Smt. Shashi Prabha Tripathi, Jind V. ITO-Ward-2, Bhiwani(Camp at Jind)

ITA 135/CHANDI/2020

• Counselvise Citation: [2022] 106 COUNSELVISE.COM (IT) 7612 (ITAT-CHANDIGARH)
• Duration Of Justice: 2 year(s) 4 month(s) 7 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 13-06-2022
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: Not Allotted
• Assessment Year: 2010-2011
• Appeal Filed On: 05-02-2020
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Deemed to accrue or arise in india; Set aside
• Section: 147; 69; 148; 142(1); 133(6); 292BB; 69A; 43; 73; 13; 153; 22

Judgement Text

आयकर अपील य अ धकरण,च डीगढ़ यायपीठ “एकल सद यीय’, च डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH ‘SMC’ CHANDIGARH ीमती दवा संह, या#यक सद य BEFORE: SMT. DIVA SINGH, JM आयकर अपील सं./ ITA No. 135/CHD/2020 नधा रण वष / Assessment Year : 2010-11 Smt.Shashi Prabha Tripathi, W/o Dr.S.B.Tripathi, 90/15, Scheme No.5, Jind. बनाम VS The ITO, Ward 2, Bhiwani. थायी लेखा सं./PAN No: AHKPT6551C अपीलाथ /Appellant यथ /Respondent नधा रती क! ओर से/Assessee by : Shri Vibhore Garg, CA राज व क! ओर से/ Revenue by : Dr. Ranjeet Kaur, Sr.DR स ु नवाई क! तार&ख/Date of Hearing : 08.06.2022 उदघोषणा क! तार&ख/Date of Pronouncement : 14.06.2022 आदेश/ORDER The present appeal has been filed by the assessee wherein the correctness of the order dated 27.12.2019 of CIT(A) Hissar pertaining to 2010-11 assessment year is assailed on the following grounds : “1. Because the action is under challenge on facts & law for upholding the reassessment u/s 147/148 of the Act for determining the assessed income at an amount of Rs 43,81,250/-. 2. Because the action is under challenge on facts & law for treating the amount of Rs 41,21,700/- as deemed income u/s 69 A of the Income Tax Act, 1961. 3. Because the action is under challenge on facts & law while ignoring the pleadings, regarding nexus, purpose, character of the receipts and payments resultingly all the transactions completely explained yet erroneous decision making. ITA-135/CHD/2020 A.Y. 2010-11 Page 2 of 17 4. Because the action is under challenge on facts & law while the addition is being made then the deduction be allowed for the payment made and (or) the loss of capital be granted. 5. Because the action is under challenge on facts and law, the authorities below has never tried to issue notices u/s 131/133 to call & summon for the information/ affidavits from the management of the school and the students who has paid the fees to the appellant and subsequently the appellant's transfer of fees to the management of school which is substantiated through the ledger account of the appellant who was actually & factually receiving fees on behalf of the management of the school where she was a Principal during the year under consideration. 6. Because the prayer is for kindly allowing any addition, modification, deletion, amendment in the grounds of appeal along with the consequential benefit thereon before the disposal of the appeal in the interest of substantial justice for a decision in accordance with law. 2. The ld. AR inviting attention to the grounds raised submitted that vide ground No.1 the challenge is posed on the jurisdictional issue. Vide ground No.2 the challenge is posed to the merits of the addition sustained and the other grounds are in support of the merits of the addition. 3. Inviting attention to the assessment order it was his submission that he is not disputing the fact that notices as found mentioned in page 2 of the assessment order may have been sent. On each of these dates, it was submitted the remarks of the AO are that neither anybody attended nor any written communication has been received from the assessee. Thereafter, it was submitted that the AO’s records in the order that the case was assigned to the concerned AO etc. and accordingly fresh notices were sent on 18.10.2017 for 25.10.2017 wherein again no one was present. It was ITA-135/CHD/2020 A.Y. 2010-11 Page 3 of 17 submitted that thereafter, the AO records in his order “However, on 27.10.2017 again notice u/s 142(1) issued for 06.11.2017 and duly served upon the assessee at her new address i.e. H.No.12, Housing Board Colony, Jind. In response thereto, Sh. K.K.Arora, ITP, A.R. of the assessee appeared and filed 'Power of Attorney', which is placed on records and case adjourned to 14.11.2017 ...........” It was his submission that the assessee in response thereto filed a reply as found mentioned at page 3 of the assessment order on 29.11.2017. 4. On the basis of this fact available on record itself, it was submitted that as per the record of the Assessing Officer himself, the earlier notices were sent at the incorrect address. Support was drawn from page 1 of the assessment order after referring to the incorrect address. Correct address has been mentioned by the AO. The same is as under : Smt. Shashi Prabha Tripathi W/o Dr. S.B.Tripathy, 90/15, Scheme No.5, Jind Now R/O : H.No.12, Housing Board Colony, Jind. Hence, admittedly earlier notices were not relevant in the eyes of law. These facts are relevant for challenge to the assumption of jurisdiction by the AO. 4.1 In the above context, it was highlighted that all the other notices which had been sent at address 90/15, Scheme No.5, Jind were not relevant in the eyes of law. The AO takes note of the correct address of the assessee subsequently and thereafter ITA-135/CHD/2020 A.Y. 2010-11 Page 4 of 17 notice was sent to as House No.12, Housing Board Colony, Jind which was responded to also. Accordingly, it was his submission that the assumption of jurisdiction is faulty as effectively within time, no notice was sent to the assessee at the correct address. 5. Referring to the impugned order, it was his submission that this ground was taken up before the CIT(A) who has not disputed the fact that the notice had been sent at the incorrect address and only on 06.11.2017, notice was finally sent to the assessee at the correct address. Not disputing the fact that it was the first notice sent in the eyes of law, the CIT(A) incorrectly referring to Section 292BB concluded that since the assessee participated in the proceedings, accordingly, the said ground was to be dismissed. 6. Inviting attention to the copy of the reasons recorded at page 2, it was again highlighted that while recording the reasons also, the AO has taken note of the old incorrect address and in terms of the decision dated 11.09.2020 of the Jaipur Bench of the ITAT in the case of Girirajkripa Developers Pvt. Ltd. Vs ITO (ITA No.168/JP/2020 placed at Paper Book pages 36-66) it was his submission that on the jurisdictional issue itself, the assessee deserves to succeed. ITA-135/CHD/2020 A.Y. 2010-11 Page 5 of 17 6.1 It was his submission that this issue has specifically been considered at Paper Book, page 63 internal page 28 of the order in paras 12 to 14. Accordingly, it was his prayer that on this ground alone, the appeal of the assessee may be allowed by quashing the proceedings. For ready reference, para 12-14 of the said order is reproduced hereunder : 12. After appreciating the facts of the present case, we are of the considered view that the facts contained in the present case are similar to the facts which are contained in the case of CIT Vs. Chetan Gupta (Supra), therefore, we are of the view that the question of service of notice U/s 148 of the Act is a jurisdictional requirement. 13. As per the facts of the present case, admittedly no attempt was made by the revenue to serve a notice to the assessee at the address provided by him. The revenue was also made aware of this lapse, as the assessee while filing of its return has made a note therein it was mentioned that no notice U/s 148 was served upon the assessee and moreover, the assessee have also served a letter to the revenue thereby categorically mentioning that no service of notice was effected upon the assessee and even the revenue in his reply dated 07/11/2017 has no where mentioned that notice U/s 148 of the Act was ever served upon the assessee. Hence, merely participation of the assessee in the proceedings is not a waiver to the service of notice U/s 148 upon the assessee. As per record, prior to completion of reassessment, the assessee has raised a categorical objection that he has not been duly served in accordance with Section 148 of the Act. Therefore, the 'proviso' to Section 292BB is attracted and Revenue cannot take advantage of the main portion of Section 292BB, This view has already been taken by the Special Bench of the Tribunal in Kuber Tobacco Products (P.) Ltd. v. Dy. CIT 20091 28 SOT 292 (Delhi) (SB). 14. After having gone through the judgment cited by both the parties and more particularly the decision of the Hon'ble Delhi High Court in the case of CIT Vs Chetan Gupta (supra), which is squarely applicable to the facts of the present case, we are also of the view that: (i) Under Section 148 of the Act, the issue of notice to the Assessee and service of such notice upon the Assessee are jurisdictional requirements that must be mandatorily complied with. They are not mere procedural requirements. (ii) For the AO to exercise jurisdiction to reopen an assessment, notice under Section 148 (1) has to be mandatorily issued to the Assessee. Further the AO cannot complete the reassessment without service of the notice so issued upon the Assessee in accordance with Section ITA-135/CHD/2020 A.Y. 2010-11 Page 6 of 17 282 (1) of the Act read with Order V Rule 12 CPC and Order III Rule 6 CPC. (iii) Although there is change in the scheme of Sections 147, 148 and 149 of the Act from the corresponding Section 34 of the 1922 Act, the legal requirement of service of notice upon the Assessee in terms of Section 148 read with Section 282 (1) and Section 153 (2) of the Act is a jurisdictional pre-condition to finalizing the reassessment. (iv) The onus is on the Revenue to show that proper service of notice has been effected under Section 148 of the Act on the Assessee or an agent duly empowered by him to accept notices on his behalf. In the present case, the Revenue has failed to discharge that onus. (v) The mere fact that an Assessee or some other person on his behalf not duly authorised participated in the reassessment proceedings after coming to know of it will not constitute a waiver of the requirement of effecting proper service of notice on the Assessee under Section 148 of the Act. (vi) Reassessment proceedings finalised by an AO without effecting proper service of notice on the Assessee under Section 148 (1) of the Act are invalid and liable to be quashed." From the entire crux of the matter, we found that the revenue has failed to bring on record any positive evidence to prove that the notice U/s 148 of the Act was served upon the assessee whereas the assessee has successfully placed on record letter dated 07/11/2017 issued by the department wherein it has no where been mentioned that the notice U/s 148 was ever served upon the assessee. In view of the above facts and circumstances, we can safely conclude that there was no 'proper service' of notice U/s 148 of the Act was effected in the present case before completion of reassessment u/s 147 r.w.s 143(3). Therefore, we set aside the orders of the lower authorities and quash the proceeding U/s 148 of the Act. This ground of appeal is allowed.” 7. Attention was also invited to the decision dated 30.06.2015 of the ITAT, New Delhi Bench in the case of ITO Vs Ajay Pal Singh, New Delhi (placed at Paper Book pages 22 to 30) for similar proposition. 8. On merits, attention was invited to assessment order page 3 wherein the reply of the assessee has been extracted. The same is reproduced hereunder for the sake of completeness : ITA-135/CHD/2020 A.Y. 2010-11 Page 7 of 17 9. Relying on the same, it was submitted that the relevant documents were made available to the AO who considering these as per page 3 of the assessment order required the assessee to file Form No.16 from his employer and evidence in respect of opening balance in the Cash Book which had been furnished and had also been seen by the AO. The AO also required the assessee to file Certificate from Ram Narain Education Society to show the amount had been deposited and also required her to file the return. For ready reference, ITA-135/CHD/2020 A.Y. 2010-11 Page 8 of 17 relevant extract from the assessment order relied upon is reproduced hereunder : “ ... ... ... ... Vide order sheet dated 29.11.2017, assessee was asked to file Form 16 from employer. Evidence in respect of opening balance of Rs.3,38,508/- in cash book. Furnish certificate from Ram Narain Education Society / Ram Narain School of Education, Kinana Distt. Jind that you deposited fee of Rs.80,90,000/- and asked her to file 1TR online and case adjourned to 07.12.2017........” (emphasis supplied) 10. The said queries were also replied to by the assessee. Inviting attention to the assessment order it was submitted, that the following reply to the AO also stands extracted at page 4 of the assessment order. Thus, it was his submission that all explanations consistently on record with supporting evidences have been shown and are available. Hence, on merits also, no addition, it was submitted, was maintainable. The relevant extract from the assessment order is reproduced hereunder : To The Income Tax Officer Ward-2 Bhiwani, Camp at Jind Sub:- In continuation of Reply dated: -Ref:- Shashi Prabha Tripati H.No. 12, Housing Board Colony, Jind Assessment Year 2010-11. R/Sir Respectfully submitted that in response to Assessment Proceedings for the Assessment Year 2010-11, the goodself issue/demanded . Copy of ITR for the above said assessment year etc. The reply of the same as under:- 1. Copy of ITR for the year under Consideration is attached here to with. 2. Copy of form No. 16 is not avaible as the employer society has wind up its B.Ed College at Village Kinana. The employer Society paid 3 months salary to the assessee through bank a/c @ Rs. 30000/- p.m. Copy of Bank a/c is attached/already placed on the file for completion of assessment proceeding ledger. 3. Copies of fee receipts and paid to the society for admission of students whom fee received is attached here to with as required by the goodself. It is therefore requested that keeping in view the above stated facts. Kindly decide the case & Oblige. Thanking You Sd/- Yours Faithfully Date:- 30.11.2017 Place:- Jind ITA-135/CHD/2020 A.Y. 2010-11 Page 9 of 17 11. Despite these facts and evidences, the Assessing Officer’s action in making the addition was assailed. The reasoning for the addition assailed is extracted hereunder : 2. The facts necessary for adjudication of the case are that as per AIR information, generated through ITD Application, assessee has made cash deposits amounting Rs. 41.21,700/- into her saving bank accounts maintained with Punjab National Bank, during the financial year 2009-10 relevant to the assessment year 2010-11. The source of cash deposits so made has not been explained by the assessee in view of the position stated above. In the backdrop of these observations, I have no hesitation in arriving at a conclusion that the assessee has made the cash deposits amounting Rs.41,21,700/- in the saving bank account from her own undisclosed sources. Reliance is placed on the decision of Hon'ble Supreme Court rendered in the case of Roshan Di Hatti v/s CIT (1977) 107 ITR 938(SC), wherein it was held that :- "The law is well settled that the onus of proving the source of a sum of money found to have received by an assessee is on him. Where the nature and source of a receipt, whether it be of money or other property, cannot be satisfactorily explained by the assessee, it is open to the Revenue to hold that it is the income of the assessee and no further burdon lies on the revenue to show that the income is from any particular source. 2.1 It was obligatory on the part of the assessee to explain the source(s) with documentary evidence(s) of deposits of cash amounting Rs.41,21,000/- into her saving bank accounts maintained with Punjab National Bank; which she failed to do so. Therefore, amount of Rs.41,21,700/- is held to be the deemed income of the assessee for the year under consideration in view of the provisions of section 69A of the I.T.Act, 1961 and the same is added to the total income of the assessee for the assessment year 2010-11.1 am satisfied that me assessee has concealed the particulars of his income at Rs.41,21,700/-. Accordingly, penalty proceedings u/ s 274 r.w.s 271(l)(c) of the Income Tax Act, 1961 are initiated separately. 12. These issues, it was submitted, were carried in appeal before the CIT(A) contending that all necessary facts and submissions stood made before the AO. However, the addition was sustained in appeal. Aggrieved, the ld. AR submitted that the addition was sustained by the ld. CIT(A) on entirely different facts and reasons which were not even the case of the AO. The decision on facts arrived at by the CIT(A) which was ITA-135/CHD/2020 A.Y. 2010-11 Page 10 of 17 assailed by the assessee is extracted hereunder for the sake of completeness : “6.2 Ground No. 2 and 3 are regarding addition of Rs. 41,21,700/-unexplained cash deposited in bank account. The appellant submitted that cash deposited amounting to Rs. 41,21,700/- into her saving bank accounts maintained with PNB, Jind during the financial year 2009-10 relevant to A.Y. 2010-11 was in nature of fee deposited by the student during the year under consideration. The appellant during assessment proceeding submitted copy of salary certificate issued by Ram Narayan institute of Education Jind and copy of account of gross fee received. It is seen that Bank account and the books of account of the college were never shown or produced before the AO during assessment proceedings nor during appellate proceedings and the assessee never reconciled these deposits of fees with her bank account entries. It is not even known whether these receipts have been included in the gross receipts or not. The college fee paid by the students, the receipt issued by the college to students subsequently cannot be completely relied upon. The submission of appellant that since she was the principal of college in M/s. Ram Narayan Institute of Education, Jind and her account was used for deposit of all fee receipt in cash it is not appears to be convincing. The appellant is not given any reason as to how the fees were taken only in cash and deposited in her bank account even though the college has a bank account in its name, Moreover the salary was paid to appellant through banking channel and she would be fully aware of the transactions in her account. It is pertinent to mention here that it is not a case of some illiterate person who is not aware of the transactions in her account but principal of an educational institution. In the light of the above discussed fact, the addition made by the AO is justified a s the assessee has not been able to discharge the onus of proving the source of cash deposits i n her account.............” 13. In the context of these facts and submissions on record ignoring the facts taken into consideration by the AO, the addition was sustained in appeal ignoring facts and evidences. Attention was invited to the copy of the bank statement of the assessee from the PNB Account wherein cash was deposited which is placed at Paper Book page 4 to 9; Copy of the Employer Certificate subsequently filed available at Paper Book page 9; Copy of the Appointment Letter of the assessee in the aforesaid position, it was submitted, is available on record placed at page 10; Copy of the Cash Book of the assessee at pages 12 to 43 wherein the fees was received on behalf of M/s ITA-135/CHD/2020 A.Y. 2010-11 Page 11 of 17 Ram Narain Institute of Education is also available. These documents were made available to the AO as well as the CIT(A) was heavily relied upon. Copy of the receipt issued by the assessee as employed by M/s Ram Narain Institute of Education available to the AO and the CIT(A) for each of the payments received from the students mentioning the name of the student as well as the course and the date on which payment was received by the assessee for the Institute, it was submitted, is available at pages 44 to 71. Apart from that, copies of reply submitted to the AO at page 71-72 and written submissions before the CIT(A) at pages 73 to 75 were relied upon. 13.1 It was his submission that in these facts when the assessee had explained consistently by way of documentary evidences that the payments were received by her on behalf of M/s Ram Narain Institute of Education and these had been deposited in the bank accounts which is being questioned, Cash Book in support of the said claim is made available, the Society documents available confirming this position are available on record. Thus, in this background, addition even on merits could not have been made. Referring to the facts available on record, it was his submission that it may be seen that the assessment year under consideration is 2010-11 i.e. the financial year 2009-10 and the assessment order has been ITA-135/CHD/2020 A.Y. 2010-11 Page 12 of 17 passed on 13.12.2017. The assessee has repeatedly placed on record that the society was disbanded subsequently and the documents showing that the cash was handed over to the Society is a fact not in dispute. In the circumstances, addition could not have been made. 14. It was also his submission that even otherwise Section 69A is not attracted as neither the assessee is owner of the money and it is not a case that it is not recorded in the books of account. As cash book recording that fees collected for the Institute from the students has been placed on record supported by copies of Receipt itself. Neither the cash book nor the copy of receipts issued have been faulted with. Accordingly, it was his submission that the two limbs of Section 69A are not attracted. Reliance was placed upon decision of the Apex Court in the case of CIT Vs Smt. P.K.Noorjahan (Paper Book page 19-21) and decision of the jurisdictional High Court in the case of CIT & ors. Vs Jawahar Lal Oswal & ors. (1-18). 15. It was also his submission referring to the CIT(A)’s order that the assessee has been faulted for not being aware despite being literate that the fees received for the Institution should have been deposited in the bank account of the Institution and not in her own individual bank account. In response thereto, it was his submission that no doubt that the assessee is literate ITA-135/CHD/2020 A.Y. 2010-11 Page 13 of 17 however, the assessee is not tax literate. Since on behalf of the Institution, she was collecting fees from the students, she was under bonafide belief that there is nothing wrong in that. It was his submission that to get students to join the Institution in the hinterlands, the name of the Institution and its significance is not so much there for the local population as for the local population, it is the common bond of trust and understanding which they have with one of their own. The personal contacts and trust in the Principal i.e. the assessee on account of which fact the admissions were being made. In the circumstances, the assessee not being aware of the financial significance of depositing the money in her own account instead of the account of the deposits in the Institution’s Bank Account may have made bonafide mistake but as far as the addition under consideration is concerned, it was not maintainable in the face of the facts as consistently available on record supported by documents. 16. Addressing the jurisdictional issue first, the ld. Sr.DR relying upon the impugned order submitted that the case law relied upon by the ld. Sr.DR is not applicable. The assumption of jurisdiction, it was her submission was correct and in accordance with law. It was argued that the challenge of the assessee is without any basis. ITA-135/CHD/2020 A.Y. 2010-11 Page 14 of 17 17. On merits, the ld. Sr.DR heavily relying upon the impugned order submitted that she would first want to reply to the argument of the assessee pleading that she was not tax literate. It was her submission that it not a question of tax literacy or otherwise at all. It was her argument that it is a case of common sense alone. Since the Institution did have a bank account, the occasion for the assessee to deposit the money in her account it was argued, was against all dictates of common sense itself. As far as the reasons recorded in the impugned order itself, it was her submission that the addition on facts has correctly been made. 18. The ld. AR in reply submitted that the tax authorities have not disputed the correctness of the Cash Book made available to the AO. The AO has referred to this Cash Book even in page 3 of his order wherein he has referred that vide ordersheet dated 29.11.2017 the assessee was required to file Form 16 from employer etc. including supporting evidence in respect of opening balance of Rs.3,38,508/- in cash book. Furnish certificate from Ram Narain Education Society / Ram Narain School of Education, Kinana Distt. Jind that fee of Rs.80,90,000/- had been deposited and requiring her to file 1TR online. It was submitted, that in hindsight, one can say that common sense dictates that the assessee should have deposited the fees collected on behalf of the Institution in the ITA-135/CHD/2020 A.Y. 2010-11 Page 15 of 17 account of the Institution, however, the fact that she was not tax literate and was acting under bonafide belief that the students were joining on account of her own contacts and connectivity. However, it was his submission that what stopped the AO from issuing notices u/s 133(6) to any of the parties to verify if the correctness of the claim made all along was doubted. There is no evidence or fact available on record to refute that fees was not collected on behalf of the Institution. The Employer Certificate, the appointment letter, the fees received on behalf of the Institution and the Cash Book alongwith the bank account, all demonstrate these facts. 18.1 Accordingly, it was his submission that the addition both on assumption of jurisdiction and on merits deserves to be deleted. 19. I have heard the submissions and perused the material on record. The case laws relied upon have been taken into consideration. It is a fact that the assessee was appointed as a Lecturer at Ram Narain School of Education on 01.10.2007 and the Employer Certificate that she was working as Principal in the Institute dated 09.09.2009 is also available on record. The Cash Book of the assessee mentioning the voucher numbers and the deposit in the bank account for the specific periods at pages 11 to 42 is available on record. It has been made available to the AO also as I have noticed that reference to the ITA-135/CHD/2020 A.Y. 2010-11 Page 16 of 17 Cash Book has been made by him in his queries raised to the assessee as per ordersheet dated 29.11.2017 referred to by him at page 3 of the assessment order dated 13.12.2017 itself. It is also seen that the Receipt Book of Ram Narain Society of Education qua these deposits for B.Ed/Courses is available from pages 43 to 70. None of these documents, it is seen have been faulted with by the Revenue. Considering the reply made before the AO as well as the CIT(A) on merits, it is seen that the occasion to make the addition or sustain it in appeal did not arise. The consistent evidence on record remains unrebutted. In the absence of any inconsistency in the assessee's claim and non rebuttal of supporting documents, the addition cannot be sustained arbitrarily. The addition is directed to be deleted. It is also seen that the assessee has raised jurisdictional challenge. On going through the facts available in the assessment order itself which have been extracted in the earlier part of this order it is seen that on the basis of which it has been pleaded that the notices issued at the incorrect address are non est. These have been elaborated at length while recording submissions advanced on behalf of the assessee, I find that the bald finding arrived at by the ld. CIT(A) though does not inspire any confidence in the correctness of the conclusion drawn on assumption of jurisdiction, however, since the addition on merits has been ITA-135/CHD/2020 A.Y. 2010-11 Page 17 of 17 deleted, the jurisdictional issue, accordingly, does not require any specific adjudication. Accordingly, the appeal of the assessee is allowed. 20. In the result, the appeal of the assessee is allowed. Order pronounced in the Open Court on 14 th June,2022. Sd/- ( दवा संह ) (DIVA SINGH) या#यक सद य/Judicial Member “प ू नम” आदेश क! त,ल-प अ.े-षत/ Copy of the order forwarded to : 1. अपीलाथ / The Appellant – 2. . यथ / The Respondent 3. .आयकर आय ु /त/ CIT 4. आयकर आय ु /त (अपील)/ The CIT(A) 5. -वभागीय त न2ध, आयकर अपील&य आ2धकरण, च4डीगढ़/ DR, ITAT, CHANDIGARH 6. गाड फाईल/ Guard File आदेशान ु सार/ By order, सहायक पंजीकार/ Assistant Registrar