KRISHNA KUMAR AGRAWAL, BILASPUR(CG) V. A.C.I.T. CIR.1(1), BILASPUR(CG)

ITA 208/BIL/2014

• Counselvise Citation: [2017] 127 COUNSELVISE.COM (IT) 9111 (ITAT-RAIPUR)
• Duration Of Justice: 2 year(s) 8 month(s) 10 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 12-05-2017
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: DB
• Assessment Year: 2006-2007
• Appeal Filed On: 01-09-2014
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: O P CHOUDHARY
• Assessee Lawyers: G S AGARWAL

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR BEFORE S/SHRI N.S SAINI, ACCOUNTANT MEMBER AND GEORGE GEORGE K, JUDICIAL MEMBER ITA NO. 208/BIL /201 4 ASSESSMENT YEAR : 2006 - 07 KRISHNA KUMAR AGRAWAL, MAIN ROAD, NEW SARKANDA, BILASPUR VS. ACIT, CIRCLE 1(1), BILASPUR PAN/GIR NO. ACLPA 7562 Q (APPELLANT ) .. ( RESPONDENT ) ASSESSEE BY : SHRI G.S.AGARWAL, AR REVENUE BY : SHRI O.P. CHOUDHARY, DR DATE OF HEARING : 11 /05 / 2017 DATE OF PRONOUNCEMENT : /05 / 2017 O R D E R PER N.S.SAINI, AM THIS IS AN APPEAL FILED BY THE ASSESSEE AGA INST THE ORDER OF CIT(A) - BILASPUR , DATED 31.3.2014 , FOR THE ASSESSMENT YEAR 2006 - 07 . 2. IN GROUND NO.1 OF THE APPEAL, THE GRIEVANCE OF THE ASSESSEE IS THAT THE CIT(A) ERRED IN TREATING AGRICULTURAL INCOME OF RS.1,15,000/ - . 3. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSING OFFICER OBSERVED THAT THE ASSESSEE HAS SHOWN AGRICULTURAL INCOME OF RS.1,15,000/ - . THE ASSESSEE 2 ITA NO. 208/BIL/2014 ASSESSMENT YEAR :2006 - 07 WAS ASKED TO PRODUCE THE DETAILS OF AGRICULTURAL INCOME. IN COMPLIANCE TO THE SAME, THE A SSESSEE SUBMITTED THAT IT OWNS 30 AC RES OF LAND WHERE TWO YIELD OF CROP IS TAKEN. COPY OF B - 1 AND P - II KHASRA IN RESPECT OF HOLDING OF LAND AND CROPS GROWN WERE FILED. IT WAS FURTHER SUBMITTED THAT THE LAND WAS GIVEN ON LEASE TO FARMERS WHO GREW VEGETABL ES, MA NGO, GUAVA, ETC., AND IN LIEU OF THE SAME, THE ASSESSEE WAS IN RECEIPT OF INCOME. THE ASSESSING OFFICER OBSERVED THAT THE ASSESSEE HAS STATED TO HAVE SOLD AGRICULTURAL PR O DUCE OF RS.3,15,000 AND EXPENDED RS.2,00,000/ - FOR THE SAME AND, THEREFORE, NE T AGRICULTURAL INCOME WAS RS.1,15,000/ - FOR THE YEAR UNDER CONSIDERATION. THE ASSESSEE HAS NOT MAINTAINED ANY DETAILS OF EXPENSES, CROPS GROWN AND SALE OF CROPS WITH BILLS AND VOUCHERS AND SALE OF AGRICULTURAL PRODUCE WITH BILLS AND VOUCHERS EXCEPT COPY O F B - 1 AND P - II REGISTER. THERE IS NO DISPUTE TO THE FACT THAT THE ASSESSEE OWNS SUBSTANTIAL AGRICULTURAL LAND, BUT THE PRIMARY CONDITION TO CLAIM EXEMPTION AS AGRICULTURAL INCOME WAS THAT THE LAND IN QUESTION SHOULD BE USED FOR THE AGRICULTURAL PURPOSE S, WHETHER EXEMPTION IS SOUGHT UNDER SUB - CLAUSE (1) OR (B) OR (C) OF SECTION 2(1A). MERE POSSESSION OF AGRICULTURAL LAND IS NOT SUFFICIENT TO JUSTIFY THE INCOME FROM AGRICULTURAL ACTIVITIES. THEREFORE, THE ASSESSING OFFICER TREATED THE AGRICULTURAL INCOME SHOWN BY THE ASSESSE E AS INCOME FROM OTHER SOURCES. 4. ON APPEAL, THE CIT(A) CONFIRMED THE ORDER OF THE ASSESSING OFFICER. 3 ITA NO. 208/BIL/2014 ASSESSMENT YEAR :2006 - 07 5. BEFORE US, LD A.R. SUBMITTED THAT THE ASSESSEE WAS SHOWING AGRICULTURAL INCOME SINCE ASSESSMENT YEAR 1998 - 99 AS UNDER: ASSESSMENT YEAR AGRICULTURAL INCOME 1998 - 1999 2,24,949/ - 1999 - 2000 3,59,420/ - 2000 - 2001 65,619/ - 2001 - 02 80,410/ - 2002 - 03 1,00,000/ - 2003 - 04 34,057/ - 2004 - 05 25,000/ - 2005 - 06 30,000/ - THE DEPARTMENT HAS ACCEPTED THE SAME. NOW , THE DEPARTMENT CANNOT HO LD THAT THE ASSESS EE HAS NOT EARNED ANY AGRICULTURAL INCOME FROM 30 ACR ES OF LAND OWNED BY THE ASSESSEE DURING THE YEAR UNDER CONSIDERATION. 6. LD D.R. ON THE OTHER HAND, RELIED ON THE ORDERS OF LOWER AUTHO RITIES. 7. AFTER CONSIDERING THE RIVAL SUBMISSIONS AND PERUSING THE MATERIALS ON RECORD, WE FIND TH A T IT IS SEEN THAT THE ASSESSEE HAS CLAIMED TO HAVE EARNED AGRICULTURAL INCOME SINCE 1998 - 99, WHICH HAS BEEN ACCEPTED BY THE DEPARTMENT. WE FIND THAT DURIN G T . HE YEAR UNDER CONSIDERATION, THE AGRICULTURAL INCOME SHOWN AT RS.1,15,000/ - IS IN CONSONANCE WITH THE AGRICULTURAL INCOME ACCEPTED BY THE DEPARTMENT IN THE EARLIER ASSESSMENT YEARS. HENCE, IN OUR CONSIDERED VIEW, THE LOWER AUTHORITIES WERE NOT JUSTIFIED IN TREATING THE AGRICULTURAL INCOME OF RS.1,15,000/ - SHOWN 4 ITA NO. 208/BIL/2014 ASSESSMENT YEAR :2006 - 07 BY THE ASSESSEE AS INCOME FROM OTHER SOURCES. LD D.R. COULD NOT CONTROVERT THE SUBMISSION OF THE ASSESSEE THAT IT HAS SHOWN AGRICULTURAL INCOME FROM SAME LAND SINCE ASSES SMENT YEAR 1998 - 99 AND SAME WAS ACCEPTED BY THE DEPARTMENT . THEREFORE, IN OUR CONSIDERED VIEW TREATING THE AGRICULTURAL INCOME SHOWN BY THE ASSESSEE AT RS.1,15,000/ - AS INCOME FROM OTHER SOURCES IS NOT JUSTIFIED. HENCE, WE SET ASIDE THE ORDERS OF LOWER A UTHORITIES AND DIRECT THE ASSESSING OFFICER TO TREAT THE INCOME AS AGRICULTURAL INCOME AND ALLOW THIS GROUND OF APPEAL OF THE ASSESSEE. 8. IN GROUND NO.2 OF THE APPEAL, THE GRIEVANCE OF THE ASSESSEE IS THAT THE CIT(A) IS NOT JUSTIFIED IN DISALLOWING RS.10 ,32,649/ - OUT OF INTEREST INCOME. 9. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE HAS SHOWN MONEY LENDING BUSINESS THROUGH PROPRIETORSHIP CONCERN M/S. KRISHNA KUMAR AGRAWAL. AFTER CLAIMING EXPENSES FROM TOTAL RECEIPTS OF RS.20,41,456/ - , THE ASSESSEE SHOWED NET INCOME FROM MONEY LENDING BUSINESS AT RS.8,39,129/ - . THE ASSESSING OFFICER REQUIRED THE ASSESSEE TO PRODUCE THE LICENCE TO SUBSTANTIATE THAT HE WAS DOING MONEY LENDING BUSINESS. THE ASSESSING OFFICER OBSERVED THAT EXPENDITURE INCLUDED PAYMENT OF BANK INTEREST OF RS.9,29,512/ - AND COMMISSION AND BANK CHARGES OF RS.1,03,137/ - . THE ASSESSING OFFICER OBSERVED THAT THESE EXPENSES ARE INADMISSIBLE U/S.57(III) OF THE ACT. HE ALSO OBSERVED THAT THE ASSESSEE HAS NOT BROUGHT ANYTHING ON 5 ITA NO. 208/BIL/2014 ASSESSMENT YEAR :2006 - 07 RECORD REGARDI NG THE PRINCIPAL AMOUNT OF LOAN FROM WHERE INTEREST INCOME HAS BEEN SHOWN. THEREFORE, HE DISALLOWED THE EXPENSES AND ASSESSED THE INCOME FROM MONEY LENDING OF RS.20,61,456/ - . 10. ON APPEAL, THE CIT(A) HELD THAT IT IS FOUND THAT THE ASSESSEE PAID INTEREST OF RS.4,28,157/ - AND RS.4,51,111/ - TO CC ACCOUNT NO.70230038 OF THE BANK OF INDIA, DAYALBAND, BILASPUR AND OD ACCOUNT NO.852046 WITH BANK OF INDIA, DAYALBAND, BILASPUR TOWARDS LOAN SANCTIONED AGAINST THE WORK ORD ER OF CHHATISGARH HOUSING BOARD. THE LOANS ARE SHOWN IN THE BOOKS OF ACCOUNT OF HIS PROPRIETARY CONCERN M/S. SAMRIDHI CONSTRUCTION, BILASPUR, WHICH IS ENGAGED IN EXECUT ION OF CIVIL CONSTRUCTION WORKS . THE ASSESSEE HAS NOT FURNISHED ANY DETAIL OF INTEREST OF RS.14,63,577/ - ALREADY DEBITED TO PROFIT & LOSS ACCOUNT OF M/S. SAMRIDHI CONSTRUCTIONS. HE OBSERVED TH A T FROM THE MATERIALS AVAILABLE ON RECORD, LIKE THE LEDGER OF CASH CREDIT ACCOUNT AND OD A/C NO.70230038 AND 852048 RESPECTIVELY IN THE BOOKS OF ACCO UNT OF THE SAID PROPRIETARY CONCERN CLEARLY REVEALS THAT THE ALLEGED BANK INTEREST HAS ALREADY BEEN CLAIMED IN THE PROFIT AND LOSS ACCOUNT OF M/S. SAMRIDHI CONSTRUCTIONS AND FURTHER CLAIM OF THE ALLEGED INTEREST AS ADMISSIBLE DEDUCTION F ROM THE INCOME OF MON EY LENDING ACTIVITIES IS NOTHING BUT A DOUBLE DEDUCTION. HE OBSERVED THAT THE BALANCE INTEREST OF RS.26,996/ - , RS.22,981/ - AND RS.267/ - RELATED TO CAR LOAN TAKEN BY THE ASSESSEE FROM SBI BRANCH, SARKANADA INTEREST ON OUTSTANDING OF OLD LOAN TAKEN LO NG BACK, THE DETAILS OF WHICH ARE NOT PROVIDED AND BANK COMMISSION INADVERTENTLY DEBITED 6 ITA NO. 208/BIL/2014 ASSESSMENT YEAR :2006 - 07 TO THIS ACCOUNT. IN THE ABSENCE OF ANY DETAIL OF INTEREST OF RS.14,63,577/ - ALREADY DEBITED TO THE PROFIT AND LOSS ACCOUNT OF M/S. SAMRIDHI CONSTRUCTIONS AND FOR THE REASONS THAT THE ABOVE INTEREST HAVE NO NEXUS WITH THE MONEY LENDING ACTIVITIES, IT IS FOUND THAT ENTIRE CLAIM OF INTEREST LIABILITY OF RS.9,29,512/ - IS INADMISSIBLE. SIMILARLY, THE ENTIRE EXPENDITURE OF BANK CHARGES AND COMMISSION OF RS.1,03,137/ - IS I NADMISSIBLE HAVING ABSOLUTELY NO NEXUS WITH THE MONEY LENDING ACTIVITIES OF THE ASSESSEE. 11. BEFORE US , LD A.R. OF THE ASSESSEE POINTED OUT FROM PAGE 27 OF THE PAPER BOOK, WHEREIN LEDGER ACCOUNT OF INTEREST OF M/S. SAMRIDHI CONSTRUCTIONS IS PLACED. IT W AS POINTED OUT THAT RS.8,79,268/ - WAS DEBITED BY SAMRIDHI CONSTRUCTIONS IN THE INTEREST ACCOUNT AND CREDIT WAS GIVEN TO M/S. K.K.AGRAWAL ON ACCOUNT OF INTEREST PAYMENT TO BANK OF INDIA FOR OD ACCOUNT OF BILASPUR AND RAIPUR BRANCH FOR FINANCIAL YEAR 2005 - 0 6. IT WAS SUBMITTED THAT SAMRIDHI CONSTRUCTION WAS CHARGED INTEREST OF RS.8,79,268/ - BY THE ASSESSEE FOR UTILISING LOAN AMOUNT TAKEN FROM BANK BY M/S. K.K,.AGRAWAL. HE SUBMITTED TH A T FROM PAGE 13 OF THE PAPER BOOK THAT INTEREST ACCOUNT IN THE BOOK OF M/S. K.K.AGRAWAL IS PLACED WHEREVER, IT CAN BE SEEN THAT RS.8,79,268 WAS SHOWN AS INTEREST INCOME BY THE ASSESSEE WHICH W AS PART OF THE TOTAL INCOME OF R S.20,61,456/ - . IT WAS SUBMITTED TH A T IT CAN BE SEEN FROM PAGE 16 OF THE PAPER BOOK THE INCOME AND EXPENDITURE ACCOUNT OF M/S. K.K,AGRAWAL IS PLACED THAT ENTIRE AMOUNT OF RS.20,61,456/ - WAS SHOWN AS INCOME BY THE ASSESSEE AGAINST WHICH THE ASSESSEE CLAIMED 7 ITA NO. 208/BIL/2014 ASSESSMENT YEAR :2006 - 07 BANK INTEREST OF RS.9,29,512.55 PAID TO BANK OF INDIA.. IT CAN BE VERIFIED FROM PAGE 13 OF THE PAPER BOOK WHERE LEDGER ACCOUNT (INTEREST ACCOUNT) OF BANK OF INDIA IS PLACED. IT WAS HIS SUBMISSION THAT THE CIT(A) WAS NOT JUSTIFIED IN SUSTAINING DISALLOWANCE OF RS.10,32,649 OUT OF DISALL OWANCE MADE BY THE ASSESSING OFFICER AT RS.12,22,327/ - . 12 .LD D.R. RELIED ON THE ORDER OF THE CIT(A). 13. AFTER CONSIDERING THE RIVAL SUBMISSIONS AND PERUSING THE ORDERS OF LOWER AUTHORITIES, WE FIND TH AT THE REASONS FOR MAKING T H E DISALLOWANCE OF INTERES T EXPENDITURE OF RS.8,79,268 WAS THAT THE FUNDS WERE UTILISED BY SAMRIDHI CONSTRUCTION AND DEDUCTION FOR INTEREST WAS CLAIMED BY IT. WE FIND THAT RS.8,79,268/ - WAS CLAIMED AS INTEREST EXPENDITURE BY SAMRIDHI CONSTRUCTION FOR THE FUNDS UTILISED BY IT OF M/ S. K.K.AGRAWAL WHICH WAS SANCTIONED AS BANK LOAN. M/S. K.K.AGRAWAL RECEIVED INTEREST OF RS.8,79,268/ - FROM SAMRIDHI CONSTRUCTION WHICH WAS SHOWN BY SAMRIDHI CONSTRUCTION AS EXPENDITURE IN ITS ACCOUNT AND CORRESPONDINGLY M/S. K.K.AGRAWAL HAS SHOWN THE AMOU NT AS INTEREST INCOME IN ITS BOOKS OF ACCOUNT. CORRESPONDINGLY, M/S. K.K.AGRAWAL CLAIMED INTEREST EXPENDITURE PAID TO BANK OF INDIA OF RS.9,29,512/ - . M/S. K.K.AGRAWA L HAS SHOWN INTEREST INCOME OF RS.20,61,456/ - AGAINST WHICH, INTEREST EXPENDITURE OF RS.9 ,29,512/ - WAS CLAIMED. THUS, IT IS NOT A CASE OF DOUBLE DEDUCTION CLAIMED BY THE ASSESSEE OF THE SAME INTEREST EXPENDITURE OF RS.8,79,268/ - . 8 ITA NO. 208/BIL/2014 ASSESSMENT YEAR :2006 - 07 THEREFORE, THE CIT(A) WAS NOT JUSTIFIED IN CONFIRMING THE DISALLOWANCE MADE BY THE ASSESSING OFFICER. 14. FURTHER, THE COMMISSION AND BANK CHARGES OF RS.1,03,137/ - TO THE BANK WAS ALSO DISALLOWED, WHICH WAS CONFIRMED BY THE CIT(A) ON THE GROUND THAT THE LOAN WAS UTILISED BY SAMRIDHI CONSTRUCTION. WE FIND THAT M/S. K.K. AGRAWAL HAS CHARGED INTEREST FROM SAMRIDH I CONSTRUCTION , WHICH HAS BEEN SHOWN AS INCOME OF THE ASSESSEE. THEREFORE, THERE IS ON THE BASIS OF MATCHING PRINCIPLE OF ACCOUNTANCY, THE CORRESPONDING EXPENDITURE FOR EARNING INTEREST INCOME HAS TO BE ALLOWED DEDUCTION TO THE ASSESSEE. THEREFORE, THE CIT(A) WAS NOT CORRECT IN DISALLOWING RS.1,03,137/ - . 15. FURTHER, THE CIT(A) HAS OBSERVED THAT OTHER INTEREST AMOUNT OF RS.26,996/ - , RS.22,981/ - AND RS.267/ - PERTAINING TO CAR LOANS FROM SBI, SARKANDA AND INTEREST ON OUTSTANDING OLD LOAN TAKEN LONG BACK. THEREFORE, THE CIT(A) CONFIRMED THE DISALLOWANCE TO THAT EXTENT. 16. DURING THE COURSE OF HEARING, NO SUBMISSION WAS MADE BY LD A.R. OF THE ASSESSEE ABOUT THE CONFIRMATION OF DISALLOWANCE MADE BY THE CIT(A). THEREFORE, THEY ARE CONFIRMED. HENCE, THE ORDER OF THE CIT(A) IS MODIFIED AND DEDUCTION OF RS.9,82,403 (RS.8,79,268 + RS.1,03,137) IS ALLOWED . THIS GROUND IS PARTLY ALLOWED. 9 ITA NO. 208/BIL/2014 ASSESSMENT YEAR :2006 - 07 17. GROUND NO.3 OF THE APPEAL IS DIRECTED AGAINST THE ORDER OF THE CIT(A) AGAINST THE REJECTION OF BOOKS OF ACCOUNT AND ESTIMATING INCOME AT 8% ON THE TURNOVER OF RS.2,95,77,003/ - , WHICH WAS SHOWN BY THE ASSESSEE AT 3.66%. 18. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSING OFFICER HAS OBSERVED THAT THE ASSESSEE HAS ONLY PRODUCED COMPUTERISED CASH BOOK AND LEDGER AND FAILED TO P RODUCE STOCK REGISTER, MUSTER ROLL FOR PAYMENT OF WAGES ETC. THEREFORE, HE HELD TH A T THE ASSESSEE FAILED TO DISCHARGE ITS ONUS BY NON - PRODUCING HIS BOOKS OF ACCOUNT, AND, THEREFORE, THE BOOK RESULTS SHOWN BY THE ASSESSEE ARE NOT ACCEPTABLE. HE OBSERVED TH AT AS P E R THE PROVISIONS OF SECTION 44AD, WHERE GROSS RECEIPTS FROM CONTRACT IS BELOW RS.40 LAKHS A SUM EQUAL TO 8% OF THE GROSS RECEIPTS MAY BE TREATED AS INCOME OF THE ASSESSEE. THEREFORE, HE ESTIMATED THE INCOME OF THE ASSESSEE BY REJECTING THE BOOK RESULTS OF THE ASSESSEE AT 10% OF THE GROSS CONTRACT RECEIPTS AND DETERMINED INCOME AT RS.29,57, 700/ - . 19. ON APPEAL, THE CIT(A) RESTRICTED THE SAME TO 8% TO THE GROSS RECEIPTS WHICH WORKED OUT TO RS.23,66,160/ - AND THEREBY ALLOWED RELIEF OF RS.5,91,540/ - . 20. BEFORE US, LD A.R. ACCEPTED THE FACT THAT ALL THE BILLS AND VOUCHERS WERE NOT PRODUCED BEFO RE THE ASSESSING OFFICER AND, THEREFORE, THE REJECTION OF BOOK RESULTS OF THE ASSESSEE WAS JUSTIFIED. HE SUBMITTED TH A T THE ESTIMATION 10 ITA NO. 208/BIL/2014 ASSESSMENT YEAR :2006 - 07 OF INCOME OF THE ASSESSEE AT 8% OF THE GROS S RECEIPTS WAS ON A HIGHER SIDE, WHEN THE ASSESSEE HAS SHOWN INCOME AT 3.66%. HE SUBMITTED TH A T IN THE SUBSEQUENT ASSESSMENT YEAR , THE INCOME AT 1.38% OF THE TURNOVER WAS AC CEPTED BY THE DEPARTMENT. WHEN , THE TURNOVER OF THE ASSESSE WAS RS.6 CRORES AS AGAINST TURNOVER OF RS.3 CRORES SHOWN IN THE PRESENT YEAR.. 21. LD D.R. PRAYED THAT THE ORDER OF THE CIT(A)SHOULD BE UPHELD. 22. AFTER CONSIDERING THE RIVAL SUBMISSIONS AND PERUSING THE MATERIALS AVAILABLE ON RECORD, WE FIND THAT THERE IS NO DISPUTE TO THE REJECTION OF BOOKS OF ACCOUNT BY THE ASSESSING OFFICER. THE ON LY DISPUTE IS REGARDING ESTIMATION OF INCOME AT 8% BY THE CIT(A). WE FIND THAT THE ASSESSEE HAS SHOWN INCOME AT 3.66% IN THE YEAR UNDER APPEAL AND THAT IN THE SUBSEQUENT ASSESSMENT YEAR, IT HAS SHOWN INCOME AT 1.38% AS STATED BY LD A.R. AND NOT CONTROVERT ED BY LD D.R. IN THE ABOVE FACTS AND CIRCUMSTANCES OF THE CASE, WE ARE OF THE CONSIDERED VIEW THAT IT WOULD MEET THE ENDS OF JUSTICE IF THE INCOME OF THE ASSESSEE IS ESTIMATED AT 5% OF THE GROSS RECEIP TS OF THE ASSESSEE, WHICH WORK OUT TO RS.14,78,850/ - AS AGAINST RS.23,66,160/ - ESTIMATED BY THE CIT(A). THUS, THE ASSESSEE GETS RELIEF OF RS.8,73,300/ - AND THE GROUND OF APPEAL IS PARTLY ALLOWED. 11 ITA NO. 208/BIL/2014 ASSESSMENT YEAR :2006 - 07 23. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IS PARTLY ALLOWED. ORDER PRONOUNCE D IN THE OPEN COURT ON 12 /05 /2017 IN THE PRESENCE OF PARTIES. SD/ - SD/ - (GEORGE GEORGE K ) ( N.S SAINI) JUDICIAL MEMBER A CCOUNTANT MEMBER RAIPUR ; DATED 12 /05 /2017 B.K.PARIDA, SPS COPY OF THE ORDER FORWARDED TO : BY ORDER, SR.PRIVATE SECRETARY 1. THE APPELLANT : KRISHNA KUMAR AGRAWAL, MAIN ROAD, NEW SARKANDA, BILASPUR 2. THE RESPONDENT. ACIT, CIRCLE 1(1), BILASPUR 3. THE CIT(A) BILASPUR 4. PR.CIT , BILASPUR 5. DR, ITAT, RAIPUR 6. GUARD FILE. //TRUE COPY//