The DCIT, Circle-4, Surat V. M/s. Rameshwar Textile Mills Ltd., Surat

ITA 1666/AHD/2011

• Counselvise Citation: 166620514 RSA 2011
• Duration Of Justice: 4 year(s) 4 month(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 21-10-2015
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: D
• Next Hearing Date: 28-09-2015
• Assessment Year: 2008-2009
• Appeal Filed On: 20-06-2011
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: G C DAXINI
• Assessee Lawyers: RASESH SHAH
• Keywords: Rejection of books of accounts; Unexplained expenditure; Business expenditure; Income from undisclosed sources; Retraction

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD D BENCH AHMEDABAD BEFORE SHRI PRAMOD KUMAR, ACCOUNTANT MEMBER, AND SHRI S. S. GODARA, JUDICIAL MEMBER. ITA. NO. 1666/AHD/2011 (ASSESSMENT YEAR:2008-09) D.C.I.T., CIRCLE-4, ROOM NO. 223, AAYAKAR BHAVAN, SURAT. APPELLANT VS. M/S. RAMESHWAR TEXTILE MILLS LTD. 5101 B WING, RAGHUKUL MARKET, RING ROAD, SURAT. RESPONDENT PAN: AAACR2714D / BY REVENUE : SHRI G. C. DAXINI, SR. D.R. / BY ASSESSEE : SHRI RASESH SHAH, A.R. /DATE OF HEARING : 29.09.2015 /DATE OF PRONOUNCEMENT :21.10.2015 ORDER PER S. S. GODARA, JUDICIAL MEMBER THIS REVENUES APPEAL FOR ASSESSMENT YEAR 2008-09, ARISES FROM ORDER OF THE CIT(APPEALS)-IV, AHMEDABAD, DATED 29.03.2011 PASSED IN APPEAL NO. CAS-IV/192/2010-11, IN PROCEED INGS U/S.143(3) OF THE INCOME TAX ACT, 1961, HEREAFTER THE ACT. ITA NO.1666/AHD/2011 (DCIT VS. M/S. RAMESHWAR TEXT ILE MILLS LTD.) A.Y. 2008-09 - 2 - 2. THE REVENUES SOLE SUBSTANTIVE GROUND CHALLENGES THE CIT(A)S ORDER DELETING ADDITION MADE ON ACCOUNT OF UNDISCLOSED INCOME FROM JOB RECEIPTS OUTSIDE THE BOOKS OF RS.5, 50,17,603/- MADE BY THE ASSESSING OFFICER IN A POST SURVEY ASSE SSMENT FRAMED ON 24.12.2010. 3. THE ASSESSEE COMPANY IS ENGAGED IN THE BUSINESS OF DYEING AND PRINTING OF ART SILK CLOTH. IT RUNS ANOTHER PR OPRIETARY CONCERN IN THE VERY BUSINESS BY THE NAME AND STYLE OF M/S. KIRTIDA SILK MILLS. THE DEPARTMENT CARRIED OUT A SURVEY ON 03.0 3.2008 IN ITS CASE. THE ASSESSEE APPEARS TO HAVE DISCLOSED A SUM OF RS.13.01 CRORE. IT FILED ITS RETURN ON 27.09.2008 DECLARING NIL INCOME FOLLOWED BY A REVISED ONE ON 30.03.2009 SEEKING MAT RECTIFICATION. THE ASSESSING OFFICER TOOK UP SCRUT INY. HE FRAMED A REGULAR ASSESSMENT ON 24.12.2012 DETERMINING TOTA L INCOME AT RS.4,12,04,491/- AFTER MAKING IMPUGNED ADDITION OF RS.6,35,17,609/- ON ACCOUNT OF UNDISCLOSED INCOME F ROM JOB RECEIPTS OUTSIDE THE BOOKS. THE ASSESSEES EXPLANA TION CLAIMING THE DISCLOSURE INCOME TO BE MERELY TURN OVER RESULT ING IN A NET PROFIT DECLARED OF RS.85LACS ACCORDINGLY STOOD REJE CTED. SO AS ITS PLEA BASED ON RETRACTION OF SURVEY DISCLOSURE HEREI NABOVE AND THE ASSERTION THAT THE SAME WAS MERELY TURN OVER AND N OT NET PROFITS ALSO MET THE SAME FATE. THE ASSESSING OFFICER ACCO RDINGLY ADDED THE ABOVE STATE FUND OF RS.6,35,17,609/- REDUCED BY A SUM OF RS.85LACS ALREADY DECLARED RESULTING THE IMPUGNED C ONSEQUENTIAL FIGURE OF RS.5,50,17,603/-. 4. THE ASSESSEE PREFERRED APPEAL. THE CIT(A) UPHOL DS ITS ALTERNATIVE PLEA OF NET PROFIT DECLARATION AS UNDER : ITA NO.1666/AHD/2011 (DCIT VS. M/S. RAMESHWAR TEXT ILE MILLS LTD.) A.Y. 2008-09 - 3 - 7. I HAVE CONSIDERED THE AO'S CONTENTION IN THE ASSESSMENT ORDER ALONG WITH VARIOUS SEIZED MATERIAL ANNEXED WITH IT AND ALSO THE CONTENTIONS OF THE ARS IN THEIR SUBMISSION AS WELL AS DURING THE COURSE OF DISCUSSION WITH ME. ALL THE GROUNDS RAISED BY TH E APPELLANT ARE RELATED TO THE ADDITION OF RS. 5,50,17,609/-. THE A O REJECTED THE BOOKS OF ACCOUNTS U/S. 145(3) OF THE ACT WHILE FINALIZING THE ASSESSMENT ORDER. IT IS OBSERVED FROM THE ASSESSMENT ORDER THAT THE A O HAD WORKED OUT TWO FIGURES OF UNACCOUNTED TURNOVER BY TWO DIFFEREN T WAYS I.E. RS.5,05,93,563/- AS PER SANJAY'S ACCOUNT AS DERIVED IN PARA 9 OF ASSESSMENT ORDER AND RS. 6,99,37,909/- AS DERIVED I N PARA 12 OF ASSESSMENT ORDER. HE OBSERVED THAT THE AMOUNT OF RS . 5,05,93,563/- WAS SMALLER THAN THE SUM OF RS. 6,99,37,909/- AND T HEREFORE ASSUMED THAT THE SMALLER AMOUNT WAS CONTAINED AND SUBSUMED IN UNACCOUNTED SALES OF RS. 6,99,37,909/-AND HENCE TREATED THE HIG HER FIGURE AS ADDITIONAL (UNDISCLOSED) TURNOVER OF THE APPELLANT COMPANY. SINCE THE EVIDENCES RELATED TO DISCOUNT GRANTED WERE FOUND RE CORDED, HE GRANTED RS. 64,23,300/- BEING 9.18% OF ADDITIONAL TURNOVER ON ESTIMATED BASIS AND DETERMINED THE NET TURNOVER AT RS. 6,35,17,609/ - AND STATED THAT THE CLAIM OF ADDITIONAL UNACCOUNTED SALARY AND WAGE S AND OTHER EXPENSES APPEARED TO BE EXCESSIVE AND FROM THE VOLU MINOUS SALARY SLIPS SUBMITTED, IT WAS NOT CLEAR AS TO WHETHER THE SLIPS REPRESENTED ACCOUNTED WAGES OR UNACCOUNTED WAGES AND SINCE THE APPELLANT HAD ALREADY CLAIMED THE EXPENSES OF SIMILAR NATURE IN T HE BOOKS OF A/C HE CONCLUDED THAT THE APPELLANT HAD CLAIMED ALL OTHER EXPENSES IN REGULAR BOOKS AND THEREFORE, DID NOT ADMIT THE ADDITIONAL E XPENSE CLAIM. IT IS OBSERVED FROM THE ASSESSMENT ORDER THAT THE AO COUL D NOT ESTABLISH THE PRECISE AMOUNT OF ADDITIONAL TURNOVER. THE AO HAS O BSERVED IN PARA 13 OF THE ASSESSMENT ORDER THAT THE SUPPRESSED JOB CHA RGES RECEIPT WAS RS. 5,05,93,563/- (DETERMINED AS PER PARA 9 OF THE ASSESSMENT ORDER ) AND RS. 6,99,37,909/- WAS ARRIVED AT AS PER PARA 12 OF THE ASSESSMENT ORDER. SIMILARLY, IN HIS STATEMENT SHRI JAYKUMAR SH ROFF DOES NOT CATEGORICALLY ADMIT THAT THE TOTAL AMOUNT OF CHEQUE S DISCOUNTED WAS TO THE EXTENT OF RS. 4,27,40,370/- AS HE DID NOT MAINT AIN ANY RECORDS OF PERSONS GIVING THE CHEQUES. 7.1 AT THE SAME TIME, FROM THE COPY OF JOB ACCOUNT AS REFLECTED IN KSM 07-08 FILE OF LAPTOP, (REFER ANNEXURE OF ASSESS MENT ORDER) IT CAN BE SEEN THAT THE APPELLANT HAD RAISED THE BILLS FOR JOB CHARGES TO THE EXTENT OF RS. 16,12,18,006/-. THE ENTRIES OF DISCOUNT GRAN TED AS REFLECTED IN THAT ACCOUNT SHOWED AN AMOUNT OF RS. 1,11,27,100/-. THEREFORE, IF THE FIGURE OF TOTAL TURNOVER OF RS. 16,12,18,006/- IS A DOPTED, THEN THE DISCOUNT OF RS.1,11,27,100/- ALSO HAS TO BE ACCEPTE D. IN VIEW OF THESE FACTS, THE PRECISE QUANTUM OF SUPPRESSED ADDITIONAL TURNOVER BECOMES DIFFICULT TO DETERMINE. IT MAY HOWEVER BE MENTIONED THAT THE FACT OF SUPPRESSION OF TURNOVER WAS CLEARLY ESTABLISHED AND ALSO ACCEPTED BY THE DIRECTORS AND ONLY THE PRECISE QUANTUM WAS DEBA TABLE. . 7.2 CONSIDERING THE DETAILED SUBMISSIONS MADE BY THE ARS ALONGWITH VARIOUS EVIDENCES, PERUSAL OF THE IMPOUND ED MATERIALS ON RECORDS AND MORE PARTICULARLY THE TRANSACTIONS AS R ECORDED AND ITA NO.1666/AHD/2011 (DCIT VS. M/S. RAMESHWAR TEXT ILE MILLS LTD.) A.Y. 2008-09 - 4 - REFLECTED IN THE LAPTOP, UNDER MENTIONED FOUR POSSI BILITIES EMERGE UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE. (I) ENTIRE TURNOVER LESS DISCOUNT GRANTED BY THE AO TO BE TREATED AS INCOME. OR (II) THE NET INCOME AFTER GRANTING EXPENDITURE AS C LAIMED BY THE APPELLANT ON THE BASIS OF CO-EXISTENCE OF EVIDENCES OF UNACCOUNTED INCOME AND EXPENDITURE TO BE TREATED AS INCOME. OR (III) THE SEIZED RECORDS AND TRANSACTIONS CONTAINED IN LAPTOP AND USB DRIVE REFLECTS THE COMBINED PICTURE OF ACCOUNTED AN D UNACCOUNTED TRANSACTIONS OF INCOME AND EXPENDITURE AND THE NET PROFIT AS REFLECTED IN LAPTOP BE ACCEPTED OR (IV) TO ESTIMATE THE GROSS PROFIT ON ADDITIONAL T URNOVER BASED ON PAST TREND AS WELL AS THE PREVAILING RATE OF NET PROFIT IN CASE OF SIMILAR OTHER INDUSTRIES. 7.3 THE MOST PECULIAR FEATURE OF THE CASE WAS THAT DURING THE COURSE OF SURVEY, THE EVIDENCES FOUND AND IMPOUNDED WERE RELATED TO BOTH ACCOUNTED AND UNACCOUNTED TRANSACTIONS AND THE SAME WERE RECORDED SYSTEMATICALLY IN FORM OF BOOKS OF ACCOUNT S MAINTAINED ON LAPTOP AND THEREFORE, IT IS UNJUSTIFIABLE IF THE SA ME IS TOTALLY IGNORED. IN VIEW OF THIS, ALL THE POSSIBILITIES ARE REQUIRED TO BE EXAMINED ON THE BASIS OF THE AVAILABLE RECORDS AND THE FACTS AND CI RCUMSTANCES OF THE CASE. 7.4 THE AO TREATED THE ENTIRE ADDITIONAL TURNOVER OF RS. 6,99,37,909/- AS NET INCOME OF THE APPELLANT AND GR ANTED DEDUCTION ON ESTIMATED BASIS FOR DISCOUNT GRANTED BY THE APPELLA NT FOR THE REASON THAT THE ENTRIES FOR DISCOUNT WERE REFLECTED IN JOB CHARGES RECEIPTS. HOWEVER, AT THE SAME TIME, THE ENTRIES OF ALL OTHER EXPENSES AS CLAIMED TO BE UNACCOUNTED WERE ALSO REFLECTED IN THE ACCOUN TS MAINTAINED BY A DIRECTOR ON HIS LAPTOP FOR ALL UNACCOUNTED TRANSACT IONS. THE APPELLANT HAD, DURING THE COURSE OF ASSESSMENT PROCEEDINGS, S UBMITTED DETAILS OF SUCH UNACCOUNTED EXPENDITURE IN SUPPORT OF VARIOUS ENTRIES FOUND IN THE LAPTOP ALONGWITH VARIOUS EVIDENCES IN FORM OF COMPA RATIVE CHART SHOWING EXPENSES AS PER AUDITED ACCOUNTS AND EXPENS ES AS PER LAPTOP. IT CLEARLY REVEALED THAT THE EXPENSES UNDER MANY HE ADS AS REFLECTED IN THE LAPTOP WERE MORE THAN ACCOUNTED FOR IN THE BOOK S OF ACCOUNTS. THUS, THE EXISTENCE OF SUCH EXPENDITURE WAS PROVED BY THE APPELLANT AND THEREFORE, IT IS UNJUSTIFIABLE TO ALLOW SOME OF THE EXPENDITURES, I.E ONLY DISCOUNT OF RS. 64,20,300/- ON ESTIMATED BASIS AND TO IGNORE THE CLAIM OF OTHER EXPENDITURES IN THE INTEREST OF NATURAL JU STICE. 7.5 NOW COMING TO THE ANOTHER ALTERNATIVE OF GRANTING THE ENTIRE CLAI M OF UNACCOUNTED EXPENDITURE ON THE BASIS OF CO-EXIST ENCE OF ENTRIES RELATED TO ACCOUNTED AND UNACCOUNTED TRANSACTIONS I N THE LAPTOP. THE APPELLANT HAD CLAIMED THAT IT HAD INCURRED A HUGE A MOUNT OF EXPENSES ITA NO.1666/AHD/2011 (DCIT VS. M/S. RAMESHWAR TEXT ILE MILLS LTD.) A.Y. 2008-09 - 5 - TOWARDS WAGES FROM UNACCOUNTED INCOME. THE AO STATE D THAT ON THE BASIS OF VOLUMINOUS SALARY SLIP SUBMITTED AND OTHER EVIDENCES ON RECORD, IT CANNOT BE PROVED CATEGORICALLY AS TO WHE THER ALL SUCH EXPENSE WERE ACCOUNTED FOR OR NOT AND THEREFORE HE ASSUMED THAT THE SAME MUST HAVE ALREADY BEEN CLAIMED IN REGULAR BOOKS OF ACCOUNTS. HOWEVER, THE RECORDS AND EVIDENCES SUBMITTED BY THE APPELLAN T AND EXISTENCE OF VARIOUS ENTRIES IN THE LAPTOP, IN WHICH COMBINED AC COUNTS WERE MAINTAINED, AND IF THE SAME IS COMPARED WITH THE AU DITED ACCOUNTS, IT CLEARLY SUGGESTS THAT VARIOUS EXPENSES WERE INCURRE D BY THE APPELLANT BUT NOT ACCOUNTED FOR IN THE REGULAR BOOKS OF ACCOU NTS. DURING ASSESSMENT PROCEEDINGS, THE APPELLANT HAD SUBMITTED THAT THE EVIDENCES OF UNRECORDED WAGES AND SALARY EXPENDITUR E INCURRED OUT OF UNACCOUNTED ADDITIONAL INCOME WERE AVAILABLE IN THE IMPOUNDED MATERIAL ITSELF. ALSO AT THE TIME OF SURVEY PROCEED INGS, THE APPELLANT HAD CLARIFIED THAT CERTAIN EXPENSES AND MORE PARTICULAR LY WAGES WERE NOT ACCOUNTED FOR OUT OF COMPULSION IN VIEW OF CERTAIN RESTRICTIONS OF OTHER LAWS AND THE EXISTENCE OF COMPULSIVE UNACCOUNTED SA LES AS A TREND IN THE MARKET WHICH PAVED WAY FOR THE APPELLANT TO INC UR CERTAIN BUSINESS EXPENDITURE FROM SUCH UNACCOUNTED RECEIPTS. I FIND FORCE IN THE ARGUMENTS OF ARS THAT THE CO-EXISTENCE OF EVIDENCES OF UNACCOUNTED INCOME AND UNACCOUNTED EXPENDITURE CANNOT BE IGNORE D IN TOTO AS THE DEPARTMENT CANNOT APPROBATE AND REPROBATE THE SAME DOCUMENT AT THE SAME TIME. HOWEVER, IT IS ALSO NOTICED THAT THE APP ELLANT HAD FAILED TO PROVE CATEGORICALLY THAT THE, IMPUGNED UNACCOUNTED TRANSACTIONS OF EXPENSES AS REFLECTED IN COMBINED BOOKS OF ACCOUNTS MAINTAINED ON THE LAPTOP WERE NOT ACCOUNTED FOR IN THE REGULAR BOOKS OF ACCOUNTS. AT THE SAME TIME, THE AO ALSO COULD NOT ESTABLISH WITH EVI DENCE THAT THE APPELLANTS CLAIM WAS INCORRECT AND ALL THE TRANSAC TIONS OF UNACCOUNTED EXPENDITURE WERE INCORPORATED IN THE REGULAR BOOKS OF ACCOUNTS. THEREFORE, I AM OF THE VIEW THAT IF ON ONE HAND IT IS NOT JUSTIFIABLE TO REJECT THE CLAIM OF UNACCOUNTED EXPENDITURE IN TOTO BUT AT THE SAME TIME, IT IS ALSO NOT JUSTIFIABLE TO GRANT THE DEDUCTION O F ALL EXPENDITURE AS CLAIMED BY THE APPELLANT. 7.6 NOW THE THIRD ALTERNATIVE ABOUT ACCEPTING THE NET PROFIT OF RS. 57,99,590/- AS PER LAPTOP IS CONSIDERED (ANNEXURE ' E' OF THE ASSESSMENT ORDER), IT IS NOTICED THAT THE BOOKS OF ACCOUNTS AS MAINTAINED IN THE LAPTOP DO NOT APPEAR TO BE THE CO MPLETE RECORDS AS THE SURVEY ACTION WAS CARRIED OUT IN THE MONTH OF M ARCH AND THEREFORE, IT IS NOT PROPER TO FULLY RELY ON SUCH RECORDS. THE RE ARE CHANCES THAT SOME TRANSACTIONS MIGHT NOT HAVE BEEN INCORPORATED IN THE LAPTOP WHICH MIGHT BE ACCOUNTED OR UNACCOUNTED TRANSACTION AND T HEREFORE THE PICTURE ACTUALLY REFLECTED ON THE BOOKS OF ACCOUNTS IN THE LAPTOP COULD NOT BE THE CORRECT AND REAL PICTURE OF THE STATE OF AFFAIRS OF THE COMPANY. THUS, THERE ARE CERTAIN ISSUES WHICH REMAINED UNANS WERED IN THE LAPTOP'S COMBINED BOOKS OF ACCOUNTS ALSO. THEREFORE , I DO NOT FIND ANY JUSTIFICATION IN ADOPTING THE ALTERNATIVE CONTENTIO N OF ACCEPTING THE BOOK RESULTS AS REFLECTED IN THE LAPTOP. ITA NO.1666/AHD/2011 (DCIT VS. M/S. RAMESHWAR TEXT ILE MILLS LTD.) A.Y. 2008-09 - 6 - 7.7 IN VIEW OF THE ABOVE DISCUSSION IT IS TO BE HELD THAT BOOKS OF A/C ARE REQUIRED TO BE REJECTED AS THE APPELLANT HA D NOT ACCOUNTED FOR THE FULL QUANTUM OF RECEIPTS. IN VIEW OF THE DISCUS SION ABOVE, THE ENTIRE ADDITIONAL TURNOVER CANNOT BE CONSIDERED AS THE ADD ITIONAL INCOME OF THE APPELLANT. THE ADDITIONAL PROFITS ACCRUING IN R ESPECT OF THE ADDITIONAL TURNOVER IS REQUIRED TO BE DETERMINED. FACED WITH S IMILAR SITUATION IN APPEAL FOR .A. Y. 2007-08, MY PREDECESSOR HAD UPHEL D THE REJECTION OF BOOKS AND ESTIMATED THE ADDITIONAL INCOME ACCRUING TO THE APPELLANT FROM UNDISCLOSED ADDITIONAL TURNOVER AT 10% ON THE GROUND THAT G.P. FROM UNACCOUNTED TURN OVER WILL BE HIGHER THAN DECL ARED TURNOVER AND ALSO KEEPING COMPARABLE CASES IN MIND. I HAVE NO RE ASON TO DIFFER FROM THE ESTIMATES OF ADDITIONAL INCOME MADE BY MY PREDE CESSOR. IF THIS IS APPLIED TO THE HIGHEST UNDISCLOSED ADDITIONAL TURNO VER DETERMINED BY THE A.O. I.E. RS. 6,35,17,609/- , THE ADDITIONAL IN COME COMES TO RS. 63,51,761/-. THE APPELLANT HAS ALREADY DISCLOSED AN AMOUNT OF RS. 85,00,000/- AS ADDITIONAL INCOME ON ACCOUNT OF UNDI SCLOSED RECEIPTS. THEREFORE NO ADDITION OVER AND ABOVE THIS ADDITIONA L INCOME IS REQUIRED TO BE MADE. THE ADDITION OF RS. 5,50,17,609/- MADE BY THE A.O. IS THEREFORE DELETED. 5. WE HAVE HEARD BOTH THE PARTIES AND PERUSED THE C ASE FILE. THE REVENUES ARGUMENTS SEEK TO RESTORE THE ENTIRE IMPUGNED ADDITION OF RS.5,50,17,603/- AS ADDED BY A SUM OF RS.85LACS DECLARED AT THE ASSESSEES BEHEST RESULTING IN GROS S SUM OF RS.6,35,17,609/- DISCLOSED IN THE SURVEY EXERCISE ( SUPRA). THE ASSESSEE FILES BEFORE US A COPY OF THE TRIBUNALS O RDER IN ASSESSMENT YEAR 2007-08, ITA NO.1568/AHD/2010 ALONG WITH REVENUES CROSS APPEAL ITA NO. 1937/AHD/2010 DECIDE D ON 09.01.2015 RE-DETERMINING ITS NET PROFIT FROM THAT @10% OF THE ABOVE STATED SURVEY DISCLOSURE AMOUNT TO 4.85% ONLY . IT CLAIMS TO HAVE SPLIT OVER THE ENTIRE DISCLOSURE SUM OF RS.13.01 CRORE. THE ASSESSEES CASE IN THIS BACKDROP OF FAC TS IS THAT THE CIT(A) HAS RIGHTLY DETERMINED THE IMPUGNED ADDITION @10% OF RS.6,35,17,609/- I.E. UNDISCLOSED ADDITIONAL TURN O VER COMING TO RS.63,51,761/- COMING TO ALREADY LESS THAN THE D ECLARED INCOME OF RS.85LACS. THE REVENUE FAILS TO REBUT TH IS FACTUAL POSITION. WE ACCORDINGLY UPHOLD THE CIT(A)S ORDER BY FOLLOWING ITA NO.1666/AHD/2011 (DCIT VS. M/S. RAMESHWAR TEXT ILE MILLS LTD.) A.Y. 2008-09 - 7 - THE CO-ORDINATE DECISION. THE REVENUES SOLE SUBST ANTIVE GROUND FAILS ACCORDINGLY. 6. THIS REVENUES APPEAL IS DISMISSED. PRONOUNCED IN THE OPEN COURT ON THIS THE 21 ST DAY OF OCTOBER, 2015. SD/- SD/- (PRAMOD KUMAR) (S. S. GODARA ) ACCOUNTANT MEMBER JUDICIAL MEMBER AHMEDABAD: DATED 21/10/2015 TRUE COPY S.K.SINHA / COPY OF ORDER FORWARDED TO:- / REVENUE 2 / ASSESSEE ! / CONCERNED CIT 4 !- / CIT (A) ( )*+ ,--. . /0 / DR, ITAT, AHMEDABAD 1 +23 45 / GUARD FILE. BY ORDER / . // . /0