ITO, Faridabad V. Smt. Arti Khattar, Faridabad

ITA 2395/DEL/2012

• Counselvise Citation: 239520114 RSA 2012
• Duration Of Justice: 2 year(s) 3 month(s) 4 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 22-08-2014
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Next Hearing Date: 19-08-2014
• Assessment Year: 2003-2004
• Appeal Filed On: 18-05-2012
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Reopening of assessment; Gift; Document seized; Accommodation entries; Reason to believe; Documents seized; Reassessment proceedings
• Section: 147; 148

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 A AA A : NEW DELHI : NEW DELHI : NEW DELHI : NEW DELHI BEFORE SHRI G.D. AGRAWAL, VICE BEFORE SHRI G.D. AGRAWAL, VICE BEFORE SHRI G.D. AGRAWAL, VICE BEFORE SHRI G.D. AGRAWAL, VICE PRESIDENT AND PRESIDENT AND PRESIDENT AND PRESIDENT AND SHRI SHRI SHRI SHRI ABY T. VARKEY ABY T. VARKEY ABY T. VARKEY ABY T. VARKEY, JUDICIAL , JUDICIAL , JUDICIAL , JUDICIAL MEMBER MEMBER MEMBER MEMBER ITA NO ITA NO ITA NO ITA NO. .. .2395/DEL/2012 2395/DEL/2012 2395/DEL/2012 2395/DEL/2012 ASSESSMENT YEAR ASSESSMENT YEAR ASSESSMENT YEAR ASSESSMENT YEAR : : : : 2003 2003 2003 2003- -- -04 0404 04 INCOME TAX OFFICER, INCOME TAX OFFICER, INCOME TAX OFFICER, INCOME TAX OFFICER, WARD WARD WARD WARD- -- -1(2), BLOCK 1 1(2), BLOCK 1 1(2), BLOCK 1 1(2), BLOCK 1- -- -B, B,B, B, CGO COMPLEX, CGO COMPLEX, CGO COMPLEX, CGO COMPLEX, F FF FARIDABAD. ARIDABAD. ARIDABAD. ARIDABAD. VS. VS. VS. VS. SMT. ARTI KHATTAR, SMT. ARTI KHATTAR, SMT. ARTI KHATTAR, SMT. ARTI KHATTAR, H.NO.489, SECTOR H.NO.489, SECTOR H.NO.489, SECTOR H.NO.489, SECTOR- -- -15, 15, 15, 15, FARIDABAD. FARIDABAD. FARIDABAD. FARIDABAD. PAN : AINPK8432B. PAN : AINPK8432B. PAN : AINPK8432B. PAN : AINPK8432B. (APPELLANT) (RESPONDENT) APPELLANT BY : MS. Y. KAKKAR, SR.DR. RESPONDENT BY : SHRI SALIL AGARWAL, ADVOCATE AND SHRI SHAILESH GUPTA, CA. ORDER ORDER ORDER ORDER PER G.D. PER G.D. PER G.D. PER G.D. AGRAWAL, VP AGRAWAL, VP AGRAWAL, VP AGRAWAL, VP : : : : THIS APPEAL BY THE REVENUE IS DIRECTED AGAINST THE ORDER OF LEARNED CIT(A), FARIDABAD DATED 24 TH FEBRUARY, 2012 FOR THE AY 2003- 04. 2. GROUND NO.1 & 2 OF THE REVENUES APPEAL ARE AGAI NST THE QUASHING OF NOTICE ISSUED UNDER SECTION 148 OF THE INCOME-TAX ACT, 1961 BY THE LEARNED CIT(A) HOLDING THE SAME TO BE I NVALID, WITHOUT JURISDICTION AND VOID AB INITIO . 3. WE HAVE HEARD THE ARGUMENTS OF BOTH THE SIDES AN D PERUSED RELEVANT MATERIAL PLACED BEFORE US. AT PAGE 1 OF T HE ASSESSMENT ORDER, THE ASSESSING OFFICER HAS GIVEN THE REASONS RECORDE D FOR REOPENING OF ASSESSMENT WHICH ARE REPRODUCED BELOW FOR READY REF ERENCE:- THERE IS AN INFORMATION WITH THE DEPARTMENT THAT T HE ABOVE NAMED ASSESSEE IS THE BENEFICIARY OF AN ITA-2395/DEL/2012 2 ACCOMMODATION ENTRY AMOUNTING TO RS.6,00,000/- WHIC H WAS ACTUALLY HIS OWN UNACCOUNTED MONEY INTRODUCED T O HIS OWN CAPITAL WITHOUT PAYING ANY TAX, BY APPROACHING THE ENTRY OPERATOR WHO AFTER RECEIVING THE CASH EQUAL T O ENTRY AMOUNT AND COMMISSION WHICH IS NORMALLY 10% OF THE ENTRY, FROM THE ASSESSEE, GOT PREPARED BANK INSTRUM ENT ON 19.04.2002 OF RS.6,00,000/- OUT OF HIS OWN BANK ACC OUNT IN FAVOUR OF THE ASSESSEE PRESENTABLE AT BOB, FARIDABA D. A BIG RACKET OF PROVIDING SUCH ACCOMMODATION ENTRIES HAS BEEN UNEARTHED BY THE INCOME TAX DEPARTMENT. AFTER EXAMINING THE INFORMATION AND FURTHER DETAILS SO AVAILABLE, I HAVE REASON TO BELIEVE THAT ON ACCOUNT FAILURE ON THE PART OF THE ASSESSEE TO DISCLOSE THE PARTICU LARS, I HAVE REASONS TO BELIEVE THAT ON ACCOUNT OF FAILURE ON THE PART OF THE ASSESSEE TO DISCLOSE THE PARTICULARS OF HIS INCOME TRULY AND CORRECTLY, AN AMOUNT OF RS.6,00,00 0/- CHARGEABLE TO TAX HAS ESCAPED ASSESSMENT FOR THE A. Y. 2003-04. IN VIEW OF ABOVE, PROCEEDINGS U/S 147 OF INCOME TAX ACT, 1961 ARE HEREBY INITIATED AGAINST THE ASSESSEE FOR THE A.Y. 2003-04, BY ISSUANCE OF NOTICE U/S 148 TO BRING TO TAX THE ABOVE MENTIONED UNDISCLOSED INCOME OF RS.6,00,000/- PLUS THE COMMISSION @ 10% OF THIS ENTRY AMOUNT (EXACT AM OUNT OF COMMISSION SUBJECT TO VERIFICATION DURING THE PROCEEDINGS U/S 147) AND ALSO ANY OTHER INCOME CHARGEABLE TO TAX WHICH HAS ESCAPED ASSESSMENT AND WHICH COMES TO MY NOTICE SUBSEQUENTLY IN THE COURSE OF THE PROCEEDINGS UNDER SECTION 147 OF THE ACT. 4. AT THE TIME OF HEARING BEFORE US, THE LEARNED CO UNSEL STATED THAT THE ASSESSEE HAD NOT RECEIVED ANY BANK INSTRUMENT O F ` 6 LAKHS AS RECORDED BY THE ASSESSING OFFICER IN THE AFORESAID REASONS. HE SUBMITTED THAT THE REASONS RECORDED BY THE ASSESSIN G OFFICER ARE FACTUALLY INCORRECT, VAGUE AND DO NOT GIVE ANY SPEC IFIC INFORMATION SO AS TO EVEN PRIMA FACIE POINT OUT ANY ESCAPEMENT OF INCOME. THE ASSESSING OFFICER HAS EVEN NOT MENTIONED THE PERSON FROM WHOM THE ALLEGED ACCOMMODATION ENTRY, IF ANY, WAS RECEIVED A ND THE NATURE OF THE ACCOMMODATION ENTRY. HE SUBMITTED THAT DURING THE ACCOUNTING YEAR RELEVANT TO ASSESSMENT YEAR UNDER CONSIDERATIO N, THE ASSESSEE ITA-2395/DEL/2012 3 HAS RECEIVED THE GIFT OF ` 2 LAKHS EACH FROM SIX PERSONS. BUT, IN THE REASONS RECORDED, THERE IS NO MENTION OF ANY GIFT A ND NO MENTION OF ` 2 LAKHS. ON THE OTHER HAND, THE ONLY MENTION IN THE REASONS RECORDED IS THE SO-CALLED ACCOMMODATION ENTRY OF ` 6 LAKHS. HE, THEREFORE, SUBMITTED THAT THE ASSESSING OFFICER HAD NOT APPLIE D HIS MIND AT ALL BEFORE ISSUING NOTICE UNDER SECTION 148. THEREFORE , ON THESE FACTS, THE DECISION OF HON'BLE JURISDICTIONAL HIGH COURT IN TH E CASE OF CIT VS. SMT. PARAMJIT KAUR [2009] 311 ITR 38 (P&H) WOULD BE SQ UARELY APPLICABLE. HE ALSO RELIED UPON THE DECISION OF HON'BLE DELHI H IGH COURT IN THE CASE OF SIGNATURE HOTELS P.LTD. VS. ITO AND ANOTHER [2 011] 338 ITR 51 (DELHI). 5. LEARNED DR, ON THE OTHER HAND, STATED THAT AT TH E TIME OF ISSUE OF NOTICE UNDER SECTION 148, ONLY A TENTATIVE OR PRIMA FACIE BELIEF REGARDING THE ESCAPEMENT OF INCOME IS REQUIRED. NO CONCLUSIVE FINDING WITH REGARD TO ESCAPEMENT OF INCOME IS REQUIRED. I N SUPPORT OF THIS CONTENTION, SHE RELIED UPON THE DECISION OF HON'BLE DELHI HIGH COURT IN THE CASE OF ADITYA KHANNA VS. ACIT [2012] 21 TAXM ANN.COM 102 (DELHI). SHE ALSO STATED THAT DEFINITE INFORMATION WAS RECEIVED FROM THE INVESTIGATION WING OF THE DEPARTMENT WITH REGAR D TO A BIG RACKET OF PROVIDING ACCOMMODATION ENTRIES. FROM THE DETAILS RECEIVED FROM THE INVESTIGATION WING, IT WAS GATHERED THAT THE ASSESS EE IS A BENEFICIARY OF ACCOMMODATION ENTRY AMOUNTING TO ` 6 LAKHS. IN PARAGRAPH 2 OF THE REASONS RECORDED, THE ASSESSING OFFICER HAS ALSO ME NTIONED THAT AFTER EXAMINING THE INFORMATION AND FURTHER DETAILS SO AV AILABLE, HE HAS REASON TO BELIEVE THAT ON ACCOUNT OF FAILURE ON THE PART OF THE ASSESSEE TO DISCLOSE PARTICULARS OF HIS INCOME TRULY AND COR RECTLY, AN AMOUNT OF ` 6 LAKHS CHARGEABLE TO TAX HAS ESCAPED ASSESSMENT. SHE, THEREFORE, SUBMITTED THAT THE REOPENING OF ASSESSMENT WAS QUIT E JUSTIFIED AND THEREFORE, THE ORDER OF LEARNED CIT(A) SHOULD BE RE VERSED AND THAT OF THE ASSESSING OFFICER MAY BE RESTORED. ITA-2395/DEL/2012 4 6. WE HAVE CAREFULLY CONSIDERED THE SUBMISSIONS OF BOTH THE SIDES AND PERUSED RELEVANT MATERIAL PLACED BEFORE US. FR OM A PERUSAL OF THE REASONS RECORDED, IT IS EVIDENT THAT THE ASSESSING OFFICER HAS MENTIONED ABOUT SOME INFORMATION BY WHICH THE ASSES SEE IS THE BENEFICIARY OF AN ACCOMMODATION ENTRY OF ` 6 LAKHS BECAUSE SOME BANK INSTRUMENT WAS GOT PREPARED ON 19.04.2002 OF ` 6 LAKHS IN FAVOUR OF THE ASSESSEE PRESENTABLE AT BANK OF BARODA, FARIDABAD. NOW, IN THE REASONS RECORDED, THERE IS NO MENTION ABOUT THE NAM E OF THE PERSON WHO ARE THE ALLEGED ENTRY PROVIDER. THE NATURE OF THE ENTRY I.E. IN WHICH FORM THE ASSESSEE IS ALLEGED TO BE TAKING ENT RIES IS GIVEN. THE INFORMATION ONLY SAYS THAT SOME BANK INSTRUMENT OF ` 6 LAKHS WAS GOT PREPARED. HOWEVER, THIS INFORMATION IS FOUND TO BE FACTUALLY INCORRECT BECAUSE IN THE ASSESSMENT ORDER WHICH IS PASSED IN PURSUANCE TO NOTICE UNDER SECTION 148, THE ASSESSING OFFICER HAS RECORDED THE FOLLOWING FINDING:- DURING THE COURSE OF ASSESSMENT PROCEEDINGS, IT WA S NOTICED THAT THE ASSESSEE RECEIVED GIFTS AMOUNTING TO RS.2 LACS EACH FROM 6 PERSONS NAMELY MS. MALA KHATRI, MR S. RENU MAINI, MR. KARAN SHARMA, MR. ISHWAR SHARMA, MR . BALVENDER SINGH & MR. RAJAN JASSAL. THE ASSESSEE F ILED VARIOUS DOCUMENTS RELATING TO THE DONORS TO JUSTIFY THE SOURCE, CAPACITY TO PAY, IDENTIFICATION AND GENUINE NESS OF THE TRANSACTIONS. FROM THE PERUSAL OF THE BANK ACC OUNTS OF THE DONORS, IT WAS NOTICED THAT THERE WAS A CREDIT ENTRY OF 2 LACS EACH AND ON THE SAME DAY I.E. 19.04.2002 IN AL L THE SIX CASES AND ALL THE DONORS MADE GIFTS OF RS.2 LACS EA CH ON THE SAME DAY I.E. 19.04.2002 TO THE ASSESSEE. FROM THE BANK ACCOUNTS OF THE DONORS, THE CAPACITY TO MADE G IFT IS NOT PROVED. 7. WHEN THESE FACTUAL DETAILS ARE COMPARED WITH THE REASONS RECORDED, WE FIND THAT THE REASONS RECORDED ARE VAG UE AND FACTUALLY INCORRECT ALSO. NO BANK INSTRUMENT OF ` 6 LAKHS WAS RECEIVED BY THE ASSESSEE. ON THESE FACTS, THE DECISION OF HON'BLE JURISDICTIONAL HIGH ITA-2395/DEL/2012 5 COURT IN THE CASE OF SMT. PARAMJIT KAUR (SUPRA) WOU LD BE SQUARELY APPLICABLE, WHEREIN THEIR LORDSHIPS HELD AS UNDER:- HELD, THAT THE ASSESSING OFFICER HAD NOT EXAMINED THE INFORMATION RECEIVED FROM THE SURVEY CIRCLE BEFORE RECORDING HIS OWN SATISFACTION OF ESCAPED INCOME AN D INITIATING REASSESSMENT PROCEEDINGS. THE ASSESSING OFFICER HAD THUS ACTED ONLY ON THE BASIS OF SUSPICION AND I T COULD NOT BE SAID THAT IT WAS BASED ON BELIEF THAT THE IN COME CHARGEABLE TO TAX HAD ESCAPED INCOME. THE ASSESSIN G OFFICER HAD TO ACT ON THE BASIS OF REASONS TO BELI EVE AND NOT ON REASONS TO SUSPECT. THE TRIBUNAL RIGHTLY CONCLUDED THAT THE ASSESSING OFFICER HAD FAILED TO INCORPORATE THE MATERIAL AND HIS SATISFACTION FOR R EOPENING THE ASSESSMENT AND THEREFORE THE ISSUANCE OF NOTICE UNDER SECTION 148 OF THE ACT FOR REASSESSMENT PROCEEDINGS WAS NOT VALID. 8. THAT THE CIT(A) HAS ALSO ALLOWED RELIEF TO THE A SSESSEE FOLLOWING THE ABOVE DECISION OF HON'BLE JURISDICTIONAL HIGH C OURT. THE FACTS OF THE ASSESSEES CASE CLEARLY SHOW THAT THE ASSESSING OFFICER HAD NOT EXAMINED THE INFORMATION RECEIVED FROM INVESTIGATIO N WING BEFORE RECORDING HIS OWN SATISFACTION OF ESCAPEMENT OF INC OME. THOUGH HE HAS MENTIONED IN THE REASONS RECORDED THAT HE HAS E XAMINED THE INFORMATION AND DETAILS SO AVAILABLE. BECAUSE HAD HE EXAMINED THE DETAILS AND INFORMATION, HE WOULD HAVE CERTAINLY KN OWN THAT THE INFORMATION IS FACTUALLY INCORRECT AND INCOMPLETE. IN VIEW OF THE ABOVE, IN OUR OPINION, THE CIT(A) RIGHTLY FOLLOWED THE ABO VE DECISION OF HON'BLE JURISDICTIONAL HIGH COURT. LEARNED DR RELIED UPON THE DECISION OF HON'BLE DELHI HIGH COURT IN THE CASE OF ADITYA KHAN NA (SUPRA). HOWEVER, THE FACTS WERE QUITE DIFFERENT IN THE ABOV E CASE WHICH WOULD BE EVIDENT FROM THE FOLLOWING FACTS NOTED BY HON'BL E DELHI HIGH COURT:- THE RECORD PRODUCED BY THE REVENUE SHOWS THAT THE ASSESSEE HAD GIVEN STATEMENTS BEFORE THE SPECIAL DI RECTOR, ENFORCEMENT DIRECTORATE. IN THE STATEMENT GIVEN, TH E ASSESSEE STATED HOW MUCH WAS HIS SHARE FOR INTRODUC ING ITA-2395/DEL/2012 6 MASEFIELD TO ANDALEEB SEHGAL. HE ALSO STATED THAT H E WAS OFFERED THE PROPOSAL BY ANDALEEB SEHGAL TO UTILIZE THE OPPORTUNITY TO GET SOME CRUDE OIL ALLOCATION FROM I RAQ WHICH CAN BE BROUGHT BY SOME COMPANY INTERESTED IN THE SAME. THE ASSESSEE APPARENTLY ACTED ON THE PROPOSAL AND CONTACTED GEORGE CURMI, WHO WAS ABLE TO FIND MASEFI ELD, WHO WAS INTERESTED IN GETTING THE OIL. GEORGE CURMI INTRODUCED THE ASSESSEE AND ANDALEEB SEHGAL TO MASE FIELD. INDRUS WAS A COMPANY IN WHICH ANDALEEB SEHGAL WAS INTERESTED. IN THE STATEMENT, THE ASSESSEE HAD ADMI TTED HIS ROLE UNDER THE OIL ALLOCATIONS AS AN INTRODUCER . THE STATEMENTS MADE BY THE ASSESSEE BEFORE THE ENFORCEM ENT DIRECTORATE WERE BEFORE THE ASSESSING OFFICER WHEN HE RECORDED THE REASONS. ANDALEEB SEHGAL HAD ALSO GIVEN A STATEMENT BEFORE T HE ENFORCEMENT DIRECTORATE. THIS STATEMENT WAS ALSO BE FORE THE ASSESSING OFFICER WHEN HE RECORDED THE REASONS. IN THIS STATEMENT, ANDALEEB SEHGAL HAD REFERRED TO THE ARGU MENTS WHICH HE HAD WITH THE ASSESSEE REGARDING INDRUS NOT RECEIVING ANY REMUNERATION FROM THE SECOND OIL CONT RACT. ULTIMATELY SOME MONEY APPEARS TO HAVE BEEN RECEIVED BY INDRUS FROM MASEFIELD AS COMMISSION. ANDALEEB SEHGA L HAD ASKED GEORGE CURMI TO TRANSFER HIS SHARE OF US$ 175 00 TO HAMDAAN INDIA. IN ADDITION TO THIS STATEMENT, THE A SSESSEE HAS ALSO MADE A STATEMENT BEFORE THE ENFORCEMENT DIRECTORATE IN WHICH HE CONFIRMED RECEIPT OF US$ 14 6247 BY INDRUS. HE ALSO STATED THAT THE MONEY WAS RECEIV ED AS 5 PER CENT PROFIT FOR 30 LACS BARRELS OF OIL CONTRACT ED WITH MASEFIELD UNDER THE 'OIL FOR FOOD PROGRAMME'. THE ASSESSEE CLARIFIED IN THE STATEMENT THAT HE DID NOT DO ANY BUSINESS WITH INDRUS OUTSIDE THE 'OIL FOR FOOD PROG RAMME'. IN ADDITION TO THE STATEMENTS MADE BY THE ASSESSEE AND ANDALEEB SEHGAL BEFORE THE ENFORCEMENT DIRECTORATE, THE DOCUMENTS SEIZED BY THE ENFORCEMENT DIRECTORATE FRO M THE PREMISES OF ANDALEEB SEHGAL AND HAMDAAN EXPORTS WER E ALSO BEFORE THE ASSESSING OFFICER WHEN HE RECORDED THE REASONS. THE SEIZED DOCUMENTS INCLUDED FACSIMILE TRANSMISSION OF MESSAGES WITH RESPECT TO DIFFERENT BUSINESS TRANSACTIONS ENTERED INTO BY INDRUS. SOME OF THE DOCUMENTS WERE FOUND TO HAVE BEEN ADDRESSED TO THE ASSESSEE AND ANDALEEB SEHGAL, WHICH ACCORDING TO TH E ASSESSING OFFICER INDICATED THAT THE ASSESSEE, WHIL E BEING PRESENT IN INDIA, TOOK STRATEGIC DECISIONS FROM THE INDIAN SOIL AND RENDERED SERVICES ON BEHALF OF INDRUS. ACC ORDING TO ITA-2395/DEL/2012 7 THE ASSESSING OFFICER, THESE DOCUMENTS ESTABLISHED THAT THE OPERATIONS OF INDRUS WERE MANAGED FROM THE PREM ISES OF ANDALEEB SEHGAL IN INDIA AND SINCE CERTAIN MESSA GES WERE ADDRESSED TO THE ASSESSEE AT THE ADDRESS OF AN DALEEB SEHGAL, THE BUSINESS CONNECTION BETWEEN THE ASSESSE E AND INDRUS WAS ESTABLISHED. 9. THUS, IN THE ABOVE MENTIONED CASE, THERE WAS MAT ERIAL BEFORE THE ASSESSING OFFICER WHICH ENABLED HIM TO REACH A PRIMA FACIE CONCLUSION WITH REGARD TO THE BUSINESS CONNECTION O F THE ASSESSEE IN INDIA. THEREFORE, ON THE FACTS, THE DECISION OF HO N'BLE DELHI HIGH COURT RELIED UPON BY THE LEARNED DR IS DIFFERENT THAN THE FACTS IN THE ASSESSEES CASE AND MOREOVER, LEARNED COUNSEL FOR T HE ASSESSEE RELIED UPON THE DECISION OF HON'BLE JURISDICTIONAL HIGH CO URT WHICH WOULD BE BINDING ON ALL THE AUTHORITIES WORKING WITHIN THE T ERRITORIAL JURISDICTION OF THE SAID HIGH COURT. WE, THEREFORE, FIND NO JUS TIFICATION TO INTERFERE WITH THE ORDER OF LEARNED CIT(A). THE SAME IS SUST AINED AND GROUND NO.1 & 2 OF THE REVENUES APPEAL ARE REJECTED. 10. GROUND NO.3 OF THE REVENUES APPEAL IS AGAINST THE DELETION OF THE ADDITION OF ` 12 LAKHS. IN OUR OPINION, ONCE THE REOPENING OF ASSESSMENT ITSELF HAS BEEN HELD TO BE INVALID, CONS EQUENTIALLY, THE ASSESSMENT ORDER PASSED IN PURSUANCE TO SUCH NOTICE UNDER SECTION 148 WOULD NOT SURVIVE. THEREFORE, GROUND NO.3 OF T HE REVENUES APPEAL HAS BECOME INFRUCTUOUS AND REJECTED AS SUCH. 11. IN THE RESULT, THE APPEAL OF THE REVENUE IS DIS MISSED. DECISION PRONOUNCED IN THE OPEN COURT ON 22 ND AUGUST, 2014. SD/- SD/- ( (( (ABY T. VARKEY ABY T. VARKEY ABY T. VARKEY ABY T. VARKEY) )) ) (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 DATED : 22.08.2014 VK. ITA-2395/DEL/2012 8 COPY FORWARDED TO: - 1. APPELLANT : INCOME TAX OFFICER, INCOME TAX OFFICER, INCOME TAX OFFICER, INCOME TAX OFFICER, WARD WARD WARD WARD- -- -1(2), BLOCK 1 1(2), BLOCK 1 1(2), BLOCK 1 1(2), BLOCK 1- -- -B, CGO COMPLEX, B, CGO COMPLEX, B, CGO COMPLEX, B, CGO COMPLEX, FARIDABAD. FARIDABAD. FARIDABAD. FARIDABAD. 2. RESPONDENT : SMT. ARTI KHATTAR, SMT. ARTI KHATTAR, SMT. ARTI KHATTAR, SMT. ARTI KHATTAR, H.NO.489, SECTOR H.NO.489, SECTOR H.NO.489, SECTOR H.NO.489, SECTOR- -- -15, FARIDABAD. 15, FARIDABAD. 15, FARIDABAD. 15, FARIDABAD. 3. CIT 4. CIT(A) 5. DR, ITAT ASSISTANT REGISTRAR