Smt. Jasbir Kaur Bhatia, New Delhi V. ITO, New Delhi

ITA 5419/DEL/2010

• Counselvise Citation: [2015] 140 COUNSELVISE.COM (IT) 97174 (ITAT-DELHI)
• Duration Of Justice: 4 year(s) 9 month(s) 3 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 04-09-2015
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: D
• Next Hearing Date: 29-07-2015
• Assessment Year: 2007-2008
• Appeal Filed On: 01-12-2010
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: SAMEER SHARMA
• Keywords: Depreciation
• Section: 142(1)

Judgement Text

1 ITA 5419/DEL/10 JASBIR KAUR BHATIA VS. ITO IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH D NEW DELHI BEFORE SHRI S.V. MEHROTRA : ACCOUNTANT MEMBER AND SHRI I.C. SUDHIR : JUDICIAL MEMBER ITA NO. 5419/DEL/2010 ASSTT. YR: 2007-08 SMT. JASBIR KAUR BHATIA, VS. INCOME-TAX OFFICER, 11100, DORIWALAN, EAST PARK ROAD, WARD 39(1), NEW DELHI. KAROL BAGH, NEW DELHI-110005. PAN: AAIPB 6318 A ( APPELLANT ) (RESPONDENT) APPELLANT BY : SHRI SALIL AGGARWAL ADV., & SHRI SHAILESH GUPTA CA RESPONDENT BY : SHRI SAMEER SHARMA DR DATE OF HEARING : 29/07/2015. DATE OF ORDER : 04/09/2015. O R D E R PER S.V. MEHROTRA, A.M. : THIS APPEAL HAS BEEN PREFERRED BY THE ASSESSEE AGAI NST THE ORDER DATED 25-8-2010 PASSED BY THE LD. CIT(APPEALS)-XXVII, NEW DELHI IN APPEAL NO. 253/2009-10, RELATING TO ASSTT. YEAR 2007-08, RAIS ING FOLLOWING GROUNDS OF APPEAL: 1.1 THE ORDER OF LEARNED COMMISSIONER OF INCOME T AX (APPEAL) IS ARBITRARY, AGAINST LAW AND FACTS ON REC ORD. 1.2 THE LEARNED COMMISSIONER OF INCOME TAX (APPEAL ) HAS ERRED IN JUSTIFYING THE ACTION OF THE ASSESSING OFFICER IN WHICH THE ASSESSING OFFICER HAS DISALLOWED THE DIFF ERENCE IN 2 ITA 5419/DEL/10 JASBIR KAUR BHATIA VS. ITO THE ACCOUNT OF SUNDRY CREDITOR I.E. M/S ITC LTD WIT HOUT APPRECIATING THE DETAILS AS WELL AS DOCUMENTARY EVI DENCE FILED DURING THE COURSE OF ASSESSMENT PROCEEDING. 1.3 THE LEARNED COMMISSIONER OF INCOME TAX (APPEAL ) HAS FAILED TO APPRECIATE THE FACT THAT THE SUNDRY C REDITORS AS WELL AS AMOUNT OF PURCHASE IS SUPPORTED WITH THE DOCUMENTARY EVIDENCE AND THERE IS NO SINGLE INSTANC ES OF BOGUS TRANSACTION AS SUCH AMOUNT OF PURCHASE SHOWN IN THE BOOKS OF ACCOUNT CANNOT BE DISALLOWED. 1.4 THE LEARNED COMMISSIONER OF INCOME TAX (APPEAL ) HAS. ALSO IGNORED THE FACT THAT THE DIFFERENCE IN T HE BALANCE AS PER BOOKS OF SUNDRY CREDITORS AND AS PER THE BOO KS OF ASSESSEE IS ON ACCOUNT OF THE DISPUTE WITH THE SUND RY CREDITORS WHICH IS PENDING BEFORE THE HIGH COURT. 1.5 THE LEARNED COMMISSIONER OF INCOME TAX (APPEAL ) HAS ERRED IN JUSTIFYING THE ACTION OF THE ASSESSING OFFICER IN WHICH THE ASSESSING OFFICER HAS DISALLOWED THE 1/5 OF THE EXPENSES DEBITED UNDER THE HEAD TELEPHONE EXPENSES AND CAR EXPENSES WITHOUT ANY BASIS. 1.6 THE APPELLANT MAY BE PERMITTED TO ADD, ALTER O R AMEND ANY OF THE FOREGOING GROUNDS OF APPEAL. 2. BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE, I N THE RELEVANT ASSESSMENT YEAR, WAS CARRYING ON WHOLESALE & RETAIL BUSINESS OF GREETING CARDS OF ALL TYPES UNDER PROPRIETARY CONCERNS M/S PRABJYOTI MARK ETING AND JYOTI TRADERS. THE ASSESSEE HAD FIELD RETURN OF INCOME DECLARING T OTAL INCOME OF RS. 1,65,210/-. THE AO NOTICED THAT IN THE CASE OF M/S PRABJYOTI MARKETING, GROSS TURNOVER HAD BEEN SHOWN AT RS. 88,93,854/- WI TH GROSS PROFIT OF RS. 12,09,730/- GIVING A G.P. RATE OF 13.60% AS AGAINST TURNOVER OF RS. 76,37,476/- WITH GROSS PROFIT OF RS. 12,03,263/- YI ELDING G.P. RATE OF 15.75% IN THE PRECEDING YEAR. IN CASE OF M/S JYOTI TRADERS , GROSS TURNOVER HAD BEEN SHOWN AT RS. 20,26,901/- WITH GROSS PROFIT OF RS. 2 ,32,822/- GIVING G.P. RATE 3 ITA 5419/DEL/10 JASBIR KAUR BHATIA VS. ITO OF 11.49% AS AGAINST GROSS TURNOVER OF RS. 9,42,662 /- WITH GROSS PROFIT OF RS. 69,019/- YIELDING G.P. RATE OF 7.32% IN THE PRECEDI NG YEAR. WHILE SCRUTINIZING THE BALANCE-SHEET OF M/S PRABJYOTI MA RKETING, IT WAS NOTICED THAT THE ASSESSEE HAD SHOWN SUNDRY CREDITOR OF RS. 91,44,472/- IN THE NAME OF M/S ITC LTD. THE AO ISSUED NOTICE U/S 143(6) TO ITC LTD. FOR CONFIRMATION OF THE ACCOUNT OF THE ASSESSEE IN THEI R BOOKS OF A/C. ITC LTD. CONFIRMED A BALANCE OF RS. 65,52,852/- AS AGAINST THE BALANCE OF RS. 91,44,472/- IN ASSESSEES BOOKS OF A/C. THUS, T HERE WAS EXCESS CREDIT OF RS. 25,91,620/- IN THE BOOKS OF ASSESSEE IN THE ACC OUNT OF CREDITOR M/S ITC LTD. THE ASSESSEE SUBMITTED FOLLOWING RECONCILIATI ON OF CREDITORS A/C AS ON 31-3-2007: BALANCE AS PER PRABJYOTI MARKETING 9144472.40 LESS: 1. AMOUNT DEBITED BY ITC BUT NOT CREDITED BY ASSESSEE. 2199867.00 2. CHEQUE ISSUED BUT NOT PRESENTED BY ITC DATE PAGE NO. AMOUNT 2.1.2007 103393.00 31.1.2007 200000.00 303393.00 3. DIFFERENCE IN OPENING BALANCE OF BOTH THE PARTIES AS ON 1.4.2006 1242282.00 2627542.00 BALANCE: 6516930.00 ADD: DIFFERENCE OF LAST YEAR OTHERS INTT. ETC. 35921.00 BALANCE AS PER ITC 6552852.00 2.1. THE AO, AFTER CONSIDERING THE CREDIT NOTES ISS UED BY ITC LTD., FOR WHICH PURCHASES WERE NOT CREDITED BY ASSESSEE IN I TS BOOKS OF A/C, OBSERVED THAT ASSESSEE COULD NOT EXPLAIN THE REASON FOR NOT PASSING THE NECESSARY 4 ITA 5419/DEL/10 JASBIR KAUR BHATIA VS. ITO ENTRIES IN ITS BOOKS OF A/C. THUS, HE CONCLUDED THA T ASSESSEE HAD SHOWN EXCESS PURCHASES BY RS. 21,99,867/-. AS REGARDS OTH ER DIFFERENCES, HE FURTHER OBSERVED AS UNDER: 2. THE ASSESSEE HAS FURTHER EXPLAINED THE REMAININ G DIFFERENCE IN HER ACCOUNTS AND THAT OF ITC LIMITED ON ACCOUNT OF THE FOLLOWING ITEMS: A. CHEQUE ISSUED BUT NOT PRESENTED BY ITC DATE PAGE NO. AMOUNT 2.1.2007 103393.00 31.1.2007 200000.00 303393 B. DIFFERENCE IN OPENING BALANCE OF BOTH THE PARTIES AS ON 1.4.2006 124282 C. DIFFERENCE OF LAST YEAR OTHERS, INTT. ETC. 35921.00 TOTAL AS REGARDS ITEMS REFLECTED AT 2.A, B & C, THE ASSES SEE COULD NOT PRODUCE ANY DOCUMENTARY EVIDENCE IN SUPPORT OF HER CONTENTION. HENCE THE CONTENTION OF THE ASSESSEE FO R THE BOOKING OF THE EXCESS SUNDRY CREDIT IN THE NAME OF M/S ITC LTD. TO THE TUNE OF RS.4,63,596/- IS NOT TENABLE. A S' STATED ABOVE, THE ASSESSEE COULD NOT FURTHER RECONCILE THE ACCOUNT WITH ITC LIMITED AS REQUIRED VIDE THIS OFFICE LETTE R DATED 15.12.-2009 AND ALSO COULD NOT EXPLAIN THE DIFFEREN CE WITH THE HELP OF THE BOOKS OF ACCOUNT. THEREFORE, THE AC COUNTS SUBMITTED ABOVE ARE NOT RELIABLE AND NOT ACCEPTABLE . CONSIDERING ALL THE FACTS OF THE CASE, IT IS CLEAR THAT THE ASSESSEE HAS FURTHER INFLATED HER: PURCHASES TO THE EXTENT OF RS.3,91 ,753/- AND REFLECTED THE CORRESPONDING AMOU NT AS OUTSTANDING LIABILITY IN THE ACCOUNT OF M/S. ITC LT D. THUS, AS THE ASSESSEE HAS NOT BEEN ABLE TO RECONCILE THE FURTHER DIFFERENCE OF RS.3,91',753/- (RS.2591620 - 2199867) ALSO IN HER ACCOUNT AND THE ACCOUNT OF M/S. ITC LTD. THE ASSESSEE HAS INFLATED HER PURCHASES BY AN AMOUNT OF RS.3,91,753/- AND SHOWN EXCESS CREDIT IN THE ACCOU NT OF 5 ITA 5419/DEL/10 JASBIR KAUR BHATIA VS. ITO THE ITC LTD OF THE CORRESPONDING AMOUNT. THUS, THE DIFFERENCE OF RS.3,91,753/- IS ALSO ASSESSABLE AS T HE INCOME OF THE ASSESSEE ON ACCOUNT OF INFLATED PURCHASES AN D EXCESS CREDIT SHOWN AS STATED ABOVE. I, THEREFORE, MAKE AN ADDITION OF RS.3,91 ,753/- TO THE DECLARED INCOME FOR THE FA CTS STATED ABOVE ON ACCOUNT OF INFLATED PURCHASES AND EXCESS C REDIT IN THE ACCOUNT OF ITC LTD. IN THE BALANCE SHEET. 2.2. THE AO FURTHER MADE DISALLOWANCE OF 1/5 TH OF THE EXPENSES INCURRED ON ACCOUNT ON PETROL, CAR EXPENSES AND DEPRECIATION IN THE BOOKS OF M/S PRABJYOTI MARKETING. 2.3. IN CASE OF M/S JYOTI TRADERS ALSO HE MADE DIS ALLOWANCE OF RS. 657/- BEING 1/5 TH OF THE EXPENSES INCURRED ON ACCOUNT OF TELEPHONE EXPENSES. COMPUTATION OF INCOME WAS MADE AS UNDER: INCOME AS DECLARED RS. 1,65,210/- ADD: 1. M/S PRABJYOTI MARKETING. I. EXCESS PURCHASES BOOKED/ DIFFERENCE IN THE ACCOUNT OF SUNDRY CREDIT M/S ITC LTD. 25,91,620 OUT OF TELEPHONE EXPENSES 5,514 OUT OF CAR EXPENSES 13,932 DIFFERENCE IN ACCOUNT 1,354 RS. 26,12,420/- 2. M/S JYOTI TRADERS: DIFFERENCE IN ACCOUNT 86 OUT OF TELEPHONE EXPENSES 657 RS. 743 RS. 27,78,373 ROUNDED OFF: RS. 27,78,370/- 2.4. LD. CIT(A) DISMISSED THE ASSESSEES APPEAL. BE ING AGGRIEVED, THE ASSESSEE IS IN APPEAL BEFORE US. 6 ITA 5419/DEL/10 JASBIR KAUR BHATIA VS. ITO 3. LD. COUNSEL FOR THE ASSESSEE REFERRED TO PAGE 25 OF THE PAPER BOOK, WHEREIN THE NOTICE U/S 142(1) IS CONTAINED IN WHICH AO HAD REQUIRED THE ASSESSEE TO EXPLAIN THE FOLLOWING DIFFERENCE ON THE BASIS OF LETTER DATED 1- 12-2009 RECEIVED FROM M/S ITC LTD.: 1. AMOUNT DEBITED BY ITC NOT CREDITED BY YOU RS. 21,99 ,667/- (DETAILS OF BILLS NOT GIVEN) 2. CHEQUE ISSUED BY YOU BUT NOT PRESENTED BY ITC RS. 3 ,03,393/- (DETAILS OF BILLS NOT GIVEN) 3. DIFFERENCE IN OPENING BALANCE OF BOTH THE PARTIES AS ON 1.4.2006 RS. 1,24,282/- 4. DIFFERENCE OF LAST YEAR INTEREST ETC. RS. 35,921 /- DIFFERENCE: RS. 26,63,463/- 3.1. LD. COUNSEL FOR THE ASSESSEE AT THE OUTSET PO INTED OUT THAT AS FAR AS DIFFERENCE OF LAST YEARS INTEREST ETC. AMOUNTING T O RS. 35,921/- IS CONCERNED, THE AO HAS WRONGLY ADDED THE SAME, WHICH SHOULD HAV E BEEN DEDUCTED. AS REGARDS THE DIFFERENCE IN OPENING BALANCE OF BOTH THE PARTIES AS ON 1-4-2006 AMOUNTING TO RS. 1,24,282/-, LD. COUNSEL POINTED OU T THAT THIS CANNOT BE ADDED, IN ANY VIEW OF THE MATTER, IN THIS YEAR. LD. COUNSEL REFERRED TO PAGE 31 OF THE PAPER BOOK, WHEREIN THE SUBMISSIONS MADE BEF ORE LD. CIT(A) ARE CONTAINED AND POINTED OUT THAT AS REGARDS THE ADDIT ION OF RS. 21,99,867/- IT WAS EXPLAINED THAT THE ENTRY OF THE AMOUNTS CREDITE D BY ITC IN THEIR ACCOUNT HAD NOT BEEN PASSED BY THE ASSESSEE BECAUSE TILL TH E CREDIT IS GIVEN BY THE SUPPLIER, THE ASSESSEE KEEPS THE STOCK AS ITS OWN S TOCK. IT WAS POINTED OUT THAT THE PRODUCTS SOLD BY THE ASSESSEE ARE FESTIVAL / OCCASION SPECIFIC. FURTHER, ON EACH CARD THE YEAR IS ALSO MENTIONED, HENCE THE SAME PRODUCT CANNOT BE SOLD IN THE NEXT YEAR. HENCE, THE SUPPLIERS ALLOWS THE RETURN OF THE GOODS 7 ITA 5419/DEL/10 JASBIR KAUR BHATIA VS. ITO FACILITY TO ITS DISTRIBUTORS. IT WAS POINTED OUT TH AT DURING THE YEAR UNDER CONSIDERATION THE ASSESSEE HAD SENT THE GOODS AMOUN TING TO RS. 26,32,303/- AS GOODS RETURNED TO ITC LTD. AGAINST WHICH THE ASS ESSEE GOT CREDIT OF RS. 21,99,867/-. THE ASSESSEE POINTED OUT THAT SINCE TH E CREDIT FOR RS. 21,99,867/- ONLY HAD BEEN GRANTED AS AGAINST THE RE TURN OF RS. 26,32,303/-, THE ASSESSEE HAD NOT ACCEPTED THE SAME AND, THEREFO RE, THE SAID GOODS RETURNEDHAD BEEN SHOWN AS STOCK IN HAND, LYING WITH THE ITC. IN SUPPORT OF ITS CONTENTION, THE ASSESSEE HAD SUBMITTED THE STOC K STATEMENT. THE ASSESSEE FURTHER POINTED OUT THAT IF THE AOS CONTENTION WAS ACCEPTED THEN THE GROSS PROFIT WOULD BE 38.34%, AS UNDER: PARTICULARS AMOUNT PARTICULARS AMOUNT TO OPENING STOCK 2215578 BY SALES 8893854 TO PURCHASES 12452905 BY CLOSING STOCK 6984359 LESS: EXCESS PURCHASES 2199867 10253038 TO GROSS PROFIT 15878213 15878213 3.2. LD. COUNSEL REFERRED TO PAGES 34 TO 93 OF THE PAPER BOOK WHEREIN STOCK STATEMENT IS CONTAINED AND POINTED OUT THAT IN THE AFOREMENTIONED COMPUTATION, THE CLOSING STOCK OF RS. 69,84,359/- I NCLUDES THE STOCK LYING WITH ITC OF RS. 26,32,303/-. 3.3. AS REGARDS THE ADDITION OF RS. 3,03,393/-, LD. COUNSEL POINTED OUT THAT IT IS THE NORMAL PRACTICE OF THE TRADE TO PROVIDE T HE BLANK CHEQUES TO THE COMPANY. THE COMPANY, AS AND WHEN REQUIRE, CAN FILL THE AMOUNT AND INFORM ITS DISTRIBUTOR ABOUT THE SAME. THE ITC LTD. HAD TA KEN INTO ITS ACCOUNT THE CHEQUES, BUT AS THE SAME HAD NOT BEEN INFORMED TO THE ASSESSEE NOR 8 ITA 5419/DEL/10 JASBIR KAUR BHATIA VS. ITO PRESENTED TO THE BANK, HENCE NOT ACCOUNTED FOR THE BANK. IN THIS REGARD LD. COUNSEL REFERRED TO PAGES 254 TO 260 OF THE PB, WHE REIN THE BANK STATEMENT IS CONTAINED TO SUBMIT THAT THE TWO CHEQUES HAVE N OT BEEN CREDITED TO ASSESSEES ACCOUNT. LD. CIT(A) REJECTED THE ASSESSE ES PLEA. 4. LD. DR SUBMITTED THAT NO PLEA WAS TAKEN IN REGAR D TO STOCK IN TRADE LYING WITH ITC. 5. WE HAVE CONSIDERED THE SUBMISSIONS OF BOTH THE P ARTIES AND HAVE PERUSED THE RECORD OF THE CASE. THERE ARE 4 ITEMS I N DISPUTE, AS NOTED EARLIER, OUT OF WHICH AT THE OUTSET, WE ARE IN AGREEMENT WI TH LD. COUNSEL FOR THE ASSESSEE THAT ADDITION OF RS. 1,24,282/- COULD NOT BE MADE IN THIS YEAR BECAUSE THE DIFFERENCE PERTAINED TO EARLIER YEAR. A S REGARDS THE ADDITION OF RS. 35,921/-, THE SAME HAD TO BE REDUCED BY AO AND NOT ADDED. THE AO WILL VERIFY THIS ASPECT. 5.1. THE MAIN ISSUE IS REGARDING ADDITION OF RS. 21 ,99,867/-. THE ASSESSEES PLEA IS THAT THOUGH CREDIT NOTES HAD BEE N ISSUED BY ITC AGGREGATING TO RS. 21,99,867/-, BUT IN ITS BOOKS OF A/C IT DID NOT ACCOUNT FOR THE SAME BECAUSE ASSESSEE HAD LODGED THE CLAIM FOR RS. 26,32,303/-, WHICH THE ASSESSEE CONTINUED TO SHOW IN ITS STOCK REGISTE R AS A SEPARATE ITEM, WHICH IS EVIDENT FROM PAGE 93 OF THE PB. IN ORDER TO EXAM INE THE CREDIBILITY OF ASSESSEES EXPLANATION, WE HAVE TO CONSIDER THE VAR IOUS ASPECTS. THE ASSESSEE, ADMITTEDLY, WAS DISTRIBUTOR OF M/S ITC LT D., AND, THEREFORE, HAD REGULAR DEALINGS WITH M/S ITC LTD. CONSIDERING THE NATURE OF ASSESSEES BUSINESS, THE EXPLANATION GIVEN BY ASSESSEE CANNOT BE FAULTED, BECAUSE THE 9 ITA 5419/DEL/10 JASBIR KAUR BHATIA VS. ITO GREETING CARDS ARE ALWAYS YEAR SPECIFIC AND THE OLD STOCK BECOME OBSOLETE AND CANNOT BE USED. THIS PRACTICE, THEREFORE, IS CO MMERCIALLY PREVALENT IN THIS LINE OF BUSINESS. 5.2. FURTHER, AS REGARDS THE CREDIT ENTRIES BEING N OT ACCOUNTED FOR IN ASSESSEES BOOKS OF ACCOUNT, KEEPING IN VIEW THE CO MMERCIAL PRACTICE, IT CANNOT BE DENIED THAT THE ASSESSEE HAD TO ACCOUNT F OR THE CREDIT NOTES BECAUSE IT IS NOT THAT ONLY ITC WAS REQUIRED TO CONFIRM THE BALANCE, BUT EVEN ASSESSEE COULD ALSO BE CALLED UPON BY THE AO TO CONFIRM THE BALANCE RELATING TO ITC LTD. IN ASSESSMENT PROCEEDINGS OF ITC. THEREFORE, I T CANNOT BE CONCLUDED THAT ASSESSEE WAS DELIBERATELY NOT ACCOUNTING FOR T HE CREDIT NOTES. UNDER SUCH CIRCUMSTANCES, NORMAL COMMERCIAL PRACTICE ASSU MES SIGNIFICANCE AND THAT HAS TO BE GIVEN DUE CREDENCE. IN THE STOCK REG ISTER, MAINTAINED BY ASSESSEE, THE STOCK LYING WITH ITC HAS SEPARATELY B EEN MENTIONED. UNDER SUCH CIRCUMSTANCE, WE ARE OF THE OPINION THAT THE A SSESSEES EXPLANATION WAS QUITE REASONABLE, CONSIDERING THE BUSINESS PRACTICE AND, THEREFORE, SHOULD HAVE BEEN ACCEPTED. IN THE GROUND OF APPEAL NO. 1.4 , THE ASSESSEE FURTHER POINTED OUT THAT DISPUTE IN THIS REGARD IS PENDING BEFORE HONBLE HIGH COURT. IN VIEW OF ABOVE, THE ADDITION MADE ON THIS COUNT I S DELETED. 5.3. AS REGARDS THE ASSESSEES EXPLANATION IN RESPE CT OF DIFFERENCE OF RS. 3,03,393/-, THAT THE CHEQUES ISSUED WERE NOT PRESEN TED BY ITC, WE RESTORE THIS ISSUE TO THE FILE OF AO FOR VERIFICATION OF AS SESSEES CLAIM WITH REFERENCE TO THE BANK ACCOUNT, WHICH HAS BEEN FILED IN THE PA PER BOOK BEFORE US. GROUND IS ALLOWED FOR STATISTICAL PURPOSES. 10 ITA 5419/DEL/10 JASBIR KAUR BHATIA VS. ITO 6. VIDE GROUND NO. 1.5, THE ASSESSEE HAS DISPUTED V ARIOUS DISALLOWANCES MADE BY AO AND CONFIRMED BY LD. CIT(A). THESE DISAL LOWANCES HAVE BEEN MADE ON THE GROUND OF PERSONAL USES. IN OUR OPINION , THE DISALLOWANCE IS QUITE REASONABLE AND, ACCORDINGLY, WE CONFIRM THE S AME. 7. IN THE RESULT, ASSESSEES APPEAL IS PARTLY ALLOW ED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN OPEN COURT ON 04/09/2015. SD/- SD/- (I.C. SUDHIR) (S.V. MEHROTRA) JUDICIAL MEMBER ACCOUNTANT MEMBER DATED: 04/09/2015. *MP* COPY OF ORDER TO: 1. ASSESSEE 2. AO 3. CIT 4. CIT(A) 5. DR, ITAT, NEW DELHI. 11 ITA 5419/DEL/10 JASBIR KAUR BHATIA VS. ITO - + DATE INITIAL 1. DRAFT DICTATED ON - 0 9 .2015 PS 2. DRAFT PLACED BEFORE AUTHOR .0 9 .2015 PS 3. DRAFT PROPOSED & PLACED BEFORE THE SECOND MEMBER JM/AM 4. DRAFT DISCUSSED/APPROVED BY SECOND MEMBER. JM/AM 5. APPROVED DRAFT COMES TO THE SR.PS/PS PS/PS 6. KEPT FOR PRONOUNCEMENT ON PS 7. FILE SENT TO THE BENCH CLERK PS 8. DATE ON WHICH FILE GOES TO THE AR 9. DATE ON WHICH FILE GOES TO THE HEAD CLERK. 10. DATE OF DISPATCH OF ORDER.