Nutan Nagrik Sahkari Bank Ltd, Ahmedabad V. The Dy.CIT, Cir-10, Ahmedabad

ITA 3468/AHD/2016

• Counselvise Citation: [2020] 110 COUNSELVISE.COM (IT) 5645 (ITAT-AHMEDABAD)
• Duration Of Justice: 3 year(s) 9 month(s) 9 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 01-10-2020
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: D
• Next Hearing Date: 31-01-2020
• Assessment Year: 2010-2011
• Appeal Filed On: 22-12-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Assessee Lawyers: S N SOPARKAR
• Keywords: Depreciation; Bad and doubtful debts; Capital expenditure

Judgement Text

, A IN THE INCOME TAX APPELLATE TRIBUNAL A BENCH, AHMEDABAD ( CONVENED THROUGH VIRTUAL COURT ) BEFORE HONBLE MR. JUSTICE P. P. BHATT, PRESIDENT & SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER ./ I.T.A. NOS. 3468 & 3469/AHD/2016 & 960/AHD/2018 ( ASSESSMENT YEARS : 2010-11, 2012-13 & 2014- 15) NUTAN NAGRIK SAHAKARI BANK LIMITED OPP. SAMRATHESWAR MAHADEV, NR. LAW GARDEN, ELLIS BRIDGE, AHMEDABAD & 2ND FLOOR, MARADIA PLAZA BUILDING, C. G. ROAD, NEAR ASSOCIATED PETROL PUMP, AHMEDABAD / VS. DCIT CIRCLE-10, AHMEDABAD & ACIT CIRCLE-5(2), AHMEDABAD ./ ./ PAN/GIR NO. : AAALN0005C ( APPELLANT ) .. ( / RESPONDENT ) / APPELLANT BY : SHRI S. N. SOPARKAR, A.R. / RESPONDENT BY : SHRI DILEEP KUMAR, SR. DR DATE OF HEARING 23/09/2020 !'# / DATE OF PRONOUNCEMENT 01/10/2020 / O R D E R ITA NOS. 3468 & 3469/AHD/2016 & 960/AHD/18 [NUTAN NAGRIK SAHAKARI BANK LTD.] - 2 - PER PRADIP KUMAR KEDIA - AM: THE CAPTIONED BUNCH OF APPEALS HAVE BEEN FILED AT T HE INSTANCE OF THE ASSESSEE AGAINST THE ORDERS OF THE COMMISSIO NER OF INCOME TAX (APPEALS), AHMEDABAD-5 (CIT(A) IN SHORT), DAT ED 04.10.2016, 05.10.2016 & 13.12.2017 RESPECTIVELY ARISING IN THE ASSESSMENT ORDER DATED 20.03.2013, 31.12.2014 & 21.12.2016 RES PECTIVELY, PASSED BY THE ASSESSING OFFICER (AO) UNDER S. 143(3 ) OF THE INCOME TAX ACT, 1961 (THE ACT) CONCERNING AY 2010-11, 2012 -13 & 2014- 15. 2. THE ISSUES INVOLVED BEING COMMON, ALL THE CAPTIO NED APPEALS OF THE ASSESSEE HAVE BEEN HEARD TOGETHER AND ARE BE ING DISPOSED OF BY COMMON ORDER. ITA NO. 3468/AHD/2016 (A.Y. 2010-11) 3. THE GROUNDS OF APPEAL RAISED BY ASSESSEE READ HE REUNDER: 1.1 THAT THE LD. CIT (A) HAS ERRED IN CONFIRMING T HE DISALLOWANCE OF RS.48,34,350 BEING CLAIM OF BAD DEBTS WRITTEN OFF T O BAD AND DOUBTFUL DEBT RESERVE ACCOUNT. 1.2 THAT THE VARIOUS REASONS ADVANCED BY THE LEAR NED CIT(APPEAL) IN CONFIRMING THE DISALLOWANCE ARE CONTRARY TO THE FAC T OF THE CASE AND EVIDENCE ON RECORD. 1.3 THE APPELLANT RESPECTFULLY SUBMITS THAT AS P ER SECTION 36(2) OF THE ACT, BAD DEBTS OF RS.48,34,350 SHOULD BE ALLOWED. 2.1 THAT THE LD. CIT (A) HAS ERRED IN NOT GRANTI NG RELIEF IN RESPECT OF CLAIM OF RS.13,25,272. 2.2 THE APPELLANT RESPECTFULLY SUBMITS THAT THE TO TAL DISALLOWANCE OF DEPRECIATION OF RS.2,20,00,663 INCLUDES RS. 13,85,2 72. THEREFORE NO SEPARATE ADDITION CAN BE MADE FOR RS. 13,85,272. TH IS WAS REQUESTED THE ASSESSING OFFICER FOR WHICH NO FINDING HAS BEEN GIVEN. 4. WHEN THE MATTER WAS CALLED FOR HEARING BY THE TRIBUNAL, THE LEARNED SENIOR COUNSEL FOR THE ASSESSE AT THE OUTSE T SUBMITTED THAT GROUND NO.1 CONCERNS CONTROVERSY FOR ALLOWABILITY O F BAD DEBTS ITA NOS. 3468 & 3469/AHD/2016 & 960/AHD/18 [NUTAN NAGRIK SAHAKARI BANK LTD.] - 3 - AMOUNTING TO RS.48,34,350/- ACTUALLY WRITTEN OFF UN DER S.36(1)(VII) OF THE ACT IN THE BOOKS OF ACCOUNT SIMULTANEOUSLY A ND PARALLELY WITH THE DEDUCTION TOWARDS PROVISION FOR BAD DEBT UNDER S.36(1)(VIIA) OF THE ACT AT SPECIFIED PERCENTAGE AMOUNTING TO RS.28, 42,274/-. TO BEGIN WITH, IT WAS SUBMITTED THAT THE REVENUE HAS C ONTROVERTED THE BAD DEBT CLAIM OF THE ASSESSEE ON THE GROUND THAT A SSESSEE IS NOT ENTITLED IN LAW TO CLAIM DEDUCTION BOTH UNDER S.36( 1)(VII) & SECTION 36(1)(VIIA) OF THE ACT SIMULTANEOUSLY. 4.1 IN THIS REGARD, IT WAS SUBMITTED THAT THE ASSES SEE IS A MULTISTATE CO-OPERATIVE SCHEDULED BANK CARRYING ON BANKING BUSINESS SINCE LAST SEVERAL YEARS AND THUS IS ENTIT LED TO DEDUCTION ON ACCOUNT OF PROVISIONS FOR BAD DEBTS UNDER S.36(1)(V IIA) R.W.S. 36(2) OF THE ACT IN THE LIGHT OF PROVISIONS OF SECTION 36 (1)(VIIA) OF THE ACT AS AMENDED W.E.F. A.Y. 2007-08. IN ELABORATION, IT WAS SUBMITTED THAT THE DEDUCTION UNDER S.36(1)(VIIA) HAS BEEN MAD E AVAILABLE TO CO-OPERATIVE BANK W.E.F. AY 2007-08 ONWARDS. THE A SSESSEE HAS ACCORDINGLY CLAIMED DEDUCTION TOWARDS PROVISIONS MA DE IN TERMS OF SECTION 36(1)(VIIA) OF THE ACT AMOUNTING TO RS.28,4 2,274/-. THE ASSESSEE HAS SIMULTANEOUSLY ALSO CLAIMED BAD DEBTS ACTUALLY WRITTEN OFF AMOUNTING TO RS.48,34,350/- UNDER S.36(1)(VII) OF THE ACT IN RELATION TO OUTSTANDING DEBTS OF THE EARLIER YEARS FOR WHICH THE PROVISIONING HAS NOT BEEN MADE OR CLAIMED SINCE THE ENTITLEMENT OF DEDUCTION FOR PROVISIONING OF BAD DEBT UNDER S.36(1 )(VIIA) OF THE ACT HAS BEEN MADE AVAILABLE TO CO-OPERATIVE BANKS B EGINNING WITH AY 2007-08 ONLY. 4.2 FOR ENTITLEMENT OF DUAL CLAIM, ONE UNDER S.36(1 )(VII) OF THE ACT FOR ACTUAL WRITE OFF DEBTS AND OTHER FOR PROVIS IONING OF BAD DEBT UNDER S.36(1)(VIIA) OF THE ACT, THE LEARNED SENIOR COUNSEL FOR THE ASSESSEE REFERRED TO THE DECISION OF THE HONBLE SU PREME COURT IN ITA NOS. 3468 & 3469/AHD/2016 & 960/AHD/18 [NUTAN NAGRIK SAHAKARI BANK LTD.] - 4 - CATHOLIC SYRIAN BANK LTD. VS. CIT(A) (2012) 343 ITR 270 (SC) WHEREIN AS PER ITS HEAD NOTE, IT HAS BEEN ESSENTIAL LY OBSERVED BY THE HONBLE SUPREME COURT THAT PROVISIONS OF SECTION 36 (1)(VII) & 36(1)(VIIA) OF THE ACT ARE DISTINCT AND INDEPENDENT ITEMS OF DEDUCTION AND OPERATE IN THEIR RESPECTIVE FIELDS. THE LEARNED SENIOR COUNSEL SUBMITTED THAT THE IMPACT OF THE DECISION O F HONBLE SUPREME COURT REFERRED ABOVE WOULD BE THAT THE ALLO WANCE TOWARDS BAD DEBT ACTUALLY WRITTEN OFF IS NOT AFFECTED OR CO NTROLLED OR LIMITED BY THE PROVISIONS OF SECTION 36(1)(VIIA) OF THE ACT WHERE THE ACTUAL WRITE OFF HAS OCCURRED OUT OF ADVANCES NOT SUBJECTE D TO ANY PROVISIONING IN ASSESSMENT YEARS PRIOR TO AY 2007-0 8. 4.3 THE LEARNED SENIOR COUNSEL HOWEVER FAIRLY SUBMI TTED THAT WHETHER THE BAD DEBT WRITTEN OFF UNDER S.36(1)(VII) OF THE ACT HAS ALSO BEEN ALREADY CLAIMED BY WAY OF PROVISIONS MADE UNDER S.36(1)(VIIA) OF THE ACT OR WHETHER CLAIM RELATES T O THE DEBTS APPEARING BEFORE AY 2007-08 WOULD REQUIRE FACTUAL V ERIFICATION WHICH HAS NOT BEEN CARRIED OUT BY THE REVENUE AUTHO RITIES SO FAR AT ANY STAGE AND THUS THE ISSUE JUSTIFIABLY REQUIRES T O GO BACK TO THE FILE OF THE AO FOR SUITABLE VERIFICATION ON THIS CO UNT. IT WAS CONTENDED THAT WHERE THE DEBTS WRITTEN OFF ARE FOUN D TO BE INDEPENDENT OF DEBTS FOR WHICH PROVISIONS HAVE BEEN MADE, THE DEDUCTION UNDER S.36(1)(VII) OF THE ACT IS ALLOWABL E INDEPENDENTLY AND IRRESPECTIVE OF PROVISION FOR BAD DEBTS CREATED BY THE SCHEDULED BANK IN RELATION TO ADVANCES MADE BY ITS RURAL BRAN CHES, SUBJECT TO LIMITATION THAT AN AMOUNT SHOULD NOT BE DEDUCTED TW ICE UNDER S.36(1)(VII) & SECTION 36(1)(VIIA) OF THE ACT SIMUL TANEOUSLY. 5. ADVERTING TO THE 2 ND ISSUE ON ACCOUNT OF RENOVATION EXPENDITURE OF CAPITAL NATURE AMOUNTING TO RS.13,85 ,272/-, THE LEARNED SENIOR COUNSEL ADVERTED TO A REPRESENTATION DATED ITA NOS. 3468 & 3469/AHD/2016 & 960/AHD/18 [NUTAN NAGRIK SAHAKARI BANK LTD.] - 5 - 04.02.2013 MADE BY ASSESSEE BEFORE THE AO AND REFER RED TO PARA 12 THEREIN TO SUBMIT THAT THE ASSESSEE HAS DISALLOWED RS.2,20,00,663/- ON ACCOUNT OF DEPRECIATION AND HAS ALSO DISALLOWED RS.13,85,272/- SEPARATELY AGAIN, PURELY OUT OF MISTAKE. IT WAS SU BMITTED THAT THE DISALLOWANCE OF RS.2,20,00,663/- ALREADY INCLUDES T HE SUM OF RS.13,25,272/-. IN THIS REGARD, LEARNED SENIOR COU NSEL SUBMITTED THAT ALTHOUGH THE MISTAKE HAS OCCURRED FROM THE END OF THE ASSESSEE AND THE RETURN OF INCOME HAS BEEN WRONGLY INFLATED TO THE EXTENT OF RS.13,25,272/- ON THIS SCORE, IT IS WELL SETTLED TH AT REVENUE SHOULD NOT TAKE ADVANTAGE OF SUCH MISTAKE COMMITTED AND SH OULD DETERMINE THE TRUE AND CORRECT INCOME ASSESSABLE TO TAX. THE LEARNED SENIOR COUNSEL FAIRLY SUBMITTED THAT THE AFORESAID ISSUE O F EXCESSIVE DISALLOWANCE WRONGLY MADE WOULD ALSO REQUIRE FACTUA L VERIFICATION AT THE END OF THE AO AND THUS MAY BE RETURNED TO TH E AO FOR DOING SO. 6. THE LEARNED DR, ON THE OTHER HAND, RELIED UPON T HE ORDERS OF THE LOWER AUTHORITIES AND POINTED OUT WITH REFERENC E TO FIRST ISSUE TOWARDS CLAIM OF BAD DEBT THAT THE RELIANCE PLACED BY THE LEARNED SENIOR COUNSEL FOR THE ASSESSEE ON CATHOLIC SYRIAN BANK LTD. (SUPRA) IS TOTALLY MISPLACED OWING TO THE FACTUAL MATRIX. IT WAS SUBMITTED THAT IN CATHOLIC SYRIAN BANK LTD. (SUPRA), THE CONTROVERSY WAS RESOLVED IN FAVOUR OF THE ASSESSEE FOR THE REASON T HAT BAD DEBT WRITTEN OFF BY THE BANK UNDER S.36(1)(VII) OF THE A CT WERE PERTAINING TO URBAN BRANCHES ONLY WHEREAS PROVISION FOR BAD DE BT UNDER S.36(1)(VIIA) OF THE ACT WAS MADE WITH REFERENCE TO RURAL BRANCHES. THUS, THE CLAIM MADE UNDER S.36(1)(VII) AND 36(1)(V IIA) OF THE ACT WERE FOUND TO BE OF DIFFERENT GENRE WHICH IS NOT SH OWN IN THE INSTANT CASE. IN A REJOINDER TO THE AFORESAID OBSE RVATION, THE LEARNED SENIOR COUNSEL FOR THE ASSESSEE HOWEVER SUBMITTED T HAT THE DISTINCTIVE POINT IN THE PRESENT CASE IS THAT THE E LIGIBILITY OF ITA NOS. 3468 & 3469/AHD/2016 & 960/AHD/18 [NUTAN NAGRIK SAHAKARI BANK LTD.] - 6 - DEDUCTION UNDER S.36(1)(VIIA) OF THE ACT ON ACCOUNT OF PROVISIONS FOR BAD DEBT WAS NOT AVAILABLE AT ALL TO THE ASSESS EE PRIOR TO AY 2007-08. THE BAD DEBTS CLAIMED ON ACCOUNT OF ACTUAL WRITE OFF RELATES TO LOANS/ADVANCES MADE IN THE ASSESSMENT YE ARS PRIOR TO THE APPLICABILITY OF PROVISIONS OF SECTION 36(1)(VIIA) OF THE ACT. IN THESE CIRCUMSTANCES, IT WAS SUBMITTED ON BEHALF OF THE ASSESSEE THAT THERE ARE INDEPENDENT CLAIMS MADE UNDER S.36(1)(VII ) OF THE ACT FOR THE ADVANCES MADE PRIOR TO AY 2007-08 AND PROVISION ING MADE OUT OF ADVANCES MADE IN THE LATER YEARS. IT WAS, IN TH E SAME VEIN, SUBMITTED ON BEHALF OF THE ASSESSEE THAT THE ASSESS EE WOULD NOT BE ALLOWED DEDUCTION UNDER S.36(1)(VII) OF THE ACT ON ACTUAL WRITE OFF OF THE PROVISIONS ALREADY CLAIMED UNDER S.36(1)(VII A) OF THE ACT ON THE SAME SET OF DEBTS. 7. ON THE 2 ND ISSUE, THE LEARNED DR FOR THE REVENUE OBSERVED THA T THE REVENUE AUTHORITIES HAVE NOT DISTURBED THE RETU RN FILED BY THE ASSESSEE HIMSELF ON THE POINT AND HENCE NO FAULT CA N BE FOUND WITH REVENUE. 8. WE HAVE CAREFULLY CONSIDERED THE RIVAL SUBMISSIO NS. 8.1 THE FIRST ISSUE RELATES TO SIMULTANEOUS CLAIM O F TWIN DEDUCTIONS IN RELATION TO BAD DEBTS; ONE TOWARDS AC TUAL WRITE OFF OF BAD DEBT UNDER S.36(1)(VII) OF THE ACT AND ANOTHER ON ACCOUNT OF PROVISIONS OF BAD DEBT UNDER S.36(1)(VIIA) OF THE A CT. AS POINTED OUT ON BEHALF OF THE ASSESSEE, THE CLAIM MADE UNDER S.36(1)(VII) OF THE ACT BY THE ASSESSEE IS TO BE RECKONED AS INDEPE NDENT OF PROVISIONING AVAILABLE UNDER S.36(1)(VIIA) OF THE A CT. AS POINTED OUT, THE BENEFIT OF PROVISIONING UNDER S.36(1)(VIIA ) OF THE ACT WAS NOT PERMISSIBLE AT ALL TO CO.OP. BANKS PRIOR TO AY 2007-08. AS STATED, THE BAD DEBT WRITTEN OFF UNDER S.36(1)(VII) OF THE ACT DOES ITA NOS. 3468 & 3469/AHD/2016 & 960/AHD/18 [NUTAN NAGRIK SAHAKARI BANK LTD.] - 7 - NOT EMANATE OUT OF LOANS AND ADVANCES FOR WHICH THE PROVISIONING HAS BEEN AVAILED UNDER S.36(1)(VIIA) OF THE ACT IN ANY MANNER. IN THE LIGHT OF THE DECISION OF THE HONBLE SUPREME CO URT IN CASE OF CATHOLIC SYRIAN BANK LTD. VS. CIT(A) [2012] 18 TAXM ANN.COM 282 (SC) , WE ARE OF THE VIEW THAT SECTION 36(1)(VII) & 36(1 )(VIIA) OF THE ACT ARE DISTINCT AND INDEPENDENT ITEMS OF DEDUCTION AND OPERATE IN THEIR RESPECTIVE FIELDS. SO LONG AS THE CLAIM OF B AD DEBT DOES NOT OVERLAP OR RESULT IN DUAL DEDUCTION, ONE ON ACCOUNT OF PROVISION OF BAD DEBT AND ANOTHER AT THE TIME OF ACTUAL WRITE OF F, THERE IS NOT STATUTORY BAR IN MAKING THE CLAIM UNDER TWO PROVISI ONS. 8.2 ON FACTS, IT IS THE CASE OF THE ASSESSEE THAT T HE BAD DEBTS ACTUALLY WRITTEN OFF ARE OUT OF LOANS & ADVANCES MA DE PRIOR TO AY 2007-08 FOR WHICH NO PROVISIONING UNDER S.36(1)(VII A) OF THE ACT COULD BE MADE. 8.3 THE ASPECTS ON DOUBLE DEDUCTION ON SAME LOAN/AD VANCES REQUIRES FACTUAL VERIFICATION. IN CASE THE AO FIND S THAT THE BAD DEBT WRITTEN OFF IS OUT OF LOANS/ADVANCES MADE PRIOR TO THE OPERATION OF SECTION 36(1)(VIIA) OF THE ACT, THE AO SHALL ALLOW THE BAD DEBT SO WRITTEN OFF, SUBJECT TO THE FULFILLMENT OF OTHER CO NDITIONS OF SECTION 36(2) OF THE ACT. HOWEVER, WHERE IT IS FOUND THAT THE BAD DEBTS RELATE TO LOANS AND ADVANCES OF THE YEARS WHERE BEN EFIT TO DEDUCTION UNDER S.36(1)(VIIA) OF THE ACT TO HAVE BEEN EXTENDE D TO THE ASSESSEE, THE AO SHALL APPROPRIATE AND REDUCE THE PROVISIONIN G ALREADY MADE FROM WRITE OFF. IN SHORT, WE HOLD THAT THE ASSESSE E SHALL NOT BE ENTITLED TO CLAIM OF DEDUCTION OF BAD DEBT FOR THE SAME LOAN/ADVANCES TWICE, ONE UNDER S.36(1)(VII) AND OTH ER UNDER S.36(1)(VIIA) OF THE ACT. IN THE LIGHT OF THESE OB SERVATIONS, THE ISSUE IS REMITTED BACK TO THE FILE OF THE AO FOR FACTUAL VERIFICATION AND EXAMINATIONS AS MAY BE CONSIDERED EXPEDIENT BY HIM TO DETERMINE ITA NOS. 3468 & 3469/AHD/2016 & 960/AHD/18 [NUTAN NAGRIK SAHAKARI BANK LTD.] - 8 - THE ISSUE AFRESH. IT SHALL BE OPEN TO THE ASSESSEE TO MAKE ALL SUBMISSIONS AND REPRESENTATIONS BEFORE THE AO ON TH E POINT. THE AO SHALL DETERMINE THE ISSUE IN ACCORDANCE WITH LAW AFTER GRANTING PROPER OPPORTUNITY TO THE ASSESSEE. 8.4 IN THE RESULT, GROUND NO.1 OF THE ASSESSEES AP PEAL IS ALLOWED FOR STATISTICAL PURPOSES. 9. GROUND NO.2 CONCERNS INADVERTENT OVER REPORTING OF INCOME BY THE ASSESSEE IN ITS RETURN OF INCOME TO THE EXTENT OF RS.13,85,272/- OWING TO MISTAKE ON THE PART OF THE ASSESSEE IN MAK ING EXCESS DISALLOWANCE. WE STRAIGHT AWAY OBSERVE THAT THIS I SSUE ALSO REQUIRES TO GO BACK TO THE FILE OF THE AO FOR FACTUAL VERIFI CATION OF EXCESSIVE DISALLOWANCES WRONGLY MADE BY THE ASSESSEE AS CLAIM ED. THE AO SHALL GRANT SUITABLE RELIEF TO THE ASSESSEE WHERE I T IS FOUND THAT THE ASSESSEE HAS WRONGLY REPORTED EXCESSIVE TAXABLE INC OME IN ITS RETURN OF INCOME INDEED OWING TO INADVERTENT MISTAKE OF EX CESSIVE DISALLOWANCE ON THE POINT. NEEDLESS TO SAY, THE AS SESSEE SHALL FULLY COOPERATE IN THE PROCEEDINGS BEFORE THE AO FOR DETE RMINATION OF THE POINT AFRESH IN ACCORDANCE WITH LAW. 10. GROUND NO.2 OF THE ASSESSEES APPEAL IS ALLOWED FOR STATISTICAL PURPOSES. 11. IN THE RESULT, APPEAL OF THE ASSESSEE IS ALLOWE D FOR STATISTICAL PURPOSES. ITA NOS. 3469/AHD/16 (AY 2012-13) & ITA NO. 960/AHD /18 (AY 2014-15) 12. AS STATED ON BEHALF OF THE ASSESSEE, IDENTICAL ISSUE TOWARDS BAD DEBT HAS ARISEN IN OTHER APPEALS OF THE ASSESSE E IN ITA NO. ITA NOS. 3468 & 3469/AHD/2016 & 960/AHD/18 [NUTAN NAGRIK SAHAKARI BANK LTD.] - 9 - 3469/AHD/2016 AY 2012-13 AS WELL AS ITA NO. 960/AHD /2018 2014- 15. FOR THE PARITY OF THE REASONS, THE ISSUE OF DU AL CLAIM OF BAD DEBT BOTH UNDER S.36(1)(VII) & 36(1)(VIIA) OF THE ACT IS REMITTED BACK TO THE FILE OF THE AO FOR ITS FRESH DETERMINATION IN A CCORDANCE WITH LAW IN THE LIGHT OF DISCUSSIONS MADE IN ITA NO. 3468/AH D/2016 CONCERNING AY 2010-11. 13. IN THE RESULT, ALL THREE APPEALS OF THE ASSESSE E ARE ALLOWED FOR STATISTICAL PURPOSES. SD/- SD/- (JUSTICE P. P. BHATT) (PRADIP KUMAR KEDIA) PRESIDENT ACCOUNT ANT MEMBER AHMEDABAD: DATED 01/10/2020 TRUE COPY S. K. SINHA !'#' / COPY OF ORDER FORWARDED TO:- &. / REVENUE 2. / ASSESSEE (. )*+ , / CONCERNED CIT 4. ,- / CIT (A) /. 012 33*+4 *+#4 56) / DR, ITAT, AHMEDABAD 7. 289 : / GUARD FILE. BY ORDER / 4 /5 *+#4 56) THIS ORDER PRONOUNCED ON 01/10/2020