The Dy. Commissioner of Income-tax, Jalandhar V. M/s. Orthonova Hospital, Jalandhar

ITA 549/ASR/2011

• Counselvise Citation: 54920914 RSA 2011
• Duration Of Justice: 2 year(s) 4 month(s) 12 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 31-03-2014
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: DB
• Next Hearing Date: 27-03-2014
• Assessment Year: 2007-2008
• Appeal Filed On: 18-11-2011
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: AMRIK CHAND
• Keywords: Unexplained cash credit; Document seized; Principle of natural justice; Documents seized
• Section: 143(3); 153A; 27

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH; AMRITSAR. BEFORE SH. H.S. SIDHU, JUDICIAL MEMBER AND SH. B.P. JAIN, ACCOUNTANT MEMBER I.T.A. NO. 538 (ASR)/2011 ASSESSMENT YEAR: 2007-08 PAN: AAAFO7491B M/S ORTHONOVA HOSPITAL VS. ACIT, CENTRAL CIRCLE, NAKODAR RAOD, JALANDHAR JALANDAHAR (APPELLANT) (RESPONDENT) AND I.T.A. NO. 549 (ASR)/2011 ASSESSMENT YEAR: 2007-08 PAN: AAAFO7491B DEPUTY COMMISSIONER OF INCOME VS. M/S ORTHONOV A HOSPITAL TAX, CENTRAL CIRCLE-II, JALANDHAR NEAR NARI N IKETAN, NAKODAR ROAD, JALANDHAR (APPELLANT) (RESPONDENT) ASSESSEE BY: SH. SURINDER MAHAJAN, CA DEPARTMENT BY: SH. AMRIK CHAND, DR DATE OF HEARING: 27.03.2014 DATE OF PRONOUNCEMENT: 31.03.2014 ORDER PER BENCH 1) THESE ARE THE CROSS APPEALS FILED BY THE ASSESSEE AS WELL AS BY THE REVENUE AGAINST THE ORDER DATED 13.09.2011 PASS ED BY LEARNED CIT(A)-I, LUDHIANA FOR THE ASSESSMENT YEAR 2007-08. THE GROUNDS OF APPEAL TAKEN BY THE ASSESSEE IN I.T.A. NO. 538(ASR) /2011 ARE AS UNDER: 2 I.T.A. NOS. 538 & 549(ASR)/2011 I. THAT IS THE FACTS AND CIRCUMSTANCES OF THE CASE, TH E ORDER UNDER APPEAL, CONFIRMING THE LEVY OF PENALTY, IS LIABLE T O BE QUASHED BEING MOST ARBITRARY, CRYPTIC AND AGAINST THE PRINC IPLES OF NATURAL JUSTICE WHEN NEITHER PROPER OPPORTUNITY OF HEARING WAS GRANTED NOR THE DETAILED WRITTEN SUBMISSIONS FILED BEFORE CIT(A ) WERE DISCUSSED AND DILATED IN THE IMPUGNED ORDER. II. THAT THE LEARNED CIT(A), RATHER THAN HAVING A RELOO K AT THE MATTER AFRESH IN PENALTY PROCEEDINGS, WAS BOGGED DOWN BY C ONFIRMATION OF QUANTUM ADDITIONS BY CIT U/S 264, WHEN NO APPEAL WAS FILED BY THE ASSESSEE, TO CONFIRM THE LEVY OF PENALTY, WHICH ACT BY ITSELF VITIATES HIS ORDER UNDER APPEAL. III. THAT ON THE MERITS OF THE CASE, WHEN THE QUANTUM AD DITIONS, APPRECIATING THE ASSESSEES CONTENTIONS CORROBORATE D BY DOCUMENTS FILED ON RECORD, WERE UNWARRANTED, THERE WAS NO SCO PE FOR LEVY OF PENALTY, MUCH LESS SUSTAINING THE SAME IN APPEAL. IV. THAT THE LEARNED CIT(A) HAS GROSSLY ERRED IN HOLDIN G, UNMINDFUL OF EXPLANATION FILED, THAT THE ASSESSEE COULD NOT EXPL AIN THE DIFFERENCE BETWEEN ASSESSED AND RETURNED INCOME. \ V. THAT THE ORDER UNDER APPEAL, TO THE EXTENT DISPUTED HEREINABOVE, IS AGAINST LAW AND FACTS OF THE CASE. 2) THE GROUNDS RAISED BY THE REVENUE IN I.T.A. NO. 549(ASR)/2011 ARE REPRODUCED AS UNDER:- I. WHETHER THE CIT(A)-I, LUDHIANA WAS RIGHT IN LAW AND ON THE FACTS IN REDUCING THE AMOUNT OF PENALTY LEVIED U/S 271(1) (C) FROM 200% TO 100% OF TAX SOUGHT TO BE EVADED, BY IGNORING THE FACT THAT THE ASSESSEE WORKED WITH A GUILTY MIND TO SUPPRESS HIS TRUE INCOME WHICH WAS CAUGHT ONLY BECAUSE OF SEIZED DOCUMENTS F OUND DURING SEARCH? II. THE APPELLANT CRAVES LEAVE TO ADD OR AMEND THE GROU NDS OF APPEAL ON OR BEFORE THE APPEAL IS HEARD AND DISPOSED OFF. III. IT IS PRAYED THAT THE ORDER OF THE COMMISSIONER OF INCOME TAX (APPEALS) BE SET-ASIDE AND THAT OF THE A.O. BE REST ORED. 3) THE FACTS RELATING TO THE ISSUE IN DISPUTE ARE THAT DR. HARPREET SINGH, AN ORTHOPAEDIC SURGEON WAS RUNNING AN ORTHO PAEDIC HOSPITAL 3 I.T.A. NOS. 538 & 549(ASR)/2011 UNDER THE NAME AND STYLE M/S ORTHONOVA HOSPITAL. A SEARCH WAS CONDUCTED AT THE BUSINESS PREMISES OF THE ASSESSEE ON 17.11.2006 AND IN THE COURSE OF SEARCH PROCEEDINGS, INCRIMINATING DOC UMENTS WERE FOUND APART FROM CASH SEIZURE AMOUNTING TO RS. 4,00,000/- . THE ASSESSING OFFICER ISSUED A NOTICE UNDER SECTION 142 OF THE IN COME-TAX ACT, 1961 (IN SHORT THE ACT) TO THE ASSESSEE CALLING FOR THE R ETURN OF INCOME FOR THE ASSESSMENT YEAR 2007-08 ON 09.10.2007. THE ASSESSEE FILED RETURN OF INCOME ON 12.06.2008 DECLARING INCOME OF RS. 54,31, 620/-. THE ASSESSING OFFICER FINALLY COMPLETED THE ASSESSMENT AT THE INCOME OF RS. 91,47,210/- BY MAKING ADDITIONS OF RS. 29,29,000/- ON ACCOUNT OF UNACCOUNTED CASH CREDIT, RS. 6,16,330/- ON ACCOUNT OF UNACCOUNTED RECEIPTS, RS. 1,00,000/- ON ACCOUNT OF INADMISSIBLE PURCHASE, RS. 61,260/- ON ACCOUNT OF INADMISSIBLE EXPENSES AND RS. 9,000/- ON ACCOUNT OF CHARITY & DONATION VIDE ORDER UNDER SECTION 153A RE AD WITH SECTION 143(3) PASSED ON 29.12.2008. THE ASSESSING OFFICER ALSO INITIATED PENALTY PROCEEDINGS UNDER SECTION 271(1)(C) OF THE ACT BY ISSUING A NOTICE UNDER SECTION 274 READ WITH SECTION 271 TO T HE ASSESSEE REQUIRING HIM TO SHOW CAUSE AS TO WHY PENALTY UNDER SECTION 2 71(1)(C) OF THE ACT SHOULD NOT BE LEVIED UPON IT FOR FURNISHING INACCUR ATE PARTICULARS OF INCOME, LEADING TO ADDITIONS OF RS. 29,29,000/- AND RS. 6,16,330/-. BEING 4 I.T.A. NOS. 538 & 549(ASR)/2011 AGGRIEVED WITH THE ASSESSMENT ORDER DATED 29.12.200 8 PASSED UNDER SECTION 153A READ WITH SECTION 143(3) OF THE ACT, T HE ASSESSEE FILED A PETITION UNDER SECTION 264 OF THE ACT BEFORE THE CO MMISSIONER OF INCOME TAX (CENTRAL), LUDHIANA ON 19.02.2009 WHICH WAS REJ ECTED AND THEREBY UPHELD EVERY ADDITION MADE BY THE THEN ASSESSING OF FICER VIDE HIS ORDER DATED 31.03.2010 PASSED UNDER SECTION 264 OF THE AC T. 4) IN RESPONSE TO THE SHOW-CAUSE NOTICE DATED 02.08 .2010, THE ASSESSEE FILED WRITTEN EXPLANATION ON 18.08.2010 ST ATING THAT DUE TO CERTAIN PROFESSION PRE-OCCUPATIONS, REPLY TO THE AB OVE NOTICE COULD NOT BE FINALIZED AND SOUGHT ADJOURNMENT FOR 23.08.2010. IN THE REPLY, THE ASSESSEE HAS MAINLY STATED THAT THE PENALTY IN DISP UTE HAS BEEN INITIATED AS A MATTER OF ROUTINE WITHOUT PROVING THE DELIBERATE MISCONDUCT OR A GUILTY MIND OF THE ASSESSEE. THEREFORE, HE REQUESTED THAT THE PENALTY IN DISPUTE MAY BE DELETED. SECONDLY, MERELY BECAUSE CERTAIN EX PENSES CLAIMED BY THE ASSESSEE ARE DISALLOWED BY AN AUTHORITY IT CANN OT MEAN THAT THE PARTICULARS FURNISHED BY THE ASSESSEE ARE WRONG. DI SALLOWANCE OF AN EXPENSE PER SE CANNOT MEAN THAT THE ASSESSEE HAS FU RNISHED INCORRECT PARTICULARS OF INCOME OF ITS INCOME. CONCEALMENT IN VOLVES PENAL ACTION WHICH HAS TO BE PROVED AS A CONSCIOUS ACT. IT IS T RUE THAT DIRECT EVIDENCE MAY NOT BE AVAILABLE IN EVERY CASE. YET IT MUST BE PROVED AS A NECESSARY 5 I.T.A. NOS. 538 & 549(ASR)/2011 COROLLARY FROM THE FACTS AND CIRCUMSTANCES ESTABLIS HED ON THE RECORD. IN SUPPORT OF HIS ARGUMENT, THE ASSESSEE HAS CITED VAR IOUS DECISIONS OF HON'BLE HIGH COURTS. AFTER CONSIDERING THE REPLY FI LED BY THE ASSESSEE AND THE ORDER PASSED BY LEARNED COMMISSIONER OF INC OME TAX(CENTRAL), LUDHIANA, DATED 31.03.2010 PASSED UNDER SECTION 26 4 OF THE ACT, THE ASSESSING OFFICER REJECTED THE EXPLANATION OF THE A SSESSEE AND WAS OF THE VIEW THAT IT IS A CLEAR CASE OF CONCEALMENT OF INCO ME BY THE ASSESSEE AND THE ASSESSEE IS LIABLE FOR PENALTY UNDER SECTION 27 1(1)(C) OF THE ACT AND HE LEVIED 200% PENALTY OF RS. 23,86,716/- VIDE ORDE R DATED 22.09.2010 PASSED UNDER SECTION 271(1)(C) OF THE ACT. 5) AGGRIEVED WITH THE PENALTY ORDER DATED 22.09.201 0, THE ASSESSEE FILED AN APPEAL BEFORE THE LEARNED FIRST A PPELLATE AUTHORITY WHO VIDE IMPUGNED ORDER DATED 13.09.2011 PARTLY ALLOWED THE APPEAL OF THE ASSESSEE BY REDUCING THE PENALTY FROM 200% TO 100% OF TAX SOUGHT TO BE EVADED. NOW, BOTH THE ASSESSEE AS WELL AS THE REVEN UE, BEING AGGRIEVED BY THE IMPUGNED ORDER DATED 13.09.2011 PASSED BY LE ARNED CIT(A)-I, LUDHIANA, FILED THE PRESENT CROSS APPEALS. 6) AT THE TIME OF HEARING, LEARNED COUNSEL FOR THE ASSESSEE FILED HIS WRITTEN SUBMISSION ALONG WITH THE PAPER BOOK ENCLOS ING TEN CASE-LAWS IN SUPPORT OF THE VERSION OF THE ASSESSEE FOR DELETING THE PENALTY IN DISPUTE 6 I.T.A. NOS. 538 & 549(ASR)/2011 AND ON THE CONTRARY LEARNED DR RELIED UPON THE ORDE R PASSED BY THE ASSESSING OFFICER DATED 22.09.2010 PASSED UNDER SE CTION 271(1)(C) OF THE ACT. 7) WE HAVE HEARD BOTH THE PARTIES AND PERUSED THE R ELEVANT RECORDS AVAILABLE WITH US AND WE ARE OF THE VIEW THAT THE A SSESSING OFFICER MADE THE ADDITION OF RS. 29,29,000/- ON ACCOUNT OF UNDIS CLOSED CASH CREDIT, WHICH ACCORDING TO THE ASSESSEE HAS BEEN INTRODUCED IN THE CASH BOOK ON SEVERAL DATES. ACCORDING TO THE ASSESSEE, THE ASSES SEE HAD PRODUCED AN UPDATED CASH BOOK WHICH WAS DULY CO-RELATED WITH TH E RECEIPT BOOKS ON DAILY BASIS. ALL THESE DOCUMENTARY EVIDENCES HAVE B EEN CHECKED BY THE ASSESSING OFFICER IN THE ASSESSMENT PROCEEDING AND THE CASH COULD NOT BE RECONCILED WITH THE RECEIPT BOOKS ON DIFFERENT DATE S, THE DIFFERENTIAL AMOUNT, WAS PLACED UNDER THE HEAD MISCELLANEOUS IN COME AND OFFERED TO TAX IN THE RETURN FILED. IN SPITE OF ALL THESE F ACTS, THE ASSESSING OFFICER MADE THE ADDITION OF RS. 29,29,000/- IN PARA 4.6 OF THE ASSESSMENT ORDER. 8) LEARNED COUNSEL FOR THE ASSESSEE HAS FILED THE COPIES OF COMPUTATION OF PROFIT AND LOSS ACCOUNT, BALANCE-SHE ET, MISCELLANEOUS INCOME ETC. ALONG WITH THE RETURN BEFORE THE ASSESS ING OFFICER, LEARNED FIRST APPELLATE AUTHORITY AS WELL AS BEFORE US. WE ARE OF THE VIEW THAT THE CASH BOOK, ON DAILY BASIS, WITH THE HELP OF RECEIPT BOOKS AND OTHER 7 I.T.A. NOS. 538 & 549(ASR)/2011 SUPPORTING BILLS/ VOUCHERS, THESE ENTRIES WERE RECO NCILED AND WHEREVER THE DIFFERENCE STILL REMAINED, WAS PLACED UNDER THE HEAD MISCELLANEOUS INCOME WHICH AGGREGATED TO RS. 15 LAKHS AND THE SA ME WAS OFFERED TO TAX WHILE FILING THE RETURN, THE PROOF OF THE SAME ARE ANNEXED AT PAGE NOS. 13 TO 20 OF THE PAPER BOOK. THEREFORE, THE ADDITIO N OF RS. 29,29,000/- HAS RESULTED IN TAXATION OF THE SAME AMOUNT TWICE, ONCE BY THE ASSESSEE HIMSELF IN THE RETURN FILED, AND THE SECOND TIME BY THE ASSESSING OFFICER BY MAKING THE ABOVE SPECIFIC ADDITION, MEANING THER EBY, THE DOCUMENTS FOR EXPLAINING THE ADDITION OF RS. 29,29,000/-, TH E ASSESSEE HAS ALREADY FILED BEFORE THE REVENUE AUTHORITY AND WE ARE OF TH E VIEW THAT THE ASSESSEE HAS NOT FILED INACCURATE PARTICULARS OF INCOME OR C ONCEALED ANY PARTICULARS OF HIS INCOME. 9) AS PER RECORD, THE OTHER ADDITION OF RS. 6,16,33 0/- MADE ON ACCOUNT OF UNACCOUNTED RECEIPTS FROM OPERATION THEA TRE (ANNEXURE A-5) WHICH WAS ALSO RECORDED IN THE RECEIPT BOOK FOR WHI CH THERE WAS A SPECIFIC COLUMN IN THE BILL BOOK. THE ASSESSEE HAD OFFERED HIS EXPLANATION WITH THE SUPPORT OF EVIDENCE ON ACCOUNT OF ANNEXURE A-5 AND THE SAME WAS REJECTED BY THE ASSESSING OFFICER. IT DOES NOT MEAN THAT THE ASSESSEE HAS FILED INACCURATE PARTICULARS OF INCOME OR CON CEALED ANY PARTICULARS OF HIS INCOME. 8 I.T.A. NOS. 538 & 549(ASR)/2011 10) AS REGARDS TO OTHER ADDITIONS OF RS. 5,00,000/-, RS. 1,00,000/- AND RS. 61,260/-, WE HAVE SEEN THE PAPER BOOK FILED BY THE ASSESSEE AND WE ARE OF THE VIEW THAT THE ASSESSEE HAS GIVEN EXPL ANATION AND FILED THE AFFIDAVIT OF MR. ASHWANI KUMAR ALIAS GOLDY SUPPORTI NG THE VERSION OF THE ASSESSEE AND CONFIRMING DIRECT RECEIPT OF THE A BOVE PAYMENTS FROM PATIENTS AGAINST SUPPLY OF IMPLANTS TO THEM, WHICH WAS FURTHER CONFIRMED TO BE PART OF THEIR REGULAR SALES AND DECLARED IN T HE RETURN FILED BY HIM BUT THE SAME HAS BEEN REJECTED BY THE REVENUE AUTHORITY . THUS, WE ARE OF THE VIEW THAT THE ASSESSEE HAS NOT FURNISHED INACCURATE PARTICULARS OF INCOME OR CONCEALED ANY PARTICULARS OF INCOME. 11) WE HAVE THOROUGHLY GONE THROUGH THE IMPUGNED ORDE R IN WHICH WE HAVE SEEN THAT THE LEARNED FIRST APPELLATE AUTHO RITY HAS ONLY REPRODUCED THE BRIEF FACTS OF THE PENALTY ORDER AND THE ORDER DATED 31.03.2010 PASSED UNDER SECTION 264 OF THE ACT BY T HE COMMISSIONER OF INCOME TAX (CENTRAL), LUDHIANA AND EVEN HIS FINDING IS ONLY ON THE BASIS OF THE ADDITION CONFIRMED BY COMMISSIONER OF INCOME TAX (CENTRAL), LUDHIANA, AND HE UPHELD THE PENALTY IN DISPUTE ONLY BY REDUCING THE PENALTY FROM 200% TO 100% OF THE TAX SOUGHT TO BE E VADED. IN OUR CONSIDERED VIEW, IT IS AN ESTABLISHED LAW THAT EVEN IF THE VERDICT IN QUANTUM HAS NOT FALLEN IN ASSESSEES FAVOUR, THAT W OULD NOT BY ITSELF SHUT 9 I.T.A. NOS. 538 & 549(ASR)/2011 THE DOORS ON ASSESSEE IN THE MATTER OF PENALTY. TO SUPPORT THIS CONTENTION, HE HAS RELIED UPON THE DECISION OF SUPREME COURT OF INDIA IN THE CASE OF ANANTHARAM VEERASINGHAIAH & CO. VS. CIT REPORTED IN (1980) 123 ITR 457 (SC), IN WHICH THE HON'BLE SUPREME COURT HAS HE LD THAT FINDING GIVEN IN THE ASSESSMENT PROCEEDING CANNOT BE REGARD ED AS CONCLUSIVE FOR THE PURPOSES OF PENALTY PROCEEDINGS- THE MERE FALSI TY OF THE EXPLANATION GIVEN BY THE ASSESSEE IS INSUFFICIENT WITHOUT THERE BEING, IN ADDITION, COGENT MATERIAL OR EVIDENCE FROM WHICH THE NECESSAR Y CONCLUSION ATTRACTING A PENALTY COULD BE DRAWN. IN ANOTHER CAS E, HON'BLE SUPREME COURT OF INDIA IN THE CASE OF T. ASHOK PAI VS. CIT REPORTED IN (2007) 292 ITR 11(SC) AGAIN HELD THAT IN PENALTY PROCEEDINGS, MATTER MUST BE CONSIDERED AFRESH FROM AN ANGLE DIFFERENT FROM ASSE SSMENT. IN THE CASE OF ACIT VS. SMT. SURINDER KAUR REPORTED IN (2009) 18 D TR (TRIB.) 38, THE LUCKNOW BENCH I.T.A.T. HAS HELD THAT WHERE LEVY OF PENALTY U/S. 271(1)(C) IN A SEARCH CASE WAS BEING CONTESTED, THE TRIBUNAL FOUND THAT THE ASSESSMENT FRAMED U/S 153A/153C, THOUGH NOT CHALLEN GED BY ASSESSEE, WAS ITSELF INVALID AND THEREFORE, THE PENALTY WAS N OT SUSTAINED OBSERVING THAT THERE WAS NO VALID PLATFORM WHICH COULD BE EXT ENDED FURTHER TO BUILD UP A CASE FOR LEVY OF PENALTY. HON'BLE SUPREME COUR T IN THE CASE OF CIT VS. RELIANCE PETROPRODUCTS REPORTED IN (2010) 230 I TR 320(SC), HAS ALSO 10 I.T.A. NOS. 538 & 549(ASR)/2011 HELD THAT WHERE THE ASSESSEE HAS CLAIMED A DEDUCTIO N WHICH IS NOT ACCEPTED BY THE A.O. FOR ANY REASON, PENALTY U/S 27 1(1)(C) OF THE ACT IS NOT LEVIABLE. 12) KEEPING IN VIEW THE AFORESAID FACTS AND CIRCUMSTA NCES OF THE PRESENT CASE, WE ARE OF THE CONSIDERED VIEW THAT TH E PENALTY IN DISPUTE HAS BEEN LEVIED BY THE REVENUE AUTHORITY ONLY ON THE BA SIS OF ADDITION SUSTAINED BY LEARNED COMMISSIONER OF INCOME TAX (CE NTRAL), LUDHIANA, VIDE ORDER DATED 31.03.2010 PASSED UNDER SECTION 26 4 OF THE ACT. NO INDEPENDENT FINDING HAS BEEN GIVEN BY THE REVENUE A UTHORITY ON THE CONCEALMENT OF PARTICULARS OF INCOME OR ON THE FURN ISHING OF INACCURATE PARTICULARS OF INCOME BY THE ASSESSEE. REVENUE AUTH ORITY HAS ALSO FAILED TO ESTABLISH WITH ANY COGENT REASON OR ANY PIECE OF EVIDENCE THAT IT HAS FILED RETURN OF INCOME WITH ANY MALA FIDE INTENTION OR BAD INTENTION, FOR WHICH THE ASSESSEE IS NOT LEGALLY ENTITLED. THEREFO RE, IN OUR CONSIDERED VIEW, THE ASSESSING AUTHORITY HAS WRONGLY LEVIED TH E PENALTY IN DISPUTE AND WRONGLY REJECTED THE EXPLANATION GIVEN BY THE A SSESSEE. IN OUR CONSIDERED VIEW, THE PENALTY IS NOT SUSTAINABLE IN THE EYE OF LAW, THEREFORE, THE IMPUGNED ORDER DATED 13.09.2011 PASS ED BY LEARNED CIT-I, LUDHIANA, IS CANCELLED AND THE PENALTY IN DISPUTE I S DELETED BY ACCEPTING 11 I.T.A. NOS. 538 & 549(ASR)/2011 THE APPEAL FILED BY THE ASSESSEE. ACCORDINGLY, THE APPEAL FILED BY THE ASSESSEE IS ALLOWED AND THE APPEAL FILED BY THE REV ENUE IS DISMISSED. 13) IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE I .E. I.T.A. NO. 538(ASR)/2011 IS ALLOWED AND THE APPEAL FILED BY TH E REVENUE I.E. I.T.A. NO. 549(ASR)/2011 IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 31 ST MARCH, 2014 SD/./- SD/./- (B.P. JAIN) (H.S. SIDHU) ACCOUNTANT MEMBER JUDICIAL MEMBER DATED: 31 ST MARCH, 2014 /RK/ COPY OF THE ORDER FORWARDED TO: 1. THE ASSESSEE: M/S ORTHONOVA HOSPITAL NAKODAR RAOD , JALANDHAR 2. ACIT, CENTRAL CIRCLE, JALANDAHAR 3. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-I I, JALANDHAR 4. THE CIT(A), 5. THE CIT, 6. THE SR DR, I.T.A.T., TRUE COPY BY ORDER (ASSISTANT REGISTRAR) INCOME TAX APPELLATE TRIBUNAL, AMRITSAR BENCH: AMRITSAR.