Late Pramod Kumar Jayaswal, Ranchi V. DCIT, Ranchi

ITA 265/RAN/2009

• Counselvise Citation: [2014] 140 COUNSELVISE.COM (IT) 85447 (ITAT-RANCHI)
• Duration Of Justice: 5 year(s) 2 month(s) 14 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 02-12-2014
• Appeal Filed By: Assessee
• Bench Allotted: DB
• Assessment Year: 1992-1993
• Appeal Filed On: 18-09-2009
• Court: TRIBUNAL
• Department Lawyers: DEEPAK ROSHAN SENIOR S CLD
• Assessee Lawyers: S K PODDAR; M K CHOUDHARY S LD ARS
• Keywords: Unexplained investment; Opportunity of being heard; Principle of natural justice
• Section: 143(3); 148; 28; 144; 2

Judgement Text

INCOME TAX APPELLATE TRIBUNAL, CIRCUIT BENCH, RANCHI BEFORE HON'BLE SHRI H.L. KARWA, PRESIDENT , AND HON'BLE SHRI B.R. BASKARAN, ACCOUNTANT MEMBER ITA NO S. 580 TO 58 2 /PAT/06 ; 84 & 85/PAT/07 & 86/PAT/07 A.YS. 1991 - 92 TO 19 96 - 97 SHRI RAJNISH KR. JAISWAL VS. D.C.I.T, SPL. INV, CIR - 2, PATNA L/R OF LATE PRAMOD KR. JAISWAL [APPELLANT ] [ RESPONDENT ] ITA NO . 265 /RAN/ 09 A.Y . 199 2 - 93 SHRI RAJNISH KR. JAISWAL VS. D.C.I.T, C.C - 2, RANCHI L/R OF LATE PRAMOD KR. JAISWAL [APPELLANT] [ RESPONDENT ] ITA NO . 252/RAN/09 A.Y . 1992 - 93 A.C.I.T, C.C - 2, RANCHI VS. SHRI RAJNISH KR. JAISWAL L/R OF LATE PRAMOD KR. JAISWAL [ DEPRTMENT ] [ RESPONDENT ] ITA NO S . 266 & 267/RAN/2009 A.Y S. 199 5 - 96 & 19 96 - 97 SHRI RAJNISH KR. JAISWAL VS. A .C.I.T, C.C - 2, RANCHI L/R OF LATE PRAMOD KR. JAISWAL [APPELLANT] [ RESPONDENT ] FOR THE A SSESSEE/RESPONDENT : S/SHRI S.K.PODDAR & M.K. CHOUDHARY, ADVOCATES, LD.ARS FOR THE RES PONDENT : SHRI DEEPAK ROSHAN, SENIOR S.C, LD. DR DATE OF HEARING : 02 - 12 - 2014 DATE OF PRONOUNCEMENT: 02 - 12 - 2014 2 ITA NO S . 580 - 582/PAT/06, 84 - 86/PA T/07 & 252,265 - 267/PAT/09 A.YS. 1991 - 92 TO 96 - 97 SH.RAJNISH KR. IAISWAL ORDER SHRI B.R. BASKARAN, ACCOUNTANT MEMBER : THE ASSESSEE HAS FILED NINE APPEA LS AND THE REVENUE HAS FILED ONE APPEAL ( ITA NO. 252/ RAN/09 ) C HALLENGING THE ORDERS PASSED BY THE LD.CIT(A) AND T HEY RELATE TO THE ASSESSMENT YEARS 1991 - 92 TO 1996 - 97. 2. THE FACTS RELATING TO THE CASE ARE STATED IN BRIEF. THE ASSESSEE IS A PROPRIETOR OF M/S. BHAGAT & CO. , AND ASSESSED TO INCOME - TAX. THE ASSESSEE IS A SUPPLIER TO THE ANIMAL HUSBANDRY DEPARTMENT [AHD] , GOVERNMENT OF BIHAR . CONSEQUENT TO THE DETECTION OF SCAM IN AHD , SEVERAL CASES WERE REGISTERED BY THE CBI ON THE ALLEGATIO N THAT MONEY WAS FRADULENTLY WITHDRAWAN FROM AHD AND TREASURY AGAINST BOGUS AND FORGE D VOUCHERS , WITHOUT MAKING SUPPLIES. THE ASSESSEE WAS ALSO ONE OF THE PARTIES ACCUSED IN THE ABOVE SAID SCAM . A CCORDINGLY A FIR WAS REGISTERED AGAINST THE ASSESSEE ALSO BY THE CBI . THE ASSESSING OFFICER RECEIVED THE INFORMATION OF THE SAME AND ACCORDINGLY ENTERTAINED THE BELIE F THAT THE ASSESSEE HAS INFLATED PURCHASES, TRANSPORTATION CHARGES AND OTHER EXPENSES. FURTHER, THE ASSESSING OFFICER NOTICED THAT THE ASSESSEE D ID NOT PRODUCE BOOKS OF ACCOUNT DURING THE COURSE OF ORIGINAL ASSESSMENT PROCEEDINGS IN SOME OF THE YEARS . HENCE, THE ASSESSING OFFICER RE - OPENED THE ASSESSMENT S RELATING TO THE ASSESSMENT YEARS 1991 - 92 TO 1994 - 95 BY ISSUING NOTICES U/S.148 OF T HE AC T ON 3 - 1 - 1997 . ACCORDING TO THE ASSESSING OFFICER, THE ASSESSEE DID NOT FILE RETURNS OF INCOME IN RESPONSE TO THE ABOVE SAID NOTICES ISSUED U/S. 148 OF THE ACT . THE ASSESSEE ALSO DID NOT APPEAR BEFORE THE ASSESSING OFFICER. HENCE, THE ASSESSING OFFICER COMPLETED THE ASSESSMENTS OF ALL THE YEARS UNDER CONSIDERATION TO THE BEST OF HIS JUDGMENT U/S. 144 OF THE ACT . 3. THE ASSESSEE CHALLENGED THE ASSESSMENT ORDERS BY FILING APPEALS BEFORE THE LD.CIT(A), BUT HE COULD NOT SUCCEED. AGAINST THE ORDERS P ASSED BY THE LD CIT(A) FOR ASSESMENT YEARS 1991 - 92 TO 1994 - 95 , THE ASSESSEE HAS FILED APPEALS WHICH HAVE BEEN NUMBERED AS ITA NO S. 580 TO 582/PAT/06 AND 84 /PAT/07. 3 ITA NO S . 580 - 582/PAT/06, 84 - 86/PA T/07 & 252,265 - 267/PAT/09 A.YS. 1991 - 92 TO 96 - 97 SH.RAJNISH KR. IAISWAL 4 . THE ASSESSING OFFICER COMPLETED THE REGULAR ASSESSMENT FOR THE ASSESSMENT YEAR S 1995 - 96 ON 26 - 03 - 1998 U/S. 143(3) OF THE ACT AND FOR THE ASSESSMENT YEAR 1996 - 97 ON 28 - 03 - 99 U/S. 144 OF THE ACT . THE APPEALS FILED BY THE ASSESSEE FOR THESE TWO YEARS WERE DISMISSED BY LD CIT(A). AGGRIEVED, THE ASSESSEE HAS FILED APPEALS BEFORE US FOR THE ASSESSMENT YEARS 1995 - 96 AND 1996 - 97 AND THEY HAVE BEEN NUMBERED AS ITA NO. 85/PAT/07 & 86/PAT/07. 5. IN ALL THE ABOVE SIX A SSESSMENT YEARS I.E 1991 - 92 TO 19 9 6 - 97, THE ASSESSING OFFICER ASSESSED THE AMOUNT RECEIVED FROM ANIMAL HUSBANDRY DEPARTMENT A S INCOME OF THE ASSESSEE. THE ASSESSING OFFICER ASSESSED THE INCOME OF THE ASSESSEE FROM PLYING OF VEHICLES ON ESTIMATE BASIS. IN THE ASSESSMENT YEARS. 1995 - 96 AND 96 - 97, THE ASSESSING OFFICER ALSO ASSESSED THE UNEXPLAINED INVESTMENT MADE IN IMMOVABLE P ROPERTIES. IN ASSESSMENT YEAR 1995 - 96 , THE ASSESSING OFFICER ALSO ASSESSED THE INCOME FROM CRUSHING CHARGES. 6 . SUBSEQUENT TO THE COMPLETION OF THE ABOVE SAID ASSESSMENTS, THE ASSESSING OFFICER AGA IN RE - OPENED THE ASSESSMENT OF THE ASSESSMENT YEAR 199 2 - 93 FOR THE SECOND TIME BY ISSUING NOTICE U/S 148 OF THE ACT ON 31.5.2001. IN THE RE - OPENED ASSESSMENT, THE ASSESSING OFFICER ASSESSED THE INCOME PERTAINING TO ASSESSEE S WIFE, SMT. MANJU BALA JAISWAL AND ASSESSEE S SON SHRI MANISH KUMAR JAISWAL ON SUBS TANTIVE BASIS IN THE HANDS OF THE ASSESSEE. IN THE APPEAL FILED BY THE ASSESSEE BEFORE THE LD.CIT(A) AGAINST SECOND ROUND OF RE - ASSESSMENT ORDER, THE LD. CIT(A) DELETED THE ADDITION RELATING TO THE INCOME OF ASSESSEE S WIFE, SMT. MANJU BALA JAISWAL ON THE REASONING THAT SHE HAS GOT INDEPENDENT SOURCE OF INCOME FROM THE BUSINESS INHERITED FROM HER FATHER. THE LD CIT(A), HOWEVER, CONFIRMED THE ASSESSMENT OF INCOME OF ASSESSEE S SON ON THE REASONING THAT THE ASSESSEE S WON WAS MINOR IN THAT YEAR AND FURTHER THE ASSESSEE HIMSELF HAS ADMITTED HIS SON S INCOME IN HIS INCOME. 7. AGGRIEVED, BY THE SAID ORDERS OF THE LD.CIT(A) BOTH THE PARTIES ARE IN APPEALS BEFORE US. THE APPEAL FILED BY THE ASSESSEE IS NUMBERED AS ITA NO . 265/RAN/09 AND THE APPEAL FILED BY THE REVENUE IS NUMBERED AS ITA NO . 252/RAN/09. 4 ITA NO S . 580 - 582/PAT/06, 84 - 86/PA T/07 & 252,265 - 267/PAT/09 A.YS. 1991 - 92 TO 96 - 97 SH.RAJNISH KR. IAISWAL 8. THE AO ALSO REOPENED THE ASSESSMENTS OF THE ASSESSMENT YEARS 19 95 - 96 AND 1996 - 97 BY ISSUING NOTICES U/S 148 OF THE ACT ON 28.3.2007 FOR BOTH THE YEARS . IN THE RE - OPENED ASSESSMENTS OF BOTH THE YEARS , THE ASSESSING OFFICER ASSESSED THE INCOME OF ASSESSEE S SON IN THE HANDS OF THE ASSESSEE ON SUBSTANTIVE BASIS. 9. THE ASSESSEE COULD NOT SUCCEED IN THE APPEAL S FILED BEFORE THE LD.CIT(A) AGAINST THE RE - ASSESSMENT ORDERS PASSED FOR THE ASSESSMENT Y EAR 1995 - 96 AND 1996 - 97 , WHEREIN THE INCOME OF THE ASSESSEE S SON ALSO ASSESSED ON SUBSTANTIVE BASIS . HEN CE, THE ASSESSEE HAS FILED APPEALS BEFORE US CHALLENGING THE ORDER S OF THE LD.CIT(A) PASSED FOR AY 1995 - 96 AND 1996 - 97 IN THE REASSESSMENT PROCEEDIDNG S . THE SAID APPEALS HAVE BEEN NUMBERED AS ITA NO S.266 & 267/RAN/2009. 10 . THE ASSESSEE HAS RAISED A LEGAL GROUND RELATING TO THE VALIDITY OF RE - OPENING OF ASSESSMENTS FOR THE ASSESSMENT YEARS 1991 - 92 TO 1994 - 95 . THE ASSESSEE HAS ALSO RAISED ANOTHER LEGA L GROUND IN THE ASSESSMENT YEAR 1991 - 92 REGARDING THE VALIDITY OF ISSUING OF NOTICES U/S. 143(2) OF THE ACT AFTER EXPIRY OF TIME LIMIT PRESCRIBED UNDER THE ACT. AT THE TIME OF HEARING THE LD.AR SUBMITTED THAT HE IS NOT PRESSING THE ABOVE SAID LEGAL ISS UES URG ED IN ASSESSMENT YEARS 1991 - 92 TO 1994 - 95 . ACCORDINGLY , THE SAID LEGAL GROUNDS URGED IN ALL THE FOUR ASSESSMENT YEARS ARE DISMISSED AS NOT PRESSED. 11. THE LD.AR FURTHER SUBMITTED T HAT THE ASSESSEE WAS IN THE JUDICIAL CUSTODY DURING THE FOLLOWING PERIODS : - A . 28 - 08 - 97 TO 02 - 05 - 98 B . 06 - 10 - 98 TO 03 - 04 - 99, AND C . 21 - 09 - 05 TO 27 - 09 - 07 HE FURTHER SUBMITTED THAT THE ASSESSMENT ORDERS RELATING TO FIRST ROUND OF RE - ASSESSMENTS PROCEEDINGS FOR THE ASSESSMENT YEARS 1991 - 92 TO 1994 - 95 AND THE REGULAR ASSESSMENT ORDERS FOR THE ASSESSMENT YEARS 1995 - 96 AND 1996 - 97 HAVE BEEN PASSED DURING THE PERIOD ON WHICH DAYS THE ASSESSEE WAS IN JUDICIAL CUSTODY . SIMILARLY, THE LD.CIT(A) HAS ALSO PASSED THE ORDERS AGAINST THE SAID 5 ITA NO S . 580 - 582/PAT/06, 84 - 86/PA T/07 & 252,265 - 267/PAT/09 A.YS. 1991 - 92 TO 96 - 97 SH.RAJNISH KR. IAISWAL ASSESSMENT ORDERS DURING THE PERIOD OF J UDICIA L CUSTODY . ACCORDINGLY, HE SUBMITTED THAT THE ASSESSEE COULD NOT CO - OPERATE WITH THE ASSESSING OFFICER AND ALSO COULD NOT FURNISH RELEVANT FACTS /MATERIAL S BEFORE THE ASSESSING OFFICER. ACCORDINGLY THE LD A.R SUBMITTED THAT THE ASSESSEE COULD NOT MAKE PROP ER REPRESENTATION ON ALL THE ISSUES. ACCORDINGLY , HE PRAYED THAT THE ORDERS PASSED BY THE LD.CIT(A) FOR THE ABOVE STATED SIX ASSESSMENT YEARS MAY KINDLY BE RESTORED THE FILE OF THE ASSESSING OFFICER FOR CARRY ING OUT THE ASSESSMENT AFRESH. 12. WE HEARD THE LD.DR ON THE SAID PLEA OF LD A.R AND ALSO PERUSED THE RECORD. ADMITTEDLY, THE ASSESSMENT ORDERS AS WELL AS THE APPELLATE ORDERS FOR THE ABOVE SAID SIX ASSESSMENT YEARS HAVE BEEN PASSED DURING PERIOD ON WHICH THE ASSESSEE WAS IN JUDICIAL CUSTODY . WE HA VE ALREADY NOTICED THAT , EXCEPT FOR THE ASSESSMENT YEAR 1995 - 96 , THE ASSESSMENT ORDERS FOR ALL OTHER FIVE ASSESSMENT YEARS HAVE BEEN PASSED U/S. 144 OF THE A C T TO THE BEST JUDGMENT OF THE ASSESSING OFFICER. THUS, WE FIND MERIT IN THE SUBMISSION OF LD A.R THAT THE ASSESSEE COULD NOT REPRESENT THE MATTERS PROPERLY BEFORE THE ASSESSING OFFICER FOR THE REASONS BEYOND THE CONTROL OF THE ASSESSEE. I N VIEW OF PECULIAR SITUATION PREVAILING IN THE INSTANT CASE, WE ARE OF THE VIEW THAT ALL THE MATTERS NEED T O BE EXAMINED AFRESH BY THE ASSESSING OFFICER , IN THE INTEREST OF NATURAL JUSTICE. . ACCORDINGLY, WE SET ASIDE THE ORDERS PASSED BY THE LD.CIT(A) IN ALL THE ABOVE S IX ASSESSMENT YEARS AND RESTORE THEM TO THE FILE OF THE ASSESSING OFFICER WITH THE DIRECTIO N TO EXAMINE ALL THE MATTERS AFRESH , AFTER AFFORDING NECESSARY OPPORTUNITY OF BEING HEARD AND TAKE APPROPRIATE DECISION IN ACCORDANCE WITH LAW. ACCORDINGLY, THE APPEALS FILED BY THE ASSESSEE IN ALL THE SIX YEARS REFERRED ABOVE ARE TREATED AS ALLOWED. 1 3 NOW, WE SHALL TAKE UP THE APPEALS FILED AGAINS T SECOND ROUND OF RE - ASSESSMENT PROCEEDINGS DONE IN THE ASSESSMENT YEAR 1992 - 93 AND ALSO IN THE RE - ASSESSMENT PROCEEDINGS RELATING TO THE ASSESSMENT YEARS 1995 - 96 AND 1996 - 97. 14. IN THE ASSESSMENT Y E AR 19 92 - 93, THE REVENUE HAS FILED THE APPEAL IN ITA NO.252/RAN/09 CHALLENGING T HE ORDER OF THE LD.CIT(A) IN DELETING THE INCOME OF 6 ITA NO S . 580 - 582/PAT/06, 84 - 86/PA T/07 & 252,265 - 267/PAT/09 A.YS. 1991 - 92 TO 96 - 97 SH.RAJNISH KR. IAISWAL THE ASSESSEE S WIFE. WE NOTICE THAT AN IDENTICAL ISSUE CAME BEFORE THE CO - ORDINATE BENCH OF THE ITAT, RANCHI IN ASSESSEE S OWN RELATING . TO THE ASSESSMENT YEAR 2000 - 01 . THE TRIBUNAL , VIDE ITS ORDER DATED 28 - 06 - 2013 IN ITA NO.256/RAN/08 , HAS CONFIRMED THE ORDER OF THE LD.CIT(A) IN DELETING THE INCOME PERTAINING TO ASSESSEE S WIFE . WE HAVE ALSO PERUSED THE ORDER PASSED BY LD CIT(A) . WE NOTICE FROM THE ORDERS PASSED BY THE LD.CIT(A) THAT ASSESSEE S WIFE, SMT. MANJU BALA JAISWAL WAS CARRYING ON BUSINESS REGULAR LY BY INHERITING THE BUSINESS NAMED M/S. R.K BHAGAT & CO. AFTER THE DEATH OF HER FATHER . THUS, WE NOTICE THAT THE LD.CIT(A) HAS DELETED THE ADDITION AFTER CONSIDERING T HE FACTUAL ASPECTS PERTAINING TO THE ISSUE . BEFORE US NO MATERIAL COULD BE PLACED BY THE LD.DR TO CONTRADICT THE FACTUAL FINDINGS GIVEN BY THE LD.CIT(A). ACCORDINGLY, WE HOLD THAT THE LD.CIT(A) WAS JUSTIFIED IN DELETING THE ASSESSMENT OF INCOME RELATING TO ASSESSEE S WIFE. ACCORDINGLY WE DISMISS THE APPEAL FILED BY THE REVENUE. 15. WE SHALL NOW TAKE UP THE APPEAL FILED BY THE ASSESSEE FOR ASSESSMENT YEAR 1992 - 93 (SECOND ROUND OF RE - OPENING), 1995 - 96 AND 1996 - 97 (REOPENED ASSESSMENTS). IN ALL THE THREE YEARS, THE ASSESSEE IS CHALLENGING THE ORDERS OF THE LD. CIT(A) IN CONFIRMING THE ASSESSMENT OF THE INCOME OF ASSESSEE S SON IN THE HANDS OF THE ASSESSEE. IN THE ASSESSMENT YEAR 1992 - 93, THE LD.AR ALSO URGED THAT THE ASSESSEE S SON WAS MINO R IN THAT YEAR AND HE NCE, THE SAME CANNOT BE CLUBBED IN THE HANDS OF THE ASSESSEE. ACCORDING TO LD A.R, THE PROVISIONS OF SEC. 64(1A) CAME INTO EFFECCT FROM ASSESSMENT YEAR 1993 - 94 ONWARDS MANDATING THE CLUBBING OF INCO ME OF MINORS. HE SUBMITTED THAT ORIOR TO AY 1992 - 93, THE INCOME OF MINOR CHILD IS LIABLE TO BE CLUBBED ONLY IF IT WAS RECEIVED FROM ASSETS DIRECTLY OR INDIRECTLY TRANSFERRED TO THE MINOR CHILD, OTHERWISE THAN FOR ADEQUATE CONSIDERATION. ACCORDINGLY, THE LD.AR SUBMITTED THAT THE TAX AUTHORITIES WERE NOT JUSTIFIED IN ASSESSING THE INCOME OF MINOR SON IN THE HANDS OF THE ASSESSEE FOR THE ASSESSMENT YEAR 1992 - 93 . 16. IN RESPECT OF ASSESSMENT YEARS 1995 - 96 AND 1996 - 97 , THE LD.AR SUBMITTED THAT THE INCOME O F THE ASSESSEE S SON HAS ALREADY BEEN DECLARED AND ASSESSED IN HIS HANDS . HE SUBMITTED THAT THE ASSESSEE S SON HAS BECOME MAJOR IN THE ABOVE SAID TWO YEARS AND HENCE THERE WAS NOT NECESSITY TO CLUB HIS INCOME WITH 7 ITA NO S . 580 - 582/PAT/06, 84 - 86/PA T/07 & 252,265 - 267/PAT/09 A.YS. 1991 - 92 TO 96 - 97 SH.RAJNISH KR. IAISWAL THE ASSESSEE. THE LD A.R PLACED RELIANC E ON THE ORDER PASSED BY THE TRIBUNAL IN THE ASSESSEE S OWN CASE RELATING .TO THE ASSESSMENT YEAR 2000 - 01, VIDE ITS ORDER DATED 28 - 06 - 2013 IN ITA NO.256/RAN/08. 17. HOWEVER, WE NOTICE THAT THE ASSESS E E HAS NOT FURNISHED THE DETAILS OF INCOME DECLARED BY THE ASSESSEE IN HIS RETURN OF INCOME FILED FOR AY 1992 - 93. IN OTHER TWO YEARS, THE PAYMENT HAS BEEN RECEIVED BY THE ASSESSEE S SON FROM AHD. THE ARGUMENT OF THE LD.AR , IN OUR VIEW , WOULD BE VALID ONLY IF THE ASESSEE S S ON HAS INCOME FROM INDEPENDEN T SOURCE S UN CONNECTED WITH THE ANIMAL HUSBANDRY SCAM. IN THE CASE OF ASSESSEE S WIFE, THERE WAS A FINDING THAT SHE HAS DERIVED INCOME FROM AN INDEPENDENT SOURCE UNCONNECTED WITH AHD SCAM, WHEREAS NO SUCH FINDING HAS BEEN GIVEN IN THE ASSESSEE S SON CASE. HENCE, IN OUR VIEW, THE ASSESSEE CANNOT TAKE SUPPORT OF THE DECISION PASSED BY THE TRIBUNAL IN AY 2000 - 01 (REFERRED SUPRA). HENCE, WE ARE OF THE VIEW THAT THE ADDITION PERTAINING TO ASSESSEE S SON ALSO REQUIRES EXAMINATION AT THE END OF THE ASSESSING O FFICER. ACCORDINGLY, WE SET ASIDE THE ORDER OF THE LD.CIT(A) ON THIS ISSUE IN ALL THE THREE ASSESSMENT YEARS AND RESTORE THEM TO THE FILE OF THE ASSESSING OFFICER WITH THE DIRECTION TO EXAMINE THE M AFRESH BY DULY CONSIDERING THE CLAIM OF ASSESSEE AND TAK E APPROPRIATE DECISION IN ACCORDANCE WITH LAW. THE ASSESSEE SHOULD BE PROVIDED WITH ADEQUATE OPPORTUNITY OF BEING HEARD. ACCORDINGLY ALL THE THREE APPEALS OF THE ASSESSEE ARE TREATED AS ALLOWED. .18 . IN THE RESULT, THE APPEAL FILED BY REVENUE FOR THE ASSESSMENT YEAR 1992 - 93 IS DISMISSED AND ALL THE APPEALS FILED BY THE ASSESSEE FOR THE ASSESSMENT YEARS 1991 - 92 TO 1995 - 96 ARE TREATED AS ALLOWED FOR STATISTICAL PURPOSE. PRONOUNCED ACCORDINGLY ON 02 - 12 - 2014 SD/ - SD/ - [ H.L. KARWA ] [ B.R. BASKARAN ] PRESIDENT ACCOUNTANT MEMBER DT. 02 - 12 - 2014 8 ITA NO S . 580 - 582/PAT/06, 84 - 86/PA T/07 & 252,265 - 267/PAT/09 A.YS. 1991 - 92 TO 96 - 97 SH.RAJNISH KR. IAISWAL PLACE : RANCHI PP, SR. PS COPY OF THE ORDER FORWARDED TO: 1. THE APPELLANT : 2 THE RESPONDENT: 3. .THE CIT, 4.THE CIT(A), 5.DR, ITAT CIRCUIT BENCH, RANCHI 6. GUARD FILE. TRUE COPY, BY ORDER, ASSTT. REGISTRAR 9 ITA NO S . 580 - 582/PAT/06, 84 - 86/PA T/07 & 252,265 - 267/PAT/09 A.YS. 1991 - 92 TO 96 - 97 SH.RAJNISH KR. IAISWAL 1. DATE OF DICTATION ........ ..... 03 - 12= - 2014 . ORDER MODIFIED BY THE MEMBER IN HIS LAPTOP ........ DICTATION TAKEN .............. 2. DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER ........................OTHER MEMBER ............................... 3. DATE ON WHICH TH E APPROVED DRAFT COMES TO THE SR. P.S./P.S. ..................... 4. DATE ON WHICH THE FAIR ORDER IS PLACED BEFORE THE DICTATING MEMBER FOR PRONOUNCEMENT.................................. 0 2 - 12 - 2014 ................................................... 5. DATE ON WHICH THE FAIR ORDER COMES BACK TO THE SR. P.S./P.S ................ 6. DATE ON WHICH THE FILE GOES TO THE BENCH CLERK ....................................... 7. DATE ON WHICH THE FILE GOES TO THE HEAD CLERK ......................................... 8. THE DATE ON WHICH THE FILE GOES TO THE ASSISTANT REGISTRAR FOR SIGNATURE ON THE ORDER ................................................................................................. 9. DATE OF DESPATCH OF THE ORDER ...................................... ........................