PASL Windtech Pvt. Ltd., Ahmedabad V. The ACIT, Circle-5, Ahmedabad

ITA 2942/AHD/2013

• Counselvise Citation: [2017] 127 COUNSELVISE.COM (IT) 8455 (ITAT-AHMEDABAD)
• Duration Of Justice: 3 year(s) 9 month(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 12-09-2017
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: A
• Next Hearing Date: 17-08-2017
• Assessment Year: 2010-2011
• Appeal Filed On: 12-12-2013
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Assessee Lawyers: S N SOPARKAR WITH PARIN SHAH
• Section: 143(3); 2

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD A BENCH AHMEDABAD BEFORE, SHRI S. S. GODARA, JUDICIAL MEMBER AND SHRI AMARJIT SINGH, ACCOUNTANT MEMBER ITA NO. 2942/AHD/2013 (ASSESSMEN T YEAR: 2010-11) PASL WINDTECH PVT. LTD., 37-B, PHASE 1, GIDC ESTATE, VATVA, AHMEDABAD 382445 AP PELLANT VS. ACIT, CIRCLE-5, AHMEDABAD RESPONDENT & ITA NO. 248/AHD/2014 (ASSESSMENT YEAR: 2010-11) INCOME TAX OFFICER, WARD 5(2), AHMEDABAD APPELLANT VS. M/S. PASL WINDTECH PVT. LTD., 37-B, PHASE 1, GIDC ESTATE, VATVA, AHMEDABAD- 382445 RESPONDENT PAN: AABCA3022G /BY ASSESSEE : SHRI S. N. SOPARKAR WITH PARIN SHAH, A.R. /BY REVENUE : SHRI PRASOON KABRA, SR. D.R. /DATE OF HEARING : 08.09.2017 /DATE OF PRONOUNCEMENT : 12.09.2017 ITA NOS. 2942/AHD/13 & 248/AHD/14 (M/S. PASL WINDT ECH PVT. LTD.) A.Y. 2010-11 - 2 - ORDER PER S. S. GODARA, JUDICIAL MEMBER THE ASSESSEE AND REVENUE HAVE INSTITUTED THEIR INST ANT CROSS APPEALS FOR ASSESSMENT YEAR 2010-11 AGAINST THE CIT(A)-XI, AHMEDABADS ORDER DATED 25.11.2013 IN CASE NO. CIT(A)-XI/295/ACIT.CIR -5/12-13, IN PROCEEDINGS U/S. 143(3) OF THE INCOME TAX ACT, 1961 ; IN SHORT THE ACT. HEARD BOTH SIDES. CASE FILE(S) PERUSED. 2. A COMBINED PERUSAL OF BOTH THE PARTIES RESPECTI VE PLEADINGS INDICATE THAT THEIR IDENTICAL GRIEVANCE IN NUT SHELL REVOLVE S AROUND COMPUTING INCOME FROM HOUSE PROPERTY IN RESPECT OF ASSESSEES PROPER TIES A & B COMPRISING OF INDUSTRIAL SHED AT PLOT NO.37-B AND 5/1/B SITUATED IN PHASE-1, GIDC, INDUSTRIAL ESTATE, VATVA, AHMEDABAD. THE ASSESSEE HAD GIVEN IT TO ITS SISTER CONCERN M/S. PATEL ALLOY STEEL PVT. LTD. (PASPL) WI THOUT CHARGING ANY RENT IN EARLIER ASSESSMENT YEARS. THE ASSESSING OFFICER FRAMED A REGULAR ASSESSMENT ON 12.03.2013 COMPUTING NET ADDITION OF RS.34,59,456/- UNDER THE HEAD INCOME FROM HOUSE PROPERTY AT RS.49,42,080 /-. IT EMERGES THAT THE VERY ISSUE HAD ARISEN FOR THE FIRST TIME IN ASSESSM ENT YEAR 2005-06. THE ASSESSING OFFICER REFERRED TO THE SAID PROCEEDINGS IN ARRIVING AT THE IMPUGNED ADDITION AMOUNT AFTER A DETAILED DISCUSSION AFTER T AKING INTO ACCOUNT THIS TRIBUNALS DIRECTIONS IN ASSESSMENT YEAR 2005-06 IN VOLVING INTEREST RATE ADDITION @17.25%. 3. THE ASSESSEE PREFERRED APPEAL. WE NOTICE THAT T HE CIT(A) TAKES INTO ACCOUNT HIS FINDINGS IN THE ABOVESTATED FIRST ASSES SMENT YEAR 2005-06 ADOPTING 8.5% TO BE THE RATE OF RETURN QUA THE TWO PROPERTIES IN QUESTION STATED TO BE AT PAR WITH PREVAILING INTEREST RATES ON LONG TERM FIXED DEPOSITS. HE HOWEVER OBSERVES THAT THE IMPUGNED ASSESSMENT YE AR SHOW THE ABOVE ITA NOS. 2942/AHD/13 & 248/AHD/14 (M/S. PASL WINDT ECH PVT. LTD.) A.Y. 2010-11 - 3 - INTEREST RISING TO 10%. HE THEREFORE ADOPTS THE SA ID LATTER RATE TO ARRIVE AT THE IMPUGNED ADDITION AMOUNT OF RS.14,03,640/- ONLY. T HE ASSESSEE HAS BEEN GRANTED RELIEF TO THE TUNE OF RS.20,55,816/- IN THI S MANNER. 4. LEARNED COUNSEL REPRESENTING ASSESSEE SUMMARIZES ITS GRIEVANCE TO BE THREE FOLDED I.E. THE CIT(A) HAS ERRED IN CONFIRMIN G ASSESSING OFFICERS ACTION IN PRINCIPLE COMPUTING NOTIONAL INCOME ON IT S PROPERTIES LET OUT TO ITS SISTER CONCERN, ADOPTING 10% RATE AS RETURN OF INVE STMENT (SUPRA) AND IN NOT TAKING INTO CONSIDERATION COST OF THE PROPERTY IN Q UESTION AS ON 31.03.2010; RESPECTIVELY. THE REVENUE ON THE OTHER HAND PLEADS THAT THE CIT(A) OUGHT NOT TO HAVE DISTURBED ASSESSING OFFICERS COMPUTATI ON ARRIVING AT THE ABOVESTATED FIGURE OF RS.49,42,080/- AS WELL AS IN HOLDING RATE OF INTEREST ON INVESTMENT TO BE THE RELEVANT BENCHMARK FOR DETERMI NING THE NOTIONAL INCOME IN QUESTION. 5. WE HAVE HEARD RIVAL SUBMISSIONS IN TUNE WITH ABO VE NARRATED PLEADINGS. WE SOUGHT TO KNOW ABOUT STATUS OF IDENT ICAL PROCEEDINGS IN PRECEDING ASSESSMENT YEARS QUA THE INSTANT ISSUE. CASE FILE INDICATES THAT THIS TRIBUNAL IN A BATCH OF CASES ITA NOS. 2639/AHD/2013 AND FOUR OTHER APPEALS IN ASSESSMENT YEARS 2005-06 , 2007-08 TO 2009-10 DE CIDED ON 17.04.2015 HAS ALREADY DEALT WITH ALL THESE ARGUMENTS IN ARRIVING AT INTEREST RATE OF 8.5% TO FORM REASONABLE BASIS AS UNDER: 4. THE FACTS OF THE CASE ARE THAT THE ASSESSEE HAS GIVEN THE IMMOVABLE PROPERTY WHICH WAS THE INDUSTRIAL SHED TO THE SISTER CONCERN WITHOUT CHARGING ANY RENT. THE ASSESSING OFFICER, IN HIS ORDER U/S 143(3) DATED 31 .12.2007, ESTIMATED THE ANNUAL LETTING VALUE (ALV FOR SHORT) OF THE PROPERTY AND A SSESSED THE SAME AS INCOME FROM HOUSE PROPERTY. ON APPEAL, THE CIT(A) CONFIRME D THE ADDITION MADE BY THE ASSESSING OFFICER. THE ASSESSEE PREFERRED AN APPEAL BEFORE THE ITAT WHICH BY ORDER DATED 31.03.2011 IN ITA NO.1165/AHD/2009 SET ASIDE THE MATTER BACK TO THE FILE OF THE ASSESSING OFFICER, WITH THE FOLLOWING F INDINGS:- ITA NOS. 2942/AHD/13 & 248/AHD/14 (M/S. PASL WINDT ECH PVT. LTD.) A.Y. 2010-11 - 4 - '5. WE HAVE HEARD BOTH THE PARTIES AND PERUSED THE MATERIAL PLACED BEFORE US. IN THE CASE OF SAKARLAL BALABHAI (SUPRA), THE H ON'BLE JURISDICTIONAL HIGH COURT HELD AS UNDER:- '... IN THE ABSENCE OF BETTER WAY OF ESTIMATING REN T, THE RATE OF INTEREST ON COST OF BUILDING AND LAND MAY PROVIDE A REASONABLE BASIS FOR DETERMINING THE ANNUAL LETTING VALUE OF P ROPERTY MORE PARTICULARLY WHEN THE PROPERTY IS OCCUPIED BY THE O WNER. THE CAPITAL VALUE OF THE PROPERTY HAS RELEVANCE IN DETE RMINING ITS ANNUAL LETTING VALUE.' IN THIS CASE, THE AO ESTIMATED THE 'ALV' ON THE BAS IS OF SOME INFORMATION SAID TO HAVE BEEN COLLECTED BY HIM BEHIND BACK OF T HE ASSESSEE. ADMITTEDLY, THOSE DETAILS WERE NOT CONFRONTED TO THE ASSESSEE. NEITHER THE SAME IS PRODUCED BEFORE US. THEREFORE, THE SAME CANNOT BE R ELIED ON FOR ESTIMATING THE 'ALV'. IN THE ABOVE CIRCUMSTANCES, WE DEEM IT P ROPER TO SET ASIDE THE ORDER OF THE AUTHORITIES BELOW ON THIS POINT AND RE STORE THE MATTER BACK TO THE FILE OF THE AO. WE DIRECT HIM TO DETERMINE THE 'ALV' AS PER THE OBSERVATIONS OF THE HON'BLE JURISDICTIONAL HIGH COU RT I.E. BY APPLYING THE REASONABLE RATE OF INTEREST ON THE COST OF IMMOVABL E PROPERTY. NEEDLESS TO MENTION, HE WILL ALLOW ADEQUATE OPPORTUNITY OF BEIN G HEARD TO THE ASSESSEE WHILE ADJUDICATING THE MATTER. 5. THE ASSESSING OFFICER GAVE EFFECT TO THE ORDER O F ITAT VIDE HIS ORDER DATED 03.12.2012 PASSED U/S 143(3) R.W.S. 254 OF THE ACT, WHEREIN THE ASSESSING OFFICER ESTIMATED INCOME AT THE RATE OF 17.25% OF THE INVES TMENT IN THE PROPERTY BY THE ASSESSEE. ON APPEAL, THE CIT(A) VIDE HIS ORDER DATE D 11.09.2013 COMPUTED THE INCOME AT 8.5% OF THE COST OF THE PROPERTY AND ALLO WED PART RELIEF TO THE ASSESSEE. THE RELEVANT PORTION IN THE ORDER OF THE CIT(A) REA DS AS UNDER:- '2.2 I HAVE CAREFULLY CONSIDERED THE RIVAL CONTENTI ONS. I AM OF THE OPINION THAT THE STAND OF A.O. IN ADOPTING THE INTEREST AS IF THE APPELLANT IS BORROWING FUNDS EQUIVALENT TO THE INVESTMENT IS NOT REASONABLE. THE APPELLANT HAD ALREADY INVESTED IN THE PROPERTY AND WHAT IS TO BE WORKED OUT IS A REASONABLE RATE OF RETURN FROM SUCH INVESTMENT , IN ACCORDANCE WITH THE DIRECTIONS GIVEN BY HON'BLE ITAT. IN SUCH A SCENARI O THE REASONABLE RATE OF RETURN CAN BE EQUATED WITH THE PREVAILING INTEREST RATE ON THE LONG TERM FIXED DEPOSIT KEPT WITH THE BANKS/NBFCS. THE APPELL ANT HAS CONTENDED THAT THE RATE OF INTEREST WHICH COULD HAVE BEEN EARNED I N RESPECT OF THE BANK DEPOSIT WOULD BE 5.5 TO 7.75%. IN THIS REGARD THE D ECISION OF HON'BLE BOMBAY ITAT IN THE CASE OF SMT. INDIRA S. JAIN REPO RTED IN 52 SOT 270 IS RELEVANT WHEREIN THE HON'BLE BENCH HAS ADOPTED AND CONFIRMED THE RATE OF RETURN AT 8.5% ON THE COST OF THE PROPERTY. I THEREFORE DEEM IT FIT TO ADOPT THE RATE OF RETURN ON INVESTMENT IN THE PROPERTY AT 8.5% WHICH IS AT PAR WITH THE PREVA ILING INTEREST RATE ON THE LONG TERM FIXED DEPOSIT DURING THE RELEVANT PERIOD. THE ALV OF THE PROPERTY IS WORKED OUT AS UNDER:- ITA NOS. 2942/AHD/13 & 248/AHD/14 (M/S. PASL WINDT ECH PVT. LTD.) A.Y. 2010-11 - 5 - PROPERTY DETAIL (AS PER SUBMISSION DT. 14.03.2012 COST OF PROPERTY (IN RS.) ALV CALCULATED ASSUMING RATE OF INTEREST AT 8.5% (IN RS.) PROPERTY 'A' 74,22,612/- 6,30,922/- PROPERTY 'B' 1,26,29,388/- 10,73,498/- TOTAL 17,04,420/- ALV AS CALCULATED ABOVE : RS. 17,04 ,420/- LESS : 30% STANDARD DEDUCTION U/S 24 : RS. 5,11,3 26/- INCOME FROM HOUSE PROPERTY : RS.11,93,094/- ACCORDINGLY THE INCOME FROM HOUSE PROPERTY IS WORKE D OUT AT RS.11,93,094/- THE APPELLANT WILL GET A RELIEF OF RS.12,28,185/-. THIS GROUND OF APPEAL IS PARTLY ALLOWED.' 6. BOTH THE PARTIES, AGGRIEVED WITH THE ORDER OF TH E LD. CIT(A), ARE IN APPEAL BEFORE US. 7. WE HAVE HEARD BOTH THE SIDES AND PERUSED THE MAT ERIAL PLACED BEFORE US. AT THE TIME OF HEARING BEFORE US, THE LD. COUNSEL FOR THE ASSESSEE STATED THAT THE ASSESSING OFFICER HAS ESTIMATED THE INTEREST WHICH THE ASSESS EE WOULD HAVE BEEN REQUIRED TO PAY HAD HE BORROWED THE MONEY FOR THE PURPOSE OF IN VESTMENT IN THE PROPERTY. HE SUBMITTED THAT IN THE CASE OF THE ASSESSEE, INCOME FROM THE PROPERTY IS TO BE ESTIMATED AND NOT INTEREST EXPENDITURE ON ACQUISITI ON OF SUCH PROPERTY HAD BORROWED MONEY BEEN UTILIZED. THEREFORE, PROPER YAR DSTICK IS TO ESTIMATE THE PROPER RATE OF RETURN ON THE INVESTMENT OF SIMILAR AMOUNT IN ANY OTHER SECURED INVESTMENT. HE GAVE BEFORE US VARIOUS BANK CERTIFIC ATES FOR INVESTMENT IN FDRS AND POINTED OUT THAT INTEREST ON THE FDRS WAS VARYI NG FROM 5.5% TO 7.5%. HE, THEREFORE, SUBMITTED THAT THE AVERAGE RATE OF INTER EST ON THE FDRS WAS AROUND 6.5% AND THEREFORE, INCOME SHOULD BE ESTIMATED AT T HE RATE OF 6.5% ON THE COST OF THE PROPERTY LET OUT BY ASSESSEE TO SISTER CONCERN. 8. THE LD. DEPARTMENTAL REPRESENTATIVE, ON THE OTHE R HAND, RELIED UPON THE ORDER OF THE ASSESSING OFFICER AND HE STATED THAT THE ASS ESSING OFFICER WAS FULLY JUSTIFIED IN ESTIMATING THE INTEREST AT THE RATE OF 17.25% ON THE BASIS OF INTEREST WHICH WOULD HAVE BEEN REQUIRED TO BE PAID BY THE ASSESSEE HAD B ORROWED MONEY BEING UTILIZED. HE ALTERNATIVELY SUBMITTED THAT IF THE ASSESSEE'S C ONTENTION WITH REGARD TO RATE OF RETURN ON INVESTMENT IS ACCEPTED, THEN THE EXAMPLES IN THE INVESTMENT IN FDRS BY THE ASSESSEE SHOULD NOT BE ACCEPTED BECAUSE THOSE I NVESTMENTS ARE FOR A SHORT PERIOD; WHILE THE INVESTMENT IN THE PROPERTY IS FOR THE LONG PERIOD. HE ALSO SUBMITTED THAT THE RATE OF RETURN SHOULD BE CONSIDE RED ON THE BASIS OF MARKET VALUE OF THE PROPERTY IN EACH YEAR AND NOT SIMPLY ON THE BASIS OF COST OF THE PROPERTY. 9. WE HAVE CAREFULLY CONSIDERED THE ARGUMENTS OF BO TH THE SIDES AND PERUSED THE MATERIAL PLACED BEFORE US. WE FIND THAT THIS ISSUE IS SQUARELY COVERED BY THE DECISION OF THE HON'BLE JURISDICTIONAL HIGH COURT I N THE CASE OF SAKARLAL BALABHAI VS INCOME-TAX OFFICER, REPORTED IN 100 ITR 97. IN T HE FIRST ROUND OF APPEAL ALSO, ITA NOS. 2942/AHD/13 & 248/AHD/14 (M/S. PASL WINDT ECH PVT. LTD.) A.Y. 2010-11 - 6 - THE ITAT HAS SET ASIDE THE MATTER BACK TO THE FILE OF THE ASSESSING OFFICER FOR DETERMINING THE ALV AS PER THE ABOVE DECISION OF HO N'BLE JURISDICTIONAL HIGH COURT. IN THE ABOVE MENTIONED CASE, THEIR LORDSHIPS OF THE HON'BLE JURISDICTIONAL HIGH COURT HAVE CONSIDERED VARIOUS DECISIONS FROM O THER COURTS AND ALSO FROM BOOK RYDE ON RATING AND THEREAFTER, CONCLUDED AS UN DER AT PAGE NO.107:- '17. THOUGH THE ABOVE PASSAGES ARE MORE OR LESS IN THE CONTEXT OF ASCERTAINING RATEABLE VALUE OF PROPERTY, THEY NONE- THE-LESS ASSURE US THAT IN THE ABSENCE OF ANY BETTER WAY OF ESTIMATING RENT, T HE RATE OF INTEREST ON COST OF BUILDING AND LAND MAY PROVIDE A REASONABLE BASIS FOR DETERMINING THE ANNUAL LETTING VALUE OF PROPERTY, AND MORE PARTICUL ARLY, AS OBSERVED IN RYDE ON RATING, WHEN THE PROPERTY IS OCCUPIED BY TH E OWNER. IN OUR OPINION, THEREFORE, THE CONTENTION OF THE LEARNED A DVOCATE-GENERAL THAT CAPITAL VALUE OF PROPERTY MAY NOT HAVE A BEARING OR RELEVANCE ON THE QUESTION OF ANNUAL LETTING VALUE, SHOULD BE REJECTE D, AND MORE PARTICULARLY, WHEN, AS IN THE INSTANT CASE, THE ANNUAL LETTING VA LUE OF A SELF-OCCUPIED PROPERTY IS TO BE ASCERTAINED....' FROM THE ABOVE, IT IS EVIDENT THAT THEIR LORDSHIPS OF HON'BLE JURISDICTIONAL HIGH COURT HAVE COME TO THE CONCLUSION THAT RATE OF INTE REST ON COST OF THE BUILDING AND LAND WOULD PROVIDE A REASONABLE BASIS FOR DETERMINI NG THE ANNUAL LETTING VALUE OF PROPERTY. THEREFORE, THE CONTENTION OF THE LD. DR T HAT INSTEAD OF COST, MARKET VALUE OF THE PROPERTY IN EACH YEAR SHOULD BE ADOPTED CANN OT BE ACCEPTED. 10. NOW, WE COME TO THE QUESTION WHETHER RATE OF IN TEREST TO BE ADOPTED FOR DETERMINING THE ALV SHOULD BE INTEREST WHICH WOULD HAVE BEEN PAYABLE BY THE ASSESSEE HAD THE ASSESSEE BORROWED THE MONEY FOR IN VESTMENT IN THE PROPERTY OR IT SHOULD BE INTEREST RECEIVABLE BY THE ASSESSEE HAD T HE SIMILAR MONEY IS INVESTED SOMEWHERE ELSE. IN OUR OPINION, FOR DETERMINING THE INCOME FROM THE PROPERTY, IT SHOULD BE RATE OF RETURN ON THE INVESTMENT OF SIMIL AR AMOUNT IN ANOTHER ASSET. THEREFORE, IN OUR OPINION, THE CIT(A) WAS FULLY JUS TIFIED IN ESTIMATING THE ALV ON THE BASIS OF INTEREST WHICH ASSESSEE WOULD HAVE EAR NED ON THE INVESTMENT OF THE SIMILAR AMOUNT. THE LD. COUNSEL FOR THE ASSESSEE HA D ARGUED THAT THE RATE OF INTEREST APPLIED BY THE CIT(A) AT 8.5% IS EXCESSIVE . IN SUPPORT OF WHICH, HE GAVE VARIOUS EXAMPLES OF INVESTMENT IN FDRS WHICH FACED THE INTEREST RANGING FROM 5.52% TO 7.5%. COPIES OF THOSE CERTIFICATES FROM TH E BANK ARE PLACED AT PAGE NO. 29 ONWARDS OF THE ASSESSEE'S PAPER-BOOK. HOWEVER, W E FIND THAT THOSE INVESTMENTS WERE FOR A VERY SHORT PERIOD. IN FIRST CASE WHERE I NTEREST RATE WAS 5.5%, THE INVESTMENT WAS ONLY FOR 46 DAYS. IN ANOTHER CASE WH ERE THE INTEREST WAS 5.6%, IT WAS ONLY FOR 31 DAYS. IN ANOTHER CASE, WHERE THE RA TE OF INTEREST WAS 6%, IT WAS FOR 91 DAYS AND IN ANOTHER CASE WHERE THE PERIOD OF DEP OSIT WAS 366 DAYS, THE RATE OF INTEREST WAS 7.75%. THE LD. DR WAS FULLY JUSTIFIED THAT IF THE RATE OF RETURN ON THE INVESTMENT IS CONSIDERED, THEN IT SHOULD BE A LONG TERM INVESTMENT BECAUSE IN ANY PROPERTY NOBODY WOULD MAKE INVESTMENT JUST FOR FEW DAYS. CONSIDERING ALL THESE FACTS, IN OUR OPINION, THE CIT(A) HAS RIGHTLY APPLI ED THE RATE OF INTEREST OF 8.5%. WE, THEREFORE, DO NOT FIND ANY JUSTIFICATION TO INT ERFERE WITH THE ORDER OF THE CIT(A), THE SAME IS SUSTAINED; AND ON THIS POINT, T HE GROUND APPEAL OF REVENUE AS WELL AS ASSESSEE ARE REJECTED. ITA NOS. 2942/AHD/13 & 248/AHD/14 (M/S. PASL WINDT ECH PVT. LTD.) A.Y. 2010-11 - 7 - BOTH PARTIES FAIL TO INDICATE ANY DISTINCTION IN T HE TWO SETS OF FACTS INVOLVED IN SAID EARLIER AND IN THE IMPUGNED ASSESS MENT YEAR. WE THEREFORE UPHOLD CIT(A)S FINDINGS EXCEPT TO THE EXTENT THAT HE HAS ARRIVED AT INTEREST RATE @10% THAN THAT @8.5% IN EARLIER ASSESSMENT YEA RS. WE THEREFORE DIRECT THE ASSESSING OFFICER TO PASS CONSEQUENTIAL ORDER A CCORDINGLY ADOPTING 8.5% AS THE RATE OF RETURN IN VIEW OF LEARNED CO-ORDINAT E BENCH DETAILED DISCUSSION EXTRACTED HEREINABOVE. REST ALL OTHER SUBSTANTIVE GROUNDS STAND REJECTED IN BOTH THESE CROSS APPEALS. 6. THE ASSESSEES APPEAL ITA NO.2942/AHD/2013 IS PA RTLY ALLOWED WHEREAS REVENUES APPEAL ITA NO.248/AHD/2014 IS DIS MISSED. [PRONOUNCED IN THE OPEN COURT ON THIS THE 12 TH DAY OF SEPTEMBER, 2017.] SD/- SD/- ( AMARJIT SINGH ) ( S. S. GODARA) ACCOUNTANT MEMBER JUDICIAL M EMBER AHMEDABAD: DATED 12/09/2017 TRUE COPY S.K.SINHA / COPY OF ORDER FORWARDED TO:- / REVENUE 2 / ASSESSEE ! / CONCERNED CIT 4 !- / CIT (A) ( )* + ,--. . /0 / DR, ITAT, AHMEDABAD 1 + 23 4 5 / GUARD FILE. BY ORDER / . // . /0