ITO, New Delhi V. Smt. Madhu Gupta, Delhi

ITA 1282/DEL/2016

• Counselvise Citation: [2020] 110 COUNSELVISE.COM (IT) 7252 (ITAT-DELHI)
• Duration Of Justice: 4 year(s) 5 month(s) 13 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 21-08-2020
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: F
• Assessment Year: 2007-2008
• Appeal Filed On: 08-03-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SARAS KUMAR SENIOR
• Assessee Lawyers: S KRISHNAN
• Keywords: Income from undisclosed sources; Assessment record; Reassessment proceedings
• Section: 13; 153; 147; 148; 144

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI DELHI DELHI BENCH BENCH BENCH BENCH F FF F : NEW DELHI : NEW DELHI : NEW DELHI : NEW DELHI (THROUGH VIDEO CONFERENCING) (THROUGH VIDEO CONFERENCING) (THROUGH VIDEO CONFERENCING) (THROUGH VIDEO CONFERENCING) BEFORE MR. JUSTICE P.P. BHATT, HONBLE PRESIDENT AN D BEFORE MR. JUSTICE P.P. BHATT, HONBLE PRESIDENT AN D BEFORE MR. JUSTICE P.P. BHATT, HONBLE PRESIDENT AN D BEFORE MR. JUSTICE P.P. BHATT, HONBLE PRESIDENT AN D SHRI SHRI SHRI SHRI G.S. PANNU G.S. PANNU G.S. PANNU G.S. PANNU, ,, , HONBLE HONBLE HONBLE HONBLE VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT ITA NO ITA NO ITA NO ITA NO . .. . 1282 1282 1282 1282 /DEL/20 /DEL/20 /DEL/20 /DEL/20 16 1616 16 ASSESSMENT YEA ASSESSMENT YEA ASSESSMENT YEA ASSESSMENT YEA R : 20 R : 20 R : 20 R : 20 07 0707 07 - -- - 08 0808 08 INCOME TAX OFF INCOME TAX OFF INCOME TAX OFF INCOME TAX OFF ICER, ICER, ICER, ICER, WARD 40(3), WARD 40(3), WARD 40(3), WARD 40(3), ROOM NO.1711, CIVIC CENTRE, ROOM NO.1711, CIVIC CENTRE, ROOM NO.1711, CIVIC CENTRE, ROOM NO.1711, CIVIC CENTRE, BLOCK E BLOCK E BLOCK E BLOCK E- -- -2, MINTO ROAD, 2, MINTO ROAD, 2, MINTO ROAD, 2, MINTO ROAD, NEW DELHI NEW DELHI NEW DELHI NEW DELHI 110 002. 110 002. 110 002. 110 002. VS. VS. VS. VS. SMT. MADHU GUPTA, SMT. MADHU GUPTA, SMT. MADHU GUPTA, SMT. MADHU GUPTA, FLAT NO.100, MILAN APARTMENT, FLAT NO.100, MILAN APARTMENT, FLAT NO.100, MILAN APARTMENT, FLAT NO.100, MILAN APARTMENT, WEST ENCLAVE, WEST ENCLAVE, WEST ENCLAVE, WEST ENCLAVE, PITAMPURA, PITAMPURA, PITAMPURA, PITAMPURA, DELHI. DELHI. DELHI. DELHI. PAN : AEQPG8724F. PAN : AEQPG8724F. PAN : AEQPG8724F. PAN : AEQPG8724F. (APPELLANT) (RESPONDENT) APPELLANT BY : S HRI SA RAS KUMAR, SENIOR DR. RESPONDENT BY : SHRI S. KRISHNAN, ADVOCATE. DATE OF HEARING : 02.06.2020 02.06.2020 02.06.2020 02.06.2020 DATE OF PRONOUNCEMENT : 21.08.2020 21.08.2020 21.08.2020 21.08.2020 ORDER ORDER ORDER ORDER PER G.S. PANNU PER G.S. PANNU PER G.S. PANNU PER G.S. PANNU, , , , VP VPVP VP : :: : THIS APPEAL BY THE REVENUE IS DIRECTED AGAINST THE O RDER OF LEARNED CIT(A)-14, NEW DELHI DATED 2 ND DECEMBER, 2015 WHICH, IN TURN, HAS ARISEN FROM THE ORDER PASSED BY THE ASSESSING OFFICER D ATED 20 TH MARCH, 2014, PERTAINING TO ASSESSMENT YEAR 2007-08. 2. IN THIS APPEAL, THE REVENUE HAS RAISED THE FOLLOWI NG GROUNDS OF APPEAL :- ON THE FACTS AND CIRCUMSTANCES OF THE CASE, THE LD.CIT (A) ERRED IN :- ITA-1282/DEL/2016 2 1. QUASHING THE ASSESSMENT PROCEEDINGS MADE U/S 147/144 OF THE ACT BY IGNORING THE FACT THAT THE NO TICE WAS ISSUED AND DEEMED SERVED UPON ASSESSEE, AS THE NOTICE WAS NOT RECEIVED BY THE AO, ON THE SAME ADDRESS WHICH WAS PROVIDED BY THE ASSESSEE IN HER PAN APPLICATION, WHI CH IS THE ONLY ADDRESS RECOGNIZED BY THE ITD SYSTEM. HE AL SO OVERLOOKED THE FACT THAT IT IS THE DUTY OF THE ASSESSEE TO CAUSE TO MAKE CHANGE OF ADDRESS IN HER PAN DATA. 2. NOT APPRECIATING THE FACT THAT IN THE ABSENCE OF ANY EXPLANATION, THE AO HAD RIGHTLY TREATED THE INCOME OF RS.7.09 CRORES AS INCOME FROM UNDISCLOSED SOURCES. 3. THE APPLICANT CRAVES THE RIGHT TO ADD, ALTER OR A MEND ANY GROUND OF THE APPEAL BEFORE OR DURING THE COURSE OF THE APPEAL. 3. THE RESPONDENT-ASSESSEE BEFORE US IS AN INDIVIDUAL, IN WHOSE CASE, THE ASSESSING OFFICER ISSUED NOTICE UNDER SECTION 14 8 OF THE INCOME-TAX ACT, 1961 (IN SHORT THE ACT) FOR THE ASSE SSMENT YEAR 2007- 08 AND ASSESSED THE INCOME AT `7.09 CRORES. PERTINENTLY , THE SAID INCOME WAS TREATED BY THE ASSESSING OFFICER AS AN INCOME ESCAPING ASSESSMENT WITHIN THE MEANING OF SECTION 147/148 OF THE ACT ON THE BASIS OF THE INFORMATION RECEIVED FROM THE INVESTIGATI ON WING WITH REGARD TO THE TRANSACTIONS OF LAND IN VARIOUS VILLAGES OF HARYANA, WHEREBY THE ASSESSEE WAS FOUND TO HAVE ENTERED INTO SALE TRANSACTIONS OF LAND OF THE VALUE OF `7.09 CRORES. THE PRESENT AP PEAL OF THE REVENUE IS PRIMARILY AGAINST THE DECISION OF THE LEARN ED CIT(A), WHEREBY IT HAS BEEN HELD THAT THE INITIATION OF THE IMPUGNED ASSESSMENT PROCEEDINGS UNDER SECTION 147/148 OF THE ACT BY THE ASSESSING OFFICER IS BAD IN LAW. THE DECISION OF THE LEA RNED CIT(A) IS BASED ON HIS FINDING THAT THE NOTICE UNDER SECTION 14 8 OF THE ACT FOR INITIATION OF ASSESSMENT/REASSESSMENT PROCEEDINGS UNDER SEC TION 147 WAS NEVER SERVED ON THE ASSESSEE. NOTABLY, THE ASSESSMENT OR DER HAS BEEN PASSED BY THE ASSESSING OFFICER UNDER SECTION 148 RE AD WITH SECTION 144 OF THE ACT, AND PARAGRAPH 4 OF THE ASSESSME NT ORDER ITA-1282/DEL/2016 3 REVEALS THAT EVEN IN THE COURSE OF ASSESSMENT PROCEEDINGS, NO APPEARANCE WAS MADE BY THE ASSESSEE OR ANY AUTHORIZED PE RSON ON HER BEHALF. BE THAT AS IT MAY, AT THE OUTSET, WE CON FINE OURSELVES TO THE CAPTIONED GRIEVANCE OF THE REVENUE WHEREBY THE AFORESAID FINDING OF THE LEARNED CIT(A) IS SOUGHT TO BE ASSAILED. 4. SECTION 147 OF THE ACT EMPOWERS AN ASSESSING OFFICER TO BRING TO TAX ANY INCOME CHARGEABLE TO TAX WHICH HAS ESCAPED ASS ESSMENT FOR ANY ASSESSMENT YEAR, SUBJECT TO THE PROVISIONS OF SECTION 148 TO 153 OF THE ACT. BEREFT OF OTHER DETAILS, IT WOULD SUFFICE F OR US TO NOTICE THAT SECTION 148 OF THE ACT MANDATES THAT BEFORE MAKING T HE ASSESSMENT, REASSESSMENT OR RECOMPUTATION UNDER SECTION 147 OF THE ACT THE ASSESSING OFFICER SHALL SERVE ON THE ASSESSEE A NOTICE REQU IRING HIM TO FURNISH WITHIN SUCH PERIOD, AS MAY BE SPECIFIED IN THE NOTICE, A RETURN OF HIS INCOME . THE AFORESAID PROVISION HAS BEEN REFERRED TO BY TH E CIT(A) TO SAY THAT IN THE PRESENT CASE, THE MANDATORY REQUIREMENT OF SERVICE OF NOTICE UNDER SECTION 148 OF THE ACT ON TH E ASSESSEE WAS NOT COMPLIED WITH. THE SAY OF THE LEARNED DR BEFORE US I S THAT THE NOTICE WAS ISSUED BY THE ASSESSING OFFICER ON THE ADDRESS KNOWN TO THE DEPARTMENT AND IN THE ABSENCE OF THE SAME HAVING BEEN RECEIVED BACK UNSERVED, IT WAS DEEMED TO HAVE BEEN SERVED. IN THIS MANNER, THE LEARNED DR HAS SOUGHT TO ASSAIL THE FINDINGS OF THE CIT(A). 5. ON THE CONTRARY, THE LEARNED REPRESENTATIVE FOR T HE RESPONDENT- ASSESSEE POINTED OUT THAT THIS IS A CASE OF NO SERVICE OF NOTICE ON THE ASSESSEE INASMUCH AS THE STATUTORY NOTICE OF SECTION 148 O F THE ACT WAS SENT TO THE WRONG ADDRESS OF THE ASSESSEE, WHILE THE CO RRECT ADDRESS WAS KNOWN TO THE DEPARTMENT. IT WAS, THEREFORE , CONTENDED THAT THE CIT(A) MADE NO MISTAKE IN TREATING THE IMPU GNED ASSESSMENT PROCEEDINGS AS BAD IN LAW. THE LEARNED COUNSEL FURTHE R REFERRED TO THE DETAILED DISCUSSION MADE BY THE CIT(A) IN THE IMPUGNED ORDER TO POINT ITA-1282/DEL/2016 4 OUT THAT THE FINDING OF THE CIT(A) WAS BASED ON THE S UBMISSIONS PUT FORTH BY THE ASSESSEE AND ALSO THE CIT(A)S INSPECTION OF THE ORIGINAL ASSESSMENT RECORDS PRODUCED BY THE ASSESSING OFFICER DURING APPELLATE PROCEEDINGS. 6. WE HAVE CAREFULLY CONSIDERED THE RIVAL SUBMISSIONS. THE STATUTORY REQUIREMENT OF ISSUANCE AND SERVICE OF NOTICE UNDER SECTION 148 OF THE ACT AS MANDATED IS SINE QUA NON FOR A VALID ASSESSMENT. IN THE INSTANT CASE, AS THE RELEVANT DISCUSSION IN THE ORD ERS OF AUTHORITIES BELOW REVEAL THAT THE RESPONDENT-ASSESSEE IS A REGULAR I NCOME TAX ASSESSEE. IN THE PAPER BOOK FILED BEFORE US, WHICH CON TAINS DOCUMENTS AVAILABLE ON THE RECORD OF THE DEPARTMENT, IT IS REV EALED THAT IN ASSESSMENT YEAR 2007-08, ASSESSEE FILED A RETURN OF INCOME ON 27 TH MARCH, 2008, A COPY OF WHICH IS PLACED AT PAGE 32 OF THE PAPER BOOK. SIMILARLY, FOR ASSESSMENT YEAR 2008-09, RETURN OF INCO ME WAS FILED ON 27 TH MARCH, 2009, A COPY OF WHICH IS PLACED AT PAGE 33. FOR ASSESSMENT YEAR 2009-10 ALSO, THE RETURN OF INCOME WAS F ILED BY THE ASSESSEE ON 29 TH JANUARY, 2010, A COPY OF WHICH IS PLACED AT PAGE 34 . A COMMON FEATURE IN ALL THESE RETURNS WAS THAT THE ASSESS EE STATED THE ADDRESS OF MILAN APARTMENTS, PITAMPURA, DELHI. WE SHAL L ADVERT TO THE RELEVANCE OF THE AFORESAID ADDRESS LATER IN THE ORDER. SIMILARLY, PAGES 35, 36 & 37 OF THE PAPER BOOK ARE COPIES OF THE RETU RNS OF INCOME FILED BY THE ASSESSEE FOR ASSESSMENT YEAR 2010-11, 2011-12 AND 20 12-13 RESPECTIVELY. 7. NOTABLY, ON 29 TH NOVEMBER, 2010, THE ASSESSING OFFICER RECEIVED THE INFORMATION FROM THE INVESTIGATION WING REGARDIN G TRANSACTIONS OF SALE OF LAND LOCATED AT MAIDAWAS, GURGAON, HARYANA UN DERTAKEN BY THE ASSESSEE ON 25 TH SEPTEMBER, 2006 FOR A CONSIDERATION OF `7.09 CRORES . BASED ON THE SAID INFORMATION, THE ASSESSING OFFICER PROC EEDED TO INITIATE PROCEEDINGS UNDER SECTION 147/148 OF THE A CT BY ISSUING NOTICE ITA-1282/DEL/2016 5 UNDER SECTION 148 OF THE ACT DATED 25 TH MARCH, 2013. IN THE COURSE OF THE HEARING BEFORE US, OUR REFERENCE WAS ALSO INVITED TO PAGE 58 OF THE PAPER BOOK WHEREIN A COPY OF AVERMENTS MADE TO THE C IT(A) AFTER INSPECTION OF ASSESSMENT RECORDS, HAS BEEN PLACED, WHEREIN IT IS CONTENDED THAT ON 13 TH AUGUST, 2012, A LETTER WAS ISSUED TO THE ASSESSEE SEEKING INFORMATION ABOUT INCOME TAX RETURNS FOR ASSESSMENT YEAR 2005-06 TO 2013-14 AT THE ADDRESS 501, HAWA SINGH BLOCK, ASIAD GAMES VILLAGE, NEW DELHI-110049 . IT IS FURTHER AVERRED THEREIN THAT SUCH LETTER WAS RETURNED UNSERVED WITH THE POSTAL REMAR K OF ADDRESSEE LEFT. A COPY OF THE NOTICE ISSUED UNDER SE CTION 148 OF THE ACT DATED 25 TH MARCH, 2013, PLACED AT PAGE 47 OF THE PAPER BOOK REVEALS THAT THE SAME IS ADDRESSED TO THE ASSESSEE AT THE AD DRESS 501, HAWA SINGH BLOCK, ASIAD GAMES VILLAGE, NEW DELH I-110049 . IN ORDER TO COMPLETE THE FACTUAL MATRIX, IT IS ALSO PERT INENT TO NOTE FROM THE MATERIAL BEFORE US THAT FOR ASSESSMENT YEAR 2013-14 , ASSESSEE FILED THE RETURN OF INCOME ON 24 TH JULY, 2013 DEPICTING THE MILAN APARTMENTS, PITAMPURA, DELHI, ADDRESS AS FOR ASSESSMENT YE ARS 2007- 08 TO 2012-13. 8. ANOTHER PERTINENT ASPECT IS THAT THE NOTICES TO THE ASSESSEE ISSUED UNDER SECTION 148 OF THE ACT AS WELL AS OTHER NO TICES REFERRED TO IN PARAGRAPH 4 OF THE ASSESSMENT ORDER ISSUED IN THE COUR SE OF IMPUGNED ASSESSMENT PROCEEDINGS, WERE ISSUED AT ASIAD VILLA GE ADDRESS BY THE ITO, WARD-23(1). THE IMPUGNED ASSESSMENT ORDER UNDER SECTION 148 READ WITH SECTION 147 OF THE ACT DATED 20 TH MARCH, 2014 HAS ALSO BEEN PASSED BY THE ITO, WARD-22(1), WHICH WAS AGAIN SENT TO THE ASIAD GAMES VILLAGE ADDRESS. 9. OSTENSIBLY, IN THE RETURNS OF INCOME FILED BY THE A SSESSEE FOR ASSESSMENT YEAR 2007-08 TO 2013-14, AS CHRONOLOGIZED IN THE EARLIER PARAGRAPHS, WERE FILED PRIOR TO THE ISSUANCE OF NOTIC E UNDER SECTION ITA-1282/DEL/2016 6 148 OF THE ACT DEPICTING MILAN APARTMENTS ADDRESS. TH E PERMANENT ACCOUNT NUMBER OF THE ASSESSEE BEING AEQPG8724F WAS AL SO DEPICTED ON EACH OF THE RETURNS AND THE RETURNS WERE FILED WITH INCOME TAX OFFICER, WARD-25(1), NEW DELHI. THE FINDING OF THE CIT(A), WHICH IS IN CHALLENGE BEFORE US, IS AS UNDER :- IT IS CLEAR AND EVIDENT THAT IN THIS CASE THE STATUTO RY NOTICES WERE SENT ON THE WRONG ADDRESS OF THE ASSESSEE AND NO SERVICE OF THE SAME WERE MADE. ON THE OTHER H AND THE LD.AR HAS PROVED THAT THE APPELLANT IS REGULAR IN COME TAX ASSESSEE AND SHE IS FILING HER IT RETURNS REGULARLY W ITH THE ITO 25(1), NEW DELHI. ON INSPECTION OF THE ORIG INAL ASSESSMENT RECORDS PRODUCED BY THE LD. AO IT HAS BEEN OBSERVED THAT THERE WAS NO SERVICE OF THE NOTICE U/S 14 8 OF THE ACT. 10. WE FIND THAT THE LEARNED CIT(A) HAS ARRIVED AT THE AFORESAID FINDING AFTER OBTAINING A REMAND REPORT FROM THE ASSE SSING OFFICER AS WELL AS INSPECTING THE ORIGINAL ASSESSMENT RECORDS PRODUCE D BY THE ASSESSING OFFICER BEFORE HIM. THE FACTUAL MATRIX NOTED BY US IN THE EARLIER PARAGRAPHS CLEARLY SUPPORTS THE FINDING ARRIVE D AT BY THE CIT(A) INASMUCH AS THE NOTICE UNDER SECTION 148 OF THE ACT D ATED 25 TH MARCH, 2013 WAS NOT CORRECTLY ADDRESSED AND THEREFORE, ASSESSEE COULD NOT RESPOND AND AN EX-PARTE ASSESSMENT ORDER WAS PASSED UNDER S ECTION 144 READ WITH SECTION 148 OF THE ACT. CURIOUSLY, TH E COPY OF THE NOTICE DATED 25 TH MARCH, 2013, PLACED AT PAGE 47 OF THE PAPER BOOK R EVEALS A HANDWRITTEN OFFICE NOTE BY THE NOTICE SERVER STATING THAT THE ASSESSEE IS NOT AVAILABLE AT THE ASIAD GAMES VILLAGE ADDRESS BEC AUSE THE ASSESSEE IS SAID TO HAVE MOVED OUT FROM THE SAID PREMISES. EVEN AT THIS STAGE, WE FIND NO TANGIBLE ACTION ON THE PART OF THE ASSESSING OFFICER TO ASCERTAIN THE CORRECT WHEREABOUTS OF THE A SSESSEE. IN FACT, THE CORRESPONDENCE PLACED AT PAGES 41 TO 51 REVEAL TH AT IT IS ONLY AFTER PASSING OF THE IMPUGNED ASSESSMENT ORDER ON 20 TH MARCH, 2014 (AT THE ITA-1282/DEL/2016 7 OLD ADDRESS), THAT THE ASSESSING OFFICER, I.E., ITO, WARD -22(1) WROTE TO THE SPECIAL CELL ASKING FOR THE PROFILE DATA OF THE ASSESSEE; AND, THIS EXERCISE LEAD TO THE REVELATION OF THE CORRECT ADDRE SS AND THE ASSESSMENT JURISDICTION OF THE ASSESSEE. IT IS CLEAR THAT S UCH AN ACTION WAS VERY MUCH BELATED ON THE PART OF THE ASSESSING OFFIC ER. THE ASSESSING OFFICER, AT THE TIME OF ISSUANCE OF NOTICE UNDE R SECTION 148 OF THE ACT, WAS EXPECTED TO BE VIGILANT AND DUTY-BOU ND TO ACCESS THE CORRECT ADDRESS AND JURISDICTION OF THE ASSESSEE INSTEAD OF MECHANICALLY SENDING THE NOTICE AT THE OLD ADDRESS OF THE ASSESSEE. AT LEAST, WHEN THE ASSESSING OFFICER WAS INFORMED BY THE N OTICE SERVER [BY WAY OF OFFICE NOTE DATED 25 TH MARCH, 2013 (SUPRA)], THE ASSESSING OFFICER OUGHT TO HAVE TAKEN APPROPRIATE COURSE OF AC TION. THE SAID OMISSION ON THE PART OF THE ASSESSING OFFICER CULMINATED IN IMPARTING ILLEGALITY AND VOIDNESS TO THE ENTIRE PROCEEDINGS INIT IATED BY WAY OF NOTICE UNDER SECTION 148 OF THE ACT DATED 25 TH MARCH, 2014, WHICH HAVE BEEN RIGHTLY TREATED BY THE LEARNED CIT(A) AS B AD IN LAW. IN THIS VIEW OF THE MATTER, WE ARE UNABLE TO FIND ANY FAULT WITH THE AFORESAID FINDING OF THE CIT(A), WHICH IS NOT ONLY BORNE OUT O F RECORD, BUT IS ALSO CONSISTENT WITH THE LEGAL POSITION. 11. IN THIS VIEW OF THE MATTER, WE HEREBY AFFIRM THE ORDER OF LEARNED CIT(A) AND REVENUE FAILS IN THIS APPEAL. IN THE RESULT, THE APPEAL OF THE REVENUE IS DISMISSED. ORDER PRONOUNCED ON 21 ST AUGUST, 2020. SD/- SD/- ( (( ( JUS JUSJUS JUS TICE P.P. BHATT TICE P.P. BHATT TICE P.P. BHATT TICE P.P. BHATT ) )) ) (G.S. PANNU (G.S. PANNU (G.S. PANNU (G.S. PANNU ) )) ) PRESIDENT PRESIDENT PRESIDENT PRESIDENT VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT VK. ITA-1282/DEL/2016 8 COPY FORWARDED TO: - 1. APPELLANT : INCOME TAX OFFICER, WARD 40(3), INCOME TAX OFFICER, WARD 40(3), INCOME TAX OFFICER, WARD 40(3), INCOME TAX OFFICER, WARD 40(3), ROOM NO.1711, CIVIC CENTRE, ROOM NO.1711, CIVIC CENTRE, ROOM NO.1711, CIVIC CENTRE, ROOM NO.1711, CIVIC CENTRE, BLOCK E BLOCK E BLOCK E BLOCK E- -- -2, MINTO ROAD, NEW DELHI 2, MINTO ROAD, NEW DELHI 2, MINTO ROAD, NEW DELHI 2, MINTO ROAD, NEW DELHI 110 002. 110 002. 110 002. 110 002. 2. RESPONDENT : SMT. MADHU GUPTA, SMT. MADHU GUPTA, SMT. MADHU GUPTA, SMT. MADHU GUPTA, F FF FLAT NO.100, MILAN APARTMENT, WEST ENCLAVE, LAT NO.100, MILAN APARTMENT, WEST ENCLAVE, LAT NO.100, MILAN APARTMENT, WEST ENCLAVE, LAT NO.100, MILAN APARTMENT, WEST ENCLAVE, PITAMPURA, DELHI. PITAMPURA, DELHI. PITAMPURA, DELHI. PITAMPURA, DELHI. 3. CIT 4. CIT(A) 5. DR, ITAT ASSISTANT REGISTRAR