ACIT-2(1), RAIPUR (CG) V. M/S SHREE SAI VIHAR, RAIPUR (CG)

ITA 138/BIL/2012

• Counselvise Citation: [2015] 134 COUNSELVISE.COM (IT) 0522 (ITAT-RAIPUR)
• Duration Of Justice: 3 year(s) 3 month(s) 8 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 18-11-2015
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: misc
• Appeal Filed On: 09-08-2012
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: RAJIV VARSHNEY
• Assessee Lawyers: R B DOSHI
• Keywords: Unexplained cash credit; Additional evidence; Corroborative evidences; Onus to prove
• Section: 133(6); 68

Judgement Text

1 ITA NOS. 138 TO 141/BLPR/2012 IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR. BEFORE SHRI MUKUL K. SHRAWAT, JUDICIAL MEMBER AND SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER. S.NO. I.T.A. NO. ASSTT. YEAR. 1. 138/BLPR/2012 2007 - 08. 2. 139/BLPR/2012 2008 - 09 3. 140/BLPR/2012 2009 - 10 4. 141/BLPR/2012 2010 - 11 ASSTT. COMMISSIONER OF INCOME - TAX, M/S SHREE SAI VIHAR, 2(1), RAIPUR. VS. PYARELAL AGRAWAL MARG, RAMSAGARPARA, RAIPUR. AAVFS 3269G. APPELLANT. RESPONDENT. APPELLANT BY : SHRI RAJIV VARSHNEY. RESPONDENT BY : SHRI R.B. DOSHI. DATE OF HEARING : 1 5 - 10 - 2015. DATE OF PRONOUNCEMENT : 1 8 TH NOV., 2015. O R D E R PER SHRI SHAMIN YAHYA, A.M . THESE APPEALS BY THE REVENUE ARE DIRECTED AGAINST THE COMMON ORDER OF LEARNED CIT(APPEALS), RAIPUR DATED 05 - 06 - 2012 FOR THE CONCERNED ASSESSMENT YEARS. SINCE THE ISSUES ARE COMMON AND CONNECTED, THESE APPEALS WERE CONSOLIDATED AND DISPOSED OF TOGETHER FOR THE SAKE OF CONVENIENCE. 2. ONE ISSUE RAISED IN ASSESSMENT YEAR 2007 - 08 IS THAT THE LEARNED CIT(APPEALS) ERRED IN DELETING THE ADDITION OF RS.49,90,000/ - MADE BY THE AO U/S 68 OF THE I.T. ACT ON ACCOUNT OF UNSECURED LOANS. ANOTHER RELATED ISSUE IS THAT T HE LEARNED CIT(APPEALS) ERRED IN DELETING THE INTEREST ON THESE LOANS AS UNDER : 2 ITA NOS. 138 TO 141/BLPR/2012 ASSTT. YEAR 2007 - 08 RS.1,48,998/ - ASSTT. YEAR 2008 - 09 RS. 52,819/ - ASSTT. YEAR 2009 - 10 RS. 38,285/ - ASSTT. YEAR 2010 - 11 RS. 43,372/ - ON THIS ISSUE THE AO NOTED THAT THE ASSESSEE HAS TAKEN FRESH LOANS TO THE TUNE OF RS.51,38,998/ - DURING THE YEAR. THE ASSESSEE WAS ASKED TO EXPLAIN THE SAME. WITH EVIDENCE. UPON RECEIVING ASSESSEES SUBMISSION THE AO OBSERVED THAT THE ASSESSEE HAS TAKEN FRESH LOANS AND HAS INVESTED IN 7 NEW PROPERTIES DURING THE YEAR. THAT THOUGH CONFIRMATIONS ARE FILED , THE ASSESSEE MADE NO EFFORTS TO ESTABLISH THE CREDITWORTHINESS OF THE LENDERS. COPIES OF ITR ARE FILED BUT COPIES OF BANK ACCOUNT OF LENDERS ARE NOT FILED. THAT FROM THE RETURNS F ROM THE LENDERS IT WAS SEEN THAT MEAGRE INCOMES ARE SHOWN AND NEITHER BALANCE SHEET NOR CAPITAL ACCOUNT IS FILED. HENCE THE AO CONCLUDED THAT NECESSARY EFFORTS FROM THE SIDE OF ASSESSEE ARE LACKING AND THE NEW UNSECURED LOANS FAILED TO BE SATISFACTORILY E XPLAINED AS GENUINE. HENCE THE AO INVOKED THE PROVISIONS OF SECTION 68. THUS THE AO MADE AN ADDITION OF RS.51,49,756/ - . 3. BEFORE T HE LEARNED CIT(APPEALS) THE ASSESSEE SUBMITTED THAT THE LOANS WERE RECEIVED FROM OUTSIDE PARTIES AND THEY WERE NOT COOPERATIN G WITH THE ASSESSEE IN FURNISHING SATISFACTORY EVIDENCES. THE ASSESSEE HAD REQUESTED THE AO VIDE LETTER DATED 28 - 11 - 2011 TO CALL FOR NECESSARY DETAILS AND CONFIRMATION BY CONDUCTING DIRECT ENQUIRY U/S 133(6) OF THE ACT BUT NO ENQUIRY WAS CONDUCTED. BEFO RE THE LEARNED CIT(APPEALS) THE ASSESSEE HAS MADE FURTHER SUBMISSIONS : . HOWEVER , THE APPELLANT FILED THE FOLLOWING DETAILS IN RESPECT OF THE CREDITORS> S.NO. NAME OF CREDITOR PARTICULARS FIL LOAN AMOU INTEREST BEFORE AO RS. THEREON RS. L . GURUCHARAN SINGH BAGGA CONFIRMATION& 4 , 00 , 000 1 - 14 , 263 / - ACKNOWLEDGEMENT , A . YR . 07/08 2. J ANKI PRASAD AGRAWAL ---- DO ---- 4 , 00 , 000 1 - 14 , 263 / - 3. KRISHNA KUMAR SHARMA -- : . - DO ---- 3 , 00 , 0001 - 10 , 697/ - 3 ITA NOS. 138 TO 141/BLPR/2012 4 . MANOJ KUMAR AGRAWAL ---- DO ---- 2 , 50 , 0001 - 8,914/ - 5. RAM GOPAL AGRAWAL ---- DO ---- 4 , 00 , 0001 - 14 , 263/ - 6 . RAM KUMAR AGRAWAL CONFIRMATION , 8 , 90 , 0001 - 2 , 804/ - COMPUTATION, ACKNOWLEDGEMENT A . YR . 07/08 & BIL L STATEMENT 7. SMT . ANITA SHARMA CONFIRMATION& 4,50,0001 - 16,046/ - ACKNOWLEDGMENT AY07/08 . 8. SMT . DHANWANTI SHARMA ----- DO ---- 4 , 50 , 0001 - 16 , 046/ - 9. SMT . KIAM DEVI AGRAWA ----- DO ----- 3 , 00 , 0001 - 10 , 697/ - 10. SMT . MADHU AGRAWAL ------ DO ----- 3 , 00,000/ - 10,697/ - LL . SMT . PURNIMA . GUPTA ------ DO ----- 3 , 00,0001 - 10 , 697/ - 12 . SMT . SARVANI DEVI SHARM ------ DO ----- 2,50 , 0001 - 8 , 914/ - 13. SWATI AGRAWAL ------ DO --- 3,00 , 0001 - 10 , 697/ - TOTAL 49,90,000/ - 1,48,9981 TOTAL LOAN AMOUNT INCLUDING PRINCIPAL & INTEREST 51,38,998/ AFTER COMPLETION OF THE ASSESSMENT , THE APPELLANT RECEIVED THE BALANCE SUPPORTING EVIDENCES AND THE SAME WERE FILED WITH REQUEST TO ACCEPT THE SAME UNDER RULE 46A OF THE RULES. IT WAS CONTENDED THAT ALL THE CREDITORS ARE ASSESSED TO TAX AND THEY HAVE SHOWN THE LOAN TRANSACTIONS AND INTEREST RECEIPTS IN THEIR INDIVIDUAL IT RETURNS . ALL THE FRESH LOANS WERE RECEIVED THROUGH ACCOUNT PAYEE CHEQUES. IT WAS CONTENDED THAT THE TRANSACTION WERE VERIFIABLE FROM THE RETURN OF THE CONCERNED PARTIES AND THEIR BALANCE SHEET SHOWS THE SAME. THE APPELLANT CONTENDED THAT SUFFICIENT FUNDS ARE AVAILA BLE WITH THE CONCERNED PARTIES FOR LENDING THE LOAN TO THE ASSESSEE . RELYING ON THE DECISION OF HON'BLE R A J STHAN HIGH COURT IN THE CASE OF KAMAL MOTORS VS CIT 186 CTR (RAJ)166 , THE APPELLANT CONTENDED THAT IF THE CREDITORS ARE ASSESSED TO TAX , THEIR CREDIT WORTHINESS IS PROVED AND NO ADDITION IS POSSIBLE . IN THE OPENING PARA OF THE SUBMISSION, IT WAS CONTENDED THAT THE A.O. HAS DISALLOWED MISCELLANEOUS EXPENSES AND MADE THE DISALLOWANCE TWICE, I.E. ONCE UNDER SEPARATE HEADING AND A GAIN BY INCLUDING IT IN THE TOTAL ADDITION OF RS.51,49,756/ - . LEARNED CIT(APPEALS) SENT THE ASSESSEES SUBMISSION ALONG WITH THE ADDITIONAL EVIDENCES TO THE AO FOR HIS COMMENTS. IN THE REPORT THE AO SUBMITTED THAT SEVERAL OPPORTUNITIES WERE ALLOWED TO TH E ASSESSEE BUT HE DID NOT MAKE THE COMPLIANCE. THE AO FURTHER OBJECTED TO THE ADMISSION OF ADDITIONAL EVIDENCES. THE AO FURTHER CONTENDED THAT MERE SUBMISSION OF CERTAIN MATERIALS WILL NOT HELP THE ASSESSEE TO DISCHARGE THE BURDEN TO PROVE THE CREDIT U/S 68. CONSIDERING THE ABOVE, LEARNED CIT(APPEALS) DELETED THE ADDITIONS HOLDING AS UNDER : 4 ITA NOS. 138 TO 141/BLPR/2012 3 . 4 I HAVE GONE THROUGH THE OBSERVATIONS OF THE AG AND SUBMISSIONS OF THE APPELLANT . THE ADDITIONAL EVIDENCES FURNISHED BY THE APPELLANT ARE COPIES OF ACKNOWLEDGEMENTS OF THE IT RETURNS, CONFIRMATION OF ACCOUNT, ETC . OF THE CREDITORS. THOUGH PARTICULARS OF THE CREDITORS WERE FURNISHED, THESE DOCUMENTS COULD NOT BE FURNISHED EARLIER FOR R EASONS OF . . NON - COOPERATION BY THEM, WHO HAPPENED TO BE THE OUTSIDERS . THIS FACT WAS BROUGHT TO THE NOTICE OF THE AG. DURING ASSESSMENT PROCEEDINGS AND HE WAS EVEN REQUESTED TO CONDUCT INQUIRIES U/S . 133(6) OF THE ACT . UNDER SUCH CIRCUMSTANCES, THE NON - SUPPLY OF REQUISITE - INFORMATION BY OUTSIDE PARTIES HAS TO BE HELD AS 'SUFFICIENT CAUSE' FOR NOT FURNISHING SUCH EVIDENCES DURING ASSESSMENT AND ACCORDINGLY, THE SAME COMES WITHIN THE CIRCUMSTANCES NARRATED IN THE RULE AND HENCE, IT IS ADMITTED IN THE INTEREST OF JUSTICE. THE EVIDENCES ESTABLISH THE IDENTITY AND CREDITWORTHINESS OF THE CREDITORS AND GENUINENESS OF THE TRANSACTIONS . THE AG. DID NOT CONDUCT ANY INQUIRIES TO ESTABLISH OTHERWISE. HE SI MPLY HAD MADE THE ADDITION FOR NON - COMPLIANCE IN A TECHNICAL MANNER , AFTER OBSERVING THAT THE INCOME SHOWN IN THE RETURNS OF THE LENDERS IS MEAGER . IT IS NOT THE CASE OF THE AG . THAT HE HAD CONDUCTED SOME INQUIRIES AND ON THE BASIS OF OUTCOME OF SUCH IN QUIRIES, HE CONCLUDED THAT THE IDENTITY AND CREDITWORTHINESS OF INVESTORS IS DOUBTFUL OR THE TRANSACTIONS ARE NOT GENUINE . THE CREDITORS ARE ASSESSED TO INCOME - TAX AT THE SAME PLACE AND THE AG . COULD HAVE VERY EASILY INVOKED SUCH INQUIRY , IF HE HAD ANY SERIOUS DOUBTS TH E TRANSACTIONS. THIS COULD HAVE BEEN DONE EITHER BY ISSUING SUMMONS U/S.131 OR DEPUTING INSPECTOR, WHICH WAS NOT DONE, INSTEAD OF THIS HE HELD THAT THE INCOME SH OWN IN THEIR CASES IS MEAGER . THEREFORE , AFTER CONSIDERING THE FACTS AND CIRCUMSTANCES , . ~ \ ..._ _ ~ R / ' OF THE CA S E AND THE CASE LAWS RELIED UP ON BY THE APPELLANT AND THE FACT THAT AL L THE P E R S ONS ARE REGULAR L Y ASSESSED TO TAX AND SUCH CREDITS / INTEREST INCOME ARE NOT DISPUTED IN THEI R RESPECTIVE CASES , THE ADDITION MADE BY THE AO IS NOT PROPER AND NOT SUSTAINABLE AND TH E S AME IS DE L ETE D . ACCORDINGLY , THE A . O . IS DIRECTED TO ALLOW THE AMOUNT INTEREST DISALLOWED AT R S . 1 4 , 796 / - (A.YR . 2007 - 08); RS . 52 , 819 / - ( A . YR . 2008 - 09) ; RS . 38 , 285 / - ( A . YR . 2009 - 10) ; R S . 43 , 372 / - ' (A. YR . 20 1 0 - 11) ON THESE LOANS. THE AMOUNT OF MISCELLANEOUS EXPENSES OFRS . 10 , 758 / - INCLU D E D IN THE TOTAL ADDITION OF RS . 51 , 49 , 756 / - IS ALSO D E L ETE D , B E I NG MA D E TWICE. IN T HE RE S ULT THE APPELLANT GET S RE L IEF OF R S. 51 , 49 , 756/ - IN A.YR. 2007 - 08; RS . 52,819/ - IN A.YR.2008 - 09) , R S .38 , 285 / - IN A. Y R . 2009 - 10 AND RS . 43,372/ - IN A.YR.2010 - 11 . THESE GROUNDS OF APPEAL AR E ACCORDINGL Y ALLOWED. 4. AGAINST THE ABOVE ORDER, REVENUE IS IN APPEAL BEFORE US. 5. WE HAVE HEARD BOTH THE COUNSEL AND PERUSED THE RECORDS. LEARNED D.R. HAD ARGUED THAT THERE IS VIOLATION OF RULE 46A INASMUCH AS THE LEARNED CIT(APPEALS) HAS ADMITTED ADDITIONAL EVIDENCES AND THE AO HAS NOT BEEN GRANTED AN OPPORTUNITY TO COMMENT UPON THE MERITS OF THE CASE OF ADD ITIONAL EVIDENCES. HENCE HE SUBMITTED THAT THE MATTER SHOULD BE REMITTED TO THE FILE OF THE AO. 6. PER CONTRA LEARNED COUNSEL OF THE ASSESSEE STATED THAT THE ASSESSEE HAS DULY PROVIDED THE NAMES, ADDRESSES AND INCOME TAX DETAILS OF THE LENDERS TO THE AO. SINCE THE LENDERS WERE NOT COOPERATING, THE ASSESSEE HAS ALSO ASKED THE AO 5 ITA NOS. 138 TO 141/BLPR/2012 TO ISSUE SUMMONS U/S 133(6) OF THE I.T. ACT. THE AO HAS CHOSEN NOT TO DO ANY ENQUIRY WHATSOEVER BUT HAS ADDED THE LOANS AND THE INTEREST THEREON AS UNEXPLAINED CASH CREDITS. 7. UPON CAREFUL CONSIDERATION WE FIND THAT W HEN THE AO HAD INFORMATION ABOUT THE NAMES AND ADDRES S ES OF THE LENDERS AND THAT THEY ARE INCOME - TAX ASSESSES AND THEIR PAN NOS. WERE ALSO SUBMITTED AND IT IS NOT THE CASE THAT THESE PARTICULARS WERE FALSE, THERE IS NO REASON WHY THE AO COULD NOT MAKE NECESSARY ENQUIRY TO SATISFY HIMSELF. BY PROVIDING ALL THE NECESSARY DETAILS REGARDING LOAN CREDITORS THE ASSESSEE HAS DULY DISCHARGED THE INITIAL ONUS. THE ONUS OF FURTHER ENQUIRY AND PROVING THAT THE LOANS WERE BOGUS LIE D ON THE AO WHO HAS CHOSEN NOT MAKE ANY ENQUIRY WHATSOEVER. IN THESE CIRCUMSTANCES, IN OUR CONSIDERED OPINION, THERE IS NO INFIRMITY IN THE ORDER OF LEARNED CIT(APPEALS). LEARNED CIT(APPEALS) HAS NOTED THAT IF THE AO HAD ANY DOUBT ABOUT THE TRANSACTIONS HE COULD HAVE ISSUED SUMMONS U/S 133(6) OR EVEN DEPUTE D THE INSPECTOR WHICH HAD NOT BEEN DONE. THE CREDITORS WERE ASSESSED TO INCOME - TAX AT THE SAME PLACE AND HENCE THE AO COULD HAVE VERY EASILY INVOKED ANY ENQUIRY. IN THESE CIRCUMSTANCES, IN OUR CONSIDERED OPINION, THERE IS NO INFIRMITY IN THE ORDER OF LEARNED CIT(APPEALS). IN THIS REGARD WE MAY REFER TO HONBLE APEX COURT DECISION IN THE CASE OF CIT VS. ORISSA CORPORATION P. LTD. 159 ITR 78. IN THIS CASE IT WAS EXPOUNDED THAT WHEN THE NAMES AND ADDRESSES OF THE CREDITORS ARE GIVEN AND THEY ARE INCOME - TAX ASSESSES, THEN THE ONUS TO DISPROVE THE SAME LIED ON THE REVENUE. IN THIS CASE ADMITTEDLY THE REVENUE HAS NOT DISCHARGED THE ONUS. WE ARE NOT INCLINED TO ACCEPT THE SUBMISSIONS OF THE LEARNED D.R. TO REM IT THE MATTER TO THE FILES OF THE AO. THE AO HAD ALL THE INFORMATIONS BEFORE HIM AT THE TIME OF ASSESSMENT. SIMILARLY HE WAS AGAIN GIVEN AN OPPORTUNITY WHEN THE SUBMISSIONS OF THE ASSESSEE WERE REMANDED TO HIM. NOW THE AO CANNOT GIVE A THIRD INNINGS WHIC H WILL BE CLEARLY AN INJUSTICE TO THE ASSESSEE AND HARASSMENT BY MULTIPLE ASSESSMENT PROCEEDINGS ON SAME ISSUE FOR NO FAULT OF THE ASSESSEE. 6 ITA NOS. 138 TO 141/BLPR/2012 ACCORDINGLY WE UPHOLD THE ORDER OF LEARNED CIT(APPEALS) ON THIS ISSUE AND DISMISS THE GROUND TAKEN BY THE REVENUE. 8 . ANOTHER ISSUE RAISED BY THE REVENUE IN ASSESSMENT YEAR 2007 - 08 IS THAT LEARNED CIT(APPEALS) HAS ERRED IN DELETING THE ADDITION OF RS.10,758/ - MADE BY THE AO ON ACCOUNT OF MISCELLANEOUS EXPENSES. 9. WE FIND THAT LEARNED CIT(APPEALS) HAS CLEARLY FOUND TH AT THE AMOUNT OF MISCELLANEOUS EXPENSES OF RS.10,758/ - WAS ADDED TWICE AS IT WAS ONCE AGAIN INCLUDED BY THE AO IN THE DISALLOWANCE FOR UNSECURED LOANS AND INTEREST. THIS IS CLEAR FROM THE READING OF THE AOS ORDER ON THE ISSUE O F ADDITION FOR UNSECURED LOA N WHEREIN THE AO HAD STARTED WITH THE FIGURE OF RS.51,38,998/ - BUT IN CONCLUSION HAD ADDED RS.51,49,756/ - . CLEARLY THE DIFFERENT AMOUNT OF RS.10,758/ - WAS A DOUBLE ADDITION. HENCE THE LEARNED CIT(APPEALS) HAS ONLY DELETED THE DOUBLE ADDITION IN THE GROUN DS DEALT WITH BY HIM. HENCE WE UPHOLD THE ORDER OF LEARNED CIT(APPEALS) ON THIS ACCOUNT. 10 . ANOTHER GROUND RAISED FOR ASSESSMENT YEAR 2008 - 09, 2009 - 10 AND 2010 IS THAT THE LEARNED CIT(APPEALS) ERRED IN DELETING THE ADDITION ON ACCOUNT OF SALARY AND OTHER EXPENSES AS UNDER : ASSESSMENT YEAR AMOUNT OF ADDITION DELETED. 2008 - 09 RS. 2,01,955/ - 2009 - 10 RS. 1,26,432/ - 2010 - 11 RS. 75,600/ - ON THIS ISSUE THE AO MADE THE DISALLOWANCE BY OBSERVING THAT THE ASSESSEE IS HAVING RECEIPT BY WAY OF RENT FROM BPCL LAND AND HAS CLAIMED VARIOUS EXPENSES. HE FOUND THAT THE EXPENSES CLAIMED WERE EXCESSIVE, UNJUSTIFIED AND 7 ITA NOS. 138 TO 141/BLPR/2012 NOT SUPPORTED BY PROPER EVIDENCE. HENCE THE AO MADE ADHOC DISALLOWANCES IN THIS REGAR D. THE LEARNED CIT(APPEALS) DELETED THE ADDITION HOLDING AS UNDER : I HAVE GONE THROUGH THE OBSERVATIONS OF THE A.O. AND SUBMISSIONS OF THE APPELLANT. THE A.O. HAS MADE THE DISALLOWANCES IN A CASUAL AND ROUTINE MANNER. THOUGH HE OBSERVED THAT NO PROPER V OUCHERS ARE AVAILABLE, HE DID NOT PINPOINT, WHICH WERE THE VOUCHERS THAT WERE IMPROPER AND HOW HE COULD CONCLUDE THAT THE ENTIRE EXPENDITURE IS NOT ADMISSIBLE. IT IS OBLIGATORY ON THE PART OF THE A.O. TO REASONABLY JUSTIFY HIS STAND THROUGH A SPEAKING ORDE R TO PASS THE TEST OF APPEAL. IT IS TRITE LAW THAT SUCH AD HOC DISALLOWANCES CANNOT BE PERMITTED. ACCORDINGLY, THE DISALLOWANCES MADE BY THE A.O. ARE DELETED AND THE APPEALS ARE ALLOWED ON THIS GROUND. 11 AGAINST THE ABOVE ORDER, ASSESSEE IS IN APPEAL BEF ORE US. 1 2 . WE HAVE HEARD BOTH THE COUNSEL AND PERUSED THE RECORDS. WE FIND THAT IT IS TRUE THAT THE AO HAS MADE THE DISALLOWANCE IN AN ADHOC MANNER WITHOUT SPECIFYING WHICH EXPENSES ARE NOT SUPPORTED BY VOUCHERS. IT IS SETTLED LAW THAT THE ADDITIONS CANNO T BE MADE ON THE BASIS OF SURMISES AND CONJECTURES. IN THIS REGARD, ASSESSEES RELIANCE ON THE FOLLOWING CASE LAW IS ALSO RELEVANT : 1. DHAKESWARI COTTON MILLS LTD. VS. CIT 26 ITR 775 (SC). 2. RAJ KUMAR JAIN VS. ACIT 50 ITD 1 (TM) (ALL.). HENCE WE DO NOT FIND ANY INFIRMITY IN THE ORDER OF LEARNED CIT(APPEALS) ON THIS ISSUE. ACCORDINGLY WE UPHOLD THE SAME. 1 3 . IN THE RESULT, THESE APPEALS FILED BY THE REVENUE STAND DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON THIS 18 TH DAY OF NOV., 2015. SD/ - SD/ - (MUKUL K. SHRAWAT) ( SHAM IM YAHYA) JUDICIAL MEMBER ACCOUNTANT MEMBER. NAGPUR, DATED: 18 TH NOV.., 2015. 8 ITA NOS. 138 TO 141/BLPR/2012 COPY FORWARDED TO : 1. M/S SHREE SAI VIHAR, PYARELAL AGRAWAL MARG, RAMSAGARPARA , RAIPUR. 2. A.C.I.T. ,RA IPUR. 3. C.I.T., CONCERNED 4. CIT(APPEALS), RAIPUR. 5. D.R., ITAT, RAIPUR. 6. GUARD FILE TRUE COPY. BY ORDER ASSISTANT REGISTRAR, ITAT, NAGPUR WAKODE