PREM KUMAR AGARWAL, Bokaro Steel City V. A.C.I.T, CIRCLE 3, Bokaro Steel City

ITA 245/RAN/2016

• Counselvise Citation: [2020] 111 COUNSELVISE.COM (IT) 8379 (ITAT-RANCHI)
• Duration Of Justice: 3 year(s) 5 month(s) 24 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 22-01-2020
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: Not Allotted
• Assessment Year: 2012-2013
• Appeal Filed On: 28-07-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Depreciation; Opportunity of being heard
• Section: 143(3); 234B

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL RANCHI BENCH, RANCHI BEFORE SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER A ND MS. MADHUMITA ROY, JUDICIAL MEMBER I.T.A. NO. 245/RAN/2016 ASSESSMENT YEAR: 2012-13 SRI PREM KUMAR AGARWAL....... ...................APPELLANT M/S. TIRUPATI TRANSPORT DHARMSHALLA MARKET, BYE-PASS ROAD, CHAS, BOKARO 827 0013. [PAN: AEJPA 4443 E] ACIT, CIRCLE - 3................................... ................................................... ..............................RESPONDENT BOKARO APPEARANCES BY: SHRI DEVESH PODDAR, ADVOCATE APPEARING ON BEHALF OF T HE ASSESSEE. SMT. NISHA SINGH MARR, JCIT APPEARING ON BEHALF OF THE REVENUE. DATE OF CONCLUDING THE HEARING : NOVEMBER 04 , 2019 DATE OF PRONOUNCING THE ORDER : JANUARY 22, 2020 ORDER PER MS. MADHUMITA ROY, JM THE INSTANT APPEAL AT THE INSTANCE OF THE ASSESSEE IS DIRECTED AGAINST THE ORDER DATED 23.06.2016 PASSED BY THE LD. CIT(A) HAZARIBAG, JHARKHAND ARISING OUT OF THE ORDER DATED 13.03.2015 PASSED U/S 143(3) OF THE I.T. ACT, 1961 (HEREIN AFTER REFERRED TO AS THE ACT) BY THE ACIT CIRCLE 3, BOKARO FOR THE A.Y. 2012-13 WITH THE FOLL OWING GROUNDS: I. FOR THAT THE AGRICULTURAL INCOME CLAIMED BY THE APPELLANT WAS FROM AGRICULTURE ACTIVITIES, DETAILS OF WHICH WERE SUBMI TTED BEFORE THE A.O. HOWEVER, IRRELEVANT DETAILS WERE ASKED FOR WHICH WE RE NOT POSSIBLE TO BE SUBMITTED. IN ANY CASE, AGRICULTURAL INCOME FROM AG RICULTURE ACTIVITIES CANNOT BE TREATED AS INCOME FROM OTHER SOURCES. II. FOR THAT DISALLOWANCE OF SALARY PAID IN TOTALIT Y TO SRI ASHISH KUMAR, SON OF THE ASSESSEE AMOUNTING TO RS. 60,000/- IS UN JUSTIFIED, ILLEGAL AND INCORRECT. LD. A.O. DID NOT ASK FOR ANY DETAIL AND MADE DISALLOWANCE OF THE TOTAL AMOUNT OF THE SALARY PAID U/S 40A(2)(B). THE DISALLOWANCE MADE IS UNJUSTIFIED AND ILLEGAL. III. FOR THAT THE ADDITION OF EMPLOYEES PROVIDENT FUND AND ESI MADE IS ILLEGAL AND INCORRECT. ENTIRE PAYMENT WAS MADE BEFO RE FILING OF THE RETURN 2 I.T.A. NOS. 245/RAN/2016 ASSESSMENT YEAR: 2012-13 SRI PREM KUMAR AGARWAL (M/S. TIRUPATI TRANSPORT) DUE DATE. AS SUCH, FOLLOWING THE DECISION OF HONBL E SUPREME COURT DEDUCTION SHOULD BE ALLOWED. IV. FOR THAT THE DISALLOWANCE OF RS. 97,197/- BEING 10% OF THE TRAVELLING AND CONVEYANCE EXPENSES, DISALLOWANCE OF RS. 2,98,8 00/- OUT OF VEHICLE MAINTENANCE EXPENSES AND DISALLOWANCE OF RS. 23,532 /- BEING 20% OF THE TELEPHONE AND MOBILE EXPENSE IS ILLEGAL AND INCORRE CT. THE EXPENSE INCURRED BEING REASONABLE, NO DISALLOWANCE WAS CALL ED FOR. THERE WAS NO ELEMENT OF PERSONAL USE. V. FOR THAT THE DISALLOWANCE OF INTEREST ON HOUSING PLOT AMOUNTING TO RS. 5,46,064/- AND DEPRECIATION OF RS. 3,81,867/- ON FL AT PURCHASED AT LAKE TOWN, KOLKATA WHICH WAS USED FOR THE PURPOSES OF BU SINESS SHOULD HAVE BEEN ALLOWED IN FULL. DISALLOWANCE MADE IS UNJUSTIF IED, ARBITRARY AND ILLEGAL. VI. FOR THAT LD. A.O. WAS NOT JUSTIFIED IN MAKING A CALCULATION FOR INCOME FROM HOUSE PROPERTY SINCE HOUSE PROPERTY WAS TREATE D AS BUSINESS ASSET AND INTEREST PAID IN FULL WAS CLAIMED AS DEDUCTION. VII. FOR THAT INTEREST U/S 234A AND 234B SHOULD BE CHARGED ON THE RETURNED INCOME AND NOT ON THE ASSESSED INCOME FOLLOWING THE DECISION OF HONBLE JHARKHAND HIGH COURT. 2. GROUND NO. 1 RELATES TO DISALLOWANCE OF THE CLAI M MADE BY THE APPELLANT OUT OF THE INCOME FROM AGRICULTURE ACTIVI TIES TO THE TUNE OF RS. 1,50,000/-. THE CASE OF THE ASSESSEE IS THIS THAT T HE ASSESSEE HAS GIVEN THE LAND TO THE FAMERS FOR FIXED AMOUNT OF CONSIDERATIO N FOR THE PURPOSE OF CULTIVATION ON THAT PARTICULAR PLOT OF LAND. HOWEVE R THE TYPE OF AGRICULTURAL PRODUCE, EXTENT OF AGRICULTURAL LAND ON WHICH CULTI VATION WAS PRACTICED, AGREEMENT WITH THE SHARE-CROPPERS OR PROOF OF QUANT ITY OF SALE/SALE PROCEEDS COULD NOT BE SUBMITTED BY THE ASSESSEE. HE NCE THE GENUINENESS OF SUCH INCOME WAS NOT ACCEPTED BY THE REVENUE AND THE LD. A.O. TREATED THE SAME AS INCOME FROM OTHER SOURCES IN THE ABSENC E THOSE DOCUMENTS AND ADDED THE SAME TO THE TOTAL INCOME OF THE ASSES SEE WHICH WAS, IN TURN, CONFIRMED BY THE FIRST APPELLATE AUTHORITY. HENCE, THE APPEAL IS BEFORE US. 3 I.T.A. NOS. 245/RAN/2016 ASSESSMENT YEAR: 2012-13 SRI PREM KUMAR AGARWAL (M/S. TIRUPATI TRANSPORT) 3. IT IS THE CASE OF THE ASSESSEE BEFORE US AS ARGU ED BY THE LD. AR THAT THE AMOUNT IS MEAGRE, THE INCOME ARISING OUT OF AGR ICULTURAL ACTIVITIES DONE BY THE FARMERS OF THE PLOT OF LAND BELONGED TO THE ASSESSEE IS ONLY 1.5 LACS AND SINCE THIS IS SMALL AMOUNT, THE ASSESSEE D ID NOT ENTER INTO ANY WRITTEN AGREEMENT WITH THE FARMERS. DUE TO SUCH PRA CTICAL DIFFICULTY THE DOCUMENTS COULD NOT BE PLACED BEFORE THE AUTHORITIE S BELOW. HOWEVER, THE DETAILS OF AGRICULTURAL LAND, THE DOCUMENTS OF OWNE RSHIP OF AGRICULTURAL LAND WERE DULY SUBMITTED BEFORE THE AUTHORITIES BEL OW. IN THAT VIEW OF THE MATTER, HE PRAYS FOR DELETION OF ADDITION MADE BY T HE REVENUE. 4. ON THE OTHER HAND, THE LD. DR RELIED UPON THE OR DERS PASSED BY THE AUTHORITIES BELOW. 5. HEARD THE PARTIES, PERUSED THE RELEVANT MATERIAL S AVAILABLE ON RECORDS. IT APPEARS THAT THE CLAIM OF THE ASSESSEE TOWARDS AGRICULTURAL INCOME IS REALLY MEAGRE ONE BEING 1.5 LACS ONLY AND THEREF ORE, THE SUBMISSION AS MADE BY THE LD. ADVOCATE FOR NOT ENTERING INTO ANY WRITTEN AGREEMENT WITH THE FARMERS SEEMS TO BE GENUINE. HOWEVER, THE ASSESSEE IS THE OWNER OF SOME AGRICULTURAL LAND, WHICH IS SUFFICIENT TO P ROVE THAT SOME INCOME MUST HAVE BEEN GENERATED FROM THE AGRICULTURAL ACTI VITIES ON THAT PARTICULAR PLOT OF LAND. UNDER THIS FACTS AND CIRCUMSTANCES OF THE CASE, WE FIND NO JUSTIFICATION IN DISALLOWING 1.5 LACS OF AGRICULTUR AL INCOME AS CLAIMED BY THE ASSESSEE. HENCE THE ADDITION IS DELETED. THIS G ROUND OF APPEAL IS, THUS, ALLOWED. 6. THE DISALLOWANCE IN RESPECT OF THE SALARY PAID T O THE SON OF THE ASSESSEE NAMELY SHRI ASHISH KUMAR TO THE TUNE OF RS . 60,000/- FOR THE YEAR UNDER CONSIDERATION IS UNDER CHALLENGE BEFORE US. THE CASE OF THE 4 I.T.A. NOS. 245/RAN/2016 ASSESSMENT YEAR: 2012-13 SRI PREM KUMAR AGARWAL (M/S. TIRUPATI TRANSPORT) ASSESSEE IS THIS THAT THE SON OF THE ASSESSEE IS LO OKING AFTER THE MANAGEMENT OF THE BUSINESS OF PATNA BRANCH OF THE A SSESSEE AND HENCE SALARY AMOUNTING TO RS. 60,000/- WAS PAID FOR THE Y EAR UNDER CONSIDERATION. SUCH CLAIM OF THE ASSESSEE WAS, HOWE VER, NOT ACCEPTED BY THE LD. A.O. SINCE THE GENUINENESS AND THE BUSINESS EXPEDIENCY ON SUCH EXPENSES INCURRED BY THE ASSESSEE COULD NOT BE ESTA BLISHED REASONABLY BY THE ASSESSEE AS HELD BY THE AO. THE SAME WAS DISALL OWED U/S 40A(2)(B) OF THE ACT WHICH WAS, IN TURN, CONFIRMED BY THE LD. CI T(A). HENCE THE APPEAL IS BEFORE US. 7. WE HAVE HEARD THE RESPECTIVE PARTIES AND ALSO PE RUSED THE RELEVANT MATERIALS AVAILABLE ON RECORD. 8. AT THE TIME OF HEARING OF THE INSTANT APPEAL, TH E LD. ADVOCATE APPEARING FOR THE ASSESSEE SUBMITTED BEFORE US THE COMPARATIVE CHART FROM WHICH IT APPEARS THE CONTRACT RECEIPT FOR THE YEAR UNDER CONSIDERATION IS OF RS. 15,45,63,492/-. HAVING REGARD TO THIS PARTICULA R FACTS RS. 60,000/- I.E. SALARY PAID TO THE SON OF THE ASSESSEE FOR LOOKING AFTER THE BRANCH OFFICE BUSINESS AT PATNA ACCORDING TO US IS QUITE JUSTIFIA BLE. HENCE, WE FIND THE PLEA MADE BY THE ASSESSEE FOR INCURRING SUCH EXPEND ITURE AFTER BUSINESS PURPOSES SEEMS TO BE PRACTICAL AND THEREFORE, WE DE LETE THE ADDITION OF THE SAID AMOUNT OF RS. 60,000/-. THIS GROUND OF APPEAL IS, THUS, ALLOWED. 9. THE AMOUNT OF RS. 1,52,479/- BEING THE CONTRIBUT ION OF EMPLOYEES PROVIDENT FUND AND ESI HAS BEEN DISALLOWED BY THE A UTHORITIES BELOW. THE CASE OF THE ASSESSEE IS THIS THAT SUCH PAYMENT WAS MADE THOUGH AFTER THE EXPIRY OF THE DUE DATE TO THE CONCERNED GOVT. A CCOUNT BUT THE SAME WAS PAID BEFORE THE RETURN WAS FILED FOR THE YEAR U NDER CONSIDERATION, THE DETAILS WHEREOF AS APPEARING AT PAGE 5 OF THE ORDER PASSED BY THE A.O. 5 I.T.A. NOS. 245/RAN/2016 ASSESSMENT YEAR: 2012-13 SRI PREM KUMAR AGARWAL (M/S. TIRUPATI TRANSPORT) WHICH IS ON RECORD BEFORE US. THE LD. AR RELIED UPO N THE JUDGEMENT PASSED BY THE JURISDICTIONAL HIGH COURT WHEREBY AND WHEREUNDER, THE PAYMENT OF THE CONTRIBUTION TOWARDS PROVIDENT FUND AND ESI TO THE CONCERNED GOVT. ACCOUNT THOUGH PAID AFTER THE DUE D ATE PRESCRIBED IN THE CONCERNED ACT BUT BEFORE THE FILING OF RETURN FOR T HE YEAR UNDER CONSIDERATION HAS BEEN ALLOWED IN FAVOUR OF THE ASS ESSEE. HE, THEREFORE, PRESSED THE SIMILAR RELIEF FROM US. ON THE CONTRARY , THE LD. DR RELIED UPON THE ORDERS PASSED BY THE AUTHORITIES BELOW. 10. HEARD THE PARTIES, PERUSED THE RELEVANT MATERIA L ON RECORD BEFORE US INCLUDING THE ORDER PASSED BY THE LD. JURISDICTIONA L HIGH COURT IN THE CASE OF JAMSHEDPUR UTILITIES SERVICES COMPANY LTD. (JUSC O) JAMSHEDPUR VS. JCIT, RANGE-2, JAMSHEDPUR IN TAX APPEAL NO. 42 OF 2 010. WE FIND THAT IN THE SAID JUDGMENT THE CLAIM OF THE ASSESSEE HAS BEEN ALLOWED IN THE SIMILAR CIRCUMSTANCES . THUS, RELYING UPON THE ORD ER PASSED BY THE LD. JURISDICTIONAL HIGH COURT, WE ALLOW THE AMOUNT OF R S. 1,52,479/- TOWARDS PAYMENT IN RESPECT OF PF & ESI MADE BY THE ASSESSEE . THIS GROUND OF APPEAL PREFERRED BY THE ASSESSEE IS, THEREFORE, ALL OWED. 11. THE DISALLOWANCE OF RS. 97,197/- BEING 10% OF T HE TRAVELLING & CONVEYANCE EXPENSES, THE DISALLOWANCE OF RS. 2,98,8 00/- OUT OF VEHICLE MAINTENANCE EXPENSES AND THE DISALLOWANCE OF RS. 23 ,532/- BEING 20% OF THE TELEPHONE AND MOBILE EXPENSES HAS BEEN CHALLENG ED BEFORE US. IT APPEARS FROM THE RECORDS THAT THE ASSESSEE HAS DEBI TED AN AMOUNT OF RS. 97,197/- UNDER THE TRAVELLING AND CONVEYANCE IN SUP PORT OF WHICH THE BILLS AND VOUCHERS WERE DULY FURNISHED BY THE ASSESSEE BE FORE THE LD. A.O. NO SPECIFIC DEFECT, IN THIS RESPECT HAS BEEN FOUND BY THE ASSESSING OFFICER AS IT APPEARS FROM THE ORDER DATED 13.03.2015 ON RECOR D BEFORE US. HOWEVER, THE SAME HAS BEEN CONFIRMED BY THE LD. CIT(A), HENC E THE APPEAL BEFORE 6 I.T.A. NOS. 245/RAN/2016 ASSESSMENT YEAR: 2012-13 SRI PREM KUMAR AGARWAL (M/S. TIRUPATI TRANSPORT) US. AS WE HAVE ALREADY STATED THAT NO DEFECT, HOWEV ER, HAS BEEN POINTED OUT EITHER BY THE A.O. OR BY THE LD. CIT(A) WHILE M AKING DISALLOWANCE IN THIS RESPECT WE FIND NO REASON TO SUSTAIN SUCH ADDI TION MADE BY THE AUTHORITIES BELOW. THE SAME IS, THUS, DELETED. THE ASSESSEE HAS FURTHER DEBITED AN AMOUNT OF RS. 34,26,020/- UNDER THE HEAD VEHICLE MAINTENANCE IN SUPPORT OF WHICH THE ASSESSEE VIDE SUBMISSION DATED 29.12.2014 FURNISHED THE LEDG ER ACCOUNT OF VEHICLE MAINTENANCE. ON PERUSAL OF THE SAME, IT W AS NOTICED THAT THERE IS NO MENTION OF THE EXPENSE HEAD ON WHICH THE GIVE N AMOUNT OF EXPENDITURE WAS INCURRED ON VARIOUS DATES. FURTHER THAT THE ASSESSEE HAS CLAIMED TO HAVE MADE CERTAIN ADVANCES AGGREGATING T O RS. 2,98,800/- WHICH WAS NOT IN THE NATURE OF EXPENSES ON THE MAIN TENANCE OF VEHICLES, NEITHER ELIGIBLE TO THE DEBITED IN THE P & L A/C. T HUS, THE SAID ADVANCES WERE DISALLOWED BY REVENUE. WE FIND NO REASON TO EN TERTAIN THIS GROUND OF APPEAL RAISED BY THE ASSESSEE SINCE THE ORDER PA SSED BY THE AUTHORITIES BELOW IS ACCORDING TO US JUST AND PROPER FOR THE RE ASON MENTIONED HEREINABOVE AND HENCE THE SAME IS HEREBY CONFIRMED. THIS GROUND OF APPEAL IS, THEREFORE, FOUND TO BE DEVOID OF ANY MER IT AND THUS DISMISSED. 12. THE ASSESSEE HAS DEBITED AN AMOUNT OF RS. 1,17, 677/- AS TELEPHONE AND MOBILE EXPENSES OUT OF WHICH 20% I.E. RS. 23,53 5/- HAS BEEN DISALLOWED ON THE GROUND OF PERSONAL USE OF THE SAM E BY THE ASSESSEE BUT TAKING INTO CONSIDERATION THE AMOUNT INVOLVED IN TH E ASSESSEES BUSINESS, TOWARDS THE SALARY EXPENSES TO THE TUNE OF RS. 24, 31,977/-, THE AMOUNT OF CONTRACT RECEIPT OF RS. 15,45,63,492/- EXPENSES INC URRED FOR TELEPHONE BILLS AND MOBILE TO THE TUNE OF RS. 1,17,677.31/- S EEMS TO BE GENUINE. HENCE ADDITION IS LIABLE TO BE DELETED. WE THUS ALL OW THIS GROUND OF APPEAL 7 I.T.A. NOS. 245/RAN/2016 ASSESSMENT YEAR: 2012-13 SRI PREM KUMAR AGARWAL (M/S. TIRUPATI TRANSPORT) PREFERRED BY THE ASSESSEE BY DELETING SUCH ADDITION MADE BY THE AUTHORITIES BELOW. 13. THE DISALLOWANCE OF INTEREST ON HOUSING LOAN AM OUNTING TO RS. 5,46,064/- AND THE DEPRECIATION OF RS. 3,81,867/- O N FLAT PURCHASED AT LAKE TOWN, KOLKATA HAS BEEN CHALLENGED BEFORE US BY THE ASSESSEE WHICH WAS CLAIMED TO HAVE BEEN USED FOR BUSINESS PURPOSES. IT APPEARS FROM THE RECORD THAT THE ASSESSEE HAS DEBITED AN AMOUNT OF R S. 5,46,064/- UNDER HEAD INTEREST ON HOUSING LOAN AND HAS CLAIMED DEP RECIATION OF RS. 3,81,867/- ON THE SAME HOUSE PROPERTY; THE SAME AMO UNT WAS DEBITED IN THE P & L A/C. THE ASSESSEE WAS ASKED TO SUBMIT THE REASON AS TO WHY SUCH AMOUNT OF RS. 5,46,064/- SHOULD NOT BE ADDED T O THE TOTAL INCOME OF THE ASSESSEE SINCE THE SAID EXPENSES IS NOT A PART OF THE P & L A/C BUT IT SHALL FORM THE PART OF CALCULATION OF INCOME FROM H OUSE PROPERTY. SHOW CAUSE WAS ISSUED AS TO WHY THE AMOUNT RS. 3,81,867/ - SHOULD NOT BE ADDED BACK TO THE INCOME IN THE ABSENCE OF SUPPORTIVE EVI DENCE TO PROVE THAT THE SAID HOUSE PROPERTY WAS USED FOR BUSINESS PURPOSES TO ESTABLISH THE GENUINENESS OF THE CLAIM MADE BY THE ASSESSEE. THE ASSESSEES CASE IS THIS THAT THE SAID PROPERTY WAS USED TO MAINTAIN ACCOUNT S AND TO CONTROL BRANCH ACTIVITIES AND FOR RECORD KEEPING. SUBSEQUENTLY THE ASSESSEE WAS FURTHER ASKED TO REPLY AS TO WHETHER THE ASSESSEE HAD CLAIM ED AS INTEREST ON HOUSING LOAN AND DEPRECIATION OF THE SAID HOUSE PRO PERTY IN THE LATER YEARS. IN RESPONSE TO THAT THE ASSESSEE SUBMITTED THAT DUR ING THE LATER YEARS THE SAID BUSINESS USAGE OF THE SAID HOUSE PROPERTY AT P LOT NO. 224/B, BANGUR AVENUE, BLOCK-A, P.S. LAKE TOWN, KOLKATA WAS DISC ONTINUED AND HENCE THE RESPECTIVE CLAIMS WERE NOT MADE IN THE P&L A/C DURING THE LATER ASSESSMENT YEARS. SUCH CLARIFICATION GIVEN BY THE A SSESSEE WAS NOT FOUND SUITABLE IN THE ABSENCE OF MATERIAL AND EVIDENCES P RODUCED AND/OR FURNISHED BY THE ASSESSEE BEFORE THE A.O. AND HENCE THE DISALLOWANCE OF 8 I.T.A. NOS. 245/RAN/2016 ASSESSMENT YEAR: 2012-13 SRI PREM KUMAR AGARWAL (M/S. TIRUPATI TRANSPORT) RS. 9,27,931/- (RS. 5,46,064/- + RS. 3,81,867/-) WA S MADE AND ADDED BACK TO THE TOTAL INCOME OF THE ASSESSEE. AS IT APPEARS FROM THE RECORD THAT THOSE EVIDENCES WERE NOT PRODUCED OF BEFORE THE FIR ST APPELLATE AUTHORITY AND HENCE IN ORDER TO AVOID THE MISCARRIAGE OF JUST ICE WE WOULD LIKE TO GIVE ANOTHER OPPORTUNITY TO THE ASSESSEE TO REPRESE NT HIS CASE BEFORE THE LD. AO AND THUS WE REMIT THE ISSUE TO THE FILE OF T HE LD. A.O. THE LD. A.O., THEREFORE, IS DIRECTED TO ADJUDICATE UPON THE SAME AFRESH AFTER GIVING AN OPPORTUNITY OF BEING HEARD TO THE ASSESSEE AND A FTER TAKING INTO CONSIDERATION THE EVIDENCES ON RECORD AND ALSO THE EVIDENCE WHICH THE ASSESSEE MAY CHOOSE TO FILE AT THE TIME OF HEARING OF THE MATTER. THIS GROUND OF APPEAL PREFERRED BY THE ASSESSEE IS, THUS , ALLOWED FOR STATISTICAL PURPOSES. 14. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS AL LOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 22 .01.2020. SD/- SD/- ( PRADIP KUMAR KEDIA) (MS. MADHUMITA ROY) ACCOUNTANT MEMBER JUDICIAL MEMBER TRUE COPY DATED: 22/01/2020 TANMAY, SR. PS COPY OF ORDER FORWARDED TO: 1. SRI PREM KUMAR AGARWAL (M/S. TIRUPATI TRANSPORT). 2. ACIT, CIRCLE 3, BOKARO. 3. THE CIT(A) 4. THE CIT 5. DR TRUE COPY, BY ORDER, SR. P.S. / H.O.O. ITAT, AHMEDABAD