M/s. Silk Museum, Navsari V. The Dy.CIT.,Navsari Circle, Navsari

ITA 4077/AHD/2008

• Counselvise Citation: [2011] 134 COUNSELVISE.COM (IT) 6549 (ITAT-AHMEDABAD)
• Duration Of Justice: 2 year(s) 5 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 03-06-2011
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: C
• Next Hearing Date: 10-03-2011
• Assessment Year: 2005-2006
• Appeal Filed On: 18-12-2008
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: CK MISHRADR
• Assessee Lawyers: J P SHAH
• Keywords: Income from undisclosed sources; Principle of natural justice; Deemed to accrue or arise in india
• Section: 133A

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD BENCH 'C' BEFORE SHRI BHAVNESH SAINI,JM & SHRI A N PAHUJA,AM ITA NO.4077/AHD/2008 (ASSESSMENT YEAR:-2005-06) M/S SILK MUSEUM, 4/235 1/2, MOTA BAZAR, NAVSARI V/S DEPUTY COMMISSIONER OF INCOME-TAX, NAVSARI CIRCLE, NAVSARI PAN: AAJFS 8580 Q [APPELLANT] [RESPONDENT] ASSESSEE BY :- SHRI J P SHAH, AR REVENUE BY:- SHRI C K MISHRA,DR O R D E R A N PAHUJA: THIS APPEAL BY THE ASSESSEE AGAINST AN ORDER DATED 27- 08-2008 OF THE LD. CIT(APPEALS), VALSAD, FOR THE AS SESSMENT YEAR 2005-06, RAISES THE FOLLOWING GROUNDS:- (1) THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) ERRED IN LAW AND ON FACTS IN CONFIRMING DISALLOWANCE OUT OF ADVERTISEME NT EXPENSES TO THE TUNE OF RS.4,18,381/-. (2) THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) ER RED IN LAW AND ON FACTS IN CONFIRMING DISALLOWANCE OUT OF PACKING EXPE NSES TO THE TUNE OF RS.1,73.252/-. (3) THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) ER RED IN LAW AND ON FACTS IN CONFIRMING DISALLOWANCE OUT OF SALARY EXPE NSES TO THE TUNE OF RS.5,00,388/-. (4) THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) ER RED IN LAW AND ON FACTS IN CONFIRMING DISALLOWANCE OUT OF SHOP EXPEN SES TO THE TUNE OF RS.1,08,885/-. (5) THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) ER RED IN LAW AND ON FACTS IN CONFIRMING DISALLOWANCE OUT OF TRAVELLING EXPENSES TO THE TUNE OF RS.1,51,776/-. (6) THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) ER RED IN LAW AND ON FACTS IN CONFIRMING DISALLOWANCE OUT OF PARTNERS SALARY TO THE TUNE OF RS.17,77,925/-. 2 ITA NO.4077/AHD/2008 2 (7) THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) ER RED IN LAW AND ON FACTS IN NOT ALLOWING THE TELESCOPING OF DISALLO WANCES / ADDITIONS MADE BY THE ID. A.O. AGAINST THE DISCLOSURE OF INCOME MADE BY THE APPELLANT TO THE TUNE OF RS.55 LACS DURING SURVEY. (8) IT IS, THEREFORE, PRAYED THAT: (A) THE DISALLOWANCES / ADDITIONS DETAILED AGAINST SERI AL NUMBERS (1),(2),(3),(4),(5) AND (7) ABOVE BE DELETED AND AL TERNATIVELY (B) ALL THE DISALLOWANCES / ADDITIONS OF ABOVE DETAILED EXPENDITURES MY PLEASE BE TELESCOPED AGAINST THE DISCLOSURE OF INCOME MADE BY THE APPELLANT TO THE TUNE OF RS.55 L ACS DURING SURVEY. (9) THE APPELLANT PRAYS FOR GRANTING SUCH OTHER RELI EF AS MAY BE DEEMED JUST AND PROPER BY YOUR HONOURS CONSIDERING THE FA CTUAL AND LEGAL ASPECTS OF THE CASE OF THE APPELLANT. (10) THE APPELLANT CRAVES LEAVE TO ADD, AMEND, ALTER, M ODIFY, SUBSTITUTE, DELETE, CHANGE OR VARY ALL OR ANY OF THE GROUNDS OF APP EAL. 2. ADVERTING TO GROUND NOS. 1 TO 7 IN THE APPEA L, FACTS, IN BRIEF, AS PER RELEVANT ORDERS ARE THAT RETURN DECLARING INCO ME OF RS.36,04,610/- FILED ON 19-10-2005 BY THE ASSESSEE, TRADING IN SAREES, READYMADE GARMENTS AND DRESS MATERIALS, WAS PROCESSED ON U/S 143(1) OF THE INCOME-TAX ACT, 1961 [HEREINAFTER REFERRED T O AS THE ACT]. SINCE A SURVEY U/S 133A OF THE ACT WAS COND UCTED IN THE BUSINESS PREMISES OF THE ASSESSEE-FIRM ON 01-03-200 5, THE RETURN WAS SELECTED FOR SCRUTINY WITH THE SERVICE OF A NOT ICE U/S 143(2) OF THE ACT ON 20-1-2006.DURING THE COURSE OF THE SURVE Y, CASH AS PER BOOKS AS ON THE DATE OF SURVEY WAS FOUND TO BE RS.2 ,87,262/- AS AGAINST PHYSICAL CASH OF RS.7,95,516/- WHILE THE CL OSING STOCK AS PER BOOKS WAS RS.1,91,50,448/- AS AGAINST PHYSICAL STOC K OF RS.2,41,62,586/-. THUS, EXCESS CASH OF RS.5,08,254 /- AND EXCESS STOCK OF RS.50,12,138/- WERE FOUND. WHEN CONFRONTED , SHRI BABUBHAI KAPADIA, ONE OF THE PARTNERS OF THE ASSESSEE-FIRM, IN REPLY TO QUESTION NOS.10 AND 11 OF HIS STATEMENT RECORDED ON OATH DURING THE COURSE OF SURVEY, VOLUNTARILY ADMITTED THE EXCESS C ASH OF RS.5,08,254/- AND EXCESS STOCK OF RS.50,12,138/- AS ADDITIONAL 3 ITA NO.4077/AHD/2008 3 INCOME OF THE FIRM FOR THE YEAR UNDER CONSIDERATION I.E. THE AY 2005- 06 AND AGREED TO PAY TAX THEREON. ACCORDINGLY, THE ASSESSEE DEBITED THE PURCHASES AND CREDITED THE SALES BY RS. 50,00,000/- BEING EXCESS STOCK FOUND DURING THE COURSE OF SURVE Y AND SIMULTANEOUSLY CREDITED THE P&L ACCOUNT BY RS.55,00 ,000/,INCLUDING THE EXCESS CASH OF RS.5,00,000/-. 2.1 ON VERIFICATION OF EXPENSES CLAIMED DURI NG THE YEAR UNDER CONSIDERATION VIS-A-VIS SALES, THE ASSESSING OFFICE R[AO IN SHORT] NOTICED THAT THE ASSESSEE CLAIMED EXCESSIVE EXPENS ES IN COMPARISON TO INCREASE IN SALES AND THEREBY REDUCE D ITS NET PROFIT. THOUGH THE SALES INCREASED BY 22.22% VIS--VIS PREC EDING YEAR, ADVERTISEMENT EXPENSES INCREASED BY 31.44%.SIMILAR WAS THE POSITION IN RESPECT OF PACKING EXPENSES, WHICH INCR EASED BY 41.04%, SALARY BY 40.33%,, SHOP EXPENSES BY 25.17%, TRADING EXPENSES BY 40.65% AND SALARY TO PARTNERS BY 1801%. THE SALARY EXCLUDING SURVEY DISCLOSURE INCREASED BY 13.55%. CO NSIDERING THE INCREASE IN SALES BY 13.55% AS THE BASIS, THE AO WO RKED OUT EXCESSIVE EXPENSES AS UNDER:- PARTICULARS OF EXPENSES CURRENT YEAR PREVIOUS YEAR INCREASE OVER LAST YEAR % CORRESPONDING EXPENSES WORKED OUT WITH REFERENCE TO INCREASE IN SALES BY 13.55% IN COMPARISON TO LAST YEAR EXCESSIVE CLAIM (2-5) 1 2 3 4 5 6 ADVERTISEMENT 1888676 1294844 593832 (31.44) 1470295 (+ 418381) PACKING EXP. 524174 309046 215128 (41.04) 350922 (+ 173252) SALARY 1551628 925795 625833 (40.33) 1051240 (+ 500388) SHOP EXP. 724102 541803 182299 (25.17) 615217 (+ 108885) TRAVELING 486316 294619 191697 (40.65) 334540 (+ 151776) PARTNERS SALARY 2490440 131000 2359440 (1801%) 712514 (+ 1777925) 4 ITA NO.4077/AHD/2008 4 2.2 IN THE LIGHT OF AFORESAID POSITION, THE AO RECA ST THE TRADING & P&L ACCOUNT AS DETAILED ON PAGE 7 & 8 OF THE ASSESSMEN T ORDER AND ARRIVED AT A NET PROFIT OF RS.9,76,731/- AFTER EXCL UDING AMOUNT DISCLOSED DURING THE SURVEY. THE AO OBSERVED THAT T HE UNACCOUNTED INCOME OF RS.55,20,392/- CREDITED TO PROFIT & LOSS ACCOUNT WAS ASSESSABLE AS INCOME IN ACCORDANCE WITH THE PROVISI ONS OF SECTION 69B OF THE ACT AND NO CORRESPONDING DEDUCTION OUT O F SUCH DEEMED INCOME IS ALLOWABLE UNDER ANY HEAD OF INCOME. AS SU CH, THE ASSESSEE OUGHT TO HAVE OFFERED FOR TAXATION ITS TOT AL INCOME AT RS.64,76,731/- (NORMAL N.P. RS.9,76,731/- + SURVEY DISCLOSURE OF RS.55,20,392/-) AGAINST WHICH THE ASSESSEE OFFERED ONLY RS.33,46,121/- AS PER RETURN OF INCOME. ACCORDINGLY , THE AO OBSERVED THAT THE ASSESSEE-FIRM UNDERSTATED THE DI SCLOSURE BY RS.31,30,618/-.TO A QUERY BY THE AO, THE ASSESSEE R EPLIED THAT NO EXCESSIVE EXPENDITURE HAVE BEEN CLAIMED BY THEM AND THE EXPENDITURE DEBITED IN THE PROFIT AND LOSS ACCOUNT WAS GENUINE BUSINESS EXPEND ITURE, INCURRED WHOLLY AND EXCLUSIVELY FOR THE PURPOSES OF THEIR BUSINESS AND WA S SUPPORTED BY BILLS, VOUCHERS, ETC.. HOWEVER, THE AO DID NOT ACCEPT THE SUB MISSIONS OF THE ASSESSEE ON THE GROUND THAT A NUMBER OF VOUCHERS WER E SELF-MAID, UNDATED, UNSIGNED BY PAYER AND PAYEE AND WERE WITHO UT NAME OF THE RECIPIENT. ACCORDINGLY, THE AO CONCLUDED THAT THE ENTIRE EXPENSES W ERE NOT WHOLLY AND EXCLUSIVELY INCURRED FOR THE PURPOSE OF BUSINESS AND PHOT OCOPY OF SOME OF THE VOUCHERS WERE ENCLOSED WITH HIS ORDER.INTER ALIA, THE A O RELIED UPON DECISIONS IN CIT V. CALCUTTA AGENCY LTD. [1951] 19 ITR 191(SC); CI T V. IMPERIAL CHEMICAL INDUSTRIES (INDIA) (P) LTD. [1969] 74 ITR 17(SC); CI T V. C. PARAKH AND CO. (INDIA) LTD. [1956] 29 ITR 661(SC) AND CIT VS. CHANDRAVILAS H OTEL (1987) 164 ITR102 (GUJ).AS A RESULT DISALLOWANCE OF RS.31,30,607/-COMPR ISING FOLLOWING EXPENSES WAS MADE:- RS. ADVERTISEMENT EXPENSES 418381 PACKING EXPENSES 173252 SALARY EXPENSES 500388 5 ITA NO.4077/AHD/2008 5 SHOP EXPENSES 108885 TRAVELING EXPENSES 151776 PARTNERS SALARY 1777925 3130607 3. ON APPEAL, THE LEARNED CIT(A) UPHELD THE DISALL OWANCE IN THE FOLLOWING TERMS:- 6.3 I HAVE CONSIDERED THE CONTENTIONS OF THE APPELLANT AS WELL AS THE OBSERVATIONS OF THE AO IN THE ASSESSMENT ORDER. I FIND THA T THE APPELLANT HAS ARGUED ON THE BASIS OF VOUCHERS OF EXPENSES WHICH ARE SELF -MADE AND WHICH DO NOT MENTION THE NAMES AND ADDRESSES OF THE PAYEE S, WHEREABOUTS OF THE PAYEE ETC. THE AO HAS ATTACHED IN AN NEXURE-A TO H, THE GLARING EVIDENCES, WHICH HE CAME ACROSS AND WHICH SUFF ICIENTLY PROVES THAT THE AO'S CONTENTIONS ARE CORRECT THAT THE APPELLANT HAS REDUCED ITS TAX LIABILITY AFTER INFLATING EXPENDITURE. THE AR HAS ARGU ED THAT IT IS ALWAYS POSSIBLE THAT THE RISE IN EXPENDITURE CAN BE DISPROPORTI ONATE TO THE RISE IN SALES, BUT THE AR DID NOT BRING ANY JUSTIFICATION TO SHOW THAT WHY THERE IS A SUDDEN RISE IN THE CURRENT YEAR IN THE ALL THE ABOVE HEA DS OF EXPENDITURE LIKE ADVERTISEMENT, PACKING, SALARY, SHOP EXPENSES, TRAVELING EXPENSES ETC. I FIND THAT THE AO HAS ACTED JUDICIOUSLY AND HE HAS R ECASTED THE ENTIRE PROFIT AND LOSS ACCOUNT AFTER TAKING INTO COGNIZANCE THE RISE IN TURNOVER ACHIEVED BY THE APPELLANT FIRM. THE AO'S WORKING IS FAIR AND JUST BECAUSE HE DID ALLOW RISE IN THE ABOVE HEADS OF EXPENSES PROPORTI ONATE TO THE RISE IN SALES. THE AO HAS JUSTIFIED IN THE BODY OF THE ASSESSMEN T ORDER THAT THE BOOKS OF THE APPELLANT ARE NOT RELIABLE AS NO QUANTITA TIVE DETAILS HAS BEEN MAINTAINED AS REPORTED IN FORM NO. 3CD BY THE AUDITO R OF THE APPELLANT FIRM. SINCE THE APPELLANT HAS NOT MAINTAINED RELIABL E RECORDS TO PROVE THE TRADING RESULTS AND AO HAS FOUND THAT THE EXPENDITURE INCURRED BY THE APPELLANT ARE NOT VERIFIABLE AS MOST OF THE CLAIMS OF EXP ENSES ARE ON THE BASIS OF SELF-MADE VOUCHERS, THE AO HAS USED HIS POWER AND R ECASTED THE PROFIT AND LOSS ACCOUNT ONLY AFTER UNEARTHING THE GLARI NG DEFECTS IN THE RECORDS OF THE APPELLANT AND THE DEFECTS IN THE EVIDENC ES MAINTAINED BY THE APPELLANT. THE AR FOR THE APPELLANT FIRM HAS NOT AT ALL OBJECTED TO THE SAID POWER OF THE AO IN RE-WORKING THE PROFIT BY RECASTI NG THE PROFIT AND LOSS ACCOUNT. REGARDING THE CLAIM OF THE REMUNERATION TO PARTNERS U/S. 40(B)(V), THE AO HAS RIGHTLY NOT ALLOWED THE REMUNERAT ION ON THE INCOME ENHANCED DUE TO DECLARATION OF ADDITIONAL INCOME OF RS. 55,00,000/- MADE DURING THE COURSE OF SURVEY. I AM, THEREFORE, OF THE C ONSIDERED VIEW THAT THE AO IS JUSTIFIED IN MAKING ADDITION / DISALLOWANCE OF RS.31,30,618/- AS WORKED OUT BY HIM IN PARA-6 OF THE ASSESSMENT ORDER. THE APPELLANTS GROUND NO.2,3,4,5,6,7 AND 10 ARE, THEREFORE, DISMISSED . 4. THE ASSESSEE IS NOW IN APPEAL BEFORE US AGAINST THE AFORESAID FINDINGS OF THE LEARNED CIT(A). THE LEARNED AR ON B EHALF OF THE ASSESSEE WHILE CARRYING US THROUGH THE IMPUGNED ORD ER, CONTENDED 6 ITA NO.4077/AHD/2008 6 THAT THE LEARNED CIT(A) WAS NOT JUSTIFIED IN UPHOLD ING THE ADDITION IN THE LIGHT OF DECISIONS REPORTED IN, 99 TTJ 305; 124 TAXMAN 8, INDWELL CONSTRUCTION VS. CIT (1998) 232 ITR 776 (AP);DCIT V S. TURQUOISE INVESTMENT AND FINANCE LTD. (2008) 299 ITR 143 (MP) ;CIT VS. SUPREME BUILDERS (2008) 303 ITR 01 (P&H),ROYALE SUN RISE VS. ITO (2006) 99 TTJ (BANG) 1305; AND ITO VS. JAMNADAS MUL JIBHAI (2006) 99 TTJ (RAJKOT) 197/THE LEARNED DR, ON THE OTHER HA ND, SUPPORTED THE FINDINGS OF THE LEARNED CIT(A) WHILE CONTENDING THAT THE ASSESSEE DID NOT PRODUCE ANY EVIDENCE BEFORE THE LO WER AUTHORITIES THAT THE AFORESAID EXPENDITURE HAD BEEN INCURRED A CTUALLY INCURRED WHOLLY AND EXCLUSIVELY FOR THE PURPOSE OF BUSINESS. 5. WE HAVE HEARD BOTH THE PARTIES AND GONE T HROUGH THE FACTS OF THE CASE AS ALSO THE CITED DECISIONS. WE FIND THAT THE ASSESSEE HAD RAISED SPECIFIC GROUND NOS. 2 TO 7 (GROUND NOS.1 TO 6 BEFORE US) BEFORE THE LD. CIT(A). INSTEAD OF RECORDING HIS SPE CIFIC FINDINGS ON EACH OF THESE GROUNDS IN THE LIGHT OF SUBMISSIONS M ADE BEFORE HIM, THE LD. CIT(A) UPHELD THE DISALLOWANCE OF RS. 31,30 ,618/- IN A CRYPTIC MANNER WITHOUT ANALYZING THE ISSUES NOR ADDUCED ANY REASONS AND NOR EVEN ATTEMPTED TO ASCERTAIN AS TO WHETHER OR N OT THE SAID EXPENDITURE, EVEN THOUGH NOT COMMENSURATE WITH SAL ES VIS--VIS EXPENDITURE INCURRED IN THE PRECEDING YEAR, WAS GEN UINE EXPENDITURE INCURRED WHOLLY AND EXCLUSIVELY FOR THE PURPOSE OF BUSINESS. EVEN THE CLAIM OF TELESCOPING THE ADDITIONS AGAINST DI SCLOSED AMOUNT OF RS. 55 LACS IN TERMS OF GROUND NO. 9 IN THE APPEAL BEFORE HIM(GROUND NO. 7 BEFORE US ), HAS NOT BEEN ADJUDICATED BY THE LD. CIT(A). IN THESE CIRCUMSTANCES, ESPECIALLY WHEN THE LD. CIT(A) HAVE NOT ASCERTAINED THE COMPLETE FACTS NOR RECORDED HIS SPE CIFIC FINDINGS ON THE ISSUES RAISED BEFORE HIM AND NOR EVEN PASSED A SPEAKING ORDER ON THE ISSUE OF AFORESAID DISALLOWANCES AMOUNTING T O RS. 31,30,618/-, WE ARE OF THE OPINION THAT ISSUES RAIS ED IN GROUND NOS.1 TO 7 IN THE APPEAL BEFORE US REQUIRE RECONSIDERATIO N BY HIM. THE APPLICATION OF MIND TO THE MATERIAL FACTS AND THE A RGUMENTS SHOULD 7 ITA NO.4077/AHD/2008 7 MANIFEST ITSELF IN THE ORDER. SECTION 250(6) OF THE ACT MANDATES THAT THE ORDER OF THE CIT(A) WHILE DISPOSING OF THE APPE AL SHALL BE IN WRITING AND SHALL STATE THE POINTS FOR DETERMINATIO N, THE DECISION THEREON AND THE REASON FOR THE DECISION. AS IS APP ARENT FROM THE IMPUGNED ORDER, IN OUR OPINION, THE ORDER PASSED BY THE LD. CIT(A) IS CRYPTIC AND GROSSLY VIOLATIVE OF ONE OF THE FACETS OF THE RULES OF NATURAL JUSTICE, NAMELY, THAT EVERY JUDICIAL/QUASI- JUDICIAL BODY/AUTHORITY MUST PASS REASONED ORDER, WHICH SHOU LD REFLECT APPLICATION OF MIND BY THE CONCERNED AUTHORITY TO T HE ISSUES/POINTS RAISED BEFORE IT. THE REQUIREMENT OF RECORDING OF R EASONS AND COMMUNICATION THEREOF HAS BEEN READ AS AN INTEGRAL PART OF THE CONCEPT OF FAIR PROCEDURE AND SAFEGUARD TO ENSURE O BSERVANCE OF THE RULE OF LAW. IT INTRODUCES CLARITY, CHECKS THE INTR ODUCTION OF EXTRANEOUS OR IRRELEVANT CONSIDERATIONS AND MINIMIZ ES ARBITRARINESS IN THE DECISION-MAKING PROCESS. WE MAY POINT OUT TH AT A DECISION DOES NOT MERELY MEAN THE CONCLUSION. IT EMBRACES WITHIN ITS FOLD THE REASONS FORMING BASIS FOR THE CONCLUSION.[MUKHT IAR SINGH VS. STATE OF PUNJAB,(1995)1SCC 760(SC)]. IN VIEW OF THE FOREGOING, WE CONSIDER IT FAIR AND APPROPRIATE TO SET ASIDE THE O RDER OF THE LD. CIT(A) AND RESTORE THE ISSUES RAISED IN GROUND NO S.1 TO 7 OF THE APPEAL, TO HIS FILE FOR DECIDING THE MATTER AFRES H IN ACCORDANCE WITH LAW, AFTER ALLOWING SUFFICIENT OPPORTUNITY TO BOTH THE PARTIES. NEEDLESS TO SAY THAT WHILE REDECIDING THE APPEAL, T HE LEARNED CIT(A) SHALL PASS A SPEAKING ORDER, KEEPING IN MIND, INTER ALIA, THE MANDATE OF PROVISIONS OF SEC. 250(6) OF THE ACT. WITH THES E OBSERVATIONS, GROUND NOS. 1 TO 7 ARE DISPOSED OF. 6. GROUND NOS.8 AND 9 BEING MERE PRAYER N OR ANY SUBMISSIONS HAVING BEEN MADE BEFORE US ON THESE GROUNDS, DO NOT REQUIRE ANY SEPARATE ADJUDICATION WHILE NO ADDITIONAL GROUND H AVING BEEN RAISED BEFORE US IN TERMS OF RESIDUARY GROUND NO. 10 IN TH E APPEAL, ALL THESE GROUNDS ARE , THEREFORE, DISMISSED. 8 ITA NO.4077/AHD/2008 8 7. IN THE RESULT, APPEAL IS ALLOWED BUT FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE COURT TODAY ON 3-06-2011 SD/- SD/- ( BHAVNESH SAINI ) JUDICIAL MEMBER ( A N PAHUJA ) ACCOUNTANT MEMBER DATED : 3-06-2011 COPY OF THE ORDER FORWARDED TO: 1. M/S SILK MUSEUM, 4/235 1/2, MOTA BAZAR, NAVSAR I 2. THE DEPUTY COMMISSIONER OF INCOME-TAX, NAVSARI C IRCLE, NAVSARI 3. CIT CONCERNED 4. CIT(A), VALSAD 5. DR, ITAT, AHMEDABAD BENCH-C, AHMEDABAD 6. GUARD FILE BY ORDER DEPUTY REGISTRAR ASSISTANT REGISTRAR ITAT, AHMEDABAD