Nilesh Nandkumar Agarwal, Pune V. Income-tax Officer, Pune

ITA 1128/PUN/2017

• Counselvise Citation: [2019] 116 COUNSELVISE.COM (IT) 8136 (ITAT-PUNE)
• Duration Of Justice: 2 year(s) 2 month(s) 13 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 18-07-2019
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: B
• Next Hearing Date: 23-01-2019
• Assessment Year: 2012-2013
• Appeal Filed On: 05-05-2017
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: M K VERMA
• Assessee Lawyers: K SRINIVASAN
• Keywords: Business income; Business expenditure; Additional evidence; Corroborative evidences; Set aside
• Section: 143(3)

Judgement Text

] IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH B , PUNE BEFORE MS. SUSHMA CHOWLA, JM AND SHRI ANIL CHATURVEDI, AM . / ITA NO.1128/PUN/2017 / ASSESSMENT YEAR : 2012-13 SHRI NILESH NANDKUMAR AGARWAL, FLAT NO.1170/15B, YASHOLAXMI APARTMENT, REVENUE COLONY, SHIVAJINAGAR, PUNE. PAN : AELPA9995B. . / APPELLANT. V/S TH E INCOME TAX OFFICER, WARD-2(1), PUNE. . / RESPONDENT ASSESSEE BY : SHRI K. SRINIVASAN. REVENUE BY : SHRI M.K. VERMA. / ORDER PER ANIL CHATURVEDI, AM : 1. THIS APPEAL FILED BY THE ASSESSEE IS EMANATING OUT OF THE ORDER OF COMMISSIONER OF INCOME TAX (A) 2, PUNE DT.13.01.2017 FOR THE ASSESSMENT YEAR 2012-13. 2. THE RELEVANT FACTS AS CULLED OUT FROM THE MATERIAL ON R ECORD ARE AS UNDER :- ASSESSEE IS AN INDIVIDUAL WHO ELECTRONICALLY FILED HIS RETURN OF INCOME FOR A.Y. 2012-13 ON 14.11.2013 DECLARING TOTAL INCOME OF RS.6,87,660/-. THE CASE WAS SELECTED FOR SCRUTINY AND THER EAFTER ASSESSMENT WAS FRAMED U/S 143(3) OF THE ACT VIDE ORDER D T.27.03.2015 AND THE TOTAL INCOME WAS DETERMINED AT RS.37,04,600/-. AGGRIEVED BY / DATE OF HEARING : 02.07.2019 / DATE OF PRONOUNCEMENT: 18.07.2019 2 THE ORDER OF AO, ASSESSEE CARRIED THE MATTER BEFORE LD.C IT(A), WHO VIDE ORDER DT.13.01.2017 (IN APPEAL NO.PN/CIT(A)-2/ITO WD-2(1)/ PN/547/ 2015-16) DISMISSED THE APPEAL OF ASSESSEE. AGGRIEVED BY T HE ORDER OF LD.CIT(A), ASSESSEE IS NOW IN APPEAL BEFORE US AND HAS R AISED THE FOLLOWING GROUNDS : 1. THAT THE LEARNED CIT(A)-II HAS EARNED ERROR IN JUSTIFICATION TO CONFIRM THE ADDITION OF RS.30,16,939/- MADE BY THE INCOME T AX OFFICER, WARD 2 (1), PUNE ON ACCOUNT OF NON-GENUINE BUSINESS EXPENS ES. THE SAME MAY BE ALLOWED REDUCED ACCORDINGLY. 2. DURING THE COURSE OF APPELLATE PROCEEDING THAT T HE LEARNED CIT(A)-II HAS UNJUSTIFIED ENHANCED THE TOTAL INCOME EQUAL TO RS.8 8,66,000/- ON ACCOUNT OF UNEXPLAINED MONEY DEPOSITED IN SAVING BANK ACCOU NT. THE SAME MAY BE VERIFIED AND JUSTIFIED TO DELETE FROM ENHANCED T OTAL INCOME COMPUTED BY THE A.O. 3. BOTH THE GROUNDS BEING INTER-CONNECTED ARE CONSIDERED TOG ETHER. 4. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, AO NOTIC ED THAT ASSESSEE HAD DEPOSITED CASH OF RS.88,66,000/- IN THE SA VING BANK ACCOUNT WITH COSMOS BANK. THE ASSESSEE WAS ASKED TO EXPLAIN THE SOURCE OF CASH DEPOSITS. ASSESSEE INTER-ALIA SUBMITTED TH AT THE CASH DEPOSITS WERE OUT OF THE CASH REFLECTED IN CASH BOOK. A O NOTED THAT ASSESSEE DID NOT PRODUCE THE LEDGER, PURCHASE BILLS ETC. AO NOTED THAT IN THE ABSENCE OF RECORDS, THE BUSINESS ACTIVITIES STATED BY THE ASSESSEE WERE IN SERIOUS DOUBT. AO ALSO NOTED THAT ASSESSEE HA S SHOWN TOTAL SALES OF RS.59,28,343/- AND THE PURCHASES OF RS.27,76,34 5/- AND APART FROM INTEREST EXPENSES OF RS.24,36,192/- (WHICH WAS PAID BY CHEQUE) HAD ALSO CLAIMED EXPENDITURE OF RS.30,16,939/-. HE FURTHER N OTED THAT ALL THE PURCHASE BILLS WERE STATED TO BE IN CASH WHICH AC CORDING TO AO WAS HIGHLY IMPROBABLE, UNUSUAL AND DIFFICULT TO ACCEPT. AO T HEREFORE CONCLUDED THAT NO BUSINESS ACTIVITY WAS CARRIED OUT BY T HE ASSESSEE AND THE EXPENDITURE OF RS.30,16,939/- SHOWN BY THE ASSESSEE WAS WITHOUT ANY SUPPORTING EVIDENCE AND THEREFORE NEEDS TO BE DISALLO WED. HE ALSO 3 CONSIDERED THE SALES OF RS.59,28,343/- AS BEING INCOME FR OM OTHER SOURCES. AGGRIEVED BY THE ORDER OF AO, ASSESSEE CARRIE D THE MATTER BEFORE LD.CIT(A), WHO UPHELD THE ORDER OF AO AND ENHANCED THE ADDITION MADE BY AO BY OBSERVING AS UNDER : 4.3 I HAVE GONE THROUGH THE ENTIRE FACTS WITH RE GARD TO CASH DEPOSITS IN THE SAVINGS BANK ACCOUNT MAINTAINED BY THE APPELLAN T. THE APPELLANT DURING THE ASSESSMENT PROCEEDING ARGUED THAT THE CA SH DEPOSITS ARE OUT OF CASH BOOK AND THE SAME REPRESENT SALES MADE IN THE BUSINESS OF SEASONAL GOODS. HOWEVER, WHEN SPECIFICALLY REQUIRED TO EXPLAIN THE NATURE OF BUSINESS ALONG WITH SUPPORTING BILLS, VOU CHERS THEN IT WAS STATED THAT THESE FILES ARE MISSING AND CANNOT BE PRODUCED. DURING THE APPELLATE PROCEEDING AS WELL THE APPELLA NT REITERATED THE SUBMISSION MADE AND STATED THAT THE CASH DEPOSITS A RE MADE OUT ' OF CASH BALANCE IN THE CASH BOOK. IN REPLY TO THE E NHANCEMENT NOTICE, IT WAS FURTHER STATED THAT THE CASH BALANCE IS BEING CARRIED FORWARD FROM THE PRECEDING YEAR. THE ASSESSING OFFI CER HAS NOT PROPERLY ANALYZED THE CASH DEPOSITS AND HE HAS INCO RRECTLY RESTRICTED THE DISALLOWANCE/ADDITION TO THE EXTENT OF RS. 30,16,939/-. PARTICULARLY WHEN HE HAD GIVEN CLEAR FINDING IN THE ASSESSMENT ORDER THAT THERE IS NO EVIDENCE TO SHOW THAT THE ASSESSEE IS ACTUALLY CARRYING ON ANY BUSINESS ACTIV ITY. 4.3.1 THE SUBMISSION OF THE APPELLANT THAT THE CASH DEPOS ITS ARE OUT OF THE CASH BOOK IS NOT AN ACCEPTABLE PROPOSITI ON. IT APPEARS THAT SUBMISSION REGARDING . CASH BOOK IS AN AFTERTHOUGHT AS BECAUSE THE APPELLANT HAS FAILED TO PROVE GENUINENESS OF AN Y BUSINESS ACTIVITY OUT OF WHICH IT CLAIMS TO HAVE GENERATED T HE CASH. THE SAME STATUS CONTINUES DURING THE APPELLATE PROCEEDI NG ALSO AND HE HAS NOT BEEN ABLE TO EXPLAIN THE NATURE OF BUSINESS ACTIVITY BEING CARRIED ON OVER THE YEARS ALONG WITH ANY SUPPORTING DETAILS. THE CASH BOOK WHICH HE IS REFERRING IS NOTHING BUT SELF -MADE AS AN AFTERTHOUGHT AND WHICH IS UNAUDITED. FURTHERMORE HE , HAS NOT BEEN ABLE TO CORRELATE THE CASH BALANCE IN THE CASH BOOK OUT OF ANY BUSINESS TURNOVER OR ANY ACTIVITY. THE GENUINENESS OF THE CASH BOOK IS THEREFORE DOUBTFUL IN ABSENCE OF ANY SUPPOR TING EVIDENCE. PARTICULARLY KEEPING IN VIEW OF THE FACT THAT IT IS UNAUDITED AND ALSO NOT SUPPORTED BY ANY INDEPENDENT EVIDENCES REFLECTI NG GENERATION OF SUCH A HUGE AMOUNT OF CASH. I THEREFORE FIND NO MERIT IN THE CONTENTION OF THE APPELLANT WITH REGARD TO SOURCE O F CASH DEPOSITS FOR THE FOLLOWING REASONS : (I) CASH DEPOSITS IN THE BANK ACCOUNTS HAVE BEEN MA DE AT VERY HIGH FIGURES AND IT GOES UP TO RS. 50,00,000/- ON 2 4.03.2012. CONSIDERING THE MEAGRE TURNOVER OF THE APPELLANT DU RING THE YEAR, THE CASH DEPOSITS ARE HIGHLY DISPROPORTIONATE TO TH E TURNOVER/INCOME SHOWN BY THE APPELLANT. (II) THE ARGUMENT THAT SOURCE OF SOME CASH DEPOSITS ARE OUT OF CASH BOOK IS NOT AN ACCEPTABLE PROPOSITION AS BECAU SE THE GENUINENESS OF THE CASH BOOK IS ITSELF IN DOUBT AS THE SAME IS UNAUDITED AND SELF MADE AND ALSO NOT SUPPORTED BY ANY INDEPENDENT EVIDENCE REFLECTING GENERATION OF S O MUCH OF CASH. 4 (III) THE APPELLANT HAS FAILED TO FURNISH ANY DETAI LS SUCH AS PURCHASE/SALES BILLS OR EVIDENCE IN SUPPORT OF EXPE NSES TO PROVE HIS ARGUMENT REGARDING GENERATION OF CASH FROM BUS INESS. REFERRING THE SAME TO THE CASH BALANCE OF PRECEDING YEAR IS NOTHING BUT AN AFTERTHOUGHT AND THE SAME CANNOT BE ACCEPTED WITHOUT ANY SUPPORTING EVIDENCE . 4.3.2 THE LAW IS WELL SETTLED THAT THE ONUS OF PROV ING THE SOURCE OF A SUM OR MONEY FOUND TO HAVE BEEN RECEIVED BY AN AS SESSEE IS ON HIM. WHERE THE NATURE AND SOURCE OF A RECEIPT, WHET HER IT BE OF MONEY OR OTHER PROPERTY, CANNOT BE SATISFACTORILY E XPLAINED BY THE ASSESSEE, IT IS OPEN TO THE REVENUE TO HOLD THAT IT IS THE INCOME OF THE ASSESSEE AND NO FURTHER BURDEN LIES ON THE REVE NUE TO SHOW THAT THE INCOME IS FROM ANY PARTICULAR SOURCE - ROSHAN DI HATTI VS. CIT (107 ITR 938) (SC). LD.CIT(A) THEREAFTER REFERRED TO VARIOUS OTHER DECI SION IN PARA 4.3.3 TO 4.3.9 AND FINALLY MADE ENHANCEMENT BY OBSERVING AS UNDER : 4.3.10 IN THE LIGHT OF AFORESAID DISCUSSION ON FAC TS AS WELL AS DECISIONS CITED, IT IS HELD THAT THE APPELLANT HAS FAILED TO DISCHARGE HIS ONUS WITH REGARD TO SOURCE OF CASH DE POSIT IN HIS SAVINGS ACCOUNT TO THE TUNE OF RS. 88,66,000/- IN T HE LIGHT OF DETAILED DISCUSSION MADE IN THIS REGARD IN THE PREC EDING PARAGRAPHS. ACCORDINGLY THE AMOUNT OF RS.88,66,000 /- IS TREATED AS UNEXPLAINED MONEY OF THE APPELLANT U/S 69A OF THE I.T. ACT. THE ASSESSING OFFICER IS DIRECTED TO ENHANCE THE INCOME OF THE APPELLANT ACCORDINGLY. GROUNDS NO.1, 2 AND 3 ARE ACCORDINGL Y DISMISSED. AGGRIEVED BY THE ORDER OF LD.CIT(A), ASSESSEE IS NOW BEFORE US. 5. BEFORE US, LD.A.R. AT THE OUTSET SUBMITTED THAT IN THE GROUP CASE OF NILESH NANDKUMAR AGARWAL, ANESH NANDKUMAR AGARWAL A ND NANDKUMAR MAIDHAN AGARWAL IN (ITA NOS.760 TO 762/PUN/2 018 ORDER DATED 21.02.2019) ON IDENTICAL FACTS, THE ISSUE WAS REMAND ED BY THE CO-ORDINATE BENCH OF THE TRIBUNAL TO THE AO. HE ALSO PLAC ED ON RECORD THE COPY OF THE AFORESAID ORDER. HE SUBMITTED THAT THE P RESENT CASE BEING IDENTICAL TO THE GROUP CASE OF NILESH NANDKUMAR AGAR WAL, ANESH NANDKUMAR AGARWAL AND NANDKUMAR MAIDHAN AGARWAL (SUP RA), THE MATTER BE REMANDED TO THE FILE OF AO. LD. D.R. ON THE OTHE R HAND DID 5 NOT CONTROVERT THE SUBMISSIONS MADE BY LD.A.R. BUT HOW EVER SUPPORTED THE ORDER OF LOWER AUTHORITIES. 6. WE HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE MATERIAL ON RECORD. IN THE PRESENT CASE, THE AO BY HOLDING THAT THE RE WAS NO EVIDENCE OF ANY BUSINESS ACTIVITY AND THEREFORE HE DISALLOWE D THE BUSINESS EXPENSES OF RS.30,16,939/- THAT WAS CLAIMED BY AS SESSEE AND FURTHER TREATED THE SALES OF RS.59,28,383/- TO BE INCOME FROM OTHER SOURCES. WHEN THE MATTER WAS CARRIED BEFORE LD.CIT(A) W HO AFTER ANALYZING THE CASH DEPOSITS MADE ENHANCEMENT AND TREATED THE D EPOSITS OF RS.88,66,000/- AS UNEXPLAINED MONEY AND MADE ADDITION U/ S 69A OF THE ACT. 7. WE FIND THAT IDENTICAL ISSUE AROSE IN THE CASE OF NILESH NANDKUMAR AGARWAL, ANESH NANDKUMAR AGARWAL AND NANDKU MAR MAIDHAN AGARWAL (SUPRA), WHEREIN THE CO-ORDINATE BENCH OF THE TRIBUNAL VIDE ORDER DATED 21.02.2019 IN ITA NOS.760 TO 762 /PUN/2018 HAS REMITTED THE MATTER BACK TO AO BY OBSERVING AS UNDER : 3. BRIEFLY STATED, THE FACTS OF THE CASE ARE THAT THE ASSESSEE MADE CERTAIN CASH DEPOSITS IN HIS SAVINGS BANK ACCOUNTS MAINTAIN ED WITH COSMOS BANK, BANK OF INDIA AND HDFC BANK. ON BEING CALLED UPON TO PRESENT THE SOURCE OF SUCH DEPOSITS, THE ASSESSEE SUBMITTED THA T THE DEPOSITS WERE MADE OUT OF CASH BALANCE IN THE CASH BOOK. THE ASSE SSEE FURTHER EXPLAINED THAT THE RECEIPTS IN CASH BOOK WERE MAINL Y FROM CASH SALES. THE ASSESSING OFFICER (AO) REQUIRED THE ASSESSEE TO PRO DUCE THE BOOKS OF ACCOUNT WHICH THE ASSESSEE COULD NOT. IT WAS HOWEVE R MAINTAINED THAT HE MADE PURCHASES IN CASH AND ALSO EFFECTED SALES IN C ASH AND THE DEPOSITS IN THE BANKS WERE OUT OF SUCH CASH SALES. THE AO TO OK UP THE FIGURE OF CASH SALES AT RS.29,20,795/- AS INCOME FROM OTHER SOURCES. AFTER ALLOWING DEDUCTION ON ACCOUNT OF INTEREST AND CONSI DERING THE PROFIT ALREADY SHOWN BY THE ASSESSEE AT RS.12,30,197/- ALO NG WITH CERTAIN EXPENDITURE BOOKED AT RS.11,54,662/-, THE AO MADE A N ADDITION OF RS.23,84,860/-, COMPRISING OF DISALLOWANCE OF EXPEN DITURE AT RS.11.54 LAKH AND NON-GENUINE SALES. THE LD. CIT(A) SUSTAINE D THE ADDITION BY OBSERVING THAT THE ASSESSEE COULD NOT PRODUCE EVEN A SINGLE DOCUMENT TO SHOW THAT HIS BANK TRANSACTIONS REPRESENTED BUSINES S RECEIPTS. THE ASSESSEE HAS COME UP IN APPEAL AGAINST THE SUSTENAN CE OF SUCH AN ADDITION. 6 4. I HAVE HEARD BOTH THE SIDES AND PERUSED THE RELE VANT MATERIAL ON RECORD. THE ASSESSEE HAS FILED A PAPER BOOK COMPRIS ING OF 207 PAGES AS ADDITIONAL EVIDENCE. THE LD. AR CONTENDED THAT THE FILES CONTAINING PURCHASE VOUCHERS ETC. WERE MISPLACED AND COULD NOT BE LOCATED DURING THE COURSE OF PROCEEDINGS BEFORE THE AUTHORITIES BE LOW, AS THOSE WERE KEPT SEPARATE WHEN RENOVATION AND CONSTRUCTION WORK WAS GOING ON. A REQUEST WAS MADE THAT A FURTHER OPPORTUNITY SHOULD BE GIVEN TO THE ASSESSEE TO ADDUCE EVIDENCE IN SUPPORT OF GENUINENESS OF TRANSA CTIONS RECORDED IN HIS BANK ACCOUNTS, WHICH IS NOW AVAILABLE. IN VIEW OF T HE FACT THAT THE AUTHORITIES BELOW HAVE DISBELIEVED THE GENUINENESS OF TRANSACTIONS OF PURCHASES, SALES AND EXPENSES ON THE GROUND THAT SU PPORTING VOUCHERS WERE NOT AVAILABLE AND THE ASSESSEE IS NOW CLAIMING TO HAVE COLLECTED ALL SUCH EVIDENCE, I AM OF THE CONSIDERED OPINION THAT THE ENDS OF JUSTICE WOULD MEET ADEQUATELY IF THE IMPUGNED ORDER ON THIS SCORE IS SET-ASIDE AND THE MATTER IS RESTORED TO THE FILE OF AO. I ORD ER ACCORDINGLY AND DIRECT HIM TO FRAME THE ASSESSMENT AFRESH AFTER ALLOWING R EASONABLE OPPORTUNITY OF HEARING TO THE ASSESSEE. IT IS MADE CLEAR THAT T HE ASSESSEE WILL BE AT LIBERTY TO LEAD ANY FRESH EVIDENCE IN SUPPORT OF HI S CLAIM WHICH HE CONSIDERS EXPEDIENT. ITA NO. 761/PUN/2018 ANESH N. AGARWAL ITA NO.762/PUN/2018 NANDKUMAR M. AGARWAL 5. THE FACTS AND CIRCUMSTANCES OF THESE TWO APPEALS ARE ADMITTEDLY SIMILAR TO THOSE OF SH. NILESH N. AGARWAL. IN THE I TA NOS.760 TO 762/PUN/2018 NILESH N. AGARWAL AND 2 OTHERS 5 CASE OF SH. ANESH N. AGARWAL, THE LD. CIT(A) SUSTAINED THE ADDITION AT R S.10,56,852/-; WHEREAS IN THE CASE OF SH. NANDKUMAR M. AGARWAL, HE SUSTAINED THE ADDITION AT 13,98,470/-. SH. ANESH N. AGARWAL IS BR OTHER OF SH. NILESH N. AGARWAL, WHOSE APPEAL HAS BEEN DISPOSED OFF ABOVE. SH. NANDKUMAR M. AGARWAL IS FATHER OF SH. NILESH N. AGARWAL. IN VIEW OF THE FACT THAT THE FACTS AND CIRCUMSTANCES OF THESE TWO APPEALS ARE AD MITTEDLY SIMILAR, FOLLOWING THE VIEW TAKEN HEREINABOVE, I SET-ASIDE T HE IMPUGNED ORDERS AND REMIT THE MATTER TO THE FILE OF AO. I ORDER ACC ORDINGLY AND DIRECT THE AO TO FRAME THE ASSESSMENTS AFRESH IN CONFORMITY WI TH THE DIRECTIONS GIVEN IN THE CASE OF SH. NILESH N. AGARWAL ABOVE. BEFORE US, LD.A.R. SUBMITTED THAT THE ISSUE IN THE PRESEN T CASE IS IDENTICAL TO THE GROUP CASE OF NILESH NANDKUMAR AGARWAL, A NESH NANDKUMAR AGARWAL AND NANDKUMAR MAIDHAN AGARWAL (SUPRA) , WHEREIN THE MATTER HAS BEEN REMANDED TO THE AO. BEFORE US, R EVENUE HAS ALSO NOT POINTED OUT ANY DISTINGUISHING FEATURE IN THE FACTS OF T HE PRESENT CASE AND IN THE GROUP CASE OF NILESH NANDKUMAR AGARWAL, ANESH NANDKUMAR AGARWAL AND NANDKUMAR MAIDHAN AGARWAL (SUPRA). WE FIND THAT THE DECISION OF TRIBUNAL IN AFORESAID GROUP CASE HAS N OT BEEN SET ASIDE, STAYED OR OVER-RULED BY HIGHER JUDICIAL AUTHORITIES. WE THEREFORE RESPECTFULLY FOLLOWING THE DECISION OF CO-ORDINATE BENCH OF TH E TRIBUNAL IN THE GROUP CASE OF NILESH NANDKUMAR AGARWAL, ANESH NA NDKUMAR 7 AGARWAL AND NANDKUMAR MAIDHAN AGARWAL (SUPRA) AND IN VIEW OF THE FACT THAT THE ISSUE IN THE PRESENT CASE IS SIMILAR TO THE ISSUE IN THE AFORESAID CASE AND FOR SIMILAR REASONS, RESTORE THE ISSUE BACK TO THE FILE OF AO WITH SIMILAR DIRECTIONS. NEEDLESS TO STATE THAT AO S HALL GRANT ADEQUATE OPPORTUNITY OF HEARING TO THE ASSESSEE. ASSE SSEE IS ALSO DIRECTED TO PROMPTLY FURNISH ALL THE DETAILS CALLED FOR BY TH E LOWER AUTHORITIES. THUS, THE GROUNDS OF THE ASSESSEE ARE ALLOWED FOR STATISTICAL PURPOSES. 8. IN THE RESULT, THE APPEAL OF ASSESSEE IS ALLOWED F OR STATISTICAL PURPOSES. ORDER PRONOUNCED ON 18 TH DAY OF JULY, 2019. SD/- SD/- ( SUSHMA CHOWLA ) ( ANIL CHATURVEDI ) ! / JUDICIAL MEMBER '! / ACCOUNTANT MEMBER PUNE; DATED : 18 TH JULY, 2019. YAMINI #$%&'('% / COPY OF THE ORDER FORWARDED TO : 1. / THE APPELLANT 2. / THE RESPONDENT 3. 4. 5 6. CIT(A)-6, PUNE. PR. CIT-5, PUNE. '#$ %%&',) &', / DR, ITAT, B PUNE; $*+,/ GUARD FILE. / BY ORDER // TRUE COPY // -./%0&1 / SR. PRIVATE SECRETARY ) &', / ITAT, PUNE.