The Deputy Commissioner of Income tax, Jalandhar V. M/s. Artisan Tanners, Jalandhar

ITA 294/ASR/2010

• Counselvise Citation: [2012] 140 COUNSELVISE.COM (IT) 63480 (ITAT-AMRITSAR)
• Duration Of Justice: 2 year(s) 2 month(s) 12 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 07-09-2012
• Appeal Filed By: Department
• Order Result: Allowed
• Bench Allotted: DB
• Next Hearing Date: 05-09-2012
• Assessment Year: 2006-2007
• Appeal Filed On: 25-06-2010
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: R L CHHANALIA
• Keywords: Bogus purchase
• Section: 142(1); 10B

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.294(ASR)/2010 ASSESSMENT YEAR:2006-07 PAN :AAFFA3449N DY.COMMR. OF INCOME-TAX, VS. M/S. ARTISAN TANNERS, RANGE-1, JALANDHAR. JALANHDAR. (APPELLANT) (RESPONDENT) APPELLANT BY:SH. R.L. CHHANALIA, DR RESPONDENT BY:SH. SURINDER MAHAJAN, CA DATE OF HEARING:05/09/2012 DATE OF PRONOUNCEMENT:07/09/2012 ORDER PER BENCH ; THIS APPEAL OF THE ASSESSEE ARISES FROM THE ORDER OF THE CIT(A), JALANDHAR, DATED 11.03.2010 FOR THE ASSESSMENT YEAR 2006-07. 2. THE ASSESSEE HAS RAISED FOLLOWING GROUNDS OF APP EAL: 1. THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF T HE CASE, THE LD. CIT(A) HAS ERRED IN LAW IN DELETING THE TRADING AD DITION OF RS. 1 CRORE MADE BY THE AO. 1.1 WHILE DOING SO, THE LD. CIT(A) FAILED TO APPRECIATE THAT I) THE CASE LAW REFERRED TO THE DECISION OF THE HON BLE PUNJAB & HARYANA HIGH COURT IN THE CASE OF CIT VS. OM ITA NO.294(ASR)/2010 2 OVERSEAS 173 TAXMAN 185 (P&H) IS NOT SQUARELY APPLI CABLE TO THE FACTS OF THE CASE IN VIEW OF THE FOLLOWINGS: A) ASSESSEE DID NOT COMPLY WITH THE REQUIREMENTS THAT AUDIT REPORT U/S 44AB OF THE ACT INDICATES THA T BOOKS OF ACCOUNT ARE NEITHER CORRECT NOR COMPLETE AND NOT OPEN FOR VERIFICATION. B) MONTHLY TRADING DETAILS DID SHOW THE SALES BUT D ID NOT REVEAL ANYTHING ABOUT THE CHEMICALS USED FOR JO B WORK. C) THE COPY OF TRADING ACCOUNT OF HIDES AND CHEMICALS FILED DURING THE ASSESSMENT PROCEEDINGS I S ALSO ENCLOSED AS ANNEXURE B. IN THIS TRADING ACCOUNT, IT IS CLEAR THAT CHEMICALS REFERRED TO THESE ACCOUNTS HAVE NOT RELEVANT TO THE JOB WORK. MOREOVER THE VALUE OF THE OPENING STOCK OF CHEMICALS AT RS.13469807 AND CLOSI NG STOCK AT RS.124095 CONFIRM THE OBSERVATION MADE IN PARA 3(A) OF THE ASSESSMENT ORDER. D) IN PARA 3 OF THE ASSTT. ORDER HIDES PROCESSED WE RE ESTIMATED AT RS. 33 LAC AND THE CORRESPONDING CHEMI CALS CONSUMED WAS TAKEN AT 20 LAC IN THE ABSENCE OF ANY EXPLANATION FROM THE ASSESSEE IN THIS REGARD AND TH E RATIO OF CHEMICALS USED/HIDES PROCESSED COMES TO 60.6% E) THE ASSESSEE DID NOT MAINTAIN ANY STOCK REGISTER IN RESPECT OF HIDES PROCESSED BY IT FOR TRADING PURPOS E AND ALSO IN RESPECT OF JOB WORK. F) NO DETAILS OF QUALITY AND QUANTITY OF CHEMICALS RECEIVED AND CONSUMED FROM M/S. ARTISAN TANNERS P. LTD. WERE FURNISHED DURING THE ASSESSMENT PROCEEDIN GS. II) THE LD. CIT(A) HAS ERRED IN CONSIDERING THAT TH E AO HAS NOT SHOWN THAT EITHER THE PURCHASES AND SALES OF TH E ASSESSEE WERE UNVERIFIABLE AND BOGUS. IN THIS CONNECTION, IT IS SUBMITTED THAT NO OBLIGATION IS CAST ON THE INCOME TAX AUTHOR ITIES TO ESTABLISH BY POSITIVE EVIDENCE THAT THE ASSESSEES ACCOUNTS ARE UNRELIABLE AND THAT THE ESTIMATE OF INCOME MADE BY THEM IS CORRECT. ALL THAT IS REQUIRED IS A JUDICIAL EXERCIS E OF DISCRETION BY ITA NO.294(ASR)/2010 3 THEM BEFORE REJECTING THE ACCOUNTS THE BURDEN OF D ISPROVING SUCH ESTIMATE LIES ON THE ASSESSEE [GANGA RAM BALMO KAND VS. CIT (1937) 5 ITR 464 (LDH); GHANSHYAMDAS PERMANAND VS. CIT (1952) 21 ITR 70 (NG.. III) WITH REFERENCE TO STATEMENT OF MR. KORDE, THE ASSESSEES SUBMISSIONS AND RELIANCE ON THE LD. CIT(A) ARE IN T OTAL CONTRAST TO THE TRADING RESULTS FURNISHED. IV) WITH REFERENCE TO THE CASE OF M/S. K.K. TANNERS P. LTD. FOR THE A.Y. 2006-07, IT IS SUBMITTED THAT THE ESTI MATE OF CONSUMPTION IN SAID CASE WAS MADE IN VIEW CONSIDERI NG THE FACTS OF THE SAID CASE WHEREIN THE ASSESSEE HAD FUR NISHED FALSE DATA IN RESPECT OF THE PURCHASE OF LEATHER AND CHEM ICALS AND THE SAME HAS BEEN ADMITTED BY THE SAID ASSESSEE DURING THE APPELLATE PROCEEDINGS. AS REGARDS THE CASE OF M/S. RAVI TANNERS, IT IS SUMITTED THAT THE LD. CIT(A) DID NOT CONSIDER TH CASE OF M/S. J.D. LEATHER P. LTD. FOR THE A.Y. 2006 -07 WHEREIN PERCENTAGE OF CHEMICAL CONSUMPTION/HIDE PROCESSED D ECLARED AT 19.93% AND THE SAME DOES FIND MENTION IN A CASE OF M/S. RAVI TANNERIES FOR THE A.Y. 2006-07. NEEDLESS TO SAY, ST IMATE OF CONSUMPTION OF CHEMICALS IN TWO CASES REFERRED TO B Y THE LD. CIT(A) WAS MADE CONSIDERING THE HIGH PERCENTAGE CLA IMED BY THE SAID ASSESSEE. HENCE, THE AO HAS RIGHTLY MADE THE TRADING ADDITION OF RS. 1 CRORE. 2. THAT, IT IS PRAYED THAT THE ORDER OF THE LD. CIT (A) BE SET-ASIDE THAT OF THE A.O. RESTORED. 3. THAT THE APPELLANT REQUESTS FOR LEAVE TO ADD OR AMEND OR ALTER THE GROUNDS OF APPEAL BEFORE THE APPEAL IS HEARD AN D DISPOSED OF. 3. THE BRIEF FACTS OF THE CASE AS ARISING FROM THE ORDER OF THE AO ARE THAT THE ASSESSEE DEALS IN TRADING OF FURNISHED LEATHER. THE ASSESSEE HAD DECLARED SALES OF RS.2,22,94,301/- WITH GROSS PROFIT OF RS.3 4,75,516/- AT G.P. RATE OF 15.59%. THE AO VIDE PARA 2(A) OF HIS ORDER ISSUED A NOTICE UNDER SECTION ITA NO.294(ASR)/2010 4 142(1) OF THE ACT, WHICH WAS REPLIED BACK BY THE AS SESSEE AS PER PARA 2(B) OF THE ORDER. IN PARA 2(C), THE AO REJECTED THE BOOKS OF ACCOUNT OF THE ASSESSEE BY OBSERVING THAT IN VIEW OF TOTALITY OF FACTS AND DEFICIENCIES, THE ACCOUNTS OF THE ASSESSEE ARE NOT CORRECT AND COMPLETE AND THER EFORE, THE SAME ARE HEREBY REJECTED. IN THIS CONNECTION, THE AO REFERRED TO J UDGMENTS OF VARIOUS COURTS OF LAW. IN PARA 2(D), THE AO BEFORE PROCEEDING TO E STIMATION OF INCOME REFERRED TO THE DECISIONS OF VARIOUS COURTS OF LAW AND THEREAFTER VIDE PARA 3 AND 3(A) OBSERVED AS UNDER BY MAKING AN ADDITION OF RS. 1 CRORE, WHICH FOR THE SAKE OF CLARITY IS REPRODUCED AS UNDER: 03. DURING THE PROCEEDINGS FOR A.Y.2006-07 IN THE CASE OF M/S. ARTISAN TANNER (P) LTD, JALANDHAR, SH. U.R. KORDE, MD ADMITTED VIDE NOTING SHEET DATED 17.12.2008 THAT CHEMICAL PURCHAS ED BY THE COMPANY ARE GIVEN TO M/S. ARTISAN TANNER FOR PROCES SING ITS RAW HIDE TO WET STAGE. THE CHEMICAL PURCHASED DURING THE YEA R BY THE COMPANY WAS AT RS.3,08,58,130/- (92588255 61730125). AS PER INFORMATION FURNISHING BY THE ASSESSE, THE R AW HIDES PROCESSED BY IT CAN BE VALUED AT RS.3300000/- AND THE CORRESP ONDING CHEMICAL CONSUMED CAN BE TAKEN AT RS.2000000/-. IN VIEW OF T HE ABOVE FACT, CLAIM OF CONSUMPTION OF CHEMICAL AT RS.13875603/- I S TOTALLY BASE LESS AND CANNOT BE ACCEPTED. THE GROSS PROFIT IN VI EW THE DATA GIVEN BY THE ASSESSEE IN RESPECT OF TRADING COMES TO NIL OR LOSS. 3(A) ASSESSEE, ,THEREFORE, IN THE GUIDES OF NON-MAI NTENANCE OF RECORD FOR CONSUMPTION IS EITHER MAKING BOGUS PURCHASES OF SUPPORTING ITS CLOSING STOCK OR IS UNDERTAKING JOB WORK, NOT BEING SHOWN IN THE BOOKS OF ACCOUNTS. CONSIDERING ALL THESE FACTORS, I T WILL BE REASONABLE TO MAKE AN ADDITION OF RS.1 CRORE TO THE RETURNED I NCOME. 4. BEFORE THE LD. CIT(A), THE ASSESSEE SUBMITTED TH E EXPLANATION WHICH WAS SENT FOR COMMENTS OF THE AO. AFTER RECEIVING TH E COMMENTS OF THE AO, ITA NO.294(ASR)/2010 5 THE LD. CIT(A) OBSERVED THAT THE AO HAD MADE THE AD DITION OF RS. 1 CRORE WHICH IS BASED ON ALLEGED STATEMENT WHICH IS NOT TH ERE AT ALL AND WHICH HAS BEEN CONTESTED RIGHT FROM THE BEGINNING BY THE PAR TY WHO IS ALLEGED TO HAVE MADE STATEMENT. THE ASSESSEE UNDOUBTEDLY DOES JOB WORK FOR ARTISAN TANNERS (P) LTD. FOR DOING THAT JOB WORK, THE ASSES SEE HAD RECEIVED CERTAIN CONSIDERATIONS AND INCURRED CERTAIN EXPENDITURE. PA RT OF THE EXPENDITURE IS ON ACCOUNT OF CHEMICALS. IT IS NOT THE CASE OF THE AO THAT THE CHEMICALS WERE NOT PURCHASED BY THE ASSESSEE SINCE NO PURCHASES HA VE BEEN SHOWN TO BE BOGUS. THE TOTAL PERCENTAGE OF CHEMICAL CONSUMPTION OF THE ASSESSEE FIRM AND THE COMPANY IS COMPABRALE TO THE CONSUMPTION IN SOME OTHER CASES AS ACCEPTED BY THE AO HIMSELF. NO DEFECT IN THE BOOKS OF ACCOUNT/BILLS HAS BEEN POINTED OUT BY THE AO. NO OTHER DEFECT HAS BEE N POINTED OUT BY THE AO. UNDER THE CIRCUMSTANCES, THE LD. CIT(A) DELETE D THE ADDITION AFTER MAKING VARIOUS OTHER OBSERVATIONS IN HIS ORDER. 5. THE LD. DR, MR. R.L. CHHANALIA, RELIED UPON THE ORDER OF THE ASSESSING OFFICER. 6. THE LD. COUNSEL FOR THE ASSESSEE, SH.SURINDER MA HAJAN,CA, RELIED UPON THE SUBMISSIONS MADE BEFORE THE LD. CIT(A) AND THE FINDINGS OF THE LD. CIT(A) AND ARGUED THAT THERE ARE NO DEFECTS POINTED OUT BY THE AO WHICH COULD LEAD TO REJECTION OF BOOKS OF ACCOUNT. AS REG ARDS THE ESTIMATION OF INCOME, NO BASIS FOR THE ESTIMATION OF INCOME HAS B EEN POINTED OUT BY THE ITA NO.294(ASR)/2010 6 A.O. THE CASES RELIED UPON BY THE AO ARE NOT RELEVA NT IN THE PRESENT FACTS AND CIRCUMSTANCES OF THE CASE. IT WAS ARGUED BY THE LD. COUNSEL FOR THE ASSESSEE, MR. SURINDER MAHAJAN THAT THE AO VISITED FACTORY PREMISES OF M/S. ARTISAN TANNERS AND ARTISAN TANNERS (P) LTD; ON 16. 12.2006 TO VERIFY MANUFACTURING BEING CARRIED OUT BY BOTH THE FIRMS. DURING VISIT OF THE A.O IT WAS EXPLAINED THAT RAW HIDES & SKINS OF ARTISAN TA NNERS (P) LTD. ARE BEING PROCESSED UP TO WET STAGE BY ARTISAN TANNERS AND C HEMICALS REQUIRED UPTO PICKLE PROCESS AND SOME WATTLED EXTRACT POWDER IS U SED BY ARTISAN TANNERS AND CHEMICALS FOR TANNING, DYING AND FAT LIQUORING ARE PROVIDED BY M/S. ARTISAN TANNERS (P) LTD. IT WAS SUBMITTED THAT SH. U.S. KORDE WAS ASKED TO ATTEND ASSESSMENT PROCEEDINGS ON 17.12.2008 WHEREIN HE WAS AGAIN ASKED ABOUT THE PROCESSING BEING DONE BY ARTISAN TANNERS AND HIS EXPLANATION WAS RECORDED IN THE ORDER SHEET DATED 17.12.2008. WHILE PUTTING HIS SIGNATURES TO THE ENTRY MADE IN THE ORDER SHEET, MR. KORDE OBJECT ED THAT NOTE OF THE FACT THAT CHEMICALS REQUIRED UP TO PICKLE PROCESS AND S OME WETTLED EXTRACT POWDER IS USED BY ARTISAN TANNERS HAVE NOT BEEN REC ORDED IN THE ORDER SHEET., ACCORDINGLY HE SIGNED ORDER SHEET BY PUTTIN G REMARKS THAT CHEMICALS UP TO PICKLE PROCESS AND SOME WETTLED EXTRACT POWDE R IS USED BY ARTISAN TANNERS. HE FURTHER SUBMITTED THAT DURING ASSESSMEN T PROCEEDINGS, THE ASSESSEE VIDE HIS LETTER EXPLAINED THAT FIRM HAS CA RRIED OUT PROCESSING OF ARTISAN TANNERS (P) LTD. WHEREIN CHEMICALS REQUIRED UPTO PICKLE PROCESS AND ITA NO.294(ASR)/2010 7 SOME WETTLED EXTRACT POWDER IS USED BY THE FIRM AND CHEMICALS REQUIRED FOR TANNING, DYING AND FAT LIQUORING ARE PROVIDED BY M/ S. ARTISAN TANNERS (P) LTD. THE LD. COUNSEL FURTHER SUBMITTED THAT MR. U. S.KORDE NOT ONLY MADE NOTE OF THE FACT THAT CHEMICALS REQUIRED UP TO PICK LE PROCESS AND SOME WETTLED EXTRACT POWDER IS USED BY ARTISAN TANNERS, ON THE ORDER SHEET OF ARTISAN TANNERS (P) LTD ALSO ON THE SAME DATE I.E. 17.12.2008, FILED LETTER WHEREIN ALONGWITH OTHER EXPLANATIONS EXPLAINED THAT CHEMICALS UPTO PICKLE PROCESS AND SOME WALTLED EXTRACT POWER FOR PROCESSI NG RAW HIDES & SKINS OF THE COMPANY ARE USED BY ARTISAN TANNERS. THE DETAIL S OF OPENING STOCK AND CLOSING STOCK WERE FILED DURING ASSESSMENT PROCEEDI NGS. THE AO WITHOUT INCORPORATING INFORMATION PROVIDED AND ALSO NOTE GI VEN IN THE ORDER SHEET PROCEEDED TO MAKE HIS OWN CALCULATIONS AND MADE ADD ITION OF RS. 1 CRORE WHICH IS ILLEGAL AND BAD IN LAW. IT IS NOT UNDERSTO OD AS TO WHY THE AO WITHOUT ANY MATERIAL ON RECORDS AND WITHOUT CONSIDE RING THE VARIOUS EXPLANATIONS FILED BY BOTH ARTISAN TANNERS & ARTISA N TANNERS (P) LTD; PROCEEDED TO MAKE ADDITION OF RS. 1 CRORE. THE LD. COUNSEL FURTHER SUBMITTED THAT EVEN FOR ARGUMENTS SAKE IF CALCULATI ONS MADE BY THE AO WHILE MAKING ADDITION OF RS. 1 CRORE ARE TAKEN AS C ORRECT, THOUGH THIS IS NOT BEING ADMITTED, GROSS PROFIT RATIO WILL BE AS UNDER : GROSS PROFIT DECLARED 3475516 ADDITION MADE 10000000 ITA NO.294(ASR)/2010 8 TOTAL ALLEGED GP : 13475516 SALES 22294301 G.P.% 60.44% THE ABOVE FIGURES SPEAKS OF ASSUMPTIONS MADE BY THE AO, GP% IN THIS TRADE FROM 8% TO 12%. THE LD. COUNSEL SUBMITTED THAT THE OBSERVATIONS OF THE AO IN PARA 3(A) OF THE ASSESSMENT ORDER ARE WITHOUT AN Y MATERIAL ON RECORD AND ARE BASED ON ASSUMPTION & PRESUMPTIONS SINCE HE HIM SELF IS SAYING THAT ASSESSEE IS EITHER MAKING BOGUS PURCHASES OR SUPPOR TING ITS CLOSING STOCK OR IS NOT UNDERTAKING JOB WORK OUTSIDE BOOKS OF ACCOUN TS. HE FURTHER SUBMITTED THAT DURING ASSESSMENT PROCEEDINGS, IT WAS EXPLAINE D THAT PROFITS OF ARTISAN TANNERS (P) LTD. ARE 100% EXEMPT U/S 10B OF THE ACT AND THERE WAS NO FUN OF PAYING PROCESSING CHARGES TO ARTISAN TANNERS WIT HOUT USE OF CHEMICALS SINCE INCOME OF THE FIRM ARTISAN TANNERS IS 100% TA XABLE. IN OTHER WORDS IT WAS EXPLAINED THAT NO PRUDENT BUSINESSMAN WILL SHIF T HIS NON TAXABLE INCOME TO TAXABLE INCOME OR WILL REDUCE HIS NON TAXABLE IN COME. HE ACCORDINGLY SUBMITTED THAT THE ADDITION OF RS.1,00,00,000/- MAD E BY THE AO IS WITHOUT ANY BASE AND WITHOUT ANY MATERIAL ON RECORDS. 6.1. MOREOVER, THE AO HAS NEVER CONFRONTED TO THE A SSESSEE WITH REGARD TO THE ADVERSE INFERENCE DRAWN AGAINST THE ASSESSEE. HE RELIED UPON VARIOUS DECISIONS OF COURTS OF LAW IN THIS REGARD. ITA NO.294(ASR)/2010 9 7. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE FACTS OF THE CASE. THERE IS NO DISPUTE TO THE FACT THAT THE AO AFTER G IVING SHOW CAUSE NOTICE FOR WHICH THE ASSESSEE HAD SUBMITTED THE EXPLANATION HA S STRAIGHTWAY COME TO THE CONCLUSION VIDE PARA 2(C) OF HIS ORDER THAT THE ACCOUNTS OF THE ASSESSEE ARE NOT CORRECT AND COMPLETE AND ACCORDINGLY REJEC TED THE SAME BY RELYING UPON THE DECISIONS OF VARIOUS COURTS OF LAW. ADVERS E INFERENCE HAS BEEN DRAWN BY THE AO WITHOUT BRINGING ANY MATERIAL ON RE CORD AND WITHOUT CONFRONTING THE SAME TO THE ASSESSEE. THEREFORE, T HE AO IS NOT JUSTIFIED IN REJECTING THE BOOKS OF ACCOUNT. MOREOVER, THE EXPLA NATIONS GIVEN BY THE ASSESSEE BEFORE THE LD. CIT(A) WERE SENT TO THE AO FOR COMMENTS WHICH HAS NOT BEEN APPRECIATED IN THE RIGHT SPIRIT BY THE AO. THE EXPLANATION GIVEN BY ASSESSEE BEFORE THE LD. CIT(A) IS FOUND TO BE SATIS FACTORY. THEREFORE, IN THE FACTS AND CIRCUMSTANCES OF THE CASE, WE FIND NO INF IRMITY IN THE ORDER OF THE LD. CIT(A) WHO HAS RIGHTLY REVERSED THE ORDER OF TH E AO WITH REGARD TO THE REJECTION OF BOOKS OF ACCOUNT BY THE A.O. 7.1 AS REGARDS THE ESTIMATION OF INCOME, THE EXPLAN ATION SUBMITTED BEFORE THE LD. CIT(A), WHICH HAS BEEN SENT FOR COMMENTS BE FORE THE AO WHO HAS NOT TAKEN THE SAME IN RIGHT SPIRIT, WHICH IN FACT IS THE SATISFACTORY EXPLANATION GIVEN BEFORE THE LD. CIT(A). THE AO WHI LE MAKING ESTIMATION HAS NOT BROUGHT ANY MATERIAL ON RECORD WITH REGARD TO THE ESTIMATION OF INCOME AND NO MATERIAL HAS BEEN CONFRONTED TO THE A SSESSEE WHILE ESTIMATING ITA NO.294(ASR)/2010 10 THE INCOME. THEREFORE, THE ESTIMATION MADE FOR THE ADDITION OF RS. 1 CRORE TO THE INCOME OF THE ASSESSEE IS WITHOUT ANY BASIS AND MATERIAL ON RECORD AND THEREFORE, THE ADDITION MADE BY THE AO BEING WITHOU T ANY BASIS, HAS RIGHTLY BEEN DELETED BY THE LD. CIT(A). NO DEFECT IN THE PU RCHASE AND SALES OR IN THE BOOKS OF ACCOUNT OR STOCK HAVE BEEN BROUGHT ON RECO RD BY THE AO. IN THE FACTS AND CIRCUMSTANCES OF THE CASE, THE LD. CIT(A ) HAS RIGHTLY REVERSED THE WHOLE ORDER OF THE A.O. THUS, ALL THE GROUNDS OF TH E REVENUE ARE DISMISSED. 8. IN THE RESULT, THE APPEAL FILED BY THE REVENUE I N ITA NO.294(ASR)/2010 IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 7TH SEPTEMBER, 2012. SD/- SD/- (H.S. SIDHU) (B.P. JAIN) JUDICIAL MEMBER ACCOUNTANT MEMBER DATED: 7TH SEPTEMBER, 2012 /SKR/ COPY OF THE ORDER FORWARDED TO: 1. THE ASSESSEE:ARTISAN TANNERS, JALANDHAR.S 2. THE DCIT RANGE-1, JALANDHAR. 3. THE CIT(A), JALANDHAR. 4. THE CIT, JALANDHAR. 5. THE SR DR, ITAT, AMRITSAR. TRUE COPY BY ORDER (ASSISTANT REGISTRAR) INCOME TAX APPELLATE TRIBUNAL, AMRITSAR BENCH: AMRITSAR.