Trans - Sphere Technologies Pvt. Ltd., Ahmedabad V. The Income Tax Officer, Ward-4(1)(1), Ahmedabad

ITA 1617/AHD/2016

• Counselvise Citation: [2018] 122 COUNSELVISE.COM (IT) 3918 (ITAT-AHMEDABAD)
• Duration Of Justice: 2 year(s) 3 month(s) 17 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 03-10-2018
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: SMC
• Assessment Year: 2012-2013
• Appeal Filed On: 16-06-2016
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: OM PRAKASH PATHAK
• Assessee Lawyers: MEHUL K PATEL
• Keywords: Unexplained cash credit; Depreciation
• Section: 37

Judgement Text

, ,L ,L,L ,L- -- -,E ,E,E ,E- -- -LH LHLH LH IN THE INCOME TAX APPELLATE TRIBUNAL SMC BENCH, AHMEDABAD L LL LK KK KOZJH OZJH OZJH OZJH OLHE VGEN OLHE VGEN OLHE VGEN OLHE VGEN] YS[KK LNL; ,OA ] YS[KK LNL; ,OA ] YS[KK LNL; ,OA ] YS[KK LNL; ,OA EK/KQFERK JKW; EK/KQFERK JKW; EK/KQFERK JKW; EK/KQFERK JKW;] ] ] ] U;KF;D LNL; DS LE{KA U;KF;D LNL; DS LE{KA U;KF;D LNL; DS LE{KA U;KF;D LNL; DS LE{KA BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SMT MADHUMITA ROY, JUDICIAL MEMBER ./ I.T.A. NO. 1617/AHD/2016 ( / ASSESSMENT YEAR : 2012-13) TRANS SPHERE TECHNOLOGIES PVT. LTD., 1/A, PUNIT PARK SOCIETY, AMBAWADI, ELLIS BRIDGE, AHMEDABAD. / VS. ITO, WARD 4(1)(1), AHMEDABAD. ./ ./ PAN/GIR NO. : AABCT 5278 K ( / APPELLANT ) .. ( / RESPONDENT ) / APPELLANT BY : SHRI MEHUL K. PATEL, A.R. / RESPONDENT BY : SHRI OM PRAKASH PATHAK, SR. D.R. / DATE OF HEARING 11/07/2018 !'# / DATE OF PRONOUNCEMENT 03/10/2018 $% / O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: THE CAPTIONED APPEAL HAS BEEN FILED AT THE INSTANCE OF THE ASSESSEE AGAINST THE ORDER OF THE COMMISSIONER OF INCOME TAX (APPEALS)7, AHMEDABAD [CIT(A) IN SHORT] VIDE APPEAL NO.CIT(A)-7 /147/15-16 DATED 26.04.2016 ARISING IN THE MATTER OF ASSESSMENT ORDE R PASSED UNDER S.143(3) OF THE INCOME TAX ACT, 1961(HERE-IN-AFTER REFERRED TO AS 'THE ACT') DATED 09.01.2015 RELEVANT TO ASSESSMENT YEAR (AY) 2012-13. ITA NO.1617/AHD/2016 TRANS-SPHERE TECHNOLOGIES PVT. LTD. VS. ITO A.Y. 2012-13 - 2 - 2. THE GROUNDS OF APPEAL RAISED BY THE ASSESSEE A RE AS UNDER:- 1. THAT ON FACTS AND IN LAW, THE LEARNED CIT(A) HA S GRIEVOUSLY ERRED IN CONFIRMING AD HOC DISALLOWANCE @ 50% OUT O F FOREIGN TRAVELLING EXPENSES TO THE TUNE OF RS.3,36, 399/-. 2. THAT ON FACTS AND IN LAW, THE LEARNED CIT(A) HAS GRIEVOUSLY ERRED IN CONFIRMING THE DISALLOWANCE OF DOMESTIC TR AVELLING EXPENSES TO THE TUNE OF RS.4,69,112/-. 3. THAT ON FACTS AND IN LAW, THE LEARNED CIT(A) HAS GRIEVOUSLY ERRED IN CONFIRMING THE DISALLOWANCE OF CLAIM OF DEPRECIATION ON MOTOR CAR OF RS.75,000/- 4. THAT ON FACTS AND IN LAW, THE LEARNED CIT(A) HAS GRIEVOUSLY ERRED IN CONFIRMING THE ADDITION OF RS.5,00,000/- M ADE U/S.68 OF THE ACT. 5. THAT THE LEARNED CIT(A) HAS GRIEVOUSLY ERRE D IN LAW AND ON FACTS IN CONFIRMING THE DISALLOWANCE OF RS.30,344/- MADE TOWARDS PRIOR PERIOD EXPENSES. 6. THE APPELLANT CRAVES LEAVE TO ADD, AMEND, A NY GROUNDS OF APPEAL. 3. THE FIRST ISSUE RAISED BY THE ASSESSEE IS THAT L D CIT(A) ERRED IN CONFIRMING THE ORDER OF AO BY SUSTAINING THE DISALL OWANCE OF RS.3,36,399/- BEING 50% OF FOREIGN TRAVELLING EXPEN SES. 4. BRIEFLY STATED FACTS ARE THAT THE ASSESSEE IS PR IVATE LIMITED COMPANY AND ENGAGED IN THE BUSINESS OF HI-TECH COMPUTER APP LICATION SOFTWARE DEVELOPMENT. THE ASSESSEE DURING THE YEAR HAS CLAIM ED FOREIGN TRAVELLING EXPENSES OF RS. 6,72,797/- ONLY. THE REL EVANT DETAILS OF FOREIGN TRAVELLING EXPENSES ARE STATED AS UNDER: ITA NO.1617/AHD/2016 TRANS-SPHERE TECHNOLOGIES PVT. LTD. VS. ITO A.Y. 2012-13 - 3 - SR. NO. PERSONS TRAVEL ABROAD AMOUNT RELATIONSHIP COUNTRY 1 MR. KALHAN VYAS 1,77,290/- DIRECTOR CHINA AND USA 2 HIMANSHU VYAS AND KUSUM H VYAS 3,44,947/- DIRECTOR KENYA 4.1 ON QUESTION BY THE AO ABOUT THE JUSTIFICATION O F FOREIGN TRAVELLING EXPENSES, THE ASSESSEE SUBMITTED AS UNDER: I. IT WAS INCURRED IN RELATION TO PRE-SALES CONSULTING AND THE CONSULTING INCOME WHICH HAS BEEN INCLUDED IN ASSESS EES TAXABLE INCOME. II. IT WAS ALSO INCURRED REGARDING INNOVATION FOR NEW S OFTWARE AND MARKETING OF EXISTING SERVICES OR SOFTWARE PRODUCTS . 4.2 HOWEVER, THE AO DISBELIEVED THE EXPLANATION FUR NISHED BY THE ASSESSEE ON THE GROUND THAT NO EVIDENCE SUBSTANTIAT ING THE CLAIM WAS FURNISHED. ACCORDINGLY, THE SAME WAS DISALLOWED AND ADDED BACK TO THE TOTAL INCOME OF THE ASSESSEE. 5. AGGRIEVED, ASSESSEE PREFERRED AN APPEAL TO LD. C IT(A). THE ASSESSEE BEFORE THE LD. CIT(A) FILED THE COPY OF TH E LEDGER SHOWING TRAVEL EXPENSES WITH ALL THE SUPPORTING DOCUMENTS. HOWEVER, THE LD CIT(A) DISREGARDED THE CONTENTIONS OF THE ASSESSEE AND CONFIRMED THE ORDER OF AO BY OBSERVING AS UNDER: ITA NO.1617/AHD/2016 TRANS-SPHERE TECHNOLOGIES PVT. LTD. VS. ITO A.Y. 2012-13 - 4 - 4.2 I HAVE CONSIDERED THE ASSESSMENT ORDER AND THE SUBMISSIONS MADE BY THE APPELLANT. DURING THE COURSE OF APPELLATE PROCE EDINGS, THE APPELLANT HAS SUBMITTED LEDGER ACCOUNTS IN RESPECT OF FOREIGN TRAVELING EXPENSES. FURTHER, 'OFFICE NOTE' HAS BEEN SUBMITTED GIVING A PARAGRAPH IN JUSTIFICATION OF THE FOREIGN TRAVELING EXPENSES TO CANADA, UNITES STATES, KENYA, ETC. NO SPECIFIC DETAILS IN RESPECT OF THE P ERSONS/OFFICIALS MET DURING THESE TRIPS, NATURE OF BUSINESS CONDUCTED, OR DESIG NATION AND EXPERIENCE OF THE PERSONS VISITING THESE COUNTRIES HAVE BEEN SUBM ITTED. A PERUSAL OF THE SUBMISSIONS SHOWS THAT THE APPELLANT HAS ENCLOSED A FEW EMAILS WHICH ARE COMMUNICATION IN RESPECT OF THESE VISITS. HOWEVER, LOOKING AT THE TOTALITY OF THE SUBMISSIONS FILED, I AM INCLINED TO AGREE WITH THE AC) THAT THE APPELLANT HAS NOT BEEN ABLE TO SATISFACTORILY JUSTIFY THE EXP ENSES INCURRED ON FOREIGN TRAVEL. KEEPING IN MIND THE EVIDENCES FILED AND THE NATURE OF BUSINESS OF THE APPELLANT, HOWEVER, THE DISALLOWANCE IS RESTRICTED TO 50% OF THE FOREIGN TRAVELLING EXPENSES. THUS, THE APPELLANT GETS RELIE F OF RS.3,36,399/- AND DISALLOWANCE OF RS.3,36,399/- IS CONFIRMED. GROUND OF APPEAL NO.1 IS ACCORDINGLY PARTLY ALLOWED. 5.1 BEING AGGRIEVED BY THE ORDER OF LD. CIT(A) ASSE SSEE IS IN SECOND APPEAL BEFORE US. 6. THE LD AR BEFORE US FILED A PAPER BOOK RUNNING F ROM PAGES 1 TO 9 AND SUBMITTED THAT THE EXPENSES WERE INCURRED IN CO NNECTION WITH THE BUSINESS ACTIVITIES. THEREFORE THE SAME SHOULD BE A LLOWED U/S 37 OF THE ACT. HOWEVER, THE LD. AR FOR THE ASSESSEE LEFT THE ISSUE AT THE DESECRATION OF THE BENCH. 7. ON THE OTHER HAND THE LD DR VEHEMENTLY SUPPORTED THE ORDER OF AUTHORITIES BELOW. 8. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. THE LD AR FOR THE ASSESSEE BEF ORE US HAS NOT FILED ITA NO.1617/AHD/2016 TRANS-SPHERE TECHNOLOGIES PVT. LTD. VS. ITO A.Y. 2012-13 - 5 - ANY DOCUMENTARY EVIDENCE JUSTIFYING THE FOREIGN TRA VEL EXPENSES. HOWEVER, ON PERUSAL OF THE ORDER OF AUTHORITIES BEL OW WE NOTE THAT IT HAS BEEN ADMITTED BY THE AO THAT THE DOCUMENTARY EVIDEN CE WERE FURNISHED BY THE ASSESSEE IN HAPHAZARD MANNER. THEREFORE, THE DISALLOWANCE WAS MADE TO THE TUNE OF 50% OF THE TOTAL TRAVELLING EXP ENSES. 8.1 IN THE GIVEN FACTS AND CIRCUMSTANCES, WE NOTE T HAT THE LOWER AUTHORITIES HAS ADMITTED THE GENUINENESS OF THE EXP ENSES TO THE TUNE OF 50% AND THE BALANCE WAS DISALLOWED ON AD HOC BASIS. AFTER CONSIDERING THE FACTS IN TOTALITY, WE ARE INCLINED TO CONFIRM T HE DISALLOWANCE OF TOTAL FOREIGN TRAVELLING EXPENSES TO THE TUNE OF 25% I.E. RS. 1,68,200/- ONLY. THUS, THIS GROUND OF APPEAL OF THE ASSESSEE IS PARTLY ALLOWED . 9. THE SECOND ISSUE RAISED BY THE ASSESSEE IS THAT LD CIT(A) ERRED IN DISALLOWING THE DOMESTIC TRAVELLING EXPENSES OF RS. 4,69,112/-. 10. THE ASSESSEE DURING THE YEAR HAS CLAIMED DOMEST IC TRAVELLING EXPENSES OF RS. 6,25,483/- ONLY. ON QUESTION BY THE AO, THE ASSESSEE HAS FILED THE XEROX COPIES OF THE TRAVELLING EXPENSES I N HAPHAZARD MANNER. HOWEVER, THE AO DURING THE ASSESSMENT PROCEEDINGS O BSERVED THAT THE DOMESTIC TRAVELLING EXPENSES HAVE BEEN INCURRED BY THE ASSESSEE ON ACCOUNT OF AIR TRAVELLING OUTSIDE AHMADABAD. THE AO ALSO OBSERVED THAT THE CLIENTS OF THE ASSESSEE ARE BASED ONLY IN THE C ITY OF AHMADABAD. THEREFORE, THE AO WAS OF THE VIEW THAT THE DOMESTIC TRAVELLING ITA NO.1617/AHD/2016 TRANS-SPHERE TECHNOLOGIES PVT. LTD. VS. ITO A.Y. 2012-13 - 6 - EXPENSES HAS NOT BEEN INCURRED EXCLUSIVELY IN CONNE CTION WITH THE BUSINESS OF THE ASSESSEE. 10.1 THE AO ALSO OBSERVED THAT THE ASSESSEE ALSO FA ILED TO FURNISH THE DETAILS TO JUSTIFY THAT THE DOMESTIC TRAVELLING EXP ENSES WERE INCURRED BY THE EMPLOYEES OF THE ASSESSEE. ACCORDINGLY, THE AO HELD THAT THE TRAVELLING EXPENSES TO THE TUNE OF 25% ARE REASONAB LE. THUS, THE AO DISALLOWED THE BALANCE AMOUNT OF RS. 4,69,112/- (6, 25,483 1,56,370) AND ADDED TO THE TOTAL INCOME OF THE ASSESSEE. 11. AGGRIEVED, ASSESSEE PREFERRED AN APPEAL TO LD C IT(A). THE ASSESSEE BEFORE THE LD CIT(A) FILED THE JUSTIFICATI ON FOR THE EXPENSES INCURRED BY IT. HOWEVER, THE LD CIT(A) DISREGARDED THE CONTENTIONS OF THE ASSESSEE AND CONFIRMED THE ORDER OF AO BY OBSER VING AS UNDER: 5.2 I HAVE CONSIDERED THE ASSESSMENT ORDER AND THE SUBMISSION MADE BY THE APPELLANT. A PERUSAL OF THE SUBMISSION MADE BY THE APPELLANT SHOWS THAT THE APPELLANT HAS SIMPLY GIVEN LEDGER ACCOUNT IN RESPECT OF DOMESTIC TRAVELLING ALONG WITH A HALF PAGE JUSTIFICATION SI GNED BY THE DIRECTOR STATING THAT THE DOMESTIC TRAVELLING PERTAINED TO M UMBAI, DELHI, GOA AND JAMMU FOR BUSINESS CONFERENCES. IT: HAS ALSO BEEN S TATED BY THE DIRECTOR THAT 'THE PERSONS INVOLVED IN SUCH TRAVEL WERE EXPE RTS IN RELEVANT FIELD THOUGH THEY ARE NEITHER EMPLOYEE NOR DIRECTORS OF C OMPANY BUT THEIR KNOWLEDGE IS QUITE USEFUL FOR THE GROWTH OF THE COM PANY, ALL TRAVEL MADE TO ABOVE MENTIONED PLACES WAS WHOLLY AND SOLELY FOR TH E BUSINESS PURPOSE ONLY.' NO DETAILS OF ANY SORT IN RESPECT OF THE BUS INESS CONDUCTED DURING THOSE BUSINESS MEETINGS, THE PERSONS MET, NATURE OF BUSINESS TRANSACTED, ETC. HAVE BEEN SUBMITTED. MOREOVER, BY THE APPELLAN T'S OWN SUBMISSIONS, THE PERSONS UNDERTAKING SUCH TRAVEL WERE NEITHER EM PLOYEES NOR DIRECTORS OF THE COMPANY. THEIR DESIGNATIONS AND AREA OF EXPE RTISE HAS NOT BEEN DISCUSSED BY THE APPELLANT. IN VIEW OF THESE FACTS, I AM INCLINED TO AGREE WITH THE AO AND THE DISALLOWANCE OF RS.4,69,112/- I S CONFIRMED, GROUND OF APPEAL NO.2 IS DISMISSED. ITA NO.1617/AHD/2016 TRANS-SPHERE TECHNOLOGIES PVT. LTD. VS. ITO A.Y. 2012-13 - 7 - 11.1 BEING AGGRIEVED BY THE ORDER OF LD CIT(A) ASSE SSEE IS IN APPEAL BEFORE US. 12. THE LD. AR BEFORE US SUBMITTED THAT DOMESTIC TR AVELLING EXPENSES HAS BEEN INCURRED IN RELATION TO THE BUSIN ESS ACTIVITIES ONLY. THEREFORE, THE SAME SHOULD BE ALLOWED. 13. ON THE HAND, LD DR VEHEMENTLY SUPPORTED THE ORD ERS OF AUTHORITIES BELOW. 14. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. THE LD AR FOR THE ASSESSEE BE FORE US HAS NOT FILED ANY DOCUMENTARY EVIDENCE JUSTIFYING THE DOMESTIC TR AVEL EXPENSES. HOWEVER, ON PERUSAL OF THE ORDER OF AUTHORITIES BEL OW WE NOTE THAT IT HAS BEEN ADMITTED BY THE AO THAT THE DOCUMENTARY EVIDEN CE WERE FURNISHED BY THE ASSESSEE IN HAPHAZARD MANNER. THEREFORE, THE DISALLOWANCE WAS MADE TO THE TUNE OF 75% OF THE TOTAL TRAVELLING EXP ENSES. 14.1 IN THE GIVEN FACTS AND CIRCUMSTANCES, WE NOTE THAT THE LOWER AUTHORITIES HAS ADMITTED THE GENUINENESS OF THE EXP ENSES TO THE TUNE OF 75% AND THE BALANCE WAS DISALLOWED ON AD HOC BASIS. AFTER CONSIDERING THE FACTS IN TOTALITY, WE ARE INCLINED TO CONFIRM T HE DISALLOWANCE OF TOTAL FOREIGN TRAVELLING EXPENSES TO THE TUNE OF 25% I.E. RS. 1,56,370/- ONLY. THUS, THIS GROUND OF APPEAL OF THE ASSESSEE IS PARTLY ALLOWED . ITA NO.1617/AHD/2016 TRANS-SPHERE TECHNOLOGIES PVT. LTD. VS. ITO A.Y. 2012-13 - 8 - 15. THE NEXT ISSUE RAISED BY THE ASSESSEE AGAINST T HE ORDER OF LD CIT(A) FOR CONFIRMING THE DISALLOWANCE OF DEPRECIAT ION ON MOTOR CAR FOR RS. 75,000/-. 16. AT THE OUTSET, THE LD COUNSEL FOR THE ASSESSEE FAIRLY AGREED THAT THE ISSUE CAN BE DECIDED AGAINST THE ASSESSEE IN VIEW O F NON AVAILABILITY OF SUPPORTING DOCUMENTARY EVIDENCE. THUS, THE GROUND O F APPEAL OF THE ASSESSEE IS DISMISSED . 17. THE NEXT ISSUE RAISED BY THE ASSESSEE IS THAT L D CIT(A) ERRED IN CONFIRMING THE ADDITION OF RS. 5,00,000/- U/S 68 OF THE ACT. 18. THE ASSESSEE DURING THE YEAR HAS TAKEN A LOAN O F RS. 5,00,000/- FROM SHRI SAMIP SHAH BUT FAILED TO FILE ANY SUPPORT ING EVIDENCE TO ESTABLISH THE GENUINENESS OF THE LOAN. THEREFORE, T HE SAME WAS DISALLOWED AND ADDED BACK TO THE TOTAL INCOME OF THE ASSESSEE. 19. AGGRIEVED, ASSESSEE PREFERRED AN APPEAL TO LD C IT(A) WHO HAS CONFIRMED THE ORDER OF THE AO BY OBSERVING AS UNDER : IN LIGHT OF THE ABOVE FACTS & CIRCUMSTANCES, SINCE THE ASSESSEE COMPANY HAS FAILED TO ESTABLISH THE IDENTITY OF THE LENDER, CREDITWORTHINESS OF THE LENDER AND ALSO GENUINENESS OF TRANSACTION, DESPITE GIVEN ADEQUATE OPPORTUNITY, THE AMOUNT OF L OAN OF RS.5,00,000/- IS TREATED AS UNEXPLAINED CASH CREDIT APPEARING IN THE BOOKS OF ACCOUNT OF THE ASSESSEE COMPANY AND ADDED U/S.68 OF THE ACT . PENALTY ITA NO.1617/AHD/2016 TRANS-SPHERE TECHNOLOGIES PVT. LTD. VS. ITO A.Y. 2012-13 - 9 - PROCEEDINGS U/S.271(1)(C) OF THE ACT FOR FURNISHING INACCURATE PARTICULARS OF INCOME AND THEREBY CONCEALMENT OF IN COME. 19.1 BEING AGGRIEVED BY THE ORDER OF LD. CIT(A) ASS ESSEE IS IN SECOND APPEAL BEFORE US. 20. THE LD AR BEFORE US SUBMITTED THAT THE LOAN WAS TAKEN BY THE ASSESSEE DURING THE YEAR FOR RS.5,00,000/- FROM SHR I SAMIP SHAH. 20.1 THE LD AR IN SUPPORT OF HIS CLAIM DREW OUR ATT ENTION ON PAGES 8 & 9 OF THE PAPER BOOK WHERE THE CONFIRMATION OF LOAN AS WELL AS BANK STATEMENTS OF THE ASSESSEE WAS PLACED. 21. ON THE OTHER HAND, LD DR SUBMITTED THAT NO DOCU MENTARY EVIDENCE WAS FILED BY THE ASSESSEE DURING THE PROCEEDINGS BE FORE THE LOWER AUTHORITIES. THE LD DR VEHEMENTLY SUPPORTED THE ORD ERS OF AUTHORITIES BELOW. 22. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. AT THE OUTSET, WE FIND THAT TH E LOAN CONFIRMATION AS WELL AS THE BANK STATEMENT WAS NOT PRODUCED BY THE ASSESSEE BEFORE THE LOWER AUTHORITIES. THEREFORE, IN THE INTEREST OF JU STICE AND FAIR PLAY WE ARE INCLINED TO RESTORE THIS ISSUE TO THE FILE OF AO FO R FRESH ADJUDICATION IN ACCORDANCE WITH THE PROVISIONS OF THE LAW. THE LD D R DID NOT RAISE ANY ABJECTION IF THE MATTER IS RESTORED BACK TO THE AO. HENCE WE ARE INCLINED TO RESTORE THIS ISSUE TO THE FILE OF AO WITH THE DI RECTION TO ADJUDICATE THE ITA NO.1617/AHD/2016 TRANS-SPHERE TECHNOLOGIES PVT. LTD. VS. ITO A.Y. 2012-13 - 10 - SAME AFRESH IN ACCORDANCE WITH THE PROVISION OF LAW . IT IS NEEDLESS TO MENTION THAT THE ASSESSEE SHALL COOPERATE IN THE AS SESSMENT PROCEEDINGS. HENCE, GROUND OF APPEAL OF THE ASSESSEE IS ALLOWED FOR STATISTICAL PURPOSES. 23. GROUND NO.5 WAS NOT PRESSED BY THE ASSESSEE. HE NCE THE GROUND OF APPEAL OF THE ASSESSEE IS DISMISSED AS NOT PRESSED. 24. IN THE RESULT, APPEAL OF THE ASSESSEE IS PARTLY ALLOWED FOR STATISTICAL PURPOSES. THIS ORDER PRONOUNCED IN OPEN COURT ON 03/10/2018 SD/- SD/- E/KQFERK E/KQFERK E/KQFERK E/KQFERK JKW; JKW;JKW; JKW; OLHE VGEN OLHE VGEN OLHE VGEN OLHE VGEN U;KF;D LNL; U;KF;D LNL; U;KF;D LNL; U;KF;D LNL; YKS[KK LN YKS[KK LN YKS[KK LN YKS[KK LNL; L; L; L; (MADHUMITA ROY) (WASEEM AHMED) JUDICIAL MEMBER ACCOUNTANT MEMBER AHMEDABAD; DATED 03/10/2018 PRITI YADAV, SR.PS !'# $#! / COPY OF THE ORDER FORWARDED TO : 1. / THE APPELLANT 2. / THE RESPONDENT. 3. & '( ) / CONCERNED CIT 4. ) () / THE CIT(A)-7, AHMEDABAD. 5. ,-. //'( , '(# , 12$&$ / DR, ITAT, AHMEDABAD. 6. .34 5 / GUARD FILE. % & / BY ORDER, , / //TRUE COPY// '/& () ( DY./ASSTT.REGISTRAR) , / ITAT, AHMEDABAD