ACIT 26(1), MUMBAI V. ANIL PRANLAL BAJARIA, MUMBAI

ITA 2244/MUM/2015

• Counselvise Citation: [2017] 128 COUNSELVISE.COM (IT) 0497 (ITAT-MUMBAI)
• Duration Of Justice: 2 year(s) 1 month(s) 14 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 31-05-2017
• Appeal Filed By: Department
• Order Result: Partly Allowed
• Bench Allotted: J
• Assessment Year: 2010-2011
• Appeal Filed On: 16-04-2015
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: ARJU GARODIA
• Assessee Lawyers: DINESH SHAH
• Keywords: Bogus purchase; Principle of natural justice; Accommodation entries
• Section: 143(3)

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES J , MUMBAI BEFORE S HRI G.S. PANNU (AM) AND SHRI RAM LAL NEGI (JM) ITA NO. 2244 /MUM/20 1 5 ASSESSMENT YEAR: 2010 - 2011 THE ACIT - 26(1), ROOM NO. 508, C - 10, 5 TH FLOOR, B.K.C. BANDRA (E), MUMBAI - 400051 VS. SHRI ANIL PRANLAL BAJARIA (PROPRIETOR OF M/S APRA ENTERPRISE), 197/2, GUJARAT SOCIETY, SION WEST, MUMBAI 400022 PAN: AABPB2538B (APPELLANT) (RESPONDENT) & ITA NO. 1685 /MUM/201 5 ASSESSMENT YEAR: 2010 - 2011 SHRI ANIL PRANLAL BAJARIA (PROPRIETOR OF M/S APRA ENTERPRISE), 1, SAI CHAMBER, 2 ND FLOOR, 365 NARSHI NATHA STREET, KATHA BAZAR, MUMBAI 400009 PAN: AABPB2538B VS. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE - 26 (1), 5 TH FLOOR, C - 10, BUILDING, P.K. BHAVAN, BANDRA KURLA COMPLEX, MUMBAI - 400051 (APPELLANT) (RESPONDENT) APPELLANT BY : MS. ARJU GARODIA (D R) RESPONDENT BY : SHRI DINESH SHAH (A R) DATE OF HEARING: 02/03 /201 7 DATE OF PRONOUNCEMENT: 31 / 0 5 /201 7 O R D E R PER RAM LA L NEGI, JM THESE ARE THE CROSS APPEALS FILED BY THE REVENUE AND THE ASSESSEE AGAINST ORDER DATED 13/01/2015 PASSED BY THE COMMISSI ONER OF INCOME TAX (APPEALS) - 38 , MUMBAI, PERTAINING TO THE ASSESSMENT YEAR 2010 - 11, WHEREBY 2 ITA NO S . 2244 & 1685/MUM/2015 ASSESSMENT YEAR: 2010 - 2011 THE LD. CIT (A) HAS PA RTLY ALLOWED THE APPEAL FILED BY THE APPELLANT/ASSESSEE AGAINST ASSESSMENT ORDER PASSED U/S 143 (3) OF THE INCOME TAX ACT, 1961 (FOR SHORT THE ACT). ITA NO. 1685 /MUM/2015 (ASSESSMENT YEAR: 2010 - 2011 ) 2. FIRST WE SHALL TAKE UP THE APPEAL OF THE ASSESSE E. BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE PROPRIETOR OF M/S APRA ENTERPRISES ENGAGED IN THE BUSINESS OF IMPORTING AND TRADING OF CHEMICALS, FILED ITS RETURN OF INCOME DECLARING THE TOTAL INCOME OF RS. 82,38,430/ - . THE RETURN WAS PROCESSED AND THE AS SESSMENT ORDER WAS PASSED U/S 143(3) OF THE ACT AND THE TOTAL INCOME OF THE ASSESSEE WAS DETERMINED AT RS. 1,60,83,970/ - AFTER MAKING ADDITION OF RS. 78,45,54 7/ - ON ACCOUNT OF BOGUS PURCHASES AND RS. 1,69,200/ - AS INCOME FROM OTHER SOURCES. THE ASSESSEE CH ALLENGED THE ASSESSMENT ORDER BEFORE THE LD. CIT (A) ON THE GROUND THAT THE AO HAS ERRED IN MAKING ADDITION OF RS. 78,45,547 / - TO THE RETURN INCOME ON ACCOUNT OF NON G ENUINE PURCHASES. THE LD. CIT (A) AFTER HEARING THE ASSESSEE ESTIMATED THE INCOME @ 12.50 % OF TOTAL ALLEGED BOGUS PURCHASES AND WORKED OUT THE AMOUNT AT RS. 9,80,593/ - AND GAVE THE RELIEF OF RS. 68,64,854/ - BY SUBTRACTING THE SAID AMOUNT FROM THE TOTAL ADDITION OF RS. 78,45,547/ - MADE BY THE AO. STILL A GGRIEVED BY THE IMPUGNED ORDER PASSED BY THE LD. CIT (A), THE ASSESSEE AND THE REVENUE ARE IN APPEAL BEFORE THE TRIBUNAL. 3. THE ASSESSEE HAS RAISED THE FOLLOWING EFFECTIVE GROUNDS OF APPEAL AGAINST THE IMPUGNED ORDER PASSED BY THE LD. CIT (A): - 1. THE INCOME IS ESTIMATED BY THE LEARNED COMMISSI ONER OF (APPEALS) 38 AT THE RATE OF 12.50 PERCENT OF TOTAL ALLEGED BOGUS PURCHASES [12.5 PERCENT OF RS. 78,45,547/ - ] (AS BOGUS PURCHASES ALLEGED BY THE INCOME TAX DEPARTMENT] IN QUESTION WHICH WORKS 3 ITA NO S . 2244 & 1685/MUM/2015 ASSESSMENT YEAR: 2010 - 2011 OUT TO] RS. 9,80,593/ - BE DELETED AS SAME IS BASED ON ASS UMPTION AND PRESUMPTION AND NOT BASED ON THE PAST RECORD OF THE APPELLANT. 2. THE LEARNED CIT (A) 38 OUGHT TO HAVE CONSIDERED VARIOUS MUMBAI INCOME TAX TRIBUNAL AND THE JURISDICTIONAL HIGH COURT DECISIONS OF PURCHASES AS CITED BY THE APPELLANT AND BOOK RESUL TS OUGHT TO HAVE BEEN ACCEPTED AND ADDITION TO THE RETURN INCOME BE DELETED. 3. CONSIDERING THE PAST GROSS PROFIT RATE AND NET PROFIT RATIOS/RATE BOOKS RESULTS OUGHT TO HAVE BEEN ACCEPTED AND OR THERE WAS NOT NEED TO ESTIMATE 12.50 PERCENT OF THE ALLEGED BOG US PURCHASE. 4. THE INCOME TAX DEPARTMENT HAS ACCEPTED THE SALE OF THE GOODS AND HAS ALSO SUBMITTED. HOW THE PURCHASE OF SUCH GOODS WERE SOLD AND OR CONSUMED IN THE PACKING MATERIALS AND SALE CANNOT BE MADE WITHOUT PURCHASES AND CONSIDERING GROSS PROFIT RATI OS AND NET PROFIT AND THE VOLUME OF PURCHASES AND SALES. THESE PURCHASE OF GOODS FOR TRADING AND OR FOR PACKING MATERIALS BE ACCEPTED. 5. THE ASSESSING OFFICER TREATED BOGUS PURCHASES FROM 6 PARTIES AMOUNTING TO RS. 78,45,547 MERELY ON THE BASIS OF THIRD PAR TIES STATEMENTS I.E. MERE NONPAYMENT M.VAT BY THESE PARTIES AND THE CIT (A) 38 AT THE RATE OF 12.50 PERCENT I.E. RS. 9,80,593/ - AS INCOME. IN SPITE OF THE FACTS THE APPELLANT HAS FULFILLED PRIMARY ONUS OF PROVING THE GENUINENESS OF PURCHASE OF GOODS FOR TR ADING AND PACKING MATERIALS AND THE APPELLANT HAS NOT BEEN GIVEN AN OPPORTUNITIES TO CROSS EXAMINE THESE WITNESSES. IN SUCH CIRCUMSTANCES ADDITION BE DELETED AS PRINCIPAL OF NATURAL JUSTICE IS VIOLATED. 4. BEFORE US, THE LD. COUNSEL FOR THE ASSESSEE SUB MITTED THAT THE LD. CIT (A) HAS WRONGLY CONFIRMED THE ADDITION OF RS. 68,64,854/ - BY ESTIMATING THE BOGUS PURCHASE AT RS. 9,80,593/ - WITHOUT CONSIDERING THE LA W LAID DOWN BY THE HONBLE JURISDICTION AL HIGH COURT AND THE INCOME TAX TRIBUNAL. THE AO HAS TREA TED THE PURCHASES FROM SIX PARTIES AMOUNTING TO RS. 78,45,547/ - AS BOGUS MERELY ON THE BASIS OF STATEMENT OF THIRD PARTIES THAT THESE PARTIES HAD NOT PAID 4 ITA NO S . 2244 & 1685/MUM/2015 ASSESSMENT YEAR: 2010 - 2011 M.VAT @ 12.50 %, DESPITE THAT THE ASSESSEE HAS DISCHARGED THE PRIMARY ONUS OF PROVING THE GENUINENESS OF THE PURCHASE OF GOODS FOR TRADING AND PACKING MATERIAL. MOREOVER, THE ASSESSEE WAS NOT GIVEN OPPORTUNITY TO CROSS EXAMINE THE SAID WITNESSES . THE TOTAL PURCHASES OF THE ASSESSEE DURING THE FINANCIAL YEAR 2009 - 10 RELEVANT TO THE ASSESSMENT YEAR UNDER CON SIDERATION WERE WORTH RS. 93,87,06,017/ - OUT OF WHICH THE AO HAS TREATED THE BOGUS PURCHASE OF RS. 78,45,547/ - WHICH IS LESS THAN GIVEN 1% OF THE TOTAL PURCHASE S . THE GROSS PROFIT AND NET PROFIT RATIO ARE COMPETITIVE JUST AND FAIR IN THIS LINE OF BUSINESS AND THE SAME HAS BEEN CONSISTENTLY ACCEPTED BY THE DEPARTMENT. THE AO HAS WRONGLY CONCLUDED THAT NO MATERIAL HAD BEEN SUPPLIED BY THE TRADERS. SO CONSIDERING THE PAST GROSS PROFIT RATE AND NET PROFIT RATIO THE LD. CIT (A) OUGHT TO HAVE ACCEPTED THE RETURN INCOME AND THERE WAS NO NEED TO ESTIMATE 12.50% OF THE ALLEGED BOGUS PURCHASE. THE DEPARTMENT HAS ACCEPTED THE SALE , THEREFORE, THERE IS NO REASON TO CONCLUDE THAT THE QUESTIONED PURCHASES WERE BOGUS. THE LD. COUNSEL FOR THE ASSESSEE RELIED THE DECISIONS RENDERED IN M/S NIKUNJ EXIMP ENTERPRISES PVT. LTD. TAXMANN 171 (BOM), CIT VS. M K BROTHERS 163 ITR 249 (GUJ) DCIT VS. SHRI RAJEEV G KALATHIL MUMBAI TRIBUNAL ITA NO. 6727/MUM/2012 DATED 20/08/2014, G G DIAMONG INTERNATIONAL VS. DY. CIT (2006) 104 TTJ MUMBAI , CIT VS. BHOLANATH POLY FAB PVT. LTD. (2013) 355 ITR 290 (GUJ) CIT VS. SMIT P SHETH (2013) 56 ITR 451 (GUJ) CIT VS. GUJARAT AMBUJA EXPORT LTD. 224 TAXMANN 34, BALAJI TEXTILE INDUSTRIES PVT. LTD. VS. ITO 1994 ITD 177 (MUMBAI TRIBUNAL) DIT (IT) VS. COPAL RE SEARCH LTD. MAURITIUS AND OTHERS WP (C) 2033, 2470, 2590, 2597/2013 DATED 14/08/2014 DELHI (HC) AND VARIOUS OTHER DECISIONS OF THE HIGH COURTS AND THE TRIBUNALS TO SUBSTANTIATE THE CONTENTION OF THE ASSESSEE. 5. ON THE OTHER HAND, THE LD. DEPARTMENTAL REP RESENTATIVE (DR) RELYING ON THE ASSESSMENT ORDER SUBMITTED THAT SINCE THE ASSESSEE HAS FAILED TO DISCHARGE THE BURDEN OF PROVING THE GENUINENESS OF THE TRANSACTIONS, AO HAS RIGHTLY 5 ITA NO S . 2244 & 1685/MUM/2015 ASSESSMENT YEAR: 2010 - 2011 MADE ADDITION OF RS. 78,45,547/ - / - TO THE INCOME OF THE ASSESSEE AS BOGUS P URCHASES. THE LD. DR FURTHER SUBMITTED THAT THE DEPARTMENT HAS FILED THE CROSS APPEAL AGAINST THE RELIEF GIVEN BY THE CIT (A) TO THE ASSESSEE BY RESTRICTING THE ADDITION TO RS. 68,64,854/ - ESTIMAT ING THE TOTAL BOGUS PURCHASE @ 12.5% OF THE TOTAL TRANSACTI ON. ACCORDINGLY, THERE IS NO MERIT IN THE APPEAL OF THE ASSESSEE. 6. WE HAVE HEARD THE RIVAL SUBMISSIONS AND ALSO PERUSED THE MATERIAL ON RECORD INCLUDING THE DECISIONS RELIED UPON BY THE ASSESSEE AND THE AUTHORITIES BELOW. THE LD. CIT (A) HAS RESTRICTED THE TOTAL ADDITION TO RS. 68,64,854/ - HOLDING AS UNDER: - 3.10 THE FACTS OF THE PRESENT CASE SHOW THAT APPELLANT COULD NOT PRODUCE EITHER CONFIRMATION OR THE PARTY FROM WHOM GOODS HAVE BEEN PURCHASED. THE SUPPLIER S IN QUESTION WERE FOUND TO BE ENGAGED IN PROVIDING BOGUS BILLS WITHOUT ACTUAL LY DEALING IN GOODS . HOWEVER, THIS IS ALSO A FACT THAT THE SALES OF THE APPELLANT HAS NOT BEEN DOUBTED BY THE AO. WHAT IS UNDER DISPUTE IS THE PURCHASES FROM THESE THREE PARTIES FROM WHOM BILLS HAVE BEEN TAKEN AND CHEQUES HAVE BEEN ISSUED TO THEM. P URCHASES PER SE FROM THESE THREE PARTIES ARE NOT IN DOUBT BUT THE PARTY FROM WHOM PURCHASES HAVE BEEN SHOWN TO HAVE BEEN MADE ARE DISPUTED AND SUSPICIOUS. THE CASE OF THE AO IS THAT THE APPELLANT TOOK ONLY BILLS FROM THESE THREE PARTIES TO EXPLAIN THE PURCHASES MADE FROM ELSEWHERE. MERELY BECAUSE THE SUPPLIERS DID NOT APPEAR BEFORE THE AO OR THE CONFIRMATION LETTER WAS NOT FURNISHED, ONE CANNOT CONCLUDE THAT THE PURCHASES WERE NOT MADE BY THE ASSESSEE. THIS VIEW IS SUPPORTED BY THE DECISION OF NIKUNJ EXIMP ENTERPRISES VS. CIT 216 TAXMAN 171 (BOM) (SUPRA). THIS BEING SO THE ENTIRE PURCHASES FROM THE SE THREE PARTIES CANNOT BE TREATED AS BOGUS AND ADDED TO INCOME BECAUSE WHAT NEEDS TO BE TAXED IS THE PROFIT ELEMENT EMBE DDED IN SUCH TRANSACTION. (RELIANCE IS PLACE ON DECISION OF CIT VS. BHOLANATH POLYFAB PVT. LTD. [2013] 355 ITR 290)(GUJ). ESTIMATION OF PROFIT RANGING FROM 12.5% TO 15% HAS BEEN UPHELD BY THE HON GUJARAT HIGH COURT IN THE CASE OF SIMIT P. SHETH 356 ITR 45 1 (GUJ ) DEPENDING UPON THE NATURE OF BUSINESS. 6 ITA NO S . 2244 & 1685/MUM/2015 ASSESSMENT YEAR: 2010 - 2011 RESPECTFULLY FOLLOWING THE DECISION OF SIMIT P. SHETH (SUPRA) AND CONSIDERING THE FACTS OF THE CASE, I AM OF THE VIEW THAT ESTIMATION OF PROFIT AT 12.5% WOULD MEET THE ENDS OF JUSTICE. THEREFORE, I DIRECT THE AO TO ESTIMATE PROFIT OF 12.5% ON THE TOTAL ALLEGED BOGUS PURCHASES WHICH WORKS OUT TO RS. 9,80,693/ - (12.5% OF 78,45,547/ - AND ADDITION TO THE EXTENT IS CONFIRMED. THE APPELLANT THEREFORE GETS THE RELIEF OF RS. 68,64,854/ - . (RS. 78,45,547 RS. 9,80,693 ). THE GROUND IS RAISED IS PARTLY ALLOWED. 7. WE NOTICE THAT THE ASSESSEE COULD NOT PRODUCE CONFIRMATIONS OR THE PARTIES FROM WHOM PURCHASES WERE MADE, BEFORE THE ASSESSING OFFICER DURING ASSESSMENT PROCEEDINGS. VERIFICATION HAS REVEALED THAT THE ASSESSE E WAS ONE OF THE BENEFICIARIES WHO HAVE TAKEN ACCOMMODATION ENTRIES FROM THE PARTIES LISTED AS HAWALA TRADERS BY MAHARASHTRA SALES TAX DEPARTMENT . VERIFICATION HAS FURTHER REVEALED THAT NO MATERIAL HAS BEEN SUPPLIED BY THE SAID PARTIES . THE STATEMENT OF SH. HIMESH HARESH DAVE MADE BEFORE THE ASSTT. COMMISSIONER SALES TAX, INVESTIGATION MUMBAI CORROBORATES THE SAID FACTS. HENCE, THIS FACT HAS BEEN ESTABLISHED THAT THE PURCHASES WORTH RS. 78,45,547/ - WERE NOT MADE BY THE ASSESSEE FROM THE ALLEGED PARTIES AN D ONLY ACCOMMODATION ENTRIES WERE OBTAINED FROM THE SAID PARTIES IN AN ATTEMPT TO EXPLAIN THE PURCHASES IN QUESTION. 8. WE FURTHER NOTICE THAT THE ASSESSEE HAS SUBMITTED THE DETAILS OF PARTIES TO WHOM SALES WERE MADE ALONG WITH THE QUANTITY WISE DETAILS OF PURCHASE AND THE AO ONLY REJECTED THE PURCHASE DETAILS AND NOT DOUBTED THE SALE. SO IN THE LIGHT OF THE DECISION OF THE HONBLE GUJRAT HIGH COURT IN CIT VS. BHOLANATH POLY FAB PVT. LTD. 355 ITR 290 , NOT THE ENTIRE AMOUNT OF BOGUS PURCHASE, BUT THE PROFI T ELEMENT EMBEDDED SHOULD BE SUBJECT TO TAX. IN OUR CONSIDERED OPINION THE ISSUE INVOLVED IN THIS APPEAL IS NOT COVERED BY THE DECISIONS RELIED UPON BY 7 ITA NO S . 2244 & 1685/MUM/2015 ASSESSMENT YEAR: 2010 - 2011 THE ASSESSEE INCLUDING THE DECISION OF THE HONBLE BOMBAY HIGH COURT RENDERED IN CIT VS. NIKUNJ EXIMP ENTERPRISES (SUPRA). 9. THE ASSESSEE HAS SUBMITTED BEFORE US THE DETAILS OF SALES, GROSS PROFIT PERCENTAGE AND NET PROFIT PERCENTAGE INCLUDING THE RETURNS OF INCOME FOR THE A.Y S . 2007 - 08 TO 2016 - 17. AS PER THE SAID DETAILS, DURING THE FINANCIAL YEAR 2009 - 10 RELEVANT TO THE ASSESSMENT YEAR UNDER CONSIDERATION , THE NET PROFIT WAS 0.89%. WE FURTHER NOTICE THAT THE PERCENTAGE OF NET PROFIT REMAINED LESS THAN 1% DURING THE AFORESAID SAID FINANCIAL YEARS. SO, IN VIEW OF THE FACT, THAT THE BOGUS PURCHASES CONSTIT UTE ONLY 0 .86% OF THE TOTAL PURCHASES OF THE ASSESSEE AND THE AVERAGE NET PROFIT OF THE ASSESSEE FOR THE PREVIOUS AND SUBSEQUENT FINANCIAL YEARS ARE LESS THAN 1% AS PER THE DETAIL SUBMITTED , WE ARE OF THE CONSIDERED VIEW THAT IN THIS CASE 12.5% NET PROFIT ESTIMATED BY THE LD. CIT(A) IS ON THE HIGHER SIDE. HENCE, WE PARTLY ALLOW THE APPEAL OF THE ASSESSEE AND MODIFY THE ORDER OF THE LD. CIT(A) AND RESTRICT THE PROFIT AT 9% OF THE TOTAL BOGUS PURCHASES. AO IS DIRECTED TO CALCULATE THE PROFIT @ 9% ON THE TOTAL BOGUS PURCHASE TO ADD THE SAME TO THE INCOME OF THE ASSESSEE. ITA NO. 2244 /MUM/2015 (ASSE SSMENT YEAR: 2010 - 2011 ) THE REVENUE HAS RAISED THE FOLLOWING EFFECTIVE GROUNDS OF APPEAL AGAINST THE IMPUGNED ORDER PASSED BY THE LD. CIT (A): - 1. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE AND IN LAW, THE LD. CIT (A) HAS ERRED IN DIRECTING TO ESTIMATE THE PROFIT @ 12.5% ON THE BOGUS PURCHASES AS AGAINST 100% TAKEN BY THE ASSESSING OFFICER. 2. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE AND IN LAW, THE LD. CIT (A) HAS ERRED IN NOT APPRECIATING THE FACT THAT THE HAWALA PARTIES HAVE ADMITTED ON OATH BEFORE THE SALES TAX AUTHORITIES THAT 8 ITA NO S . 2244 & 1685/MUM/2015 ASSESSMENT YEAR: 2010 - 2011 THEY DID NOT SUPPLY ANY GOODS BUT ISSUED ONLY FAKE BILLS GIVING ACCOMMODATION ENTRIES TO THE ASSESSEE. 3. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE AND IN LAW, THE LD. CIT (A) HAS ERRED IN NOT CONSIDERING THAT DURING THE COURSE OF ASSESSMENT PROCEEDINGS THE ASSESSEE, IN SPITE OF BEING PROVIDED WITH SUFFICIENT OPPORTUNITY, FAILED TO PRODUCE THE PURCHASE PARTIES AND ALS O FAILED TO SUBSTANTIATE THE GENUINENESS OF PURCHASES WITH DOCUMENTARY EVIDENCES LIKES STOCK REGISTER, PARTY - WISE SALE DETAILS ETC. 2. SINCE, WE HAVE MODIFIED THE ORDER OF LD. CIT(A) AND ISSUED THE DIRECTION TO THE AO TO CALCULATE THE NET PROFIT @ 9% ON THE TOTAL AMOUNT OF BOGUS PURCHASES, THE REVENUES APPEAL HAS BECOME INFRUCTUOUS. HENCE, WE DISMISS THE APPEAL FILED BY THE REVENUE AS INFRUCTUOUS. 3. IN THE RESULT, APPEAL FILED BY THE ASSESSEE FOR THE ASSESSMENT YEAR 2010 - 11 IS PARTLY ALLOWED AND THE APPEAL OF THE REVENUE IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT 31ST MAY , 2017 . SD/ - SD/ - ( G.S. PANNU ) ( RAM LAL NEGI ) ACCOUNTANT MEMBER JUDICIAL MEMBER MUMBAI ; DATED: 31 / 0 5 / 2017 ALINDRA PS / COPY OF THE ORDER FORWARDED TO : 1. / THE APPELLANT 2. / THE RESPONDENT. 3. ( ) / THE CIT(A) - 4. / CIT 9 ITA NO S . 2244 & 1685/MUM/2015 ASSESSMENT YEAR: 2010 - 2011 5. , , / DR, ITAT, MUMBAI 6. / GUARD FILE . / BY ORDER, //TRUE COPY// / (DY./ASSTT. REGISTRAR) , / ITAT, MUMBAI