Appeal details
Counselvise Citation
[2023] 101 COUNSELVISE.COM (IT) 9463 (ITAT-AHMEDABAD)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
7 month(s) 5 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
19-12-2023
Appeal Filed By
Department
Order Result
Dismissed
Bench Allotted
B
Next Hearing Date
13-12-2023
Assessment Year
2019-2020
Appeal Filed On
14-05-2023
Judgement Text
IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER & SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER I .T .A . N o . 3 7 4/ A h d /2 0 23 ( A s se ss m e nt Y e a r : 20 19- 20 ) I nc o m e Ta x O f fic er ( E) , B h a v n ag a r , G uj a r a t - 3 64 00 1 vs . R a mj i M a nd i r Re li g io u s An d C h ar i ta b l e Tr u s t , B u dh e l, D ho li v a v, B h av n ag ar A la nd R o a d P o s t , B ud h el , Ta l : B h a v na ga r- 3 64 0 0 2 [ P A N N o . AA D T R 0 38 1C ] (Appellant) .. (Respondent) Appellant by : Shri Sudhendu Das, CIT DR Respondent by: Shri Tushar Hemani, Sr. Advocate & Shri Parimalsinh B Parmar, A.R. D at e of H ea r i ng 14.12.2023 D at e of P r o no u n ce me nt 20.12.2023 O R D E R PER SIDDHARTHA NAUTIYAL, JM: This appeal has been filed by the Revenue against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short “Ld. CIT(A)”), National Faceless Appeal Centre, (in short “NFAC”), Delhi in DIN & Order No: ITBA/NFAC/S/250/2022-23/1050288250(1) vide order dated 01.03.2023 passed for the Assessment Year 2019-20. 2. The Revenue has raised the following grounds of appeal:- “(i) Whether in the facts and in the law, the Ld.CIT(A), !s right in holding that not filing of Form No.10 and / or 10B within due date as prescribed under the Act, is a procedural lapse, ignoring the law laid down by the Hon'ble Supreme Court in the case of M/s. Wipro Ltd. in the Civil Appeal No.1449 of 2022, wherein the Hon'ble Apex Court has held that exemption provisions are to be strictly arid literally complied with and the same cannot be construed as procedural requirement. ITA No. 374/Ahd/2023 ITO vs. Ramji Mandir Religious & Charitable Trust Asst. Year –2019-20 - 2 - (ii) Whether in the facts and in law, the Ld.CIT(A) is right in directing the Assessing Officer to allow the claim of assessee u/s.11 of the Act, after due verification, in view of his finding that not filing of Form No.10 and /or 10B within due date as prescribed under the Act is merely a procedural lapse. (iii) Whether in the facts and in law, the Ld. CIT(A) is right in directing the Assessing Officer to allow the claim of assessee u/s.11 of the Act, in contradiction to his finding while the Ground No.1 raised by the assessee, after holding that the CPC was well within the power to make such adjustment as the assessee has not filed the Form No.10B within the due date prescribed under the Act. (iv) The appellant crave leave to add, amend, delete or modify ground of appeal before the finalization of appeal.” 3. The brief facts of the case are that the assessee filed original return of income on 25.09.2019 wherein exemption of Rs. 2.40 lakhs was claimed under Section 11(2) of the Act. Thereafter, assessee filed revised return of income on 13.03.2020 wherein exemption of Rs. 1,73,00,000/- was claimed under Section 11(2) of the Act. The Assessing Officer passed intimation under Section 143(1) of the Act on 26.08.2020 whereby exemption under Section 11(2) of the Act was restricted to Rs. 2.40 lakhs as per the original return of income, as against the claim of Rs. 1,73,00,000/- as per the revised return of income, broadly on the ground that assessee had not filed “ITR” and “Form 10” within the due date prescribed under Section 139(1) of the Act. 4. In appeal, Ld. CIT(Appeals) allowed the appeal of the assessee with the following observations: “4.3.1 As per section 12A, the appellant had to fulfill two conditions to avail the benefits of exemption u/s 11 & 12: (a) to file return of income under section 139(4A) within the time specified in that section. (b) to file Form 10B before the "specified date" as per section 44AB. ITA No. 374/Ahd/2023 ITO vs. Ramji Mandir Religious & Charitable Trust Asst. Year –2019-20 - 3 - 4.3.2 In this regard, the appellant had to file its return of income as per the provisions of section 139(4A) which are reproduced hereunder: "Section 139...... [4A] Every person in receipt of income derived from property held under trust or other legal obligation wholly for charitable or religious purposes or in part only for such purposes, or of income being voluntary contributions referred to in sub-clause [iia] of clause [24] of section 2, shall, if the total income in respect of which he is assessable as a representative assessee [the total income for this purpose being computed under this Act without giving effect to the provisions of sections 11 and 12] exceeds the maximum amount which is not chargeable to income-tax, furnish a return of such income of the previous year in the prescribed form and verified in the prescribed manner and setting forth such other particulars as may be prescribed and all the provisions of this Act shall, so far as may be, apply as if it were a return required to be furnished under subsection [1]." Hence, as per the section 139(4A), the time limit to file return of income is the time limit to file return of income u/s 139(1). Further, for A.Y. 2019-20, the extended due date to file return of income was 31.10.2019 and the appellant filed its return of income on 13.03.2020 i.e. belated return. However, the appellant in its submission contended that the return filed on 13.03.2020 is revised return and the original return of income was filed u/s 139(4A) on 25.09.2019 i.e. before the extended due date 31.10.2019. The above fact is also confirmed from the CPC 2.0 portal where it can be seen that the appellant filed original return of income was filed on 25.09.2019 and the same was revised vide return filed u/s 139(5) on 13.03.2020. Hence, the claim of CPC that the appellant filed belated return of income, is factually incorrect. 4.3.3 The appellant also had to file Form 10B to avail the benefits of exemption u/s 11 & 12 before the "specified date" as per section 44AB. The specified date to file Form 10B is mentioned in explanation (ii) of section 44AB which is as under: "[ii "specified date", in relation to the accounts of the assesses of the previous year relevant to an assessment year, means[date one month prior to][the due date for furnishing the return of income under sub-section (1) of section 139].]]" For the A.Y. 2019-20 the due date for furnishing the return of income u/s 139(1) was 31.10.2019. Hence, the due date to file Form 10B would be 01.10.2019. However, the appellant filed Form 10B for A.Y. 2019-20 on 13.03.2020 i.e. belated. 4.3.4 The question of delayed filing of audit report, after the return of income has been filed, has been scrutinized by various courts of law. It has generally been held that if the assessee submits the audit report before the assessing officer during the assessment proceedings, the assessee should not be denied the benefit of claiming exemption under section 11 and 12. Some of the case laws are detailed below. ITA No. 374/Ahd/2023 ITO vs. Ramji Mandir Religious & Charitable Trust Asst. Year –2019-20 - 4 - (i) In the case of CIT vs. Rai Bahadur Bissesswarlal Motilal Malwasie Trust (1992) 195 ITR 825, the Calcutta High Court has affirmed that the requirement of filing the audit report with the return is merely a procedural requirement, and that exemption cannot be denied so long as the report is available to the assessing officer before the completion of assessment. (ii) In the case of Calcutta Management Association vs. VTO (1992) 42ITD 62, the Calcutta bench of the Tribunal held that the Audit Report can even be filed at the time of appeal before the Commissioner (Appeals). (iii) On a similar issue the Hon'ble Supreme Court in the case of CIT vs. Nagpur Hotel Owners Association [2001] 114 Taxman 255 (SC) held "It is abundantly clear from the wordings of sub-section (2) of section 11 that it is mandatory for the person claiming the benefit of section 11 to intimate to the assessing authority the particulars required, under rule 17 in Form No. 10. If during the assessment proceedings the Assessing Officer does not have the necessary information, the question of excluding such income from assessment does not arise at all. As a matter of fact, the benefit of excluding this particular part of the income from the net of taxation arises from section 11 and is subject to the conditions specified therein. Therefore, it is necessary that the assessing authority must have this information at the time it completes the assessment. In the absence of any such information, it will not be possible for the assessing authority to give the assessee the benefit of such exclusion and once the assessment is so completed, it would be futile to find fault with the assessing authority for having included such income in the assessable income of the assessee. Therefore, even assuming that there is no valid limitation prescribed under the Act and the Rules, even then it is reasonable to presume that the intimation required under section 11 has to be furnished before the assessing authority completes the concerned assessment because such requirement is mandatory and without the particulars of the income, the assessing authority cannot entertain the claim of the assessee under section 11. Therefore, compliance of the requirement of the Act will have to be any time before the assessment proceedings." 4.3.5 In the instant case the appellant/assessee e-filed the Form 10 on 13.03.2020. The above fact is confirmed during the appellate proceedings from CPC 2.0 portal. As per the case laws mentioned above, the Hon'ble Courts took the view that the benefit of exemption should not be denied merely on account of delay in furnishing the audit report and it is permissible for the assessee to produce the audit report at a later stage, either before the AO or the appellate authority. This view has been reiterated by the Hon'ble Court in the recent judgement of Hon'ble Gujarat High Court in the case of Sarvodaya Charitable Trust v. Income Tax Officer. (Exemption) [2021] 125 taxmann.com 75 (Gujarat). 4.3.6 In view of the above discussion, I am of the view that the assessing officer erred in not allowing deduction to the appellant/assessee for the amount accumulated under the provisions of section 11 of the Income Tax Act, 1961. It was ITA No. 374/Ahd/2023 ITO vs. Ramji Mandir Religious & Charitable Trust Asst. Year –2019-20 - 5 - merely a procedural lapse on part of assessee to not file Form 10 alongwith return of income. The appellant/assessee uploaded the audit report at a later stage after filing the return of income. The benefit of exemption under section 11 cannot be denied merely on account of delay in furnishing audit report. Thus, the assessing officer is directed to allow the claim of the appellant after due verification as per the IT. Act, 1961. Hence, grounds no. 2to4raised by the appellant are partly allowed. 4.4 Ground No. 5: This ground relates to the levying of interest u/s 234A, 234B, 234C and 234D which is mandatory and consequential in nature. Hence, ground no. 5 is dismissed. 5. In result the appeal is partly allowed.” 5. The Department is in appeal before us against the aforesaid order passed by Ld. CIT(Appeals) allowing the appeal of the assessee. 6. Before us, the DR submitted that filing of Form 10 is a mandatory requirement and the same needs to be filed within the time prescribed under the Act i.e. before the due date of filing of return of income. The Ld. DR placed reliance on the case of Principal CIT v. Wipro Ltd. 140 Taxman.com 223 (SC) wherein the honourable Supreme Court held that for claiming benefit under Section 10B, both conditions of furnishing declaration to AO in writing and to file same before due date of filing original return of income under Section 139(1), are mandatory in nature, thus, assessee would not be entitled to benefit under Section 10B(8) on non- compliance of twin conditions as provided under Section 10B(8). 7. In response, the Counsel for the assessee submitted cases in support of the contention that filing of Form 10 is a procedural requirement and further, the case of Wipro Limited supra was rendered on its own set of facts, which are distinguishable from the facts of the assessee’s case. In the case of Wipro Limited supra, deduction u/s 10B was claimed in the original return, which was sought to be withdrawn by way of filing of revised return ITA No. 374/Ahd/2023 ITO vs. Ramji Mandir Religious & Charitable Trust Asst. Year –2019-20 - 6 - of income. However, it was submitted before us that in the instant facts, the claim of deduction under Section 11(2) of the Act had been filed by the assessee in the original return of income itself, which was filed by the assessee within the due prescribed date along with the Form 10 and similar claim was also filed in the revised return of income filed by the assessee. In this case, the Assessee filed original' return on 25.09.2019 (before due- date), wherein claim of Rs.2,40,000/- was made u/s 11(2) of the Act and even Form 10 / 10B were filed before due-date. Thus, the requirements of Section 11(2) stand fulfilled. Later, assessee realized that there was an error in the claim u/s 11(2), and therefore, assessee filed "revised return of income" and "revised Form 10 / 10B" on 13.03.2020 i.e. after due-date u/s 139(1) wherein claim u/s 11(2) was revised to Rs.1,73,00,000/-. In such peculiar facts, CPC was not justified in denying claim u/s 11(2) on the count that "Form 10 / 10B was not filed within due-date" since in the present case (i) Original Form 10 / 10B was filed before due-date; (ii) Only revised Form 10 / 10B was filed after due-date; (iii) Such revised Form 10 / 10B was filed on account of error in claim. Under such facts and circumstances, it is not a case of "not filing Form 10 / 10B before the prescribed due-date at all", rather, it is a case of "filing original Form 10 / 10B before the due-date and thereafter, owing to an error which crept in the same, filing of revised Form 10 / 10B after due-date u/s 139(1) of the Act. Accordingly, it was submitted that Ld. CIT(Appeals) has correctly appreciated the facts of the instant case and allowed relief to the assessee in accordance with law. 8. We have heard the rival contentions and perused the material on record. We observe that in the instant facts, it is not a case where the ITA No. 374/Ahd/2023 ITO vs. Ramji Mandir Religious & Charitable Trust Asst. Year –2019-20 - 7 - assessee had not filed Form 10 in the original return of income, before the due date prescribed of filing return of income. It is only a case where the assessee observed that a certain error had crept in the original return of income, wherein the quantum of deduction claimed under Section 11(2) of the Act required correction and accordingly, the assessee filed revised return of income with the higher claim of deduction under Section 11(2) of the Act. It has been held by various Courts that the requirement of filing Form 10 / 10B is merely directory in nature and failure to furnish Form 10 / 10B before due-date prescribed u/s 139(1) of the Act cannot be so fatal so as to deny they very claim of exemption u/s 11(2) of the Act especially when Form 10 / 10B was available on record when the intimation was passed by CPC u/s 143(1) of the Act. The following judicial precedents have reiterated the aforesaid principal I. Association of Indian Panelboard Mfg. - TA 655 of 2022 (Guj); II. DCIT vs. Cryogas Equipment P. Ltd. - ITA 415/Ahd/2020; III. True Sparrow Systems P. Ltd. vs. PCIT - ITA 765/Ahd/2019; IV. Shardaben Education Trust vs. ITO - ITA 2312/Ahd/2018; V. CIT vs. Xavier Kelavani Mandal P. Ltd. - 221 Taxman 43 (Guj); VI. Zenith Processing Mills vs. CIT - 219 ITR 721 (Guj); VII. CIT vs. Mayur Foundation - 274 ITR 562 (Guj); VIII. CIT vs. Gujarat Oil & Allied Industries - 201 ITR 325 (Guj); IX. CIT vs. G. M. Knitting Industries - 376 ITR 456 (SC); X. CIT vs. Web Commerce (India) P. Ltd. - 318 ITR 135 (Del); XI. CIT vs. Contimeters Electricals P. Ltd. - 317 ITR 422 (Del); XII. PCIT vs. Surya Merchants - 387 ITR 105 (Allhabad); ITA No. 374/Ahd/2023 ITO vs. Ramji Mandir Religious & Charitable Trust Asst. Year –2019-20 - 8 - XIII. DIC Fine Chemicals P. Ltd. vs. DCIT - 177 ITD 672 (Kol.); 9. Further, we are also an agreement for the Counsel for the assessee that the case of Wipro Limited supra was rendered on a different set of facts, wherein in the original return of income the assessee had claimed benefit under Section 10B of the Act and thereafter, a revised return of income was filed by the assessee foregoing the claim of benefit of Section 10B of the Act. However, the facts of the instant case are clearly distinguishable for the reason that in both the original return of income as well as the revised return of income, the assessee has taken a consistent stand and has claimed deduction under Section 11(2) of the Act, and further in the original return of income (which was filed within the due prescribed date), Form 10 was duly furnished by the assessee. It was only later when the assessee noticed that the claim of deduction under Section 11(2) of the Act required correction that the assessee filed revised return of income along with Form 10. Therefore, there is a marked distinction between the facts of the Wipro Ltd case supra and the instant facts. Further, observe that Ahmedabad ITAT in the case of DCIT V. CroygasEquipments Private Ltd in ITA number 415/AHD/2020 had also held that the principal of Wipro Limited supra cannot be uniformly applied to all cases and the aforesaid decision was distinguished by the Ahmedabad Tribunal, with the following observations: “6.3 Another notable issue for consideration is that recently the Hon'ble Supreme Court was confronted with the claim of benefit u/s 10B in Pr. CIT v. Wipro Ltd. [2022] 140 taxmann.com 223/288 Taxman 491/446 ITR 1. The assessee furnished original return taking the benefit of section 10B and did not carry forward the loss. Thereafter, a revised return was filed foregoing the claim of deduction u/s 10B. The AO rejected the withdrawal of exemption under section 10B by holding that assessee did not furnish the necessary declaration in writing before due date of filing return of ITA No. 374/Ahd/2023 ITO vs. Ramji Mandir Religious & Charitable Trust Asst. Year –2019-20 - 9 - income, which was an essential requirement for not claiming the benefit of section 10B. The Hon'ble High Court decided the issue in favour of the assessee by holding that the requirement of filing the declaration was mandatory but filing it along with the return of income u/s 139(1) was a directory requirement. The matter was brought by the Revenue before the Hon'ble Supreme Court. The assessee, inter alia, relied on the judgment of the Apex Court in G.M. Knitting Industries (P.) Ltd. (supra). Their Lordships held that the requirement of filing the report in support of deduction u/s 10B was not a directory but a mandatory requirement. It further held that both the conditions of - filing the declaration and filing it before the time limit u/s 139(1) - were mandatory and had to be cumulatively satisfied. Rejecting the reliance on G.M. Knitting Industries (P.) Ltd. (supra), the Hon'ble Supreme Court held that that decision was relevant in the context of deduction provisions and not the exemption provisions as given under Chapter III of the Act. 6.3.1. In our view, the aforesaid decision would not apply to assessee’s set of facts and would not preclude / prohibit the assessee from claiming deduction u/s 10AA of the Act, for the following reasons: (i) Firstly, in the case of Wipro Limited supra, the issue for consideration before the Hon'ble Supreme Court was that in the original return of income, the assessee had claimed deduction under section 10B of the Act, whereas in the revised return filed under section 139(5) of the Act, assessee did not claim deduction under section 10B of the Act, and instead claimed benefit of carry forward of losses. It was in light of these facts that the Hon'ble Supreme Court held that on a plain reading of section 10B(8) of the Act, it is clear that where assessee claimed benefit under section 10B(8) by furnishing declaration in revised return much after due date prescribed under section 139(1), same was to be denied as requirement of furnishing declaration before AO before due date of filing original return under section 139(1) was a mandatory condition not directory. However, notably, there is no such equivalent/similar provision in section 10AA of the Act, which gives an option to the assessee to file a declaration before the due date of return of income under section 139(1) of the Act, to the effect that the provisions of this section may not be made applicable to him, for the impugned assessment year. Therefore, going by the strict language of section, the relevant statutory provisions on which the decision of Wipro was based, were on a different footing. Further, the issue for consideration in the Wipro case is also distinguishable, since in the assessee’s case, it had claimed benefit of deduction u/s. 10AA in the original return of income (and only Form 56F was omitted to be e-filed alongwith return of income), whereas the issue for consideration in Wipro case supra was that once the assessee had claimed benefit of section 10B in the original return of income, whether such benefit could be foregone/withdrawn by filing declaration u/s. 10B(8) of the Act in the revised return of income filed u/s 139 (5) of the Act (and the assessee could, in turn, avail the benefit of carry forward losses in the revised return of income). ITA No. 374/Ahd/2023 ITO vs. Ramji Mandir Religious & Charitable Trust Asst. Year –2019-20 - 10 - (ii) Secondly, the Hon'ble Supreme Court in the case of Wipro Limited held that section 10B of the Act is an “exemption provision” and hence, assessee claiming such exemption has to be “strictly” comply with the exemption provisions. However, notably, the Hon'ble Supreme Court in the case of CIT v. Yokogawa India Ltd 391 ITR 274 (Supreme Court), held that section 10A of the Act is a “deduction provision ” and not an “exemption provision”. Therefore, apparently there seems to be a difference of opinion to whether section 10A/B provisions qualify as “Exemption” or Deduction” provisions. Therefore, since it is well-settled principle of law that deduction provisions, which have been introduced in the Statute to provide incentive to the assessee, should be construed “liberally”, in our considered view, once it is not disputed that the instant set of facts, the assessee claimed the benefit of provisions under section 10AA in the return of income (which in our view is a mandatory/directory requirement), the benefit of section 10AA cannot be denied only on the ground that the assessee could not file Form 56F along with the return of income (being a procedural requirement), especially when Form 56F has been filed by the assessee at the assessment stage when such claim was being considered by the Assessing Officer. (iii) Besides the above, in the case of G. M. Knitting Industries (P.) Ltd. case supra, the Hon'ble Supreme Court further held that even though necessary certificate in Form 10CCB along with return of income had not been filed but same was filed before final order of assessment was made , assessee was entitled to claim deduction under section 80-IB of the Act as well. Therefore, in light of the decision of Yokogawa supra (which is held that section 10A of the Act is a “deduction provision ” not an “exemption provision”) and the decision of G. M. Knitting Industries case supra, which have been rendered on a similar facts as that of the assessee i.e. claim of deduction was made in the original return of income itself, in our view, the ratio laid down in the Wipro Ltd case would not disentitle assessee to claim benefit of section 10AA of the Act, since it has been rendered on a different set of facts. Therefore in our considered view, once such claim has been made in the original return of income and assessee has also furnished Form 56F during the course of assessment proceedings itself, before the assessment was finalized. The assessee should not be denied the benefit of s. 10AA of the Act. It is a well settled principle of law that if there is any ambiguity regarding interpretation of a Statutory provision, an interpretation favourable to the assessee may be taken, especially when we are dealing with Statutory provisions aimed at giving some incentive to the assessee. 6.4 Another aspect for consideration is that whether there is sufficient compliance once assessee has filed the revised Form 56F during the course of assessment proceedings. In the case of M/s. ACN Info-Tech vs. ACIT ITA No. 79/Viz/2017, instead of claiming deduction u/s. 10AA of the Act, the assessee claimed deduction u/s. 10B of the Act in the income tax return. The A.O. rejected the claim on the ground that assessee did not file form 56F along with return of income and had filed form 56G instead. The ld. A.R argued that the AO ought to have allowed the deduction u/s. 10AA since the assessee had filed form 56F during assessment ITA No. 374/Ahd/2023 ITO vs. Ramji Mandir Religious & Charitable Trust Asst. Year –2019-20 - 11 - proceeding which was a pure technical mistake. The Tribunal held that benefit of deduction should not be disallowed as the assessee had duly fulfilled the conditions for claiming exemption u/s. 10AA of the Act. In the case of ITO v. Accentia Technologies 52 taxmann.com 89 (Mum), the Mumbai Tribunal held that deduction under section 10A cannot be denied merely because at time of filing of return, claim had mistakenly been made under section 10B of the Act. The Gujarat High Court in the case of Zenith Processing Mills v CIT 219 ITR 721 (Guj) held that provision of section 80J(6A) to extent it requires furnishing of auditor's report in prescribed form along with return, is directory in nature and not mandatory. Further, assessee can be permitted to produce such report at later stage when question of disallowance arises during course of assessment proceedings. In the instant case, the A.O. has denied s. 10AA benefit on account of an inadvertent error on the part of the assessee in not e- filing Form 56F along-with return of income. We are therefore of the view that there is sufficient compliance if the Form 56F has been filed during the course of assessment proceeding, since there is no material objective to be achieved by the assessee in not e-filing the same, once the same was already available with the assessee. 6.5 In view of the above, we are of the considered view that CIT(A) has not erred in facts and in law in allowing the claim of the assessee that deduction u/s. 10AA of the Act cannot be denied simply on the ground that the assessee did not e-file form 56F along with the return of income, when the assessee furnished form 56F to the ld. Assessing Officer during the assessment proceedings when the claim of deduction u/s. 10AA of the Act was being examined by the ld. Assessing Officer.” 10. Accordingly, in the light of the above facts, the judicial precedents on the subject and the foregoing discussion, we find no infirmity in order of Ld. CIT(Appeals) so as to call for any interference. 11. In the result, the appeal of the Department is dismissed. This Order pronounced in Open Court on 20/12/2023 Sd/- Sd/- (WASEEM AHMED) (SIDDHARTHA NAUTIYAL) ACCOUNTANT MEMBER JUDICIAL MEMBER Ahmedabad; Dated 20/12/2023 TANMAY, Sr. PS TRUE COPY ITA No. 374/Ahd/2023 ITO vs. Ramji Mandir Religious & Charitable Trust Asst. Year –2019-20 - 12 - आदेश क त ल प अ े षत/Copy of the Order forwarded to : 1. अपीलाथ / The Appellant 2. यथ / The Respondent. 3. संबं धत आयकर आय ु त / Concerned CIT 4. आयकर आय ु त(अपील) / The CIT(A)- 5. वभागीय त न ध, आयकर अपील!य अ धकरण, अहमदाबाद / DR, ITAT, Ahmedabad 6. गाड' फाईल / Guard file. आदेशान ु सार/ BY ORDER, उप/सहायक पंजीकार (Dy./Asstt.Registrar) आयकर अपील य अ धकरण, अहमदाबाद / ITAT, Ahmedabad 1. Date of dictation 18.12.2023(Dictated by Hon’ble Member on his Dragon Software) 2. Date on which the typed draft is placed before the Dictating Member 18.12.2023 3. Other Member..................... 4. Date on which the approved draft comes to the Sr. P.S 19.12.2023 5. Date on which the fair order is placed before the Dictating Member for pronouncement .12.2023 6. Date on which the fair order comes back to the Sr. P.S 20.12.2023 7. Date on which the file goes to the Bench Clerk 20.12.2023 8. Date on which the file goes to the Head Clerk.......................................... 9. The date on which the file goes to the Assistant Registrar for signature on the order.......................... 10. Date of Despatch of the Order..........................................
