Shri Shiv Charan Singh Bais, Bhopal V. The ITO wd-3(1), Bhopal

ITA 187/IND/2014

• Counselvise Citation: [2018] 126 COUNSELVISE.COM (IT) 2336 (ITAT-INDORE)
• Duration Of Justice: 3 year(s) 10 month(s) 23 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 31-01-2018
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: 2008-2009
• Appeal Filed On: 07-03-2014
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: K G GOYAL
• Keywords: Capital asset; Additional evidence
• Section: 143(3); 54; 139

Judgement Text

, , IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER AND SHRI MANISH BORAD, ACCOUNTANT MEMBER ITA NO.187/IND/2014 ASSESSMENT YEAR: 2008-09 SHRI SHIV CHARAN SINGH BAIS, 175, INDUS EMPIRE, E-8, TRILANGA, BHOPAL (M.P.) / VS. ITO, WARD - 3(1) , BHOPAL ( REVENUE ) ( RESPONDENT ) P.A. NO. AECPB0687G APPELLANT BY SHRI PRANAY GOYAL , C A RE VENUE BY SHRI K. G. GOYAL, SR. DR DATE OF HEARING: 09.01.2018 DATE OF PRONOUNCEMENT: 31.01.2018 / O R D E R PER KUL BHARAT, J.M: THIS APPEAL BY THE ASSESSEE IS DIRECTED AGAINST THE ORDER OF LD. COMMISSIONER OF INCOME TAX(APPEALS)-2, BHOPAL, (IN SHORT CIT(A)), DATED 11.12.2013 PERTAINING TO THE A.Y. 2008-09. TH E ASSESSEE HAS RAISED FOLLOWING GROUNDS OF APPEAL: 1. THAT, ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, LD. CIT(A)-II, BHOPAL HAS ERRED IN CONFIRMING ADDITION TO THE EXTENT OF RS.23,89,533/- TO THE TOTAL INCOME OF THE ASSESS EE ON ACCOUNT OF DISALLOWANCE OF EXEMPTION U/S 54 OF THE IT ACT, 1961. SHIVCHARAN SINGH 2 2. THAT, THE LD. CIT(A)-II, BHOPAL HAS ERRED NOT TO CONSIDER THE ADDITIONAL EVIDENCES I.E. PHOTOGRAPH OF THE HOUSE P ROPERTY, PERMISSION AND APPROVAL MAP OF RESIDENTIAL HOUSE PR OPERTY BY MUNICIPAL CORPORATION, INDORE DATED. 11/1/2011 AND ARCHITECTS CERTIFICATE CERTIFYING COMPLETION OF HOUSE AND COST OF EXPENDITURE IN CONSTRUCTION OF RESIDENTIAL HOUSE PROPERTY (RS.1 2,53,350/-) DATED. 31.07.2011 FILED BY THE APPELLANT, WHICH CLE ARLY SHOWS THAT CONSTRUCTION OF RESIDENTIAL HOUSE HAS BEEN COM MENCED WELL BEFORE THE EXPIRY OF SPECIFIED PERIOD GIVEN U/S 54. THUS DISALLOWING THE EXEMPTION U/S 54 DUE TO NON FURNISH ING OF APPROVED MAP BY MUNICIPAL CORPORATION AND ARCHITECT S CERTIFICATE OF COMPLETION OF HOUSE DURING THE ASSES SMENT PROCEEDINGS IS UNJUSTIFIED. 3. THAT, LD. CIT(A)-II, BHOPAL HAS ERRED NOT TO CON SIDER THE FACT THAT THE ENTIRE CONSIDERATION RECEIVED ON SALE OF O LD PROPERTY HAS BEEN INVESTED FOR THE PURCHASE OF LAND AND EVEN THE PURCHASE VALUE OF THE LAND IS MORE THAN THE LONG TERM CAPITA L GAINS TAXABLE IN THE HANDS OF THE APPELLANT. PLEASE RELY ON THE DECISION HELD IN THE CASE OF V.A. THARABAI VS. DCIT 149 TTJ 41 (I.T.A.T. CHENNAI) IN WHICH IT WAS HELD THAT WITHOU T PURCHASING LAND, HOUSE CANNOT BE CONSTRUCTED. THE FIRST STEP I S PURCHASE OF LAND WHICH WAS DONE BY THE ASSESSEE. THEREFORE, THE ENTIRE AMOUNT SPENT BY THE ASSESSEE IN PURCHASING THE LAND SHOULD BE CONSTRUED AS AMOUNT INVESTED IN PURCHASE/CONSTRUCTI ON OF RESIDENTIAL HOUSE. 4. THAT, LD. CIT(A)-II, BHOPAL HAS ALSO ERRED NOT T O CONSIDER THE WRITTEN SUBMISSION MADE BY THE APPELLANT STATING TH AT HE HAS INVESTED TOTAL SALE CONSIDERATION IN THE PURCHASE O F LAND/CONSTRUCTION OF HOUSE BEFORE THE COMPLETION OF THREE YEARS THOUGH THE HOUSE WAS COMPLETED AFTER THE EXPIRY OF THREE YEARS. RELIANCE CAN BE PLACED ON THE FOLLOWING CASE LAWS I N WHICH IT IS HELD THAT EXEMPTION U/S. 54 IS AVAILABLE EVEN IF TH E CONSTRUCTION OF NEW HOUSE IS NOT COMPLETED WITHIN STATUTORY PERI OD:- CIT VS. SAMBANDAM UDAYKUMAR KARNATAKA H.C. 72 DTR 2 32 CIT VS. SARDARMAL KOTHARI 302 ITR 286 (MAD. H.C.) MRS. SEETHA SUBRAMANIAN VS. ACIT 56 TTJ 417(MAD.) SMT. RANJEET SANDHU VS. DCIT 133 TTJ 64 I.T.A.T., C HDG. SHIVCHARAN SINGH 3 2 . BRIEFLY STATED FACTS ARE THAT THE CASE OF THE ASS ESSEE WAS PICKED UP FOR SCRUTINY ASSESSMENT WHILE FRAMING THE ASSESS MENT U/S 143(3) OF THE INCOME TAX ACT, 1961(HEREINAFTER CALL ED AS THE ACT). THE ASSESSING OFFICER REJECTED THE CLAIM OF THE ASS ESSEE FOR EXEMPTION U/S 54 OF THE ACT. THE ASSESSING OFFICER HAS OBSERVED THAT THE ASSESSEE HAD SOLD A HOUSE PROPERTY FOR SAL E CONSIDERATION OF RS.38,55,000/-. IT WAS STATED BEFORE THE AO THAT THE ASSESSEE HAD PURCHASED 4 RESIDENTIAL PLOTS AT INDORE ON 15.1 1.2007 FOR SUM OF RS.35,25,450/- IN THE JOINT NAMES OF ASSESSEES SISTER IN LAW, SMT. PRITIKANWAR SINGH AND THE ASSESSEE. THIS CLAIM OF THE ASSESSEE WAS REJECTED BY THE AO, ON THE GROUND THAT THE PLOT S HAVE BEEN PURCHASED IN THE JOINT NAMES AND THE RESIDENTIAL HO USE IS NOT CONSTRUCTED WITHIN THE THREE YEARS FROM THE DATE OF TRANSFER. 3. AGGRIEVED BY THIS THE ASSESSEE PREFERRED AN APPE AL BEFORE THE LD. CIT(A) WHO AFTER CONSIDERING THE SUBMISSIONS SUSTAI NED THE ADDITION TO THE EXTENT OF RS. 23,89,533/- AGAINST R S.28,59,057/- MADE BY THE AO IN RESPECT OF LONG TERM CAPITAL GAIN S. 4. NOW THE ASSESSEE HAS PREFERRED THE PRESENT APPEA L. GROUND NO.1 TO 4 ARE AGAINST REJECTING OF CLAIM OF EXEMPTION U/ S 54 OF THE ACT, THEREFORE, ALL THE GROUNDS ARE BEING DISPOSED OF TO GETHER. GROUND NO.5 IS GENERAL IN NATURE THUS, THE SAME DOES NOT R EQUIRE ANY SEPARATE ADJUDICATION. 5. APROPOS GROUND NO.1 TO 4 THE LD. COUNSEL FOR THE ASSESSEE REITERATED THE SUBMISSIONS AS MADE BEFORE THE LD. C IT(A). THE LD. COUNSEL SUBMITTED THAT AUTHORITIES BELOW WERE NOT J USTIFIED IN REJECTING THE CLAIM OF EXEMPTION U/S 54 OF THE ACT. THE LD. COUNSEL SHIVCHARAN SINGH 4 SUBMITTED THAT PLOTS WERE PURCHASED AND APPLICATION FOR CONSOLIDATING THE SAME WAS MADE TO THE CONCERNED AU THORITY ALONG WITH MAP. THE LD. COUNSEL FURTHER REITERATED THE SU BMISSIONS AS MADE IN THE WRITTEN SUBMISSIONS. THE LD. COUNSEL AL SO PLACED RELIANCE ON THE VARIOUS CASE LAWS IN SUPPORT OF HIS CONTENTION. LD. COUNSEL PLACE RELIANCE ON THE DECISION OF CO-ORDINA TE BENCH OF THIS TRIBUNAL IN THE CASE OF V.A. THARABAI VS. DCIT 149 TTJ 41 (I.T.A.T., CHENNI). LD. COUNSEL FURTHER PLACED RELIANCE ON THE FOLLOWING CASE LAWS; I. CIT VS. SAMBANDAM UDAYKUMAR KARNATAKA H.C. 72 DTR 232 (KARNATAKA) II. CIT VS. SARDARMAL KOTHARI 302 ITR 286 (MAD. H.C.) III. MRS. SEETHA SUBRAMANIAN VS. ACIT 56 TTJ 417(MAD.) IV. SMT. RANJEET SANDHU VS. DCIT 133 TTJ 64 ITAT,(TRIBU NAL). IN SUPPORT OF CONTENTION THAT EXEMPTION U/S 54 WOUL D BE AVAILABLE EVEN IF THE CONSTRUCTION WITHIN STATUTORY PERIOD, W HERE THE ENTIRE SALE CONSIDERATION IS INTERESTED IN PURCHASE OF LAN D/CONSTRUCTION OF HOUSE. 6. ON THE CONTRARY LD. DR OPPOSED THE SUBMISSION AN D SUBMITTED THAT CASE LAW WOULD NOT SUPPORT THE CASE OF THE ASS ESSEE AS THE ASSESSEE FAILED TO DEMONSTRATE THAT THE LAND WAS PU RCHASED IN ASSESSEES NAME AND CONSTRUCTION WAS COMPLETED WITH IN THE PERIOD STIPULATED UNDER THE PROVISIONS OF THE ACT. HE SUBM ITTED THAT THE CASE LAWS AS RELIED UPON THE ASSESSEE DO NOT HELP T HE ASSESSEE. HE SUBMITTED THAT THE CASE LAWS AS RELIED BY THE LD. C OUNSEL ARE ONE IS THAT THE EXEMPTION WOULD BE ALLOWABLE EVEN IF THE C ONSTRUCTION OF RESIDENTIAL PROPERTY IS MADE IN JOINT NAME WITH SPO USE OR SHIVCHARAN SINGH 5 DEPENDENT CHILDREN. AND ANOTHER ISSUE IS WHERE THE ASSESSEE INVESTED ENTIRE CAPITAL GAIN FOR CONSTRUCTION OF RE SIDENTIAL HOUSE BUT THE BUILDER FAILS TO CONSTRUCT WITHIN THE SPECIFIED PERIOD. THE EXEMPTION SHOULD NOT BE DENIED IN SUCH CASE. 7. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE MATERIAL ON RECORD. WE NEED TO EXAMINE IN THE LIGHT OF FACTS OF PRESENT CASE AND THE CASE LAWS AS RELIED BY THE LD. COUNSEL FOR THE ASSESSEE. UNDISPUTED FACTS ARE THAT THE ASSESSEE SOLD A HOUSE PROPERTY AT SALE CONSIDERATION OF RS.38,55,000/- ON 17.09.2007 AND PURCHASED FOUR RESIDENTIAL PLOT ON 15.11.2007 FOR A SALE CONS IDERATION OF RS.35,25,450/- IN JOINT NAMES OF ASSESSEES SISTER IN LAW, SMT. PRITIKANWAR SINGH. APPLICATION FOR CONSOLIDATION OF PLOT ALONG WITH MAP WAS MADE ON 24.12.2010 AND PERMISSION WAS GRANT ED ON 11.01.2011. NO EVIDENCE IS PLACED ON RECORD SUGGEST ING THAT THE ASSESSEE MADE ANY APPLICATION SEEKING APPROVAL OF C ONSTRUCTION OF HOUSE PRIOR TO 24.12.2010. HOWEVER AN APPLICATION D ATED 15.03.2010 BY SISTER-IN-LAW IS PLACED ON RECORD. TH US, EX-FACIE NO EFFORT MADE BY THE ASSESSEE FOR CONSTRUCTION OF RES IDENTIAL HOUSE WITHIN THREE YEARS OF SALE OF ORIGINAL CAPITAL ASSE T EXCEPT, PURCHASING OF RESIDENTIAL PLOTS. UNDER THESE FACTS LET US EXAMINE WHETHER THE LAW ENTITLES THE ASSESSEE FOR EXEMPTION U/S 54 OF THE ACT. FOR THE SAKE OF CLARITY SECTION 54 IS REPRODUC ED HEREIN BELOW: SUBJECT TO THE PROVISIONS OF SUB-SECTION (2), WHER E, IN THE CASE OF AN ASSESSEE BEING AN INDIVIDUAL OR A HINDU UNDIV IDED FAMILY], THE CAPITAL GAIN ARISES FROM THE TRANSFER OF A LONG-TERM CAPITAL ASSET [***], BEING BUILDINGS OR LANDS APPUR TENANT THERETO, AND BEING A RESIDENTIAL HOUSE, THE INCOME OF WHICH IS CHARGEABLE UNDER THE HEAD 'INCOME FROM HOUSE PROPER TY' SHIVCHARAN SINGH 6 (HEREAFTER IN THIS SECTION REFERRED TO AS THE ORIGI NAL ASSET), AND THE ASSESSEE HAS WITHIN A PERIOD OF [ONE YEAR BEFOR E OR TWO YEARS AFTER THE DATE ON WHICH THE TRANSFER TOOK PLA CE PURCHASED], OR HAS WITHIN A PERIOD OF THREE YEARS A FTER THAT DATE CONSTRUCTED, A RESIDENTIAL HOUSE, THEN], INSTEAD OF THE CAPITAL GAIN BEING CHARGED TO INCOME-TAX AS INCOME OF THE P REVIOUS YEAR IN WHICH THE TRANSFER TOOK PLACE, IT SHALL BE DEALT WITH IN ACCORDANCE WITH THE FOLLOWING PROVISIONS OF THIS SE CTION, THAT IS TO SAY, (I) IF THE AMOUNT OF THE CAPITAL GAIN [IS GREATER T HAN THE COST OF [THE RESIDENTIAL HOUSE] SO PURCHASED OR CONSTRUCTED (HEREAFTER IN THIS SECTION REFERRED TO AS THE NEW ASSET)], THE DI FFERENCE BETWEEN THE AMOUNT OF THE CAPITAL GAIN AND THE COST OF THE NEW ASSET SHALL BE CHARGED UNDER SECTION 45 AS THE INCOME OF THE PREVIOUS YEAR; AND FOR THE PURPOSE OF COMPUTING IN RESPECT OF THE NEW ASSET ANY CAPITAL GAIN ARISING FROM ITS TRANSFE R WITHIN A PERIOD OF THREE YEARS OF ITS PURCHASE OR CONSTRUCTI ON, AS THE CASE MAY BE, THE COST SHALL BE NIL; OR (II) IF THE AMOUNT OF THE CAPITAL GAIN IS EQUAL TO OR LESS THAN THE COST OF THE NEW ASSET, THE CAPITAL GAIN SHALL NOT B E CHARGED UNDER SECTION 45; AND FOR THE PURPOSE OF COMPUTING IN RESPECT OF THE NEW ASSET ANY CAPITAL GAIN ARISING FROM ITS TRA NSFER WITHIN A PERIOD OF THREE YEARS OF ITS PURCHASE OR CONSTRUCTI ON, AS THE CASE MAY BE, THE COST SHALL BE REDUCED BY THE AMOUNT OF THE CAPITAL GAIN. [***] [(2) THE AMOUNT OF THE CAPITAL GAIN WHICH IS NOT AP PROPRIATED BY THE ASSESSEE TOWARDS THE PURCHASE OF THE NEW ASSET MADE WITHIN ONE YEAR BEFORE THE DATE ON WHICH THE TRANSF ER OF THE ORIGINAL ASSET TOOK PLACE, OR WHICH IS NOT UTILISED BY HIM FOR THE PURCHASE OR CONSTRUCTION OF THE NEW ASSET BEFORE TH E DATE OF FURNISHING THE RETURN OF INCOME UNDER SECTION 139 , SHALL BE DEPOSITED BY HIM BEFORE FURNISHING SUCH RETURN [SUC H DEPOSIT BEING MADE IN ANY CASE NOT LATER THAN THE DUE DATE APPLICABLE IN THE CASE OF THE ASSESSEE FOR FURNISHING THE RETU RN OF INCOME UNDER SUB-SECTION (1) OF SECTION 139] IN AN ACCOUNT IN ANY SUCH BANK OR INSTITUTION AS MAY BE SPECIFIED IN, AND UTI LISED IN SHIVCHARAN SINGH 7 ACCORDANCE WITH, ANY SCHEME30 WHICH THE CENTRAL GOV ERNMENT MAY, BY NOTIFICATION IN THE OFFICIAL GAZETTE, FRAME IN THIS BEHALF AND SUCH RETURN SHALL BE ACCOMPANIED BY PROOF OF SU CH DEPOSIT; AND, FOR THE PURPOSES OF SUB-SECTION (1), THE AMOUN T, IF ANY, ALREADY UTILISED BY THE ASSESSEE FOR THE PURCHASE O R CONSTRUCTION OF THE NEW ASSET TOGETHER WITH THE AMO UNT SO DEPOSITED SHALL BE DEEMED TO BE THE COST OF THE NEW ASSET : PROVIDED THAT IF THE AMOUNT DEPOSITED UNDER THIS SU B-SECTION IS NOT UTILISED WHOLLY OR PARTLY FOR THE PURCHASE OR C ONSTRUCTION OF THE NEW ASSET WITHIN THE PERIOD SPECIFIED IN SUB-SE CTION (1), THEN, (I) THE AMOUNT NOT SO UTILISED SHALL BE CHARGED UND ER SECTION 45 AS THE INCOME OF THE PREVIOUS YEAR IN WHICH THE PER IOD OF THREE YEARS FROM THE DATE OF THE TRANSFER OF THE ORIGINAL ASSET EXPIRES; AND (II) THE ASSESSEE SHALL BE ENTITLED TO WITHDRAW SUC H AMOUNT IN ACCORDANCE WITH THE SCHEME AFORESAID. THUS, FROM THE ABOVE IT IS EVIDENT THAT THE ASSESSE E IS REQUIRED TO CONSTRUCT A RESIDENTIAL HOUSE WITHIN THREE YEARS FR OM THE DATE OF TRANSFER OF THE ORIGINAL ASSET. THE PROVISION CLEAR LY MANDATES THE UTILIZATION OF WHOLLY OR PARTLY FOR THE PURCHASE OR CONSTRUCTION OF NEW ASSET I.E. RESIDENTIAL HOUSE. WE HAVE PERUSED T HE CASE LAWS AS RELIED BY THE LD. COUNSEL FOR THE ASSESSEE. THE LD. COUNSEL RELIED UPON THE JUDGMENT OF HON'BLE JURISDICTIONAL HIGH CO URT RENDERED IN CASE OF SMT. SHASHI VARMA VS. CIT 152 CTR 0227, IN SUPPORTED OF THE CONTENTION THAT THE ASSESSEE HAD MADE SUBSTANTI AL INVESTMENT IN PURCHASE OF PLOTS WHEN THE HON'BLE COURT HELD AS UNDER: 3. WE HAVE HEARD COUNSEL AND PERUSED THE RECORD. I N FACT, THE TRIBUNAL HAS TAKEN A VERY PEDANTIC APPROACH WHILE C ONSTRUING THE PROVISIONS OF SECTION 54 OF THE INCOME-TAX ACT. IN THE PRESENT CASE, IN FACT, THE CAPITAL GAIN IS RS. 51,980 ; WHE REAS THE FIRST SHIVCHARAN SINGH 8 INSTALMENT TOWARDS THE FLAT FROM THE DELHI DEVELOPM ENT AUTHORITY WAS RS. 71,256, I.E., MUCH MORE THAN THE CAPITAL GAINS. THE CENTRAL BOARD OF DIRECT TAXES ALSO ISSUE D CIRCULAR NO. 471 (SEE [1986] 162 ITR (ST.) 41), DATED OCTOBE R 15, 1986, AND HAS CLARIFIED AS UNDER : ' THEREFORE, FOR THE PURPOSE OF CAPITAL GAINS TAX, THE COST OF THE NEW ASSET IS THE TENTATIVE COST OF CONSTRUCTION AND THE FACT THAT THE AMOUNT WAS ALLOWED TO BE PAID IN INSTALMENTS DO ES NOT AFFECT THE LEGAL POSITION STATED ABOVE. IN VIEW OF THESE FACTS, IT HAS BEEN DECIDED THAT CASES OF ALLOTMENT OF FLATS U NDER THE SELF- FINANCING SCHEME OF THE DELHI DEVELOPMENT AUTHORITY SHALL BE TREATED AS CASES OF CONSTRUCTION FOR THE PURPOSE OF CAPITAL GAINS.' 8. IT IS THE CONTENTION OF THE ASSESSEE THAT HE HAS SUBSTANTIALLY INVESTED MONEY IN CONSTRUCTION OF RESIDENTIAL HOUSE . ADMITTEDLY, THE ASSESSEE HAD PURCHASED IN JOINT NAMES 4 PLOTS. IT I S ALSO EVIDENT FROM THE RECORD THAT AN APPLICATION FOR CONSOLIDATI ON OF THESE PLOTS WAS MADE BY SISTER-IN-LAW OF THE ASSESSEE ON 15.03. 2010. IN OUR CONSIDERED VIEW ON THE FACTS OF THE PRESENT CASE TH E JUDGMENT OF HON'BLE M.P. HIGH COURT WOULD NOT BE APPLICABLE AS IN THE PRESENT CASE ORIGINAL ASSET WAS SOLD ON 17.09.2007. THE APP LICATION FOR CONSOLIDATION AND CONSTRUCTION OF THE HOUSE WAS MAD E BY SISTER-IN- LAW OF THE ASSESSEE ON 15.03.2010 I.E. AFTER TWO YE ARS AND 7 MONTHS AND APPLICATION FOR CONSTRUCTION OF HOUSE WAS MADE AFTER EXPIRY OF THREE YEARS I.E. ON 24.12.2010 AND THE APPROVAL WAS GRANTED ON 11.01.2011. THE ASSESSEE COULD NOT DEMONSTRATE THAT THE DELAY IN CONSTRUCTION OF THE PROPERTY WAS CAUSED BY ANY CIRC UMSTANCES WHICH WERE BEYOND HIS CONTROL. THEREFORE, WE DO NOT SEE ANY REASON TO INTERFERE TO THE FINDING OF THE AUTHORITIES BELO W. MOREOVER, THERE SHIVCHARAN SINGH 9 IS NO INORDINATE DELAY ON THE PART OF THE LEGAL AUT HORITY TO GRANT PERMISSION FOR CONSTRUCTION OF HOUSE. THERE IS ANOT HER ASPECT OF THE MATTER THAT ASSESSEE HAD PURCHASED PLOTS FOR THE PU RPOSE OF INVESTMENT UNLESS THE ASSESSEE AFTER TAKING POSSESS ION THEREOF MAKES EFFORTS TO CONSTRUCT THE RESIDENTIAL HOUSE ON SUCH PLOTS. THUS, THE GROUNDS RAISED IN THIS APPEAL ARE DISMISS ED. 9. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS DISMI SSED. ORDER WAS PRONOUNCED IN THE OPEN COURT ON 31 .01. 2018. SD/- (MANISH BORAD) SD/- (KUL BHARAT) CCOUNTANT MEMBER JUDICIALMEMBER INDORE; DATED : 31 / 01/2018 CTX? P.S/. . . COPY TO: ASSESSEE/AO/PR. CIT/ CIT (A)/ITAT (DR)/GUA RD FILE. BY ORDER PRIVATE SECRETARY/DDO, INDORE