The Dy. Commr. Of Income Tax, Cir.-1(1), RAJKOT-GUJARAT V. M/s Tirth Agro Technology Pvt. Ltd., Shapar (Veraval)

ITA 324/RJT/2016

• Counselvise Citation: [2020] 111 COUNSELVISE.COM (IT) 0962 (ITAT-RAJKOT)
• Duration Of Justice: 3 year(s) 9 month(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 01-06-2020
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: 2013-2014
• Appeal Filed On: 01-09-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: M N MOURYA
• Assessee Lawyers: DM RINDANI
• Keywords: Corroborative evidences; TDS
• Section: 131

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL RAJKOT BENCH, RAJKOT BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER & SMT. MADHUMITA ROY, JUDICIAL MEMBER ./ I.T.A. NOS. 324/RJT/2016 & 151/RJT/2017 ( / ASSESSMENT YEARS : 2013-14 & 2014-15 ) DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1), RAJKOT ROOM NO.508, AAYAKAR BHAVAN, RACE COURSE RING ROAD, RAJKOT 360001 / VS. M/S TIRTH AGRO TECHNOLOGY PVT. LTD. PLOT NO.8, SURVEY NO.108/1, GONDAL ROAD, N.H. 8B, SHAPAR (VERAVAL) & M/S TIRTH AGRO TECHNOLOGY PVT. LTD. SURVEY NO.108/1, PLOT NO.B, NR. BHARUDI TOLL PLAZA, TAL: GONDAL, DIST: RAJKOT ./ ./ PAN/GIR NO. : AABCT6282F ( / APPELLANT ) .. ( / RESPONDENT ) / APPELLANT BY : SH RI M. N. MOURYA , CIT .D.R. / RESPONDENT BY : SHRI D. M. RINDANI, A.R. / DATE OF HEARING 28/02/2020 !'# / DATE OF PRONOUNCEMENT 01/06 /2020 $% /O R D E R ITA NO. 324/RJT/16 & 151/RJT/17 [DCIT VS. M/S. TIRT H AGRO TECHNOLOGY PVT. LTD.] A.Y. 2013-14 & 2014-15 - 2 - PER BENCH: THE CAPTIONED APPEAL HAS BEEN FILED AT THE INSTANCE OF THE REVENUE AGAINST THE ORDER OF THE COMMISSIONER OF IN COME TAX (APPEALS)-1, RAJKOT (CIT(A) IN SHORT) DATED 08/07/2 016 & 30.03.2017 RELEVANT TO ASSESSMENT YEARS (AY) 2013-1 4 & 2014-15. 2. THE ONLY ISSUE RAISED BY THE REVENUE IS THAT THE LEARNED CIT (A) ERRED IN DELETING THE ADDITION MADE BY THE AO FOR RS. 8,01,6 8,698/- ON ACCOUNT OF JOB CHARGES. 3. AT THE OUTSET WE NOTE THAT, THE ISSUE RAISED BY THE REVENUE IS IDENTICAL TO THE ISSUE RAISED IN ITA NO. 414/RJT/2015 WHICH HAS BEEN DECIDED IN FAVOR OF THE ASSESSEE BY US VIDE ORDER DATED 28-05-2020. TH E RELEVANT EXTRACT OF THE ORDER IS REPRODUCED AS UNDER: 10. WE HAVE HEARD THE RIVAL CONTENTIONS OF BOTH THE PARTIES AND PERUSED THE MATERIALS AVAILABLE ON RECORD BEFORE US. THE ISSUE I N THE PRESENT CASE RELATES TO THE DISALLOWANCE OF THE EXPENSES CLAIMED BY THE ASSESSEE UNDER THE HEAD JOB WORK CHARGES TO THE TUNE OF RS. 10,24,42,002/-. THE AO WA S OF THE VIEW THAT THE IMPUGNED EXPENSES ARE BOGUS OR FICTITIOUS IN NATURE AND THEREFORE THE SAME WAS DISALLOWED BY HIM. HOWEVER THE LEARNED CIT (A) WAS PLEASED TO DELETE THE ADDITION IN VIEW OF THE FACT THAT THE TRANSACTION WAS CARRIED OUT THROUGH BANKING CHANNEL, NECESSARY DOCUMENTARY EVIDENCES WERE FURNISHED SUBST ANTIATING GENUINENESS OF PARTIES AND TRANSACTION AND FURTHERMORE SIMILAR EXP ENSES WERE CLAIMED IN THE EARLIER YEARS WHICH WERE ACCEPTED BY THE REVENUE. FROM THE PRECEDING DISCUSSION, WE NOTE THAT THE ENT IRE BASIS OF MAKING THE DISALLOWANCE BY THE AO WAS THAT JOB WORKER HAS NOT SUFFICIENT EQUIPMENT AND MACHINERY TO PERFORM REQUIRED JOB, THEY ARE PROVIDIN G SERVICES FROM ASSESSEE PREMISES AND THERE WAS THE MISMATCH IN THE SIGNATUR E OF THE JOB WORKERS IN THE BANK OPENING FORM AND IN THE BILLS/INVOICES RAISED TO THE ASSESSEE. IN OUR CONSIDERED VIEW THE BASIS OF DISALLOWANCES BY THE AO ARE MERELY A SUSPICION AND NOT THE CONCLUSIVE EVIDENCES ESPECIALLY IN THE CIRC UMSTANCES WHERE THERE ARE MANY MORE DIRECT EVIDENCES AVAILABLE ON RECORD. SUCH EVID ENCES INCLUDE THE PAYMENT THROUGH BANKING CHANNEL AFTER THE DEDUCTION OF TDS, CO PIES OF THE INCOME TAX RETURNS, CONFIRMATION IN THE STATEMENT RECORDED UNDE R SECTION 131 OF THE ACT, REGISTRATIONS UNDER THE PROVIDENT FUND ACT OF THE LA BOUR CONTRACTORS. FURTHER THE ALLEGATION OF THE AO FOR MISMATCH IN THE SIGNATURE AS DISCUSSED ABOVE AND THE JOB WORKER WORKING FROM THE PREMISES OF THE A SSESSEE HAS BEEN SUFFICIENTLY ADDRESSED BY THE ASSESSEE. ACCORDINGLY, THE LEARNED CIT (A) HAS GIVEN VERY CLEAR FINDING OF ON THE ISSUES RAISED BY THE AO. SIMILARLY, THE JOB WORKERS IN THEIR STATEMENT RECORDED UNDER SECTION 131(1) HAVE CONFIRM ED THAT THEY PROVIDED ITA NO. 324/RJT/16 & 151/RJT/17 [DCIT VS. M/S. TIRT H AGRO TECHNOLOGY PVT. LTD.] A.Y. 2013-14 & 2014-15 - 3 - SERVICES OF JOB WORK, RECEIVED CHARGES BASED ON COMP ETITIVE MARKET RATE AND OFFERED THE SAME FOR THE TAXATION. THE LEARNED CIT (A) FURTHER GIVEN THE FINDING THAT THE THERE WAS NO EVIDENCE BROUGHT BY THE REVEN UE SUGGESTING THAT THE AMOUNT PAID TO THE JOB WORKER RETURNED TO THE ASSES SEE IN ANY MANNER. ON PERUSAL OF THE DETAILS OF THE JOB WORK EXPENSES IN CURRED BY THE ASSESSEE IN THE EARLIER YEARS, WE FIND THAT THE EXPENSES FOR THE YEA R UNDER CONSIDERATION TOWARDS THE JOB CHARGES IN RELATION TO THE SALES HAS REDUCE D SIGNIFICANTLY. THUS, IN OUR CONSIDERED VIEW THERE IS A DIRECT RELATION BETWEEN THE AMOUNT OF SALES VIZ A VIZ THE JOB WORK CHARGES INCURRED BY THE ASSESSEE, THEREFORE SUCH TURNOVER CANNOT BE ACHIEVED WITHOUT INCURRING THE JOB WORK EXPENSES. IT IS ALSO PERTINENT TO NOTE THAT, AT THE TIME OF HE ARING THE LEARNED DR HAS NOT BROUGHT ANYTHING ON RECORD CONTRARY TO THE FINDING O F THE LEARNED CIT (A). THUS THERE CANNOT BE ANY DISALLOWANCE OF THE JOB WORK EXP ENSES AS ALLEGED BY THE AO. IN HOLDING SO WE FIND SUPPORT AND GUIDANCE FROM THE J UDGEMENT OF HONBLE GUJARAT HIGH COURT IN THE CASE OF CIT VS. AVINASH M JHAWAR IN TAX APPEAL NUMBER 2299 OF 2009 WHEREIN IT WAS HELD AS UNDER: FROM THE ABOVE DISCUSSION, IT CAN BE CLEARLY SEEN THAT THE ENTIRE ISSUE HAS BEEN DECIDED BY THE TRIBUNAL ON THE BASIS OF EV IDENCE ON RECORD. THE ASSESSEE HAD MADE PAYMENTS FOR JOB WORK DONE THROUG H ACCOUNT PAYEE CHEQUES. THERE WERE OTHER CORROBORATIVE EVIDENCES T O PROVE SUCH EVIDENCE. THE ASSESSING OFFICER HAS COMMITTED ERROR IN DISALL OWING SUCH CLAIM. IN ADDITION TO HAVING MADE PAYMENTS THROUGH A/C. PAYEE CHEQUES, THE ASSESSEE HAD ALSO PRODUCED TDS CERTIFICATE IN SUPPORT OF ITS CLAIM. T HE ASSESSING OFFICER OBSERVING THAT SUCH CHEQUE PAYMENTS COULD HAVE BEEN WITHDRAWN AND REVERTED BACK TO THE ASSESSEE WERE NOT BASED ON EVIDENCE. WE FIND NO INFIRMITY IN THE ORDER OF THE TRIBUNAL. ACCORDINGLY, TAX APPEAL STANDS DISMISSED. IN VIEW OF THE ABOVE AND AFTER CONSIDERING THE FACTS I N TOTALITY, WE DO NOT FIND ANY INFIRMITY IN THE ORDER OF THE LEARNED CIT (A). HENCE, WE DECLINE TO INTERFERE IN THE ORDER OF THE LEARNED CIT-A. HENCE THE GROUND OF APPEA L OF THE REVENUE IS DISMISSED. 4. AT THE TIME OF HEARING BOTH THE LEARNED DR AND T HE LEARNED AR BEFORE US VEHEMENTLY SUBMITTED THAT THE ISSUE RAISED BY THE R EVENUE IS IDENTICAL TO THE ISSUE RAISED BY IT IN ITA NO. 414/RJT/2015 AND ACCO RDINGLY AGREED THAT THE OUTCOME OF THE SAME (ITA NO. 414/RJT/2015) SHALL BE APPLIED FOR THE YEAR UNDER CONSIDERATION MUTATIS MUTANDIS. RESPECTFULLY FOLLOWING THE SAME WE DO NOT FIND ANY REASON TO DEVIATE FROM THE SAID ORDER. HENCE THE GROUND OF APPEAL OF THE REVENUE IS DISMISSED. 5. IN THE RESULT, APPEAL FILED BY THE REVENUE IS DI SMISSED. ITA NO. 324/RJT/16 & 151/RJT/17 [DCIT VS. M/S. TIRT H AGRO TECHNOLOGY PVT. LTD.] A.Y. 2013-14 & 2014-15 - 4 - COMING TO ITA NO. 151/RJT/2017 A.Y. 2014-15 6. THE ONLY ISSUE RAISED BY THE REVENUE IS THAT THE LEARNED CIT (A) ERRED IN DELETING THE ADDITION MADE BY THE AO FOR RS. 2,77,7 1,150.00 ON ACCOUNT OF JOB CHARGES. 7. AT THE OUTSET WE NOTE THAT, THE ISSUE RAISED BY THE REVENUE IS IDENTICAL TO THE ISSUE RAISED IN ITA NO. 324/RJT/2016 WHICH HAS BEEN DECIDED IN FAVOR OF THE ASSESSEE BY US VIDE PARAGRAPH NO. 3 OF THIS ORD ER. FOR DETAIL DISCUSSION, PLEASE REFER THE RELEVANT PARAGRAPH. RESPECTFULLY F OLLOWING THE SAME WE DO NOT FIND ANY REASON TO DEVIATE FROM THE SAID ORDER. HEN CE THE GROUND OF APPEAL OF THE REVENUE IS DISMISSED. 8. BEFORE WE PART WITH THE ISSUE/APPEAL AS DISCUSSE D ABOVE, IT IS PERTINENT TO NOTE THAT THE CLAUSE OF RULE 34 OF THE APPELLA TE TRIBUNAL RULES 1963 REQUIRES THE BENCH TO MAKE ENDEAVOUR TO PRONOUNCE T HE ORDER WITHIN 60 DAYS FROM THE CONCLUSION OF THE HEARING. HOWEVER THE PER IOD OF 60 DAYS CAN BE EXTENDED UNDER EXCEPTIONAL CIRCUMSTANCES BUT THE SA ME SHOULD NOT ORDINARILY BE FURTHER EXTENDED BEYOND ANOTHER 30 DAYS. IN SIMP LE WORDS THE TOTAL TIME AVAILABLE TO THE BENCH IS OF 90 DAYS UPON THE CONCL USION OF THE HEARING. HOWEVER, DURING THE PREVAILING CIRCUMSTANCES WHERE THE ENTIRE WORLD IS FACING THE UNPRECEDENTED CHALLENGE OF COVID 2019 OUTBREAK, RESULTING THE LOCKDOWN IN THE COUNTRY, THE ORDERS THOUGH SUBSTANTIALLY PREPAR ED BUT COULD NOT BE PRONOUNCED FOR THE UNAVOIDABLE REASONS WITHIN THE M AXIMUM PERIOD OF 90 DAYS. IN SUCH CIRCUMSTANCES WE FIND THAT THE HONBLE MUMB AI TRIBUNAL IN THE CASE OF JSW LIMITED VS DEPUTY COMMISSIONER OF INCOME TAX IN ITA NO. 6103/MUM/2018 VIDE ORDER DATED 14-5-2020 EXTENDED THE TIME FOR PRONOUNCING THE ORDER WITHIN 90 DAYS OF TIME BY OBS ERVING AS UNDER: 9. LET US IN THIS LIGHT REVERT TO THE PREVAILING SI TUATION IN THE COUNTRY. ON 24TH MARCH, 2020, HONBLE PRIME MINISTER OF INDIA TOOK T HE BOLD STEP OF IMPOSING A NATIONWIDE LOCKDOWN, FOR 21 DAYS, TO PREVENT THE SP READ OF COVID 19 EPIDEMIC, AND THIS LOCKDOWN WAS EXTENDED FROM TIME TO TIME. AS A MATTER OF FACT, EVEN BEFORE THIS ITA NO. 324/RJT/16 & 151/RJT/17 [DCIT VS. M/S. TIRT H AGRO TECHNOLOGY PVT. LTD.] A.Y. 2013-14 & 2014-15 - 5 - FORMAL NATIONWIDE LOCKDOWN, THE FUNCTIONING OF THE INCOME TAX APPELLATE TRIBUNAL AT MUMBAI WAS SEVERELY RESTRICTED ON ACCOUNT OF LOC KDOWN BY THE MAHARASHTRA GOVERNMENT, AND ON ACCOUNT OF STRICT ENFORCEMENT OF HEALTH ADVISORIES WITH A VIEW OF CHECKING SPREAD OF COVID 19. THE EPIDEMIC SITUAT ION IN MUMBAI BEING GRAVE, THERE WAS NOT MUCH OF A RELAXATION IN SUBSEQUENT LO CKDOWNS ALSO. IN ANY CASE, THERE WAS UNPRECEDENTED DISRUPTION OF JUDICIAL WOK ALL OV ER THE COUNTRY. AS A MATTER OF FACT, IT HAS BEEN SUCH AN UNPRECEDENTED SITUATION, CAUSING DISRUPTION IN THE FUNCTIONING OF JUDICIAL MACHINERY, THAT HONBLE SUP REME COURT OF INDIA, IN AN UNPRECEDENTED ORDER IN THE HISTORY OF INDIA AND VID E ORDER DATED 6.5.2020 READ WITH ORDER DATED 23.3.2020, EXTENDED THE LIMITATION TO E XCLUDE NOT ONLY THIS LOCKDOWN PERIOD BUT ALSO A FEW MORE DAYS PRIOR TO, AND AFTER , THE LOCKDOWN BY OBSERVING THAT IN CASE THE LIMITATION HAS EXPIRED AFTER 15.03.2020 THEN THE PERIOD FROM 15.03.2020 TILL THE DATE ON WHICH THE LOCKDOWN IS L IFTED IN THE JURISDICTIONAL AREA WHERE THE DISPUTE LIES OR WHERE THE CAUSE OF ACTION ARISES SHALL BE EXTENDED FOR A PERIOD OF 15 DAYS AFTER THE LIFTING OF LOCKDOWN . HONBLE BOMBAY HIGH COURT, IN AN ORDER DATED 15TH APRIL 2020, HAS, BESIDES EXTEND ING THE VALIDITY OF ALL INTERIM ORDERS, HAS ALSO OBSERVED THAT, IT IS ALSO CLARIFIED THAT WHILE CALCULATING TIME FO R DISPOSAL OF MATTERS MADE TIME-BOUND BY THIS COURT, THE PERIOD FOR WHICH THE ORDER DATED 26TH MARCH 2020 CONTINUES TO OPERATE SHALL BE ADDED AND TIME SHALL STAND EXTENDED ACCORDINGLY , AND ALSO OBSERVED THAT ARRANGEMENT CONTINUED BY AN ORDER DATED 26TH MARCH 2020 TILL 30TH APRIL 2020 SH ALL CONTINUE FURTHER TILL 15TH JUNE 2020 . IT HAS BEEN AN UNPRECEDENTED SITUATION NOT ONLY IN INDIA BUT ALL OVER THE WORLD. GOVERNMENT OF INDIA HAS, VIDE NOTIFICATI ON DATED 19 TH FEBRUARY 2020, TAKEN THE STAND THAT, THE CORONAVIRUS SHOULD BE CO NSIDERED A CASE OF NATURAL CALAMITY AND FMC (I.E. FORCE MAJEURE CLAUSE) MAYBE INVOKED, WHEREVER CONSIDERED APPROPRIATE, FOLLOWING THE DUE PROCEDURE. THE TER M FORCE MAJEURE HAS BEEN DEFINED IN BLACKS LAW DICTIONARY, AS AN EVENT OR EFFECT THAT CAN BE NEITHER ANTICIPATED NOR CONTROLLED WHEN SUCH IS THE POSITION, AND IT IS OFFICIALLY S O NOTIFIED BY THE GOVERNMENT OF INDIA AND THE COVID-19 EPIDEMI C HAS BEEN NOTIFIED AS A DISASTER UNDER THE NATIONAL DISASTER MANAGEMENT ACT , 2005, AND ALSO IN THE LIGHT OF THE DISCUSSIONS ABOVE, THE PERIOD DURING WHICH LOCK DOWN WAS IN FORCE CAN BE ANYTHING BUT AN ORDINARY PERIOD. 10. IN THE LIGHT OF THE ABOVE DISCUSSIONS, WE ARE O F THE CONSIDERED VIEW THAT RATHER THAN TAKING A PEDANTIC VIEW OF THE RULE REQUIRING P RONOUNCEMENT OF ORDERS WITHIN 90 DAYS, DISREGARDING THE IMPORTANT FACT THAT THE ENTI RE COUNTRY WAS IN LOCKDOWN, WE SHOULD COMPUTE THE PERIOD OF 90 DAYS BY EXCLUDING A T LEAST THE PERIOD DURING WHICH THE LOCKDOWN WAS IN FORCE. WE MUST FACTOR GROUND RE ALITIES IN MIND WHILE INTERPRETING THE TIME LIMIT FOR THE PRONOUNCEMENT O F THE ORDER. LAW IS NOT BROODING OMNIPOTENCE IN THE SKY. IT IS A PRAGMATIC TOOL OF T HE SOCIAL ORDER. THE TENETS OF LAW BEING ENACTED ON THE BASIS OF PRAGMATISM, AND THAT IS HOW THE LAW IS REQUIRED TO INTERPRETED. THE INTERPRETATION SO ASSIGNED BY US I S NOT ONLY IN CONSONANCE WITH THE LETTER AND SPIRIT OF RULE 34(5) BUT IS ALSO A PRAGM ATIC APPROACH AT A TIME WHEN A DISASTER, NOTIFIED UNDER THE DISASTER MANAGEMENT AC T 2005, IS CAUSING UNPRECEDENTED DISRUPTION IN THE FUNCTIONING OF OUR JUSTICE DELIVERY SYSTEM. UNDOUBTEDLY, IN THE CASE OF OTTERS CLUB VS DIT [(2017) 392 ITR 244 (BOM)] , HONBLE BOMBAY HIGH COURT DID NOT APPROVE AN ORDER BEING PASSED BY THE TRIBUNAL BEYOND A PERIOD OF 90 DAYS, BUT THEN IN THE PRESENT SITUATION HONBLE BOMBAY HIGH COURT ITSELF HAS, VIDE JUDGMENT DATED 15 TH APRIL 2020, HELD THAT DIRECTED WHILE CALCULATING THE TIME FOR DISPOSAL OF MATTERS MADE T IME-BOUND BY THIS COURT, THE PERIOD FOR WHICH THE ORDER DATED 26TH MARCH 2020 CO NTINUES TO OPERATE SHALL BE ADDED AND TIME SHALL STAND EXTENDED ACCORDINGLY . THE EXTRAORDINARY STEPS TAKEN SUO MOTU BY HONBLE JURISDICTIONAL HIGH COURT AND H ONBLE SUPREME COURT ALSO ITA NO. 324/RJT/16 & 151/RJT/17 [DCIT VS. M/S. TIRT H AGRO TECHNOLOGY PVT. LTD.] A.Y. 2013-14 & 2014-15 - 6 - INDICATE THAT THIS PERIOD OF LOCKDOWN CANNOT BE TRE ATED AS AN ORDINARY PERIOD DURING WHICH THE NORMAL TIME LIMITS ARE TO REMAIN I N FORCE. IN OUR CONSIDERED VIEW, EVEN WITHOUT THE WORDS ORDINARILY, IN THE LIGHT O F THE ABOVE ANALYSIS OF THE LEGAL POSITION, THE PERIOD DURING WHICH LOCKOUT WAS IN FO RCE IS TO EXCLUDED FOR THE PURPOSE OF TIME LIMITS SET OUT IN RULE 34(5) OF THE APPELLA TE TRIBUNAL RULES, 1963. VIEWED THUS, THE EXCEPTION, TO 90-DAY TIME-LIMIT FOR PRONO UNCEMENT OF ORDERS, INHERENT IN RULE 34(5)(C), WITH RESPECT TO THE PRONOUNCEMENT OF ORDERS WITHIN NINETY DAYS, CLEARLY COMES INTO PLAY IN THE PRESENT CASE. OF COU RSE, THERE IS NO, AND THERE CANNOT BE ANY, BAR ON THE DISCRETION OF THE BENCHES TO REF IX THE MATTERS FOR CLARIFICATIONS BECAUSE OF CONSIDERABLE TIME LAG BETWEEN THE POINT OF TIME WHEN THE HEARING IS CONCLUDED AND THE POINT OF TIME WHEN THE ORDER THER EON IS BEING FINALIZED, BUT THEN, IN OUR CONSIDERED VIEW, NO SUCH EXERCISE WAS REQUIR ED TO BE CARRIED OUT ON THE FACTS OF THIS CASE. 11. TO SUM UP, THE APPEAL OF THE ASSESSEE IS ALLOWE D, AND APPEAL OF THE ASSESSING OFFICER IS DISMISSED. ORDER PRONOUNCED UNDER RULE 3 4(4) OF THE INCOME TAX (APPELLATE TRIBUNAL) RULES, 1962, BY PLACING THE DE TAILS ON THE NOTICE BOARD. CONSIDERING THE ABOVE, WE EXPRESS TO PRONOUNCE THE ORDER BEYOND THE PERIOD OF 90 DAYS. ACCORDINGLY, WE PROCEED TO PRONOUNCE TH E ORDER AS ON DATE. 9. IN THE RESULT, APPEAL FILED BY THE REVENUE IS DI SMISSED. 10. IN THE COMBINED RESULT, BOTH APPEALS FILED BY T HE REVENUE ARE DISMISSED. SD/- SD/- (MADHUMITA ROY) (WASEEM AH MED) JUDICIAL MEMBER ACCOUNTANT MEMBER AHMEDABAD: DATED 01/06/2020 TRUE COPY S. K. SINHA / COPY OF ORDER FORWARDED TO:- 1. / REVENUE 2. $ / ASSESSEE 3. ) *+ , / CONCERNED CIT 4. ,- / CIT (A) 5. 012 33*+, *+#, 56$)$ / DR, ITAT, AHMEDABAD 6. 289 : / GUARD FILE. BY ORDER DEPUTY/ASSTT.REGISTRAR ITAT, RAJKOT THIS ORDER PRONOUNCED IN OPEN COURT 01/06/2020