Appeal details
Counselvise Citation
4022714 RSA 2014
Assessee PAN
Bench
Appeal Number
Duration Of Justice
4 month(s) 10 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
21-05-2014
Appeal Filed By
Department
Order Result
Partly Allowed
Bench Allotted
DB
Assessment Year
2009-2010
Appeal Filed On
10-01-2014
Judgement Text
, A IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BE NCH INDORE , . ., BEFORE : SHRI JOGINDER SINGH, JM & SHRI R.C.SHARMA, AM !' ./ ITA NO.40/IND/2014 ( #$% & /ASSESSMENT YEAR : 2009-10) ACIT, CIR-2(1), INDORE VS. M/S ALANKAR REAL ESTATE, 169, RNT MARG, INDORE (MP) ' ./ ( ./PAN/GIR NO. : AANFA 6412 F ( !' ') /APPELLANT ) .. ( *+') / RESPONDENT ) /REVENUE BY : SHRI R.A. VERMA #$,- /ASSESSEE BY : SHRI MANOJ GUPTA, SHRI MAHESH AGARWAL, & SHRI PANKAJ SHAH . # / -0 / DATE OF HEARING : 2 ND MAY, 2014 1&% / -0 /DATE OF PRONOUNCEMENT : , 2014 / O R D E R PER R.C.SHARMA (A.M.) : THIS IS AN APPEAL FILED BY THE REVENUE AGAINST THE ORDER OF CIT(A)-I, INDORE FOR THE ASSESSMENT YEAR 2009-10, I N THE MATTER OF ORDER PASSED UNDER SECTION 143(3) OF THE I.T. ACT, WHEREIN FOLLOWING TWO GROUNDS HAVE BEEN TAKEN :- 1.1 ON THE FACTS AND IN THE CIRCUMSTANCES OF THE C ASE, THE LD. CIT(A) WAS NOT JUSTIFIED IN DELETING THE ADDITION O F RS.11,08,244/- MADE BY THE AO ON ACCOUNT OF INCREAS E IN CAPITAL GAIN BASED ON THE REPORT OF THE DVO BY HOLD ING THAT THE REFERENCE TO THE DVO WAS WITHOUT ASSIGNING ANY REAS ON FOR DOUBTING THE VALUATION OF THE REGISTERED VALUER AS SUBMITTED BY THE ASSESSEE BECAUSE THE REFERENCE WAS MADE AFTER D ETECTING SPECIFIC LACUNAE IN THE DOCUMENTS SUBMITTED. 1.2 ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CA SE, THE LD. ITA NO.40/IND/2014 2 CIT(A) ERRED IN DELETING THE ADDITION OF RS.10,39,4 40/- BY OBSERVING THAT THE AO HAD NOT PROVED THAT THE PROPE RTY WAS SOLD BELOW THE MARKET RATE AND ALSO NOT REJECTED THE BOO KS OF ACCOUNT BECAUSE THE LD. CIT(A) FAILED TO APPRECIATE THAT AS A RESULT OF INCREASE IN THE VALUE OF THE PROPERTY DUE TO VALUATION DONE BY THE DVO THE PROFIT SHOWN OUGHT TO HAVE BEEN INCREASED, WHICH WAS CORRECTLY DONE BY THE AO. 2. RIVAL CONTENTIONS HAVE BEEN HEARD AND RECORD PERUS ED. FACTS IN BRIEF ARE THAT THE ASSESSEE HAD PURCHASED THE LA ND IN THE YEAR 1991-1992, WHICH WAS HELD AS CAPITAL ASSET TILL FIN ANCIAL YEAR 2004- 05. DURING THE FINANCIAL YEAR 2004-05, RELEVANT TO THE ASSESSMENT YEAR 2005-06, THE ASSESSEE CONVERTED THE LAND INTO STOCK-IN-TRADE. THE ASSESSEE GOT VALUATION REPORT FROM THE REGISTER ED VALUER, WHICH INDICATED VALUE OF LAND AT RS.6,11,61,000/-. THEREAFTER CONSTRUCTION ACTIVITY WAS CARRIED OUT AND DEVELOPED PROPERTY WAS SOLD IN THE ASSESSMENT YEAR 2008-09 TO 2011-2012. D URING THE YEAR UNDER CONSIDERATION, THE ASSESSEE HAS OFFERED CAPIT AL GAINS ON CONVERSION OF INVESTMENT INTO STOCK-IN-TRADE AS PE R SECTION 45(2) AND ALSO BUSINESS PROFIT SO ACCRUED ON SALE OF STOC K-IN-TRADE. THE ASSESSEE HAS ALSO OFFERED CAPITAL GAINS AS PER THE PROVISION OF SECTION 45(2), ON WHICH TAX WAS ALSO PAID ON CORRES PONDING SALE OF STOCK-IN-TRADE. SINCE THE PART OF THE PROPERTY WAS ONLY SOLD, THE REMAINING PROPERTY WAS LET OUT AND RENT WAS RECEIVE D WHICH WAS OFFERED BY THE ASSESSEE UNDER THE HEAD INCOME FROM HOUSE PROPERTY. DURING THE COURSE OF SCRUTINY ASSESSMENT , THE AO MADE A REFERENCE TO THE DVO, WHO DETERMINED THE VALUE OF L AND IN THE YEAR OF CONVERSION AT RS.7,03,96,225/-. ITA NO.40/IND/2014 3 3 . THE AO ALSO REJECTED BOOKS OF ACCOUNT ON THE PLEA THAT DUE TO CHANGE IN THE VALUATION OF LAND SO CONVERTED INTO S TOCK-IN-TRADE THE BOOK PROFIT SHOWN BY THE ASSESSEE IS NOT TRUE AND C ORRECT. THE AO OBSERVED THAT DUE TO CHANGE IN VALUE OF STOCK-IN-TR ADE, THERE RESULTED LOSS UNDER THE HEAD INCOME FROM BUSINESS, WHICH AS PER THE AO WAS NOT POSSIBLE. AFTER REJECTING BOOKS OF A CCOUNTS, THE AO ESTIMATED NET PROFIT RATE OF 6% AND MADE ADDITION O F RS.10,39,440/-. AGAINST THE ABOVE ORDER OF AO, THE ASSESSEE APPROAC HED BEFORE THE CIT(A). BY THE IMPUGNED ORDER, THE CIT(A) DELETED T HE ADDITION MADE ON ACCOUNT OF DVOS REPORT AFTER HAVING FOLLOW ING OBSERVATIONS :- 5. IN THIS YEAR THE APPELLANT HAS CONTROVERTED THE INVESTMENT IN A LAND INTO STOCK IN TRADE. THE P RESENT MARKET VALUE OF LAND AND STRUCTURE ON IT IS TAKEN A T RS.6,11,61,000/- AND CAPITAL GAIN ARISING ON THIS C ONVERSION WAS CALCULATED AS PER SECTION 45(2) OF THE INCOME T AX ACT R.W.S. 2(47) OF THE INCOME TAX ACT. THEREFORE OUT O F RS.6,11,61,000/- INDEXED COST OF LAND OF RS.1,75,03 ,711/- WAS REDUCED TO COME TO A DEEMED CAPITAL GAIN OF RS.4,36,57,289/- WHICH IS RS.272.42 PER SQ. FT. ON A TOTAL SALEABLE AREA OF 1,60,226 SQ. FT. CONSTRUCTED ON TH AT LAND. OUT OF THIS, AREA SOLD THIS YEAR WAS 19227 SQ. FT. ON W HICH APPELLANT OFFERED A CAPITAL GAIN OF RS.52,38,781/- THIS YEAR. 6. THE AO WITHOUT ASSIGNING ANY REASON FOR DOUBTING THIS VALUATION OF RS.6,11,61,000/- REFERRED THE SAME TO DVO. THE DVO VALUED IT AT RS.7,03,96,225/-. BEFORE REFERRING MATTER TO DVO FOR VALUATION, THE AO WAS REQUIRED TO POINT OUT DEFECTS IN VALUATION OF REGISTERED VALUER IN EITHER AREA OF LA ND OR CONSTRUCTION OR ITS RATE, AND SHOULD HAVE REJECTED THE BOOKS OF APPELLANT ON THAT BASIS. HAVING NOT DONE SO, THE AO WAS NOT JUSTIFIED IN REFERRING THE MATTER TO DVO AS HELD IN CASE OF SARGAM CINEMA [2010] 328 ITR 513 (SC) AND LUCKNOW EDUCATIONAL SOCIETY [2010] 339 ITR 588 (ALL). BESID ES SINCE THE FAIR MARKET VALUE DETERMINED BY DVO IS AROUND 1 5% VARIATION FROM THAT SHOWN BY APPELLANT, HENCE THE V ALUE SHOWN BY APPELLANT CANNOT BE DISTURBED AS HELD IN C ASE OF K.P. VARGHESE [1981] 131 ITR 597. IN VIEW OF THE AF ORESAID DISCUSSION, BASED ON FACTS AND CASE LAWS DISCUSSED ABOVE, ITA NO.40/IND/2014 4 THE ADDITION OF RS.11,08,244/- ON ACCOUNT OF INCREA SE IN CAPITAL GAIN BASED ON REPORT OF DVO IS HEREBY DELET ED. THE ADDITION MADE ON ACCOUNT OF PROFIT ESTIMATED BY THE AO AT 6% BY REJECTING THE BOOKS OF ACCOUNT AMOUNTING TO RS.1 0,39,440/- WAS ALSO DELETED BY THE CIT(A) AFTER HAVING THE FOLLOWI NG OBSERVATIONS :- 7. THE SECOND ISSUE OF ADDITION OF RS.10,39,440/- AS ESTIMATED PROFIT BY ADOPTING A NP RATE OF 6%, IS DO NE BY AO ON THE ARGUMENT THAT ONCE THE COST OF LAND IS ENHAN CED FROM RS.6.11 CRORE TO RS.7.03 CRORE BASED ON REPORT OF D VO, THEN SALE OF UNITS CONSTRUCTED ON SUCH LAND WOULD RESULT IN A LOSS AND NO PRUDENT BUSINESSMAN WOULD LIKE TO INCUR A LO SS. THIS COULD NEVER BE A VALID ARGUMENT BECAUSE BUSINESS CO ULD RESULT IN A LOSS OR PROFIT DEPENDING ON MARKET FORC ES, WHICH CANNOT BE DETERMINED BY TAX AUTHORITY. THE AO WAS R EQUIRED TO FIND OUT RATE PER SQ. FT. AT WHICH APPELLANT SOL D THE PROPERTY ;AND HE WAS REQUIRED TO PROVE THAT SUCH RATE WAS BE LOW MARKET RATE AND SHOULD HAVE FURTHER PROVED THAT APP ELLANT HAS RECEIVED CONSIDERATION OVER AND ABOVE DECLARED VALU E OF THE SAME AS HELD IN CASE OF SADHNA GUPTA (IT APPEAL NO. 434 OF 2012) ORDER PRONOUNCED ON 06.03.2013 (DELHI HIGH CO URT) AND PUNEET SABHARWAL [2011] 338 ITR 485 (DELHI HIGH COURT). SINCE AO HAS NOT PROVED THE SAME AND ALSO N OT REJECTED BOOKS OF ACCOUNTS, HENCE ESTIMATION OF NP AT 6% AND ADDITION OF RS.10,39,440/- BASED ON SUCH ESTIMA TION, CANNOT BE SUSTAINED. THIS GROUND OF APPEAL IS ALSO ALLOWED. 4. AGAINST THE ABOVE ORDER OF CIT(A), THE REVENUE IS IN FURTHER APPEAL BEFORE US. 5. IT WAS ARGUED BY THE LEARNED DR THAT WHILE ACCEPTI NG THE CAPITAL GAINS OFFERED BY THE ASSESSEE, THE AO IS FU LLY EMPOWERED TO REFER THE VALUATION OF ASSETS TO THE DVO, WHO IS AN AUTHORIZED VALUER ON BEHALF OF THE DEPARTMENT. ACCORDINGLY, THE CIT(A ) HAS WRONGLY HELD THE ACTION OF THE AO FOR REFERRING TO THE VALU ATION OFFICER AS UNCALLED FOR. AS PER THE LEARNED DR SINCE THE BOOKS OF ACCOUNTS WERE REJECTED, THE AO HAS CORRECTLY APPLIED THE NET PROFIT AT THE RATE OF 6% ON THE CONSTRUCTIONS WORK UNDERTAKEN BY THE A SSESSEE. ITA NO.40/IND/2014 5 6. ON THE OTHER HAND, LEARNED AR SUPPORTED THE ACTION OF THE CIT(A), HOWEVER AS AN ALTERNATIVE ARGUMENT, HE SUBM ITTED THAT EVEN IF THE ADDITION MADE BY THE AO WITH REFERENCE TO TH E DVOS REPORT IS ACCEPTED, THE VALUE OF OPENING STOCK WILL CORRESPON DINGLY BE INCREASED WHICH WILL RESULT INTO LOWERING OF BUSINE SS PROFIT DURING THE YEAR UNDER CONSIDERATION BY VERY SAME AMOUNT OF DIF FERENCE. AS PER THE LEARNED AR THE EFFECT OF TAX LIABILITY IF THE D VOS REPORT IS ACCEPTED, WILL BE AS UNDER :- EFFECT ON INCOME UNDER HEAD CAPITAL GAINS IN SUBSEQ UENT YEARS. SALE CONSIDERATION AS PER DEPARTMENT VALUER - RS.7, 03,96,225 LESS: SALE CONSIDERATION AS PER REGISTERED VALUER - RS.6,11,61,000 ADDITIONAL CAPITAL GAINS SUBJECT TO TAX - RS. 9 2,35,225 ADDITIONAL TAX ON SUCH AMOUNT @20(APPROX) - RS. 1 8,47,045 EFFECT ON INCOME UNDER BUSINESS PROFESSION IN SUBSE QUENT YEARS INCREASE IN VALUE OF STOCK IN TRADE RESULTING IN - RS. 92,35,225 REDUCTION OF PROFITS IN P&L TAXED AS BUSINESS INCOM E REDUCTION IN TAX LIABILITY @ 30% ON BUSINESS INCOME - RS. 27,70,567 NET TAX SAVINGS TO ASSESSEE IF DVOS VALUE IS ACCEPTED. - RS. 9,23,522 IN VIEW OF ABOVE, IT WAS CONTENDED BY LD. AR THAT A SSESSEE WILL BE MORE BENEFITTED BY THE ADDITION SO GOT DONE BY THE AO WITH REFERENCE TO DVOS REPORT. 7. WITH RESPECT TO AOS ACTION FOR REJECTION OF BOOKS OF ACCOUNTS WITH REFERENCE TO SUBSTITUTION OF DVOS VALUATION I N THE OPENING STOCK, THE CONTENTION OF THE LEARNED AR WAS THAT TH E AO HAS NOT ITA NO.40/IND/2014 6 FOUND ANY DEFECT IN THE BOOKS OF ACCOUNTS AND THE A SSESSEE IN THE AUDITED ACCOUNTS HAS DISCLOSED MORE THAN 6% GROSS P ROFIT, ACCORDINGLY, THERE IS NO JUSTIFICATION FOR REJECTIO N OF BOOKS OF ACCOUNTS AND APPLYING THE PROFIT RATE OF 6%. 8. WE HAVE CONSIDERED RIVAL CONTENTIONS, CAREFULLY GO NE THROUGH THE ORDERS OF THE AUTHORITIES AND FOUND FROM THE RE CORD THAT FOR ARRIVING AT THE CORRECT CAPITAL GAINS EARNED BY THE ASSESSEE AND WHICH WAS OFFERED UNDER SECTION 45(2) ON CONVERSION OF SUCH CAPITAL ASSET INTO STOCK-IN-TRADE, THE AO HAS REFERRED VALU ATION OF CAPITAL ASSETS TO THE DVO. AS PER THE DVOS REPORT, THE AO HAS MADE ADDITION OF RS.11,08,244/- ON ACCOUNT OF CAPITAL GA INS OFFERED BY ASSESSEE. HOWEVER, WITHOUT ASSIGNING ANY REASON, TH E CIT(A) HAS HELD THAT REFERENCE BY THE AO TO DVO WAS NOT JUSTIF IED. THE CIT(A) WAS ALSO NOT JUSTIFIED IN OBSERVING THAT THE AO HAS NOT REJECTED BOOKS OF ACCOUNTS, WHEREAS THE AO HAS CLEARLY STATE D THE REJECTION OF BOOKS OF ACCOUNTS. WE DO NOT FIND ANY MERIT IN T HE ACTION OF THE CIT(A) FOR FINDING FAULT IN THE ACTION OF THE AO FO R REFERRING THE MATTER TO THE DVO. SINCE THE ASSESSEE HAS OFFERED CAPITAL GAIN U/S.45(2) IN RESPECT OF CAPITAL ASSET SO CONVERTED INTO STOCK-IN -TRADE, THE AO HAS CORRECTLY MADE REFERENCE TO THE DVO, WHILE EXAMININ G THE CORRECTNESS OF CAPITAL GAINS SO OFFERED. ACCORDINGL Y, WE DO NOT FIND ANY MERIT IN THE ACTION OF THE CIT(A). HENCE, WE CO NFIRM THE ACTION OF AO WITH REGARD TO THE REFERENCE MADE TO DVO WHIC H RESULTED INTO ADDITION OF RS.11,08,244/- UNDER THE HEAD CAPITAL G AINS U/S.45(2). ITA NO.40/IND/2014 7 NOW, COMING TO THE CONSEQUENCES WHICH FLOW FROM THI S ADDITION, IF WE ACCEPT AND APPLY THE DVOS VALUATION, AS A NATUR AL COROLLARY THE AO IS DUTY BOUND TO GIVE EFFECT TO THE VALUATION SO TAKEN ON CONVERSION OF CAPITAL ASSET INTO STOCK-IN-TRADE, ME ANING THEREBY THE VALUE OF STOCK-IN-TRADE TAKEN AS AT THE BEGINNING O F THE YEAR IS TO BE ENHANCED AS PER THE VALUATION TAKEN BY THE DVO. ONC E, WE TAKE THE HIGHER VALUATION AS MADE BY THE DVO IN RESPECT OF T HE LAND WHICH HAS BEEN CONVERTED INTO STOCK-IN-TRADE, THE BUSINES S PROFIT WILL BE CORRESPONDINGLY REDUCED BY THE QUANTUM OF INCREASED VALUE OF STOCK-IN-TRADE. ACCORDINGLY, WE DIRECT THE AO TO GI VE EFFECT TO THE CHANGE IN THE VALUATION AS PER THE DVOS REPORT WHI LE WORKING OUT BUSINESS PROFIT OF ASSESSEE BY INCREASING VALUE OF OPENING STOCK BY THE VERY SAME AMOUNT OF DIFFERENCE AS FOUND OUT BY THE DVO IN THE VALUE OF LAND AND REWORK OUT THE BUSINESS PROFIT AC CORDINGLY IN SUBSEQUENT YEARS. WE DIRECT SO. 9 . NOW, COMING TO THE AOS ACTION REGARDING REJECTIO N OF BOOKS OF ACCOUNTS, WE FOUND THAT AO HAS REJECTED THE BOOKS O F ACCOUNT MERELY BY OBSERVING THAT THE SUBSTITUTION OF FAIR M ARKET VALUE OF LAND AS PER DVOS REPORT WILL RESULT INTO LOSS, WHICH IS NOT COMMERCIALLY ACCEPTED. HOWEVER, NO DEFECT WAS POINTED OUT BY THE AO IN BOOKS OF ACCOUNT. MERELY BECAUSE OF CHANGE IN VALUATION O F LAND DUE TO DVOS REPORT CANNOT BE MADE A REASON FOR REJECTION OF BOOKS OF ACCOUNTS INSOFAR AS SEPARATE ADDITION WAS MADE BY T HE AO FOR SUCH CHANGE IN VALUATION OF LAND IN THE CAPITAL GAINS DE CLARED BY THE ITA NO.40/IND/2014 8 ASSESSEE U/S.45(2). SINCE NO DEFECT WAS POINTED OUT BY THE AO IN BOOKS OF ACCOUNTS, THERE WAS NO JUSTIFICATION FOR R EJECTION OF BOOK RESULTS, AND MAKING ADDITION BY ESTIMATING PROFIT. AS PER OUR CONSIDERED VIEW, THE BOOKS OF ACCOUNT REGULARLY MAI NTAINED IN THE COURSE OF BUSINESS WHICH ARE DULY AUDITED UNDER THE PROVISIONS OF INCOME TAX ACT, 1961 AND WHICH ARE FREE FROM ANY QU ALIFICATION BY THE AUDITORS SHOULD BE TAKEN AS CORRECT UNLESS THER E ARE STRONG AND SUFFICIENT REASON TO INDICATE THAT THEY ARE UNRELIA BLE. FOR REJECTING THE BOOKS OF ACCOUNT, IT IS REVENUE'S ONUS TO PROVE THAT EITHER THE BOOKS OF ACCOUNT MAINTAINED BY THE ASSESSEE ARE NOT CORRECT AND COMPLETE OR THE METHOD OF ACCOUNTING ADOPTED IS SUC H THAT TRUE PROFITS CANNOT BE DEDUCED THEREFROM. AS THE ONUS TO MAKE OUT A CASE FOR REJECTION OF BOOKS OF ACCOUNT IS ON THE REVENUE, THE ASSESSING OFFICER IS REQUIRED TO INDICATE SPECIFIC DEFECTS IN THE BOOKS OF ACCOUNT WHICH CLINCHES THE PROFIT SHOWN BY THE ASSESSEE OR ITS STATE OF AFFAIRS. IN THE CASE BEFORE US THE AO COMPLETELY FAILED TO INDICATE ANY DEFECTS IN THE BOOKS OF ACCOUNTS. AFTE R PRODUCTION OF BOOKS OF ACCOUNT AND SUBMISSION OF EXPLANATION BY T HE ASSESSEE, IF ANY ASKED FOR, THE AO MAY ACCEPT THE SAME OR AFTER POINTING OUT THE SPECIFIC DEFECT MAY REJECT THE BOOKS OF ACCOUNT AND PROCEED TO DETERMINE THE ASSESSEE'S INCOME AS PER THE PROVISIO NS OF SEC. 145. EVEN THOUGH, IT IS NOT POSSIBLE TO LAY DOWN THE EXA CT CIRCUMSTANCES IN WHICH ACCOUNTS SHOULD BE REJECTED AS UNRELIABLE OR INCORRECT, YET THE ACCOUNTS MAY BE REJECTED AS UNRELIABLE IF IMPORTANT ENTRIES AND ITA NO.40/IND/2014 9 TRANSACTIONS ARE OMITTED THEREFROM OR IF PROPER PAR TICULARS AND VOUCHERS, BILLS, ETC. ARE NOT FORTHCOMING OR IF THE Y DID NOT INCLUDE ENTRIES RELATING TO PARTICULARS CLASS OF BUSINESS T RANSACTION ETC. THE ASSESSEE SHOULD INVARIABLY BE GIVEN OPPORTUNITY FOR OFFERING EXPLANATION REGARDING DEFECTS IN ACCOUNTS AND ON HI S FAILURE TO SATISFACTORILY EXPLAIN THE DEFECTS, THE DEPARTMENT WOULD BE JUSTIFIED IN REJECTING THE BOOKS OF ACCOUNT. THUS, BOOKS OF ACCOUNT SHOULD NOT BE REJECTED LIGHT-HEARTEDLY. IN THE INSTANT CASE TH E ASSESSING OFFICER HAS NOT INDICATED ANY DEFECT IN THE SYSTEM OF ACCOU NTING REGULARLY FOLLOWED BY THE ASSESSEE, OR ITS CORRECTNESS, NOR THERE WAS ANY CHANGE IN THE METHOD OF ACCOUNTING DURING THE YEAR UNDER CONSIDERATION AS COMPARED TO THE EARLIER YEARS TO I NDICATE ANY INTENTION OF ASSESSEE TO SHOW LOW GROSS PROFIT. HOWEVER, ON MERITS, WE FOUND THAT IN THE INSTANT CASE DURING THE YEAR U NDER CONSIDERATION, THE ASSESSEE HAS SHOWN GROSS RECEIPT OF RS.173.24 LACS ON WHICH GROSS PROFIT OF RS.38.19 LACS WAS WOR KED OUT GIVING GROSS PROFIT RATE OF 22.04%, WHICH IS QUITE REASONA BLE LOOKING TO THE NATURE OF BUSINESS UNDERTAKEN BY THE ASSESSEE. 10 . IN THE RESULT, APPEAL FILED BY THE REVENUE IS ALL OWED IN PART. ',%-2 / !' 3 - / - 4 5 ORDER PRONOUNCED IN THE OPEN COURT ON THIS 21/5/20 14. / 1&% . 6 7#2 21/5/2014 / 5 SD/- SD/- ( ) (JOGINDER SINGH) ( . . ) (R.C.SHARMA) / JUDICIAL MEMBER / ACCOUNTANT MEMBER INDORE; 7# DATED 21/5/2014 ITA NO.40/IND/2014 10 *. . ./PKM , # . / PS !' #'$ / COPY OF THE ORDER FORWARDED TO : % & / BY ORDER, ' / ( ) ( ASSTT. REGISTRAR) , / ITAT INDORE 1. !' ') / THE APPELLANT 2. *+') / THE RESPONDENT. 3. . <- ( !' ) / THE CIT(A), INDORE 4. . <- / CIT, INDORE 5. => *-#?$ , !' 0 !?$% , / DR, ITAT, INDORE 6. @ A / GUARD FILE. +='- *- //TRUE COPY//
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