Rajendra Kumar and Nirmala Gupta, New Delhi V. DIT(E), New Delhi

ITA 4421/DEL/2010

• Counselvise Citation: 442120114 RSA 2010
• Duration Of Justice: 1 year(s) 6 month(s) 23 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 27-04-2012
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: F
• Next Hearing Date: 27-01-2012
• Assessment Year: misc
• Appeal Filed On: 04-10-2010
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: B R R KUMARDR
• Assessee Lawyers: SWEETY KOTHARI ARS
• Keywords: Charitable institution; Condonation of delay
• Section: 80G; 12A; 12AA

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI F BENC H BEFORE SMT. DIVA SINGH, JM & SHRI A.N. PAHUJA, AM ITA N OS. 4421 & 5592/DEL/2010 RAJENDRA KUMAR & NIRMALA GUPTA CHARITABLE TRUST,89, OLD ISHWAR NAGAR, OKHLA MORE, NEW DELHI. V/S . DIT(EXEMPTIONS), AAYAKAR BHAWAN, DISTRICT CENTRE,LAXMI NAGAR, NEW DELHI [PAN : AABTR5169G] (APPELLANT) (RESPONDENT) ASSESSEE BY SH. V.K. BINDAL, & MS. SWEETY KOTHARI, ARS REVENUE BY SHRI B.R.R. KUMAR,DR DATE OF HEARING 24-04-2012 DATE OF PRONOUNCEMENT 27-04-2012 O R D E R A.N.PAHUJA:- THESE TWO APPEALS FILED BY THE ASSESSEE- ITA NO. 4 421/DEL/2010 ON 04.10.2010 AND THE ITA NO. 5592/DEL/2010 ON 9.1 2.2010 AGAINST A COMMON ORDER DATED 5.08.2010 OF THE LD. DIT(EXEMPTIONS),NEW DELH I U/S 12AA(1)(B) & 80G(5)(VI) OF THE INCOME TAX ACT, 1961[ HEREINAFTER REFERRED TO A S THE ACT],RAISE THE FOLLOWING GROUNDS: - ITA NO. 4421/DEL/2010: 1. THE LD. DIT(E), NEW DELHI ERRED IN LAW AND ON F ACTS IN REJECTING THE APPLICATION OF THE ASSESSEE SEEKING GRANT OF REGIST RATION U/S 12A BY ALLEGING THAT A) THE ASSESSEE DID NOT FILE ANY EVIDENCE TO SHOW T HAT ACTUAL CHARITABLE ACTIVITIES HAVE BEEN CARRIED OUT BY THE APPLICANT T RUST. B) IN THE ABSENCE OF CHARITABLE ACTIVITY CONDUCTED BY THE APPLICANT, THE GENUINENESS OF THE ACTIVITIES COULD NOT BE ESTABLIS HED AND THEREFORE CONDITIONS FOR GRANTING REGISTRATION U/S 12AA IS NO T SATISFIED IGNORING THE PROVISIONS OF THE ACT AND THE FACTS AND SUBMISSIONS PLACED ON RECORD. THUS, REGISTRATION U/S 12A SHOULD BE GRANTED TO THE ASSESSEE. 2. THE LD. DIT ERRED IN LAW AND ON FACTS IN REJECTI ON OF THE APPLICATION OF THE ASSESSEE SEEKING REGISTRATION U/S 80G ENABLING THE ASSESSEE TO ISSUE ITA NOS. 4421&5592 /D/2010 2 CERTIFICATES FOR DONATIONS IGNORING THE FACTS AND E VIDENCES PLACED ON RECORD THOUGH ALL THE CONDITIONS WERE FULFILLED BY THE ASSESSEE. THUS, REGISTRATION U/S 80G SHOULD BE GRANTED TO THE ASSES SEE. 3. THE APPLICANT CRAVES THE LEAVE TO ADD, SUBSTITUT E, MODIFY, DELETE OR AMEND ALL OR ANY GROUND OF APPEAL EITHER BEFORE OR AT THE TIME OF HEARING. ITA NO. 5592/DEL/2010 1. THE LD. DIT ERRED IN LAW AND ON FACTS IN REJECT ING THE APPLICATION OF THE ASSESSEE SEEKING REGISTRATION U/S 80G WHICH COULD E NABLE THE ASSESSEE TO ISSUE CERTIFICATES FOR DONATIONS RECEIVED IGNORI NG THE EVIDENCES PLACED ON RECORD MERELY BECAUSE REGISTRATION U/S 12AA WAS NOT GRANTED BY HIM AND AN ACTION WHICH HAS BEEN CHALLENGED IN A SEPARA TE APPEAL THOUGH ALL THE CONDITIONS WERE FULFILLED BY THE ASSESSEE. THU S, REGISTRATION U/S 80G SHOULD BE GRANTED TO THE ASSESSEE. 2. THE APPELLANT CRAVES THE LEAVE TO ADD, SUBSTITUT E, MODIFY, DELETE OR AMEND ALL OR ANY GROUND OF APPEAL EITHER BEFORE OR AT THE TIME OF HEARING. 2. AT THE OUTSET, WE FIND THAT THE APPEAL IN ITA NO. 5592/DEL/2010 FILED ON 9.12.2010 IS DELAYED BY 66 DAYS. IN THE REQUEST FOR CONDONATION OF DELAY IN FILING THE APPEAL, THE ASSESSEE SUBMITTED THAT INITIALLY ON LY ONE APPEAL WAS INADVERTENTLY FILED AGAINST A COMMON ORDER DATED 5.8.2010 U/S 12AA(1)(B ) & 80G(5)(VI) OF THE LD. DIT(EXEMPTIONS).HOWEVER, WHEN DEFECT WAS POINTED OU T BY THE BENCH DURING THE COURSE OF HEARING ON 2.12.2010, A SEPARATE APPEAL A GAINST ORDER U/S 80G(5)(VI) OF THE ACT WAS FILED, RESULTING IN DELAY OF 66 DAYS IN FIL ING THIS APPEAL. THE LD. AR ADDED THAT DELAY BEING NOT INTENTIONAL, BE CONDONED. THE LD. D R DID NOT OPPOSE THESE SUBMISSIONS OF THE LD. AR 3. . WE HAVE HEARD BOTH THE PARTIES AND GON E THROUGH THE FACTS OF THE CASE AS ALSO THE REASONS FOR DELAY. THE ISSUE BEFORE US IS AS TO WHETHER OR NOT THERE WAS SUFFICIENT CAUSE FOR DELAY IN FILING THE APPEAL. IN THE CASE OF STATE OF WEST BENGAL VS. ADMINISTRATOR, HOWRAH MUNICIPALITY AIR 1972 SC 749, THE HON'BLE SUPREME COURT WHILE CONSIDERING THE SCOPE OF EXPRESSION 'SUFFICIE NT CAUSE' FOR CONDONATION OF DELAY HAVE HELD THAT THE SAID EXPRESSION SHOULD RECEIVE A LIBERAL CONSTRUCTION SO AS TO ADVANCE THE SUBSTANTIAL JUSTICE WHEN NO NEGLIGENCE OR INACTION OR WANT OF BONA FIDE IS IMPUTABLE TO THE PARTY. IN THE CASE OF VEDABAI ALI AS VAIJAYANTABAI BABULAO PATIL VS. SHANTARAM BABURAO PATIL & ORS., IT WAS HELD BY THE HONBLE APEX COURT THAT WHILE EXERCISING DISCRETION UNDER S. 5 OF THE LIMITATION ACT, 1963, TO CONDONE DELAY FOR ITA NOS. 4421&5592 /D/2010 3 SUFFICIENT CAUSE IN NOT FILING THE APPEAL WITHIN TH E PERIOD PRESCRIBED, COURTS SHOULD ADOPT A PRAGMATIC APPROACH. IT HAS BEEN CONSISTENTL Y HELD BY THE HONBLE APEX COURT THAT IN THE MATTER OF CONDONATION OF DELAY, A LIBER AL AND PRAGMATIC VIEW SHOULD BE TAKEN. IN THE FACTS AND CIRCUMSTANCES OF THE CASE, WE ARE OF THE OPINION THAT THE REASONS GIVEN BY THE ASSESSEE FOR THE DELAY OF 66 DAYS APPEAR TO BE SUFFICIENT CAUSE FOR DELAY IN FILING THE APPEAL AND, ACCORDINGLY, TH E DELAY OF 66 DAYS IN FILING THE APPEAL IS CONDONED. 4. FACTS, IN BRIEF, AS PER RELEVANT ORDERS ARE THAT THE AFORESAID TRUST SUBMITTED TWO APPLICATIONS ON 26.02.2010 IN FORM NO. 10A, SEEKING REGISTRATION U/S 12A OF THE INCOME TAX ACT, 1961[HEREINAFTER REFERRED TO AS THE ACT] AND FORM NO. 10G ,SEEKING APPROVAL U/S 80G(5)(VI) OF THE ACT. ON RECEIPT OF THESE APPLICATIONS, THE DIT(E) SOUGHT THE FOLLOWING DETAILS FROM THE ASSESSEE: - I) JUSTIFY WITH THE BILLS/VOUCHERS OF THE INCOME APPLIED FOR CHARITABLE ACTIVITIES ALONGWITH PROOF OF BENEFICIARIES. II) PLEASE FILE THE UNDERTAKING THAT THERE SHALL BE NO INFRINGEMENT TO THE PROVISO TO SEC. 2(15) OF THE I.T. ACT. III) A NOTE ON ACTIVITIES OF THE TRUST/SOCIETY SINC E ITS INCEPTION/DURING LAST THREE YEARS ALONG WITH SUPPORTING DOCUMENTARY EVIDE NCE. IV) AUDITED ACCOUNTS FOR THE PERIOD ENDING 31.10.20 09 SINCE THE INCEPTION OF THE SOCIETY/TRUST OR LAST THREE YEARS, WHICHEVER IS APPLICABLE. V) A CERTIFICATE FROM THE MANAGING TRUSTEE THAT THE RE IS NO CHANGE IN THE OBJECTIVES ACTIVITIES OF THE TRUST. IN CASE THERE HAS BEEN ANY CHANGE IN OBJECTIVES/ACTIVITIES THAT MAY BE POINTED OUT. VI) DETAILS OF EXPENDITURE INCURRED ON RELIGIOUS AC TIVITIES. VII) AN AFFIDAVIT FROM THE MANAGING TRUSTEE THAT TH ERE HAS BEEN NO INFRINGEMENT OF PROVISIONS OF SEC. 13 OF THE I.T. A CT SINCE THE INCEPTION OF THE SOCIETY/DURING THE LAST THREE YEARS TRUST, WHAT EVER IS APPLICABLE. VIII) DETAILS OF DONATIONS RECEIVED AND MADE DURING THE LAST THREE YEARS OR SINCE THE INCEPTION OF THE TRUST/SOCIETY INCLUDING CORPUS DONATIONS WITH COMPLETE NAME, ADDRESS & PAN. IX) PROOF OF FILING RETURNS OF INCOME FOR LAST ONE YEAR. X) PLEASE JUSTIFY YOUR CLAIM FOR EXEMPTION U/S 80G. XI) PLEASE FURNISH CONTACT NO. & E-MAIL ADDRESS OF THE APPLICANT & ITS MEMBERS. XII) PLEASE INSERT A CLAUSE IN THE DEED/MOA PROVIDI NG THAT THE FUNDS/PROPERTY OF THE TRUST WILL BE USED ONLY FOR THE OBJECTIVES O F THE TRUST/SOCIETY. 4.1. AFTER OBTAINING VARIOUS DETAILS, THE LD . DIT(E) NOTICED THAT THE TRUST, ESTABLISHED ON 9 TH OCTOBER, 2009, INTER-ALIA, FOR THE PURPOSE OF PROM OTION OF EDUCATION AND LEARNING IN ALL ITS BRANCHES., RECEIV ED VOLUNTARY CONTRIBUTION OF ` 1,01,100/- AND DONATED AN AMOUNT OF RS. 1 LAKH TO M /S CHIMNAYA MISSION. ITA NOS. 4421&5592 /D/2010 4 BESIDES, THE TRUST OBTAINED CORPUS DONATION OF RS. 1CRORE 10 LACS FROM SHAYAM LAL CHARITABLE TRUST ,AN INSTITUTION REGISTERED U/S 12A OF THE ACT. SINCE THE ASSESSEE DID NOT FILE ANY CONCRETE EVIDENCE REGARDING ACTUAL CHARITABLE ACTIVITIES UNDERTAKEN BY IT AND CONSEQUENTLY, DID NOT ESTABLISH GENUINEN ESS OF ITS ACTIVITIES, THE LD. DIT(E) DENIED REGISTRATION U/S 12A OF THE ACT AS AL SO APPROVAL U/S 80G(5)(VI) OF THE ACT. 5. THE ASSESSEE IS NOW IN APPEAL BEFORE US AGAINST THE AFORESAID FINDINGS OF THE LD. D.IT(E). THE LD. AR ON BEHALF OF THE ASSESS EE WHILE CARRYING US THROUGH THE OBJECTS OF THE TRUST SUBMITTED THAT THE MAIN OBJEC T OF THE INSTITUTION IS TO PROMOTE EDUCATION AND LEARNING AS ALSO TO UNDERTAKE OR SUPP ORT PROJECTS AND MISSIONS FOR THE SAID PURPOSE. OUT OF VOLUNTARY CONTRIBUTION OF ` 1,01,100/-, ` .1 LAKH WAS DONATED TO CHIMNAYA MISSION., A TRUST HAVING SIMILA R OBJECTS. AS REGARDS OBJECT OF EDUCATION, THE APPLICANT DID NOT UNDERTAKE ANY ACTI VITIES AT THE TIME OF SUBMISSION OF APPLICATION. WHILE INVITING OUR ATTENTION TO PAG E 1 TO 34 OF THE PAPER BOOK, THE LD. AR SUBMITTED THAT SUBSEQUENTLY A PROJECT REPORT FOR SETTING UP OF A SCHOOL WAS MADE AND APPLICATION DATED 8.12.2010 FOR ALLOTMENT OF LAND WAS SUBMITTED TO NOIDA DEVELOPMENT AUTHORITY. SINCE THE APPLICANT T RUST HAD UNDERTAKEN CHARITABLE ACTIVITIES, THE LD. DIT(E) WAS NOT JUSTI FIED IN DENYING REGISTRATION U/S 12A OF THE ACT OR APPROVAL U/S 80G(5)(VI) OF THE ACT, T HE LD. AR ARGUED. ON THE OTHER HAND, LD. DR POINTED OUT THAT SINCE DOCUMENTS PLACE D AT PAGE 1 TO 34 OF THE PAPER BOOK WERE NOT AVAILABLE BEFORE THE LD. DIT(E), THEI R COGNIZANCE COULD NOT BE TAKEN. SINCE THE APPLICANT FAILED TO ESTABLISH THE GENUINE NESS OF THE ACTIVITIES IN RELATION TO MAIN OBJECT OF EDUCATION, THE LD. DIT(A) RIGHTLY DE NIED REGISTRATION, THE LD. DR ADDED. . 6. . WE HAVE HEARD BOTH THE PARTIES AND GONE THRO UGH THE FACTS OF THE CASE. WE FIND THAT THE APPLICANT TRUST WAS CREATED ON 9 TH OCTOBER, 2009 WITH THE FOLLOWING MAIN OBJECTS AS MENTIONED IN PARA 4A OF THE TRUST D EED:- I) TO PROMOTE EDUCATION AND LEARNING IN ALL ITS BRA NCHES AS ALSO TO UNDERTAKE AND/OR SUPPORT PROJECTS AND MEASURES OF T HE SAID PURPOSE. II) TO DIFFUSE USEFUL EDUCATIONAL, MEDICAL, CULTURA L MORAL, SPIRITUAL, ART, CRAFT AND SOCIAL KNOWLEDGE THROUGH MULTI-MEDIA AND/ OR PROJECTS. III) TO ESTABLISH/TAKEOVER/SUPPORT/RUN MAINTAIN, SC HOOLS, COLLEGES AND/OR SIMILAR OTHER EDUCATIONAL INSTITUTIONS. ITA NOS. 4421&5592 /D/2010 5 IV) TO GIVE GRANTS, SCHOLARSHIPS, STIPENDS, PRIZES, REWARDS, ALLOWANCES AND OTHER ASSISTANCE OR HELP TO DESERVING AND NEEDY STUDENTS/SCHOLARS IN PROMOTING THEIR STUDIES RESEAR CH AND TRAINING. V) TO PROMOTE MEDICAL RELIEF OF ALL SORTS TO HUMANI TY AT LARGE AS ALSO TO UNDERTAKE AND SUPPORT PROJECTS OF THE SAME. VI) TO ESTABLISH/TAKEOVER, SUPPORT AND RUN CHARITAB LE HOSPITALS, CLINICS DISPENSARIES, MEDICAL LABORATORIES, DIAGNOSTIC, TES TING AND HEALTH- CARE AND YOGA CENTERS. VII) TO UNDERTAKE AND SUPPORT PROJECTS FOR HUMAN WE LFARE, RELIEF OF THE NEEDY, DISABLED, INFIRM, DESTITUTE, DOWN TRODDEN, S ICK DISTRESSED, AFFLICTED AND THE LOWER STRATA OF THE SOCIETY; AS A LSO WELFARE AND DEVELOPMENT OF RURAL/BACKWARD AREAS. VIII) TO UNDERTAKE AND SUPPORT JEEV-DAYA MEASURES A ND PROJECTS FOR ALL LIVING BEINGS IN WHATEVER FORM AND/OR MEANS INCLUDI NG FODDER-CENTERS, GAUSHALAS AND VETERINARY CENTRES. IX) TO WORK FOR THE PROTECTION AND PROMOTION OF MUL TI DIMENSIONAL CULTURE AND HERITAGE OF INDIA AND TO UNDERTAKE/SUPPORT PROJ ECTS FOR THE SAME. X) TO PROMOTE UNDERTAKE AND SUPPORT THE DOCTRINE OF AHIMSA AND VEGETARIANISM. XI) TO PROMOTE NATIONAL UNITY AND INTEGRATION. XII) TO TAKE OVER, ESTABLISH, BUILD AND/OR SUPPORT DHARAMSHALAS, SHELTERHOMES, ORPHANAGES, BHOJANSHALAS, COMMUNITY C ENTRES AND OTHER SUCH PUBLIC UTILITY PROJECTS. XIII) TO UNDERTAKE, PROMOTE AND SUPPORT PROJECTS OF RESEARCH AND DEVELOPMENT IN THE FIELDS OF PHILOSOPHY, LITERATURE , MEDICINE, ARTS, ARCHITECTURE, SCIENCES, AGRICULTURE, HORTICULTURE A ND OTHER SUCH DISCIPLINES. XIV) TO WORK FOR THE DEVELOPMENT OF MENTAL, SPIRITU AL AND SOCIO-CULTURAL FACULTIES OF HUMAN RACE AND ESTABLISH/SUPPORT INSTI TUTIONS AND PROJECTS FOR THE PURPOSE. XV) TO PROMOTE SPORTS IN GENERAL AND SUPPORT/UNDERT AKE SPORTS EVENTS AS ALSO TO ESTABLISH, SUPPORT AND/OR TAKE OVER/RUN SPO RTS INSTITUTIONS. XVI) TO UNDERTAKE/SUPPORT RENOVATION (JEERANODHAR) OF OLD MONUMENTS & BUILDINGS OF HISTORICAL VALUE. XVII) TO ESTABLISH, TAKEOVER, MAINTAIN AND/OR SUPPO RT HOSTELS AND PROVIDE BOARDING & LODGING FACILITIES FREE OF COST OR OTHER WISE AS THE TRUSTEES MAY DEEM FIT. XVIII) TO HONOUR SCHOLARS, TEACHERS, SCIENTISTS, TE CHNICIANS, ACHIEVERS, INNOVATORS AND SOCIAL WORKERS WITH AWARDS AND/OR OT HER MEANS. XIX) TO SUPPORT AND/OR UNDERTAKE PROJECTS FOR THE C ONSERVATION OF ECOLOGY, ENVIRONMENT, ENERGY AND WATER RESOURCES. XX) TO GIVE DONATIONS/CONTRIBUTIONS/AID IN CASH OR KIND FOR THE PROMOTION OF AFOREMENTIONED OBJECTS. 6.1 FURTHER, PARA 4B OF THE AFORESAID TRUST DEED CONTAINS INCIDENTAL OR ANCILIARY OBJECTS. INDISPUTABLY, OBJECTS ENSHRINED IN THE TRU ST DEED DATED 9 TH OCTOBER, 2009 ARE CHARITABLE IN THE NATURE. THE LD. DIT(E) CONCLU DED THAT THE APPLICANT DID NOT UNDERTAKEN ANY CHARITABLE ACTIVITY AND THEREFORE, W AS NOT ENTITLED TO REGISTRATION U/S 12A OR APPROVAL U/S 80G(5)(VI) OF THE ACT WHILE THE LD. AR NOW PLEADED THAT THE ITA NOS. 4421&5592 /D/2010 6 APPLICANT HAD DONATED AN AMOUNT OF 1 LAC TO CHINMAY A MISSION, A TRUST HAVING SIMILAR OBJECTS. HOWEVER, THERE IS NOTHING ON RECOR D TO SUGGEST THAT CHINMAYA MISSION IS HAVING SIMILAR OBJECTS AS THE APPLICANT TRUST NOR THE LD. AR BROUGHT TO OUR NOTICE ANY MATERIAL IN THAT CONNECTION. MOREOVER, T HE PAPER BOOK FILED BEFORE US CONTAINS PAGES 1 TO 34 BY WAY OF DOCUMENTS ,WHICH WERE NOT BEFORE THE LD. DIT(E). PAGE 1 TO 14 ARE A COPY OF APPLICATION FO R ALLOTMENT OF LAND FOR SETTING UP OF A SCHOOL , PG. 15 TO 26 A COPY OF PROJECT REPOR T FOR SETTING UP OF SCHOOL AND PAG.27 TO 34-A COPY OF AUDITED BALANCESHEET AS ON 3 1.3.2010. ADMITTEDLY, THESE DOCUMENTS WERE NOT BEFORE THE LD. DIT(E) NOR THE AP PLICANT SUBMITTED ANY APPLICATION BEFORE US FOR ADMISSION OF ADDITIONAL E VIDENCE. IN ANY CASE, THERE IS NOTHING TO SUGGEST AS TO WHETHER OR NOT THE LD. DIT (E) CONDUCTED ANY INDEPENDENT ENQUIRIES TO ASCERTAIN THE GENUINENESS OF ACTIVITI ES OF THE TRUST BEFORE REJECTING THE APPLICATION FOR REGISTRATION NOR SEEMS TO HAVE ALL OWED SUFFICIENT OPPORTUNITY TO THE APPLICANT TRUST BEFORE REJECTING THE APPLICATION.. IN THESE CIRCUMSTANCES , WE CONSIDER IT FAIR AND APPROPRIATE TO VACATE THE FIN DINGS OF THE LD. DIT(E) AND RESTORE THE MATTER TO HIS FILE WITH THE DIRECTIONS TO ALLOW SUFFICIENT OPPORTUNITY TO THE ASSESSEE FOR ESTABLISHING GENUINENESS OF THE ACTIVI TIES OF THE TRUST AND THEREAFTER, PASS A SPEAKING ORDER IN ACCORDANCE WITH LAW . WE M AY CLARIFY THAT THE LD. DIT(E) IS FREE TO UNDERTAKE ANY INDEPENDENT ENQUIRIES, NECESS ARY TO ASCERTAIN THE GENUINENESS OF ACTIVITIES OF THE TRUST. WITH THESE DIRECTIONS GROUND NO.1 IN THESE TWO APPEALS IS DISPOSED OF. 7. NO ADDITIONAL GROUND HAVING BEEN RAISED BEFORE US IN TERMS OF RESIDUARY GROUND NO. 3 & 2 OF THE RESPECTIVE APPEALS, THEREFO RE, THESE GROUNDS ARE DISMISSED. 8. NO OTHER PLEA OR ARGUMENT WAS MADE BEFORE US. 9. IN THE RESULT, BOTH THESE APPEALS ARE ALLOWED BUT FOR STATISTICAL PURPOSES. SD/- SD/- (DIVA SINGH) (A.N. PAHUJA) (JUDICIAL MEMBER) (ACCOUNTANT MEMBER) ORDER PRONOUNCED IN OPEN COURT ITA NOS. 4421&5592 /D/2010 7 COPY OF THE ORDER FORWARDED TO :- 1. RAJENDRA KUMAR & NIRMALA GUPTA CHARITABLE TRUST,89, OLD ISHWAR NAGAR, OKHLA MORE, NEW DELHI. 2. DIT(EXEMPTIONS),AAYAKAR BHAWAN, DISTRICT CENTRE,LAXMI NAGAR, NEW DELHI. 3.. DR, ITAT,F BENCH, NEW DELHI 4.. GUARD FILE. BY ORDER, DEPUTY / ASSTT.REGISTRAR ITAT,DE LHI BENCHES