Smt Saroj Ramesh Rander, Nagpur V. Add.Commissioner of Income Tax Rang-4, Nagpur

ITA 56/NAG/2013

• Counselvise Citation: [2015] 134 COUNSELVISE.COM (IT) 1605 (ITAT-NAGPUR)
• Duration Of Justice: 2 year(s) 9 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 24-11-2015
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: DB
• Assessment Year: 2008-2009
• Appeal Filed On: 08-02-2013
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: NARENDRA KANE
• Keywords: Gross profit estimation
• Section: 143(3); 68; 144

Judgement Text

1 ITA NO. 56/NAG/2013 IN THE INCOME TAX APPELLATE TRIBUNAL, NAGPUR BENCH, NAGPUR BEFORE SHRI MUKUL K. SHRAWAT, JUDICIAL MEMBER AND SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER. I.T.A. NO.56/NAG/2013 ASSESSMENT YEAR : 2008 - 09. SMT. SAROJ RAMESH RANDER, ADDL. COMMISSIONER OF INCOME - TAX NAGPUR. VS. RANGE - 4, NAGPUR. APPELLANT. RESPONDENT. APPELLANT BY : SHRI VIJAY CHANDAK. RESPONDENT BY : SHRI NARENDRA KANE. DATE OF HEARING : 21 - 10 - 2015 DATE OF PRONOUNCEMENT : 24 TH NOV., 2015 O R D E R P ER MUKUL K. SHRAWAT, J.M. THIS IS AN APPEAL FILED BY THE ASSESSEE ARISING FROM AN ORDER OF LEARNED CIT(APPEALS) - 19 (CAMP OFFICE NAGPUR) DATED 09 - 11 - 2012. THE GROUNDS RAISED ARE ARGUMENTATIVE IN NATURE. HOWEVER, THE MAIN ISSUE RAISED AS PER THE FOLLOWING GROUNDS : (1) THAT THE ORDER O F THE LEARNED ADDL . COMMISSIONER OF INCOME TAX IS BAD IN LAW AND WRONG ON FACTS AND THE LEARNED CIT (APPEAL) ERRED IN CONFIRMING THE SAME. ON THE FACTS AND CIRCUMSTANCES OF THE CASE THE ACTION OF THE CIT(A) IS UNJUSTIFIED. (2) (A) THAT THE ASSESSING OFFICER ERRED IN LAW AND ON FACTS IN REJECTING THE BOOK RESULTS AND ESTIMATING THE GROSS PROFIT OF RS .. 87,42,864J - AS AGAINST RS.25,04,929J - DISCLOSED IN THE BOOKS OF ACCOUNTS AND LEARNED CIT(A) WAS UNJUSTIFIED IN UPHOLDING THE ACTI ON OF L EARNED A O . ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND EVIDENCE PRODUCED, THE ORDER OF THE LEARNED AUTHORITIES WAS GROSSLY ERRONEOUS AND LIABLE TO BE SET ASIDE. THE AUTHORITIES HAVE NOT BROUGHT ANY EVIDENCE ON 2 ITA NO. 56/NAG/2013 RECORD TO PROVE THEIR CONTENTION THAT THE BOOKS OF ACCOUNTS DO NOT SHOW A TRUE AND FAIR VIEW OF THE PROFITABILITY OF THE BUSINESS. (B) THAT THE LEARNED A O ERRED IN LAW AND ON FACTS IN I NVOKING PROVISIONS OF SECTION 145(3) AND MAKING ASSESSMENT U / S . 1 44 AND THE LEARNED CIT(A) WAS NO T JUSTIFIED IN UPHOLDING THE ASSESSMENT ON SUCH BASIS. (C) THAT THE ASSESSING OFFICER ERRED IN LAW AND ON FACTS IN STATING THAT THE ASSESSEE HAS COMPLETELY FAILED TO SUBSTANTIATE THE FLUCTUATION IN RATES OF SALES AND HENCE HAS FAILED TO QUANTIFY AND SU PPORT THE GROSS PROFIT AS SHOWN IN BOOKS AND LEARNED CIT(A) WAS UNJUSTIFIED IN CONFIRMING THE SAME. ON THE FACTS AND CIRCUMSTANCES OF THE CASE, THE ACTION OF THE AUTHORITIES IN NOT CONSIDERING THE EXPLANATION PROVIDED BY THE APPELLANT WAS ARBITRARY AND UNJ USTIFIED. (3) (A) THAT THE LEARNED ASSESSING OFFICER ERRED IN LAW AND ON FACTS IN HOLDING THAT THE AGRICULTURAL INCOME OF RS.3,47,484/ - HAS NOT BEEN SATISFACTORILY EXPLAINED BY THE ASSESSEE AND LEARNED CIT(A) ERRED IN UPHOLDING THE ACTION OF LEARNED A O. ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND EVIDENCE PRODUCED THE ACTION OF ASSESSING OFFICER IN DOUBTING THE GENUINENESS OF AGRICULTURAL INCOME IS UNJUSTIFIED. (B) THAT THE LEARNED ASSESSING OFFICER ERRED IN LAW AND ON FACTS IN INVOKING THE PRO VISIONS OF SECTION 68 OF THE INCOME TAX ACT AND THE LEARNED CIT(A) FURTHER ERRED IN UPHOLDING THE SAME. (4) THAT LEARNED CIT(A) ERRED IN UPHOLDING THAT THE ASSESSEE HAS FAILED TO DISCHARGE THE ONUS CAST UPON HIM TO PROVE WITH DOCUMENTARY EVIDENCES THE CLAIM MADE BY HIM IN THE RETURN OF INCOME. ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND EVIDENCE PRODUCED, THE ORDER OF THE LEARNED AUTHORITY IS ERRONEOUS AND LIABLE TO BE SET ASIDE. (5) THAT THE ASSESSING OFFICER ERRED IN LAW AND ON FACTS III CHARGING INTEREST U/S.234B AND 234D OF THE INCOME TAX ACT AND THE LEARNED CIT(A) ERRED IN CONFIRMING THE SAME ON THE BASIS OF SURMISES. HENCE THE ACTION OF AUTHORITIES IS UNJUSTIFIED. 2. FACTS IN BRIEF AS EMERGED FROM THE CORRESPONDING A SSESSMENT ORDER PASSED U/S 144 READ WITH SECTION 143(3) DATED 30 TH DEC., 2010 WERE THAT THE ASSESSEE IS IN INDIVIDUAL CAPACITY IS IN THE BUSINESS OF TRADING IN YARN AND ALSO A COMMISSION AGENT. DURING THE COURSE OF ASSESSMENT PROCEEDINGS IT WAS OBSERVED BY THE AO THAT THE TURNOVER WAS TO THE TUNE OF RS.33,62,63,995/ - AND THE GROSS PROFIT DECLARED WAS RS.25,04,925/ - . THE RATIO OF THE GROSS PROFIT WAS 3 ITA NO. 56/NAG/2013 CALCULATED BY THE ASSESSEE AT 0.74 %. ACCORDING TO THE AO THE RATIO OF PROFIT EARNED WAS VERY LOW. AN EN QUIRY WAS RAISED ON THE GROUND THAT IN THE PAST THE GROSS PROFIT RATIO WAS HIGHER THAN THE PROFIT DECLARED FOR THE YEAR UNDER CONSIDERATION. THE EXPLANATION OF THE ASSESSEE WAS THAT THE PRICES OF THE YARN WERE ALWAYS SUBJECT T O FLUCTUATION, HENCE THERE WA S NO FIXED MARGIN OF PROFIT IN THIS LINE OF BUSINESS. THE MARGIN OF PROFIT DIFFER FROM YEAR TO YEAR. THE ASSESSEE HAS FURNISHED THE DETAILS OF THE SALES MADE TO DEMONSTRATE THAT EVEN ON A PARTICULAR DATE THE RATES WERE NOT FIXED BUT FLUCTUATED. THE DETAILS OF THE RATES FLUCTUATION WERE RECORDED BY THE AO IN THE ORDER. HOWEVER, THE AO WAS NOT CONVINCED AND FINALLY HELD AS UNDER : 1. IF THE GROSS PROFIT FOR THE LAST TWO YEARS WAS ANALYZED AND IT WAS FOUND T~LAT THE RATIO WAS MUCH HIGHER THAN 0.74 %. - CROSS PROFIT PERCENT S.NO. ASS.T. YE AQ R TURN OVER 1. 2008 - 09 RS. 33,6 - 2,63,995/ - RS. 25,04,929/ - 0.74% - .. - . -- _ .. - - . - - - RS. 24,07,11,394/ - RS. 62,58,496/ - 2.6% 2 2007 - 08 (AS ASSESSED) - - - RS. 7,00,09,343/ - RS.7,32,914/ - 1.5% 3. 2006 - 07 - -- -- -- _._ - _ ..... -- - - 4 2005 - 06 RS. 1,16,27,872/ - RS.4,41,723/ - 3.7% -- -- . - ... - - , -- . -- THE GP % FOR PREVIOUS THREE YEARS IS 3.7%, 1.5% & 2.6% FAT' AY 2005 - _06, 2006 - 07 & 2007 - 08 IS RESPECTIVELY. BUT IN THE PRESENT ASSESSMENT YEAR, THE GROSS PROFIT PERCENT HAS REDUCED TO 0.74% WHICH IS ABYSMALLY LOW. THE ASSESSEE WAS ASKED TO SUBMIT THE REASONS FOR THIS, BUT THE REASONS GIVEN CANNOT IN ANY WAY SUBSTANTIATE LOW GP WHICH ARE DISCUSSED IN DETAIL ABOVE AND HENCE LOW GP OF 0.74% IS NOT ACCEPTABLE. AS ASSESSEE HAS COMPLETELY FAILED TO SUBSTANTIATE THE FLUCTUATION RATES OF SALES AND HENCE HAS COMPLETELY FAILED TO QUANTIFY & SUPPORT THE GP AS SHOWN IN HER BOOKS OF ACCOUNT. AS PER SEC. 145(3) WHERE THE AO IS NOT SATISFIED ABOUT THE CORRECTNESS OR COMPLETENESS OF THE ACCOUNT OF THE' ASSESSEE OR WHERE THE METHOD OF ACCOUNTING PR OVIDED IN SUB - SEC. (1) OR ACCOUNTING STANDARDS ARE NOTIFIED UNDER SUB - SEC. (2), HAVE NOT BEEN. REGULARLY FOLLOWED BY THE ASSESSEE, THE AO MAY MAKE AN ASSESSMENT IN THE MANNER PROVIDED IN SEC. 144. ,AS THE ASSESSEE HAS COMPLETELY FAILED TO SUBSTANTIATE THE FLUCTUATIONS IN SALES WHICH COULD QUANTIFY THE LOW GP SHOWN BY THE ASSESSEE. THE DETAILS OF FLUCTUATIONS ARE ENUMERATED ABOVE AND FOR VARIOUS REASONS GIVEN ABOVE, THE CORRECTNESS OF THE BOOKS MAINTAINED BY THE ASSESSEE ARE NOT SATISFACTORY AS PER TH E IT ACT AND HENCE THE 4 ITA NO. 56/NAG/2013 BOOK RESULTS SHOWN BY THE ASSESSEE ARE HEREBY REJECTED U/S. 145(3) AND I PROCEED TO MAKE AN ASSESSMENT AS PROVIDED IN SEC. 144 OF LT. ACT, 1961. FROM THE GROSS PROFIT ANALYSIS OF THE LAST THREE YEARS IN ASSESSEE'S OWN CASE, IT I S SEEN THAT THE GP PERCENT IS MUCH HIGHER THAN THE PRESENT ASSTT. YEAR. TAKING THAT . GP PERCENTAGE OF ASSESSEE'S OWN CASE FOR A.Y. 2007 - 08 I.E. 2.6% (AS ASSESSED) > ' A.Y. 2006 - 07 I.E. 1.5% (AS PER RETURN) & FOR A.Y. 2005 - 06 OF 3.7%(AS PER RETURN). - : .. THE AVERAGE OF THE ABOVE THREE YEARS IS I.E. 2.6+ 1.5+3.7/3 = 2.6% IS TAKEN AS CORRECT GP FOR THE CURRENT ASSTT. YEAR AND ASSESSED ACCORDINGLY. 3. BEING AGGRIEVED, THE MATTER WAS CARRIED BEF O RE THE F I RST APPELLATE AUTHORITY WHO HAS CONFIRMED THE ACTION OF THE AO AFTER ASSIGNING THE FOLLOWING REASONS : I HAVE CAREFULLY CONSIDERED THE FACTS OF THE CASE, THE SUBMISSIONS OF THE APPELLANT AND ASSESSMENT ORDER. IN APPEAL, NO EVIDENCE HAS BEEN FURNISHED TO CONTROVERT THE FINDING AND THE REASONING GIVEN BY THE AO FOR ESTIMATING THE GP RATE. THE AO HAS GIVEN DETAILED CHART AND MADE ANALYSIS TO SUPPORT HER FINDINGS. THE ASSESSEE APART FROM MAKING A GENERAL STATEMENT HAS NOT SU BSTANTIATED ITS FINDING THROUGH DOCUMENTARY EVIDENCE. FROM THE PROCEEDINGS IN THE ORDER SHEET IT IS NOTICED THAT THE HEARING HAS BEEN ACCORDED ON 22.07.2011, 04.08.2011, 23.09.2011, 11.11.2011, 22.11.2011, 19.01.2012, 03.02.2012, 23.02.2012 AND LASTLY ON 05.11.2012. IT IS NOTICED THAT ONLY ON ONE O CCASION A WRITTEN SUBMISSION DTD. 30.12.2011 HAS BEEN FILED. ALONGWITH THE WRITTEN SUBMISSION SOME UNSIGNED XEROX OF BILLS WERE PRODUCED WHICH ARE NOT LEGIBLE. THE PAPERS ATTACHED WITH THE WRITTEN SUBMISSION NE ITHER SUBSTANTIATE THE CLAIM OF THE ASSESSEE NOR CONTROVERT THE FINDING OF THE AO. IT IS A SETTLED LAW THAT THE ONUS IS ON THE ASSESSEE TO PROVE WITH DOCUMENTARY EVIDENCES THE CLAIM THAT HE HAS MADE. THE ASSESSWEE HAS FAILED TO DO SO. THE AO AFTER DETAILED REASONING HAS ESTIMATED THE GROSS PROFIT RATE. CONSIDERING THE FACTUAL MATRIX OF THE CASE, I UPHOLD THE ACTION OF THE ASSESSING OFFICER AND DISMISS THE CLAIM OF THE APPELLANT. GROUND NO. 2 & 3 DISMISSED. 4. IN THE LIGHT OF THE ABOVE FACTUAL BACKGROUND W E HAVE HEARD BOTH THE SIDES. AT THE OUTSET WE HAVE BEEN INFORMED THAT IN ASSESSEES OWN CASE THE ITAT, 5 ITA NO. 56/NAG/2013 NAGPUR BENCH IN ITA NO. 114/NAG/2013 FOR ASSESSMENT YEAR 2009 - 10 TITLED AS DCIT VS. SMT. SAROJ RANDER VIDE ORDER DATED 20 TH MAY, 2015 HAS HELD THAT THE ISSUE OF ADDITION PERTAINING TO THE GROSS PROFIT WAS NOT TO BE SUSTAINED. RE L EVANT PORTIONS ARE REPRODUCED BELOW : 3. UPON ASSESSEES APPEAL, LEARNED CIT(APPEALS) NOTED THAT THE GROSS PROFIT PERCENTAGE SHOWN DURING THE YEAR UNDER CONSIDERATION IS .91% WHICH IS HIGHER THAN THE GP PERCENTAGE OF .21% AND .75% AS SHOWN IN ASSESSMENT YEARS 2007 - 08 AND 2008 - 09 RESPECTIVELY. LEARNED CIT(APPEALS) FURTHER OBSERVED THAT THE ASSESSING OFFICER HAS NOT BROUGHT ON RECORD ANY MATERIAL TO SHOW THAT THERE ARE DEFECTS IN THE BOOKS OF ACCOUNT OF THE ASSESSEE WARRANTING THEIR REJECTION. LEARNED CIT(APPEALS) FURTHER REFERRED TO THE CIT(APPEALS) ORDER FOR ASSESSMENT YEAR 2007 - 08 WHEREIN IT WAS HELD THAT THE REJECTION OF BOOKS OF ACCOUNT BY THE ASSESSING OFFICER AND THE ESTIM ATION OF GP IS NOT JUSTIFIED. ACCORDINGLY, LEARNED CIT(APPEALS) DELETED THE ADDITION. AGAINST THE ABOVE ORDER, REVENUE IS IN APPEAL BEFORE US. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 5. LEARNED COUNSEL OF THE ASSESSEE, ON THE OTHER HAND, SUBMITTED THAT THE ASSESSING OFFICER HAS COMPARED THE GROSS PROFIT WITH THAT ASSESSED IN EARLIER YEARS. LEARNED COUNSEL SUBMITTED THAT THE GROSS PROFIT AS ASSESSED BY THE ASSESSING OFFICER IN EARLIER YEARS HAS BEEN DELETED IN APPELLATE PROCEEDI NGS. HENCE HE SUBMITTED THAT THERE IS NO BASIS FOR ADDITION MADE BY THE ASSESSING OFFICER. IN THIS REGARD, LEARNED COUNSEL REFERRED TO THE DECISION OF ITAT, NAGPUR BENCH IN ASSESSEES OWN CASE FOR ASSESSMENT YEAR 2007 - 08 IN ITA NO. 250/NAG/2012. IN THIS C ASE VIDE ORDER DATED 19 - 11 - 2014 THE TRIBUNAL HAD HELD THAT THE CIT(APPEALS) HAS MADE A CATEGORICAL FINDING THAT THE ASSESSING OFFICER COULD NOT FIND ANY IRREGULARITY IN THE BOOKS OF ACCOUNT WHICH COULD TRIGGER REJECTION OF BOOKS. THE TRIBUNAL UPHELD THE C IT(APPEALS) ORDER THAT THE RESULTS AS DECLARED BY THE ASSESSEE SHOULD BE ACCEPTED. 5. WE HAVE CAREFULLY CONSIDERED THE SUBMISSIONS AND PERUSED THE RECORDS. WE FIND THAT THE ASSESSING OFFICER HAS NOT FOUND ANY DEFECTS IN THE BOOKS OF ACCOUNT. HE HAS REJEC TED THE BOOKS OF ACCOUNT OF THE ASSESSEE ONLY BY COMPARING THE GROSS PROFIT RATIO OF THE CURRENT YEAR WITH THAT ASSESSED IN EARLIER YEARS. THE GROSS PROFIT AS ASSESSED BY THE ASSESSING OFFICER IN EARLIER YEARS HAS NOT BEEN SUSTAINED BY THE APPELLATE AUTHOR ITY. HENCE IT CANNOT BE SAID THAT THE BENCH MARK ADOPTED BY THE ASSESSING OFFICER FOR COMPARING THE GROSS PROFIT OR ASSESSING THE GROSS PROFIT IS 6 ITA NO. 56/NAG/2013 SUSTAINABLE. IN ASSESSEES OWN CASE THE ITAT FOR ASSESSMENT YEAR 2007 - 08 IN SIMILAR CIRCUMSTANCES HAD UPHELD T HE ORDER OF LEARNED CIT(APPEALS). SINCE IN ASSESSEES OWN CASE SIMILAR ADDITION MADE BY THE ASSESSING OFFICER WAS DELETED BY THE CIT(APPEALS) AND THE SAME WAS UPHELD BY THE ITAT, WE FIND THAT DOCTRINE OF STARELECESIS MANDATES THAT WE FOLLOW THE PRECEDENT A ND UPHOLD THE ORDER OF LEARNED CIT(APPEALS) SINCE THE FACTS ARE IDENTICAL. FOLLOWING THE ABOVE DECISION, WE UPHOLD THE ORDER OF LEARNED CIT(APPEALS). 4.1 APART FROM THE AFOREMENTIONED ORDER OF THE TRIBUNAL IN WHICH BOTH OF US ARE THE SIGNATORIES, ONE MO RE DECISION OF ITAT, NAGPUR BENCH, NAGPUR DATED 19 - 11 - 2014 HAS BEEN REFERRED BEFORE US PERTAINING TO THE ASSESSMENT YEAR 2007 - 08 BEARING ITA NO. 320/NAG/2012 AND ITA NO. 250/NAG/2012 (CROSS APPEALS) TITLED AS SMT. SAROJ RANDER VS. ACIT WHEREIN AS WELL T HE IMPUGNED ADDITION WAS DELETED. 5. SINCE IN ASSESSEES OWN CASE A CONSISTENT VIEW HAS BEEN TAKEN BY THE RESPECTED COORDINATE BENCHES, THEREFORE, WE FIND NO REASON TO TAKE ANY OTHER VIEW FOR THE YEAR UNDER CONSIDERATION BUT TO FOLLOW THE VIEW ALREADY TAKEN I N THE PAST. 6. IN THE RESULT, THE GROUND RAISED BEFORE US BY THE ASSESSEE IS ALLOWED. 7. GROUND NO. 3 : THE ASSESSEE HAD SHOWN AN AGRICULTURAL INCOME OF RS.3,47,484/ - . . THE AO HAD ENQUIRED ABOUT THE AGRICULTURAL LAND AVAILABLE FOR AGRICULTURAL OPERATION . FROM THE SIDE OF THE ASSESSEE, A 7/12 EXTRACT WAS FURNISHED. THE OBJECTION OF THE AO WAS THAT THE ASSESSEE HAD NOT INCURRED OR CLAIMED ANY AGRICULTURAL OPERATION EXPENSES. FURTHER AS PER THE AO THE DET A ILS OF THE RECEIPTS OF AGRICULTURAL INCOME HAVE ALS O NOT BEEN SUBSTANTIATED. FINALLY BY INVOKING THE PROVISIONS OF SECTION 68 OF I.T. ACT THE SAID AGRICULTURAL INCOME WAS TAXED. 8. WHEN THE MATTER WAS CARRIED BEFORE THE FIRST APPELLATE AUTHORITY, LEARNED CIT(APPE A LS) HAS AFFIRMED THE ACTION OF THE AO. 7 ITA NO. 56/NAG/2013 9. W E HAVE HEARD BOTH THE SIDES ON THIS ISSUE. BEFORE US THE ADMITTED FACTUAL POSITION WAS THAT IN THE PAST THE ITAT, NAGPUR BENCH, NAGPUR IN THE ORDER DATED 19 - 11 - 2014 (SUPRA) HAS RESTORED THE ISSUE FOR FRESH ADJUDICATION IN RESPECT OF INCOME EARNED FROM AG RICULTURAL OPERATION. HOWEVER, FOR THE YEAR UNDER CONSIDERATION THE ADMITTED FACTUAL POSITION IS THAT SINCE IN THE PAST SO MANY YEARS THE REVENUE AUTHORITIES WERE ENQUIRING ABOUT THE DETAILS OF THE AGRICULTURAL OPERATION AND THE EVIDENCE IN RESPECT OF THE RECEIPT OF AGRICULTURAL INCOME. MERELY BY FURNISHING 7/12 EXTRACT THE EXACT AMOUNT OF AGRICULTURAL INCOME EARNED COULD NOT BE DETERMINED. FOR THAT PURPOSE THE DETAILS OF INCOME AND EXPENDITURE WAS REQUIRED TO BE FURNISHED BY THE ASSESSEE. SINCE THE ASSESSE E HAD CONSISTENTLY FAILED TO PLACE ON RECORD THE EVIDENCE BEFORE THE REVENUE AUTHORITIES, WE FIND NO REASON TO GIVE AN ANOTHER ROUND OF OPPORTUNITY FOR THE YEAR UNDER CONSIDERATION. THE ADDITION MADE BY THE AO WAS RIGHTLY CONFIRMED BY THE LEARNED CIT(APPEA LS). THIS GROUND OF THE ASSESSEE IS HEREBY DISMISSED. 10. IN THE RESULT, THE ASSESSEES APPEAL IS PARTLY ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON THIS 24 TH DAY OF NOV., 2015. SD/ - SD/ - ( SHAMIM YAHYA) (MUKUL K . SHRAWAT) ACCOUNTANT MEMBER. JUDICIAL MEMBER NAGPUR, DATED: 24 TH NOV., 2015. 8 ITA NO. 56/NAG/2013 COPY FORWARDED TO : 1. SMT. SAROJ RAMESH RANDER, , C/O M/S LOYA BAGRI & CO., C.AS., GANDHIBAGH, NAGPUR. 2. ADDL. .C.I.T., RANGE - 4 , NAGPUR. 3. C.I.T., CONCERNED 4. CIT(APPEALS) - , NAGPUR. 5. D.R., ITAT, NAGPUR. 6. GUARD FILE TRUE COPY BY ORDER ASSISTANT REGISTRAR, INCOME TAX APPELLATE TRIBUNAL, NAGPUR BENCH, NAGPUR.