Smt. Bandita Prakash Mallick, Surat V. The Income Tax Officer, Ward-7(1), , Surat

ITA 2477/AHD/2014

• Counselvise Citation: [2017] 128 COUNSELVISE.COM (IT) 5815 (ITAT-AHMEDABAD)
• Duration Of Justice: 2 year(s) 8 month(s) 9 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 18-05-2017
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: C
• Next Hearing Date: 08-05-2017
• Assessment Year: 2010-2011
• Appeal Filed On: 08-09-2014
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Keywords: Unexplained investment; Salary income; Peak credit; Corroborative evidences; Onus to prove; Bogus loan
• Section: 143(3); 68

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD C BENCH AHMEDABAD BEFORE, SHRI S. S. GODARA, JUDICIAL MEMBER AND SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER ITA NO. 2477/AHD/2014 (ASSESSMENT YEAR: 2010-11) SMT. BANDITA PRAKASH MALLICK ROOM NO.2020, BLOCK NO.237, LIG-540, GUJARAT HOUSING BOARD, PANDESARA, SURAT-394221 APPELLANT VS. ITO, WARD 7(1), SURAT RESPONDENT PAN: ALKPM0633J /BY ASSESSEE : NONE /BY REVENUE : MR. PRASOON KABRA, SR. D.R. /DATE OF HEARING : 08.05.2017 /DATE OF PRONOUNCEMENT : 18.05.2017 ORDER PER S. S. GODARA, JUDICIAL MEMBER THIS ASSESSEES APPEAL FOR ASSESSMENT YEAR 2010-11 EMANATES FROM THE CIT(A)-V, SURATS ORDER DATED 26.06.2014, PASSED IN CASE NO. CAS/V/80/2013-14 UPHOLDING ASSESSING OFFICERS ACTI ON IN ADDING ITA NO. 2477/AHD/2014 (SMT. BANDITA P. MALLICK VS . ITO) A.Y. 2010-11 - 2 - UNEXPLAINED CASH DEPOSITS OF RS.17,77,380/- IN ASSE SSMENT ORDER DATED 26.03.2013, IN PROCEEDINGS U/S. 143(3) OF THE INCO ME TAX ACT, 1961; IN SHORT THE ACT. CASE CALLED TWICE. NONE APPEARS AT ASSESSEES BEH EST. THE REGISTRY HAS ALREADY ISSUED RPAD NOTICE DATED 10.04 .2017. THE SAME HAS BEEN RECEIVED BACK UNSERVED. WE THUS PROCEED EX PA RTE AGAINST THE ASSESSEE. HER MAIN APPEAL IS TAKEN UP FOR ADJUDICATION ON MER ITS. 2. THE ASSESSEES SOLE SUBSTANTIVE GROUND CHALLENGE S UNEXPLAINED CASH DEPOSITS ADDITION OF RS.17.77LACS AS MADE BY THE AS SESSING OFFICER AND AFFIRMED IN LOWER APPELLATE PROCEEDINGS ON ACCOUNT OF HER FAILURE IN BOTH PROVING SOURCE AS WELL AS SUBSTANTIVE EVIDENCE OF R OTATION OF THE SAME MONEY IN SUPPORT OF HER LATTER PLEA SEEKING ADDITION OF O NLY PEAK AMOUNT. WE NOTICE THAT THE CIT(A) HAS DEALT WITH THE ISSUE AS UNDER: 6.1. I HAVE CONSIDERED THE ASSESSMENT ORDER AS WEL L AS THE SUBMISSIONS OF THE APPELLANT. THE APPELLANT HAS TAKEN TWO GROUNDS OF A PPEAL. THE ALTERNATIVE GROUND OF APPEAL PERTAINING TO CASH DEPOSITS IS BEI NG ADJUDICATED FIRST AS THE APPELLANT HAS MADE SUBMISSIONS IN DETAIL ON THIS GR OUND IN THE FIRST PLACE. THE GROUNDS OF APPEAL- GROUND NO. 1 (ALTERNATIVE GROUND OF APPEAL AS PER APPEAL MEMO) PERTAINS TO THE INCOME TAX OFFICER, WARD-7(L) , SURAT HAS ERRED BOTH IN FACTS AND IN TAW BY MAKING ADDITION OF CASH DEPOSIT S IN THE BANK ACCOUNTS. ON THE PERUSAL OF THE DETAILS, IT IS OBSERVED THAT THE APPELLANT IS HAVING ONLY SALARY INCOME AND THE BANK ACCOUNT IN KOTAK MAHINDRA BANK WAS NOT DISCLOSED BY THE APPELLANT. THE AO HAD AIR INFORMATION REGARDING THE UNDISCLOSED BANK ACCOUNT IN KOTAK MAHINDRA BANK WHICH WAS NOT DISCLO SED BY THE APPELLANT EVEN ON SPECIFIC QUERY MADE BY THE AO. THE APPELLAN T DURING THE ASSESSMENT PROCEEDINGS AS WELL AS APPELLATE PROCEEDINGS COULD NOT ADDUCE ANY EVIDENCE REGARDING THE SOURCE OF THE CASH DEPOSITS OF RS. 17 ,40,880/- IN MADE IN THE KOTAK MAHINDRA BANK. THE APPELLANT ALSO COULD NOT P RODUCE ANY EVIDENCE TO SHOW THAT THE CASH DEPOSITS WERE MADE OUT OF THE CA SH WITHDRAWALS AS CLAIMED BY THE APPELLANT. THE APPELLANT CASH BOOK PRODUCED DURING THE APPELLATE PROCEEDINGS IS A SELF SERVING DOCUMENTS IN ABSENCE OF ANY SUPPORTING EVIDENCE IN FORM OF BILL, VOUCHERS ETC. IN ABSENCE OF PRIMAR Y DOCUMENTS THE BENEFIT OF THE PEAK CREDIT ALSO CANNOT BE GIVEN TO THE APPELLANT. 6.1.1 IT IS AN OBLIGATORY DUTY CAST UPON A PERSON F ILING THE RETURN OF INCOME TO DISCLOSE ALL HIS INCOME DERIVED FROM ANY SOURCE UND ER VARIOUS HEADS AND INDICATE THE INCOME UNDER EACH HEAD, WHICH IS CHARG EABLE TO INCOME-TAX, AFTER ITA NO. 2477/AHD/2014 (SMT. BANDITA P. MALLICK VS . ITO) A.Y. 2010-11 - 3 - MAKING THE PERMISSIBLE DEDUCTIONS. DISCLOSURE OF IN COME WOULD BE DISCLOSURE OF PARTICULARS OF INCOME, WHICH A PERSON IS DUTY BO UND TO DISCLOSE IN FULFILLMENT OF HIS STATUTORY OBLIGATIONS TO PAY TAX ON THE INCO ME CHARGEABLE TO TAX. AFTER THE RETURN IS FILED UNDER SECTION 139(1), THE ASSESSMEN T OF TAX IS TO BE MADE AND FOR THE PURPOSE OF MAKING AN ASSESSMENT UNDER THE ACT, THE ITO MAKES AN ENQUIRY CONTEMPLATED BY SECTION 142, UNDER WHICH NOTICE IS ISSUED ON THE PERSON WHO HAS MADE THE RETURN TO PRODUCE ACCOUNTS, DOCUMENTS OR FURNISH VERIFIED INFORMATION IN WRITING INCLUDING STATEMENT OF ALL A SSETS, ETC. HOWEVER, WHERE THE AO IS SATISFIED THAT THE RETURN IS CORRECT AND COMPLETE, AS WERE THE WORDINGS OF SECTION 143(1) AT THE RELEVANT TIME, HE HAS TO A SSESS THE TOTAL INCOME WITHOUT REQUIRING THE PRESENCE OF THE ASSESSEE OR PRODUCTIO N BY HIM OF ANY EVIDENCE THAT THE RETURN IS CORRECT AND COMPLETE, AS LAID DO WN IN SECTION 143(1). WHERE, HOWEVER, THE AO IS NOT SATISFIED WITHOUT THE PRESEN CE OF THE ASSESSEE OR PRODUCTION OF EVIDENCE THAT THE RETURN IS CORRECT A ND COMPLETE, HE IS REQUIRED TO ISSUE NOTICE ENABLING THE ASSESSEE TO PRODUCE EVIDE NCE ON WHICH HE MAY RELY IN SUPPORT OF THE RETURN. THE TOTAL INCOME IN SUCH CAS ES OF REGULAR ASSESSMENT IS, ASSESSED AFTER HEARING THE EVIDENCE ADDUCED AND CON SIDERING ALL MATERIAL GATHERED BY THE ASSESSING OFFICER AS PROVIDED IN SE CTION 143(3). IT, THEREFORE, FOLLOWS THAT IN THE ASSESSMENT PROCEEDINGS UNDER SE CTION 143, THE AO CAN FIND OUT WHETHER THE RETURN OF INCOME IS CORRECT AND COM PLETE. IF HE HOLDS THAT THE RETURN OF INCOME IS NOT CORRECT OR THAT, IT IS NOT COMPLETE IN RESPECT OF THE PARTICULARS OF INCOME WHICH ARE REQUIRED TO BE STAT ED IN THE RETURN, HE WILL REACH THE CORRECT FIGURE OF TOTAL INCOME, AND DETER MINE THE SUM PAYABLE BY THE ASSESSEE OR REFUNDABLE ON THE BASIS OF SUCH ASSESSM ENT. IF THE INCOME CHARGEABLE TO TAX HAS ESCAPED ASSESSMENT FOR ANY AS SESSMENT YEAR, BY REASON OF OMISSION OR FAILURE OF THE ASSESSEE TO DISCLOSE FULLY AND TRULY ALL MATERIAL FACTS NECESSARY FOR HIS ASSESSMENT, REASSESSMENT PR OCEEDING CAN BE INITIATED AS PROVIDED UNDER SECTION 147. THIS AGAIN SHOWS THAT F ULL AND TRUE DISCLOSURE OF INCOME IS A PRIMARY OBLIGATION OF THE ASSESSEE. 6.1.2 THE APPELLANT HAS ALSO CONTENDED THAT THE TOT AL CASH DEPOSITED HAS BEEN ERRONEOUSLY ADDED AND ONLY ADDITION OF THE PEAK CRE DIT COULD HAVE BEEN TAKEN EVEN IF ADDITION IS TO BE MADE. BUT THE APPELLANT H AS NOT PROVIDED ANY SUPPORTING DOCUMENT TO DEMONSTRATE THE CLAIM OF PEA K CREDIT EXCEPT FOR A PRINT OUT OF CASH BOOK AND BANK BOOK. MERE FILING OF CASH BOOK AND BANK BOOK DOES NOT DISCHARGE THE BURDEN OF PROOF VIS-A-VIS PEAK CR EDIT. THE APPELLANT'S CLAIM OF APPLYING PEAK CREDIT IS WITHOUT ANY MATERIAL OR BAS IS. AN ANALYSIS OF THE PEAK CREDIT CONCEPT WILL CLARIFY THAT THE APPELLANT'S CL AIM IS NOT VALID. THE CONCEPT OF PEAK CREDIT HOLDS THAT SOMETIMES, AN ASSESSEE MAY C ONDUCT HIS UNACCOUNTED TRANSACTIONS THROUGH ONE OR MORE BANK ACCOUNTS OR M AY RECORD SUCH TRANSACTIONS IN A VAGUE MANNER IN ONE OR MORE BOOKS . THE DEPOSITS IN SUCH BANK ACCOUNTS MAY REFLECT. UNACCOUNTED SALES. UNACCOUNTED CASH INTRODUCED. UNACCOUNTED LOAN RECEIVED FROM OTHER. UNACCOUNTED LOANS RETURNED BY OTHERS, ITA NO. 2477/AHD/2014 (SMT. BANDITA P. MALLICK VS . ITO) A.Y. 2010-11 - 4 - UNACCOUNTED SALE PROCEEDS OF INVESTMENTS SUCH AS SHARES, PROPERTIES. 6.1.3 DETAILS MAY NOT BE AVAILABLE TO SEGREGATE THE DEPOSITS INTO THE ABOVE HEADS AND QUANTITY THE TOTAL AMOUNT UNDER EACH OF T HE ABOVE HEADS. ESTIMATING THE PROFIT AS A PERCENTAGE OF THE TOTAL OF THE DEPO SITS WOULD BE INCORRECT. IN SUCH CASES, WORKING OUT THE PEAK CREDITS (RECEIPTS) OR THE DEBITS (PAYMENT) MAY GIVE AN INDICATION OF THE TOTAL UNACCOUNTED MONEY I N THE POSSESSION OF THE ASSESSEE WHICH MAY BE ASSESSED AS HIS INCOME. 6.1.4 BUT THE PEAK CREDIT STATEMENTS CAN BE PREPARE D ONLY IF RECORDS FOR THE RECEIPT AND PAYMENT OF MONEY FOR THE ENTIRE ACCOUNT ING PERIOD ARE KEPT. THE RECORD NEED NOT: BE REGULAR BOOKS OF ACCOUNT MAINTA INED UNDER DOUBLE ENTRY SYSTEM. EVEN A ROUGH ACCOUNT WHERE DATES OF RECEIPT AND PAYMENT OF MONEY ARE RECORDED WOULD SUFFICE. FOR EXAMPLE: WHERE AN ASSES SEE MAINTAINED UNDISCLOSED BANK ACCOUNTS, FROM THE BANK ACCOUNT ST ATEMENTS, PEAK CREDIT OR THE-PEAK OF THE AMOUNTS DEPOSITED CAN BE WORKED OUT . BUT IF THE RECORDS ARE INCOMPLETE OR IF THE RECORDS AVAILABLE ONLY SHOW TO TAL AMOUNT RECEIVED ON A PARTICULAR DATE, A PEAK CREDIT STATEMENT CANNOT BE PREPARED. IN THE INSTANT CASE, THE APPELLANT DOES NOT MAINTAIN ANY BOOKS OF ACCOUN TS -REGULAR OR ROUGH ON THE BASIS OF WHICH THE PEAK CREDIT CAN BE WORKED OUT. H ENCE THIS CONTENTION OF THE APPELLANT FALLS FLAT ON MERITS AND FACTS AS HE IS U NABLE TO DEMONSTRATE THE SOURCE AND UTILIZATION OF THE CASH DEPOSITS AND WIT HDRAWALS IN THE BANK ACCOUNTS AS DISCUSSED ABOVE. 6.1.5. THE COMPLETE CONTENTION OF APPELLANT HAS BEE N EXAMINED. IT IS A MATTER OF FACT THAT THIS SECRET BANK A/C WOULD NOT HAVE COME TO THE KNOWLEDGE OF THE TAX DEPARTMENT SAVE THE USE OF TECHNOLOGY AND COLLECTIO N OF INFORMATION BY THE INCOME TAX DEPARTMENT REGARDING HIGH VALUE TRANSACT IONS THROUGH BANKING AND FINANCIAL INSTITUTIONS. THE BURDEN OF PROOF LIE S ON THE APPELLANT TO SUPPORT HIS CONTENTION THAT THE EXPLANATION REGARDING SOURC E OF DEPOSITS. THE PRIMARY ONUS IS ON THE APPELLANT TO PROVE THE SOURCE OF CAS H DEPOSITS SUPPORTED WITH EVIDENCES. THE EXPRESSION 'BURDEN OF PROOF REALLY MEANS TWO DIFFERENT THINGS. IT MEANS SOMETIMES THAT A PARTY IS REQUIRED TO PROVE A N ALLEGATION BEFORE JUDGMENT CAN BE GIVEN IN HIS FAVOUR. IT ALSO MEANS THAT ON A CONTESTED ISSUE, ONE OF THE TWO CONTENDING PARTIES HAS TO INTRODUCE EVIDENCE. IN THE FIRST SENSE, IF THE BURDEN IS NOT DISCHARGED, THE PARTY MUST EVENTU ALLY FAIL. IN THE SECOND CASE, WHERE THE PARTIES HAVE JOINED ISSUE AND HAVE LED EV IDENCE AND THE CONFLICTING EVIDENCE CAN BE WEIGHED TO DETERMINE WHICH WAY TO I SSUE CAN BE DECIDED, THE QUESTION OF BURDEN OF PROOF BECOMES AN ABSTRACT QUE STION AND IS THEREFORE ACADEMIC. SECTION 101 TO 114 OF INDIAN EVIDENCE ACT , 1872 DEALS WITH BURDEN OF PROOF. SECTION 102 OF THE EVIDENCE ACT PROVIDES THAT THE BURDEN OF PROOF LIES ON THAT PARTY WHO WOULD FAIL IF NO EVIDENCE AT AIL WERE GIVEN ON EITHER SIDE. THUS, IF AN ASSESSEE CLAIMS THAT MONEY OR BULLION F OUND IN HIS POSSESSION AT THE TIME OF THE SEARCH OR SURVEY DOES NOT BELONG TO HIM BUT SOMEONE ELSE, THE ONUS IS ON HIM TO ESTABLISH IT BECAUSE THE ORDINARY PRES UMPTION IS THAT HE IS THE OWNER AS THE MONEY ETC. WAS FOUND IN HIS POSSESSION . SIMILARLY, IN ALL CASES WHERE A PARTICULAR RECEIPT IS SOUGHT TO BE TAXED AS INCOME, THE INITIAL ONUS IS ON ITA NO. 2477/AHD/2014 (SMT. BANDITA P. MALLICK VS . ITO) A.Y. 2010-11 - 5 - THE ASSESSING OFFICER TO PROVE THAT IT IS TAXABLE. WHERE, HOWEVER, THE ASSESSEE CLAIMS EXEMPTION, THE BURDEN IS ON THE ASSESSEE TO PROVE IT TO BE EXEMPT. SAME IS THE POSITION IN CASE OF ALLOWANCES,-DEDUCTIONS, OR CLAIMS OF LOSS, ETC. SIMILARLY, WHERE THERE IS A STATUTORY REBUTTABLE PR ESUMPTION AGAINST THE ASSESSEE, AS IN CASE OF CASH CREDITS ETC., U/S 68 O R UNEXPLAINED INVESTMENT U/S 69, THE INITIAL BURDEN OF PROOF IS ON THE ASSESSEE TO SHOW THAT THE CASH CREDIT IS GENUINE OR THE INVESTMENT IS NOT UNEXPLAINED. THE A O SHOULD, THEREFORE, ALWAYS EXAMINE AS TO WHO HAS TO DISCHARGE THE BURDEN OF PR OOF. IT MAY ALSO BE NOTED THAT IN THE COURSE OF ASSESSMENT, THE BURDEN OF PRO OF MAY SHIFT FROM ONE TO THE OTHER. FOR INSTANCE, IF THE' ASSESSEE DISCHARGES HI S INITIAL BURDEN OF PROOF, THE ONUS SHIFTS TO THE ASSESSING OFFICER WHO MUST BRING OUT FACTS TO REFUTE ASSESSEE'S VERSION. 6.1.6. THE PROCEEDINGS UNDER THE INCOME TAX ACT ARE CIVIL PROCEEDINGS. THE DEGREE OF PROOF REQUIRED IN ASSESSMENT PROCEEDINGS IS BASE ON THE PRINCIPLES OF PREPONDERANCE OF PROBABILITY, UNLIKE, IN CRIMINAL PROCEEDINGS WHERE PROOF BEYOND REASONABLE DOUBT IS INSISTED UPON. IT IS OPE N TO THE ASSESSING OFFICER TO PROBABILISE HIS STAND AND SHOW ITS PREPONDERANCE WH ERE CONCLUSIVE PROOF IS NOT FORTHCOMING. THE OBSERVATIONS OF THE SUPREME COURT IN STATE OF WEST BENGAL V. MIR MOHAMMAD OMAR AND OTHERS JT 2000(9) SC 467 MADE IN THE CONTEXT OF A CRIMINAL CASE ARE RELEVANT FOR OUR PURPOSE. 'THE PRISTINE RULE THAT THE BURDEN OF PROOF IN ON T HE PROSECUTION TO PROVE THE GUILT OF THE ACCUSED SHOULD NOT BE TAKEN AS A FOSSI LIZED DOCTRINE AS THOUGH IT ADMITS OF NO PROCESS OF INTELLIGENT REASONING. THE DOCTRINE OF PRESUMPTION IS NOT ALIEN TO THE ABOVE RULE, NOR WOULD IT IMPAIR TH E TEMPER OF THE RULE. ON THE OTHER HAND, IF THE TRADITIONAL RULE RELATING TO BUR DEN OF PROOF OF THE PROSECUTION IS ALLOWED TO BE WRAPPED IN PEDANTIC COVERAGE THE O FFENDERS OF SERIOUS OFFENCES WOULD BE THE MAJOR BENEFICIARIES AND THE SOCIETY WO ULD BE THE CASUALTY...' 6.1.7. THIS RAISES THE QUESTION WHETHER THE APPAREN T CAN BE CONSIDERED AS REAL. AS LAID DOWN BY APEX COURT IN THE CASE CIT V. DURGA PRASAD MORE [1971] 82 ITR 540 , APPARENT MUST BE CONSIDERED REAL UNTIL IT IS SHOW N THAT THERE ARE REASONS TO BELIEVE THAT THE APPARENT IS NOT THE REA L AND THAT THE TAXING AUTHORITIES ARE ENTITLED TO LOOK INTO THE SURROUNDI NG CIRCUMSTANCES TO FIND OUT THE REALITY AND THE MATTER HAS TO BE CONSIDERED BY APPLYING THE TEST OF HUMAN PROBABILITIES. THE HON SUPREME COURT HELD THAT 'IT IS TRUE THAT AN APPARENT MUST BE CONSIDERED, REAL UNTIL IT IS SHOWN THAT THE RE ARE REASONS TO BELIEVE THAT THE APPARENT IS NOT THE REAL PARTY WHO RELIES ON A RECITAL IN A DEED HAS TO ESTABLISH THE TRUTH OF THOSE RECITALS, OTHERWISE IT WILL BE VERY EASY TO MAKE SELF- SERVING STATEMENTS IN DOCUMENTS EITHER EXECUTED OR TAKEN BY A PARTY AND RELY ON THOSE RECITALS. IF ALL THAT AN ASSESSES WHO WANTS T O EVADE TAX IS TO HAVE SOME, RECITALS MADE IN A DOCUMENT EITHER EXECUTED BY HIM OR EXECUTED IN HIS FAVOUR THEN THE DOOR WILL BE LEFT WIDE OPEN TO EVADE TAX, A LITTLE PROBING WAS SUFFICIENT IN THE PRESENT CASE TO SHOW THAT THE APPARENT WAS N OT THE REAL. THE TAXING AUTHORITIES WERE NOT REQUIRED TO PUT ON BLINKERS WH ILE LOOKING AT THE DOCUMENTS PRODUCED BEFORE THEM. THEY WERE ENTITLED TO LOOK IN TO THE SURROUNDING CIRCUMSTANCES TO FIND OUT THE REALITY OF THE RACITA LS MADE IN THOSE ITA NO. 2477/AHD/2014 (SMT. BANDITA P. MALLICK VS . ITO) A.Y. 2010-11 - 6 - DOCUMENTS.' CIT V. DURGA PRASAD MORE [1971] 82 UR 540, AT PP. 5 45, 547' (SC). 6.1.8 ON THE BASIS OF THE FACTS AND CIRCUMSTANCES, IT IS EVIDENT THAT THE APPELLANT HAS FAILED TO DISCHARGE THE BURDEN OF PROOF REGARDI NG THE CASH DEPOSITS IN THE BANK ACCOUNT. IN ABSENCE OF ANY EVIDENCE AND FAILUR E TO PRODUCE ANY EVIDENCE TO SUBSTANTIATE HIS CLAIM, THE ADDITION MADE BY THE AO IS CONFIRMED AND THE GROUND OF APPEAL IS DISMISSED.( CONFIRMED- RS. 17,87,960/-) 3. WE HAVE HEARD LEARNED DEPARTMENTAL REPRESENTATIV E STRONGLY SUPPORTING THE ABOVE IMPUGNED ADDITION. IT IS EVID ENT FROM THE CASE FILE THAT THE ASSESSEE HAS NOT BEEN ABLE EXPLAIN SOURCE OF HE R DEPOSIT IN QUESTION AS WELL AS COGENT MATERIAL IN SUPPORT OF THE LATTER PL EA (SUPRA). WE THUS FIND NO REASON TO INTERFERE WITH THE CIT(A)S CONCLUSION EX TRACTED HEREINABOVE. 4. THIS ASSESSEES APPEAL IS DISMISSED. [PRONOUNCED IN THE OPEN COURT ON THIS THE 18 TH DAY OF MAY, 2017.] SD/- SD/- ( PRADIP KUMAR KEDIA ) (S. S. GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER AHMEDABAD: DATED 18/05/2017 TRUE COPY S.K.SINHA / COPY OF ORDER FORWARDED TO:- / REVENUE 2 / ASSESSEE ! / CONCERNED CIT 4 !- / CIT (A) ( )*+ ,--. . /0 / DR, ITAT, AHMEDABAD 1 +23 45 / GUARD FILE. BY ORDER / . // . /0