ACIT (OSD), Gurgaon V. Smt. Chanderwati Wd/o. Late Sh. Jagdish Chand, Gurgaon

ITA 1966/DEL/2012

• Counselvise Citation: [2016] 132 COUNSELVISE.COM (IT) 7116 (ITAT-DELHI)
• Duration Of Justice: 4 year(s) 2 month(s) 8 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 05-07-2016
• Appeal Filed By: Department
• Order Result: Partly Allowed
• Bench Allotted: B
• Next Hearing Date: 09-06-2016
• Assessment Year: 1992-1993
• Appeal Filed On: 27-04-2012
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: V R SONBHA DRA SENIOR
• Keywords: Unexplained investment
• Section: 143(3); 69

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI DELHI DELHI BENCH BENCH BENCH BENCH B BB B : NEW DELHI : NEW DELHI : NEW DELHI : NEW DELHI BEFORE SHRI BEFORE SHRI BEFORE SHRI BEFORE SHRI G.D. AGRAWAL, VICE PRESIDENT G.D. AGRAWAL, VICE PRESIDENT G.D. AGRAWAL, VICE PRESIDENT G.D. AGRAWAL, VICE PRESIDENT AND AND AND AND SHRI KULDIP SINGH SHRI KULDIP SINGH SHRI KULDIP SINGH SHRI KULDIP SINGH, JUDICIAL MEMBER , JUDICIAL MEMBER , JUDICIAL MEMBER , JUDICIAL MEMBER ITA NO ITA NO ITA NO ITA NO . .. . 1966/DEL/2012 1966/DEL/2012 1966/DEL/2012 1966/DEL/2012 ASSESSMENT YEAR : ASSESSMENT YEAR : ASSESSMENT YEAR : ASSESSMENT YEAR : 1992 1992 1992 1992 - -- - 93 9393 93 ASSISTANT COMMISSIONER OF ASSISTANT COMMISSIONER OF ASSISTANT COMMISSIONER OF ASSISTANT COMMISSIONER OF INCOME TAX (OSD), INCOME TAX (OSD), INCOME TAX (OSD), INCOME TAX (OSD), WARD WARD WARD WARD- -- -1(1), 1(1), 1(1), 1(1), GURGAON. GURGAON. GURGAON. GURGAON. VS. VS. VS. VS. SMT. CHANDERWATI, SMT. CHANDERWATI, SMT. CHANDERWATI, SMT. CHANDERWATI, WD/O LATE SHRI JAGDISH CHAND AND WD/O LATE SHRI JAGDISH CHAND AND WD/O LATE SHRI JAGDISH CHAND AND WD/O LATE SHRI JAGDISH CHAND AND S/SHRI RAMESH CHAND, SHYAM LAL, S/SHRI RAMESH CHAND, SHYAM LAL, S/SHRI RAMESH CHAND, SHYAM LAL, S/SHRI RAMESH CHAND, SHYAM LAL, AMAR CHAND, PHOOL CHAND, RAVI AMAR CHAND, PHOOL CHAND, RAVI AMAR CHAND, PHOOL CHAND, RAVI AMAR CHAND, PHOOL CHAND, RAVI CHAND, PEHLAD & NAND KISHORE, CHAND, PEHLAD & NAND KISHORE, CHAND, PEHLAD & NAND KISHORE, CHAND, PEHLAD & NAND KISHORE, ALL SONS AND L/HS OF SHRI JAGDISH ALL SONS AND L/HS OF SHRI JAGDISH ALL SONS AND L/HS OF SHRI JAGDISH ALL SONS AND L/HS OF SHRI JAGDISH CHAND, CHAND, CHAND, CHAND, VILLAGE MALAB, TEHSIL : NUH, VILLAGE MALAB, TEHSIL : NUH, VILLAGE MALAB, TEHSIL : NUH, VILLAGE MALAB, TEHSIL : NUH, DISTRICT GURGAON. DISTRICT GURGAON. DISTRICT GURGAON. DISTRICT GURGAON. PAN/GIR NO. PAN/GIR NO. PAN/GIR NO. PAN/GIR NO.745 745 745 745- -- -J. J.J. J. (APPELLANT) (RESPONDENT) APPELLANT BY : SHRI V.R. SONBHADRA, SENIOR DR. RESPONDENT BY : SHRI ANKIT GUPTA, ADVOCATE. DATE OF HEARING : 09.06.2016 09.06.2016 09.06.2016 09.06.2016 DATE OF PRONOUNCEMENT : 05.07.2016 05.07.2016 05.07.2016 05.07.2016 ORDER ORDER ORDER ORDER PER G.D. AGRA PER G.D. AGRA PER G.D. AGRA PER G.D. AGRAWAL, VP WAL, VP WAL, VP WAL, VP : :: :- -- - THIS APPEAL BY THE REVENUE FOR THE ASSESSMENT YEAR 1992-93 IS DIRECTED AGAINST THE ORDER OF LEARNED CIT(A), FARID ABAD DATED 19 TH JANUARY, 2012. 2. THE REVENUE HAS RAISED THE FOLLOWING GROUNDS OF APPEAL :- 1. ON THE FACTS AND CIRCUMSTANCES OF THE CASE, THE LD.CIT(A) HAS ERRED ON THE FACTS AND IN LAW, IN DEL ETING THE ADDITION OF RS.39,26,062/- EVEN WHEN THE UNACCOUNTE D INVESTMENT WAS COMPUTED BY THE AO IN A LOGICAL WAY. 2. ON THE FACTS AND CIRCUMSTANCES OF THE CASE, THE LD.CIT(A) HAS ERRED ON THE FACTS AND IN LAW, IN EST IMATING ITA-1966/DEL/2012 2 THE INVESTMENT IN PAWNING BUSINESS DURING THE YEAR AT RS.3,92,506/- AND ALSO IN HOLDING THAT THIS UNACCOU NTED INVESTMENT HAS BEEN INVESTED OUT OF INTEREST INCOME EARNED DURING THE YEAR. WHEREAS, CONTRARY TO HIS O WN OBSERVATION, THE INTEREST INCOME DURING THE YEAR HA S BEEN COMPUTED AT RS.2,55,634/-. THIS OBSERVATION OF THE LD.CIT(A) IS IRRATIONAL AS THE INTEREST INCOME OF RS.2,55,634/-, IN NO WAY DEFEND THE INVESTMENT OF RS.3,92,506/-. 3. THAT THE JUDGMENTS RELIED UPON BY THE LD.CIT(A) ARE DISTINGUISHABLE. THE RATIO OF THE JUDGMENT OF HON BLE HIGH COURT OF MADHYA PRADESH, IN THE CASE OF CIT VS. BAJ RANGLAL DWARKA PRASAD (220 ITR 649) IS APPLICABLE IN THIS C ASE IN WHICH THE IDENTICAL ISSUE HAS BEEN ADDRESSED. 4. THAT THE APPELLANT CRAVES FOR THE PERMISSION TO ADD, DELETE OR AMEND THE GROUNDS OF APPEAL BEFORE OR AT THE TIME OF HEARING OF APPEAL. 3. WE HAVE HEARD THE SUBMISSIONS OF BOTH THE SIDES AND HAVE PERUSED THE MATERIAL PLACED BEFORE US. IN THIS CAS E, THE ORIGINAL ASSESSMENT WAS COMPLETED U/S 143(3) DATED 22 ND MARCH, 1995 ON A TOTAL INCOME OF `31,33,650/-. ON APPEAL, LEARNED C IT(A), VIDE HIS ORDER DATED 24 TH JANUARY, 1997, SET ASIDE THE ASSESSMENT TO THE FIL E OF THE ASSESSING OFFICER. THE ASSESSING OFFICER COMPLETED THE SET ASIDE ASSESSMENT VIDE ORDER DATED 26 TH MARCH, 1999 ON A TOTAL INCOME OF `47,49,325/- WHEREIN HE MADE THE ADDITION OF `39,25 ,062/- FOR UNEXPLAINED INVESTMENT IN PAWNING BUSINESS AND `8,2 4,263/- AS INTEREST INCOME FROM PAWNING BUSINESS. ON APPEAL, LEARNED CIT(A) DELETED THE ADDITION OF `39,25,062/- AND REDUCED TH E ADDITION OF `8,24,263/- TO `2,55,634/-. THE REVENUE, AGGRIEVED WITH THE DELETION OF `39,25,062/-, IS IN APPEAL BEFORE US. THE ASSES SEE HAS NOT FILED ANY APPEAL AGAINST THE ORDER OF LEARNED CIT(A). 4. WE HAVE HEARD THE SUBMISSIONS OF BOTH THE SIDES. WE FIND THAT LEARNED CIT(A) HAS DELETED THE ADDITION OF `39,25,0 62/- WITH THE FOLLOWING FINDING:- ITA-1966/DEL/2012 3 IN THE INSTANT APPEAL, THE AO HAS WORKED OUT THE UNEXPLAINED INVESTMENT AND INTEREST INCOME ON THE B ASIS OF ESTIMATED AMOUNT OF LOAN ADVANCED AGAINST PAWNED ORNAMENTS. IT IS, HOWEVER, RELEVANT TO CONSIDER IF THE ENTIRE LOAN AMOUNTS ESTIMATED AGAINST THE PAWING OF SILVER /GOLD ORNAMENTS CAN BE UNEXPLAINED INVESTMENT AND RELEVAN T TO ONLY ASSESSMENT YEAR 1992-93. IT WOULD NOT BE PRUD ENT TO INFER THAT TOTAL LOAN AMOUNT ADVANCED TO 2009 PERSO NS AND ESTIMATED AT RS.39,25,062/- COULD BE UNEXPLAINED INVESTMENT, PARTICULARLY WHEN IT HAS NOT BEEN DISPU TED BY THE AO THAT THE ASSESSEE WAS IN THE MONEY LENDING BUSINESS SINCE LAST 35 YEARS. IT IS ABUNDANTLY CLE AR FROM THE ASSESSMENT ORDER THAT THE AO DID NOT MAKE ANY ENQUIRY FROM ANY OF THE PERSON WHO PLEDGED/MORTGAGE D THEIR ORNAMENTS AGAINST LOAN TAKEN FROM THE APPELLA NT, DESPITE THE FACT THAT A LIST OF 2009 PERSONS WITH A DDRESSES WAS AVAILABLE WITH HIM. THIS VITAL INQUIRY COULD H AVE BEEN HELPFUL IN ASCERTAINING AT LEAST THE LOAN AMOUNT VI S-A-VIS THE VALUE OF ORNAMENTS ON THE DATE OF ADVANCING LOA N AND RATE OF INTEREST PAID ETC. IT APPEARS TO ME THAT T HE AO HAS NOT UNDERSTOOD THE BASIS FEATURES OF PAWNING BUSINE SS. AN INTENDING LOANEE AGREES TO TAKE LOAN AT AGREED RATE OF INTEREST BY GIVING GOLD/SILVER ORNAMENTS AS SECURIT Y AND THE LOAN AMOUNT ALONGWITH INTEREST IS REQUIRED TO BE RE PAID WITHIN THE AGREED PERIOD. WHEN THE AMOUNT OF LOAN REPAYABLE ALONGWITH INTEREST EXCEEDS THE MARKET VAL UE OF THE PAWNED ARTICLE, THE LOANEE MAY PREFER NOT TO MA KE THE REPAYMENT. IN SUCH SITUATIONS, THE PAWNED ARTICLES REMAIN IN THE CUSTODY OF THE LOANER WHICH ALSO CANNOT BE D ISPOSED OF OR SOLD BY HIM IN ANTICIPATION OF REPAYMENT OF L OAN IN FUTURE BY THE LOANEE. THERE WOULD OF COURSE, BE CA SES WHERE THE AMOUNT OF LOAN ALONGWITH INTEREST IS PAID AND THE PAWNED ARTICLES ARE TAKEN BACK BY THE LOANEE. THE LOANER IN THAT SITUATION RECOVERS HIS INVESTMENT MA DE IN ADVANCING LOAN AND EARNS INTEREST. THE INTEREST SO EARNED IS AGAIN UTILIZED IN THE SAME BUSINESS OF MONEY LEN DING AFTER PLEDGING THE PAWNED JEWELLERY. THUS, THE PAR TY OF JEWELLERY LOOTED BY THE DACOITS WOULD ALSO REPRESEN T THE PAWNED ARTICLES, EARLIER UNCLAIMED BY THE LOANEES, IN RESPECT OF WHICH THE APPELLANT DID NEITHER RECEIVE BACK THE LOAN AMOUNT NOR THE INTEREST. THESE UNCLAIMED ARTI CLES ARE THUS, GENERATED EITHER FROM THE MONEY ADVANCED IN E ARLIER YEAR OUT OF REPAYMENTS OR FROM INTEREST INCOME EARN ED IN EARLIER YEARS. THEREFORE, IT WAS INCUMBENT UPON TH E AO TO AT LEAST LOOK INTO THE BACKGROUND BEHIND THE DIRECT ION OF LD.CIT(APPEALS) AGAINST TAXING THE ENTIRE INVESTMEN T ONLY IN ONE YEAR. IT REMAINS AN UNDISPUTED FACT THAT THE U NCLAIMED ARTICLES WOULD ALSO NOT GENERATE ANY INTEREST INCOM E. ITA-1966/DEL/2012 4 THUS, THE ESTIMATION OF INTEREST INCOME AT RS.8,24, 263/- BY CONSIDERING THE ENTIRE INVESTMENT MADE IN ONE YEAR AND THAT TO AS INCOME GENERATING IS AGAINST THE BASIC B USINESS PRINCIPLES OF PAWNING. WHEN THE AO HAS ESTIMATED I NTEREST INCOME OF RS.8,24,263/- FOR THE YEAR UNDER APPEAL ( SUBJECT TO ADJUDICATION), IT CANNOT BE INFERRED THAT THE AP PELLANT HAD NOT BEEN EARNING ANY INTEREST INCOME IN EARLIER YEARS. GOING BY THE STANDARD ADOPTED BY THE AO FOR ESTIMAT ING INTEREST INCOME AT RS.8,24,263/- IN ONE YEAR AND LE AVING ASIDE THE INTEREST EARNED AND UTILIZED IN FINANCING DURING THE YEAR PRIOR TO THE DATE OF DACOITY, THE MAJOR PA RT OF INVESTMENT IN ADVANCING LOAN AGAINST PAWNED ARTICLE S IS COVERED BY EARLIER FIVE YEARS IF IT IS ACCEPTED THA T THE APPELLANT EARNED ALMOST SIMILAR AMOUNT OF INTEREST INCOME IN EARLIER FIVE YEARS ALSO. THUS, THE WHOLE EXERCI SE OF THE AO IN MAKING SO CALLED ESTIMATION AND ENTIRE ADDITI ON IN ONE YEAR DOES NOT SERVE ANY PURPOSE MUCH LESS THE INTEREST OF REVENUE. SINCE THE APPELLANT WAS DOING MONEY LENDING BUSINESS FOR THE LAST MANY YEARS, MONEYS IN VESTED IN PAWNING BUSINESS WAS ACCUMULATION OF INCOME GENERATED YEAR AFTER YEAR AND BY NO STRETCH OF IMAG INATION, ALL THE MONEYS INVESTED, ESTIMATED BY THE AO AT RS.39,25,062/- IN THE PAWNING BUSINESS CAN BE HELD AS UNEXPLAINED INVESTMENT RELEVANT TO A.Y. 1992-93 IN TERMS OF SECTION 69 OR 69B OF THE ACT, MORE PARTICULARLY WHEN NO EVIDENCE HAS BEEN BROUGHT ON RECORD IF THE ASSESSEE WAS HAVING INCOME FROM ANY SOURCE OTHER THAN THE MONEY LENDING BUSINESS. THEREFORE, THE ENTIRE ADDITION M ADE BY THE AO IS WHOLLY UNWARRANTED AND HIGHLY UNJUSTIFIED . EVEN IF THE APPELLANT HAS NOT FILED NECESSARY DETAILS OR NOT PRODUCED BOOKS OF ACCOUNTS, IT DOES NOT NECESSARILY ENTAIL THE AO TO MAKE ANY ABSURD ADDITION. THE HONBLE GU JARAT HIGH COURT IN USHAKANT N. PATEL VS. CIT (282 ITR 55 3), RELIED UPON BY THE LEARNED COUNSEL, HAS HELD THAT I N THE FIRST INSTANCE IT IS INCUMBENT UPON THE AUTHORITY T O ESTABLISH THAT THERE WAS INVESTMENTS MADE BY THE ASSESSEE; THAT SUCH INVESTMENTS WERE NOT RECORDED I N THE BOOKS OF ACCOUNT MAINTAINED BY THE ASSESSEE; AND TH AT, SUCH INVESTMENTS HAD BEEN MADE IN THE FINANCIAL YEA R IMMEDIATELY PRECEDING THE ASSESSMENT YEAR IN QUESTI ON. THEREFORE, THE AO HAS UTTERLY FAILED TO DISCHARGE T HE PRIMARY BURDEN THAT LAY ON HIM. AT THE RELEVANT TI ME WHEN THE ASSESSMENTS WERE MADE, THE BLOCK PERIOD FOR SEA RCH ASSESSMENT CONSISTED OF 10 YEARS AND EVEN THE PROVI SIONS OF SECTION 149 OF THE ACT PROVIDED FOR REOPENING OF LAST 10 ASSESSMENT YEARS. WHEN THE APPELLANT HAD BEEN ENGA GED IN THE BUSINESS OF PAWNING FOR OVER LAST 35 YEARS ( A FACT NOT DENIED BY THE AO), IT WOULD NOT BE IN ANY DISPUTE T O ITA-1966/DEL/2012 5 REASONABLY INFER AND SPREAD THE UNACCOUNTED INVESTM ENT OVER LAST 10 YEARS CONSIDERING THE ABOVE PROVISIONS . HENCE, THE UNACCOUNTED INVESTMENT DURING THE YEAR U NDER APPEAL WOULD WORK OUT TO ONLY RS.3,92,506/-. ONCE, THE AO HAS MADE ADDITION ON ACCOUNT OF INTEREST ON ESTIMAT ED BASIS AT RS.8,24,263/- FOR THE YEAR UNDER APPEAL, T HE NORMAL PRESUMPTION WOULD BE THAT SUCH INTEREST INCO ME EARNED HAS BEEN UTILIZED IN MAKING ADVANCES AGAINST PAWNED ARTICLES. THEREFORE, IN ABSENCE OF ANYTHING CONTRARY BROUGHT ON RECORD, THERE WOULD BE NO CASE FOR MAKING ANY ADDITION ON ACCOUNT OF UNEXPLAINED INVES TMENT DURING THE YEAR BY APPLYING THE THEORY OF TELESCOPY . THEREFORE, THE ENTIRE ADDITION MADE BY THE AO ON AC COUNT OF UNACCOUNTED INVESTMENT IS NOT SUSTAINABLE AND DELETED. 5. FROM THE ASSESSMENT ORDER, ORDER OF LEARNED CIT( A) AND ARGUMENTS OF BOTH THE PARTIES, IT IS GATHERED THAT THE ASSESSING OFFICER MADE AN ADDITION OF `39,25,062/- IN RESPECT OF UNEX PLAINED INVESTMENT IN THE PAWNING BUSINESS BY THE ASSESSEE. THE CIT(A ) HAS RECORDED THAT THE ASSESSEE WAS ENGAGED IN THE PAWNING BUSINESS OV ER THE LAST 35 YEARS AND THEREFORE, THE ENTIRE INVESTMENT CANNOT B E ATTRIBUTED TO ONE YEAR. HE, THEREFORE, OPINED THAT ONLY 1/10 TH OF THE INVESTMENT CAN BE CONSIDERED AS ATTRIBUTABLE TO THE YEAR UNDER CONSID ERATION WHICH HE WORKED OUT AT `3,92,506/-. TO THIS EXTENT, WE ENTI RELY AGREE WITH THE FINDING OF LEARNED CIT(A). WHEN ADMITTEDLY THE ASS ESSEE IS CARRYING ON PAWNING BUSINESS FOR MORE THAN THREE DECADES, THE E NTIRE INVESTMENT IN THE PAWNING BUSINESS CANNOT BE ATTRIBUTABLE TO O NE YEAR. THEREAFTER, THE CIT(A) DID NOT SUSTAIN THE ADDITION OF `3,92,506/- ALSO ON THE GROUND THAT IT WAS MADE OUT OF THE INCOME FR OM PAWNING BUSINESS WHICH THE ASSESSING OFFICER HAS DETERMINED AT `8,24,263/-. WE ALSO AGREE WITH THE ASSESSING OFFICER THAT THE I NCOME FROM PAWNING BUSINESS CAN BE REINVESTED IN THE PAWNING BUSINESS IN THE SUBSEQUENT YEAR. THE CIT(A), WHILE DECIDING THE SECOND GROUND , HAS REDUCED THE INCOME FROM INTEREST OF THE PAWNING BUSINESS DETERM INED BY ASSESSING OFFICER AT `8,24,263/- TO `2,55,634/-. HOWEVER, WH ILE CONSIDERING THE AVAILABILITY OF FUNDS FOR INVESTMENT IN THE PAWNING BUSINESS, HE ITA-1966/DEL/2012 6 CONSIDERED THE INCOME FROM INTEREST AS DETERMINED B Y THE ASSESSING OFFICER. IN OUR OPINION, WHEN HE HAS REDUCED THE I NTEREST INCOME FROM PAWNING BUSINESS, THE FUNDS AVAILABLE FOR INVESTMEN T IN THE PAWNING BUSINESS WOULD BE THE INTEREST INCOME AS DETERMINED BY LEARNED CIT(A) AND NOT THE INTEREST INCOME AS ASSESSED BY THE ASSE SSING OFFICER. IT WOULD NOT BE OUT OF PLACE TO MENTION THAT NEITHER P ARTY IS IN APPEAL AGAINST THE INTEREST INCOME DETERMINED BY THE CIT(A ). THEREFORE, THE INTEREST INCOME AT `2,55,634/- AS DETERMINED BY THE CIT(A) HAS BECOME FINAL. THEREFORE, IN OUR OPINION, THE CREDIT FOR T HE INTEREST INCOME AS DETERMINED BY THE CIT(A) AT `2,55,634/- ONLY CAN BE GIVEN FOR CONSIDERING THE INVESTMENT DURING THE YEAR UNDER CO NSIDERATION. WE, THEREFORE, SUSTAIN THE ADDITION OF `1,36,872/- I.E. , `3,92,506/- MINUS `2,55,634/-. 6. IN THE RESULT, THE APPEAL OF THE REVENUE IS PART LY ALLOWED. DECISION PRONOUNCED IN THE OPEN COURT ON 05.07.2016 . SD/- SD/- (KULDIP SINGH (KULDIP SINGH (KULDIP SINGH (KULDIP SINGH ) )) ) ( (( ( G.D. AGRAWAL G.D. AGRAWAL G.D. AGRAWAL G.D. AGRAWAL ) )) ) JUDICIAL MEMBER JUDICIAL MEMBER JUDICIAL MEMBER JUDICIAL MEMBER VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT VK. COPY FORWARDED TO: - 1. APPELLANT : ASSISTANT COMMISSI ASSISTANT COMMISSI ASSISTANT COMMISSI ASSISTANT COMMISSIONER OF INCOME TAX (OSD), ONER OF INCOME TAX (OSD), ONER OF INCOME TAX (OSD), ONER OF INCOME TAX (OSD), WARD WARD WARD WARD- -- -1(1), GURGAON. 1(1), GURGAON. 1(1), GURGAON. 1(1), GURGAON. 2. RESPONDENT : SMT. CHANDERWATI, SMT. CHANDERWATI, SMT. CHANDERWATI, SMT. CHANDERWATI, WD/O LATE SHRI JAGDISH CHAND AND WD/O LATE SHRI JAGDISH CHAND AND WD/O LATE SHRI JAGDISH CHAND AND WD/O LATE SHRI JAGDISH CHAND AND S/SHRI RAMESH CHAND, SHYAM LAL, AMAR CHAND, S/SHRI RAMESH CHAND, SHYAM LAL, AMAR CHAND, S/SHRI RAMESH CHAND, SHYAM LAL, AMAR CHAND, S/SHRI RAMESH CHAND, SHYAM LAL, AMAR CHAND, PHOOL CHAND, RAVI CHAND, PEHLAD & NAND KISHORE, PHOOL CHAND, RAVI CHAND, PEHLAD & NAND KISHORE, PHOOL CHAND, RAVI CHAND, PEHLAD & NAND KISHORE, PHOOL CHAND, RAVI CHAND, PEHLAD & NAND KISHORE, ALL SONS AND L/HS OF SHRI JAGDISH ALL SONS AND L/HS OF SHRI JAGDISH ALL SONS AND L/HS OF SHRI JAGDISH ALL SONS AND L/HS OF SHRI JAGDISH CHAND, CHAND, CHAND, CHAND, VILLAGE MALAB, TEHSIL : NUH, VILLAGE MALAB, TEHSIL : NUH, VILLAGE MALAB, TEHSIL : NUH, VILLAGE MALAB, TEHSIL : NUH, DISTRICT GURGAON. DISTRICT GURGAON. DISTRICT GURGAON. DISTRICT GURGAON. 3. CIT 4. CIT(A) 5. DR, ITAT ASSISTANT REGISTRAR