DISHA RESOURCES LTD. (FORMERLY KNOWN AS ARIHANT AVENUES AND CREDIT LIMITED.),AHMEDABAD V. THE ACIT, CENTRAL CIRCLE-2(1), AHMEDABAD

MA 87/AHD/2025

AI Insights

Disha Resources Ltd. filed Miscellaneous Applications under Section 254(2) of the Income Tax Act, 1961, seeking rectification of an earlier Tribunal order concerning disallowed donations claimed as deductions under section 35(1)(ii). The Tribunal had previously disallowed these deductions based on the institute's lack of approval during the relevant assessment years. The assessee argued that similar cases had been allowed deductions, citing specific judgments. However, the Tribunal, referencing the Supreme Court's decision in CIT Vs. M/s. Reliance Telecom Limited, emphasized that Section 254(2) is limited to correcting mistakes apparent from the record and does not extend to reviewing or re-appreciating evidence or case laws.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 788837 (ITAT-AHMEDABAD)
• Duration Of Justice: 2 month(s) 29 day(s)
• Appeal Type: Miscellaneous Application
• Pronouncement Date: 26-11-2025
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: SMC
• Assessment Year: misc
• Appeal Filed On: 28-08-2025
• Other Referred Cases: Kaustubhbhai Dhirajlal Patel V. DCIT, Chemstar International V. DCIT, JG Engineers (P) Ltd. Vs. ITO, ACIT Vs. Praveen Sushil Kanda, Kushal Virendra Tandon V. ACIT, Lord Real Estate (P) Ltd Vs. DCIT, Sopariwala Exports Pvt Ltd Vs. DCIT, SSL Exports Ltd Vs. DCIT, Mr. Sammy E. Major Vs. ACIT, ACIT Vs. Shirish Lakhamshi Keniya (HUF), Urnish Jewellers Vs. ACIT, M/s. Avis Life Care Pvt Ltd Vs. DCIT, ACIT Vs. M/s. J.M. Enviro Studies Pvt Ltd, Tushar Chawda V. ITO, Brigtech Valves & Controls Pvt. Ltd. V. DCIT, Circle - 1(1)(1), Ahmedabad, Joshi Technologies International Inc. V. Commissioner of Income-tax (IT & TP), Dattani And Co. V. Income Tax Officer
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Keywords: Set aside; Reassessment proceedings; Depreciation; Reopening of assessment; Cancellation of registration
• Section: 147; 12AA

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT MS. SUCHITRA R. KAMBLE, JUDICIAL MEMBER MA Nos. 86 & 87/Ahd/2025 (In ITA Nos. 534 & 535/Ahd/2025) Assessment Year: 2013-14 & 2014-15 Disha Resources Ltd., (Formerly known as Arihant Avenues and Credit Ltd.,) 3, Rajesh Apartment, Behind Navgujarat College, Sanyas Ashram road, Ahmedabad-380014 [PAN : AADCA 8197 Q] Vs. The Assistant Commissioner of Income-tax, Circle-2(1), Ahmedabad (Applicant) .. (Respondent) Applicant represented by : Shri Pritesh Shah, CA Respondent represented by: Shri Abhijit, Sr DR Date of Hearing 26.09.2025 Date of Pronouncement 26.11.2025 O R D E R PER DR. B.R.R. KUMAR, VICE-PRESIDENT:- These Miscellaneous Applications have been filed by the Assessee under section 254(2) of the Income Tax Act, 1961 (“the Act”) seeking rectification of the order dated 09.07.2025, passed by the Tribunal in ITA Nos. 534 & 535/Ahd/2025, pertaining to the Assessment Years 2013-14 & 2014-15. 2. The assessee has pointed out that certain mistakes apparent from record have occurred in the order of the Tribunal and the same require rectification. The contents of the assessee’s application dated 26.08.2025 are reproduced hereunder for ready reference:- “Sub.: An Application Under Section 254(2) of the Income Tax Act, 1961. With respect to the cautioned subject, we state, submit and explain herewith the following in respect of the order passed by the Honourable Bench of Income Tax Appellate Tribunal, Ahmedabad as per the details mentioned above. Printed from counselvise.com MA Nos. 86 & 87/Ahd/2025 Disha Resources Ltd Vs. ACIT Asst. Years : 2013-14 & 2014-15 - 2– We have made a perusal of the Order passed by the Honourable Bench and noted that there some mistakes apparent on record and which needs to be rectified, hence we apply for the rectification under section 254(2) of the Income Tax Act, 1961. These two errors are apparent on record. 01. The paper books contains the following Judgement of Ahmedabad ITAT which is directly applicable on this case due to the reason that the donation was given to same institution and allowed by ITAT, Ahmedabad. The copy of the above judgement was enclosed in the Paper Book as shown in the above chart. The crux of such judgement was stated in Para graph No 13 Page No. 15 of our paper book. The same is reproduced herewith. ITAT Ahmedabad - Kaustubhbhai Dhirajlal Patel V. DCIT - (2021) Tax Corp (A.T.) 88457. Judgement Crux: - Appellant has made payment of Rs. 15,00,000/- as donation for the A.Y. 2014- 15 to the institution i.e. School of Human Genetics & Population Health (SHG&PH) when the said institution has valid registration u/s 35(l)(ii) by and under Notification No. 35/2008/F. No. 203/135/2007/ITA II dated 14.03.2018. The said donee School of Human Genetics & Population Health is also a registered institution under Section 12AA of the Act and certificate of exemption under Section 80G(5) of the Act by the Commissioner of Income Tax (Exemption) Kolkata under letter dated 03.02.2005. Mistake No. 1 Failure To Consider the Judgements Submitted in Paper Book including Direct Decision with Same Facts of Ahmedabad ITAT in which Donation was given to the same Institution being School of Human Genetics & Population Health (SHG&PH) in Which Honourable Bench of ITAT, Ahmedabad has given decision in favour of assessee by allowing the donation deductible under section 35(l)(ii) of the Income Tax Act, 1961. Index Judgement Copy on Page Nos. Court / ITAT Case Law Name Reported At/Appeal No. Sr. No. Page No. From To 38 3 197 200 ITAT Ahmedabad Kaustubhbhai Dhirajlal Patel V. DCIT (2021) TaxCorp (A.T.) 88 Printed from counselvise.com MA Nos. 86 & 87/Ahd/2025 Disha Resources Ltd Vs. ACIT Asst. Years : 2013-14 & 2014-15 - 3– It is the case of the appellant that ^ince the registration of that institution was cancelled by the Ministry of Finance on 06.09.2016 at the time of making donation by the appellant the said institution was holding the genuine registration under Section 35(l)(ii) of the Act. And, therefore, on that score alone the disallowance herding the said institution engaged in laundering of unaccounted money is not sustainable in the eye of law, taking into consideration the date of cancellation of registration of the said institution as on 06.09.2016. Appeal filed by the assessee by deleting the disallowance made by revenue relating to the claim of donation made by the assessee to School of Human Genetics & Population Health (SHG&PH). We, therefore, delete such disallowance made by revenue. Assessee’s appeal is allowed. 02. Our Paper Book contains the submission of various case laws as per Index Sr. No.38 to 60 being Total 23 Case Laws out of which Sr. No.38 to 56 are in respect Donations made under section 35(1)(ii) of the Income Tax Act, 1961. Out of the above, the following are the judgements in which the donation made to School of Human Genetics & Population Health (SHG&PH) has been allowed as deductible under section 35(1)(ii). Donation Given to School of Human Genetics & Population Health (SHG&PH) Allowed by ITATs Index Judgement copy on page Nos. Court /ITAT Case Law Name Reported At / Appeal No. Sr. No. Page No. From To 38 3 197 200 ITAT Ahmedabad Kaustubhbhai Dhirajlal Patel V. DCIT (2021) TaxCorp (A.T.) 88457 39 3 201 207 ITAT Mumbai Chemstar International V. DCIT 2024 TaxmPub (DT) 6485 40 3 208 213 ITAT Kolkata JG Engineers (P) Ltd. Vs. ITO 2024 TaxPub (DT) 6485 41 3 214 221 ITAT Raipur ACIT Vs. Praveen Sushil Kanda (2022) 143 Taxmann.com 331 43 3 233 251 ITAT Mumbai Kushal Virendra Tandon V. ACIT (2022) 215 TTJ 630; (2021) 91 ITR_Trib (Trib) 610 44 3 252 257 ITAT Kolkata Lord Real Estate (P) Ltd Vs. DCIT 2022 TaxPub(DT) 3596 45 3 258 264 ITAT Mumbai Sopariwala Exports Pvt Ltd Vs. DCIT (2021) TaxCorp (AT) 90666 48 3 270 280 ITAT Kolkata SSL Exports Ltd Vs. DCIT (2020) TaxCorp (AT) 86353 49 3 281 287 ITAT Mumbai Mr. Sammy E. Major Vs. ACIT (2020) TaxCorp (AT) 83936 Printed from counselvise.com MA Nos. 86 & 87/Ahd/2025 Disha Resources Ltd Vs. ACIT Asst. Years : 2013-14 & 2014-15 - 4– 50 4 288 301 ITAT Mumbai ACIT Vs. Shirish Lakhamshi Keniya (HUF) (2020) TaxCorp (AT) 82762 51 4 302 306 ITAT Mumbai Urnish Jewellers Vs. ACIT [2019] 107 taxmann.com 19 53 4 312 325 ITAT Jaipur M/s. Avis Life Care Pvt Ltd Vs. DCIT ITA No. 989/JP/2018 54 4 326 337 ITAT Jaipur ACIT Vs. M/s. J.M. Enviro Studies Pvt Ltd ITA No. 1229/JP/2018 Date : 06.06.2019 56 4 342 345 ITAT Kolkata Tushar Chawda V. ITO (2018) Tax Corp (AT) 62550 Honourable Bench has applied the following Judgements, the facts of which are different as compared to our case. These two judgements has no application in our case. We request to consider the chart below. Mistake No.2 Application Two judgements whose facts are different and opposite as compared to our case Point of Distinction Case on Which ITAT Relied - Ahmedabad ITAT Facts of Our Case Brigtech Valves & Controls Pvt. Ltd. Joshi Technologies International Inc. Disha Resources Ltd.- Assessee Donation Given to Which Institute Shri Arvindo Institute of Applied Scientific Research Trust School of Human Genetics & Population Health (SHG & PH) Cancellation of Registration 31/03/2006. 06/09/2016. Assessment Year in Which Donation Was Given. 2012/13. 2015/16. 2013/14 Whether Donation was given Before or After Cancellation of Registration & Period. Donation Given After 5 Years After Cancellation of Registration Donation Given After 8 Years After Cancellation of Registration Donation Given Before 2 Years of Cancellation of Registration. Whether Approval U/s 35(1)(ii) was Available at the time of giving of Donation ? No Yes Printed from counselvise.com MA Nos. 86 & 87/Ahd/2025 Disha Resources Ltd Vs. ACIT Asst. Years : 2013-14 & 2014-15 - 5– Judgements on Which Honourable Bench of ITAT, Ahmedabad has relied. 03. Ahmedabad ITAT - Brightech Valves & Controls Pvt. Ltd. V. DCIT, Circle - 1(1)(1), Ahmedabad. Reported at (2025) TaxCorp (A.T.) 118572. Highlights Ineligible Weighted Deduction under Section 35(1 )(ii): The assessee’s claim for weighted deduction under section 35(1 )(ii) of the Income Tax Act for donation to an institute was challenged by the revenue, on the ground that the recipient institute was not approved for the relevant assessment year 2015-16. Approval of Institute Expired Before Relevant Year: It was found that the institute’s approval u/s 35(l)(ii) had expired on 31/03/2006, well before the impugned assessment year. CBDT Advisory dated December 2018 alerted field officers to this fact, confirming the institute's lack of approval for the period in question. Reliance on Precedent: The Tribunal placed reliance on its decision in Joshi Technologies International Inc [2023 (12) TMI 1161 - ITAT Ahmedabad], which dealt with an identical issue regarding donation to an unapproved institute and denial of the corresponding deduction. Detailed Analysis The primary legal controversy centered around whether the assessee was entitled to claim a weighted deduction under section 35(1)(ii) of the Income Tax Act, 1961, for a donation made to a scientific research institute whose approval had expired prior to the relevant assessment year, i.e., A.Y. 2015-16. The reopening of assessment under section 147 was based on the allegation that the assessee’s claim was ineligible since the recipient institute was not recognized under the requisite provisions during the period in question. Section 35(1)(ii) specifically allows a deduction for sums paid to an approved scientific research association, university, college, or other institution for the purpose of scientific research. However, such approval is a statutory precondition, as clarified through a combined reading of the section and Fraud Element Institute fraudulently receiving donation thereafter by forging documents showing - subsistence of approval. No Such observation found by us Printed from counselvise.com MA Nos. 86 & 87/Ahd/2025 Disha Resources Ltd Vs. ACIT Asst. Years : 2013-14 & 2014-15 - 6– relevant CBDT notifications. The record, as per the Commissioner of Income Tax (Appeals), revealed that the institute’s approval under section 35(1 )(ii) lapsed on 31/03/2006. Further, the CBDT’s Advisory (December 2018) communicated this lapse to all field officers, instructing them to not allow deduction for donations made to the said institute post approval expiry. This advisory was critical in guiding the field formation’s action for the relevant assessment year. The ITAT’s reliance on Joshi Technologies International Inc [2023 (12) TMI 1161 ITAT Ahmedabad] was pivotal. In that case, an identical issue was adjudicated: the Tribunal held that where the statutory approval under section 35(l)(ii) was not in force during the year of donation, the assessee could not claim the weighted deduction. The Tribunal emphasized that such approval is mandatory and donation made to an unapproved institute cannot qualify for deduction. Applying this rationale, the ITAT Ahmedabad in the present case found that since the institute’s approval had expired nearly nine years prior to the donation, the deduction was rightly disallowed in the reassessment proceedings. Conclusion In light of the factual determination that the institute’s approval under section 35(1 )(ii) had lapsed well before the impugned assessment year, the ITAT allowed the assessee’s appeal, holding that the reopening of assessment and consequent denial of deduction was justified. The Tribunal’s decision underscores the importance of verifying the approval status of recipient institutions at the time of making charitable donations if deduction is to be claimed under section 35 (1) (ii). Implications for Other Assessees Arising Out of the Decision This decision serves as a clear caution to taxpayers intending to claim weighted deductions under section 35(1 )(ii) for donations made to scientific research institutes. It is imperative for assessees to ascertain and document the approval status of the recipient institution as on the date of donation. Tax planning measures should include obtaining and preserving valid approval certificates or notifications for the relevant assessment year. In the event of a lapse in approval, any (deduction claimed may be subject to reopening of assessment and subsequent disallowance, as evidenced in this case. Moreover, taxpayers should regularly monitor CBDT advisories and notifications to avoid inadvertent non-compliance and resultant tax exposure. This case also highlights the significance of due diligence and Printed from counselvise.com MA Nos. 86 & 87/Ahd/2025 Disha Resources Ltd Vs. ACIT Asst. Years : 2013-14 & 2014-15 - 7– documentation in claiming tax incentives for charitable or scientific donations. Held The issue is squarely covered in the case of Joshi Technologies International Inc wherein held Institute, to which donation was made by the assessee during the impugned year and weighted deduction claimed thereon u/s. 35(1)(ii) of the Act, was not approved for the said purposes for the impugned year. The fact on record availably with the CIT is that the approval granted to the said Institute expired on 31/03/2006. Impugned year before us is A.Y 2015-16. The Advisory issued by the CBDT in December-2018 brought this fact to the notice of all its Field Officers. Therefore, the fact on record was that the said Institute was not approved for receiving donations u/s. 35(1 )(ii) of the Act during the impugned year 4. Ahmedabad ITAT - Joshi Technologies International Inc. V. Commissioner of Income-tax (IT & TP)* - [2023] 157 taxmann.com 275 /[2024] 204 ITD 496. INCOME TAX : Where assessee made donation to an institute in relevant financial year 2014-15, however, said institute was not approved for receiving donations under section 35(1 )(ii) during said year as approval granted to it was expired long back, impugned claim of assessee for weighted deduction for relevant assessment year 2015-16 was patently incorrect and, thus, order of Assessing Office:} allowing said claim was erroneous Section 35, read with section 263, of the Income-tax Act, 1961 – Scientific research expenditure (Donation) - Assessment year 2015-16 - Assessee- company made donation to a trust during year and claimed weighted deduction at rate of 175 per cent under section 35(1 )(ii) - Assessing Officer allowed same- Commissioner invoked revision jurisdiction on ground that approval granted to said institute for receiving donations under said section had expired long back - He thus set aside order of Assessing Officer - Whether since institute to which donation was made by assessee during relevant assessment year was not approved for said purposes for impugned year as approval granted to said institute expired long back, Assessing Officer had committed an error in allowing said claim of assessee for weighted deduction - Held, yes - Whether, thus, order of Assessing Officer allowing said claim was erroneous, and accordingly, impugned revision was justified - Held, yes [Paras 14 to 16] [In favour of revenue] Printed from counselvise.com MA Nos. 86 & 87/Ahd/2025 Disha Resources Ltd Vs. ACIT Asst. Years : 2013-14 & 2014-15 - 8– Circulars and Notifications : CBDT Instruction F. No. 225/351/2018-IT A (II),dated 14-12-2013; CBDT Notification, dated 30-10-2006 and CBDT Notification dated 14-5-2012. Case Laws Section 254 Bench should consider the judgements submitted. 05. Supreme Court:- Honda Siel Power Products Ltd. V. CIT - (2007) 295 ITR 466 : 213 CTR 425 : 165 TAXMAN 307 (SC). Conspectus Appeal (Tribunal)—Rectification of mistake under s. 254(2)—Mistake apparent—Non-consideration of order of co-ordinate Bench—One of the important reasons for giving the power of rectification to the Tribunal is to see that no prejudice is caused to either of the parties appearing before it by its decision based on a mistake apparent from the record—\"Rule of precedent\" is an important aspect of legal certainty in rule of law—That principle is not obliterated by s. 254(2)—When prejudice results from an order attributable to the Tribunal’s mistake, error or omission, then it is the duty of the Tribunal to set it right—Tribunal was justified in exercising its powers under s. 254(2) when it was pointed out that an order of the co- ordinate Bench placed before the Tribunal was not considered by it while passing the original order—Tribunal has acknowledged its mistake, it has accordingly rectified its order—The High Court was not justified in interfering with the said order. Held:- The assessee-company is engaged in the manufacture of portable generator sets in technical collaboration with Honda Motor Company, Japan. In this civil appeal, we are concerned with the asst. yr. 1991-92. On 30th Dec., 1991, a return of income was filed by the assessee declaring nil income. During the relevant year, the assessee had taken a term loan in foreign exchange for the import of machinery. On account of fluctuation in the foreign exchange rate, the liability of the assessee to repay the loan in terms of rupees went up by Rs. 7,10,910. By referring to the provisions of s. 43A, the assessee enhanced the figure of WDV (written down value) of the block of assets and claimed depreciation accordingly. The AO came to the conclusion that such revision in the actual cost was not admissible as s. 43A refers to adjustment qua the actual cost of the machinery on account of increase or decrease in the liability of unpaid loans utilized for the purchase of machinery. Aggrieved by the said decision, the matter was carried in appeal by the assessee before; the CIT(A) who took the view that the claim of the assessee Printed from counselvise.com MA Nos. 86 & 87/Ahd/2025 Disha Resources Ltd Vs. ACIT Asst. Years : 2013-14 & 2014-15 - 9– was admissible in view of the fact that in the year preceding the asst. yr. 1991- 92 increased depreciation was given to the assessee. On this aspect therefore, the Department carried the matter in appeal to the Tribunal (\"the Tribunal\") for both the asst. yrs. 1990-91 and 1991-92. By the judgment and order dt. 2nd April, 2002, the Tribunal held that the CIT(A) had erred in allowing the enhanced depreciation as under s. 43A actual payment was a condition precedent for availing of the benefit under that section. According to the Tribunal, if actual payment was not made after fluctuation then the value of the asset cannot be increased by adding the increase on account of fluctuation. On the facts, the Tribunal found that, in the present case, there was no actual payment after the fluctuation and, therefore, the assessee was not entitled to claim the benefit under s. 43A. \"Rule of precedent\" is an important aspect of legal certainty in rule of law. That principle is ne t obliterated by s. 254(2) of the IT Act, 1961. When prejudice results from an order attributable to the Tribunal's mistake, error or omission, then it is the duty of the Tribunal to set it right. Atonement to the wronged party by the Court or the Tribunal for the' wrong committed by it has nothing to do with the concept: of inherent power to review. In the present case, the Tribunal was justified in exercising its powers under s. 254(2) when it was pointed out to the Tribunal that the judgment of the co- ordinate Bench was placed before the Tribunal when the original order came to be passed but it had committed a mistake in not considering the material which was already on record. The Tribunal has acknowledged its mistake, it has accordingly rectified its order. In our view, the High Court was not justified in interfering with the said order. We are not going by the doctrine or concept of inherent power. We are simply proceeding on the basis that if prejudice had resulted to the party, which prejudice is attributable to the Tribunal's mistake, error or omission and which error is a manifest error then the Tribunal would be justified in rectifying its mistake, which had been done in the present case. For the afore stated reasons, the impugned judgment of the High Court is set aside and the order passed by the Tribunal allowing the rectification application filed by the assessee is restored. Consequently, the appeal is allowed with no order as to costs. 06. Gujarat High Court Dattani And Co. V. Income Tax Officer - [2014] 41 taxmann.com 330. Judgement Crux IT : Whenever any decision has been relied upon and/or cited by assessee and/or any party, Tribunal is bound to consider and/or deal with same and opine whether in facts and circumstances of particular case, same will be applicable or not Printed from counselvise.com MA Nos. 86 & 87/Ahd/2025 Disha Resources Ltd Vs. ACIT Asst. Years : 2013-14 & 2014-15 - 10– Section 254 of the Income-tax Act, 1961 - Appellate Tribunal - Order of [Duties of Tribunal] - Whether whenever any decision has been relied upon and/or cited by assessee and/or any party, Tribunal is bound to consider and/or deal with same and opine whether in facts and circumstances of particular case, same will be applicable or not - Held, yes - Whether, therefore, where Tribunal while disposing of appeal, failed to consider applicability assessee, impugned order passed by Tribunal was to be set aside and, matter was to be remanded back for disposal afresh - Held, yes [Para 4] [Matter remanded] Thanking You, Yours truly, For, Disha Resources Ltd. Sd/- Krishna Awater Kabra, Managing Director Place: Ahmedabad. Date : 26/08/2025.” 3. The Ld. DR opposed the MAs, submitting that section 254(2) permits rectification only of mistakes apparent from the record and does not allow a review, re-appreciation of evidence, or reconsideration of case laws. It was further submitted by the Ld. DR that the assessee is attempting to re-argue the appeal on merits, which is beyond the scope of this limited jurisdiction. 4. On this issue, we are guided by the judgement of Hon’ble Supreme Court in the case of CIT Vs. M/s. Reliance Telecom Limited, 133 taxmann.com 41, wherein it was held as under:- “…. The powers under Section 254(2) of the Act are only to correct and/or rectify the mistake apparent from the record and not beyond that. Even the observations that the merits might have been decided erroneously and the ITAT had jurisdiction and within its powers it may pass an order recalling its earlier order which is an erroneous order, cannot be accepted. As observed hereinabove, if the order passed by the ITAT was erroneous on Printed from counselvise.com MA Nos. 86 & 87/Ahd/2025 Disha Resources Ltd Vs. ACIT Asst. Years : 2013-14 & 2014-15 - 11– merits, in that case, the remedy available to the Assessee was to prefer an appeal before the High Court….” 5. Since the order has been passed after considering entire facts on record, the plea of the assessee, if accepted, will result into revision of the order which is beyond the purview of the provisions of Section 254 (2) of the Act. 6. In the result, the Miscellaneous Applications filed by the assessee are dismissed. The order is pronounced in the open Court on 26.11.2025 Sd/- Sd/- (SUCHITRA R. KAMBLE) (DR. B.R.R. KUMAR) JUDICIAL MEMBER VICE-PRESIDENT Ahmedabad; Dated 26.11.2025 btk आदेश की \u0007ितिलिप अ ेिषत/Copy of the Order forwarded to : 1. अपीलाथ\u0007 / The Appellant 2. \b थ\u0007 / The Respondent. 3. संबंिधत आयकर आयु\u0015 / Concerned CIT 4. आयकर आयु\u0015(अपील) / The CIT(A)- 5. िवभागीय \bितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad 6. गाड फाईल / Guard file. आदेशानुसार/ BY ORDER, True Copy सहायक पंजीकार (Dy./Asstt. Registrar) आयकर अपीलीय अिधकरण, , , , अहमदाबाद / ITAT, Ahmedabad 1. Date of dictation …………….25.11.2025…… 2. Date on which the typed draft is placed before the Dictating Member …25.11.2025……… 3. Other Member ………25.11.2025……… 4. Date on which the approved draft comes to the Sr.P.S./P.S ……25.11.2025…………… 5. Date on which the fair order is placed before the Dictating Member for pronouncement …26.11.2025………… 6. Date on which the fair order comes back to the Sr.P.S./P.S ……26.11.2025…………… 7. Date on which the file goes to the Bench ………26.11.2025………… 8. Date on which the file goes to the Head Clerk…………………………………... 9. The date on which the file goes to the Assistant Registrar for signature on the order 10. Date of Dispatch of the Order…………………………………… Printed from counselvise.com "