DCIT, CENTRAL CIRCLE-1, GURUGRAM V. PLANET INFRA PROMOTERS P.LTD, NEW DELHI

ITA 8988/DEL/2019

AI Insights

The case involves an appeal by the Revenue against the order of the CIT(Appeals)-3, Gurgaon, which deleted the additions made by the Assessing Officer (AO) under section 153A(1)(b) of the Income Tax Act, 1961, for the assessment year 2013-14. The additions were based on documents seized during a search and seizure operation under Section 132 conducted on the Antriksh Group of companies. The Revenue contended that these documents, which included cash transaction records, belonged to the assessee company, Planet Infra Promoters P. Ltd. The CIT(A) found that the documents did not belong to the assessee, a decision supported by the Supreme Court's ruling in CIT vs. Singhad Technical Education Society and the Delhi High Court's decision in M/s Canyon Financial Services Ltd. The Tribunal also noted that the satisfaction note recorded by the AO did not establish a clear nexus between the seized documents and the assessee company.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 787312 (ITAT-DELHI)
• Duration Of Justice: 6 year(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 19-11-2025
• Appeal Filed By: Department
• Order Result: Partly Allowed
• Bench Allotted: F
• Assessment Year: 2013-2014
• Appeal Filed On: 19-11-2019
• Other Referred Cases: CIT vs. Singhad Technical Education Society, M/s Canyon Financial Services Ltd. vs. CIT, ITO vs. Vikram Sujit Kumar Bhatia
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: MONIKA SINGH
• Assessee Lawyers: AKSHAT JAIN; RAJAT JAIN
• Keywords: Document seized; Documents seized; Search and seizure; Loose papers
• Section: 132

Judgement Text

"ITA No.8988/Del/2019 1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “F” NEW DELHI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER आ.अ.सं/.I.T.A No.8988/Del/2019 िनधा रणवष /Assessment Year:2013-14 DCIT, Central Circle-1, 7th Floor, HSIIDC Building, Udyog Vihar, Phase-V, Gurgaon, Haryana. बनाम Vs. PLANET INFRA PROMOTERS P. LTD. 34c, Sector-8, Rohini, New Delhi. PAN No.AAGCP8614E अपीलाथ\u0014 Appellant \u0016\u0017यथ\u0014/Respondent Revenue by Ms. Monika Singh, CIT DR Assessee by Shri Akshat Jain, Advocate & Shri Rajat Jain, Advocate सुनवाईक\bतारीख/ Date of hearing: 07.10.2025 उ\u000eोषणाक\bतारीख/Pronouncement on 19.11.2025 आदेश /O R D E R PER C.N. PRASAD, J.M. This appeal is filed by the Revenue against the order of the Ld. CIT(Appeals)-3, Gurgaon dated 06.09.2019 for the AY 2013-14. The Revenue has raised the following grounds of appeal along with Form 36 originally filed on 19.11.2019: Printed from counselvise.com ITA No.8988/Del/2019 2 (i) “The satisfaction note in the instant case was recorded on 25.02.2016. The provisions of section 153C have been substituted by Finance Act, 2015 w.e.f. 01.06.2015. Being procedural provisions, these will apply to all the proceedings u/s 153C initiated after 01.06.2015. As per substituted section 153C, the proceedings u/s 153C can be initiated on the basis of satisfaction of the AO that any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein relates to a person other than the person referred to in section 153A. (ii) The satisfaction note in the instant case was properly recorded which clearly mentioned that incriminating documents seized from possession of Sh. Rakesh Kumar Yadav reveals that M/s Planet Infra Promoters Pvt. Ltd. had entered into various cash transactions with him. (iii) The AO in his satisfaction note has clearly mentioned the documents which would have been handed over to the AO of the person i.e. M/s Planet Infra Promoters Pvt. Ltd. (who was same in the instant case). (iv) During the assessment proceedings, the assessee failed to furnish any reply regarding the transactions and furthermore the assessee was unable to furnish any reason for not furnishing the explanation regarding the nature and source of these transactions. (v) The AO in his report has submitted that the documents seized from the premises of Shri Rakesh Kumar Yadav belongs to M/s Planet Infra Promoters Pvt. Ltd. and therefore, as per provisions of section 153C of the Act, a satisfaction note was recorded by the AO in the case of searched person as well as in the case of other person on 02.03.2016. While issuing notice u/s 153C of the Act the incriminating Printed from counselvise.com ITA No.8988/Del/2019 3 documents found from the residence of searched person were perused and these revealed unrecorded transactions with the assessee company. Therefore, it was categorically held that the documents seized from the premise of searched person belong to the assessee and hence notice u/s 153C of the Act was issued.” 2. The Assessing Officer filed the following revised grounds of appeal along with modified Form 36 on 01.07.2022: “Revised Grounds of Appeal: i) Whether on facts and circumstances of the case and in law, the Ld. CIT(A) while allowing the appeal on grounds that the conditions for issue of notice u/s 153C were not satisfied in absence of seized documents belonging to the assessee erred and misread the relevant facts as well as legal provisions of section 153C. ii) Whether on facts and circumstances of the case, the Ld. CIT(A) erred in holding that the seized material did not belong to the assessee company but Sh. Rakesh Kumar Yadav. iii) Whether on facts and circumstances of the case, the ld. CIT(A) failed to appreciate that section 153C has been amended by the Finance Act, 2015 w.e.f. 01.06.2015 and as per amended section 153C, proceedings u/s 153C canbe initiated on the basis of satisfaction of the AO that any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein relates to a person other than the person referred to in section 153A. Being procedural provisions, these will apply to all the proceedings u/s 153C initiated after 01.06.2015 and the satisfaction note in the instant case was recorded on 02.03.2016. iv) The appellant craves to add, amend, alter or modify any grounds of appeal at the time of hearing.” Printed from counselvise.com ITA No.8988/Del/2019 4 3. Brief facts of the case are that a search and seizure action under Section 132 was conducted on Antriksh Group of cases on 05.02.2014 wherein a document was found and seized from the residence of Rakesh Kumar Yadav annexurized as Page - 19 of Annexure A - 3 alleged to be belonging to the Assessee company. The Ld. AO of the searched person i.e. Rakesh Kumar Yadav has recorded a satisfaction note dated 02.03.2016 stating that Page - 19 of Annexure A - 3 found and seized from the residence of Rakesh Kumar Yadav belongs to the Assessee company which contains receipts of Rs.75,00,000/- and has a bearing on the determination of the total income of the Assessee. Thereafter the Id. AO of the appellant company has recorded the satisfaction note on the same date i.e. 02.03.2016 stating the he is satisfied that Page - 19 of Annexure A-3 found and seized from the residence of Rakesh Kumar Yadav belongs to the appellant company containing receipt of Rs.75,00,000/- and has a bearing on the determination of the total income of the appellant. Consequent upon, a notice dated 02.03.2016 under section 153C of the Income Tax Act, 1961 (herein after referred as ‘Act’) to the Assessee for the assessment year 2013-14, assessing officer has passed assessment order u/s 153A(1)(b) of the Act dated 29.03.2016 Printed from counselvise.com ITA No.8988/Del/2019 5 by treating the said transactions as unexplained income for the assessment year 2013-14. 4. The Assessee preferred an appeal before Ld. CIT(A) and the Ld. CIT(A) vide his appellate order dated 06.09.2019 has deleted the additions holding that seized document does not “belong to” the appellant company by relying upon the decision of Hon’ble Supreme Court in the case of CIT vs. Singhad Technical Education Society (397 ITR 344) observing as under: > Satisfaction note recorded in the case of appellant that document seized in the search of M/s Antriksh Group do not belong to the appellant company. > AO failed to rebut the legal presumption under Section 292C that documents belong to the searched person. > The AO of the searched person in the satisfaction note has not listed the documents which were to be handed over to the AO of the appellant company. > The satisfaction note did not clearly show that the seized documents belonged to the appellant company. > For searches before 01.06.2015, law required that seized documents must “belong to” another person. The amendment substituting the phrase “pertains to” or “relates to” (effective 01.06.2015) was prospective and not Printed from counselvise.com ITA No.8988/Del/2019 6 applicable here by relying upon decision of Hon’ble Delhi High Court in the case of M/s Canyon Financial Services Ltd. With the above observations the Ld. CIT(Appeals) held that addition made by the AO on account of unaccounted transactions has not been on the basis of any document belonging to the assessee and it has been done on the basis of diary found from possession of Shri Rakesh Kumar Yadav, Director of Antriksh Group of Companies showing transactions of receipts and payments made in cash by Shri Rakesh Kumar Yadav. 5. The Ld. DR submitted that the Ld. CIT(A) has erred in applying the pre-amendment “belongs too” test while ignoring the binding legal position post Finance Act, 2015 and as subsequently affirmed by the Hon’ble Supreme Court in the case ITO vs. Vikram Sujit Kumar Bhatia (2024) (300 taxman 601). Ld. DR submitted that the statutory amendment has substituted the expression belongs to grounds with the wider phrase “pertains to or relates to” thereby enlarging the scope of 153C so as to cover all incriminating material found during the course of search even if such material does not strictly belongs to the assessee. Ld. DR submits that in view of the decision of the Hon’ble Supreme Court in the case of ITO vs. Vikaram Sujit Kumar Bhatia (supra) amendment to section 153C of Printed from counselvise.com ITA No.8988/Del/2019 7 the Act brought by the Finance Act, 2015 would also be applicable to search conducted prior to 01.06.2015 and in the case of the assessee the search was conducted prior to 01.06.2015. 6. The Ld. DR further submitted that the satisfaction note prepared by the Assessing Officer in this case meets all judicially recognized bench marks that it specifically identifies the seized diary and loose sheets, it establishes a clear nexus between those documents and the assessees cash transactions and purchase, it quantifies the undisclosed receipts and payment relatable to the assessee for AY 2013-14 and it demonstrates how the seized material impact income determination. Thus, it is submitted that the satisfaction note is neither wague nor general, it is concrete, year specific and directly linked to the incriminating documents and compliance satisfies even the height and scrutiny standards laid down by quotes. Ld. DR also filed written submissions on various other legal contentions raised by the Assessee in its Rule 27 application filed. 7. On the other hand, the Ld. Counsel for the assessee submits that the Assessing Officer has recorded satisfaction note for initiation of proceedings under section 153C of the Act on the basis of document found and seized i.e. Page - 19 of Annexure A - 3 from Printed from counselvise.com ITA No.8988/Del/2019 8 the residence of Rakesh Kumar Yadav containing a narration “Received from Ajit 75 lac\". On perusal of above narration on seized page it is clearly evident that name of the appellant company does not appear anywhere and the transaction recorded therein pertain to other party and not to the appellant. Therefore, said seized document do not belongs / pertains / or any information contained therein relates to the appellant. 8. Ld. Counsel submits that the satisfaction note recorded by the Assessing Officer is invalid as it does not specify how the seized document / incriminating material found is related to or belongs to the appellant company and also did not specify the nature of transaction. It merely makes a general observation without establishing any live or proximate nexus between the seized materials and the appellant. It is submitted that no material has been found during the search to suggest that the said transactions have any link with the appellant company. Ld. Counsel further submits that the assessing officer in the satisfaction note has not listed the documents which were handed over to the AO of the appellant company. 9. Also Ld. Counsel further submitted that the assessing officer while recording satisfaction note has mentioned that the appellant Printed from counselvise.com ITA No.8988/Del/2019 9 during the post search proceedings vide letter dated 16.06.2014 has accepted the transactions recorded in the seized documents, whereas said letter has been filed by the Antriksh Group and no such letter has been filed by appellant. Further Ld. Counsel referring to the said letter submits that on perusal of said letter, it is also clear that name of the appellant company is not appearing anywhere in the said letter. The Ld. Counsel for the assessee further submitted that the letter dated 16.06.2014 which the AO has referred to in the satisfaction note that the assessee furnished this letter accepting the financial transactions recorded in the seized documents through an excel sheet, submitted that the assessee never furnished any such letter before the DDIT-II, Gurgaon and as a matter of fact this is the letter furnished by the Antriksh Group of Companies and this Tribunal considered this very fact in its decision in the case of DCIT vs. Shri Jatmal Mehta in ITA Nos. 8985 to 8987/Del/2019 by order dated 19.07.2023 that the said letter dated 16.06.2014 filed before the DDIT-II, Investigation, Gurgaon accepting the financial transactions mentioned in the seized document was in fact filed by Antriksh Group and the entire transactions reflected therein were owned up by Antriksh Group and came forward to offer 13.95 crores as their undisclosed income for Printed from counselvise.com ITA No.8988/Del/2019 10 the AY 2014-15 spreading over among six Companies belonging to the said group. 10. Ld. Counsel for the assessee further submitted that the Tribunal had considered almost identical facts situation in the case of Shri Jatmal Mehta on identical facts wherein the additions were made based on the seized materials found in the case of Shri Rakesh Kumar Yadav and the Tribunal held that such seized documents do not belong to or pertain to the assessee namely Shri Jatmal Mehta and the additions made therein based on such seized materials was deleted. This decision squarely applies to the facts of the assessee’s case. 11. The Ld. Counsel for the assessee further submitted that the provisions of section 153C of the Act has been amended with effect from 01.06.2015 by substituting the words “belongs or belong to” with “pertains or pertain to, or any information contained therein, relates to. In case of appellant the Hon’ble CIT(A) by relying upon the decision of Hon’ble Delhi High Court in case of M/s Canyon Financial Services Ltd. held that for searches before 01.06.2015, law required that seized documents must “belong to” another person. The amendment substituting the phrase “pertains to” or “relates to” (effective 01.06.2015) was prospective and not Printed from counselvise.com ITA No.8988/Del/2019 11 applicable here. Ld. Counsel submits that in 2023. the Hon’ble Supreme Court in case of Income-tax Officer v. Vikram Sujit kumar Bhatia held that the amendment brought to section 153C vide Finance Act,2015 shall also be applicable to searches conducted under section 132 before 01.06.2015. Ld. Counsel submits that even after considering the judgment of Vikram Sujitkumar Bhatia (SC) and also the amendment in section 153C, the seized document in the present case neither belongs to nor pertains to / any information contained therein relates to the appellant company as the name of the appellant company does not appear on the document and there is no evidence to show any connection / link of the appellant with the transactions recorded therein. 12. Heard rival submissions, perused the orders of the authorities below. In this case a search and seizure action u/s 132 was conducted on Antriksh Group of cases on 05.02.2014 wherein a document was found and seized from the resident of Rakesh Kumar Yadav annexurized page 19 of Annexure A-3 was alleged to be belonging to the assessee company. The AO of the searched person i.e. Rakesh Kumar Yadav has recorded a satisfaction note dated 02.03.2016 stating that the document seized i.e. page 19 Annexure- 3 from the premises of Shri Rakesh Kumar Yadav and the huge Printed from counselvise.com ITA No.8988/Del/2019 12 transactions found recorded in these incriminating documents revealed that these transactions were made for the assessee company. In the satisfaction note the AO records that transactions were entered into between Rakesh Kumar Yadav and Ajit Singh and they belong to the assessee company. The satisfaction note recorded by the AO is as under: Printed from counselvise.com ITA No.8988/Del/2019 13 13. As could be seen from the above satisfaction note the details of transaction by Ajit Singh with Rakesh Kumar Yadav of Rs.75 lakhs as per page 19 Annexure-3 seized in the course of search is narrated. However, the seized copy of ledger marked as 19 Annexure-3 is as under: Printed from counselvise.com ITA No.8988/Del/2019 14 Printed from counselvise.com ITA No.8988/Del/2019 15 The above seized document i.e. copy of ledger nowhere suggests the name of the assessee. The seized document only mentions that “Received from Ajit Singh Rs.75 lakhs”. The name of the assessee company do not appear in the seized document. It is a transaction between Shri Rakesh Kumar Yadav and Shri Ajit Singh. The reason given by the Assessing Officer in the satisfaction note to say that the transaction belongs to or pertains to the assessee is that during the course of post search enquiries and investigation the assessee submitted letter dated 16.06.2014 in the office of DDIT-II, Gurgaon wherein assessee accepted the financial transactions recorded in the seized documents through an excel sheet and on going through the excel sheet submitted by the assessee it was noted that the transactions in respect of M/s Planet Infra Promoters Pvt. Ltd. mentioned above duly matched with the entries found recorded on incriminating documents. However, we find that this letter dated 16.06.2014 purportedly said to have been filed by the assessee before the DDIT-II, Investigation, Gurgaon was not filed by the assessee but was filed by Antriksh Group of Companies and also these companies owned up all the transactions in the seized materials, and this fact was taken note of by the Tribunal while dealing with similar case in the case of DCIT vs. Shri Jethmal Mehta Printed from counselvise.com ITA No.8988/Del/2019 16 in ITA Nos. 8985 to 8987/Del/2019 dated 19.07.2023 wherein the Tribunal observed as under: “10. It is not in dispute that the document containing certain cash entries (both receipts and payments) which are tabulated in pages 3 & 4 of the assessment order were seized from the premises of Sh. Rakesh Kumar Yadav and Sh. Rajbir Goyat belonging to Antriksh Group, during the course of their search on 05/02/2014. It is not in dispute that the said tabular form contained a surname called ‘Mehta’, which was suspected by the Department to be representing Sh. Jethmal Mehta, the assessee herein. The assessee had categorically denied in his reply that these transactions were not at all related to him and he has nothing to do with the same. This goes clearly to prove that assessee had categorically disowned seized document as not belonging to him or pertaining to him or relating to him. Admittedly these seized documents were seized from the premises of Sh. Rakesh Kumar Yadav and Sh. Rajbir Kumar Goyat during the course of their search and hence the presumption in terms of section 292C of the Act would be that the said document belongs/pertains/relates to the searched person. It is not in dispute that the seized documents were in the handwriting of searched person. However, the aforesaid presumption could be rebutted by the AO of the searched person with cogent material by recording a satisfaction note that the said material does not belong/pertain/relate to the searched person but instead belongs/pertains/relates to some other person (a 3rd party). The only material available with the Revenue is the surname ‘Mehta’ used in the said seized document which is assumed by the Revenue to be Jethmal Mehta i.e., the assessee herein. He had categorically denied right from the inception that his name is not at all mentioned in the seized document. No cogent evidence has been brought on the record by the Revenue to prove that the surname mentioned in the seized document in fact refers to Jethmal Mehta i.e., the assessee herein. The entire seized documents that is the subject matter of the addition were placed on record by the Ld. AR before us. On perusal of the same, we find that nowhere the name of Jethmal Mehta is mentioned and only the surname Mehta is mentioned. We find that the Revenue was not able to collaborate the seized document with any other transactions belonging/pertaining/ relating to the assessee to give weightage to these seized documents. Hence, the said Printed from counselvise.com ITA No.8988/Del/2019 17 seized document becomes merely dumb documents in the hands of the assessee. In our considered opinion, the assessee cannot be held to be having control over what the third person records in his regular books of accounts or in the parallel books of account. Here the seized documents are merely loose sheets not forming part of the books of account of the assessee and that they do not constitute admissible evidence and are to be merely discarded as dumb documents as there are no other corroborative material or evidence to link those documents. 11. Before us, the Ld. DR vehemently relied on the letter dated 16/06/2014 filed before the DDIT-II, Investigation, Gurugaon, accepting the financial transactions mentioned in the seized document in this regard. It is pertinent to note that the letter dated 16/06/2014 was not filed by the assessee before the Investigation Wing. Instead, this letter dated 16/06/2014 was filed by Antriksh Group before the DDIT, Investigation, Gurugaon. The assessee does not belong to Antriksh Group. The assessee also filed an affidavit clearly affirming that the letter dated 16/06/2014, accepting the financial transactions recorded in the seized documents was not filed by the assessee herein. This fact is further confirmed from pages 13 to 14 of the PB filed by the Revenue before us which contains the letter dated 16/06/2014 filed before the DDIT, Investigation, wherein Antriksh Group of companies had owned up the entire transaction and had came forwarded to offer Rs.13.95 Crores as their undisclosed income for AY 2014-15 spread over six companies belonging to the said group. We are conscious of the fact that the Hon’ble Supreme Court in the recent decision in the case of ITO vs. Vikram Sujitkumar Bhatia reported in [2023] live Law (SC) 274 dated 06/04/2023 in Civil Appeal No.911/2022 had held that the amendment brought in Section 153C of the Act w.e.f 01 /06/2015 ought to be construed retrospectively and would apply in respect of searches conducted prior to 01/06/2015 also. Respectfully relying on the said decision, the observation made by the Ld. CIT(A) in para 6.10(v) is hereby reversed. However, the other observations made by the Ld. CIT(A) that the satisfaction note recorded by the Ld. AO for initiating proceedings u/s 153C of the Act did not specify the nature of transactions; did not contain the name of the assessee in clear terms and said seized documents did not belong/pertain/relate to the assessee remains un- controverted by the Revenue before us with cogent evidences. The Revenue right from the inception has been assuming that Printed from counselvise.com ITA No.8988/Del/2019 18 the surname Mehta mentioned in the seized documents refers to Jethmal Mehta i.e., the assessee herein. We have already given our observations in this regard (supra) that assessee had categorically denied the contents of the seized materials when they were confronted to him. The assessee cannot be expected to prove the negative. On the contrary, the Ld. AO is supposed to bring on record with cogent evidences while recording the satisfaction note that a particular seized document which was seized from the premises of Rakesh Kumar Yadav does not belong to/pertain/relate to them and that the said documents belongs/pertains/relates to the assessee herein by duly mentioning the nature of transactions carried thereon and duly bringing on record with other cogent/collaborative evidences implicating the assessee thereof. This has not been done by the Revenue in the instant case. This conclusion of ours is further fortified from the fact that neither Sh. Rakesh Kumar Yadav nor Sh. Rajbit Goyat during the course of statement recorded from them u/s 132(4) of the Act had mentioned even the name of the assessee anywhere. The copy of the statements recorded from them are enclosed pages 1 to 40 of the Paper Book filed by the Department before us. Hence, no proceedings per se could be initiated on the assessee u/s 153C of the Act based on the seized documents found in the premises of Rakesh Kumar Yadav and Rajbir Goyat. Accordingly, we do find any infirmity in the observations made by the Ld. CIT(A) in para 6.10 from (i) to (iv) in page 26 of his order. Accordingly, revised grounds (i) & (ii) raised by the Revenue are dismissed and revised ground (hi) raised by the Revenue is allowed.” 14. As could be seen from para 11 of the Tribunal’s order the letter dated 16.06.2014 which the AO referred to in the satisfaction note and the transactions therein, were owned up and already offered to tax by 6 companies in Antriksh Group of Companies. Therefore, the satisfaction note recorded by the AO in the case of the assessee that the assessee submitted a letter dated 16.06.2014 and accepted the financial transactions recorded in the seized Printed from counselvise.com ITA No.8988/Del/2019 19 documents through excel sheet and the transactions mentioned therein duly matched with the entries found recorded on incriminating documents is factually not correct and as such recording of satisfaction note stating that incriminating documents found from the possession of Shri Rakesh Kumar Yadav reveals transaction made for Assessee company and the financial transactions recorded in seized document duly matched and accepted by Assessee is without any basis. 15. Therefore, we are of the view that the AO could not in the satisfaction note recorded, established that the seized documents belong/pertains to or relates to the assessee and thus, the addition made based on such seized documents which were already considered in the Antriksh Group of Companies cannot be considered for making an addition in the hands of the assessee. In the circumstances, we do not find any infirmity in the observations made by the Ld. CIT(A) in para 6.10 at page 21 & 22 of his order and deleting the additions made by AO. Accordingly, revised grounds (i) & (ii) raised by the Revenue are dismissed and revised ground no.(iii) raised by the Revenue is allowed. Printed from counselvise.com ITA No.8988/Del/2019 20 16. In the result, the appeal filed by the Revenue is partly allowed as indicated above. Order pronounced in the open court on 19.11.2025 Sd/- Sd/- (BRAJESH KUMAR SINGH) (C.N. PRASAD) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 19.11.2025 *Kavita Arora, Sr. P.S. Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR ITAT, NEW DELHI Printed from counselvise.com "