The Asstt. Commissioner of Income-tax, Amritsar. V. M/s. Great Value Foods, 93, Gr. FI., Amritsar.

ITA 386/ASR/2011

• Counselvise Citation: 38620914 RSA 2011
• Duration Of Justice: 11 month(s) 8 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 01-06-2012
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: DB
• Next Hearing Date: 29-05-2012
• Assessment Year: 2006-2007
• Appeal Filed On: 23-06-2011
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: R L CHHANALIA
• Assessee Lawyers: SSH VIJAY KUMAR UMAT; RAKESH MAGO W CAS
• Keywords: Gift
• Section: 37(1)

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH; AMRITSAR. BEFORE SH. H.S. SIDHU, JUDICIAL MEMBER AND SH. B.P.JAIN, ACCOUNTANT MEMBER I.T.A. NOS. 314, 386 & 387(ASR)/2011 ASSESSMENT YEAR:2005-06, 2006-07 & 2007-08 PAN:AAFFG1704L THE ASSTT. COMMR. OF INCOME TAX VS. M/S. GREAT VALU E FOODS, CIRCLE V, AMRITSAR. LAWRENCE ROAD, AMRITSAR. (APPELLANT) (RESPONDENT) APPELLANT BY: SH. R.L. CHHANALIA, DR RESPONDENT BY:S/SH. VIJAY KUMAR UMAT & RAKESH MAGO W, CAS DATE OF HEARING :29/05/2012 DATE OF PRONOUNCEMENT:01/06/2012 ORDER PER BENCH: THESE THREE APPEALS OF THE REVENUE ARISE FROM THR EE DIFFERENT ORDERS OF THE CIT(A), AMRITSAR, DATED 22.03.2011, 07.04. 2011 & 07.04.2011 FOR THE ASSESSMENT YEARS 2005-06, 2006-07 & 2007-08 RES PECTIVELY. 2. IN ITA NO.314(ASR)/2011, THE REVENUE HAS RAISED FOLLOWING GROUNDS OF APPEAL: I) ON THE FACTS AND CIRCUMSTANCES OF THE CASE, THE LD. CIT(A) AMRITSAR, HAS ERRED IN DELETING THE ADDITION OF RS. 22,97,165/- MADE ON ACCOUNT OF BUSINESS PROMOTION EXPENSES WITH OUT APPRECIATING THE FACTS THAT THE ASSESSEE FAILED TO PRODUCE LIST OF ITA NOS. 314, 386 & 387(ASR)/2011 2 THE RECIPIENTS TO WHOM GIFTS WERE MADE, INSPITE OF THE FACTS THAT SUFFICIENT OPPORTUNITIES WERE PROVIDED. II) ON THE FACTS AND CIRCUMSTANCES OF THE CASE, THE LD. CIT(A) AMRITSAR, HAS ERRED IN DELETING THE ADDITION OF RS. 11 LACS MADE BY THE ASSESSING OFFICER WITHOUT APPRECIATING THE F ACTS THAT THE ASSESSEE COULD NOT PRODUCE ANY RECORD/EVIDENCE REG ARDING RENDERING OF SERVICES BY MISRA & MISRA ASSOCIATES. III) ON THE FACTS AND CIRCUMSTANCES OF THE CASE, THE LD. CIT(A) AMRITSAR, HAS ERRED IN DELETING BOTH THE ABOVE ADDI TIONS WITHOUT APPRECIATING THE FACTS THAT THE ASSESSE FAI LED TO LEAD ANY RECORD, EVIDENCE UNDER BOTH THE HEADS DURING THE CO URSE OF ASSESSMENT PROCEEDINGS. IV) THE APPELLANT CRAVES LEAVE TO AMEND OR ADD ANY OR M ORE GROUNDS OF APPEAL. 3. IN ITA NO.386(ASR)/2011, THE REVENUE HAS RAISED FOLLOWING GROUNDS OF APPEAL: I. ON THE FACTS AND CIRCUMSTANCES OF THE CASE, THE LD. CIT(A), HAS ERRED IN DELETING THE ADDITION OF RS.16,50,000/- MA DE BY THE A.O. ON ACCOUNT OF DISALLOWANCE UNDER THE HEAD LEGA L & PROFESSIONAL EXPENSES REPRESENTING SUCH PAYMENTS MA DE TO M/S. MISHRA & MISHRA ASSOCIATES, LUCKNOW (AMOUNTING TO RS.14,50,000/-) AND TO M/S. ANAND SONAMI OF M/S. B ALAJI SALES CORPN. (AMOUNTING TO RS.2,00,000/-). THE LD. CIT(A) HAS FAILED TO APPRECIATE THAT THE A SSESSEE DID NOT PRODUCE ANY CORRESPONDENCE/RECORDS REGARDING D EFATING OF ADVISORY SERVICES AND RENDERING OF SERVICES BY THE SAID M/S. MISHRA & MISHRA ASSOCIATES AND M/S. ANAND SONAMI OF M/S. BALAJI SALES CORPN. ON ACCOUNT OF PROCUREMENT OF BU SINESS OF THE ASSESSEE. THE LD. CIT(A) HAS FAILED TO APPRECIATE THAT THE A O HAS DISALLOWED RS.50,000/- OUT OF TOTAL CLAIM OF RS.12, 80,834/- UNDER THE HEAD BUSINESS PROMOTION EXPENSES AS THE ASSESSEE FAILED TO PRODUCE LIST OF THE RECIPIENTS TO WHOM GI FTS WERE MADE. ITA NOS. 314, 386 & 387(ASR)/2011 3 MOREOVER, THE EXPENSES ARE NOT VERIFIABLE AND HAVE BEEN CLAIMED ON THE BASIS OF SELF MADE VOUCHERS. II. ON THE FACTS AND CIRCUMSTANCES OF THE CASE, THE LD. CIT(A) AMRITSAR, HAS ERRED IN DELETING THE ABOVE ADDITION WITHOUT APPRECIATING THE FACTS THAT THE ASSESSEE FAILED TO LEAD ANY RECORD/EVIDENCE UNDER BOTH THE HEADS DURING THE COU RSE OF ASSESSMENT PROCEEDINGS. THE LD. CIT(A) HAS FAILED TO APPRECIATE THAT THE AS SESSEE DID NOT PRODUCE ANY CORRESPONDENCE/RECORDS REGARDING D EFATING OF ADVISORY SERVICES AND RENDERING OF SERVICES BY THE SAID M/S. MISHRA & MISHRA ASSOCIATES ON ACCOUNT OF PROCUREMEN T OF BUSINESS OF THE ASSESSEE. III. APPELLANT CRAVES LEAVE TO AMEND OR ADD ANY OR MORE GROUNDS OF APPEAL. 4. IN ITA NO.387(ASR)/2011, THE REVENUE HAS RAISED FOLLOWING GROUNDS: I. ON THE FACTS AND CIRCUMSTANCES OF THE CASE, THE LD. CIT(A) HAS ERRED IN DELETING THE ADDITION OF RS.50,000/- MADE BY THE AO ON ACCOUNT OF DISALLOWANCE UNDER BUSINESS PROMOTION EX PENSES. II) ON THE FACTS AND CIRCUMSTANCES OF THE CASE, THE LD. CIT(A) HAS ERRED IN DELETING THE ADDITION OF RS.22,61,000/- MA DE BY THE AO ON ACCOUNT OF DISALLOWANCE UNDER THE HEAD LEGAL & P ROFESSIONAL EXPENSES REPRESENTING SUCH PAYMENTS MADE TO M/S. MI SHRA & MISHRA ASSOCIATES, LUCKNOW. III) ON THE FACTS AND CIRCUMSTANCES OF THE CASE, THE LD. CIT(A) HAS ERRED IN DELETING BOTH THE ABOVE ADDITIONS WITHOUT APPRECIATING THE FACTS THAT THE ASSESSEE FAILED TO LEAD ANY REC ORD/EVIDENCE UNDER BOTH THE HEADS DURING THE COURSE OF ASSESSMEN T PROCEEDINGS. IV) THE APPELLANT CRAVES LEAVE TO AMEND OR ADD ANY OR M ORE GROUNDS OF APPEAL. ITA NOS. 314, 386 & 387(ASR)/2011 4 5. FIRST OF ALL, WE TAKE UP APPEAL OF THE REVENUE I N ITA NO.314(ASR)/2011 FOR THE ASSESSMENT YEAR 2005-06. T HE BRIEF FACTS IN GROUND NO.1 ARE THAT THE ASSESSEE HAD CLAIMED THE B USINESS PROMOTION EXPENDITURE AMOUNTING TO RS. 30,04,175/- AND EXPEND ITURE OF RS.22,97,165/- HAD BEEN INCURRED IN THE MONTH OF NOVEMBER, 2004. T HE ASSESSEE WAS REQUIRED TO EXPLAIN THE SAID EXPENDITURE. THE ASSES SEE SUBMITTED ITS EXPLANATION VIDE LETTER DATED 20.06.2007 THAT THE S AID EXPENDITURE HAD BEEN INCURRED ON DIWALI FESTIVAL WHEN VARIOUS GIFTS AND SWEETS WERE DISTRIBUTED TO THE SUPPLIERS OF RAW MATERIALS AND ALL THE BUSIN ESS ASSOCIATES AND BUSINESS CONTACTS ETC. THE NAME WISE DETAILS OF THE DIWALI D ISTRIBUTION IS NOT KEPT. THE AO BEING NOT SATISFIED WITH THE EXPLANATION OF THE ASSESSEE CONSIDERED THAT THE SAID EXPENSES HAVE BEEN INCURRED ON PAYMEN TS MADE IN KIND TO VARIOUS OFFICIALS OF THE GOVERNMENT AGENCIES IN THE FORM OF DIWALI GIFTS AND AS PER EXPLANATION TO SECTION 37(1), THE SAID EXPE NDITURE IS PROHIBITED BY LAW AND THEREFORE, NO DEDUCTION U/S 37(1) OF THE AC T CAN BE ALLOWED. ACCORDINGLY, THE AO DISALLOWED THE SAID EXPENDITURE . 5.1. BEFORE THE LD. CIT(A), IT WAS ARGUED AND SUBMI TTED THAT THE ASSESSEE HAD STARTED THE BUSINESS IN THE MIDDLE OF FEBRUARY, 2004 AND ASSESSEE FOR THE ASSESSMENT YEAR 2004-05 HAD DECLARED AN INCOME OF R S.3,33,29,720/-. DURING THE IMPUGNED YEAR, THE ASSESSE HAD DECLARED AN INCOME OF ITA NOS. 314, 386 & 387(ASR)/2011 5 RS.29,07,28,925/-. THE BUSINESS PROGRESS IN SUCH A SHORT PERIOD IS APPRECIABLE AND THE EXPENDITURE INCURRED HAS TO BE CONSIDERED IN THAT BACKGROUND. THE EXPENDITURE WAS INCURRED ON DIWALI DISTRIBUTION AS SUBMITTED BEFORE THE AO AND THE SAME EXPENDITURE HA D NOT BEEN INCURRED FOR ANY EXPENDITURE FOR ANY PURPOSE WHICH WAS AN OFFENC E OR PROHIBITED BY LAW. THE EXPENDITURE IS NEITHER UNREASONABLE NOR EXCESS IVE BY CONSIDERING LARGE VOLUME OF BUSINESS AND THE FAST PROGRESS OF BUSINES S. THERE IS NO EVIDENCE ON RECORD THAT ANY PART OF EXPENDITURE INCURRED IS PROHIBITED BY LAW. LAW DOES NOT OBLIGE THE ASSESSEE TO SEEK ANY PERMISSION OR APPROVAL FOR LAWFUL EXPENSES INCURRED FOR THE PURPOSE OF BUSINESS. THE LD. CIT(A) AFTER APPRECIATING THE CONTENTION OF THE ASSESSEE BY CON SIDERING THE INCREASE OF THE SALES MANIFOLD AND BETTER TRADING RESULTS AND THE EXPENSES HAVING BEEN INCURRED IN THE PRECEDING YEAR AS WELL, THESE EX PENSES INCURRED ON SUPPLIERS OF GOODS FOR TIMELY AND QUALITY PRODUCTS ARE CUSTOMARY & HAVE BEEN INCURRED WHOLLY AND EXCLUSIVELY FOR BUSINESS P URPOSES AND TO ENSURE MAINTENANCE OF GOOD REPUTATION AND RELATIONS IN A S MOOTH AND CONSISTENT MANNER, DELETED THE ADDITION MADE BY THE A.O. 6. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE FACTS OF THE CASE. WE CONCUR WITH THE VIEWS OF THE LD. CIT(A) THAT THE ASSESSEE HAD INCURRED EXPENSES FOR THE PURPOSE OF BUSINESS AND TO MAINTAI N CORDIAL RELATIONS WITH ITA NOS. 314, 386 & 387(ASR)/2011 6 THE SUPPLIERS AND OTHER PERSONS AND TO MAINTAIN GO OD BUSINESS REPUTATION AND TO MEET THE MARKET COMPETITION. ALSO THERE IS NO DISPUTE OF HAVING INCURRED EXPENDITURE WHICH HAVE BEEN ARGUED TO HAVE BEEN INCURRED BY MAKING ACCOUNT PAYEE CHEQUES FOR PURCHASING THE SAI D GIFTS. NO SUCH EXPENDITURE, WHICH HAS BEEN PROHIBITED BY LAW, HAS BEEN BROUGHT ON RECORD BY THE AO AND IN THE FACTS AND CIRCUMSTANCES OF TH E CASE, SUCH EXPENSES BY TAKING THE VOLUME OF THE TURNOVER AND THE INCOME DE CLARED BEING SECOND YEAR OPERATION OF THE ASSESSEES BUSINESS, THE EXPE NDITURE INCURRED IS REASONABLE. IN VIEW OF THE ABOVE DISCUSSIONS, WE FI ND NO INFIRMITY IN THE ORDER OF THE LD. CIT(A), WHO HAS RIGHTLY DELETED TH E ADDITION SO MADE. THUS, THIS GROUND OF THE REVENUE IS DISMISSED. 7. AS REGARDS GROUND NO.2, THE BRIEF FACTS ARE THAT THE ASSESSEE HAD INCURRED THE EXPENDITURE OF RS. 11 LACS I.E. RS. 8 LACS BY PAYMENT TO M/S. MISHRA & MISHRA ASSOCIATES AND RS. 3 LACS TO MR. ANAND SOMANI OF M/S. BALAJI SALES CORPN. FOR LEGAL AND PROFESSIONAL CHA RGES. THE ASSESSEE HAS NOT PRODUCED ANY CORRESPONDENCE REGARDING DRAFTING OF S UCH ADVISORY SERVICES BY M/S. MISHRA & MISHRA ASSOCIATES. THE AGREEMENTS INCLUDING PARTNERSHIP DEEDS ARE SILENT ABOUT ANY CONTRIBUTION BY M/S. MIS HRA & MISHRA ASSOCIATES. WITH RESPECT TO LIASON WORK BY M/S. BALAJI SALES C ORPN., THE AO OBSERVED THAT NO SUCH LIASONING IS REQUIRED BY ANY MIDDLEME N FOR THE CONTRACTS OF THE ITA NOS. 314, 386 & 387(ASR)/2011 7 GOVERNMENT SINCE TENDERS ARE ALLOTTED ON THE BASIS OF COMPETITIVE BIDS. THE AO ACCORDINGLY DISALLOWED RS.11,00,000/- AND ADDED TO THE INCOME OF THE ASSESSEE BEING EXPENSES NOT INCURRED WHOLLY AND EXC LUSIVELY FOR THE PURPOSES OF THE BUSINESS OF THE ASSESSEE. 7.1. BEFORE THE LD. CIT(A), IT WAS SUBMITTED THAT M /S. MISHRA & MISHRA ASSOCIATES WERE APPOINTED FOR PROVIDING PROFESSION AL SERVICES AS WELL AS CONSULTATION ETC. FOR DOCUMENTATION, CONSULTATION, LEGAL OPINIONS AND OTHER ADVISORY SERVICES FOR DRAFTING, REVIEWING AND FINA LIZATION OF TENDER RELATED DOCUMENTS IN VARIOUS STATES LIKE ANDHRA PRADESH, PU NJAB, UTTAR PRADESH ETC. THEY WERE ENGAGED KEEPING IN VIEW THE BUSINESS EXP EDIENCY. THE PAYMENT HAS BEEN MADE TO THEM AFTER DEDUCTING TDS. COPY OF THE BILL HAS ALSO BEEN PLACED ON RECORD. THE FIRM WAS BASED AT LUCKNOW, BE ING CAPITAL OF U.P. AND THEIR SERVICES WERE ALWAYS REQUIRED FOR DEALING WIT H THE G.P. GOVT. AS REGARDS THE PAYMENT TO M/S. BALAJI SALES CORPN. KOT LA MUBARARAHUR, NEW DELHI, THE SERVICES RENDERED WERE FOR MARKETING OF THE FIRM IN VARIOUS STATES, SUCH AS ANDHRA PRADESH, HARYANA, PUNJAB AND UTTAR PRADESH ETC. THE SAID FIRM SUCCEEDED TO GET CONTRACTS IN ANDHRA PRAD ESH AND U.P. AND BECAUSE OF THE SAID, THE ASSESSEE HAS BEEN ABLE TO ACHIEVE HUGE VOLUME OF WORK. THE PAYMENT HAS BEEN MADE THROUGH CHEQUE AFTE R DEDUCTING TDS. COPIES OF THE BILLS HAVE BEEN PLACED ON RECORD. THE LD. CIT(A) AFTER ITA NOS. 314, 386 & 387(ASR)/2011 8 CONSIDERING THE EXPLANATION OF THE ASSESSEE OBSERVE D THAT THE A.O. HAD MADE THE ADDITION WITHOUT BRINGING ON RECORD ANY CONCRET E ADVERSE MATERIAL ESTABLISHING THE FALSEHOOD OF THE CLAIM OF THE ASSE SSEE. THE EXPENSES ARE DULY VOUCHED, WHICH HAVE BEEN PAID THROUGH CHEQUES AFTER DEDUCTION AND DEPOSITING THE TAX AT SOURCE. ACCORDINGLY, THE LD. CIT(A) ALLOWED THE CLAIM OF THE ASSESSEE. 8. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE FACTS OF THE CASE. WE CONCUR WITH THE VIEWS OF THE LD. CIT(A) THAT THE AO HAD MADE THE ADDITION WITHOUT BRINGING ON RECORD ANY ADVERSE MAT ERIAL ABOUT THE CLAIM OF THE ASSESSEE. THE AMOUNT HAS BEEN PAID THROUGH CHEQ UES AFTER DEDUCTING TAX AT SOURCE. COPIES OF THE BILLS AND TDS CERTIFICATE ARE ON RECORD. MOREOVER, THE AO CAN NOT SIT IN THE ARMS OF THE BUSINESSMAN A ND CANNOT DECIDE HOW TO RUN THE BUSINESS. THIS IS A WELL SETTLED LEGAL PRO POSITION LAID DOWN BY VARIOUS COURTS OF LAW. IN THE FACTS AND CIRCUMSTANC ES OF THE CASE, WE FIND NO INFIRMITY IN THE ORDER OF THE LD. CIT(A), WHO HAS R IGHTLY DELETED THE ADDITION SO MADE. THUS, GROUND NO.2 OF THE REVENUE IS DISMIS SED. 9. GROUND NOS. 3 & 4 OF THE REVENUE ARE GENERAL IN NATURE AND THEREFORE, DO NOT REQUIRE ANY ADJUDICATION. ITA NOS. 314, 386 & 387(ASR)/2011 9 10. AS REGARDS APPEAL OF THE REVENUE IN ITA NO.386( ASR)/2011 FOR THE ASSESSMENT YEAR 2006-07, THE FACTS AND GROUNDS OF A PPEAL ARE IDENTICAL TO THE FACTS IN REVENUES APPEAL IN ITA NO.314(ASR)/2011 FOR THE A.Y. 2005-06. THE AO IN THE PRESENT APPEAL MADE A DISALLOWANCE OF RS.14,50,000/- BEING PAYMENTS MADE TO M/S. MISHRA & MISHRA ASSOCIATES AN D RS.2,00,000/- TO M/S. BALAJI SALES CORPN. THE FACTS IN THE PRESENT C ASE ARE IDENTICAL TO THE FACTS AS IN ASSESSEES OWN CASE FOR THE ASSESSMENT YEAR 2005-06. THE LD. CIT(A) DELETED THE ADDITION ON IDENTICAL FACTS FOR THE ASSESSMENT YEAR 2005-06. 11. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE FACTS OF THE CASE. SINCE THE ISSUE INVOLVED IN THE PRESENT APPEAL IS I DENTICAL TO THE FACTS IN ASSESSEES OWN APPEAL FOR THE ASSESSMENT YEAR 2005- 06, WHICH HAS BEEN DECIDED BY US HEREINABOVE IN ITA NO.314(ASR)/2011 B Y OUR ORDER OF EVEN DATE. FOLLOWING THE SAME, THE APPEAL OF THE REVENUE IN ITA NO.386(ASR)/2011 IS DISMISSED. 12. GROUND NOS. 2 & 3 ARE GENERAL IN NATURE AND THE REFORE, DO NOT REQUIRE ANY ADJUDICATION. ITA NOS. 314, 386 & 387(ASR)/2011 10 13. NOW WE TAKE UP APPEAL OF THE REVENUE IN ITA NO. 387(ASR)/2011 FOR THE ASSESSMENT YEAR 2007-08. THE FACTS IN GROUND NO .1 ARE IDENTICAL TO THE FACTS IN ASSESSES OWN APPEAL FOR THE ASSESSMENT YE AR 2005-06 ON ACCOUNT OF DISALLOWANCE OF BUSINESS PROMOTION EXPENSES. THE AO HAS MADE DISALLOWANCE OF RS.50,000/- OUT OF TOTAL CLAIM OF R S.12,80,834/-, WHICH HAS BEEN DELETED BY THE LD. CIT(A). 14. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE FACTS OF THE CASE. SINCE THE FACTS IN THE PRESENT APPEAL ARE IDENTICAL TO THE FACTS IN ASSESSEES OWN CASE FOR THE ASSESSMENT YEAR 2005-06 WHICH HAS BEEN DECIDED BY US HEREINABOVE IN ITA NO.314(ASR)/2011 WHERE THE REVEN UES APPEAL HAS BEEN DISMISSED. FOLLOWING THE SAME WE DISMISS GROUND NO. 1 OF THE REVENUE. 15. IN GROUND NO.2, THE FACTS ARE IDENTICAL TO THE FACTS IN ASSESSEES OWN CASE IN ITA NO.314(ASR)/2011 FOR THE ASSESSMENT YEA R 2005-06 BEING PAYMENT MADE TO M/S. MISHRA & MISHRA ASSOCIATES. TH E AMOUNT DISALLOWED IN THE PRESENT CASE IS RS.22,61,000/-, WHICH HAS B EEN DELETED BY THE LD. CIT(A). 16. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE FACTS OF THE CASE. SINCE THE FACTS IN THE PRESENT CASE ARE IDENTICAL TO THE FACTS IN ASSESSEES OWN ITA NOS. 314, 386 & 387(ASR)/2011 11 APPEAL IN ITA NO.314(ASR)2011 FOR THE A.Y. 2005-06, WHICH HAS BEEN DECIDED BY US HEREINABOVE, WHERE THE REVENUES APPE AL HAS BEEN DISMISSED. FOLLOWING THE SAME WE DISMISS GROUND NO.2 OF THE RE VENUE. 17. GROUNDS NO. 3 & 4 ARE GENERAL IN NATURE AND THE REFORE, DO NOT REQUIRE ANY ADJUDICATION. 18. IN THE RESULT, THE APPEALS OF THE REVENUE IN IT A NOS. 314, 386 & 387(ASR)/2011 ARE DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 1ST JUNE, 2012. SD/- SD/- (H.S. SIDHU) (B.P. JAIN) JUDICIAL MEMBER ACCOUNTANT MEMBER DATED: 1ST JUNE, 2012 /SKR/ COPY OF THE ORDER IS FORWARDED TO : 1. THE ASSESSEE:M/S. GEAT VALUE FOODS, LAWRENCE ROAD, AMRITSAR. 2. THE ACIT RANGE-IV, AMRITSAR. 3. THE CIT(A), ASR. 4. THE CIT, ASR. 5. THE SR DR, ITAT, AMRITSAR TRUE COPY BY ORDER (ASSISTANT REGISTRAR) INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH : AMRITSAR.