Shri Chokshi Natvarlal Vachhraj Charitable Trust, JUNAGADH V. The Income Tax Officer, JUNAGADH

ITA 196/RJT/2014

• Counselvise Citation: [2014] 140 COUNSELVISE.COM (IT) 85408 (ITAT-RAJKOT)
• Duration Of Justice: 6 month(s) 28 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 10-10-2014
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB
• Next Hearing Date: 08-10-2014
• Assessment Year: 2006-2007
• Appeal Filed On: 13-03-2014
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Charitable institution; Maximum Marginal Rate
• Section: 143(3); 12A; 148; 263; 63; 12; 11

Judgement Text

: : IN THE INCOME TAX APPELLATE TRIBULAL: RAJKOT BENCH: RAJKOT BEFORE SHRI G.C. GUPTA, VICE PRESIDENT AND SHRI ANIL CHATURVEDI, ACCOUNTANT MEMBER ./ ITA NO.196/RJT/2014 / ASSESSMENT YEAR: 2006-07 SHRI CHOKSHI NATVARLAL VACHHRAJ CHARITABLE TRUST, GANDHIGRAM, JUNAGADH PAN : AAATC 2604 G VS INCOME TAX OFFICER, WARD-1(1) JUNAGADH / (APPELLANT) / (RESPONDENT) ASSESSEE(S) BY : SHRI SAMIR JANI, ADVOCATE REVENUE BY : SHRI YOGESH PANDE, DR / DATE OF HEARING : 08/10/2014 / DATE OF PRONOUNCEMENT: 10/10/2014 / O R D E R PER SHRI ANIL CHATURVEDI, ACCOUNTANT MEMBER : THIS APPEAL IS PREFERRED BY THE ASSESSEE AGAINST TH E ORDER OF THE LEARNED COMMISSIONER OF INCOME-TAX, RAJKOT-III, RAJ KOT DATED 11.09.2010, PASSED U/S 263 OF THE INCOME-TAX ACT F OR THE ASSESSMENT YEAR 2006-07. 2. THE FACTS AS CULLED OUT FROM THE MATERIAL ON REC ORD ARE AS UNDER: 3. THE ASSESSEE IS A CHARITABLE TRUST INCORPORATED ON 02.03.2000 & REGISTERED WITH CHARITY COMMISSIONER UNDER BOMBAY P UBLIC TRUST ACT. 4. THE ASSESSEE MADE AN APPLICATION FOR REGISTRATIO N U/S 12A ON 23.03.2000 WHICH WAS SENT THROUGH REGISTERED POST A ND WAS RECEIVED ITA NO 196/RJT/2014 AY 2006-07 SHRI CHOKSHI NATVARLAL VACHHRAJ CHARITABLE TRUST - 2 - BY THE OFFICE OF THE CIT ON 28.03.2000. ON NOT REC EIVING THE REGISTRATION CERTIFICATE, THE TRUST SENT A REMINDER ON 10.04.2002 TO CITS OFFICE. THE ASSESSEE THEREAFTER FILED ITS FIR ST RETURN OF INCOME FOR AY 2001-02 WHEREBY IT CLAIMED EXEMPTION U/S 11 ON T HE ASSUMPTION OF HAVING GRANTED REGISTRATION CERTIFICATE UNDER THE D EEMING PROVISIONS OF SECTION 12A(2). 5. FOR ASSESSMENT YEAR 2006-07, THE ASSESSEE ORIGIN ALLY FILED ITS RETURN OF INCOME ON 27.9.2006 DECLARING TOTAL INCOME AT RS.6,15,200/-. THE RETURN OF INCOME WAS PROCESSED U/S 143(1) OF TH E ACT. SUBSEQUENTLY, NOTICE U/S 148 WAS ISSUED ON 11.03.20 11 BY THE ASSESSING OFFICER FOR THE REASON THAT ON THE BASIS OF AIR INFORMATION RECEIVED BY HIM, IT WAS NOTICED THAT ASSESSEE HAD D EPOSITED CASH OF RS.15,90,000/- IN HIS SAVINGS BANK A/C AND IT WAS N OT REFLECTED IN THE RETURN OF INCOME AND THEREFORE, THE AFORESAID AMOUN T HAS ESCAPED ASSESSMENT. IN RESPONSE TO NOTICE U/S 148, THE ASSE SSEE SUBMITTED THAT THE RETURN OF INCOME OF RS.6,15,200/- FILED ORIGINA LLY ON 27.09.2006 BE CONSIDERED AS RETURN FILED IN RESPONSE TO NOTICE IS SUED U/S 148. THEREAFTER THE ASSESSMENT WAS FRAMED U/S 143(3) R.W .S. 147 VIDE ORDER DATED 01.12.2011 AND THE TOTAL INCOME WAS DETERMINE D AT RS.6,15,200/- BEING THE RETURNED INCOME. SUBSEQUENT LY, ON EXAMINATION OF THE RECORDS OF THE ASSESSMENT, THE L D. CIT NOTICED THAT THE ASSESSEE HAD DECLARED TOTAL INCOME OF RS.6,15,2 00/- AFTER CLAIMING EXEMPTION OF RS.20,42,511/- U/S 11 OF THE ACT. HE N OTICED THAT DURING THE ASSESSMENT PROCEEDINGS, THE ASSESSING OFFICER D ID NOT VERIFY THE CONDITIONS MAKING ELIGIBLE THE TRUST FOR EXEMPTION U/S 11 OF THE ACT AS WELL AS THE GENUINENESS OF THE ACTIVITIES OF THE TR UST. HE WAS, THEREFORE, OF THE VIEW THAT THE ALLOWANCE OF BENEFITS U/S 11 O F THE ACT WITHOUT VERIFYING REGISTRATION U/S 12A OF THE ACT AS WELL A S GENUINENESS OF ITS ACTIVITIES VIS--VIS THE OBJECTS OF THE TRUST, WAS NOT ONLY ERRONEOUS BUT ITA NO 196/RJT/2014 AY 2006-07 SHRI CHOKSHI NATVARLAL VACHHRAJ CHARITABLE TRUST - 3 - ALSO PREJUDICIAL TO THE INTEREST OF THE REVENUE. HE ACCORDINGLY ISSUED NOTICE AND CALLED UPON THE ASSESSEE TO SHOW-CAUSE A S TO WHY THE ORDER U/S 263 OF THE ACT NOT BE PASSED. IN RESPONSE TO TH E SHOW-CAUSE NOTICE, THE ASSESSEE INTER-ALIA OBJECTED TO THE INI TIATION OF PROCEEDINGS U/S 263 OF THE ACT. THE SUBMISSIONS OF THE ASSESSE E WERE NOT FOUND ACCEPTABLE TO THE CIT. HE WAS OF THE VIEW THAT THE TRUST IS NOT ELIGIBLE FOR THE BENEFITS U/S 11 & 12 OF THE ACT AND THE INT EREST OF ITS BENEFICIARIES IS ALSO NOT DEFINED AND THE TOTAL INC OME WILL BE CHARGEABLE TO TAX AT MAXIMUM MARGINAL RATE OF TAX AS PROVIDED IN SECTION 164(1) OF THE ACT. HE WAS, THEREFORE, OF THE VIEW THAT THE ASSESSMENT FRAMED BY THE ASSESSING OFFICER WAS ERRONEOUS AND THEREFOR E PREJUDICIAL TO THE INTEREST OF THE REVENUE. HE, THEREFORE, MODIFIED TH E ORDER PASSED ON 01.12.2011 BY CONSIDERING THE GROSS INCOME SHOWN BY THE ASSESSEE AS PER INCOME AND EXPENDITURE ACCOUNT AS THE TOTAL INC OME OF THE ASSESSEE. AGGRIEVED BY THE ORDER OF THE CIT, THE A SSESSEE IS NOW IN APPEAL BEFORE US. 6. BEFORE US, LD. AR SUBMITTED THAT THE ASSESSEE HA D MADE APPLICATION FOR REGISTRATION U/S 12A ALONGWITH REQU IRED DOCUMENTS ON 23.03.2000 WHICH WAS SENT THROUGH REGISTERED POST T O THE OFFICE OF THE CIT ON 28.03.2000. THE ASSESSEE THEREAFTER PURSUED THE GRANT OF REGISTRATION BUT ON NOT RECEIVING THE REGISTRATION CERTIFICATE, IT AGAIN SENT A REMINDER ON 10.04.2002 TO CITS OFFICE. SINC E THE TIME TO FILE THE RETURN WAS DUE, THE ASSESSEE ALONGWITH AUDITED ACCO UNTS FILED ITS FIRST RETURN OF INCOME FOR AY 2001-02 CLAIMING EXEMPTION U/S 11 ON THE ASSUMPTION OF HAVING GRANTED THE REGISTRATION CERTI FICATE UNDER THE DEEMING PROVISIONS OF SECTION 12A(2) OF THE ACT. HE FURTHER SUBMITTED THAT THE ASSESSEE HAS SINCE BEEN REGULARLY FILING I TS RETURN OF INCOME WITHIN THE TIME PERMITTED U/S 139(1) AND THE ASSESS MENT HAS ALSO BEEN COMPLETED U/S 143(1) TILL ASSESSMENT YEAR 2012-13. THE LD. AR FURTHER ITA NO 196/RJT/2014 AY 2006-07 SHRI CHOKSHI NATVARLAL VACHHRAJ CHARITABLE TRUST - 4 - SUBMITTED THAT FOR AY 2006-07 THE ASSESSMENT WAS IN ITIALLY COMPLETED U/S 143(1). DURING THE YEAR, THE ASSESSEE HAD MADE CERTAIN INVESTMENTS AND BASED ON THE AIR INFORMATION, THE A SSESSING OFFICER HAD ISSUED NOTICE U/S 147 AND THEREAFTER, AFTER EXA MINING THE REPLIES OF THE ASSESSEE AND OTHER RECORDS AND ON BEING SATISFI ED, THE ASSESSING OFFICER PASSED ORDER U/S 143(3) R.W.S. 147 ON 01.12 .2011. THE LD. AR FURTHER SUBMITTED THAT IN THE PRESENT CASE THE PRE- REQUISITE CONDITIONS SPECIFIED U/S 263 WERE NOT SATISFIED AND THEREFORE THE PROCEEDINGS U/S 263 LACKS JURISDICTION AND ARE BAD IN LAW. HE SUBM ITTED THAT UNDER SECTION 263, THE CIT CAN REVISE AN ORDER PASSED BY THE ASSESSING OFFICER ONLY ON THE SATISFACTION OF TWIN CONDITIONS , NAMELY, (1) THE ORDER IS ERRONEOUS AND (2) IT IS PREJUDICIAL TO THE INTER EST OF THE REVENUE. HE FURTHER SUBMITTED THAT ERROR ENVISAGED BY SECTION 2 63 SHOULD BE ACTUAL ERROR, EITHER FACTS OR LAW; AND WHEN TWO VIEWS ARE POSSIBLE AND THE ASSESSING OFFICER HAS TAKEN ONE VIEW WITH WHICH CIT DOES NOT AGREE, THE ORDER OF ASSESSING OFFICER CANNOT BE TREATED AS ERRONEOUS ORDER PREJUDICIAL TO THE INTEREST OF THE REVENUE UNLESS T HE VIEW TAKEN BY THE ASSESSING OFFICER IS UNSUSTAINABLE IN LAW. THE LD. AR FURTHER SUBMITTED THAT DURING THE COURSE OF ASSESSMENT PROCEEDINGS U/ S 143(3) R.W.S. 147, THE ASSESSING OFFICER HAD VERIFIED THE SUBMISS IONS OF THE ASSESSEE AND ON BEING SATISFIED HAD ACCEPTED THE RETURN INCO ME AS THE TOTAL INCOME OF THE ASSESSEE. HE, THEREFORE, SUBMITTED TH AT SINCE THE VIEW HAS ALREADY BEEN TAKEN BY THE ASSESSING OFFICER, TH E ORDER OF THE ASSESSING OFFICER CANNOT BE CONSIDERED AS PREJUDICI AL TO THE INTEREST OF THE REVENUE. HE FURTHER PLACED RELIANCE ON THE DECI SION OF THE TRIBUNAL IN THE CASE OF ADI NEMNATH JAIN DAHERASAR-NI-PEDHI V. CIT IN ITA NO.319/AHD/2008, ORDER DATED 29.05.2009 AND ORDER I N THE CASE OF SHRI PARASHWANATH DHERASSAR TRUST V. ADIT (EX.) IN ITA NO.435/AHD/2007, ORDER DATED 01.06.2007. HE ALSO P LACED RELIANCE ON THE DECISION OF SPECIAL BENCH OF TRIBUNAL IN THE CA SE OF BHAGWAD ITA NO 196/RJT/2014 AY 2006-07 SHRI CHOKSHI NATVARLAL VACHHRAJ CHARITABLE TRUST - 5 - SWARUP SHRI SHRI DEVRAHA BABA MEMORIAL SHRI HARI PA RMARTH DHAM TRUST V. CIT, REPORTED IN [2008] 111 ITD 175 (DELHI ) (SB), A COPY OF WHICH IS PLACED AT PAGE NO.38-44 OF THE PAPER-BOOK. HE ALSO PLACED RELIANCE ON THE DECISION OF THE HONBLE HIGH COURT OF ALLAHABAD IN THE CASE OF SOCIETY FOR THE PROMOTION OF EDUCATION ADVE NTURE SPORT & CONSERVATION OF ENVIRONMENT V. CIT, REPORTED IN (20 08) 216 CTR (ALL) 167; COPY OF WHICH IS ALSO PLACED AT PAGE NO.49-54 OF THE PAPER-BOOK. 7. THE LD. DR, ON THE OTHER HAND, SUBMITTED THAT AF TER SENDING THE APPLICATION IN MARCH 2000 BY POST THE ASSESSEE DID NOT MADE ANY EFFORTS TO VERIFY ABOUT THE FATE OF ITS APPLICATION . HE FURTHER SUBMITTED THAT THE PROVISIONS OF SECTION 12A ARE DIRECTORY IN NATURE. HE FURTHER SUBMITTED THAT THE CASE-LAWS RELIED UPON BY THE ASS ESSEE ARE DISTINGUISHABLE ON FACTS. HE FURTHER PLACED RELIANC E ON THE DECISION OF THE HONBLE ORISSA HIGH COURT IN THE CASE OF M/S. S RIKHETRA, A.C. BHAKTIVEDANTA SWAMI CHARITABLE TRUST VS. ACIT, ORDE R DATED 09.05.2006 AND DECISION OF HONBLE MADRAS HIGH COUR T IN THE CASE OF CIT VS. KARIMANGALAM ONRIYA PENGAL SEMIPU AMAIPU LT D., REPORTED IN 354 ITR 483 ORDER DATED 20.03.2013. HE THUS SUPPO RTED THE ORDER OF THE CIT. 8. WE HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE MATERIAL ON RECORD. THE ISSUE IN THE PRESENT CASE IS ABOUT INVO KING OF PROVISIONS OF SECTION 263 BY THE CIT. SECTION 263(1) OF THE ACT D EALS WITH THE POWERS UNDER WHICH THE COMMISSIONER HAS ASSUME POWER FOR R EVISION, WHICH READS AS UNDER:- 263. (1) THE [PRINCIPAL COMMISSIONER OR] COMMISSIO NER MAY CALL FOR AND EXAMINE THE RECORD OF ANY PROCEEDING UNDER THIS ACT, AND IF HE CONSIDERS THAT ANY ORDER PASSED THEREIN BY TH E [ASSESSING] OFFICER IS ERRONEOUS IN SO FAR AS IT IS PREJUDICIAL TO THE INTERESTS OF THE REVENUE, HE MAY, AFTER GIVING THE ASSESSEE AN O PPORTUNITY OF BEING HEARD AND AFTER MAKING OR CAUSING TO BE MADE SUCH INQUIRY ITA NO 196/RJT/2014 AY 2006-07 SHRI CHOKSHI NATVARLAL VACHHRAJ CHARITABLE TRUST - 6 - AS HE DEEMS NECESSARY, PASS SUCH ORDER THEREON AS T HE CIRCUMSTANCES OF THE CASE JUSTIFY, INCLUDING AN ORD ER ENHANCING OR MODIFYING THE ASSESSMENT, OR CANCELLING THE ASSESSM ENT AND DIRECTING A FRESH ASSESSMENT. THE READING OF THE ABOVE PROVISIONS MAKES IT VERY C LEAR THAT THE POWER OF SUO-MOTU REVISION U/S.263(1) IS IN THE NAT URE OF SUPERVISORY JURISDICTION AND THE SAME CAN BE EXERCISED ONLY IF THE CIRCUMSTANCES SPECIFIED THEREIN EXISTS. TWO CIRCUMSTANCES MUST EX IST TO ENABLE THE COMMISSIONER TO EXERCISE POWER OF REVISION U/S.263, NAMELY; (1) THE ORDER OF THE ASSESSING OFFICER MUST BE ERRONEOUS AN D (2) BY VIRTUE OF THE ORDER BEING ERRONEOUS, PREJUDICE HAS BEEN CAUSE D TO THE INTEREST OF THE REVENUE. THE HONBLE APEX COURT IN THE CASE OF MALABAR INDUSTRIAL CO. LTD. VS. COMMISSIONER OF INCOME TAX, [2000] 243 ITR 83 (SC), HAS HELD THAT PROVISIONS OF SECTION 263 CANNOT BE INVOK ED TO CORRECT EACH AND EVERY TYPE OF MISTAKE OR ERROR COMMITTED BY THE ASSESSING OFFICER. IT HAS FURTHER HELD THAT WHEN AN INCOME TAX OFFICER ADOPTED ONE OF THE COURSES PERMISSIBLE IN LAW AND IT HAS RESULTED IN L OSS OF REVENUE; OR WHERE TWO VIEWS ARE POSSIBLE AND THE INCOME TAX OFF ICER HAS TAKEN ONE VIEW WITH WHICH THE COMMISSIONER DOES NOT AGREE, IT CANNOT BE TREATED AS AN ERRONEOUS ORDER PREJUDICIAL TO THE INTERESTS OF THE REVENUE UNLESS THE VIEW TAKEN BY THE INCOME TAX OFFICER IS UNSUSTA INABLE IN LAW. IN THE CASE OF CIT V. GABRIEL INDIA LTD. [1993] 203 ITR 10 8 (BOM), THE HONBLE MUMBAI HIGH COURT HAS HELD THAT AN ORDER C ANNOT BE TERMED AS ERRONEOUS UNLESS IT IS NOT IN ACCORDANCE WITH LA W. SECTION 263 DOES NOT VISUALIZE A CASE OF SUBSTITUTION OF THE JUDGMEN T OF THE COMMISSIONER FOR THAT OF THE INCOME-TAX OFFICER, WH O PASSED THE ORDER UNLESS THE DECISION IS HELD TO BE ERRONEOUS. CASES MAY BE VISUALIZED WHERE THE INCOME-TAX OFFICER WHILE MAKING AN ASSESS MENT EXAMINES THE ACCOUNTS, MAKES ENQUIRIES, APPLIES HIS MIND TO THE FACTS AND CIRCUMSTANCES OF THE CASE AND DETERMINES THE INCOME EITHER BY ACCEPTING THE ACCOUNTS OR BY MAKING SOME ESTIMATE H IMSELF. THE ITA NO 196/RJT/2014 AY 2006-07 SHRI CHOKSHI NATVARLAL VACHHRAJ CHARITABLE TRUST - 7 - COMMISSIONER, ON PERUSAL OF THE RECORDS, MAY BE OF THE OPINION THAT THE ESTIMATE MADE BY THE OFFICER CONCERNED WAS ON T HE LOWER SIDE AND LEFT TO THE COMMISSIONER HE WOULD HAVE ESTIMATED TH E INCOME AT A FIGURE HIGHER THAN THE ONE DETERMINED BY THE INCOME -TAX OFFICER. THAT WOULD NOT VEST THE COMMISSIONER WITH POWER TO RE- E XAMINE THE ACCOUNTS AND DETERMINE THE INCOME HIMSELF AT A HIGH ER FIGURE. IT IS BECAUSE THE INCOME TAX OFFICER HAS EXERCISED THE QU ASI-JUDICIAL POWER VESTED IN HIM IN ACCORDANCE WITH LAW AND ARRIVED AT CONCLUSION AND SUCH A CONCLUSION CANNOT BE TERMED TO BE ERRONEOUS SIMPLY BECAUSE THE COMMISSIONER DOES NOT FEEL SATISFIED WITH THE C ONCLUSION. IT MAY BE SAID IN SUCH A CASE THAT IN THE OPINION OF THE COMM ISSIONER THE ORDER IN QUESTION IS PREJUDICIAL TO THE INTEREST OF THE REVE NUE. BUT THAT BY ITSELF WILL NOT BE ENOUGH TO VEST THE COMMISSIONER WITH TH E POWER OF SUO MOTU REVISION BECAUSE THE FIRST REQUIREMENT, NAMELY , THAT THE ORDER IS ERRONEOUS, IS ABSENT. SIMILARLY IF AN ORDER IS ERR ONEOUS BUT NOT PREJUDICIAL TO THE INTEREST OF THE REVENUE THEN ALS O THE POWER OF SUO MOTU REVISION CANNOT BE EXERCISED. ANY AND EVERY ER RONEOUS ORDER CANNOT BE SUBJECT MATTER OF REVISION BECAUSE THE SE COND REQUIREMENT ALSO MUST BE FULFILLED. 9. IN THE PRESENT CASE, IT IS SEEN THAT FOR AY 2006 -07 INITIALLY THE ASSESSMENT WAS FRAMED U/S 143(1). THEREAFTER, THE C ASE WAS RE- OPENED AND THE ASSESSMENT WAS FRAMED U/S 143(3) R.W .S. 147 AND THE INCOME RETURNED BY THE ASSESSEE WAS EXAMINED AND AC CEPTED BY THE ASSESSING OFFICER. IN SUCH A SITUATION, IT CANNOT B E SAID THAT THE ASSESSING OFFICER HAS NOT EXAMINED THE CONDITIONS A BOUT THE ELIGIBILITY OF ASSESSEE FOR EXEMPTION U/S 11 OF THE ACT MORE SO WHEN THE CASE OF THE ASSESSEE HAS BEEN REOPENED U/S 148 OF THE ACT A ND FOR WHICH WE ALSO GET SUPPORT FROM THE DECISION OF THE HONBLE D ELHI HIGH COURT IN THE CASE OF CIT VS. HONDA SIEL POWER PRODUCTS LTD, 333 ITR 547 (DEL.), ITA NO 196/RJT/2014 AY 2006-07 SHRI CHOKSHI NATVARLAL VACHHRAJ CHARITABLE TRUST - 8 - WHEREIN IT HAS BEEN HELD THAT WHEN A REGULAR ASSESS MENT IS MADE U/S 143(3) OF THE ACT, A PRESUMPTION CAN BE RAISED THAT THE ORDER HAS BEEN PASSED UPON AN APPLICATION OF MIND. FURTHER, THE SU BMISSIONS OF THE ASSESSEE THAT IT HAD MADE AN APPLICATION FOR REGIST RATION U/S 12A BEFORE THE CIT HAS NOT BEEN DOUBTED BY THE REVENUE AND THE VIEW OF THE ASSESSEE OF BEING GRANTED THE REGISTRATION UNDER TH E DEEMING PROVISIONS OF SECTION 12A(2) IS ALSO BASED ON THE B ASIS OF JUDICIAL PRONOUNCEMENTS. BEFORE US, THE REVENUE HAS NOT BROU GHT ANY MATERIAL ON RECORD TO DEMONSTRATE THAT THE VIEW TAKEN BY THE ASSESSING OFFICER IN AN IMPERMISSIBLE VIEW AND WAS CONTRARY TO LAW AN D WAS UPON ERRONEOUS APPLICATION OF LEGAL PRINCIPLES NECESSITA TING EXERCISING OF REVISIONARY POWER U/S 263 OF THE ACT. CONSIDERING T HE AFORESAID FACTS, WE ARE OF THE VIEW THAT IN THE PRESENT CASE THE COM MISSIONER OF INCOME-TAX WAS NOT JUSTIFIED IN RESORTING THE REVIS IONARY POWERS U/S 263 OF THE ACT. WE, THEREFORE, SET ASIDE THE ORDER OF THE COMMISSIONER OF INCOME-TAX. THUS, THE GROUND OF THE ASSESSEE IS ALLOWED. 10. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS AL LOWED. ORDER PRONOUNCED IN THE COURT ON FRIDAY, THE 10 TH OF OCTOBER, 2014 AT RAJKOT. SD/- SD/- (G.C. GUPTA) VICE PRESIDENT ( ANIL CHATURVEDI ) ACCOUNTANT MEMBER AHMEDABAD; DATED /10/2014 *BIJU T. ! / COPY OF ORDER FORWARDED TO:- 1. ! / APPELLANT- SHRI CHOKSHI NATVARLAL VACHHRAJ CHARI TABLE TRUST, GANDHIGRAM, J UNAGADH 2. #$ ! / RESPONDENT- INCOME TAX OFFICER, WARD-1(1), JUNAG ADH ITA NO 196/RJT/2014 AY 2006-07 SHRI CHOKSHI NATVARLAL VACHHRAJ CHARITABLE TRUST - 9 - 3. &'& ( / CONCERNED CIT/DIT 4 . )*+ #,, , , / DR, ITAT, RAJKOT 5 . +./ 01 / GUARD FILE. ' / BY ORDER, TRUE COPY #/$ % ( DY./ASSTT.REGISTRAR) & ' / ITAT, RAJKOT