M/s Chittosho Motor, Patiala V. ACIT, Patiala

ITA 525/CHANDI/2011

• Counselvise Citation: 52521514 RSA 2011
• Duration Of Justice: 7 month(s) 28 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 10-01-2012
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: B
• Next Hearing Date: 05-01-2012
• Assessment Year: 2007-2008
• Appeal Filed On: 13-05-2011
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: S KHEMWAL

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL CHANDIGARH BENCH B CHANDIGARH BEFORE SHRI H.L.KARWA, VICE PRESIDENT AND SHRI MEHAR SINGH, ACCOUNTANT MEMBER ITA NO. 525/CHD/2011 ASSESSMENT YEAR: 2007-08 M/S CHITTOSHO MOTOR, V ACIT, CIRCLE, SIRHIND ROAD, PATIALA. PATIALA. PAN: AACFC-8334M (APPELLANT) (RESPONDENT) ASSESSEE BY : SHRI TEJ MOHAN SINGH DEPARTMENT BY : SHRI S.KHEMWAL DATE OF HEARING : 05.01.2012 DATE OF PRONOUNCEMENT : 10.01.2012 ORDER PER MEHAR SINGH, AM THE PRESENT APPEAL FILED BY THE ASSESSEE IS DIRECTE D AGAINST THE ORDER DATED 08.03.2011 PASSED BY THE LD . CIT(A) U/S 250(6) OF THE INCOME-TAX ACT,1961 (IN SHORT 'TH E ACT'). 2. IN THIS APPEAL, THE ASSESSEE HAS RAISED THE FOLL OWING GROUNDS OF APPEAL: 1. THAT THE APPELLATE ORDER IS AGAINST THE LAW AND FACTS OF THE FILE. 2. THAT LD. ACIT HAS WRONGLY MADE AN ADDITION OF RS.7,37,022/- ON ACCOUNT OF UNDER VALUATION OF STOCK OF MOTOR CYCLES & SPARES PARTS. THE CIT(A) HAS SUSTAINED THE ENTIRE ADDITION MADE BY THE LD. ACIT WITHOUT ASSIGNING ANY SPECIFIC REASON FOR THE SAME.. 2 3. THE LD. ACIT HAS MADE AN ADDITION OF RS.1,00,000/- OUT OF PURCHASES OF STATIONERY & PRINTED MATERIAL IN MOHALI BRANCH WHICH WAS PURCHASED ON ACCOUNT OF NEW OPENING OF MARUTI SHOWROOM. NO VALUE OF STOCK WAS LEFT AT THE END OF THE YEAR. THE AO MADE AN ADDITION OF RS.1,00,000/- ON ACCOUNT OF NON AVAILABILITY OF CLOSING STOCK. THE LD. CIT(A) HAS CONFIRMED THE SAME WITHOUT ASSIGNING ANY SPECIFIC REASON FOR THE SAME. 4. THE FIRM IS MAINTAINING A GUEST HOUSE AT MOHALI FOR THE STAY OF OFFICER OF MARUTI UDYOG LTD. AND HAS PAID RENT OF RS.1,26,667/- FOR THE PERIOD 20.09.2006 TO 2.3.2007 TO SHRI SHAKUNTLA DEVI & NIRPINDER. THE LD. ACIT HAS DISALLOWED THE SUM OF RS.1,26,667/- ON ACCOUNT OF RENT PAID FOR MAINTAINING A GUEST HOUSE AT MOHALI ON FLIMSY GROUNDS. THE LD. CIT(A) HAS CONFIRMED THE SAME WITHOUT ASSIGNING ANY SPECIFIC REASON FOR THE SAME. 5. THE LD. ACIT HAS MADE A DISALLOWANCE OF RS.1,00,000/- ON ACCOUNT OF EXPENSES DEBITED TO THE PROFIT & LOSS ACCOUNT I.E. ON ACCOUNT OF STAFF TEA, HOUSE KEEPING & GENERAL EXPENSES. OUT OF TOTAL EXPENSES OF RS.13,44,596/- OUT OF WHICH RS.7,00,838/- PERTAINS TO PATIALA HEAD OFFICE AND RS.6,43,758/- OF MOHALI BRANCH. OUT OF TOTAL OF RS.6,43,758/- MOHALI BRANCH EXPENSES A SUM OF RS.1,52,117/- HAS BEEN PAID FOR HOUSE KEEPING EXPENSES TO M/S BROOKE & HADLEY, CHANDIGARH FROM 2.1.2007 TO 31.3.2007 AND THE REST OF THE EXPENSES ARE ON ACCOUNT OF STAFF TEA EXPENSES, REFRESHMENTS & EXPENSES PERTAINING TO MAHURAT OF NEWLY OPENED SHOWROOM OF MARUTI VEHICLES AT MOHALI. THE LD. CIT(A) HAS CONFIRMED THE ADDITION MADE 3 BY THE LD. ACIT WITHOUT ANY REASON, SIMPLY ON THE PLEA THAT THE AO HAS MADE THE REASONABLE DISALLOWANCE. 3. GROUND NO.1 IS GENERAL IN NATURE AND NEEDS NO SEPARATE ADJUDICATION. 4. IN GROUND NO.2, THE ASSESSEE CONTENDED THAT CIT( A) HAS WRONGLY SUSTAINED ADDITION OF RS.7,37,022/- ON ACCOUNT OF UNDER VALUATION OF STOCK OF MOTOR CYCLES AND SPA RES. IN THE COURSE OF PRESENT APPELLATE PROCEEDINGS, IT WAS CONCEDED BY THE LD. 'AR', AFTER REFERRING TO PAGE 19 TO 30 O F THE PAPER BOOK AND PARA 11 OF THE ORDER OF THE ITAT, CHANDIGA RH IN ASSESSEE'S OWN CASE VIDE ITA NO. 1233/CHD/2009 A.Y. 2006-07, DATED 18.03.2012, THAT THE ISSUE IS COVERE D AGAINST THE REVENUE. THE RELEVANT PART OF THE ORDE R OF THE ITAT IS REPRODUCED HEREUNDER : 11. GROUND NOS.4 AND 5 RAISED BY THE REVENUE ARE AGAINST THE ADDITION MADE ON ACCOUNT OF VALUATION O F STOCK. THE ASSESSEE HAS ALSO RAISED GROUND NO.2 IN ITS APP EAL AGAINST THE ADDITION OF 20% OF RS.8,59,650/- BEIN G THE ALLEGED UNDER-VALUATION OF CLOSING STOCK OF SPARE PARTS CONFIRMED BY THE COMMISSIONER OF INCOME-TAX (A). T HE ASSESSEE, BY GROUND NO.2 IN ITS CROSS OBJECTION HAS ALSO RAISED THE ISSUE AS IN GROUND NO.2 OF ITS APPEAL. THE GROUND NO.3 RAISED BY THE ASSESSEE IN ITS CROSS OBJ ECTION IS IN SUPPORT OF THE ORDER OF THE COMMISSIONER OF I NCOME- TAX (A) IN RESPECT OF DELETION OF ADDITION ON ACCOU NT OF VALUATION OF CLOSING STOCK OF MOTORCYCLES. 12. THE BRIEF FACTS RELATING TO THE ISSUE ARE THAT THE ASSESSEE IS AN AUTHORIZED DEALER OF HERO HONDA MOTO RS LTD. AT PATIALA. DURING THE COURSE OF ASSESSMENT PROCE EDINGS, THE ASSESSING OFFICER FOUND THAT THE ASSESSEE WAS 4 MAINTAINING QUANTITATIVE TALLY OF VEHICLES BUT NO S TOCK REGISTER WAS MAINTAINED IN RESPECT OF SPARE PARTS. AS PER THE INVENTORY, THE CLOSING STOCK OF THE ASSESSEE WA S VALUED AT RS.3,38,08,303/-, WHICH INCLUDED STOCK OF SPARE PARTS OF RS.85,96,513/-. THE ASSESSING OFFICER PERUSED THE BILL OF PURCHASE OF 55 VEHICLES OF SPLENDOR PLUS BRAND, AS PER WHICH THE COST OF EACH MOTORCYCLE CAME TO RS.35,841 /-, WHILE THE ASSESSEE HAD SHOWN IN ITS STOCK THE VALUE AT RS.33,519/-. THE ASSESSING OFFICER WAS OF THE VIEW THAT THE ASSESSEE HAD UNDERVALUED ITS STOCK OF MOTORCYCLES. IN RESPECT OF INVENTORY OF SPARE PARTS FILED ALONGWITH BILLS, THE ASSESSING OFFICER ON VERIFICATION FOUND THAT TH ESE WERE VALUED AT PURCHASE RATES BUT NO OVERHEAD EXPENSES I .E. FREIGHT, INSURANCE AND CST WERE ADDED. THE ASSESSE E WAS ASKED TO PRODUCE THE BILLS/VOUCHERS FOR VERIFICATIO N AND IN THE ABSENCE OF THE SAME, THE PROVISIONS OF SECTION 145(3) OF THE INCOME-TAX ACT WERE ATTRACTED. THE ASSESSING O FFICER ALSO NOTED THAT AS PER THE NOTES OF THE AUDITOR IN PARA-5, THE STOCK WAS VALUED AT COST PRICE. THE ASSESSING OFFICER ESTIMATED THE UNDERVALUATION OF MOTORCYCLES @ 2% AN D SPARE PARTS @ 10% THE VALUE OF WHICH CAME TO RS.5,04,235/- AND RS.8,59,650/- RESPECTIVELY RESULT ING IN ADDITION OF RS.13,63,885/-. 13. BEFORE THE CIT(A) THE PLEA OF THE ASSESSEE WAS THAT ADDITION ON ACCOUNT OF UNDER VALUATION OF MOTOR CYC LES WAS MADE BY TAKING AVERAGE COST WITHOUT CONSIDERING THE MODEL WISE COST OF THE DIFFERENT MOTOR CYCLES REFLECTED I N THE CLOSING STOCK. THE LEARNED AR FURTHER POINTED OUT THAT IN THE BILL REFERRED TO BY THE ASSESSING OFFICER, THER E WERE TWO MODELS OF MOTORCYCLES, SPLENDER PLUS AND SUPER SPLE NDER, COST OF WHICH WAS CALCULATED AS PER INVOICE. THE W ORKING OF THE COST OF BOTH THE MODELS IS REPRODUCED IN PAR A 3.2 AT PAGE 7 OF THE APPELLANT ORDER. THE ASSESSEE ALSO FI LED THE COMPLETE DETAILS OF CLOSING STOCK OF MOTOR CYCLES S HOWING QUANTITY, UNIT PRICE, ELEMENT OF FREIGHT AND INSURA NCE, CENTRAL SALES TAX AND TOTAL VALUE OF THE ITEMS. THE DETAILS WERE CONFRONTED TO THE ASSESSING OFFICER. HOWEVER, IN THE 5 REMAND REPORT, THE ASSESSING OFFICER STATED THAT TH OUGH SUFFICIENT OPPORTUNITIES WERE GIVEN TO THE ASSESSEE , THE ASSESSEE FAILED TO DISCHARGE HIS ONUS DURING ASSESS MENT PROCEEDINGS AND HENCE REJECTED THE EXPLANATION. I N REJOINDER TO THE REMAND REPORT OF THE ASSESSING OFF ICER, THE ASSESSEE SUBMITTED THE MODEL WISE DETAILS OF CLOSIN G STOCK OF MOTOR CYCLES ARE AVAILABLE ON RECORD OF THE ASSE SSING OFFICER. THE DETAILS OF CLOSING STOCK OF SPARE PAR TS GIVING DETAILS OF NATURE OF THE PART, QUANTITY, RATE, OVER HEAD EXPENSES AND FINAL VALUATION WERE FILED. THE CIT( A) HELD THAT THE METHOD ADOPTED BY THE ASSESSING OFFICER I N TAKING AVERAGE COST OF MOTOR CYCLE IS NOT A RECOGNI ZED METHOD OF VALUATION OF STOCK IN THE CASE OF THE FAC TS WHEN COMPLETE DETAILS ARE AVAILABLE WITH THE ASSESSEE. THE CIT(A) FURTHER HELD THAT FROM THE LIST OF STOCK OF MOTOR CYCLE IT IS FOUND THAT THE COST THEREOF RANGES FORM RS. 22000+ TO RS. 66,000+ AND UNDER SUCH CIRCUMSTANCES, IT WILL NOT BE CORRECT TO RESTORE TO WEIGHTED COST. SI NCE, NO DEFECT IN THE WORKING OF THE CLOSING STOCK HAS BEEN POINTED OUT BY THE ASSESSING OFFICER IN HIS COUNTER COMMENT S, IN RESPECT OF MOTOR CYCLE, HENCE, THE ADDITION TO THE EXTENT OF RS. 5,04,235/-, WAS DELETED BY CIT(A). HOWEVER, IN RESPECT OF THE VALUATION OF THE STOCK IN SPARE PART S, THE CIT(A) FORWARDED THE LIST FILED BY THE LEARNED AR F OR THE ASSESSEE TO THE ASSESSING OFFICER WHO HAD REITERATE D THE SAME VIEW AS TAKEN IN THE ASSESSMENT ORDER. THE C IT(A) HOWEVER, TOOK NOTE OF THE PLEA OF THE ASSESSEE THA T THE GP PERCENTAGE SHOWN WAS HIGHER THAN SHOWN IN THE EARLI ER YEAR AND THE PLEA OF THE ASSESSEE THAT THERE WAS NO MOTI VATION FOR SUPPRESSING THE VALUATION OF CLOSING STOCK, WHI CH WILL BE THE OPENING STOCK OF THE SUBSEQUENT YEAR, THE CI T(A) OBSERVED THAT THOUGH COMPUTERIZED DETAILS HAD BEEN MAINTAINED BY THE ASSESSEE BUT IN THE FACTS AND CIRCUMSTANCES OF THE CASE, ADDITION TO THE EXTENT O F 20% WAS UPHELD. 14. THE LEARNED AR FOR ASSESSEE DREW OUR ATTENTION TO THE DETAILS OF CLOSING STOCK OF MOTOR CYCLE PLACED AT P AGE 30 OF 6 THE PAPER BOOK WHEREIN ITEM WISE DETAILS OF VARIOUS MODELS OF MOTOR CYCLES WERE FURNISHED BEFORE THE ASSESSING OFFICER. THE LEARNED AR POINTED OUT THAT THE VARI OUS MODELS OF THE MOTOR CYCLES WERE DIFFERENTLY PRICED AND THERE WAS NO MERIT IN ADOPTING AN AVERAGE COST FOR THE DIFFERENT MODELS OF MOTOR CYCLES. THE LEARNED AR ALSO PLACED RELIANCE ON THE SUPPORTING BILLS OF PURCHASE OF VARIOUS MODELS OF MOTOR CYCLES PLACED AT PAGES 93 T O 104 OF THE PAPER BOOK. THE PLEA OF THE ASSESSEE THAT THE ASSESSING OFFICER DID NOT CONSIDER THE OTHER MODELS WHILE COM PUTING THE AVERAGE COST OF MOTOR CYCLE AND WORKING OUT TH E ADDITION. IN RESPECT OF THE SPARE PARTS, THE LEAR NED AR POINTED OUT THAT THE ASSESSEE MAINTAINED QUANTITATI VE STOCK DETAILS OF THE SPARE PARTS WHICH ARE PLACED AT PAGE S 34 TO 81 OF THE PAPER BOOK. THE LEARNED AR FURTHER POIN TED OUT THAT THE VALUATION OF THE CLOSING STOCK IS MADE AFT ER INCLUDING THE INCIDENTAL COST I.E. FREIGHT AND INSU RANCE, CST ETC. SOME OF THE SUPPORTING BILLS FOR THE VALUA TION OF STOCK OF SPARE PARTS ARE PLACED AT PAGES 85 TO 90 O F THE PAPER BOOK. THE LEARNED AR POINTED OUT THAT THE ASS ESSING OFFICER DURING THE COURSE OF ASSESSMENT PROCEEDINGS , HAD PICKED UP THE ITEMS OF STOCK OF SPARE PARTS AS PER THE BILL OF NOVEMBER 2005, WHICH ARE PLACED AT PAGES 83 AND 84 OF THE PAPER BOOK AND THIS PARTICULAR ITEM WAS NOT PART OF THE CLOSING STOCK AT THE END OF THE ASSESSMENT YEAR. A LL THE AFORESAID DETAILS WERE CLAIMED TO HAVE BEEN FILED B EFORE THE CIT(A) WHICH WERE FORWARDED TO THE ASSESSING OFFICE R FOR EXAMINATION. THE LEARNED DR FOR THE REVENUE PLACED RELIANCE ON THE ORDER OF THE ASSESSING OFFICER IN R ESPECT OF ADDITION MADE ON ACCOUNT OF VALUATION OF MOTOR CYCL E AND THE FINDINGS OF THE CIT(A) ON PAGE 8 IN RESPECT OF VALUATION OF SPARE PARTS. 15. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE RECORDS. THE ISSUE OF VALUATION OF CLOSING STOCK I S ON ACCOUNT OF STOCK OF MOTOR CYCLES AND STOCK OF SPARE PARTS. THE ASSESSEE HAS MAINTAINED ITEM WISE, QUANTITATIVE DETAILS OF THE VARIOUS MODELS OF MOTOR CYCLES AVAILABLE IN THE STOCK 7 AT THE END OF THE YEAR. THE VALUATION OF THE STOCK OF MOTOR CYCLES HAS BEEN DONE BY THE ASSESSEE BY ADOPTING TH E COST AND THE ALLIED CHARGES AS PART OF THE COST AND WORK ED OUT THE TOTAL VALUE OF THE PARTICULAR MODEL OF MOTOR CY CLE. FROM THE PERUSAL OF DETAILS FURNISHED AT PAGE 30 OF THE PAPER BOOK, WE FIND THAT THE COST OF THE MOTOR CYCL ES IS VARIABLE VIZ-A-VIZ THE MODEL OF THE MOTOR CYCLE. THE VALUATION WORKED OUT BY THE ASSESSEE IS FURTHER BAC KED BY THE BILLS MAINTAINED BY THE ASSESSEE. THE ASSESSI NG OFFICER, HOWEVER, WORKED OUT THE AVERAGE COST AFTER CONSIDERING PURCHASE OF A PARTICULAR MODEL OF MOTOR CYCLE AND ADOPTED THE SAME FOR WORKING OUT THE VALUATION OF THE TOTAL STOCK AT THE CLOSE OF THE YEAR. WE ARE IN CO NFORMITY WITH THE ORDER OF CIT(A) THAT THERE IS NO MERIT IN THE ADDITION OF RS. 5,04,235/- AS NO DEFECT IN THE WORK ING OF CLOSING STOCK OF THE MOTOR CYCLE HAD BEEN POINTED O UT BY THE ASSESSING OFFICER IN HIS COUNTER COMMENTS. WE UPH OLD THE CIT(A) IN THIS REGARD AND DISMISS THE GROUND NO. 4 & 5 RAISED BY THE REVENUE. 5. RESPECTFULLY FOLLOWING THE ORDER OF THE ITAT, CHANDIGARH IN ASSESSEE'S OWN CASE, THIS GROUND OF A PPEAL IS DECIDED IN FAVOUR OF THE ASSESSEE. 6. IN GROUND NO.3, THE ASSESSEE CONTENDED THAT THE CIT(A) ERRED IN CONFIRMING THE ADDITION OF RS.1,00,000/- O N ACCOUNT OF PURCHASES OF STATIONERY AND PRINTED MATERIAL IN MOHALI BRANCH. THE LD. 'AR' CONTENDED THAT MOHALI BRANCH WAS NEW BRANCH AND NO STOCK OF SUCH ITEMS WAS LYING AT THE END OF THE YEAR. HE JUSTIFIED THE PURCHASES OF STATIONERY AND PRINTED MATERIAL. THE CIT(A), AFTER CONSIDERING TH E REMAND REPORT OF THE AO, UPHELD THE ADDITION MADE BY THE A O. 7. HAVING REGARD TO THE ENTIRETY OF THE FACTS AND CIRCUMSTANCES OF THE CASE, WE ARE OF THE OPINION T HAT 8 DISALLOWANCE OF RS.50,000/- IS FAIR AND REASONABLE. HENCE, TO THIS EXTENT, THE ORDER OF THE LD. CIT(A) IS UPHE LD. THEREFORE, ASSESSEE GETS PARTIAL RELIEF AND THIS GR OUND OF APPEAL OF THE ASSESSEE IS PARTLY ALLOWED. 8. IN GROUND NO.4, THE LD. 'AR' CONTENDED THAT THE CIT(A) ERRED IN CONFIRMING THE DISALLOWANCE OF RS.1,26,667 /- ON ACCOUNT OF RENT PAID FOR MAINTAINING A GUEST HOUSE AT MOHALI ON FLIMSY GROUNDS. IN THE COURSE OF PRESENT APPELLATE PROCEEDINGS, ASSESSEE FILED FORM NO.16A, WHEREBY TDS OF RS.1,00,530/- HAS BEEN DEDUCTED OUT OF THE R ENT PAID AND DEPOSITED IN THE BANK. THE LD. CIT(A) HELD THAT THERE IS NO JUSTIFICATION FOR THE ASSESSEE TO MAINTAIN A GUE ST HOUSE AT MOHALI FOR USE OF THE PARTNERS OR STAFF OF MARUT I. IT IS COMMON KNOWLEDGE THAT STAFF OF BIGGER COMPANIES LIK E MARUTI ARE LODGED IN SMALL PLACES AND FOR SHORT DUR ATION. THIS IS MORE OF AN EXCUSE TO MAINTAIN A GUEST HOUSE . ACCORDINGLY, LD. CIT(A) UPHELD THE ADDITION MADE BY THE AO. 9. HAVING REGARD TO THE FACT SITUATION OF THE CASE AND THE EVIDENCES FILED BY THE ASSESSEE, WE DO NOT FIND ANY JUSTIFICATION IN THE CONFIRMATION OF ADDITION MADE BY THE LD. CIT(A) AND HENCE, THE IMPUGNED ADDITION IS DELETED. THEREFORE, THIS GROUND OF APPEAL OF THE ASSESSEE IS ALLOWED. 10. IN GROUND NO.5, THE ASSESSEE CONTENDED THAT LD. CIT(A) ERRED IN CONFIRMING ADDITION OF RS.1,00,000/- OUT O F VARIOUS EXPENSES CLAIMED UNDER VARIOUS HEADS IN THE PROFIT & LOSS ACCOUNT. THE AO FOUND THAT ASSESSEE HAD CLAIMED EX PENSES UNDER VARIOUS HEADS, FOR WHICH PERSONAL ELEMENT OF USE BY 9 THE PARTNERS AND UN-VOUCHED EXPENSES CANNOT BE RULE D OUT. THE ASSESSEE HAD SHOWN STAFF TEA EXPENSES AT RS.3,59,739/-, HOUSE KEEPING EXPENSES AT RS.1,52,11 7/- AND GENERAL EXPENSES AT RS.13,44,597/-. CONSEQUENT LY, THE AO MADE DISALLOWANCE ON ACCOUNT OF PERSONAL USE BY THE ASSESSEE. THE LD. CIT(A), HAVING REGARD TO THE FAC TS AND CIRCUMSTANCES OF THE CASE AND THE REMAND REPORT, SU BMITTED BY THE AO, UPHELD THE IMPUGNED ADDITIONS. THE ADDI TION MADE BY THE AO, ON THE GROUND OF PERSONAL ELEMENT I N USE OF SUCH SERVICES BY THE PARTNERS AND IN VIEW OF UN-VOU CHED EXPENSES, CANNOT BE BRUSHED ASIDE. HOWEVER, KEEPIN G IN VIEW THE FACTUM OF REASONABLENESS OF SUCH EXPENSES, THE ADDITION MADE BY THE AO AND CONFIRMED BY THE CIT(A) IS UPHELD, TO THE EXTENT OF RS.80,000/-. THE ASSESSEE GETS PARTIAL RELIEF. ACCORDINGLY, THIS GROUND OF APPEAL OF THE ASSESSEE IS PARTLY ALLOWED. 11. IN THE RESULT, APPEAL OF THE ASSESSEE IS PARTLY ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 10 TH JAN.,2012. SD/- SD/- (H.L.KARWA) (MEHAR SINGH) VICE PRESIDENT ACCOUNTANT MEMBER DATED: 10 TH JAN.,2012. POONAM COPY TO: THE APPELLANT, THE RESPONDENT, THE CIT(A), THE CIT,DR ASSISTANT REGISTRAR, ITAT CHANDIGARH