The Asstt.Commissioner of Income-tax, Jalandhar V. Dr. Jasleen Kaur, Jalandhar

ITA 286/ASR/2012

• Counselvise Citation: 28620914 RSA 2012
• Duration Of Justice: 1 year(s) 7 month(s) 16 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 14-02-2014
• Appeal Filed By: Department
• Order Result: Allowed
• Bench Allotted: DB
• Next Hearing Date: 28-01-2014
• Assessment Year: 2007-2008
• Appeal Filed On: 28-06-2012
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Keywords: Unexplained investment; Corroborative evidences
• Section: 142(1); 132

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH; AMRITSAR. BEFORE SH. H.S. SIDHU, JUDICIAL MEMBER AND SH. B.P.JAIN, ACCOUNTANT MEMBER I.T.A. NO.286(ASR)/2012 ASSESSMENT YEAR:2007-08 PAN :ABIPK6994L ASSTT. COMMR. OF INCOME TAX, VS. DR. JASLEEN KAUR, C.C. II, JALANDHAR. C/O M/S. ORTHONOVA HOSPITAL, NAKODAR ROAD, JALANDHAR. (APPELLANT) (RESPONDENT) APPELLANT BY:SH. MAHAVIR SINGH, DR RESPONDENT BY:SH.SURINDER MAHAJAN, CA DATE OF HEARING: 28/01/2014 DATE OF PRONOUNCEMENT:14/02/2014 ORDER PER BENCH ; THIS APPEAL OF THE REVENUE ARISES FROM THE ORDER OF THE CIT(A), JALANDHAR DATED 16.04.2012 FOR THE ASSESSMENT YEAR 2007-08. THE REVENUE HAS RAISED FOLLOWING GROUNDS OF APPEAL: 1. THAT THE ORDER OF THE LD. CIT(A) IS AGAINST THE LAW AND FACTS OF THE CASE. 2. THAT THE LD. CIT(A)-1, LUDHIANA HAS ERRED IN LAW AND FACTS IN DELETING ADDITION OF RS.20,00,000/- AS UNDER: ITA NO.286(ASR)/2012 2 I) THERE IS NO EVIDENCE THAT THE AGREEMENT WAS CANC ELLED AS NO AGREEMENT FOR CANCELLATION WAS FILED WITH THE AO OR WITH CIT(A) IN THE PROCEEDINGS BEFORE IT. II) THERE IS NO RECEIPT PRODUCED OF ANY CASH HAVING BAC K RETURNED ON THE CANCELLATION OF THE AGREEMENT WITH SH. SANDEEP KUMAR. III) NO EVIDENCE IN SUPPORT OF ABOVE TWO CLAIMS WAS FOUN D OR SEIZED DURING THE SEARCH PROCEEDINGS. 3. THE LD. CIT(A) HAS ERRED IN DELETING THE ADDITION O F RS.20 LAC BY ACCEPTING ASSESSEES EXPLANATION THAT AMOUNT OF RS.20 LACS HAS BEEN RETURNED TO SH. SANDEEP KUMAR ON CANCELLAT ION OF AGREEMENT MERELY ON THE BASIS OF A CHART WHICH WAS NOT SUBSTANTIATED BY ANY EVIDENCE, ORIGINAL PURCHASE/SA LE AGREEMENT AND CANCELLATION AGREEMENT SPECIALLY WHEN THE ORIGI NAL AGREEMENT FOR SALE WAS EXECUTED ON 29.09.2006 AND C LAIMED TO HAVE BEEN CANCELLED MUCH LATER AFTER A LAPSE OF ABO UT 15 MONTHS. 4. THE LD CIT(A) HAS ERRED IN IGNORING THE FACT THAT THERE IS NO EVIDENCE ON RECORD TO SHOW THAT THE AMOUNT OF RS. 2 0 LACS RECEIVED IS STILL PAYABLE. HENCE, CIT(A) HAS IGNO RED THE PROVISIONS OF SECTION 51 OF THE IT. ACT. 5. THE APPELLANT CRAVES LEAVE TO ADD OR AMEND THE GROU NDS OF APPEAL ON OR BEFORE THE APPEAL IS HEARD AND DISPOSE D OFF. 6. IT IS PRAYED THAT THE ORDER OF THE CIT(A) BE SET AS IDE AND THAT OF THE A.O. BE RESTORED. 2. THE BRIEF FACTS OF THE CASE AS ARISING FROM THE ORDER OF THE AO FOR REPRODUCED FOR THE SAKE OF CONVENIENCE AS UNDER: 2. IN RESPONSE TO THIS, THE ASSESSEE FILED RETURN OF INCOME ON 31.03.2008 DECLARING INCOME AT RS.19,04,480/-. NOTI CE U/S 143(2) & 142(1) WERE ISSUED ALONG WITH THE QUESTION NAIRE. IN RESPONSE TO THESE NOTICES, SH. J.S.BHASIN, ADV. AND SH. DINESH GUPTA, C.S. ATTENDED THE PROCEEDINGS FROM TIME TO T IME AND CASE WAS DISCUSSED WITH THEM. ITA NO.286(ASR)/2012 3 3. FROM THE RECORDS, AS MADE AVAILABLE BY THE ASSES SEE, IT APPEARS THAT THE ASSESSEE DERIVED INCOME FROM BUSINESS OR P ROFESSION TO THE TUNE OF RS20,99,796/-. 3.1. THE ASSESSEE HAS NOT FILED ANY BALANCE SHEET A LONG WITH HER RETURN OF INCOME. THE SB A/C NO.9172 WITH BANK OF B ARODA, JALANDHAR IN THE NAME OF THE ASSESSEE WAS CLAIMED TO HAVE BEEN MAINTAINED THROUGH THE BOOKS OF ACCOUNT OF THE FIRM M/S. ORTHONOVA HOSPITAL. THUS, IT IMPLIES THAT WHATEVER HAD BEEN RECEIVED AND SPENT IN THE NAME OF THE ASSESSEE IS E ITHER REFLECTED IN THE CAPITAL ACCOUNT OF THE ASSESSEE IN THE FIRM OR IN ITS PROFIT & LOSS A/C. 4. DURING THE COURSE OF SEARCH U/S 132 AT M/S. ORTH ONOVA HOSPITAL CUM RESIDENTIAL PREMISES OF THE ASSESSEE, VARIOUS O RIGINAL AGREEMENTS, PERTAINING TO SALE AND PURCHASE OF IMMO VABLE PROPERTIES WERE FOUND AND SEIZED AS PER ANNEXURE A- 36. 4.1. AS PER IST AGREEMENT DATED 24.07.2006 ANNEXURE A-36, THE ASSESSEE HAS MADE A PAYMENT OF RS.15 LAKH ( RS.10 L AKH BY CASH AN RS. 5 LAKH BY CHEQUE OF BANK OF BARODA . 4.2. THE ASSESSEE HAS NOT APPENDED ANY COPY OF BALA NCE SHEET TO SHOW HER PURPORTED WITHDRAWAL OF RS. 10 LAKH. IT IS RELEVANT TO NOTE THAT A CASH PAYMENT OF RS.10 LAKH HAS BEEN MA DE ALONGSIDE A CHEQUE PAYMENT FOR GIVING ADVANCE OF RS . 15 LAKH TO SH. HITESH KUMAR S/O SH. N.K.AGGARWAL. THE PROPE RTY FOR WHICH THE ADVANCE OF RS. 15 LAKH WAS PAID IS LOCATE D AT VILLAGE MALKO, TEHSIL JALANDHAR AND ITS AREA IS 51 MARLAS 1 59 SQ. FT. 4.3. REGARDING SOURCE OF RS.10 LAKH CASH PAID ON 24 .07.2006, NO DOCUMENTARY EVIDENCE OR EXPLANATION OF THE SOURCE W HATSOEVER HAS BEEN FURNISHED BY THE ASSESSEE DURING THE COURS E OF SEARCH & SEIZURE PROCEEDINGS. 4.4. THEREFORE, THIS AMOUNT OF RS.10 LAKH IS BEING TREATED AS UNEXPLAINED INVESTMENT IN THE HAND OF THE ASSESSEE. 4.5. FURTHER, IN 2 ND AGREEMENT THE PROPERTY OF 51 MARLAS 159 SQ. FT. AT VILLAGE MALKO WAS TO BE SOLD BY THE ASSESSEE TO SH. SANDEEP KUMAR SON OF SH. OM PARKASH, RAJA GARDEN, MITHAPUR ROAD, ITA NO.286(ASR)/2012 4 JALANDHAR. AND RECEIVED AN ADVANCE OF RS.20,00,000 FROM SH. SANDEEP KUMAR ON 29.09.2006. 4.6. THE ASSESSEE HAS SUBMITTED THAT THIS AGREEMEN T WAS CANCELLED AND THE ADVANCE WAS FORFEITED. 4.7. THEREFORE, IT IS SEEN THAT THE ASSESSEE EARNED RS.20 LAC AS INCOME FROM FORFEITED ADVANCE. THE SAME IS BEING AD DED AS UNDISCLOSED INCOME OF THE ASSESSEE. 4.8. FURTHER, IN THE THIRD AGREEMENT (ANNEXURE A-36 , PAGES 6 TO 8), THE ASSESSEE HAS MADE AN AGREEMENT TO PURCHASE PROP ERTY AT 749-C, GTB NAGAR. THE PROPERTY AREA IS 10 MARLAS AN D 45 SQ. FT. AD THE TOTAL CONSIDERATION OF THE TRANSACTION I S 4.32 CRORE. THE ASSESSEE HAS PAID AN ADVANCE OF RS.20 LAKH ON 2 9.09.2006 AS THE SOURCE OF RS. 20 LAKH HAS BEEN TAKEN AS AMO UNT RECEIVED BY THE ASSESSEE ON ACCOUNT OF FORFEITED ADVANCE, RE CEIVED BY HER FROM SHRI SANDEEP KUMAR, ON ADVERSE VIEW IS BEING T AKEN ON THIS ACCOUNT. 4.9. ON THIS NOTE THE ASSESSEES EXPLANATION IS REJ ECTED AND THIS SUM OF RS.30,0,000/- IS ADDED TO HER TOTAL INCOME. 3. BEFORE THE LD. CIT(A), THE ASSESSEE MADE SUBMISS IONS WHICH WERE SENT TO THE AO FOR COMMENTS, WHO SUBMITTED THE COMM ENTS AND THE LD. CIT(A) VIDE PARA 8 OF HIS ORDER DELETED THE ADDITIO N. FOR THE SAKE OF CONVENIENCE, SUBMISSIONS OF THE ASSESSEE, REMAND RE PORT OF THE AO AND FINDINGS OF THE CIT(A) ARE REPRODUCED AS UNDER: 7. DURING THE COURSE OF APPELLATE PROCEEDINGS THE AR OF THE APPELLANT SUBMITTED HIS ARGUMENTS ON THE ISSUE AS U NDER: THERE IS ANOTHER ADDITION OF RS.20 LACS MADE BY TH E AO AS PER PARA 4.5 TO 4.7 OF HIS ORDER WHICH IS UNDER CHA LLENGE. HERE AGAIN, THE ADDITION MADE IS IN TOTAL DISREGARD TO W HAT WAS ITA NO.286(ASR)/2012 5 STATED BEFORE HIM. ON FACTS, THE ASSESSEE, AFTER HA VING ENTERED INTO ABOVE AGREEMENT WITH SHRI HITESH KUMAR, FURTH ER ENTERED INTO ANOTHER AGREEMENT TO SELL ON 29.09.2006, WITH ONE SHRI SANDEEP KUMAR, SON OF SHRI OM PARKASH RAJA, RAJA GA RDEN, JALANDHAR, IN RESPECT OF THE SAME VERY PROPERTY AT VILLAGE MALKO, FOR WHICH SHE RECEIVED AN ADVANCE OF RS. 20 LACS SUBJECT TO EXECUTION OF REGISTERED SALE DEED ON 28.03.2007. WHAT IS OSTENSIBLE FROM THE NATURE OF ABOVE DEEDS IS THAT H AVING ENTERED INTO SUCH DEALS ONLY WITH THE INTENTION TO TRADE, T HE ASSESSEE, IN HER ID TO MAKE A QUICK BUCK, PARTED WITH HER RIGHTS IN THE PROPERTY SO AS TO REALIZE THE ADVANCE PAID AT A MA RGINAL PREMIUM. HOWEVER, THIS DEAL, FOR CERTAIN UNFORESEEN REASONS, FAILED TO MATURE AND WAS SUBSEQUENTLY CANCELLED. UP ON CANCELLATION, THE AMOUNT RECEIVED HAD TO BE RETURN ED. THIS POSITION WAS SO STATED IN THE CHART APPENDED TO REP LY FILED ON 26.11.08 UNDER THE COLUMN PRESENT STATUSES. THIS S TATUS WAS RELATABLE TO THE DATE OF FILING OF THE REPLY I.E. 2 6.11.08. HOWEVER, THE AO WITHOUT CONSULTING THE ASSESSEE OR THE ABOVE CHART FILED WITH HIM INFERRED OF HIS OWN, AND WRONG LY SO THAT ON THE CANCELLATION OF DEAL, THE ADVANCE RECEIVED WAS FORFEITED. HE FURTHER ENDEAVOURED TO STRENGTHEN THIS WRONG INFERE NCE BY MAKING A SPECIFIC MENTION IN PARA 4.8 OF HIS ORDER, THAT THIS FORFEITED AMOUNT OF RS.20 LACS WAS FURTHER UTILIZED BY ASSESSEE IN THE PURCHASE OF PROPERTY I.E. 749C, GTB NAGAR, J ALANDHAR ON 29.9.2006 AND THUS THE SUBSEQUENT INVESTMENT DID NOT WARRANT ANY ADVERSE VIEW. HAVING INFERRED SO, THE A O WENT AHEAD WITH EFFORTLESS EASE TO MAKE THE IMPUGNED ADD ITION OF RS.20 LACS. THE ABOVE FINDINGS OF THE AO TO SAY THE LEAST, ARE AGAIN NOT CONSISTENT WITH THE FACTS AND MATERIAL PLACED ON RE CORD BEFORE HIM. THE ASSESSEE IN THE CHART REFERRED TO ABOVE HAD MENTIONED THAT THE DEAL WAS CANCELLED AND AMOUNT RE TURNED. IN THE SAME CHART, THE INVESTMENT IN PROPERTY AT GTB N AGAR, WAS ALSO EXPLAINED TO HAVE BEEN MADE OUT OF ADVANCE REC EIVED FROM SANDEEP KUMAR AGAINST PROPERTY AT VILL. MALKO. WHAT ESCAPED THE MARVEL EYE OF THE AO WAS THAT THE CANCELLATION OF MALKO PROPERTY DEAL HAD NOT TAKEN PLACE DURING THE YEAR U NDER APPEAL. IT WAS STATED TO BE THE PRESENT STATUS AS C OULD BE RELATED TO THE PERIOD WHEN THE REPLY WAS FILED. THE ASSESSE ES REPLY THAT ITA NO.286(ASR)/2012 6 AMOUNT WAS RETURNED, WAS NEITHER DISPUTED NOR QUEST IONED FURTHER. IT APPEARS TO HAVE JUST BEEN IGNORED. BUT THE FACT REMAINS THAT THE AMOUNT WAS ACTUALLY RETURNED SUBSE QUENTLY AND THE SAME COULD HAVE BEEN EXPLAINED WITH EVIDENC E IF QUESTIONED BY THE AO. THUS, THE ADDITION MADE BY TH E AO BY INFERRING THAT THE AMOUNT WAS FORFEITED, IS NOT ONL Y A RESULT OF GROSS MISREADING OF THE REPLY FILED BY ASSESSEE, B UT ALSO, IT IS WITHOUT ANY BASIS WHATSOEVER BROUGHT ON RECORD. THE REFORE, SUCH ERRONEOUS AND HYPOTHETICAL ADDITION DOES NOT D ESERVE TO BE SUSTAINED. COPIES OF ABOVE DEEDS ARE ALSO ENCLOS ED FOR KIND PERUSAL. 8. SINCE THE AO HAD MADE THE ADDITION ON THE PRESUM PTION THAT ASSESSEE HAD FORFEITED THE AMOUNT RECEIVED AS ADVANCED CLARIFICATION WAS SOUGHT DURING THE APPELLATE PROCE EDINGS ON THIS ISSUE. THE AO DIRECTED TO BRING ON RECORD ANY EVIDENCE IN THE FORM OF SUBMISSION BY THE AR MAKING THE CLAIM O F FORFEITURE AS RECORDED IN THE ASSESSMENT ORDER. THE COMMENTS O F THE AO ON THE ISSUE WERE SUBMITTED VIDE LETTER DATED 19.3. 2012 WHICH ARE REPRODUCED AS UNDER: AS REGARDS FORFEITURE OF RS. 20 LACS BIANA WHICH WAS SUPPOSED TO HAVE BEEN RECEIVED FROM SANDEEP KUMAR, A SUPPORTING CART OF STOCK-IN-TRADE WAS FILED DURING ASSESSMENT ON 24.12.2008, IN WHICH IN RESPECT OF THE DEAL WIT H SANDEEP KUMAR, IT WAS MENTIONED THAT AGREEMENTS CANCELLED AMOUNTS RETURNED. BUT THERE WAS NO FURTHER EXPLANATION GIV EN, MAY BE DUE TO SHORTAGE OF TIME, NOR ANY EVIDENCE FILED ABO UT THE DATE OF CANCELLATION OF DEAL AND RETURNING OF AMOUNT OF RS. 20 LACS. OBVIOUSLY IN THE ABSENCE OF NECESSARY DETAILS, DURI NG ASSESSMENT PROCEEDINGS AND ALSO DURING SEARCH, THE AO ASSUMED THAT THE AMOUNT WAS NOT RETURNED BUT FORFEI TED SINCE NO SUPPORTING EVIDENCE WAS FOUND OR SEIZED DURING S EARCH. 9. I HAVE CONSIDERED THE BASIS OF ADDITION MADE BY THE AO AND THE ARGUMENTS OF THE AR ON THE ISSUE AS WELL AS THE COMMENTS OF THE AO IN THE REMAND REPORT. IT IS SEEN THAT THE ASSESSEE HAD RECEIVED A SUM OF RS. 20 LACS FROM SH. JATINDER KUMAR IN CASH ON ACCOUNT OF CANCELLATION OF DEAL IN RESPECT OF PROPERTY NO.749C GTB NAGAR AND THIS AMOUNT HAD BEEN ACCEPTED BY THE AO AS SUCH. FURTHER SAME AMOUNT OF RS. 20 ITA NO.286(ASR)/2012 7 LACS WAS USED BY THE ASSESSEE TO RETURN IT TO SH. S ANDEEP KUMAR ON CANCELLATION OF AGREEMENT IN RESPECT OF VILLAGE MALKO PROPERTY. SIMILARLY SH. HITESH KUMAR ALSO RETURNS T O RS.15 LACS TO THE ASSESSEE WHEREBY RS. 10 LACS HAD BEEN PAID I N CASH AND RS. 5 LACS IN CHEQUE. THE SEQUENCE OF EVENTS MAKES IT QUITE CLEAR THAT ASSESSEES CLAIM OF RETURNING THE AMOUNT OF RS. 20 LACS IS LOGICAL AND THE AO HAD NO BASIS TO WRONGLY ATTRIBUTE FORFEITURE OF THIS AMOUNT ON THE PART OF THE ASSESS EE. THE REMAND REPORT CLEARLY BRINGS ON RECORD THIS FACT TH AT THE AO HAD CONCLUDED FORFEITURE ONLY ON THE BASIS OF PRESU MPTION AND ATTRIBUTED THE SAME TO THE ASSESSEES SUBMISSIONS. IN THE CIRCUMSTANCES THE ADDITION MADE BY THE AO IS DIRECT ED TO BE DELETED. 4. THE LD. JCIT(DR), MR. MAHAVIR SINGH, ARGUED THAT THE ASSESSEE RECEIVED AN ADVANCE OF RS. 20 LACS FROM SH. SANDEEP KUMAR ON 29.09.2006. AS PER 4.6 OF AOS ORDER, THERE WAS SUBMISSION OF T HE ASSESSEE THAT THIS AGREEMENT WAS CANCELLED AND THE ADVANCE WAS FORFEIT ED AND ACCORDINGLY THE AO MADE AN ADDITION OF RS. 20 LACS AS INCOME OF THE AMOUNT OF ADVANCE FORFEITED AS UNDISCLOSED INCOME OF THE ASSESSEE. T HE LD. JCIT (DR), MR. MAHAVIR SINGH FURTHER ARGUED THAT IT IS THE SAID AMOUNT FORFEITED AMOUNTING TO RS.20 LACS WHICH HAS BEEN CONSIDERED A S SOURCE FOR PAYMENT MADE AGAINST THE AGREEMENT TO PURCHASE PROPERTY AT 749-C, GTB NAGAR, MEASURING 10 MARLAS AND 45 SQ. FT AND ACCORDINGLY THE SAID FORFEITED AMOUNT WAS CONSIDERED AS SOURCE OF INCOME AGA INST THE DEAL OF PURCHASE OF PROPERTY AT 749-C GTB NAGAR AND ACCORDINGLY NO ADDITIONS HAVE BEEN MADE FOR THE SOURCE OF 749-C GTB NAGAR. THE SA ID FORFEITED AMOUNT ITA NO.286(ASR)/2012 8 HAS BEEN ADJUSTED TO HAVE BEEN GIVEN AS AN ADVANCE AGAINST THE SAID PROPERTY WHICH IS EVIDENT FROM PARA 4.8 OF AOS ORD ER. 5. THE LD. CIT(A) AND THE AO IN THE REMAND REPORT H AS RELIED UPON A CHART OF STOCK-IN-TRADE AND THE AO IN THE REMAND PR OCEEDINGS HAD MADE THE ASSUMPTIONS THAT DUE TO SHORTAGE OF TIME, THE EVIDE NCE MAY NOT HAVE BEEN FILED BY THE ASSESSEE AND DUE TO THE SHORTAGE IN T HE ORIGINAL ASSESSMENT PROCEEDINGS MUST HAVE MADE ASSUMPTION THAT THE AMOU NT HAS NOT BEEN RETURNED BUT HAS BEEN FORFEITED. THESE FINDINGS OF THE AO IN THE REMAND PROCEEDINGS AND CONSEQUENTLY BY THE LD. CIT(A) THA T THE AMOUNT OF RS. 20 LACS HAVE BEEN RETURNED AND THE ADDITIONS HAVE BEEN DELETED IS PERVERSE OF THE FACTS. THE PERVERSITY IN THE ORDER OF THE LD. CIT(A) IS AS MENTIONED HEREINABOVE WITH REGARD TO THE FINDINGS OF THE AO I N PARA 4.6 THAT IN CASE THE AMOUNT OF RS. 20 LACS HAS BEEN RETURNED, HOW THE S AID ADVANCE OF RS. 20 LACS HAS BEEN GIVEN AS ADVANCE TO PURCHASE PROPERTY AT 749C GTB NAGAR. MOREOVER, NO AGREEMENT OR ANY OTHER EVIDENCE HAS BE EN BROUGHT ON RECORD BY THE AO IN THE REMAND PROCEEDINGS OR BEFORE THE L D. CIT(A) AGAINST THE FINDINGS OF THE AO IN THE ORIGINAL ASSESSMENT. THER EFORE, IF THE AMOUNT HAS BEEN RETURNED THE SOURCE OF SAID RS.20 LACS GIVEN AS ADVANCE AGAINST THE PURCHASE OF PROPERTY AT 749C GTB NAGAR REMAINS UNEX PLAINED. THE AO IN THE REMAND REPORT AS WELL AS THE LD. CIT(A) HAS MIS SED THIS ASPECT THAT ITA NO.286(ASR)/2012 9 ULTIMATELY THERE IS SHORTAGE OF RS.20 LACS WHICH HA S RIGHTLY BEEN ADDED TO THE INCOME OF THE ASSESSEE BY THE AO. THE LD. CIT(A), I S THEREFORE, NOT JUSTIFIED IN DELETING THE ADDITIONS MADE BY THE AO. IN THE FACTS AND CIRCUMSTANCES OF THE CASE, WE REVERSE THE ORDER OF THE LD. CIT(A) AND CONFIRM THE ORDER OF THE ASSESSING OFFICER. 6. IN THE RESULT, THE APPEAL FILED BY THE REVENUE I N ITA NO.286(ASR)/2012 IS ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 14TH FEBRUARY, 2014. SD/- SD/- (H.S. SIDHU) (B.P. JAIN) JUDICIAL MEMBER ACCOUNTANT MEMBER DATED: 14TH FEBRUARY, 2014 /SKR/ COPY OF THE ORDER FORWARDED TO: 1. THE ASSESSEE:DR. JASLEEN KAUR, NAKODAR ROAD, JALAND HAR. 2. THE ACIT, CC-II, JALANDHAR. 3. THE CIT(A), JLR. 4. THE CIT, JLR. 5. THE SR DR, ITAT, AMRITSAR. TRUE COPY BY ORDER (ASSISTANT REGISTRAR) INCOME TAX APPELLATE TRIBUNAL, AMRITSAR BENCH: AMRITSAR