Shri Mahesh Kumar Chopra, Ludhiana V. ITO, W-7(4), Ludhiana

ITA 1042/CHANDI/2019

• Counselvise Citation: [2020] 110 COUNSELVISE.COM (IT) 7898 (ITAT-CHANDIGARH)
• Duration Of Justice: 1 year(s) 1 month(s) 1 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 24-08-2020
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Next Hearing Date: 24-08-2020
• Assessment Year: 2016-2017
• Appeal Filed On: 23-07-2019
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Loose papers; Opportunity of being heard; Principle of natural justice; Additional evidence; Corroborative evidences; Set aside; FORM 26AS
• Section: 69; 44AD; 142(1); 143(2)

Judgement Text

, , IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BE NCH A, CHANDIGARH (VIRTUAL COURT) .., !' '# $, % &' BEFORE: SHRI. N.K.SAINI, VP & SHRI , SANJAY GARG, J M ITA NO. 1042/CHD/2019 ASSESSMENT YEAR : 2016-17 SH. MAHESH KUMAR CHOPRA HOUSE NO. 17, GREN PARK LUDHIANA THE ITO WARD-7(4), LUDHIANA PAN NO: AFMPC7629C APPELLANT RESPONDENT !' ASSESSEE BY : SHRI PARIKSHIT AGGARWAL, CA #!' REVENUE BY : SHRI DAYA INDER SINGH SIDHU, SR. DR $ %! & DATE OF HEARING : 24/08/2020 '()*! & DATE OF PRONOUNCEMENT : 24/08/2020 &(/ ORDER PER N.K. SAINI, VICE PRESIDENT THIS IS AN APPEAL BY THE ASSESSEE AGAINST THE ORDER DT. 01/05/2019 OF LD. CIT(A)-3, LUDHIANA. 2. FOLLOWING GROUNDS HAVE BEEN RAISED IN THIS APPEA L: 1. THAT THE LEARNED COMMISSIONER OF INCOME TAX (APPEAL S)-3, LUDHIANA HAS ERRED THE CONFIRMING THE ADDITION OF RS. 13,99,372/ - MADE BY THE LEARNED ASSESSING OFFICER ON ACCOUNT OF INVESTMENT MADE FOR THE PURCHASES/IMPORTS OF MACHINERY WITHOUT CONSIDERING THE SUBMISSIONS FIEL D BY THE APPELLANT DURING THE COURSE OF ASSESSMENT PROCEEDINGS AS WELL AS IN APPE LLATE PROCEEDINGS AND WITHOUT GIVING ANY OPPORTUNITY TO THE APPELLANT. TH EREFORE, ADDITION MADE BY THE LEARNED ASSESSING OFFICER FOR RS. 13,99,372/- AND CO NFIRMED BY THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS)-3, LUDHIANA IS ILLEGAL, UNWARRANTED, UNCALLED FOR AND NEEDS TO BE DELETED. 2. THAT THE LEARNED COMMISSIONER OF INCOME TAX (APPEAL S)-3, LUDHIANA HAS ERRED THE CONFIRMING THE ADDITION OF RS. 13,99,372/ - MADE BY THE LEARNED ASSESSING OFFICER ON ACCOUNT OF INVESTMENT MADE FOR THE PURCHASES/IMPORTS OF MACHINERY WITHOUT GIVING ANY PROPER OPPORTUNITY TO THE APPELLANT, WHEREAS 2 DURING THE COURSE OF ASSESSMENT PROCEEDINGS AS WELL AS IN APPELLATE PROCEEDINGS, COMPLETE DETAILS ALONG WITH NECESSARY INFORMATION O F SUCH IMPORTS WERE FILED BY THE APPELLANT. THEREFORE, ADDITION MADE BY THE LEAR NED ASSESSING OFFICER FOR RS. 13,99,372/- AND CONFIRMED BY THE LEARNED COMMISSION ER OF INCOME TAX (APPEALS)-3, LUDHIANA IS ILLEGAL, UNWARRANTED, UNCA LLED FOR THE NEEDS TO BE DELETED. 3. THAT THE APPELLANT CRAVES TO LEAVE OR TO AMEND THE GROUND OF APPEALS BEFORE OR AT THE TIME OF HEARING. 3. VIDE GROUND NO. 1 THE MAIN GRIEVANCE OF THE ASSE SSEE RELATES TO THE PROPER OPPORTUNITY NOT BEING GIVEN EITHER BY THE A. O. OR BY THE LD. CIT(A). 4. FACTS OF THE CASE IN BRIEF ARE THAT THE ASSESSEE E-FILED THE RETURN OF INCOME ON 12/10/2016 DECLARING AN INCOME OF RS. 2,84,780/- . LATER ON THE CASE WAS SELECTED FOR SCRUTINY. 5. DURING THE COURSE OF ASSESSMENT PROCEEDINGS THE A.O. NOTICED THAT THE ASSESSEE HAD IMPORTED MACHINERIES AMOUNTING TO RS. 36,00,000/- AND RS. 13,03,575/-. THE A.O. ISSUED THE QUESTIONNAIRE ALON GWITH NOTICE UNDER SECTION 142(1) OF THE ACT TO THE ASSESSEE ON 08/12/2018 . I N RESPONSE THE ASSESSEE SUBMITTED AS UNDER: 1. THAT THE ASSESSEE IS DOING THE BUSINESS OF MAN UFACTURING AND JOB WORK OF HOSIERY GOODS DURING THE YEAR UNDER CONSIDERATION. 2. THAT THE COPY OF INCOME TAX RETURN RECEIPT AND C OMPUTATION CHART OF INCOME IS FOR THE YEAR UNDER CONSIDERATION ATTACHED HEREWITH FOR YOUR KIND PERUSAL. THAT THE ASSESSEE HAS FILED HIS RETURN OF INCOME U/S 44AD OF THE INCOME TAX ACT, 1961 DURING THE YEAR UNDER CONSIDERATION. 3. THAT THE ASSESSEE HAS EARNED INCOME FROM BUSINES S OF MANUFACTURING AND JOB SHOWN IN THE COMPUTATION CHART OF INCOME. 4. THAT THE ASSESSEE HAS MAINTAINED FOLLOWING BANK ACCOUNTS: NAME OF THE RANK ADDRESS ACCOUNT NO. 3876201000187 ACCOUNT TYPE. CANARA BANK SME, SUNDER NAGAR, LUDHIANA 3876201000187 CURRENT PUNJAB NATIONAL BANK CHAURA BAZAR, LUDHIANA 240300100154907 SAVINGS 3 5. THAT, THE ASSESSEE HAS MADE THE IMPORT OF FOUR MAC HINES FROM OUTSIDE INDIA FOR RS. 36,00,000/-. THAT THE ASSESSEE HAS MA DE THE PAYMENT AGAINST THE IMPORT OF MACHINES AS UNDER: NARRATION AMOUNT DALE OF PAYMENT PAID THROUGH RTGS FROM CURRENT ACCOUNT WITH CANARA BANK 6,00,000/- 20.07.2015 PAID THROUGH RTGS FROM CURRENT ACCOUNT WITH CANARA BANK 3,00,000/- 21.07.2015 PAID THROUGH RTGS FROM CURRENT ACCOUNT WITH CANARA BANK 3.00,000/- 22.07.2015 PAID THROUGH RTGS FROM CURRENT ACCOUNT WITH CANARA BANK 4.00.000/ 31.07.2015 PAID THROUGH LOAN ACCOUNT BEARING NO. 3876766000045 WITH CUNARA BANK 18,00,000/- 06.08.2015 PAID CASH ON DIFFERENT DALES 2.00.000/- ON DIFFERENT DATES FURTHER, SUBMITTED THAT THE IMPORTS SHOWN AT SERIAL NO. 2 HAVING INVOICE VALUE OF RS. 13,03,575/- OF AIR INFORMATION PROVIDED BY YOUR HONOR TO THE ASSESSEE HAS NOT MADE BY THE ASSESSEE AND DOES NOT RELATES TO THE AS SESEE. 6. THAT THE COPY OF FORM 26AS, FOR THE YEAR UNDER C ONSIDERATION AS REQUIRED BY YOUR HONOR IS ATTACHED HEREWITH FOR YOUR KIND PE RUSAL. 5.1 THEREAFTER THE A.O. AGAIN ISSUED THE NOTICE DT. 18/12/2018 TO THE ASSESSEE WHICH READS AS UNDER: PLEASE REFER TO THE ASSESSMENT PROCEEDINGS IN YOUR CASE OF THE A. Y. 2016-17. 2. YOUR CASE FOR THE A. Y. 2016-17 WAS SELECTED FOR LIMITED SCRUTINY THROUGH CASS WITH THE REASON 'LARGE VALUE OF IMPORTS SHOWN IN THE EXPORT IMPORT DATA' AND NOTICE U/S 143(2) HAS BEEN ISSUED ON 18.09.2017 .WHICH IS SERVED UPON THE ASSESSEE THROUGH ITBA PORTAL & NOTICE SERVER OF THI S OFFICE. IN THE COURSE OF ASSESSMENT PROCEEDING, FOLLOWING N OTICES HAVE BEEN SENT TO YOU:- SR. NO. NOTICE U/S DATE OF NOTICE DATE OF RESPONSE TO BE SUBMITTED MODE OF SERVICE REMARKS 1 U/S 143(2) 18.09.2017 02.08.2016 THROUGH 1TBA & NOTICE SERVER NO RESPONSE SUBMITTED. 2 NOTICE U/S 142(1) ALONGWITH QUESTIONNAIRE 29/08/2018 10/09/2018 THROUGH 1TBA NO RESPONSE SUBMITTED 3 NOTICE U/S 142(1) ALONGWITH QUESTIONNAIRE 08.12.20 18 10.12.2018 THROUGH 1TB A NO RESPONSE SUBMITTED 4 4. ON PERUSAL OF ITS FOR THE A. Y 2016-17, IT IS NOT ICED THAT YOU HAVE PURCHASED THE MACHINERY AMOUNTING TO RS. 36,00,000/ - ON DATED 01.09.2015 & RS. 13,03,575/- ON DATED 15.09.2015. 5. ON PERUSAL OF YOUR REPLY DATED 17.12.2018, YOU HA VE SUBMITTED THAT YOU HAVE MADE THE IMPORT OF FOUR MACHINES FROM CHINA TO R RS 36.00,000/- ONLY THROUGH M/S ESS ESS FABRICS, LUDHIANA. BUT YOU DID NOT GIVE ANY DOCUMENTS/EVIDENCE REGARDING THE PURCHASE OF MACHIN ERY AMOUNTING TO RS.13,03,575/-. THEREFORE, YOU ARE GIVEN TO SHOW CA USE AS TO WHY ADDITION OF RS. 13,03,575/- MAY NOT BE MADE U/S 69 W.R.T. UNEXPLAIN ED INVESTMENT, IN YOUR RETURNED INCOME. IN THIS RESPECT, TO MEET THE ENDS OF NATURAL JUSTICE YOU ARE HEREBY ALLOWED FINAL OPPORTUNITY TO GIVE RESPONSE O N 20.12.2018. PLEASE NOTE THAT THE PROCEEDINGS IN YOUR CASE SHALL GET BARRED BY LI MITATION OF TIME BY 31.12.2018, HENCE, NO FURTHER ADJOURNMENT WILL BE ALLOWED. FAIL URE TO RESPOND TO THIS NOTICE WILL MEAN THAT YOU HAVE NOTHING TO SAY IN THE MATTE R, CONSEQUENTLY, YOUR CASE WILL BE DECIDED ON MERITS. NOTICE U/S 142(1) IS ENCLOSED HEREWITH. 5.2 IN RESPONSE TO THE ABOVE THE ASSESSEE SUBMITTED AS UNDER: 'THAT THE ASSESSEE HAS ALREADY DENIED THE IMPORT OF MACHINERY OF RS. 13,03,575/- FURTHER SUBMITTED THAT THE SHOW CAUSE NOTICE HAS BE EN ISSUED ON THE BASIS OF AIR INFORMATION. THAT THE BURDEN LIES ON THE DEPARTMENT TO PROVE THAT THE ASSESSEE HAS PURCHASED THE MACHINERY ON RECEIVED THE INFORMA TION RECEIVED BY YOUR HONOR AND REQUESTED TO YOUR HONOR TO GET THE DETAIL S INFORMATION REGARDING THE IMPORT OF THE MACHINERY ON RECEIVING THE INFORMATIO N FROM YOUR HONOR REPLY TO SHOW CAUSE NOTICE WILL BE FILED IN DETAILED'. 5.3 THE A.O. HOWEVER WAS NOT SATISFIED FROM THE SUB MISSIONS OF THE ASSESSEE AND MADE THE ADDITION OF RS. 13,99,372/- BY OBSERVI NG IN PARA 6 & 7 OF THE ASSESSMENT ORDER DT. 28/12/2018, AS UNDER: 6. ALL THE SUBMISSION DOCUMENTS FILED BY THE ASSESS EE ARE DULY PERUSED AND FOUND INCORRECT. IT IS PERTINENT TO MENTION HERE TH AT THE PRIMARY ONUS IS ALWAYS UPTO THE ASSESSEE TO PROVE THAT THE INFORMATION GIV EN BY HIM IS TRUE ALONGWITH SUPPORTING EVIDENCE. AS PER ITS INFORMATION AVAILAB LE WITH THIS DEPARTMENT THE ASSESSEE HAS PURCHASED THE MACHINERY AMOUNTING TO R S. 36,00,000/- ON DATED 01.09,2015 & RS. 13,03,575/- ON DATED 15.09.2015. THIS ITS DETAILS H AS BEEN FILED BY THE CENTRAL BOARD OF DIRECT TAXES (CBEC) WHICH IS F ULLY AUTHENTIC AND RELIABLE. THE SAME IS ALREADY CONFRONTED TO THE ASSESSEE. BUT THE ASSESSEE FAILED TO PROVE THAT THE INFORMATION RECEIVED BY THE CBEC IS NOT CORRECT AND ONLY SUBMITTED THAT THE INFORMATION WITH REGARD TO THE PURCHASE OF MACHINER Y HAVING INVOICED VALUE RS. 13,03,575/- IS NOT RELATED TO HIM AND SHIFTED THE B URDEN ON THE DEPARTMENT TO 5 PROVE THE GENUINENESS OF THE INFORMATION PROVIDED B Y THE CBEC ONLY THE FAG END OF THE E-ASSESSMENT WHEN IT IS GOING TO BE TIME BAR RED ON 31.12.2018. 7. BASED ON THE ABOVE FACTS AND CIRCUMSTANCES OF TH E CASE, THE SUBMISSION/EXPLANATION REGARDING THE PURCHASE OF MA CHINERY AMOUNTING TO RS.36,00,000/- IS ACCEPTED AND ADDITION OF RS. 13,9 9.372/ (INCLUDING ALL CHARGES), AS PER INFORMATION RECEIVED FROM THE CBEC THROUGH I TS DETAILS IS MADE U/S 69 OF THE INCOME-TAX ACT, 1961 W.R.T. UNEXPLAINED INVESTM ENT IN MACHINERY. 6. BEING AGGRIEVED THE ASSESSEE CARRIED THE MATTER TO THE LD. CIT(A) AND FURNISHED THE WRITTEN SUBMISSIONS WHICH HAS BEEN IN CORPORATED BY THE LD. CIT(A) AT PAGE NO. 3 TO 5 OF THE IMPUGNED ORDER, FOR THE C OST OF REPETITION THE SAME IS NOT REPRODUCED HEREIN. THE LD. CIT(A) SUSTAINED TH E ADDITION MADE BY THE A.O. BY OBSERVING IN PARA 5.2 & 5.3 OF THE IMPUGNED ORDE R AS UNDER: 5.2 DURING THE APPELLATE PROCEEDINGS THE ASSESSEE HAS CHALLENGED THE ADDITION OF RS. 13,03,575 /- ON ACCOUNT OF INVESTMENTS MADE FOR THE PURCHASE/IMPORTS OF MACHINERY WITHOUT CONSIDERING THE SUBMISSIONS FILED BY THE APPELLANT DURING THE COURSE OF ASSESSMENT PROCEEDINGS. THE ASSESSEE HAS STATED THAT HE HAS DENIED THE PURCHASES /IMPORTS OF MACHINERY WORTH RS.13,03, 575/- UNDER QUESTION DURING THE COURSE OF ASSESSMENT PROCEEDINGS. APART FROM IT THE ASSESSEE ALSO CHALLENGED THAT THE ADDITION STATING THAT, THE ASSESSEE WAS NO T GIVEN PROPER OPPORTUNITY BY THE ASSESSING OFFICER DURING THE ASSESSMENT YEAR AS THE ASSESSING OFFICER WAS REQUESTED TO SUPPLY THE DETAILED INFORMATION OF SUC H IMPORTS, BUT NO DETAILS WERE GIVEN BY THE ASSESSING OFFICER. I HAVE CAREFULLY CONSIDERED RIVAL SUBMISSION. AFTER CONSIDERING THE FACTS OF THE CASE I DO NOT FIND MYSELF IN AGREEMENT WITH THE CON TENTION OF ASSESSEE. IT IS SEEN THAT DURING APPELLATE PROCEEDINGS THE ASSESSEE HAS FILED SUBMISSION STATING THAT THE ASSESSEE HAS NOT PURCHASED THE MACHINERY WORTH RS. 13,03,575/- . THE ASSESSEE HAS FURTHER EXPLAINED THAT ASSESSEE HAS IM PORTED THE MACHINERY WORTH RS. 36 LAKH THROUGH M/S ESS ESS FABRICS, LUDHIANA A ND ALL THE NECESSARY FORMALITIES HAVE BEEN PERFORMED BY THE ASSESSEE FOR THE IMPORT. HOWEVER WHEN PURCHASE ORDER OF PURCHASE OF MACHINERY RS. 36 LAKH WAS COMP LETED BY THE M/S ESS ESS FABRICS, LUDHIANA .THEREAFTER M/S ESS FABRICS, LUDH IANA MISUSED SOME SIGNS LOOSE PAPERS LYING WITH IT AND DID NOT RETURN THESE DOCUM ENTS. LATER ON M/S ESS ESS FABRICS, LUDHIANA MADE FURTHER IMPORT MACHINERY OF RS. 13,03,575/- WITHOUT CONSENT OF ASSESSEE AND WITHOUT INFORMING TO THE AS SESSEE. THEREAFTER M/S ESS ESS FABRICS, LUDHIANA , FILED A CIVIL SUIT PROCEEDINGS AGAINST ASSESSEE WHEREIN THE ASSESSEE HAS BEEN ALLEGED TO ISSUE CHEQUES WHICH HA VE BEEN DISHONORED. IN THIS CONNECTION I HAVE GONE THROUGH THE COMPLAINT FILED BY M/S ESS ESS FABRICS, LUDHIANA AGAINST THE IN SIGNS CHEQUE ASSESSEE AND O THER DETAILS HAVE BEEN MENTIONED. AFTER CONSIDERING THE DETAILED SUBMISSIO N OF ASSESSEE EVIDENCE FILED BY THE ASSESSEE, I DO NOT FIND MYSELF IN AGREEMENT WITH CONTENTION OF ASSESSEE. APPARENTLY THESE ARE THE DOCUMENTS WHICH HAVE BEEN DULY SIGNED BY THE ASSESSEE AND IT FURTHER SHOWS THAT THE ASSESSEE HAD ISSUED CHEQUES TO THE M/S ESS ESS FABRICS LUDHIANA, WHICH HAVE BEEN DISHONORED. M OST IMPORTANTLY APPARENTLY 6 THIS EXPLANATION HAS NOT BEEN GIVEN BY THE ASSESSEE DURING THE ASSESSMENT PROCEEDINGS BEFORE THE ASSESSING OFFICER AS THE SAM E HAS NOT BEEN DISCUSSED BY THE ASSESSING OFFICER IN THE ASSESSMENT ORDER. APPA RENTLY THE ASSESSEE HAS NOT REQUESTED FOR ADMISSION OF ADDITIONAL EVIDENCE AND HAS RULE 46 A, THEREFORE EVEN THIS EXPLANATION CANNOT BE CONSIDERED AS THE SAME H AS NOT BEEN EXPLAINED BY THE ASSESSEE AT THE TIME OF ASSESSMENT PROCEEDINGS AND THE DOCUMENTS AS RELIED UPON BY THE ASSESSEE HAS NOT BEEN SUBJECTED TO VERI FICATION AND ENQUIRY BY THE ASSESSING OFFICER DURING THE ASSESSMENT PROCEEDINGS . THEREFORE THE SUBMISSION OF THE ASSESSEE HAS CANNOT BE CONSIDERED IN ABSENCE OF EXPLICIT REQUEST FOR ADMITTANCE OF ADDITIONAL EVIDENCE AND THE REASONS U NDER WHICH THE SAME COULD NOT BE FILED BEFORE THE ASSESSING OFFICER. 5.3 THE ASSESSEE HAS ALSO CHALLENGED THE ADDITION O N THE GROUND, THAT THE ASSESSEE WAS NOT GIVEN DUE OPPORTUNITY AT THE TIME OF ASSESSMENT PROCEEDINGS. AFTER CAREFUL CONSIDERATION OF THE FACTS I DO NOT F IND MYSELF IN AGREEMENT WITH THE ASSESSEE AS APPARENT FROM THE ASSESSMENT ORDER THE ASSESSEE WAS GIVEN DUE OPPORTUNITIES IN TIME AND AGAIN THE ASSESSEE WAS AS KED TO EXPLAIN THE PURCHASE OF MACHINERY TO IMPORT WORTH RS. 36,00,000/- AND RS . 13,03,575/- FOR WHICH THE ASSESSEE EVEN AFTER AVAILING OPPORTUNITIES FAILED T O EXPLAIN, WITH REGARD TO MACHINERY PURCHASE WORTH 13,03,575/- . ACCORDINGLY IN MY CONSIDERED VIEW SINCE THE ASSESSEE HAS FAILED TO EXPLAIN PURCHASE OF MACH INERY WORTH RS. 13,03,575/- , EVEN TO DISCHARGE ITS ONUS , THAT THE PURCHASE HAS NOT BEEN MADE BY HIM. ACCORDINGLY THE DISALLOWANCE MADE BY ASSESSING OFFI CER ON THIS ACCOUNT IS UPHELD. 7. NOW THE ASSESSEE IS IN APPEAL. 8. LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT ALL THE INFORMATION AND DETAILS WERE FURNISHED BEFORE THE A.O. AS WELL AS THE LD. C IT(A) WHO DID NOT CONSIDER THE SAME IN RIGHT PERSPECTIVE AND MADE THE IMPUGNED ADD ITION IN ARBITRARY MANNER WITHOUT PROVIDING PROPER OPPORTUNITY OF BEING HEARD TO THE ASSESSEE. HE REQUESTED TO SET ASIDE THIS CASE BACK TO THE FILE O F THE A.O. FOR FRESH ADJUDICATION AFTER CONSIDERING THE DOCUMENTS FURNISHED BY THE AS SESSEE BEFORE THE LD. CIT(A) AND GIVING DUE AND REASONABLE OPPORTUNITY OF BEING HEARD. 9. IN HIS RIVAL SUBMISSIONS THE LD. SR. DR ALTHOUGH SUPPORTED THE ORDERS OF THE AUTHORITIES BELOW BUT COULD NOT CONTROVERT THE AFOR ESAID CONTENTION OF THE LD. COUNSEL FOR THE ASSESSEE. 10. WE HAVE CONSIDERED THE SUBMISSIONS OF BOTH THE PARTIES AND PERUSED THE MATERIAL AVAILABLE ON THE RECORD. IN THE PRESENT CA SE IT APPEARS THAT THE 7 REASONABLE OPPORTUNITY OF BEING HEARD WAS NOT PROVI DED TO THE ASSESSEE BY THE A.O. AND THE LD. CIT(A) DID NOT CONSIDER THE EVIDEN CES FURNISHED BEFORE HIM FOR THE REASON THAT THE APPLICATION WAS NOT FURNISHED U NDER RULE 46A OF THE INCOME TAX RULES 1962 BY THE ASSESSEE. WE THEREFORE DEEM I T APPROPRIATE TO SET ASIDE THIS CASE BACK TO THE FILE OF THE A.O. TO BE ADJUDI CATED AFRESH IN ACCORDANCE WITH LAW AFTER PROVIDING DUE AND REASONABLE OPPORTU NITY OF BEING HEARD TO THE ASSESSEE. 11. IN THE RESULT, APPEAL OF THE ASSESSEE IS ALLOWE D FOR STATISTICAL PURPOSES. (ORDER PRONOUNCED ON 24/08/2020 ) SD/- SD/- '# $ .., (SANJAY GARG ) ( N.K. SAI NI) % &'/ JUDICIAL MEMBER / VICE PRESIDENT AG DATE: 24/08/2020 (+! ,-.- COPY OF THE ORDER FORWARDED TO : 1. THE APPELLANT 2. THE RESPONDENT 3. $ / CIT 4. $ / 01 THE CIT(A) 5. -2 45&456789 DR, ITAT, CHANDIGARH 6. 8:% GUARD FILE (+ $ BY ORDER, ; # ASSISTANT REGISTRAR