The ITO, Ward-1(2), Surat V. M/s. Gulsan Prints Pvt. ltd., Dist.Surat

ITA 3439/AHD/2008

• Counselvise Citation: [2011] 140 COUNSELVISE.COM (IT) 50878 (ITAT-AHMEDABAD)
• Duration Of Justice: 3 year(s) 8 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 25-10-2011
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: D
• Next Hearing Date: 05-10-2011
• Assessment Year: 2005-2006
• Appeal Filed On: 17-10-2008
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: JAY RAJ KUMAR
• Keywords: Gross profit estimation; Rejection of books of accounts; Business income; Depreciation
• Section: 145

Judgement Text

-1- IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD BENCH 'D' [BEFORE SHRI T K SHARMA JUDICIAL MEMBER] [AND SHRI A K GARODIA, ACCOUNTANT MEMBER] ITA NO.3439/AHD/2008 (ASSESSMENT YEAR:-2005-06) THE INCOME-TAX OFFICER, WARD-1(2), ROOM NO.112, AAYAKAR BHAVAN, MAJURA GATE, SURAT V/S GULSHAN PRINTS PVT. LTD., 254-255/B, GIDC, PANDESARA, SURAT PAN: AAACG 8635 L [APPELLANT] [RESPONDENT] APPELLANT BY :- SHRI JAYRAJ KUMAR, SR. DR RESPONDENT BY:- SHRI HARDIK VORA, AR DATE OF HEARING:- 07-10-2011 DATE OF PRONOUNCEMENT:- 25-10-2011 O R D E R PER T K SHARMA [JM] : THIS IS AN APPEAL BY REVENUE AGAINST AN ORDER DATED 07-08-2008 PASSED BY LEARNED COMMISSION ER OF INCOME-TAX (APPEALS)-I, SURAT [THE CIT(A)] FOR AS SESSMENT YEAR (AY) 2005-06. THE ONLY EFFECTIVE GROUND RAISED BY T HE REVENUE READS AS UNDER:- [3] ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND IN LAW, THE LEARNED CIT(A)-I, SURAT HAS ERRED IN DELETING THE ADDITION MADE BY THE AO OF RS.5,77,400/- BEING 1% OF THE TOTAL PURCHASES MADE OF RAW MATERIALS FOR WANT OF QUANTITATIVE DETAILS OF STOCK AND DAY TO DAY MAINTENANCE OF CONSUMPTION RECORDS. 2 THE FACTS IN BRIEF ARE THAT ON PERUSAL OF SCHEDUL E-2 DETAILS OF CLOSING STOCK OF RAW MATERIALS IT WAS FOUND BY THE ASSESSING OFFICER [AO] THAT THE ASSESSEE HAS FURNISHED THE VALUE OF CLOSING STOCK AND NOT QUANTITY-WISE DETAILS. THE ASSESSEE WAS ASKED T O FURNISH MONTH- WISE OPENING STOCK, PURCHASE, CONSUMPTION AND CLOSI NG STOCK OF RAW MATERIALS IN TERMS OF QUANTITY AND VALUE. THE ASSES SEE SUBMITTED 2 IT A NO.3439/AHD/2008 THE ABOVE DETAILS AND STATED THAT THE STATEMENT OF VARIOUS RAW MATERIALS SHOWING QUANTITY AND VALUE OF PURCHASE WA S ENCLOSED. IT WAS ALSO SUBMITTED THAT AS PER THE ACCOUNTING POLIC Y ADOPTED BY THE ASSESSEE COMPANY PHYSICAL STOCK WAS TAKEN ON YEARLY BASIS AS COUNTING OF QUANTITY OF STOCK, LIKE COLOUR AND CHEM ICAL, LIGNITE, ETC. IS NOT PRACTICABLE IN THIS LINE OF BUSINESS. THE AO OB SERVED THAT IN THE ABSENCE OF DAY-TO-DAY QUANTITY DETAILS, THE CORRECT NESS OF PURCHASE VIS--VIS CONSUMPTION CANNOT BE VERIFIED. THE AO ST ATED THAT THERE WAS STEEP INCREASE IN CONSUMPTION OF FOLLOWING RAW MATERIALS:- PARTICULARS AY 2004-05 AY 2005-06 -------------------- --------------------- ------ ------------ TURNOVER RS.12.58 CRORE RS.11.59 CRORE COAL & LIGNITE 83,84,677 6.63% 89,19,965 7.70 % DIESEL 9,86,887 0.78% 13,09,267 1.13% STORES & SPARES 35,64,939 2.83% 41,00,606 3. 54% THE AO STATED THAT IN THE ABSENCE OF PROPER CHECK O VER OF THESE EXPENSES, 1% OF THESE EXPENSES ARE DISALLOWED. 3 ON APPEAL, THE LEARNED CIT(A) DELETED THE DISALLO WANCE IN THE FOLLOWING MANNER:- 2.2 DURING THE APPELLATE PROCEEDINGS, THE APPELLAN T ARGUED THAT THE DISALLOWANCE OF 1% OF PURCHASE IS ADHOC WITHOUT BRI NGING ANY MATERIAL ON RECORD. THE GROSS PROFIT DURING THE YEAR WAS HIGHER AS STATED BY THE AO HIMSELF IN PARA-3 OF THE ASSESSMENT ORDER. THE TURN OVER DURING THE YEAR IS RS.11.58 CRORE AND GROSS PROFIT OF RS.1.23 CRORE SH OWING G.P. @10.64%. THE TURNOVER IN THE LAST YEAR WAS RS.12.57 CRORE AN D G.P. RATE WAS ONLY 9.76%. THE APPELLANT HAS STATED THAT SINCE THE RESU LTS ARE BETTER THAN LAST YEAR, NO DISALLOWANCE CAN BE MADE WITHOUT BRINGING ANY MATERIAL ON RECORD THAT THE BOOKS OF ACCOUNT ARE NOT RELIABLE. THE APPELLANT FURTHER ARGUED THAT EVEN THE NET PROFIT AFTER DEPRECIATION WAS MORE THAN THE LAST YEAR. IN THE LAST YEAR, THE NET PROFIT WAS RS.9.01 LACS WHEREAS IN THE CURRENT YEAR IT IS RS.12.76 LACS. THE APPELLANT ARG UED THAT THE A.O. HAS MADE THE DISALLOWANCE WITHOUT APPLICATION OF MIND B ECAUSE THE A.O. HAS STATED THAT ALL THESE EXPENSES HAVE INCREASED COMPA RED TO LAST YEAR. THE APPELLANT HAS STATED THAT ALTHOUGH THE COAL LIGNITE , DIESEL, STORES & SPARES INCREASED SLIGHTLY AS STATED BY THE A.O. BUT COLOUR & CHEMICALS DECREASED 3 IT A NO.3439/AHD/2008 SUBSTANTIALLY. THE APPELLANT HAS STATED THAT THE CO MPARATIVE FIGURE IS AS UNDER:- AY 2004-05 AY 2005-06 TOTAL SALES 1257,74,217 11,58,76,730 COAL LIGNITE 83,34,677 6.63 89,19,865 7.70 DIESEL 9,86,887 0.78 13,09,267 1.13 STORES & SPARES 35,64,939 2.83 41,00,606 3.54 COLOUR & CHEMICALS 5,81,27,307 46.22 4,34,10,035 37.46 TOTAL PURCHASES 7,10,13,810 56.46 5,77,39,873 39.83 THE APPELLANT HAS STATED THAT THE TOTAL PURCHASES I N THE LAST YEAR WAS 56.46% WHEREAS IN THE CURRENT YEAR ONLY 49.83% AS S EEN FROM THE ABOVE CHART. IT IS ARGUED BY THE APPELLANT THAT THE A.O. DISREGARDED THE FACT THAT THE COLOUR & CHEMICALS WAS 46.22% IN LAST YEAR WHER EAS IT IS ONLY 37.46% IN THE CURRENT YEAR. 2.3 I HAVE CONSIDERED THE SUBMISSION OF THE APPELLA NT AND OBSERVATION MADE BY THE A.O. THE FACTS STATED FOR MAKING THE AD DITION ARE WRONG. ALTHOUGH THERE IS A SLIGHT INCREASE IN THE COAL, LI GNITE, DIESEL AND STORES & SPARES BUT AS IS CLEAR FROM THE ABOVE CHART, THERE IS A SUBSTANTIAL DECREASE IN COLOUR & CHEMICALS AND TOTAL PURCHASES IN THE CU RRENT YEAR. FURTHER, THE G.P. RATE DURING THE CURRENT YEAR IS HIGHER THAN TH E LAST YEAR AND THE N.P. RATE DURING THE CURRENT YEAR IS HIGHER THAN THE LAS T YEAR, HENCE THE DISALLOWANCE MADE BY THE A.O. CANNOT STAND. THE DIS ALLOWANCE IS, THEREFORE, DELETED AND THIS GROUND OF APPEAL IS ALL OWED. 4 AGGRIEVED WITH THE ORDER OF THE LEARNED CIT(A), T HE REVENUE IS IN APPEAL BEFORE US. ON BEHALF OF THE REVENUE, SHRI JAYRAJ KUMAR, LEARNED SENIOR DR APPEARED AND SUPPORTED THE ORDER OF THE AUTHORITIES BELOW. 5 ON THE OTHER HAND, ON BEHALF OF THE ASSESSEE, SHR I HARDIK VORA, LEARNED AR APPEARED AND SUPPORTED THE ORDER O F THE LEARNED CIT(A). THE LEARNED AR ALSO SUBMITTED THAT SIMILAR ISSUE HAS BEEN DECIDED BY THE ITAT AHMEDABAD BENCH-D IN FAVOUR OF THE ASSESSEE IN THE CASE OF ITO VS. M/S ASHISH DYEING & PRINTING MILLS PVT. LTD. [ ITA NO.2057/AHD/2010, ORDER DATED 01-04-2011]. 4 IT A NO.3439/AHD/2008 6 WE HAVE HEARD BOTH THE SIDES AND CAREFULLY GONE T HROUGH THE ORDERS OF THE AUTHORITIES BELOW. WE HAVE ALSO GONE THROUGH THE ORDER OF THE ITAT AHMEDABAD BENCH-D IN FAVOUR OF TH E ASSESSEE IN THE CASE OF ITO VS. M/S ASHISH DYEING & PRINTING MI LLS PVT. LTD. [ ITA NO.2057/AHD/2010, ORDER DATED 01-04-2011], WHEREIN THE TRIBUNAL HAS HELD AS UNDER:- 7. WE HAVE HEARD BOTH THE PARTIES AND GONE THROUGH THE FACTS OF THE CASE AS ALSO THE DECISIONS RELIED UPON. WE FIND FROM THE ASSESSMENT ORDER THAT THE AO DID NOT POINT OUT ANY SPECIFIC DEFECTS IN THE BOOKS OF ACCOUNT WHILE IGNORING THE BOOK RESULTS NOR BROUGHT ANY MATERIAL ON RECORD REGARDING THE GENUINENESS OF EXPENDITURE ON ACCOUNT OF COLOUR CHEMICALS, FREIGHT, ELECTRICITY, OCTROI AND GAS ETC .. THERE IS NO FINDING OR OPINION EITHER THAT THE RECORDS WERE INCORRECT AND INCOMPLETE OR THAT T HE METHOD APPLIED WAS SUCH THAT THE INCOME COULD NOT BE DEDUCED FROM THE ACCOUNTS MAINT AINED BY THE ASSESSEE. THE ID. CIT(A) FOUND THAT THE ASSESSEE HAS BEEN ABLE TO EXP LAIN THE FALL IN GP RATE DUE TO DECREASE IN JOB CHARGES RECEIVED AND INCREASE IN CO ST OF COLOUR AND CHEMICALS AS WELL AS OWING TO NON-RECEIPT OF ELECTRIC SUBSIDY IN THE YEA R UNDER CONSIDERATION. HON'BLE GAUHATI HIGH COURT IN ALUMINIUM INDUSTRIES (P) LTD. V. CIT (I.T.R. NO. 12 OF 1990) OBSERVED THAT A LOWER RATE OF GROSS PROFIT DECLARED BY THE ASSESSEE AS COMPARED TO THE PREVIOUS YEAR, WOULD NOT IN ITSELF BE SUFFICIENT TO JUSTIFY ANY AD DITION. THE MERE FACT THAT THE PERCENTAGE OF LOSS OR GROSS PROFIT IS HIGH OR LOW IN A PARTICULAR YEAR DOES NOT NECESSARILY LEAD TO INFERENCE THAT THERE HAS BEEN SUPPRESSION. LOW PROF IT IS NEITHER A CIRCUMSTANCE NOR MATERIAL TO JUSTIFY ADDITION OF PROFITS. THE RATIO OF THE JUDGMENTS IN DHAKESWARI COTTON MILLS LTD. V. CIT [1954] 26 ITR 775 (SC); RAGHUBIR MANDAL HARIHAR MANDAL V. STATE OF B IHAR [1957] 8 STC 770 (SC); STATE OF KERALA V. C. VELUKU TTY [1966] 60 ITR 239 (SC); STATE OF ORISSA V. MAHARAJA SHRI B.P. SINGH DEO [1970] 76 IT R 690 (SC); BRIJ BHUSAN LAL PARDUMAN KUMAR V. CIT [1978] 115 ITR 524 (SC); CHOU THMAL AGARWALLA V. CIT [1962] 46 ITR 262 (ASSAM); R.V.S. AND SONS DAIRY FARM V. CIT [2002] 257JTR 764 (MAD); INTERNATIONAL FOREST CO. V. CIT [1975] 101 ITR 721 (J & K) ; M. DURAI RAJ V. CIT [1972] 83 ITR 484 (KER); RAMCHANDRA RAMNIVAS V. STATE OF ORISSA [197 0] 25 STC 501 (ORISSA); ACTION ELECTRICALS V. DEPUTY CIT [2002] 258 ITR 188 (DELHI) AND KAMAL KUMAR SAHARIA V. CIT [1995] 216 ITR 217 (GAUHATI) INDICATE THAT THE AO IS NOT FETTERED BY A NY TECHNICAL RULES OF EVIDENCE AND PLEADINGS, AND HE IS ENTITLED TO ACT ON MATERIAL WHICH ARE NOT ACCEPTABLE IN EVIDENCE IN A COURT OF LAW, BUT WHILE MAKING THE ASSESSMENT UNDER THE PRINCIPLES OF BEST JUDGMENT, THE INCOME-TAX OFFICER IS NOT ENTITLED TO MAKE A PURE GUESS WITHOUT REFERENCE TO ANY EVIDENCE OR MATERIAL. THER E MUST BE SOMETHING MORE THAN A MERE SUSPICION 1O SUPPORT THE ASSESSMENT. LOW PROFI T IN A PARTICULAR YEAR IN ITSELF CANNOT BE A GROUND FOR INVOKING THE POWERS OF BEST JUDGMEN T ASSESSMENT WITHOUT SUPPORT OF ANY MATERIAL ON RECORD. THE HON'BLE GUJARAT HIGH COURT IN THE CASE OF CIT VIS. AMITBHAI GUNWANTBHAI, 129 ITR 573 HELD THAT IF THERE WAS NO CHALLENGE TO THE TRANSACTIONS REPRESENTED IN THE BOOKS THEN IT IS NOT OPEN TO REV ENUE TO CONTEND THAT WHAT IS SHOWN BY THE ENTRIES IS NOT THE REAL STATE OF AFFAIRS. SECON DLY, EVEN IF FOR SOME REASON, THE BOOKS ARE REJECTED IT IS NOT OPEN TO THE AO TO MAKE ANY A DDITION ON ESTIMATE BASIS OR ON PURE GUESS WORK. THE AO, WITHOUT RECORDING ANY FINDING T HAT THE BOOKS OF ACCOUNT MAINTAINED BY THE ASSESSEE WERE INCORRECT, RENDERING IT IMPOSS IBLE TO DEDUCE THE PROFITS, PROCEEDED TO REJECT THE BOOK RESULTS, INVOKING THE PROVISIONS OF SEC. 145 OF THE ACT. NO SPECIFIC DISCREPANCIES OR DEFECTS IN THE BOOKS OF ACCOUNT OF THE ASSESSEE HAVE BEEN POINTED OUT BEFORE US NOR WAS ANY MATERIAL BROUGHT TO OUR NOTIC E TO ESTABLISH THAT PURCHASES WERE INFLATED OR RECEIPTS SUPPRESSED. IN THESE CIRCUMSTA NCES , THERE WAS NO JUSTIFICATION IN INVOKING THE PROVISIONS OF SECTION 145 OF THE ACT [ VIKRAM PLASTICS,239 ITR 161(GUJ). SINCE THE AO HAS NOT MENTIONED ANY SPECIFIC DEFECTS FOR IGNORING THE BOOK RESULTS NOR ADDUCED ANY BASIS FOR INCREASING THE GP BY 1%, WE A RE OF THE OPINION THAT THE ID. CIT(A) WAS JUSTIFIED IN DELETING THE ADDITION. AS REGARDS DECISIONS RELIED UPON IN THE STATEMENT OF 5 IT A NO.3439/AHD/2008 FACTS, THESE WERE RENDERED ON THEIR OWN PECULIAR FA CTS AND THE ID. DR DID NOT DEMONSTRATE BEFORE US AS TO HOW THESE DECISIONS ARE APPLICABLE IN THE FACTS AND CIRCUMSTANCES OF THE CASE UNDER CONSIDERATION. RATHER, IN THE DECISION R ELIED UPON BY THE ID. AR IN DHARMESH SILK MILLS P. LTD.(SUPRA), THE ITAT DELETED THE ADD ITION UNDER SIMILAR CIRCUMSTANCES WHILE DISTINGUISHING THE DECISIONS RELIED UPON IN THE STA TEMENT OF FACTS. THE TRIBUNAL HELD IN THEIR ORDER DATED 21-08-2009 AS UNDER:- '7. WE LIVE HEARD THE RIVAL SUBMISSIONS. IT IS PERT INENT TO NOTE THAT THE ASSESSES IS ENGAGED IN THE DYEING AND PRINTING OF GREY CLOTH ON JOB WORK BASIS. IT IS THE OBSERVATION OF THE AUTHORITIES BELOW THAT THE ASSESSES HAS NO QUANTITATIVE RECORDS IN RESPECT OF DAY TO DAY CONSUMPTION OF COLOR AND C HEMICALS AND OTHER INPUTS, WHICH ARE THE MAJOR RAW MATERIALS FOR THE ASSESSEE. TO THIS THE ASSESSEE'S EXPLANATION IS THAT KEEPING QUANTITATIVE RECORDS OF COLOUR AND CHEMICALS IS VERY DIFFICULT TO KEEP AS THE ITEMS ARE IN LIQUID FORM A ND THEREFORE THE STOCK OF COLOURS AND CHEMICALS IS PHYSICALLY TAKEN ON 31 ST MARCH BY THE MANAGEMENT AND THE SAME IS VALUED AT COST. THERE IS NO DISPUTE OF THE FACT THAT THE ASSESSEE HAS MAINTAINED THE DETAILS OF PURCHASES OF COLOURS AND CHEMICALS AND STEAM COAL. NO DEFECT COULD BE POINTED OUT BY THE REVENUE IN THE S AID DETAILS. WHEN THE ASSESSEE HAS MAINTAINED THE DETAILS OF PURCHASES AN D ALSO THE PHYSICAL STOCK AS ON 31 ST MARCH VALUED AT COST, FROM WHICH NO DEFECT WAS FOU ND BY THE REVENUE, IN OUR CONSIDERED VIEW, NON-MAINTENANCE OF DAY TO DAY CONSUMPTION RECORD OF THE INPUTS CANNOT BE A GROUND FOR REJECTION OF BOOKS OF ACCOUNTS. THE DECISIONS RELIED ON BY THE LEARNED CIT(A) IN SUPPORT OF HIS ORDER CO NFIRMING REJECTION OF BOOKS OF ACCOUNTS ARE ON DISTINGUISHED FACTS. IN THE CASE OF KACHWALA GEMS V. JCIT (288 ITR 10), THE ASSESSEE HAD NOT MAINTAINED QUANTITATI VE DETAILS/STOCK REGISTER; THERE WAS NO EVIDENCE TO VERIFY CLOSING STOCK, THE GENUINENESS OF PURCHASES WAS NOT PROVED WITHOUT ANY DOUBT. BUT IN THE PRESENT CA SE AT HAND, THERE IS NO DISPUTE ABOUT THE PURCHASES OF COLOURS, CHEMICALS, STEAM CO ALS ETC. NO DEFECT HAS BEEN POINTED OUT BY THE AUTHORITIES BELOW IN SUCH DETAIL S OF PURCHASES. THE ASSESSEE HAS MAINTAINED CLOSING STOCK BY TAKING PHYSICAL STO CK OF THE YEAR. IN THE CASE OF ABDUL RAUHMAN & BROTHERS V. CIT (210 ITR 406) AND I N THE CASE OF HARI SHANKAR GOPAL HARI V. CIT (97 ITR 716) RELIED ON BY THE LEA RNED CIT(A), IT HAS BEEN OBSERVED THAT WHETHER THE PRESENCE OR THE ABSENCE O F A STOCK REGISTER IS MATERIAL OR NOT WOULD DEPEND UPON THE TYPE OF THE BUSINESS. IN THE INSTANT CASE THE ASSESSEES IS ENGAGED ON THE DYEING AND PRINTING OF GREY CLOTH ON JOB WORK BASIS. THE USE OF COLOUR AND CHEMICALS DEPENDS UPON THE DE SIGNS OF COLOUR TO BE PRINTED. IN CASE OF DARK COLOURS THE USE OF COLOUR AND CHEMICALS IS HIGHER AND THEREFORE, THE RATIO OF CONSUMPTION OF COLOUR AND C HEMICALS CANNOT BE D IN PROPORTION OF THE TURNOVER OF PROCESSED METERS OF C LOTH. CONSIDERING THE NATURE OF BUSINESS, THERE IS NO DENIAL OF THE FACT THAT IN SU CH TYPE OF BUSINESS IT IS VERY DIFFICULT TO MAINTAIN DAY TO DAY CONSUMPTION OF COL OURS, CHEMICALS AND STEAM COAL ETC. TRUE IT IS THAT DURING THIS YEAR THE ASSESSEE HAS SHOWN GP OF 4.49% DURING THE YEAR UNDER CONSIDERATION AGAINST GP OF 5.66% IN ASSESSMENT YEAR 2002-03 AND 5.35% IN THE ASSESSMENT YEAR 2003-04 AND THUS T HERE IS FALL IN THE GP IN TERMS OF PERCENTAGE BY 0.86% IN COMPARISON TO LAST YEAR. MERE LOW GP ALONE CANNOT BE A GROUND FOR REJECTION OF BOOKS OF ACCOUN TS. THEREFORE, CONSIDERING THE FACTS AND CIRCUMSTANCES OF THE CASE IN ENTIRETY, TH E REJECTION OF BOOKS OF ACCOUNTS AND MAKING ADDITION BY WAY OF ESTIMATION OF GP, IN OUR CONSIDERED VIEW, IS NOT PROPER. THE ADDITION OF RS.2,27,389 MADE ON THIS CO UNT IS DELETED.' 7.1 IF THERE IS NO CHALLENGE TO THE TRANSACTIONS RE PRESENTED IN THE BOOKS, THEN IT IS NOT OPEN TO REVENUE TO CONTEND THAT WHAT IS SHOWN BY TH E ENTRIES IS NOT THE REAL STATE OF AFFAIRS. IN VIEW OF THE FOREGOING, ESPECIALLY WHEN THE REVENUE HAVE NOT PLACED BEFORE US ANY MATERIAL CONTROVERTING THE AFORESAID FINDINGS O F THE ID. CIT(A). WE HAVE NO HESITATION IN UPHOLDING HIS FINDINGS. CONSEQUENTLY, GROUND NO. 1 IS DISMISSED. 6 IT A NO.3439/AHD/2008 IN VIEW OF ABOVE, FOLLOWING THE AFORESAID ORDER OF THE ITAT, WE DO NOT FIND ANY INFIRMITY IN THE ORDER OF THE LEARNED CIT(A) IN DELETING THE DISALLOWANCE. WE UPHOLD THE ORDER OF THE LEARNE D CIT(A). 7 IN THE RESULT, THE REVENUES APPEAL IS DISMISSED. ORDER PRONOUNCED IN THE COURT TODAY ON 25-10-2011 SD/- SD/- (A K GARODIA) ACCOUNTANT MEMBER (T K SHARMA) JUDICIAL MEMBER DATE : 25-10-2011 COPY OF THE ORDER FORWARDED TO: 1. GULSHAN PRINTS PVT. LTD., 254-255/B, GIDC, PANDE SARA, SURAT 2. THE INCOME-TAX OFFICER, WARD-1(2), ROOM NO.112, AAYAKAR BHAVAN, MAJURA GATE, SURAT 3. CIT CONCERNED 4. CIT(A)-I, SURAT 5. DR, ITAT, AHMEDABAD BENCH-D, AHMEDABAD 6. GUARD FILE BY ORDER DEPUTY REGISTRAR ASSISTANT REGISTRAR ITAT, AHMEDABAD