BIKASH KUMAR AGRAWAL,RAIPUR V. INCOME-TAX OFFICER-3(4), RAIPUR, RAIPUR

ITA 67/RPR/2024

AI Insights

The case involves Bikash Kumar Agrawal, who appealed against the order of the Commissioner of Income-Tax (Appeals), which confirmed the additions made by the Assessing Officer under Section 68 of the Income-tax Act, 1961. The additions pertained to Rs. 19.20 lakhs received as gifts/loans from family members, which were treated as unexplained cash credits. The Tribunal dismissed the appeal, agreeing with the lower authorities that the assessee failed to substantiate the genuineness of the transactions. Additionally, the Tribunal upheld the application of a 60% tax rate on these credits, rejecting the assessee's argument that the rate should be 30% as per the pre-amendment law applicable for the assessment year 2017-18.

• Counselvise Citation: [2024] 140 COUNSELVISE.COM (IT) 35792 (ITAT-RAIPUR)
• Duration Of Justice: 7 month(s) 20 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 21-10-2024
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: SMC
• Next Hearing Date: 26-09-2024
• Assessment Year: 2017-2018
• Appeal Filed On: 02-03-2024
• Other Referred Cases: CIT Vs. Abdul Aziz, Kaushal Prasad Manhar Vs. CIT
• Laws Referred To: Income-tax Act, 1961
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: PRIYANKA PATEL
• Assessee Lawyers: R.B DOSHI
• Keywords: Opportunity of being heard; Additional evidence; Unexplained cash credit; Gift; Bonafide mistake
• Section: 143(3); 143(2); 68

Judgement Text

"आयकर अपीलȣय अͬधकरण Ûयायपीठ “एक-सदèय” मामला रायपुर मɅ IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH “SMC”, RAIPUR Įी रवीश सूद, ÛयाǓयक सदèय क े सम¢ BEFORE SHRI RAVISH SOOD, JUDICIAL MEMBER आयकर अपील सं. / ITA No. 67/RPR/2024 Ǔनधा[रण वष[ / Assessment Year : 2017-18 Bikash Kumar Agrawal Prop. M/s. Balaji Trading Co. Gali No.1, Ganesh Jee Bhawan, Fafadih, Raipur (C.G.)-492 001 PAN : AGVPA0031C .......अपीलाथȸ / Appellant बनाम / V/s. The Income Tax Officer-3(4), Raipur (C.G.) ……Ĥ×यथȸ / Respondent Assessee by : Shri R.B Doshi, CA Revenue by : Dr. Priyanka Patel, Sr. DR सुनवाई कȧ तारȣख / Date of Hearing : 26.09.2024 घोषणा कȧ तारȣख / Date of Pronouncement : 21.10.2024 2 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 आदेश / ORDER PER RAVISH SOOD, JM: The present appeal filed by the assessee is directed against the order passed by the Commissioner of Income-Tax (Appeals), National Faceless Appeal Center (NFAC), Delhi, dated 22.12.2023, which in turn arises from the order passed by the A.O under Sec. 143(3) of the Income-tax Act, 1961 (in short ‘the Act’) dated 17.12.2019 for the assessment year 2017- 18. The assessee has assailed the impugned order on the following grounds of appeal: “1) That order of CIT(A) is bad-in-law, illegal and void-ab-initio. 2) On facts and in the circumstances of the case and in law, order passed by CIT(A) is not as per law because it was passed on 22.12.2023 by permitting time up to 14.12.2023, in spite of adjournment was sought for a month in adjournment request filed on 28.11.2023 by giving specific reason, thus, no proper opportunity of being heard was given to the assessee. 3) Without prejudice to ground nos. 1 & 2, CIT(A) has erred in dismissing appeal without deciding appeal on merit of the case properly and judicially. 4) Without prejudice to ground nos. 1 & 2, on the facts and in the circumstances of the case, CIT(A) has erred in confirming addition of Rs. 19,20,000/- made by the Assessing Officer u/s 68 for alleged unexplained cash credits without considering the facts and circumstances of the case properly and judicially. The assessee prays that the addition of Rs. 19,20,000/- be deleted. 5) Without prejudice to ground nos. 1 to 4, on facts and in the circumstances of the case and in law, CIT(A) has erred in confirming action of Assessing Officer in levying tax u/s 115BBE(1) @ 60% on alleged unexplained cash credit u/s 68 since applicable rate in the A.Y. 2017/18 u/s 115BBE was 30% as amendment proposed in the \"The Taxation Law (Second Amendment) Bill, 2016\" was applicable from 01.04.2017, i.e. from 3 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 the A.Y. 2018/19 onwards and not retrospectively to the transactions made during the F.Y. 2016-17. 6) The assessee reserves the right to add, amend, alter or withdraw any ground/grounds of appeal at the time of hearing.” 2. Shri R.B Doshi, Ld. Authorized Representative (for short ‘AR’) for the assessee at the threshold of hearing of the appeal, submitted that the present appeal involves a delay of 11 days. After perusing the application filed by the assessee a/w. “affidavits” of the assessee and his counsel, viz. Shri Lalit Jain, Chartered Accountant, dated 14.03.2024, wherein the reason leading to the impugned delay in filing of the present appeal had been deposed, the same was condoned vide order sheet entry dated 24.05.2024. 3. Succinctly stated, the assessee had e-filed his return of income for A.Y.2017-18 on 04.10.2017, declaring an income of Rs.6,62,520/-. Thereafter, the case of the assessee was selected for scrutiny assessment u/s. 143(2) of the Act. 4. Original assessment was framed by the A.O. vide his order passed u/s. 143(3) of the Act, dated 17.12.2019, wherein after treating the gifts/loans aggregating to Rs.19.20 lacs received by the assessee from his family members as unexplained cash credit u/s. 68 of the Act the income of the assessee was determined at Rs.25,82,520/-. 5. Aggrieved, the assessee carried the matter in appeal before the CIT(Appeals) but without success. As the assessee despite having been 4 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 afforded sufficient opportunity had failed to participate in the proceedings before the first appellate authority, therefore, the latter after deliberating on the observations of the A.O. upheld the addition made by him. 6. The assessee being aggrieved with the order of the CIT(Appeals) has carried the matter in appeal before the tribunal. 7. I have heard the Ld. Authorized Representatives of both the parties, perused the orders of the lower authorities and the material available on record, as well as considered the judicial pronouncements that have been pressed into service by them to drive home their respective contentions. 8. Shorn of unnecessary details, the A.O while framing the assessment observed that the assessee had claimed to have received gifts/loans aggregating to Rs.19.20 lacs from his five family members, as under: Sl. No. Name of persons Amoun of Loan/Gift 01. Smt. Geeta Devi Agrawal 5,00,000 02. Sh. Pawan Agrawal 1,80,000 03. Sh. Akash Agrawal 5,00,000 04. Smt. Kiran Devi Agrawal 2,40,000 05. Smt. Priyanka Agrawal 5,00,000 Total 19,20,000 5 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 The assessee on being called upon to substantiate the authenticity of the aforesaid gifts/loan transaction, filed with the A.O. copies of the bank statements and the returns of income of the aforementioned donors/lenders. On a perusal of the details gathered from the aforementioned documents filed by the assessee, the A.O observed that the respective amounts of loans/gifts received by the assessee from the aforementioned persons were sourced from cash deposits made in their bank accounts either on the same date or on a nearby date, the details as regards which were culled out by him in the body of the assessment order, as under: 6 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 Ostensibly, the A.O. observed that there was a common trend in the aforesaid gift/loan transactions, i.e. the respective impugned gifts/loans received by the assessee were preceded by cash deposits in the bank 7 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 accounts of the lenders/donors either on the date of transfer of the amount to the assessee; or on a nearby date. Apart from that, the A.O. observed that there were no significant transactions in the bank accounts of the aforesaid persons through out the year. Also, the A.O. observed that the end of the year the balance lying in the bank account of the said lenders/donors was very meager. On being confronted with the aforesaid facts, the assessee submitted that as per the return of income of the aforementioned lenders/donors for the immediately preceding year i.e 2016-17, there was sufficient cash balance available with them to source the subject cash deposits made in their bank accounts during the year under consideration. However, the A.O. did not find favor with the claim of the assessee of having received genuine loans/gifts from the aforementioned persons. The A.O on examination of the returns of income of the aforementioned persons for the preceding year i.e A.Y 2016-17, observed that though the same revealed availability of sufficient cash in hand with the aforementioned lenders (except for in case of one of the donor, viz. Shri. Pawan Kumar Agrawal), but it was noticed by him that the said returns of income were filed by the said persons after the demonization scheme had came into effect on 09.11.2016. The A.O based on the aforesaid facts, held a firm conviction that the assessee had deliberately shown substantial amount of cash balances in the respective returns of income of the aforementioned lenders/donors so that the source of the cash deposits made by them in their bank accounts during 8 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 the year under consideration could be explained. The A.O fortified his aforesaid conviction based on the fact that a similar trend as regards availability of substantial amount of cash in hand did not emanate from the returns of income of the said donors/lenders in the earlier years, i.e. A.Y.2015-16 or prior thereto. 9. Apart from that, the A.O. drawing support from the returns of income of two lenders, viz. Smt. Priyanka Agrawal and Shri Akash Agrawal, observed that the loan of Rs.5 lac each that was claimed to have been advanced to the assessee by the said respective persons was not commensurate with their aggregate returned income for the last 3/4 years. Also, the A.O. observed that as per the bank accounts of the aforementioned persons there were no corresponding withdrawals, which could explain the source of cash deposits made in said accounts during the year under consideration. Accordingly, the A.O. in the absence of any plausible explanation regarding the nature and source of the cash deposits of Rs.19.20 lacs (supra) received by the assessee from the aforementioned five persons, held the same as unexplained cash credits u/s. 68 of the Act. 10. Shri R.B Doshi, Ld. AR at the threshold assailed the order of the CIT(Appeals) on the ground that he had disposed off the appeal without affording sufficient opportunity to the assessee. Elaborating on his contention, the Ld. AR submitted that the CIT(Appeals) vide his notice dated 9 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 20.11.2023 had fixed the appeal for hearing on 28.11.2023. The Ld. AR submitted that the assessee on 28.11.2023 had uploaded an application for adjournment for the reason that the requisite documents for preparing the appeal were yet to be collected by his new counsel. The Ld. A.R submitted that the assessee had in his application requested that a period of one month be allowed for furnishing the reply/submissions. Carrying his contention further, the Ld. AR submitted that the CIT(Appeals) had most arbitrarily proceeded with, wherein, he had after scrapping the request of the assessee for allowing a time of one month for collecting the requisite details, had issued notice on 07.12.2023 fixing the hearing of the appeal for 14.12.2023 and disposed off the same vide his order dated 22.12.2023. The Ld. AR submitted that as the CIT(Appeals) had hushed through the matter and not considered the assessee’s request for adjournment, therefore, the order passed by him be set-aside to his file with a direction to re-adjudicate the same. 11. On merits, the Ld. AR submitted that the assessee had filed an application under Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963 requesting for admission of certain documents, viz. gifts/loan confirmations and copies of the returns of income of the lenders/donors as “additional evidence”. As the Tribunal without expressing any view on the admission of the additional evidence, had brought it to the notice of the Ld. A.R that photocopies of the gift confirmations filed before it were liable to be 10 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 rejected, therefore, the assessee vide his letter dated 01.07.2024 had placed on record original gift confirmations of donors, viz. Smt. Geeta Devi Agrawal and Shri Pawan Kumar Agrawal. 12. On a specific query by the bench that why the aforementioned documents filed as additional evidence were not filed before the lower authorities, the Ld. AR had drawn my attention to the application filed by the assessee. Ostensibly, the assessee appellant in his application filed under Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963, had stated that the aforementioned documents could not be filed before the lower authorities as the counsel who was looking after the assessee’s case harbored a belief that no such confirmations were required to be submitted. Accordingly, it was the assessee’s claim that the aforesaid documents were not filed before the lower authorities for the reason that he was not properly advised by his the then counsel. 13. I have perused the said documentary evidence, i.e. gifts/loans confirmations, copies of returns of income of the lenders/donors, for admission of which liberty has been sought by the assessee vide his application filed under Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963. I may herein observe that the casual approach of the assessee in filing the aforesaid documents can be gathered from the fact that photocopies of the loan/gift confirmations of the lenders, viz. Shri Akash Agrawal, Page 9 11 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 of application, Shri Kiran Agrawal, Page 11 of application, and Smt. Priyanka Agrawal, Page 14 of application have been filed before me. Although it is the claim of the assessee that failure to place on record the aforementioned gift/loans confirmations a/w. copies of the return of income of the aforementioned doners was attributable to his counsel who had failed to properly advise the assessee, but I am unable to persuade myself to accept the said unsubstantiated claim. One can comprehend that there could be a bonafide mistake in not filing the aforementioned documents before the A.O for the reason that the assessee was not properly advised by his the then counsel, but I am unable to fathom that as to why the same were not filed in the course of proceedings before the CIT(Appeals). As the assessee had failed to come forth with any plausible explanation as to why the aforesaid documents could not be filed before either of the lower authorities, therefore, I find no justification in admitting the same. 14. Before parting on the aforesaid issue, I may herein observe, that even otherwise Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963 does not entitle the parties to the appeal to produce additional evidence either oral or documentary before the Tribunal, but if the Tribunal requires any document to be produced or any witness to be examined or any affidavit to be filed to enable it to pass orders or for any other substantial cause, or, if the income-tax authorities have decided the case without giving sufficient opportunity to the assessee to adduce evidence either on points specified by 12 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 them or not specified by them, then the Tribunal, for reasons to be recorded, may allow such document to be produced or witness to be examined or affidavit to be filed or may allow such evidence to be adduced. For the sake of clarity, Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963 is culled out as under: “29. The parties to the appeal shall not be entitled to produce additional evidence either oral or documentary before the Tribunal, but if the Tribunal requires any document to be produced or any witness to be examined or any affidavit to be filed to enable it to pass orders or for any other substantial cause, or, if the income-tax authorities have decided the case without giving sufficient opportunity to the assessee to adduce evidence either on points specified by them or not specified by them, the Tribunal, for reasons to be recorded, may allow such document to be produced or witness to be examined or affidavit to be filed or may allow such evidence to be adduced.” Be that as it may, as there is neither any justifiable reason for the assessee to file the aforementioned documents as “additional evidence” for the first time before me; nor the filing of the said documents fall within either of the circumstances contemplated under Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963, therefore, the admission of the same is declined. Thus, the Grounds of appeal Nos. 2 & 3 raised by the assessee are dismissed in terms of the aforesaid observations. 15. I shall now advert to the facts involved in the present case before me. Admittedly, it is a matter of fact borne from the record that the loans/gifts of Rs.19.20 lacs claimed by the assessee to have been received from the 13 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 aforesaid five lenders/donors were sourced from cash deposits made in the respective bank accounts of the said persons, either on the same date or on a nearby date. As observed by the A.O, and rightly so, the fact that there were no significant transactions in the bank account throughout the year, and at the end of the year the balance lying in the said bank accounts were very meager, therein, raises serious doubt as regards the authenticity of the loans/gifts as claimed by the assessee to have been received from the aforementioned persons with little financial means. Although the assessee had tried to substantiate the authenticity of the loan/gift transactions by claiming that the respective persons had sufficient cash balances available with them as per their respective returns of income for the immediately preceding year, i.e A.Y 2016-17, but then the very fact that the said returns of income of the said persons were filed after the demonetization scheme had come into effect i.e. from 09.11.2016, further supplements the serious doubts as regards the veracity of the aforesaid claim of the assessee. I cannot remain oblivion of the fact that the generation of substantial amounts of cash in hand, as reflected in the returns of income for A.Y.2016-17 of the aforementioned persons, could have purposively been done to justify the subsequent cash deposits in their bank accounts which, in turn, was thereafter channelized as loans/gifts by the said persons to the assessee during the year under consideration. My aforesaid conviction is fortified by the observation of the A.O that no such cash balances were reflected in the 14 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 returns of income of the aforementioned lenders/donors in the previous year i.e. A.Y.2015-16 or earlier years. Apart from that, the fact that there was no corresponding withdrawals made by the aforementioned lenders/donors which could explain the source of the cash deposits in question made in their bank accounts during the year under consideration, thus, clearly falsify the explanation of the assessee. I find that not only the assessee had failed to discharge the onus that was cast upon him as regards proving the authenticity of the loan/gift transactions based on clinching documentary evidence before the lower authorities, but also a glance over their credentials, i.e. returns of income for the last preceding years is by no means found to be commensurate with the amount of loans/gifts which is stated to have been advanced/given by them to the assessee. As observed by the A.O, one of the lenders Smt. Priyanka Agrawal, who is claimed to have advanced a loan of Rs.5 lacs to the assessee, had returned an income of Rs.6,23,770/- (aggregate) for the last three years i.e. A.Y.2013-14 to 2015- 16. On a similar footing, Shri Akash Agrawal who is claimed to have advanced a loan of Rs.5 lacs to the assessee, had returned an income of Rs.8,30,790/- (aggregate) for the last four years, i.e. A.Y.2012-13 to 2015- 16. Also, a peculiar aspect pertaining to both the aforementioned lenders is that there was no corresponding withdrawals from their respective bank accounts which could explain the source of the cash deposits in their bank 15 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 account during the year under consideration which, in turn, were channelized in garb of alleged loans/gifts by them to the assessee. 16. Although, the Ld. AR had placed reliance on the judgment of the Hon’ble High Court of Chhattisgarh in the case of CIT Vs. Abdul Aziz, (2012) 251 CTR 58 (Chhattisgarh), but the same being distinguishable on facts would not carry his case any further. Ostensibly, in the aforementioned case, the Hon’ble High Court had observed that the statements of 27 creditors in question were recorded on oath by the A.O, wherein they had duly confirmed the transactions and had filed “affidavits” in support thereof. Unlike the facts involved in the aforementioned case, as the assessee in the present case before me had failed to place on record confirmations/affidavits of the lenders/donors to substantiate the authenticity of the loan/gift transactions; nor placed on record any such documentary evidence which would have proved the genuineness of the said respective transactions to the hilt, therefore, he had failed to discharge the primary onus that was cast upon him as regards proving the authenticity of the loans/gifts transactions in question. All that the assessee had furnished in the course of proceedings before the CIT(Appeals) were the bank statements of the lenders/donors, balance sheets, capital accounts a/w. copies of the returns of income of the aforementioned persons. Although, the assessee in his attempt to substantiate the authenticity of the loan/gift transactions had placed on record the “balance sheet” and “capital account” for A.Y.2017-18 of two 16 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 donors (out of five donors/lenders), viz. Smt. Geeta Devi Agrawal, Page 21 of APB and Shri Pawan Kumar Agrawal, Page 58 of APB, but the same would also not assist his case. I, say so, for the reason that on a specific query by the bench as to whether the aforesaid financial statements, i.e. capital account, balance sheet etc. were filed alongwith the returns of income of the aforementioned persons, the Ld. AR in all fairness had answered in negative. 17. As the assessee in the present case before me had failed to discharge the onus that was cast upon him to prove the authenticity of the loan/gift transactions based on irrefutable documentary evidence as per the mandate of Section 68 of the Act, therefore, I, find no infirmity in the view taken by the lower authorities who had rightly held the same as unexplained cash credits u/s. 68 of the Act. My aforesaid view that where the assessee had failed to discharge the primary onus that was cast upon him as regards proving the authenticity of the loan/credits transaction in its books of account, then the same is liable to be held as unexplained cash credit u/s. 68 of the Act is supported by the judgment of the Hon’ble High Court of Chhattisgarh in the case of Kaushal Prasad Manhar Vs. CIT, TAX Case No.12 of 2010, dated 06.08.2010. Thus, the Ground of appeal No.4 raised by the assessee is dismissed in terms of the aforesaid observations. 17 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 18. I shall now deal with the assessee’s claim that the A.O had grossly erred in levying tax u/s.115BBE(1)(a) of the Act @ 60% on the alleged cash credits u/s. 68 of the Act. 19. The Ld. AR submitted that Section 115BBE(1) of the Act that was initially inserted vide the Finance Act, 2012 w.e.f. 01.04.2013, inter alia, provided for levy of tax on the income referred to in Section 68 of the Act @30%, had thereafter been substituted by The Taxation Law (Second Amendment) Act, 2016 w.e.f. 01.04.2017, wherein the tax rates on the income referred to in Section 68 had been raised to 60%. The Ld. A.R states that the aforesaid amendment had been made available on the statute w.e.f. 01.04.2017, i.e. from A.Y. 2018-19 and onwards. Elaborating on his contention, the Ld. AR submitted that as the case of the assessee for the year under consideration, i.e. A.Y.2017-18 was governed by the pre- amended Section 115BBE of the Act, therefore, the CIT(Appeals) had grossly erred in confirming the action of the A.O in levying tax u/s.115BBE (1) of the Act @60% on the alleged unexplained cash credit u/s. 68 of the Act. 20. I have thoughtfully considered the contentions advanced by the Ld. Authorized Representatives of both the parties qua the aforesaid issue in hand. At the threshold, I may herein observe that the A.O. in the body of the assessment order had observed that the addition made by him u/s. 68 of the Act of Rs.19.20 lacs is to be taxed u/s. 115BBE of the Act. Also, I find 18 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 that neither the assessee had raised any contention qua the rate of tax u/s. 115BBE of the Act before the CIT(Appeals) nor there is any adjudication by him on the aforesaid issue while disposing the appeal. 21. Be that as it may, I am of the considered view that as the amendment to Section 115BBE of the Act had been made available on the statute vide The Taxation Laws (Second Amendment), Act, 2016 w.e.f. 01.04.2017, therefore, the same would be applicable from A.Y.2017-18 and onwards. As the case of the assessee before me pertains to A.Y.2017-18, therefore, it would be the post-amended tax rate contemplated u/s. 115BBE(1) of the Act that would be applicable in his case. Thus, the Ground of appeal No.5 raised by the assessee is dismissed in terms of the aforesaid observations. 22. Grounds of appeal No.1 & 6 being general in nature are dismissed as not pressed. 23. In the result, the appeal of the assessee is dismissed in terms of the aforesaid observations. Order pronounced in open court on 21st day of October, 2024 Sd/- (रवीश सूद /RAVISH SOOD) ÛयाǓयक सदèय/JUDICIAL MEMBER रायपुर/ RAIPUR ; Ǒदनांक / Dated : 21st October, 2024. **#SB, Sr.PS 19 Bikash Kumar Agrawal Vs. ITO-3(4), Raipur (C.G.) ITA No. 67/RPR/2024 आदेश कȧ ĤǓतͧलͪप अĒेͪषत / Copy of the Order forwarded to : 1. अपीलाथȸ / The Appellant. 2. Ĥ×यथȸ / The Respondent. 3. The CIT(Appeals)-1, Raipur (C.G) 4. The Pr. CIT-1, Raipur (C.G) 5. ͪवभागीय ĤǓतǓनͬध, आयकर अपीलȣय अͬधकरण,रायपुर बɅच, रायपुर / DR, ITAT, Raipur Bench, Raipur. 6. गाड[ फ़ाइल / Guard File. आदेशानुसार / BY ORDER, // True Copy // Senior Private Secretary आयकर अपीलȣय अͬधकरण, रायपुर / ITAT, Raipur. "