The ITO, Ward-2, Surendranagar V. Shri Dharmendrabhai Muljibhai doshi, Surendranagar

ITA 463/RJT/2012

• Counselvise Citation: 46324914 RSA 2012
• Duration Of Justice: 1 year(s) 7 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 14-08-2013
• Appeal Filed By: Department
• Order Result: Allowed
• Bench Allotted: DB
• Next Hearing Date: 26-07-2013
• Assessment Year: 2008-2009
• Appeal Filed On: 07-08-2012
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: M K SINGH DR CIS
• Keywords: Unexplained expenditure; Salary income; Charitable institution; Peak credit; Additional evidence; Corroborative evidences
• Section: 143(3)

Judgement Text

D , IN THE INCOME TAX APPELLATE TRIBULAL; RAJKOT BENCH, RAJKOT. B . . CR B . . B BEFORE SHRI T. K. SHARMA JM AND SHRI D. K. SRIVASTAVA AM ITA NO. 4 6 3/RJT/2012 CI I / ASSESSMENT YEAR 200 8 - 09. THE INCOME - TAX OFFICER, WARD - 2,SURENDRANAGAR,ROOM NO.5, IRISH HOSPITAL BUILDING, OPP: MELA MAIDAN, S URENDRANAGAR . ( / APPELLANT) SHRI DHARMENDRABHAI MULJ I BHAI DOSHI, MAH AVIR SOCIETY, NR. JNV HIGH SCHOOL, SURENDRANAGAR. PAN : A BEPD5975A BH / RESPONDENT / REVENUE BY SHRI M. K. SINGH , DR CIS / ASSESSEE BY NONE / DATE OF HEARING 26 - 07 - 2013 / DATE OF PRONOUNCEMENT 14 - 08 - 2013 / ORDER . . , CR / T. K. SHARMA, J. M. : THIS APPEAL BY THE REVENUE IS AGAINST THE ORDER DATED 21 ST MAY, 2012 OF LD. CIT (A ) - XVI, AHMEDABAD FOR THE ASSESSMENT YEAR 200 8 - 09. 2 . ON THE DATE FIXED FOR HEAR ING, NONE WAS PRESENT FROM THE SIDE OF THE ASSESSEE. AN APPLICATION FOR ADJOURNMENT IS FILED WHEREIN REQUEST WAS MADE TO ADJOURN THE CASE ON THE GROUND THAT COUNSEL OF THE ASSESSEE IS BUSY WITH MEDICAL INVESTIGATION S AND MEDICAL TREATMENT OF HIS FATHER. O N THE LAST DATE OF HEARING I.E. 14 - 06 - 2013, THIS CASE WAS ADJOURNED AND IT WAS MADE CLEAR IN THE OPEN COURT THAT NO FURTHER ADJOURNMENT WILL BE ALLOWED. THIS CASE HAS BEEN ADJOURNED MORE THAN THREE TIMES THEREFORE, WE PROCEED TO DECIDE THIS APPEAL ON THE BASIS OF SUBMISSIONS MADE BY LD. DR AND MATERIALS AVAILABLE ON RECORD. 3. T HE FACTS , IN BRIEF, ARE THAT THE ASSESSEE IS A N INDIVIDUAL DERIVING INCOME FROM SALARY, INTEREST AS WELL AS CAPITAL GAIN. FOR THE ASSESSMENT YEAR UNDER APPEAL, HE FILED THE RETURN OF INCOME ON 30 - 07 - 2008 DECLARING T OTAL INCOME OF RS. 1,03,030 / - . DURING THE COURSE OF ASSESSMENT PROCEEDINGS, IT WAS NOTICED THAT ASSESSEE HAS CREDITED RS.10,23,500/ - BY CASH IN ACCOUNT NO.SS/27446 WITH ADARSH CO OPERATIVE BANK, SURENDRANAGAR (OLD NAME TH E SNR MERCANTILE CO ITA 4 6 3 - 2012 2 OP BANK) DURING THE FY 2007 - 08 RELEVANT TO AY 2008 - 09, THE DETAILS OF WHICH ARE ENUMERATED BY AO IN PARA - 4(I) OF THE ASSESSMENT ORDER. ON VERIFICATION, AO FURTHER NOTICED THAT AFORESAID BANK ACCOUNT IS NOT ACCOUNTED IN THE BOOKS OF ACCO UNTS OF THE ASSESSEE FOR THE F.Y. 2007 - 08 RELEVANT TO ASSESSMENT YEAR UNDER APPEAL AND CLOSING BALANCE AMOUNTING TO RS.963.62 WAS ALSO NOT REFLECTED IN THE BALANCE SHEET. THE ASSESSEE HAS ALSO CREDITED RS.12,54,112/ - IN THE SAID BANK ACCOUNT BY CLEARING AN D TRANSFER OF VARIOUS CHEQUES. IN THIS MANNER, AO NOTICED THAT ASSESSEE HAS CREDITED AGGREGATE AMOUNT OF RS.22,77,612/ - DURING THE F.Y. 2007 - 08 AND ENTIRE BANK ACCOUNTS REMAINED UNACCOUNTED. AO ALLOWED AMPLE OPPORTUNITIES TO ASSESSEE TO FURNISH EXPLANATIO N IN RESPECT OF NATURE AND SOURCE OF CASH DEPOSITED IN THE BANK ACCOUNT BUT NO EXPLANATION WAS FURNISHED. AO ACCORDINGLY, FINALIZED THE ASSESSMENT U/S. 143(3) OF THE I.T. ACT WHEREIN HE MADE ADDITION OF RS.22,77,612/ - U/S.69C OF THE I.T. ACT, 1961. 4. O N APPEAL IN THE IMPUGNED ORDER, THE LD. CIT (A) WORKED OUT THE PEAK CREDIT AND RESTRICTED THE ADDITION OF RS.22,77,612/ - TO RS.7,46,200/ - AS MENTIONED IN PARA - 3.4 ON PAGE 14 OF THE IMPUGNED ORDER, WHICH READS AS UNDER: - 3.4 THIS NOW LEAVES US TO THE QUESTIO N OF DETERMINING THE AMOUNT WH I CH REQUIRES TO BE ADDED BACK TO THE TOTAL INCOME OF THE APPELLANT TAKING THE PEAK CREDIT THEORY. A PERUSAL OF THE BANK ACCOUNT SHOWS THAT THE HIGHEST AMOUNT OF CASH DEPOSIT ON ONE SINGLE DAY I.E. ON 12 - 01 - 2008 WAS RS.5,40,000 / - . SIMILARLY, THE HIGHEST AMOUNT OF CHEQUE DEPOSIT ON A SINGLE DAY I.E.19 - 02 - 2008 WAS RS.2,06,200/ - . THUS, THE AMOUNT OF CORRECT ADDITION APPLYING THE PEAK CREDIT THEORY WORKS OUT TO RS.7,46,200/ - BEING THE AGGREGATE OF RS. 5,40,000/ - + RS.2,06,200/ - . ACCO RDINGLY, THE ADDITION MADE BY THE A.O. AMOUNTING TO RS.22,77,612/ - TAKING CUMULATIVE TOTAL OF ALL THE CASH AND CHEQUE DEPOSIT IN THE SAID BANKS ( CORRECT FIGURE RS.20,39,634/ - ) APPLYING PEAK CREDIT THEORY OF ROLL OVER OF THE SAME FUNDS IS RESTRICTED TO RS. 7,46,200/ - AS ABOVE. AGGRIEVED WITH THE ORDER OF LD. CIT (A), THE REVENUE IS IN APPEAL BEFORE THE TRIBUNAL ON THE FOLLOWING GROUNDS: - 1 . THE LD. CIT (A) HAS ERRED IN LAW AND ON FACTS IN DELETING THE ADDITION OF RS.1 5,31,412 / - MADE ON ACCOUNT OF UNACCOUNTE D INVESTMENT U /S.6 9C OF THE ACT WITHOUT PROPERLY APPRECIATING THE FACT OF THE CASE AND MATERIAL BROUGHT ON RECORD BY THE A.O. 2 . THE LD. CIT (A) HAS ALSO ERRED IN LAW AND ON FACTS IN ADMITTING THE ADDITIONAL EVIDENCES IN CONTRAVENTION TO RULE 46A OF I.T. RUL ES, 1962, AS INSPITE OF NUMBER OF OPPORTUNITIES GIVEN TO THE ASSESSEE TO PRODUCE BOOKS OF ACCOUNTS AND OTHER DOCUMENTS , THE ASSESSEE FAILED TO DO SO. 3 . O N THE FACTS & CIRCUMSTANCES OF THE CASE, THE LD. CIT (A) OUGHT TO HAVE UPHELD THE ORDER OF THE ASSESSING OFFICER. ITA 4 6 3 - 2012 3 4 . IT IS THEREFORE , PRAYED THAT THE ORDER OF THE LD. CIT (A) MAY BE SET - ASIDE AND THAT OF THE ORDER OF THE ASSESSING OFFICER BE RESTORED TO THE ABOVE EXTENT. 5 . AT THE TIME OF HEARING BEFORE US, SHRI M. K. SINGH, DR, APPEARED FOR THE REVENUE POINTE D OUT THAT DURING THE COURSE OF SCRUTINY PROCEEDINGS, THE AO ASKED THE ASSESSEE RIGHT FROM NOTICE U/S.142(1) DATED 01 - 08 - 2010 FOR FURNISHING OF EXPLANATION OF CREDIT OF RS. 22,77,612/ - BUT ASSESSEE HAS NOT FURNISHED THE SAME. HE POINTED OUT THAT IN FACT, DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE ASSESSEE WAS ASKING TIME FOR PREPARING OF FABRICATING DOCUMENTS. THE LD. DR FURTHER POINTED OUT THAT THE ASSESSMENT OF THE ASSESSEE WAS GETTING TIME BARRED BY LIMITATION THEREFORE EXPLANATION FURNISHED ONLY ON 03 - 12 - 2010 WHICH IS ALSO HALF - DONE. CONTINUING HIS ARGUMENT, THE LD. DR POINTED OUT THAT THE DECISION OF LD. CIT (A) IS NOT ACCEPTABLE FOR RESTRICTING THE ADDITION OF RS.7,46,200/ - ALLOWING THE RELIEF OF RS.15,31,412/ - AS THE ASSESSEE HAS NOT FURNISHE D THE COMPLETE DETAILS IN RESPECT OF AMOUNT CREDITED IN BANK ACCOUNT BY CASH AND CHEQUE. HE FAILED TO EXPLAIN SOURCE OF AMOUNT DEPOSITED IN BANK ACCOUNT AND SOURCE OF AMOUNT CREDITED IN THE BANK ACCOUNT THEREFORE CREDIT OF BANK ACCOUNT IS HELD TO BE AS UNE XPLAINED INVESTMENT U/S.69C OF THE I.T. ACT, 1961. HE FURTHER SUBMITTED THAT THE BENEFIT OF PEAK CREDIT CANNOT BE ALLOWED UNLESS THE ASSESSEE PROVE S THE NEXUS AS RECENTLY HELD BY HONBLE ITAT MUMBAI BENCH B IN THE CASE OF M. H. R ANEY V. ITO, 12 (3)(1) [2 013] 34 TAXMANN.COM 5 (MUMBAI - TRIB.) W HEREIN, IT WAS HELD THAT WHE RE NEITHER NATURE OF CASH DEPOSIT S IN BANK N OR UTILIZATION STANDS EXPLAINED BY ASSESSEE SATISFACTORILY, HIS PLEA THAT ONLY PEAK AMOUNT OF RS.5.32 LAKHS OUGHT TO BE SUBJECT ED TO TAX WAS NOT MAINTAINABLE. THE LD. DR POINTED OUT TH AT FOLLOWING THE DECISION, IT MAY BE HELD THAT ASSESSEE IS NOT ENTITLED TO THE BENEFIT OF PEAK CREDIT THEORY. FINALLY, THE LD. DR DREW OUR ATTENTION TO PARA - 2 OF THE REMAND REPORT DATED 06 - 03 - 2012 OF AO WHICH IS REPRO DUCED IN PARA - 6 OF THE IMPUGNED ORDER WHEREIN, AO HAS MENTIONED THAT IN THE WRITTEN SUBMISSION OF THE ASSESSEE FORWARDED TO AO CALLING REMAND REPORT, EXPLANATION OF THE ASSESSEE WAS NOT FOUND ENCLOSED. IN THIS MANNER, THE LD. CIT (A) HAS ADMITTED THE FRES H EVIDENCE FOR WHICH AO COULD NOT SUBMIT HIS COMMENTS WHICH IS IN CONTRAVENTION OF RULE 46A OF THE I.T. RULES, 1962. ITA 4 6 3 - 2012 4 6. AFTER HEARING THE LD. DR, WE HAVE CAREFULLY GONE THROUGH THE ORDERS OF AUTHORITIES BELOW. RECENTLY, THE MUMBAI TRIBUNAL IN THE CASE OF M . H. R A NE Y (SUPRA) HELD AS UNDER (HEAD NOTES FROM (2013) 34 TAXMAN.COM 5 (MUMBAI TRIB): - SECTION 69A OF THE INCOME - TAX ACT, 1961 - UNEXPLAINED MONEYS [PEAK CREDIT THEORY] - ASSESSMENT YEAR 2008 - 09 - WHETHER PEAK CREDIT THEORY IS BASED ON RECYCLING OF FUND S IMPLYING SYSTEMATIC ACTIVITY - HELD, YES - DURING PREVIOUS YEAR ASSESSEE HAD DEPOSITED CASH IN AGGREGATE OF RS. 29.16 LAKHS IN HIS BANK ACCOUNT - ASSESSEE'S SON IN HIS REPRESENTATIVE CAPACITY APPEARED BEFORE ASSESSING OFFICER AND MADE EXPLANATION TO EFFE CT THAT (I) HIS FATHER HAD EXPIRED IN SEPTEMBER, 2009 AND BANK ACCOUNT WAS HANDLED EXCLUSIVELY BY HIM, (II) SAID SUM COMPRISED OF CASH/CONTRIBUTIONS COLLECTED FROM VARIOUS DONORS OUTSIDE MUMBAI IN SMALL AMOUNTS WITH HELP OF FEW VOLUNTEERS AND WELL WISHERS TO BE UTILIZED FOR CHARITABLE PURPOSES IN WHICH HIS FATHER WAS ACTIVELY INVOLVED, (III) IN VIEW OF CLOSE PROXIMITY BETWEEN CASH DEPOSITS AND WITHDRAWALS, SUBSEQUENT DEPOSITS SHOULD BE TREATED AS SOURCED FROM SAID WITHDRAWALS, IN WHICH CASE AMOUNT OF UNEXPL AINED CASH DEPOSITS WOULD STAND REDUCED TO RS. 5.32 LAKHS , AND (IV) THEREFORE, ONLY PEAK AMOUNT OF RS. 5.32 LAKHS OUGHT TO BE SUBJECTED TO TAX - SAID EXPLANATION WAS NOT SUPPORTED BY ANY CORROBORATIVE EVIDENCE - ASSESSING OFFICER REJECTED EXPLANATION AND T REATED ENTIRE AMOUNT OF DEPOSITS AS UNEXPLAINED CASH DEPOSITS - WHETHER SINCE NEITHER NATURE OF CASH DEPOSITS IN BANK NOR THEIR UTILIZATION WAS EXPLAINED BY ASSESSEE'S SON SATISFACTORILY, HIS PLEA THAT ONLY PEAK AMOUNT OF RS. 5.32 LAKHS OUGHT TO BE SUBJECT ED TO TAX WAS NOT MAINTAINABLE - HELD, YES [PARA 6] [IN FAVOUR OF REVENUE] FACTS THE ASSESSING OFFICER HAVING NOTICED THAT DURING THE ASSESSMENT YEAR 2008 - 09 THE ASSESSEE HAD DEPOSITED CASH IN THE AGGREGATE OF RS. 29.16 LAKHS IN HIS BANK ACCOUNT REQUIRED HIM TO FURNISH AN EXPLANATION WITH SUPPORTING EVIDENCE WITH REGARD TO THE SOUR CE OF THE CASH DEPOSITED IN BANK. THE ASSESSEE'S SON IN HIS REPRESENTATIVE CAPACITY APPEARED BEFORE THE ASSESSING OFFICER AND MADE AN EXPLANATION TO THE EFFECT THAT (I) HIS FATHER HAD EXPIRED IN SEPTEMBER, 2009 AND THE BANK ACCOUNT WAS HANDLED EXCLUSIVELY BY HIM, (II) THE SAID SUM IN FACT COMPRISED OF CASH/CONTRIBUTIONS COLLECTED FROM VARIOUS DONORS OUTSIDE MUMBAI IN SMALL AMOUNTS WITH THE HELP OF FEW VOLUNTEERS AND WELL WISHERS TO BE UTILIZED FOR CHARITABLE PURPOSES IN WHICH HIS FATHER WAS ACTIVELY INVOLVE D, (III) IN VIEW OF THE CLOSE PROXIMITY BETWEEN THE CASH DEPOSITS AND WITHDRAWALS, THE SUBSEQUENT DEPOSITS SHOULD BE TREATED AS SOURCED FROM THE SAID WITHDRAWALS, IN WHICH CASE THE AMOUNT OF UNEXPLAINED CASH DEPOSITS WOULD STAND REDUCED TO RS. 5.32 LAKHS A ND (IV) THEREFORE, ONLY PEAK AMOUNT OF RS. 5.32 LAKHS, OUGHT TO BE SUBJECTED TO TAX. THE SAID EXPLANATION WAS NOT SUPPORTED BY ANY CORROBORATIVE EVIDENCE. THE ASSESSING OFFICER DID NOT ACCEPT THE EXPLANATION OF THE ASSESSEE'S SON AND TREATED THE ENTIRE AMOUNT OF DEPOSITS AS UNEXPLAINED CASH DEPOSIT. HE, THEREFORE, ADDED THE ENTIRE AMOUNT OF DEPOSITS IN THE ASSESSEE'S INCOME. ON APPEAL, THE COMMISSIO NER (APPEALS) UPHELD THE ORDER OF THE ASSESSING OFFICER. ON SECOND APPEAL: ITA 4 6 3 - 2012 5 HELD THE UNDISCLOSED PROFITS EARNED DURING AN EARLIER YEAR COULD CONSTITUTE A SOURCE OF EITHER UNACCOUNTED EXPENDITURE OR INVESTMENT, I.E., SUFFERED OR MADE BY AN ASSESSE E SUBSEQUENTLY, AS THE CASE MAY BE, IS A WELL - SETTLED PROPOSITION. THIS IS AS THERE IS NO, NOR POSSIBLY COULD BE ANY, BAR IN LAW ON APPLICATION OF FUNDS AVAILABLE WITH THE ASSESSEE FOR HIS PURPOSES. HOWEVER, BOTH THE EXISTENCE OF THE FUNDS AS WELL AS THEIR SUBSEQUENT UTILIZATION ARE ESSENTIALLY MATTERS OF FACT TO BE REASONABLY ESTABLISHED BY THE ASSESSEE OR THE INFERENCE AS TO WHICH WOULD FLOW ON AN OVERALL CONSIDERATION OF THE FACTS AND CIRCUMSTANCES OF THE CASE. THE UNACCOUNTED PROFITS OF THE PAST, MAY WE LL HAVE BEEN EXPENDED OR DISSIPATED ON A HOST OF AVENUES, SO THAT THE FACT THAT IT WAS NOT SO, AND THE SAME WERE INDEED AVAILABLE, AND DRAWN UPON DURING THE RELEVANT YEAR, LIQUIDATING THE CORRESPONDING INVESTMENT OR ANY OTHER FORM IN WHICH THE SAME WERE HE LD, WOULD BE REQUIRED TO BE REASONABLY SHOWN. IN EACH CASE, THEREFORE, IT HAS TO BE INDIVIDUALLY DETERMINED WHETHER IT IS A FIT CASE FOR APPLICATION OF THE PEAK CREDIT THEORY, WHICH ESSENTIALLY SIGNIFIES OR GIVES CREDENCE TO THE RECYCLING OF FUNDS. [PARA 5 .1] THE EXPLANATION OF THE ASSESSEE'S SON IS VAGUE AND UNSUBSTANTIATED, CONTENDING RECYCLING SO AS TO IMPACT THE ADDITION TO INCOME EXIGIBLE ON ACCOUNT OF THE UNEXPLAINED NATURE AND SOURCE OF THE INVESTMENT. THE PEAK CREDIT THEORY IS BASED ON RECYCLIN G OF FUNDS IMPLYING SYSTEMATIC ACTIVITY. IN THE INSTANT CASE, NEITHER OF THE DEPOSITS NOR THEIR UTILISATION STANDS EXPLAINED. SO THAT THE PLEA IS NOT MAINTAINABLE AT THE THRESHOLD. SCRUTINY OF THE BANK ACCOUNT STATEMENT REVEALS IT TO BE INCONSISTENT WITH N OT ONLY THE EXPLANATION OF THE AMOUNTS BEING POSSIBLY USED FOR CHARITABLE PURPOSES, BUT ALSO WITH THE FACT OF THE SAME BEING, APART FROM WITHDRAWN IN CASH, ALSO BY CHEQUES FOR OSTENSIBLY PERSONAL PURPOSES, ON A REGULAR BASIS AND IN NO INSIGNIFICANT SUMS. F URTHER THE PATTERN OF WITHDRAWAL REVEALS THE ACCOUNT TO BE EMPLOYED FOR TRANSFER OF FUNDS IN THE MAIN, I.E., DEPOSIT OF CASH AT ONE PLACE AND ITS WITHDRAWAL AT OTHER, THE FUNDS BEING WITHDRAWAL ALMOST IN TOTO AND SOON AFTER THEIR DEPOSIT. THE ASSESSEE HAS BEEN WHOLLY UNABLE TO DISCHARGE THE ONUS OF A SATISFACTORY EXPLANATION QUA CASH DEPOSITS, INCLUDING THE QUANTUM OF FUNDS INVOLVED. ACCORDINGLY, HIS APPEAL FAILS. [PARA 6] . 7. THERE IS NO DOUBT AND DEBATE THAT BENEFIT OF PEAK CREDIT CANNOT BE ALLOWED UNL ESS THE ASSESSEE PROVE S THE NATURE AND SOURCE OF CASH AND CHEQUE DEPOSIT. THOUGH, THE ASSESSEE HAS STATED BEFORE THE LD. CIT (A) THAT HE HAD EXPLAINED EACH ENTRY RECORDED IN THE BANK STATEMENT BUT ON VERIFICATION OF ASSESSEES SUBMISSION, AO NOTICED THAT SUBMISSION OF ASSESSEE FORWARDED TO AO CALLING REMAND REPORT ENCLOSURE WAS MISSING. SINCE NONE WAS PRESENT BEFORE US AT THE TIME OF HEARING, WE THEREFORE IN THE INTEREST OF JUSTICE, REMAND THE CONTROVERSY INVOLVED IN THIS APPEAL TO THE FILE OF LD. CIT (A) WITH THE DIRECTION THAT LD. CIT (A) AGAIN FORWARDED THE SUBMISSION OF ASSESSEE WHICH CONTAINS EXPLANATION OF THE ASSESSEE IN RESPECT OF EACH AND EVERY CREDIT AND DEBIT OF ALL THE ENTRIES IN BANK ACCOUNT. AO THEREAFTER SUBMIT HIS COMMENTS. THE LD. CIT (A) C ONSIDER THE COMMENTS OF AO AND THEREAFTER RE - ADJUDICATE THE CONTROVERSY ITA 4 6 3 - 2012 6 INVOLVED IN THIS APPEAL AFRESH KEEPING IN VIEW THE DECISION OF ITAT MUMBAI BENCH IN THE CASE OF M. H. RANEY (SUPRA). 8 . IN THE RESULT, FOR STATISTICAL PURPOSES, THE APPEAL OF THE REVE NUE IS TREATED AS ALLOWED. 9 . THIS O RDER IS PRONOUNCED IN OP EN COURT ON THE DATE MENTIONED HEREINABOVE. SD/ - SD/ - ( . . D. K. SRIVASTAVA ) ( . . I / T. K. SHARMA) / ACCOUNTANT MEMBER C / JUDICIAL MEMBER / ORDER DATE 14 - 08 - 2013. /RAJKOT NVA/ - 8 RJO O / COPY OF ORDER FORWARDED TO: - 1 . / APPELLANT - THE INCOME - TAX OFFICER, WARD - 2 , SURENDRANAGAR, ROOM NO.5, IRISH HOSPITAL B UILDING, OPP: MELA MAIDAN, SURENDRANAGAR. 2 . BH / RESPONDENT - SHRI DHARMENDRABHAI MULJBHAI DOSHI, MAHAVIR SOCIETY, NR. JNV HIGH SCHOOL, SURENDRANAGAR 3 . D E / CONCERNED CIT - V, AHMEDABD 4 . E - / CIT (A) - XVI, AHMEDABAD. 5 . BCCD , D , / DR, ITAT, RAJKOT 6 . I / GUARD FILE. / BY ORDER TRUE COPY. PRIVATE SECRETARY, ITAT, RAJKOT