INDUS UDYOG & INFRASTRUCTURE PRIVATE LIMITED, RAIPUR V. INCOME TAX OFFICER, WARD 4(1), RAIPUR

ITA 36/RPR/2018

AI Insights

The case involves Indus Udyog & Infrastructure Private Limited, which appealed against the order of the CIT(Appeals)-II, Raipur, confirming the addition of Rs.44.75 lacs as unexplained credit under section 68 of the Income Tax Act, 1961. The addition was initially made by the Assessing Officer (A.O.) during the scrutiny assessment for the assessment year 2014-15, due to doubts about the creditworthiness and genuineness of the share application money received from M/s. Land Mark Fiscal Pvt. Ltd. The Tribunal examined the evidences, including bank statements and previous assessments, and concluded that the assessee had adequately proven the legitimacy of the transaction.

• Counselvise Citation: [2022] 140 COUNSELVISE.COM (IT) 128044 (ITAT-RAIPUR)
• Duration Of Justice: 4 year(s) 8 month(s) 17 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 13-12-2022
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB
• Next Hearing Date: 20-09-2022
• Assessment Year: 2014-2015
• Appeal Filed On: 26-03-2018
• Other Referred Cases: CIT Vs. Ultra Modern Exports Pvt. Ltd., CIT Vs. Orchid Industries P. Ltd., Shreedham Constructions Pvt. Ltd, TRM Energy Pvt. Ltd, Nova Promoters and Finlease Pvt. Ltd., Oasis Hospitalities
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Unexplained cash credit; Opportunity of cross examination; Set aside
• Section: 131

Judgement Text

आयकर अपीलȣय अͬधकरण Ûयायपीठ रायप ु र मɅ। IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR BEFORE SHRI RAVISH SOOD, JUDICIAL MEMBER AND SHRI G D PADMAHSHALI, ACCOUNTANT MEMBER आयकर अपील सं. / ITA No. 36/RPR/2018 Ǔनधा[रण वष[ / Assessment Year : 2014-15 Indus Udyog & Infrastructure Private Limited House No.104, Las Vista Colony, Amlidih, Raipur (C.G.)-492 001 PAN : AACCI7244K .......अपीलाथȸ / Appellant बनाम / V/s. The Income Tax Officer-4(1), Raipur (C.G.) ......Ĥ×यथȸ / Respondent Assessee by : Shri R.B Doshi, CA Revenue by : Shri G.N Singh, Sr. DR स ु नवाई कȧ तारȣख / Date of Hearing : 21.09.2022 घोषणा कȧ तारȣख / Date of Pronouncement : 14.12.2022 2 Indus Udyog & Infrastructure Private Limited Vs. ITO, Ward-4(1) ITA No. 36/RPR/2018 आदेश / ORDER PER RAVISH SOOD, JM: The present appeal filed by the assessee is directed against the order passed by the CIT(Appeals)-II, Raipur, dated 22.01.2018, which in turn arises from the order passed by the A.O. u/s.143(3) of the Income- tax Act, 1961 (for short ‘Act’), dated 30.12.2016 for A.Y. 2014-15. Before us the assessee has assailed the impugned order on the following grounds of appeal: “(1). In the facts and circumstances of the case and in law, Ld. CIT(A) erred in confirming the addition made by the A.O of Rs.44,75,000/- on account of unexplained credit u/s.68 of the Income Tax Act, 1961, Ld. CIT(A) was not justified in confirming the additions made by the A.O. (2) The appellant reserves the right to amend, modify or add any of the ground/s of appeal.” 2. Succinctly stated, the assessee company which is engaged in the business of trading of coal had e-filed its return of income for the A.Y.2014-15 on 04.10.2014, declaring an income of Rs.6,75,369/-. The case of the assessee was thereafter selected for scrutiny assessment u/s. 143(2) of the Act. 3. During the course of the assessment proceedings, it was observed by the A.O that the assesee company had during the year under consideration received share application money of Rs.44.75 lacs from one M/s. Land 3 Indus Udyog & Infrastructure Private Limited Vs. ITO, Ward-4(1) ITA No. 36/RPR/2018 Mark Fiscal Pvt. Ltd., 15, P.S. Bow Bazar, Kolkata (W.B.). On being called upon to furnish the requisite details the assessee placed on record details of subscribers, confirmation, bank statement, copy of return of income a/w. computation of income. In order to verify the authenticity of the aforesaid transaction the A.O issued notice u/s.133(6) of the Act to the Principal Officer, Land Mark Fiscal Pvt. Ltd., calling upon it to furnish full details regarding the transaction in question which, however, was returned by the postal department with an endorsement “not known”. The A.O brought the aforesaid facts to the knowledge of the assessee and directed him to produce the director of the share applicant company so that the identity, creditworthiness and genuineness of the transaction in question may be verified. However, the aforesaid letter so issued by the A.O was also returned by the postal department with the remark “not known”. Backed by the aforesaid facts the A.O drawing support from the judgment of the Hon’ble High Court of Delhi in the case of CIT Vs. Ultra Modern Exports Pvt. Ltd., ITA No.262/2012, dated 11.12.2012 held the impugned amount of share application money of Rs.44.75 lacs (supra) as an unexplained cash credit u/s.68 of the Act. 4. Aggrieved, the assessee carried the matter in appeal before the CIT(Appeals). Considering the fact that the returned income of the share applicant company i.e. M/s. Land Mark Fiscal Pvt. Ltd. and also its revenue was lowly pitched, the CIT(Appeals) not being inspired with the 4 Indus Udyog & Infrastructure Private Limited Vs. ITO, Ward-4(1) ITA No. 36/RPR/2018 latters financial statements held a conviction that it lacked creditworthiness to make the impugned investment with the assessee company. Accordingly, the CIT(Appeals) upheld the addition of Rs.44.75 lacs made by the A.O. u/s.68 of the Act by observing as under: “6. have considered the grounds of appeal, gone through the submissions of the appellant d seen the order of the AO and also seen the copies of return and balance sheet as on 31.03.2013 and 31.03.2014. For the AY 2014-15 I observe that the gross total income shown by Land Mark Fiscal Pvt Ltd is Rs.51,348/-. As on 31.03.2013 the total revenue from operations and other income is at Rs.9,87,771/- and the corresponding figures as on 31.03.2014 for the AY 2014-15 is Rs.3,39,490/-. Thus for the AY 2014-15 the investor company i.e, Land Mark Fiscal Pvt Ltd had income from operations at Rs.3,17,566/- plus other income of Rs. 21,924/- (totaling Rs. 3,39,490/-). The total expenses for the year under consideration is at Rs.2,88,142/- and the earnings before tax is at Rs.51,348/-. On perusal of the schedule of fixed assets of land mark it is seen that the fixed asset appearing in the schedule is only a flat at Raipur whose value has been shown at Rs.20,95,280/- as on 1.4.2013. During the appeal proceedings the id. Counsel appearing on behalf of the appellant relied on the decision of the Mumbai ITAT in ITA No. 3754 to 3756 dated 14.11.2017 in the case of Shreedham Constructions Pvt. Ltd in support of its contentions. I have gone through the order of the hon'ble Tribunal and find that the facts are distinguishable such as in the referred case all share applicants responded to notices issued be the AO u/s.133(6) of the Act and all necessary material was furnished by the assessee during the assessment proceedings. The AO relied upon third party information and the statements were recorded at the back of the assessee. Moreover the copy of statement of Shri Praveen Kumar Jain recorded by the investigation party was not supplied to the assessee. No opportunity of cross examination was provided by the AO during the assessments. In the case of TRM Energy Pvt. Ltd relied upon by the appellant in ITA no.453 for the AY 2012-13 of the hon'ble Delhi Tribunal the facts are distinguishable as the AO did not ask for the production of the investor company for examination of section 131 of the Act. No inquiry was made directly or indirectly by the AO on the documents filed by the assessee company at the assessment stage. Further no adverse material was found during the course of search to prove that share application money received by the 5 Indus Udyog & Infrastructure Private Limited Vs. ITO, Ward-4(1) ITA No. 36/RPR/2018 assessee company was bogus or was an arranged affair of the assessee company. The above facts are at variance with the case on hand. 7. From the above observations and also from the bank statements it is clear that Lan Mark Fiscal Pvt. Ltd. does not have the creditworthiness of making such investments in the shares of the appellant company. As stated earlier investor company does not have assets, and the turnover from operations is too low for investing an amount of Rs.44,75,000/- in the appellant company. Besides the above no material has been brought record justifying the genuineness of the transactions. The hon'ble Delhi Court in the decision of Oasis Hospitalities has laid stress on identity, creditworthiness and genuineness which are required to be established in such share transactions. Reliance is also placed on the decision of Nova Promoters and Finlease Pvt. Ltd. of the hon'ble Delhi High Court. In view of the above facts and circumstances of the case there is no merit in the grounds raised by the appellant with respect to explanation of share application money received. Accordingly, the addition u/s.68 made by the AO of Rs.44,75,000/- is confirmed and this ground of appeal is dismissed.” 5. The assessee being aggrieved with the order of the CIT(Appeals) has carried the matter in appeal before us. 6. We have heard the ld. authorized representatives of both the parties, perused the orders of the lower authorities and the material available on record, as well as considered the judicial pronouncements that have been pressed into service by them to drive home their respective contentions. 7. The Ld. Authorized Representative (for short ‘AR’) for the assessee at the very outset of the hearing of the appeal took us through the facts involved in the present case. Our attention was drawn by the Ld. AR to the copy of the bank statement of the share applicant company viz. M/s. Land Mark Fiscal Pvt. Ltd., a NBFC, out of which the investment towards share 6 Indus Udyog & Infrastructure Private Limited Vs. ITO, Ward-4(1) ITA No. 36/RPR/2018 application money was claimed to have been made in the assessee company, Page 28 to 39 of APB. It was averred by the Ld. AR that the fact that the notice issued u/s.133(6) by the A.O to the share applicant company was returned unserved was never brought to the knowledge of the assessee. Alternatively, it was submitted by the Ld. AR that the mere fact that notice u/s.133(6) of the Act issued to the share applicant company was returned unserved would not conclusively disprove the authenticity of the assessee’s claim of having raised genuine share application money from the said share applicant. Reliance in support of his aforesaid contention was placed by the Ld. AR on the judgment of the Hon’ble High Court of Bombay in the case of CIT Vs. Orchid Industries P. Ltd. (2017) 397 ITR 136 (Bom.). It was further averred by the Ld. AR that the assessee company had in A.Y.2012-13 received an amount of Rs.28.05 lacs towards share application money from the same share applicant company viz. M/s. Land Mark Fiscal Pvt. Ltd., which after necessary verification was accepted by the A.O vide his order passed u/s.143(3) dated 12.11.2014, Page 42 to 45 of APB. In sum and substance, it was claim of the Ld. AR that creditworthiness of the aforesaid share application money had been looked into and accepted after necessary deliberations by the department while framing assessment in the assessee’s case for A.Y.2012-13. Also, it was submitted by the Ld. AR that the assessee had in the immediately succeeding A.Y i.e. A.Y.2015-16 allotted 1,25,000 shares 7 Indus Udyog & Infrastructure Private Limited Vs. ITO, Ward-4(1) ITA No. 36/RPR/2018 at the rate of Rs.60/- per share ( Face value Rs.10/- and Rs.50/- share premium to the aforesaid share applicant) which after necessary verifications had been accepted by the A.O vide his order passed u/s.143(3) dated 05.12.2017 for the said year, Page 47 to 49 of APB. It was further submitted by the Ld. AR that the order passed by the A.O u/s.143(3) dated 05.12.2017 for A.Y.2015-16 was, thereafter, taken up for revision by the Pr. CIT, Raipur-1 u/s.263 of the Act and “Show Cause” notice (SCN) dated 15.03.2021 was issued to the assessee. It was averred by the Ld. AR that the Pr. CIT, had, inter alia, doubted the genuineness of loan of Rs.5.28 crore (approx.) that was raised by the assessee company during the year from the aforementioned party viz. M/s. Land Mark Fiscal Pvt. Ltd., Kolkata and had called upon it to show cause as to why the order passed by the A.O u/s.143(3) dated 05.12.2017 accepting the same may not be set aside in exercise of powers vested with him u/s.263 of the Act. Our attention was drawn by the Ld. AR to the copy of the SCN dated 15.03.2021 issued by the Pr. CIT u/s.263 of the Act, Page 50-52 of APB. 7.1 It was further submitted by the Ld. AR that the assessee in compliance to the aforesaid SCN dated 15.03.2021 had, thereafter, filed its reply with the Pr. CIT-1, Raipur wherein, it had, inter alia, substantiated the creditworthiness of the lender in question viz. M/s. Land Mark Fiscal Pvt. Ltd. on the basis of supporting documentary evidence. It was submitted by the Ld. AR that the Pr. CIT, Raipur-1 being satisfied with the 8 Indus Udyog & Infrastructure Private Limited Vs. ITO, Ward-4(1) ITA No. 36/RPR/2018 reply of the assessee had thereafter vacated the proceedings which were initiated u/s.263 of the Act and no further action was taken on his part. On the basis of the aforesaid facts, it was the claim of the Ld. AR that as not only the assessee had on the basis of clinching documentary evidence substantiated the creditworthiness of the share applicant company i.e. M/s. Land Mark Fiscal Pvt. Ltd., but also the same was looked into and accepted by the department while framing the scrutiny assessments of the assessee company for A.Y.2012-13, A.Y.2015-16 and A.Y.2017-18, therefore, there was no justification for the A.O to have drawn adverse inferences qua the amount of Rs.44.75 lacs (supra) that was received from the said share applicant company during the year under consideration. Also, it was the claim of the Ld. AR that now when the Pr. CIT, Raipur-1 finding favour with the claim of the assessee that the party in question viz. M/s. Land Mark Fiscal Pvt. Ltd. had financial credibility to advance an unsecured loan of Rs.5.28 crores to the assessee in A.Y.2015-16, therefore, the creditworthiness of the said party to make an investment of Rs.44.75 lacs (supra) towards share application money with the assessee company during the year under consideration could not have been doubted. 8. Per contra, the Ld. Departmental Representative (for short ‘DR’) relied on the orders of the lower authorities. It was submitted by the Ld. DR that as the assessee had failed to prove the identity, creditworthiness and genuineness of the transaction of having received an amount of 9 Indus Udyog & Infrastructure Private Limited Vs. ITO, Ward-4(1) ITA No. 36/RPR/2018 Rs.44.75 lacs (supra) towards share application money from the aforesaid party viz. M/s. Land Mark Fiscal Pvt. Ltd., therefore, the A.O had rightly held the said amount as an unexplained cash credit u/s.68 of the Act, which thereafter, had rightly been upheld by the CIT(Appeals). 9. We have in the backdrop of the contentions of the Ld. authorized representatives of both the parties given a thoughtful consideration to the issue in hand, i.e., sustainability of the addition of Rs.44.75 lacs (supra) made by the A.O u/s.68 of the Act. As is discernible from the records, the share applicant company viz. M/s. Land Mark Fiscal Pvt. Ltd. had made an investment of Rs.44.75 lacs towards share application money with the assessee company out of its bank A/c. No.498601010035300 with Union Bank of India, Branch : Korba. On a careful perusal of the aforesaid bank account of the share applicant company, we find that the funds therein available were primarily sourced out of the amounts which were credited in its account through RTGS or transfers. Ostensibly, it is not the case of the department that the source of the investment made by the share applicant company was in any way out of tainted funds on the basis of which it could be inferred that the unaccounted money of the assessee had been routed back to its coffers in the garb of share application money. In fact, we find that the aforesaid material aspect had absolutely been lost sight of by the A.O who had drawn adverse inferences qua the creditworthiness of the share applicant company, for the reason that its lowly pitched returned 10 Indus Udyog & Infrastructure Private Limited Vs. ITO, Ward-4(1) ITA No. 36/RPR/2018 income as well as weak financials did not inspire much of confidence as regards its creditworthiness. We are unable to persuade ourselves to concur with the very basis adopted by the A.O for drawing adverse inferences qua the authenticity of the transaction in question. We, say so, for the reason that now when the investment of Rs.44.75 lacs (supra) made by the share applicant company had been made out of its duly disclosed sources, therefore, the A.O without placing on record any material which would have otherwise proved to the contrary could not have justifiably drawn adverse inferences as regards the authenticity of the transaction in question. 10. On the same basis, we are of a strong conviction that now when there is no whisper in the orders of the lower authorities as regards the genuineness of the source out of which share applicant company had made the investment in question, therefore, there was no justification on their part in dubbing the transaction in question, i.e., receipt of share application money as an unexplained cash credit u/s.68 of the Act. Rather, a careful perusal of the bank account of the share applicant company by no means justify the dubbing of the amount of Rs.44.75 lacs (supra) transferred to the assessee company as an unexplained cash credit u/s.68 of the Act in the latter hands. On the basis of our aforesaid deliberations, we are of the considered view that now when the assessee had duly discharged the primary onus that was cast upon it as regards 11 Indus Udyog & Infrastructure Private Limited Vs. ITO, Ward-4(1) ITA No. 36/RPR/2018 proving the source of the source of the share applicant company, which we may reiterate (supra) had not been doubted by the A.O, therefore, there was no justification in treating the amount of Rs.44.75 lacs (supra) as an unexplained cash credit u/s.68 of the Act. 11. Apart from that, we find substance in the claim of the Ld. AR that now when the financial credibility of the share applicant company had been looked into and accepted by the A.O while framing of the respective assessments in the assessee’s own case for A.Y.2012-13, A.Y.2015-16 and A.Y.2017-18, therefore, without placing on record any material which would prove to the contrary and justify drawing of a contrary view during the year under consideration i.e. A.Y.2014-15, the A.O could not have adopted an inconsistent view and drawn adverse inferences as regards its financial credibility qua the transaction of making an investment of Rs.44.75 lacs (supra) towards share application money with the assessee company during the year under consideration. We, say so, for the reason that the respective investments made by the share applicant company in question with the assessee company, i.e., in the form of share application money and advance of unsecured loans had after necessary deliberations been accepted by the A.O while framing of the respective scrutiny assessments in the case of the assessee company for A.Y.2012-13, A.Y.2015-16 and A.Y.2017-18, as under: 12 Indus Udyog & Infrastructure Private Limited Vs. ITO, Ward-4(1) ITA No. 36/RPR/2018 Sl. No. A.Y. Date of receipt of share application Amount of share application receipt Mode of receipt 1. 2012-13 16.12.2011 18.01.2012 25.01.2012 27.02.2012 10,00,000 35,00,000 10,00,000 5,50,000 Cheque Total 60,50,000/- Accepted by the A.O vide order passed u/s.143(3) dated 12.11.2014 2. 2015-16 (i) 1,25,000 shares @ Rs.60/- per share ( face value of Rs.10/- per share and share premium of Rs.50/- per share) were allotted to M/s. Land Mark Fiscal Pvt. Ltd. against share application money that was received during earlier FYs. (ii) Unsecured loan of Rs.5,28,04,000/- raised by M/s. Land Mark Fiscal Pvt. Ltd. ( out of which, an amount of Rs.44 lacs was repaid during the year) Accepted by the A.O vide order passed u/s.143(3) dated 05.12.2017 3. 2017-18 (i) 4,70,588 shares @85/- per share ( face value of Rs.10/- per share and share premium of Rs.75/- per share) were allotted to M/s. Land Mark Fiscal Pvt. Ltd. Accepted by the A.O vide order passed u/s.143(3) dated 16.12.2019 Also, we find that the assessment in the case of share applicant company viz. M/s. Land Mark Fiscal Pvt. Ltd. for A.Y.2017-18 was framed u/s.143(3) dated 14.11.2019 wherein after, inter alia, examining the loan/advances and investments made by the said investor company the returned income was accepted after being subjected to minuscule addition, 13 Indus Udyog & Infrastructure Private Limited Vs. ITO, Ward-4(1) ITA No. 36/RPR/2018 Page 67-68 of APB, which fact in itself supports the claim of the assessee that the share applicant company had the financial credibility to make an investment of Rs.44.75 lacs (supra) towards share application money under consideration. 12. Considering the aforesaid factual position, we are of the considered view that not only the assessee by placing on record supporting documentary evidence had discharged the primary onus that was cast upon it as regards proving the identity and creditworthiness of the share applicant company a/w. genuineness of the transaction, but in fact the acceptance of the latters creditworthiness qua the substantial investments which were made by it in the assessee company, both in preceding and succeeding years, which after necessary vetting had been accepted by the department while framing of the respective assessments u/s.143(3) for the said years, i.e., A.Y.2012-13, A.Y.2015-16 and A.Y.2017-18 further fortifies the assessee’s claim of having received genuine share application money of Rs.44.75 lacs (supra) during the year under consideration. 13. Also, the very fact that though the Pr. CIT, Raipur-1 had vide his SCN, dated 15.03.2021 issued u/s.263 of the Act sought to revise the order passed by the A.O u/s.143(3) dated 05.12.2017 for A.Y.2015-16, for the reason that he had without verifying the genuineness of the loan of Rs.5.28 crore that was raised by the assessee from M/s. Land Mark Fiscal 14 Indus Udyog & Infrastructure Private Limited Vs. ITO, Ward-4(1) ITA No. 36/RPR/2018 Pvt. Ltd. (supra) accepted the same, but thereafter had after considering the reply of the assessee dated 19.03.2021 not proceeded any further with the purported action therein further supports the assessee’s claim. We, say so, for the reason that now when the advancing of a substantial loan of Rs.5.28 crore (supra) by the investor company in question had undeniably been accepted by the departmental authorities, i.e., both by the A.O and Pr. CIT in the immediately succeeding year i.e. A.Y.2015-16, therefore, there could be no justification for doubting the creditworthiness of the said investor company for making an investment of Rs.44.75 lacs (supra) towards share application money with the assessee company during the year under consideration. Apropos the observation of the A.O that the notice u/s.133(6) that was issued to the share applicant company was returned unserved by the postal department with the remark “not known”, we are of the considered view that now when the investments made by the said company with the assessee both during the preceding/succeeding years had been accepted by the A.O while framing of the respective assessments for the said years u/s.143(3) of the Act, therefore, the aforesaid adverse observations qua the existence/identity of the share applicant company would not hold the ground any more. 14. In so far the observation of the lower authorities that the lowly pitched returned income a/w. financial statements of the investor company does not inspire much of confidence as regards the authenticity 15 Indus Udyog & Infrastructure Private Limited Vs. ITO, Ward-4(1) ITA No. 36/RPR/2018 of the investment made with the assessee company, we are of the considered view that in absence of any adverse observation by the lower authorities either as regards the source or the source of source out of which the investments over the year were made by the share applicant company, the aforesaid view so arrived at by them cannot be sustained. Accordingly, on the basis of our aforesaid observations, we are of the considered view that as the assessee had duly discharged the primary onus that was cast upon it as regards establishing the identity of the investor company, proving its creditworthiness and establishing the genuineness of the transaction in question i.e. receipt of share application money of Rs.44.75 lacs (supra), which had not been doubted by the A.O by placing on record any material which would prove to the contrary, therefore, no adverse inferences as regards the authenticity of the transaction of receipt of share application money of Rs.44.75 lacs (supra) could have justifiably been drawn by the lower authorities. We, thus, in terms of our aforesaid deliberations set-aside the order of the CIT(Appeals) and vacate the addition of Rs.44.75 lacs made by the A.O. u/s.68 of the Act. Thus, the Ground of appeal No.1 raised by the assessee is allowed in terms of our aforesaid observations. 15. Ground of appeal No.2 being general in nature is dismissed as not pressed. 16 Indus Udyog & Infrastructure Private Limited Vs. ITO, Ward-4(1) ITA No. 36/RPR/2018 16. In the result, appeal of the assessee is allowed in terms of our aforesaid observations. Order pronounced under rule 34(4) of the Appellate Tribunal Rules, 1963, by placing the details on the notice board. Sd/- Sd/- G D PADMAHSHALI RAVISH SOOD (ACCOUNTANT MEMBER) (JUDICIAL MEMBER) रायप ु र/ RAIPUR ; Ǒदनांक / Dated : 14 th December, 2022 SB आदेश कȧ ĤǓतͧलͪप अĒेͪषत / Copy of the Order forwarded to : 1. अपीलाथȸ / The Appellant. 2. Ĥ×यथȸ / The Respondent. 3. The CIT(Appeals), Raipur (C.G) 4. The CIT, Raipur (C.G) 5. ͪवभागीय ĤǓतǓनͬध, आयकर अपीलȣय अͬधकरण, रायप ु र बɅच, रायप ु र / DR, ITAT, Raipur Bench, Raipur. 6. गाड[ फ़ाइल / Guard File. आदेशान ु सार / BY ORDER, // True Copy // Ǔनजी सͬचव / Private Secretary आयकर अपीलȣय अͬधकरण, रायप ु र / ITAT, Raipur.