectives of the Trust are being noticed by the ld. CIT (E) in the impugned order and we would also like to take note of these objectives from the Trust Deed as under : Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 12 ARTICLE 2: AIMS & OBJECTS OF THE TRUST 2. The objectives of the Trust shall be as follows:- 2.1 To establish, promote or to render aid to schools, colleges. Educational institutes. Technical institutions. Training Institutions, Training Institutions in one or all fields of Engineering, research, Medical & Hospitals. Dental. Nursing. Paramedical, Hospitals. Commerce, Arts, Skilled or any other system of education. 2.2 To do all charitable work Projects & Activities. 2-3 To promote education, vocational, technical & otherwise the diffusion or useful Knowledge medical relief, industrial training including all aspects or rural reconstruction and social welfare projects. 2.4 To engage in social welfare activities aimed at improving living conditions & general welfare of the poor and indigent persons of whatsoever occupation irrespective of race, caste ,community or creed 2.5 To promote deeper spiritual values in personal and Community life. 2.6 To diffuse such useful secular, social & religious knowledge. 2.7 To print & publish any newspaper, periodical, books & to utilize oilier mass Communication, radio, film & television for spread of knowledge. 2.8 To train to maintain the personnel to be in charge of different schools and institutions of the society or hospital or medical education. 2.9 To establish building for such objects, libraries, reading rooms equipped with the necessary supply of books, papers, periodicals, furniture & audio – visual aids. 2.10 To receive gifts or money or other properties, both moveable and immoveable or any requests for any one or more objects of the society. 2.11 To acquire by purchase, lease, grants or likewise from any person, company, society, Govt. Organizations moveable or immoveable properties of all descriptions deemed necessary or useful for any purpose of the society & administer the same. 2.12 To alienate by way of sale, lease, mortgage, pledge, exchange, gifts or otherwise the properties or funds of the society or any portions Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 13 thereof including giving subscriptions, bodies or persons as seen necessary or appropriate from time to lime. 2.13 To invest, lay asides, deposit in banks or post offices otherwise deal with money or funds with society not immediately required for the objects of the trust. 2.14 To borrow or raise funds from banks and other financial institutions or private parties for the purpose and objects of the trust with or without security in any manner as the trust may deem fit and repay the same. 2.15 To use all the incomes from students by way of fees , boarding & lodging and from other institutions, hospitals & from moveable or immoveable property or from the works of the trust or from staff of the schools or the institutions or from the rent from the building wherever derived from the pursuit of the objects of the trust as set forth in memorandum provided that no portion thereof be distributed among its trustees by way of profits or dividend or bonus except where payment or usage is allowed to employees, members, office bearers or any other person in lieu of service rendered or agreed to by the trust/institution setup by the trust. 2.16 To collect donations, membership fee & other contribution from the members & others. 2-17 To frame bye-laws, rules and regulations for the smooth working of the institutions and to alter or amend or reconstitute new rules & regulations as the trustees may deem fit from time to time. 2.18 To sell, mortgage, property of the trust for the upliftment of the trust. 2.19 To promote or to encourage social, cultural and intellectual activities amongst its trustees on the lines of the community centre. 2.20 To establish, maintain and conduct social and cultural centre and to afford members, privileges, advantages, conveniences and accommodation in the trust. 2.21 To provided free education to poor children. 2.22 To organize free medical camps. Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 14 2.23 In case the society is dissolved, its moveable & immoveable assets will be transferred to the organization having similar aims & objects. 2.24 To provide Scholarships or aid to deserving candidates and to disburse funds in this regards in any manner they choose including the payment of fees and other demands or charges demanded by educational institutions. This objective shall include the meeting of all expenses connected to the education of a deserving candidate who shall be chosen at the sole discretion of the Trustees But this is not binding because the objective is education with the purpose of enabling a deserving person to make a living and become a good citizen. The decision of the Trustees as regards the candidates and the amount of assistance or manner of assistance shall be final. In case funds are collected or donated by other individuals for this purpose special attempts will be made to communicate the use of funds donated or gifted by them. However, the decision of the Trustees will be final in all ways. 2.25 To provide and promote better health facilities for human beings. This would include the setting up of hospitals, nursing home's, old peoples care facilities and homes, laboratories and the setting up of medical, dental and nursing colleges. The Trustees shall have discretion to expand their activity as the circumstances demand. 2.26 To accept, receive subscriptions, donations, grants and gifts from the Central or State Government, any individual, firms and corporate etc. promote the activities of the trust. 2.27 To render medical help and meet the surgical expenses of operations of sick persons who are unable to meet expenses themselves. Decision as to deserving 'persons and manner as well as quantum of help and assistance shall be at the discretion of the Trustees and their decision shall be final. 2.28 To grant relief on the occasion of earthquakes, floods, tempest and other occasions due to calamities of similar nature, and/ or to give donations to other institutions doing such relief work. 2.29 To purchase, take on lease, hire or otherwise acquire any movable or immovable properly, rights or privileges necessary or convenient for the purpose of carrying out the objects of the Trust. To sell, mortgage, exchange, dispose off or otherwise deal with all or any part of the property or funds of the trust. Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 15 2.30 To engage in and promote any other object of general public utility and service for the good of society and works of public charity. 10. Let us evaluate the finding of ld. CIT (E) apprising herself with the above objectives. A perusal of the impugned order would indicate that ld. CIT (E) has not specifically dealt with any of the objectives. Though her order is running into 13 pages but maximum part contains reproduction of Show Cause Notice or Trust Deed. The finding of ld. CIT (E) starts from paragraph No.3.2, which reads as under : “3.2 As per the reply furnished by the applicant, it is observed that the applicant is associated with individuals who are already operating Rayat Bahra group of educational institutions that has been granted tax exemption. The formation of new entity raises concern about intent of creating separate entity. Further the applicant claimed to have performed charitable activity in the form of distribution of books to the underprivileged students. It is seen that the said bill of purchase of books is delivered at the Central Library of Rayat Bahra University, so it is difficult to verify that they were distributed to underprivileged students. More so because the books relate to university curriculum. The claimed charitable activities primarily support the students enrolled in Rayat Bahra group of Institutions. As per provisions the objective of 12AB registration is to facilitate tax exemptions to entities engaged in charitable activities benefitting the public at large which is not revealed in the instant case. Further, the expenditure incurred by the applicant towards charitable activity is also not reflected in the submitted -bank statement which means that claimed charitable activity performed by the applicant is exclusively in cash which is contrary to the requirement of Income Tax Act. On review of the bank statement, it is seen that-most of the fund is diverted to already established institution which is under control of Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 16 individuals associated with the applicant. For example, there are multiple instances of consideration received by the applicant from Rayat Bahra Group of Institutions on 29.11.2023, 21.12.2023, 6.01.2024 and 12.01.2024 and later on diverted to one of his own entities i.e on 05.03.2024 to Nirmal Singh Rayat, on 19.03.2024 to Rayat Bahra Dental CO and on 19.03.2024 & 29.03.2024 to Bahra University. The relevant extract of the Bank statement is reproduced as under:- x x x The formation of new entity appears to be an extension of existing institution rather than serving as a distinct charitable purpose benefiting the public at large. The suspicious transactions suggest that new entity may be used as mechanism for ta; avoidance rather than carrying out independent genuine charitable activities which raises concern over the financial integrity of institution. 4. In view of the above discussions, it is evident that the evidences submitted by the applicant are not sufficient and justifiable and are found to be unsatisfactory in respect of genuineness of the activities as per the objects mentioned in the Trust Deed. Accordingly, the application filed by the applicant for registration u/s 12A(1)(ac)(iii) of the Act is hereby rejected, which also supersede any registration granted u/s 12AB of the Act by any authority at any earlier time.” 11. The contention of the assessee is that ld. CIT(E) was required to appreciate objectives of the Trust, whether they are genuine and charitable. The ld. CIT(E) has nowhere pointed out that assessee failed to fulfil other laws. It is the initial year of the Society and it has distributed the books in order to fulfil some of the objectives. It is pertinent to note that in order to distribute the books, assessee has to identify students to whom such books could be distributed. Therefore, it has identified Rayat Bahra University which is also engaged in imparting education, Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 17 one of the charitable objectives contemplated in Section 2(15) of the Income Tax Act. We fail to appreciate as to how ld. CIT(E) has inferred that assessee will not carry out its objectives in future and it is mere extension of a similarly situated Trust. Such a finding is misplaced without support of any material. It is equivalent to denial of existence of a Trust which has been created for imparting education and fulfilment of other objectives. If a Trust or Institution has been created for imparting education, then this activity will fall within the first limb of Section 2(15) and would be per-se charitable. The ld. CIT(E) ought to have examined as to how its activities will not be genuine which has not been done. Accordingly, we set aside the impugned order and direct the ld. CIT(E) to grant registration to the assessee u/s 12A(1)(ac)(iii) of the Act for the period contemplated in the Act subject to the conditions required to be put on by the Department while granting registration. 12. Since we have held that assessee Trust has been created for imparting education and allied activities which are charitable in nature, we have directed that assessee be Printed from counselvise.com ITA No.555 & 556/CHD/2025 A.Y.2025-26 18 registered u/s 12A(1)(ac)(iii) of the Act, accordingly, we direct the ld. CIT(E) to grant approval u/s 80G of the Income Tax Act also. 13. In the result, both the appeals are allowed. Order pronounced on 23.03.2026. Sd/- Sd/- (KRINWANT SAHAY) (RAJPAL YADAV) ACCOUNTANT MEMBER VICE PRESIDENT “Poonam” आदेश कᳱ ᮧितिलिप अᮕेिषत/ Copy of the order forwarded to : 1. अपीलाथᱮ/ The Appellant 2. ᮧ᭜यथᱮ/ The Respondent 3. आयकर आयुᲦ/ CIT 4. िवभागीय ᮧितिनिध, आयकर अपीलीय आिधकरण, च᭛डीगढ़/ DR, ITAT, CHANDIGARH 5. गाडᭅ फाईल/ Guard File सहायक पंजीकार/ Assistant Registrar Printed from counselvise.com "