M/S CHHATTISGARH STATE CRICKET SANGH, RAIPUR (CG) V. THE COMMISSIONER OF INCOME TAX, RAIPUR (CG)

ITA 353/BIL/2016

• Counselvise Citation: [2019] 117 COUNSELVISE.COM (IT) 5462 (ITAT-RAIPUR)
• Duration Of Justice: 2 year(s) 4 month(s) 16 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 16-05-2019
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB
• Assessment Year: misc
• Appeal Filed On: 30-12-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: P K MISHRA
• Keywords: Charitable institution; Condonation of delay; Set aside
• Section: 12A; 12; 11

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR BEFORE SHRI PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER AND DR. MITHA LAL MEENA, ACCOUNTANT MEMBER . / ITA NO. 353 /RPR/20 16 CHHATTISGARH STATE CRICKET SANGH, 35/75, PUNJABI COLONY, KATORA TALAB, RAIPUR, CG - 492 001. PAN : AABTC1016F ....... / APPELLANT / V/S. THE COMMISSIONER OF INCOME TAX RAIPUR (C.G.) / RESPONDENT A SSESSEE BY : SHRI PRAVEEN JAIN, CA REVENUE BY : SHRI P.K. MISHRA, CIT - DR / DATE OF HEARING : 16 .05 .2019 / DATE OF PRONOUNCEMENT : 16 .05 .2019 / ORDER PER PARTHA SARATHI CHAUDHU RY, JM : THIS APPEAL PREFERRED BY THE ASSESSEE EMANATES FROM THE ORDER OF THE LD. CIT(EXEMPTION) DATED 30.05.2014 AS PER THE GROUNDS OF APPEAL ON RECORD. 2 ITA NO. 353 / RPR /20 16 CHHATTISGARH STATE CRICKET SANGH 2. AT THE OUTSET, WE NOTICE THAT THE PRESENT APPEAL IS TIME BARRED BY 878 DAYS. THE ASSESSEE HAS FILED AN AFFIDAVIT ALONG WITH CONDONATION OF DELAY PETITION. WE HAVE GONE THROUGH THE CONDONATION PETITION AS WELL AS THE AFFIDAVIT AND HAVE FOUND THAT REASONS SPECIFIED THEREIN ARE JUSTIFIED AND THAT THE DELAY CANNOT BE ATTRIBUTED TO THE DELIBERATE CONDUCT OF THE ASSESSEE NEITHER THROUGH INTENTION NOR THROUGH ACTION. THE REASONS FOR DELAY IN FILING THE APPEAL LATE WERE BEYOND THE CONTROL OF THE ASSESSEE AND EVEN THE LD. DR STATED THAT HE HAS NO OBJECTION, IF THE DELAY IS CONDONED. IN VIEW OF THE MATTER, WE CONDONE THE DELAY AND PROCEED TO HEAR THE APPEAL ON MERITS. 3 . THE CRUX OF THE GRIEVANCE OF THE ASSESSEE IN THIS APPEAL IS REJECTION OF APPLICATION FOR GRANTING REGIS TRATION U/S.12AA OF THE INCOME TAX ACT, 1961 (HEREINAFTER REFERRED TO AS THE ACT). 4 . AT THE TIME OF HEARING, THE LD. AR OF THE ASSESSEE APPRAISED THE BENCH THAT THE BASIC REASON FOR REJECTION OF APPLICATION U/S.12AA OF THE ACT ON THE PART OF THE REVENU E IS THAT ACCORDING TO THE REVENUE THE ASSESSEE IS HIT BY PROVISO TO SECTION 2(15) OF THE ACT. MEANING THEREBY ACCORDING TO THE REVENUE, THE ASSESSEE IS ENGAGED IN ACTIVITIES OF BUSINESS, TRADE AND COMMERCE OR IS RENDERING SERVICES IN RELATION TO SUCH BUSI NESS, TRADE OR COMMERCE AND THEREFORE, REGISTRATION U/S.12AA OF THE ACT WAS 3 ITA NO. 353 / RPR /20 16 CHHATTISGARH STATE CRICKET SANGH DENIED TO THE ASSESSEE. THAT FURTHERMORE, IT IS THE OBSERVATION OF THE REVENUE THAT SINCE THE ASSESSEE TRUST IS RECEIVING GRANT FROM BCCI AND THAT BCCI ITSELF IS INVOLVED IN IPL M ATCHES AND THEREFORE, THE ACTIVITIES ARE IN THE NATURE OF TRADE, COMMERCE OR BUSINESS. 5. THE LD. AR VEHEMENTLY ARGUED THAT THE ONLY OBJECT OF THE ASSESSEE TRUST IS PROMOTION OF CRICKET IN THE STATE OF CHHATTISGARH AND TO BRING IN NEW TALENT IN THE SPO RTS WHEREBY THE DESERVING PLAYERS CAN REPRESENT THE COUNTRY AT SO ME POINT OF TIME . THE GRANT/SUBSIDY R ECEIVED FROM BCCI IS IN THE NATURE OF ASSOCIATE SERVICES REQUIRED DURING IPL MATCHES WHICH INVOLVES DRINKING WATER FACILITY, GROUND MAINTENANCE, SECURITY ETC. THE ENTIRE IPL MATCHES REVENUE TRANSACTIONS ARE UNDERTAKEN BY THE RESPECTIVE FRANCHISE E AND THE ASSESSEE TRUST HA S NOTHING TO DO WITH IT. THE ASSESSEE T RUST ALSO CONDUCTS CHARITABLE MATCHES, COACHING CAMPS FOR WHICH EXPENSES ARE INCURRED AND THOSE ARE REIMBURSE D FROM BCCI SINCE THE ASSESSEE TRUST IS ONLY AUTHORIZED BODY OF BCCI IN THE STATE OF CHHATTISGARH. THE LD. AR FURTHER SUBMITTED THAT ON SIMILAR FAC TS AND SITUATION AND ON MERITS IN ASSESSEES OWN CASE IN ITA NO. 265/RPR/2017, THIS CO - ORDINATE BENCH HAS CONSIDERED THESE ISSUES. THAT ON SIMILAR FACTS AND CIRCUMSTANCES ON MERITS, THE LD. AR PRAYED THAT IN THE INSTANT CASE ALSO, PRAYER FOR REGISTRATION U /S.12AA OF THE ACT MAY BE ACCEPTED. 4 ITA NO. 353 / RPR /20 16 CHHATTISGARH STATE CRICKET SANGH 6 . PER CONTRA, THE LD. DR HAS PLACED RELIANCE ON THE ORDER OF THE LD. COMMISSIONER OF INCOME TAX (EXEMPTION) . 7 . WE HAVE PERUSED THE CASE RECORDS AND HEARD THE RIVAL CONTENTIONS AND CONSIDERED THE VARIOUS JUDICIAL PRON OUNCEMENTS PLACED ON RECORD. WE FIND THAT IN ASSESSEES OWN CASE IN ITA NO.265/RPR/20 17, WE HAVE OBSERVED IN DETAIL THE MERITS OF THE ASSESSEES CASE ON SIMILAR ISSUE WHEREIN WE HAVE HELD AS UNDER: 7. WE HAVE PERUSED THE CASE RECORDS AND HEARD THE RIVAL CONTENTIONS. WE HAVE ALSO ANALYZED THE FACTS AND CIRCUMSTANCES IN THIS CASE. THE ASSESSEE SOCIETY HAS MADE AN APPLICATION BEFORE THE LD. CIT(EXEMPTION) U/S.12AA OF THE ACT FOR GRANTING REGISTRATION. IT IS SETTLED VIEW AS HELD BY THE VARIOUS CO - ORDINATE BENCH OF THE TRIBUNAL AS WELL AS HONBLE HIGH COURT THAT AT THE TIME OF GRANTING REGISTRATION, THE MATTER TO BE LOOKED INTO ARE THE OBJECTS OF THE APPLICANT AND WHETHER PAST ACTIVITIES ARE CONCERNED WITH S UCH OBJECTS. IF THESE ARE ACCORDING TO THE PROVISIONS OF LAW, THEN REGISTRATION CAN BE GRANTED. HOWEVER, IF AT THE ASSESSMENT STAGE, IT IS NOTICED THAT FUNDS ARE NOT UTILIZED FOR CHARITABLE PURPOSES THEN THE ASSESSING OFFICER MAY REJECT THE EXEMPTION U/S. 11 AND 12 OF THE ACT IN RESPECT TO THE CONCERNED ASSESSEE. AT THE TIME OF GRANTING REGISTRATION U/S.12AA OF THE ACT, IF THE OBJECTS ARE CHARITABLE IN NATURE THEN REGISTRATION U/S.12AA HAS TO BE GRANTED TO SUCH ASSESSEE. THAT ON PERUSAL OF THE OBJECTS OF TH E ASSESSEE SOCIETY IN THE INSTANT CASE, IT IS PREDOMINANTLY FOR PROMOTION OF CRICKET IN THE STATE OF CHHATTISGARH AND TO BRING OUT NEW TALENT IN THE FIELD OF CRICKET SO THAT THEY CAN REPRESENT THE STATE AS WELL AS COUNTRY UNDER SUPERVISION OF BCCI BEING PA RENT BODY OF CRICKET IN INDIA. THE ASSESSEE SOCIETY IS SOLELY AUTHORIZED BODY TO BCCI SO FAR AS THE CHHATTISGARH IS CONCERNED. THE ASSESSEE SOCIETY IS RECEIVING MONEY FROM BCCI IN RESPECT OF CONDUCTING CRICKET COACHING CAMPS, CHARITABLE MATCHES SO THAT FR OM ASSESSEE SOCIETY, NEW TALENT CAN BE BROUGHT IN. EVEN WITH REGARD TO THE IPL MATCHES, ALL THE REVENUE TRANSACTION ARE DONE BY THE FRANCHISEE IN SUCH IPL TOURNAMENT. WHENEVER THE MATCHES ARE HELD IN CHHATTISGARH, THE MAINTENANCE PART AND SECURITY PART AR E TAKEN CARE OF BY THE ASSESSEE AND FOR THIS PURPOSE, CERTAIN AMOUNT IS PAID BY THE 5 ITA NO. 353 / RPR /20 16 CHHATTISGARH STATE CRICKET SANGH BCCI AND THE ASSESSEE HAS TO MEET UP THE EXPENSES FOR THESE ACTIVITIES. THE ASSESSEE SOCIETY IS THEREFORE WELL WITHIN THE DEFINITION OF CHARITABLE PURPOSE AS ENSHRINED U/S. 2(15) OF THE ACT UNDER THE LIMB OF ADVANCEMENT OF ANY OTHER OBJECT OF GENERAL PUBLIC UTILITY. NOW THE PROVISO TO SECTION 2(15) OF THE ACT PROVIDES EMBARGO WITH REGARD TO THIS LIMB I.E. ADVANCEMENT OF ANY OTHER OBJECT OF GENERAL PUBLIC UTILITY SHALL NOT BE A CHARITABLE PURPOSE, IF IT INVOLVES THE CARRYING ON OF ANY ACTIVITY IN THE NATURE OF TRADE, COMMERCE OR BUSINESS OR ANY ACTIVITY OF RENDERING ANY SERVICE IN RELATION TO ANY TRADE, COMMERCE OR BUSINESS, FOR A CESS OR FEE OR ANY OTHER CONSIDERATION. 8. IN ORDER TO ADJUDICATE THE PROVISO TO SECTION 2(15), WE WOULD REVERT TO THE FACTUAL POSITION WITH REGARD TO ISSUE IN HAND: CRICKET IS INDEED AN IMMENSELY POPULAR GAME IN THIS PART OF THE WORLD, AND ANYTHING TO DO WITH CRICKET RESULTS IN MASS INVOLVEMENT OF P UBLIC AT LARGE. THE SHEER STRENGTH OF THESE NUMBERS RESULTS IN HIGHER VISIBILITY OF CRICKETING ACTIVITIES AND THE SCALE OF OPERATIONS ON WHICH THE WORK FOR DEVELOPMENT OF CRICKET IS TO BE CARRIED OUT. THESE FACTS, BY ITSELF, AND WITHOUT THE ASSESSEE BEFORE US DEVIATING FROM THEIR OBJECTS OR VENTURING INTO TRADE, COMMERCE OR BUSINESS, CANNOT REQUIRE THE ACTIVITIES TO BE TREATED AS COMMERCIAL ACTIVITIES. WHEN A CRICKET STADIUM IS TO BE BUILT, IT HAS TO ACCOMMODATE A VERY LARGE NUMBER OF PERSONS BUT THE SIZE O F THE STADIUM WOULD NOT MEAN THAT THE ACTIVITY IS FOR ANYTHING OTHER THAN PROMOTION OF CRICKET. WHEN THE SCALE OF OPERATIONS ARE LARGER, EVEN THE SURPLUS OR DEFICIT COULD BE LARGE, BUT THEN THE SCALE OF OPERATIONS MAY BE A SCALE ON WHICH COMMERCIAL ACTIVIT IES COULD BE CARRIED OUT BUT THAT FACT CANNOT CONVERT AN OBJECT OF GENERAL PUBLIC UTILITY INTO A COMMERCIAL ACTIVITY. WE HAVE CAREFULLY ANALYSED THE OBJECTS OF THE ASSESSEE, AND WE DO NOT FIND ANY OBJECTS, OTHER THAN OBJECT OF CRICKET, BEING PURSUED BY THE SE CRICKET ASSOCIATIONS. THE OBJECTS OF THESE CRICKET ASSOCIATIONS CLEARLY DEMONSTRATE THAT THESE CRICKET ASSOCIATIONS EXIST AND OPERATE PURELY FOR THE PURPOSE OF PROMOTING CRICKET. THEREFORE, IN OUR CONSIDERED VIEW THE PROVISO TO SECTION 2(15) CANNOT BE I NVOKED IN THE CASE OF THE ASSESSEE. 9. WE FIND THAT IN THE CASE OF DCIT VS. TAMIL NADU CRICKET ASSOCIATION (SUPRA.) BEFORE THE CO - ORDINATE BENCH OF THE TRIBUNAL, CHENNAI, THE FACTS ARE THAT THE ASSESSEE SOCIETY WAS AFFILIATED TO BOARD OF CONTROL FOR CRICKET IN INDIA AND ASSESSEE DERIVES INCOME FROM SUBSCRIPTION, RENT FOR HIRING CRICKET GROUND, SPONSORSHIP, FEE FOR PROV IDING SERVICE TO IPL, INCOME FROM ADVERTISEMENT, SUBSIDY/SUBVENTION FROM BCCI SALE OF TICKETS FOR CONDUCTING MATCHES, RESTAURANT AND CATERING INCOME. ASSESSEE CLAIMED EXEMPTION U/S.11 OF THE ACT AND THE ASSESSING OFFICER DISALLOWED THE CLAIM OF THE 6 ITA NO. 353 / RPR /20 16 CHHATTISGARH STATE CRICKET SANGH ASSESSE E MAINLY ON THE GROUND THAT ACTIVITY OF THE ASSESSEE WAS COMMERCIAL IN NATURE. THE ASSESSING OFFICER ALSO FOUND THAT PROVISO TO SECTION 2(15) WOULD COME INTO OPERATION SINCE GROSS RECEIPTS OF ASSESSEE EXCEEDED PRESCRIBED LIMIT AND THE LD. CIT(A) UPHELD THA T ORDER. THE CO - ORDINATE BENCH OF THE TRIBUNAL, CHENNAI HAS HELD THAT ACTIVITY OF THE ASSESSEE COULD NOT BE CONSIDERED TO BE BUSINESS ACTIVITY. THE ASSESSEE WAS NOT PROVIDING ANY SERVICES TO ANY TRADE OR COMMERCE OR INDUSTRY. THEREFORE, THE PROVISO TO SECT ION 2(15) WAS NOT APPLICABLE TO THE ASSESSEE AND THE ASSESSEE WAS ENTITLED FOR EXEMPTION U/S.11 OF THE ACT. IN THE PRESENT CASE ALSO, THE ASSESSEE IS RECEIVING MONEY FROM BCCI AS SUBSIDY FOR PROVIDING SERVICES IN THE IPL MATCHES, FOR CONDUCTING CRICKET MAT CHES FOR HIRING GROUND ONLY TO PROMOTE THE CRICKET AND ENCOURAGING NEW TALENT IN THE FIELD OF CRICKET AND OBJECTS OF ALL THE OTHER CRICKET ASSOCIATIONS OF ANY OTHER STATE ARE SIMILAR IN NATURE. THEREFORE, THE ASSESSEE HAS NOT PROVIDED ANY SERVICES TO ANY T RADE, COMMERCE OR INDUSTRY AS DEFINED IN THE PROVISO TO SECTION 2(15) OF THE ACT. 10. THE HONBLE APEX COURT IN THE CASE OF CIT VS. GUJARAT MARITIME BOARD REPORTED (SUPRA.) HAS HELD THAT IF THE PRIMARY PURPOSE AND THE PREDOMINANT OBJECT IS FOR WELFARE OF GENERAL PUBLIC THEN THE PURPOSE WOULD BE CHARITABLE IN NATURE. 11. BEFORE US, THE LD. AR OF THE ASSESSEE ALSO SUBMITTED THAT PREDOMINANT OBJECT AND ACTIVITY OF ALL THE STATE ASSOCIATION AFFILIATED TO BCCI ARE ALMOST SIMILAR. ALMOST ALL THE STATE ASSOCIATI ONS ARE ENJOYING BENEFIT OF 12A AND THE ASSESSEE IS DENIED OF THE SAME IN SPITE OF BEING ENGAGED IN EXACTLY SAME ACTIVITY. THE LD. AR OF THE ASSESSEE HAS PLACED RELIANCE ON THE DECISION OF THE HONBLE BOMBAY HIGH COURT IN ITA NO.500 TO 504/NAG/2016 IN THE CASE OF TAX PRACTITIONER BENEVOLENT FUND VS. CIT REPORTED IN 266 ITR 561 WHEREIN IT WAS HELD THAT WHEN OBJECTS OF TWO INSTITUTIONS ARE SIMILAR THEN IT IS NOT OPEN TO THE INCOME TAX DEPARTMENT TO APPLY DIFFERENT PARAMETERS TO DIFFERENT TRUSTS CARRYING SIMIL AR OBJECTS AND SIMILAR PURPOSES SEEKING GRANT OF EXEMPTION U/S.80G OF THE ACT. WE HAVE ALREADY ANALYZED THE OBJECTS OF THE TRUST VIS - A - VIS OTHER ASSOCIATIONS OF VARIOUS OTHER STATE UNDER BCCI SUPERVISION FOR PROMOTING CRICKET. WE HAVE ALSO EXAMINED THAT T HE OBJECTS OF THE OTHER STATES ASSOCIATIONS ARE SIMILAR TO THAT OF THE ASSESSEE AND WHEN THOSE ASSOCIATIONS ARE ENJOYING THE BENEFIT OF 12A AND EXEMPTION U/S.80G OF THE ACT THEN THE ASSESSEE ON THE SIMILAR PARAMETERS AND OBJECTS IS ENTITLED FOR REGISTRATI ON U/S.12AA OF THE ACT AND EXEMPTION U/S.80G OF THE ACT. MOREOVER, THE FACTS DEMONSTRATE 7 ITA NO. 353 / RPR /20 16 CHHATTISGARH STATE CRICKET SANGH THAT THIS IS NOT A PRIVATE TRUST FOR THE BENEFIT OF A SINGLE FAMILY BUT A SOCIETY IN WHICH ANY PERSON OF GENERAL PUBLIC OF ANY CASTE, COMMUNITY OR CREED CAN BECOME THE MEMBER OF THE ASSESSEE SOCIETY WITHOUT ANY RESTRICTION. THE ASSESSEE SOCIETY RUNS THROUGH ITS MEMBERS. THE SOCIETY PERFORMS ALL THE FUNCTION ONLY THROUGH ITS MEMBERS. THE MEMBERS OF THE SOCIETY ARE FULLY DEDICATED TO ACHIEVE THE MAIN OBJECT OF THE SOCIETY . ALL THE OBJECTS OF THE SOCIETY ARE FOR THE PROMOTION OF CRICKET. SOCIETY HAS BEEN FORMED WITH THE LIKE - MINDED MEMBERS WHOSE AIM IS TO PROMOTE CRICKET SPORTS IN INDIA. THE OBJECT NOWHERE SPEAKS OR INTENDS TO PROVIDE ANY FINANCIAL ASSISTANCE TO ITS MEMBERS . 12. WE HAVE ALREADY EXAMINED THAT THE ASSESSEE IS NOT HIT BY THE PROVISO TO SECTION 2(15) OF THE ACT SINCE IT DOES NOT CONDUCT ANY SERVICE OR ACTIVITIES WHICH ARE IN THE NATURE OF TRADE, COMMERCE OR BUSINESS. ALL THE FACTS BEING EXAMINED VIS - - VIS TAKI NG INTO CONSIDERATION OF JUDICIAL PRONOUNCEMENTS PLACED BEFORE US AND EXAMINING OBJECT OF THE ASSESSEES SOCIETY PROVIDES THAT IT IS FOR CHARITABLE PURPOSE FOR ADVANCEMENT OF ANY OTHER OBJECT OF GENERAL PUBLIC UTILITY. THE HONBLE APEX COURT IN THE CASE OF CASE OF CIT VS. GUJARAT MARITIME BOARD (SUPRA.) HAS HELD THAT IF THE PRIMARY PURPOSE AND THE PREDOMINANT OBJECT IS FOR WELFARE OF GENERAL PUBLIC THEN THE PURPOSE WOULD BE CHARITABLE IN NATURE. 13. THE HONBLE SUPREME COURT OF INDIA IN THE CASE OF AHMEDAB AD RANA CASTE ASSOCIATION VS. COMMISSIONER OF INCOME TAX (1971) 82 ITR 0704 WHEREIN IT HAS BEEN HELD THAT THE OBJECT OF THE TRUST MAY BE CHARITABLE IN NATURE AND AN OBJECT BENEFICIAL TO A SECTION OF PUBLIC IS AN OBJECT OF GENERAL PUBLIC UTILITY. THE SECTIO N OF PUBLIC MUST BE DEFINITE AND IDENTIFIABLE AND IT IS NOT NECESSARY THAT THE OBJECT SHOULD BENEFIT THE WHOLE MANKIND. IN THE CASE OF THE ASSESSEE, SINCE IT IS FOR PROMOTION OF CRICKET, IT MAY NOT BE BENEFITING THE ENTIRE MANKIND BUT THOSE BEING BENEFITE D ARE DEFINITELY IDENTIFIABLE AND THEY ARE SECTIONS OF PUBLIC. 14. IN THE INSTANT CASE OF THE ASSESSEE, THE WORK OF THE ASSESSEE SOCIETY IS TO PROMOTE CRICKET SO AS TO BRING FORTH NEW TALENTS AND PROVIDE OPPORTUNITY TO THE PEOPLE FOR REPRESENTING THE STAT E AS WELL AS THE COUNTRY. THEREFORE, THE OBJECT OF THE ASSESSEE IS FOR CHARITABLE PURPOSE AND NOTHING ELSE. IN VIEW OF THE MATTER AND AS PER THE AFORESAID DISCUSSION OF FACTS AND JUDICIAL PRONOUNCEMENTS, WE SET ASIDE THE ORDER OF THE LD.CIT(EXEMPTION) AND DIRECT THE LD.CIT(EXEMPTION) TO GRANT REGISTRATION U/S.12AA OF THE ACT TO THE ASSESSEE SOCIETY. 8 ITA NO. 353 / RPR /20 16 CHHATTISGARH STATE CRICKET SANGH 15. IN THE RESULT, APPEAL OF THE ASSESSEE IS ALLOWED. RESPECTFULLY, FOLLOWING THE AFORESAID DECISION, WE DIRECT THE L D. COMMISSIONER OF INCOME TAX ( EXEMPTION) TO GRANT REGISTRATION U/S.12AA OF THE ACT TO THE ASSESSEE SOCIETY. 8 . IN THE RESULT, APPEAL OF THE ASSESSEE IS ALLOWED. ORDER PRO NOUNCED ON 16TH DAY OF MAY , 201 9 . SD/ - SD/ - MITHA LAL MEENA PARTHA SARATHI CHAUDHURY ACCOUNTANT MEMBER JUDICIAL MEMBER / RAIPUR ; / DATED : 16 TH MAY, 2019. SB / COPY OF THE ORDER FORWARDED TO : 1. / THE APPELLANT. 2. / THE RESPONDENT. 3. THE CIT (EXEMPTION), RAIPUR. 4. THE JCIT( EXEMPTION), RAIPUR. 5. , , , / DR, ITAT, RAIPUR BENCH, RAIPUR. 6. / GUARD FILE. // TRUE COPY // / BY ORDER, / PRIVATE SECRETARY , / ITAT, RAIPUR.