The Asstt. Commissioner of Income Tax, Jalandhar V. Ripan Deep Takhar, Jalandhar

ITA 665/ASR/2014

• Counselvise Citation: [2016] 133 COUNSELVISE.COM (IT) 0688 (ITAT-AMRITSAR)
• Duration Of Justice: 1 year(s) 7 month(s) 10 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 13-06-2016
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: DB
• Next Hearing Date: 02-06-2016
• Assessment Year: 2009-2010
• Appeal Filed On: 03-11-2014
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: UMESHKUMAR TAKYAR
• Keywords: Block assessment; Documents seized
• Section: 143(3); 132; 15

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH; AMRITSAR. BEFORE SH. A.D. JAIN, JUDICIAL MEMBER AND SH. T.S. KAPOOR, ACCOUNTANT MEMBER ITA NO.665(ASR)/2014 ASSESSMENT YEAR:2009-10 PAN: ATVPT1531B ASSTT. COMMR. OF INCOME TAX, VS. RIPAN DEEP TAKHAR, CENTRAL CIRCLE-1, 544, MODEL TOWN, JALANDHAR. JALANDHAR. (APPELLANT) (RESPONDENT) C.O. NO.02(ASR)/2015 (ARISING OUT OF ITA NO.665(ASR)/2014) ASSESSMENT YEAR:2009-10 PAN: ATVPT1531B RIPAN DEEP TAKHAR, VS. ASSTT. COMMR. OF INCOME TAX , 544, MODEL TOWN, CENTRAL CIRCLE-1, JALANDHAR. JALANDHAR. (APPELLANT) (RESPONDENT) DEPARTMENT BY: SH. UMESH KUMAR TAKYAR, DR ASSESSEE BY: SH.SANDEEP VIJH, CA DATE OF HEARING: 02/06/2016 DATE OF PRONOUNCEMENT: 13/06/2016 ORDER PER A.D. JAIN, JM: THIS IS THE DEPARTMENTS APPEAL FOR THE ASSESSMENT YEAR 2009-10, AGAINST THE ORDER, DATED 12.08.2014, PASSED BY THE LD. CIT(A), JALANDHAR. THE ASSESSEE HAS ALSO FILED CROSS OBJECTION. ITA NO.665(ASR)/2014 C.O.02(ASR)/2015 A.Y. 2009-10 2 2. THE CROSS OBJECTION FILED BY THE ASSESSEE INVOLV ES A LEGAL ISSUE AND AS SUCH, IT IS BEING TAKEN UP FOR DECISION FIRST. A S PER THIS CROSS OBJECTION, ABSENCE OF SATISFACTION OF THE AO IN THE CASE OF THE PERSON SEARCHED IS NOT A CURABLE DEFECT WHEN CONSIDERING THE PROVISIONS OF SECTION 153C OF THE INCOME TAX ACT, 1961 AND THE LD . CIT(A)S ORDER HOLDING OTHERWISE HAS BEEN CHALLENGED BY THE ASSES SEE. 2. THE FACTS ARE THAT A SEARCH WAS CARRIED OUT IN T HE CASE OF M/S. PUNJAB IRON & STEEL COMPANY LTD. AND ALSO IN THE CA SE OF ONE OF ITS DIRECTORS SH. RAMESH INDER SINGH, WHO IS THE FATHER OF THE ASSESSEE . IT IS AN UNDISPUTED POSITION THAT THERE WAS NO SEARCH WAR RANT IN THE CASE OF THIS ASSESSEE AND THE ASSESSMENT HAS ALSO BEEN FRAM ED U/S 153C. 3. THE ASSESSEE TOOK THE FOLLOWING GROUND BEFORE TH E LD. CIT(A): THAT THE ORDER UNDER SECTION 153C READ WITH SECTIO N 143(3) IS BAD IN LAW. 4. THE LD. CIT(A) DECIDED THE ISSUE HOLDING AS FOLL OWS: I HAVE CONSIDERED THE FACTS OF THE CASE, THE BASIS OF JURISDICTION ASSUMED BY THE ASSESSING OFFICER UNDER SECTION 153C AND ARGUMENTS OF THE AR DURING ASSESSMENT PROC EEDINGS AS WELL AS APPELLATE PROCEEDINGS ON THE ISSUE. THE COMMENTS OF THE ASSESSING OFFICER DURING REMAND PROCEEDINGS HAV E ALSO BEEN CONSIDERED. THE PROVISIONS OF SECTION 153C WHI CH GOVERN 'ASSESSMENT OF INCOME OF ANY OTHER PERSON' READ AS UNDER:- 'NOTWITHSTANDING ANYTHING CONTAINED IN SECTION 139, SECTION 147, SECTION 148, SECTION 149, SECTION 151 AND SECTION 153, WHERE THE ASSESSING OFFICER IS SATISFIED THAT ANY MONEY, BULLION, JEWELLERY OR OTHER VALUABLE ARTICLE OR THI NG OR BOOKS OF ITA NO.665(ASR)/2014 C.O.02(ASR)/2015 A.Y. 2009-10 3 ACCOUNT OR DOCUMENTS SEIZED -OR REQUISITIONED BELON GS OR BELONG TO A PERSON OTHER THAN THE PERSON REFERRED TO IN SECTION 153A, THEN THE BOOKS OF ACCOUNT OR DOCUMENTS OR ASS ETS SEIZED OR REQUISITIONED SHALL BE HANDED OVER TO THE ASSESS ING QFFICER HAVING JURISDICTION OVER SUCH OTHER PERSON AND THAT ASSESSING OFFICER SHALL PROCEED AGAINST EACH SUCH OTHER PERSO N AND ISSUE SUCH OTHER PERSON NOTICE AND ASSESS OR REASSESS INC OME OF SUCH OTHER PERSON IN ACCORDANCE WITH THE PROVISIONS OF SECTION 153A.' 7. THE PERUSAL OF THE ABOVE DETAILED PROVISION SHOW S THAT THE SATISFACTION HAS TO BE ARRIVED AT BY THE ASSESS ING OFFICER OF THE PERSON SEARCHED FROM WHOM RELEVANT VALUABLES OR INCRIMINATING DOCUMENTS ARE SEIZED AND THEREAFTER S UCH DOCUMENTS OR ASSETS ARE TO BE HANDED OVER TO THE AS SESSING OFFICER OF SUCH OTHER PERSON AND THE SAID ASSESSING OFFICER SHOULD PROCEED IN ACCORDANCE WITH THE PROVISIONS OF SECTION 153A. IT IS SEEN THAT THE ASSESSING OFFICER OF SEAR CHED PERSON AS WELL AS THE ASSESSING OFFICER OF THE APPELLANT A RE THE SAME. SATISFACTION RECORDED BY THE ASSESSING OFFICER OF T HE APPELLANT AMOUNTS TO RECORDING OF SATISFACTION BY THE ASSESSI NG OFFICER OF THE SEARCH PERSON FROM WHOM IMPUGNED DOCUMENTS HAD BEEN SEIZED. 8. THE AR OF THE APPELLANT HAS RELIED UPON THE JUD GMENT OF HON'BLE ITAT BENCH AT DELHI IN THE CASE OF DSL PROP ERTIES (P.) LTD. VS. DCIT [2013] 60 SOT 88 (DELHI- TRIB.)(URO) WHEREIN THE FOLLOWING OBSERVATIONS HAVE BEEN MADE:- 'THE ASSESSING OFFICER OF THE PERSON SEARCHED AND S UCH OTHER PERSON MAY BE THE SAME, BUT THESE ARE TWO DIFFERENT ASSESSEE AND, THEREFORE, THE ASSESSING OF FICER HAS TO CARRY OUT THE DUAL EXERCISE, FIRST AS THE AS SESSING OFFICER OF THE PERSON SEARCHED, IN WHICH HE HAS TO RECORD THE SATISFACTION DURING THE COURSE OF ASSESSMENT PROCEEDINGS OF THE PERSON SEARCHED. AFTER RECORDING SUCH SATISFACTION NOTE IN THE FILE OF THE PERSON SEARCHE D, THE SAME IS TO BE PLACED IN THE FILE OF SUCH OTHER PERS ON. THEN IN HIS CAPACITY AS THE ASSESSING OFFICER OF SUCH OT HER PERSON, HE SHOULD TAKE COGNIZANCE OF SUCH SATISFACT ION NOTE AND THEREAFTER ISSUE NOTICE UNDER SECTION 158B C. IN THE INSTANT CASE THIS EXERCISE OF RECORDING THE SAT ISFACTION DURING THE ASSESSMENT PROCEEDINGS OF THE PERSON SEARCHED HAS NOT BEEN CARRIED OUT. ON THE OTHER HAN D, THE ASSESSING OFFICER RECORDED THE SATISFACTION IN THE CASE OF SUCH OTHER PERSON WHICH DOES NOT SATISFY TH E ITA NO.665(ASR)/2014 C.O.02(ASR)/2015 A.Y. 2009-10 4 CONDITION OF ASSUMING JURISDICTION UNDER SECTION 15 3C. THEREFORE, THE ABOVE SATISFACTION NOTE CAN NOT BE S AID TO BE A VALID SATISFACTION NOTE WITHIN THE MEANING OF SECTION 153C. [PARA 15]' 9. THE APPARENT PROCEDURAL FLAW COULD BE REGULARIZED BY APPLICATION OF PROVISION OF SECTION 292B OF THE INC OME TAX ACT, 1961 WHICH READS AS UNDER: NO RETURN OF INCOME, ASSESSMENT, NOTICE, SUMMONS OR OTHER PROCEEDINGS, FURNISHED OR MADE OR ISSUED OR TAKEN OR PURPORTED TO HAVE BEEN FURNISHED OR MADE OR ISSU ED OR TAKEN IN PURSUANCE OF ANY OF THE PROVISIONS OF THIS ACT SHALL BE INVALID OR SHALL BE DEEMED TO BE INVALID M ERELY BY REASON OF ANY MISTAKE, DEFECT OR OMISSION IN SUC H RETURN OF INCOME, ASSESSMENT, NOTICE, SUMMONS OR OT HER PROCEEDING IF SUCH RETURN OF INCOME, ASSESSMENT, NO TICE, SUMMONS OR OTHER PROCEEDINGS IS IN SUBSTANCE AND EF FECT IN CONFORMITY WITH OR ACCORDING TO THE INTENT AND P URPOSE OF THIS ACT.' IN VIEW OF THE ABOVE DETAILED ANALYSIS OF PROVISION S OF THE STATUTE, I DO NOT AGREE WITH THE CONTENTION OF THE APPELLANT THAT THE PROCEDURAL FLAW POINTED OUT BY HIM AMOUNTS ANNU LMENT OF THE IMPUGNED ASSESSMENT ORDER. THIS GROUND OF APPEA L IS THEREFORE DISMISSED 5. THUS, THE LD. CIT(A) HELD THAT SINCE THE ASSESSI NG OFFICER OF SEARCHED PERSON AS WELL AS THE ASSESSING OFFICER OF THE ASSESSEE (THE OTHER PERSON) ARE THE SAME, THE SATISFACTION RECORDED BY THE ASSESSING OFFICER IN THE CASE OF THE ASSESSEE AMOUN TS TO RECORDING OF SATISFACTION BY THE ASSESSING OFFICER OF THE SEA RCHED PERSON FROM WHOM, DOCUMENTS HAD BEEN SEIZED; AND THAT THE APPAR ENT PROCEDURAL FLAW COULD BE REGULARIZED BY APPLICATION OF PROVISIONS OF SECTION 292B OF THE INCOME TAX ACT. ITA NO.665(ASR)/2014 C.O.02(ASR)/2015 A.Y. 2009-10 5 7. THE LD. COUNSEL FOR THE ASSESSEE PLACED RELIANCE ON THE FOLLOWING CASE LAWS: I) MANISH MAHESHWARI VS. ACIT, 289 ITR 341 (SC) II) DHAPUBAI JAIN VS. ACIT, (ITAT INDORE) IT(SS)A.NO.78/IND/2008, AY 2003-04, DATED 31.05.201 1. III) TANVIR COLLECTIONS VS. ACIT, ( ITAT DEL) 153 ITD 486 IV) DCIT VS. L.K. INDIA, (ITAT AHMEDABAD) 43 CCH 263 V) VINOD KUMAR CHAURASIYA VS. ACIT, ( ITAT LUCK) 42 CCH 30 VI) DSL PROPERTIES VS. DCIT, ( ITAT DEL.) 60 SOT 88 VII) CIT MECHMEN, (MP ) 380 ITR 591 VIII) PR. CIT VS. NIKKI DRUGS, 236 TAXMAN 305 (DEL.) IX) CENTRAL VS. GOPI APPARTMENT, (ALL.) 46 TAXMAN.COM , 280 X) CIT VS. SHETTYS PHARMACEUTICALS (AP) 90 CCH 517 XI) DCIT VS. LALITKUMAR N PATEL (GUJ.) 222 TAXMAN 8. THE LD. DR, ON THE OTHER HAND, RELIED ON THE IMP UGNED ORDER. NO DECISION CONTRARY TO THE ABOVE CASE LAWS WAS CITED. 9. IN MANISH MAHESHWARI VS. ACIT (SUPRA), IT HAS BEEN HELD THAT WHERE THE PREMISES OF A DIRECTOR OF A COMPANY AND H IS WIFE WERE SEARCHED UNDER SECTION 132 OF THE INCOME-TAX AC, 19 61, AND A BLOCK ASSESSMENT HAD TO BE DONE IN RELATION TO THE COMPAN Y, THE ASSESSING OFFICER HAD TO (I) RECORD HIS SATISFACTION THAT ANY UNDISCLOSED INCOME BELONGED TO THE COMPANY, AND (II) HAND OVER THE BOO KS OF ACCOUNT AND OTHER DOCUMENTS AND ASSETS SEIZED TO THE ASSESSING OFFICER HAVING JURISDICTION OVER THE COMPANY. ITA NO.665(ASR)/2014 C.O.02(ASR)/2015 A.Y. 2009-10 6 10. THEN, THE HONBLE SUPREME COURT IN THE CASE OF M/S. CALCUTTA KNITWEARS IN CIVIL APPEAL NO.3958 OF 2014, VIDE JU DGMENT DATED 12.03.2014, HELD THAT FOR THE PURPOSES OF SECTION 1 58BD, RECORDING OF A SATISFACTION NOTE IS A PRE-REQUISITE AND THE SATISF ACTION NOTE MUST BE PREPARED BY THE AO BEFORE HE TRANSMITS THE RECORD T O THE OTHER AO, WHO HAS JURISDICTION OVER THE PERSON OTHER THAN THE PERSON SEARCHED UNDER SECTION 158BD OF THE ACT. 11. THE LD. CIT(A) FURTHER OBSERVED THAT THE SEARC H IN THIS CASE WAS CARRIED OUT IN THE CASE OF M/S PUNJAB IRON & STEEL COMPANY LTD. AND ALSO IN THE CASE OF ONE OF ITS DIRECTORS SH. RAMESH INDER SINGH, WHO IS THE FATHER OF THE ASSESSEE. IT IS AN UNDISPUTED POS ITION THAT THERE WAS NO SEARCH WARRANT IN THE CASE OF THIS ASSESSEE. THE AS SESSING OFFICER WAS THUS REQUIRED TO RECORD SATISFACTION IN VIEW OF THE DECISION OF THE SUPREME COURT IN THE CASE OF MANISH MAHERSHWARI VS . ACIT, REPORTED AT 289 ITR 341 (SC) IN THE CASE OF THE PERSON SEARCHED THAT CERTAIN DOCUMENTS HAVING IMPLICATION ON COMPUTATION OF INCO ME BELONG TO A PERSON OTHER THAN THE ONE SEARCHED AND ONLY THEREAF TER, THE PROCEEDINGS COULD COMMENCE IN THE CASE OF SUCH OTHER PERSON. IN THE PRESENT CASE, THE SATISFACTION HAS ONLY BEEN RECORDED IN THE CASE OF THE ASSESSEE HIMSELF, I.E., THE PERSON NOT SEARCHED OR, THE OTH ER PERSON. THE REQUIREMENT, AS MANDATED BY THE SUPREME COURT IN TH E CASE OF MANISH MAHESHWARI (SUPRA), HAS THUS NOT BEEN COMPLIED WIT H AND THE ITA NO.665(ASR)/2014 C.O.02(ASR)/2015 A.Y. 2009-10 7 PROCEEDINGS IN THE CASE OF THIS ASSESSEE ARE BAD IN LAW AND ORDER U/S 153C READ WITH 143(3) SHOULD BE QUASHED ON THIS SCO RE ITSELF. 12. FURTHER THE HONBLE SUPREME COURT, VIDE JUDGME NT DATED 12.03.2014, IN CIVIL APPEAL NO. 3958 OF 2014, IN TH E CASE OF M/S. CALCUTTA KNITWEARS, HAS MANDATED THE RECORDING OF SATISFACTION AND PREPARATION OF SATISFACTION NOTE BY THE AO OF THE P ERSON SEARCHED, NOTWITHSTANDING THE FACT THAT THE AO OF THE PERSON SEARCHED IS THE SAME AS THAT OF THE OTHER PERSON. 13. ALL THE OTHER DECISIONS CITED BY THE ASSESSEE A RE TO THE SAME EFFECT. 14. EVEN THE CBDT, KEEPING THE VARIOUS DECISIONS O F JUDICIAL AUTHORITIES, ISSUED CIRCULAR NO. 24 OF 2015, ACCEP TING THE DECISION OF THE SUPREME COURT IN THE CASE OF CIT-III VS. CALCUTTA KNITWEARS AND THOSE OF VARIOUS HIGH COURTS. IT WAS STATED THAT THE VIEW OF THE COURTS THAT THE PROVISIONS OF SECTION 153C ARE SUBSTANTIALLY SIMILA R/PARI-MATERIA TO THE PROVISIONS OF SECTION 158BD OF THE ACT HAD BEEN ACC EPTED. IT WAS CONCEDED THAT SATISFACTION HAS TO BE RECORDED EVEN IF THE A.O OF PERSON SEARCHED AND THE OTHER PERSON IS THE SAME. THE CI RCULAR CLARIFIES THAT IT WOULD BE APPLICABLE TO PENDING LITIGATION ALSO. 15. THIS CBDT CIRCULAR HAS BEEN CONSIDERED IN SHIE LD HOME PVT. LTD., BY THE ITAT DELHI, VIDE ORDER DATED 24.2.2016 (COPY AT APB 237 TO 239) AND HARDEVI KESHWANI, BY THE ITAT CHANDIGARH BEN CH, VIDE ORDER DATED 5.4.2016 (APB 240 TO 243). ITA NO.665(ASR)/2014 C.O.02(ASR)/2015 A.Y. 2009-10 8 16. THE SAID CBDT CIRCULAR HAS BEEN FILED BEFORE US ALSO. IT READS AS FOLLOWS: CBDT CIRCULAR NO.24/2015 F.NO.279/MISC./140/2015/ITJ GOVERNMENT OF INDIA MINISTRY OF FINANCE DEPARTMENT OF REVENUE CENTRAL BOARD OF DIRECT TAXES NEW DELHI, 31 ST DECEMBER, 2015 SUBJECT: RECORDING OF SATISFACTION NOTE UNDER SECTI ON 158BD 153C OF THE ACT - REG.- THE ISSUE OF RECORDING OF SATISFACTION FOR THE PURP OSES OF SECTION 158BD/153C HAS BEEN SUBJECT MATTER OF LITIGATION. 2. THE HONBLE SUPREME COURT IN THE CASE OF M/S CALCUTTA KNITWEARS IN ITS DETAILED JUDGMENT IN CIVIL APPEAL NO.3958 OF 2014 DATED 12.3.2014(AVAILABLE IN NJRS AT 2014-LL-0312-5 1) HAS LAID DOWN THAT FOR THE PURPOSE OF SECTION 158BD OF THE A CT, RECORDING OF A SATISFACTION NOTE IS A PREREQUISITE AND THE SATIS FACTION NOTE MUST BE PREPARED BY THE AO BEFORE HE TRANSMITS THE RECOR D TO THE OTHER AO WHO HAS JURISDICTION OVER SUCH OTHER PERSON U/S 158BD.J THE HONBLE COURT HELD THAT THE SATISFACTION NOTE COULD BE PREPARED AT ANY OF THE FOLLOWING STAGES: (A) AT THE TIME OF OR ALONG WITH THE INITIATION OF PROCEEDINGS AGAINST THE SEARCHED PERSON UNDER SECTION 158BC OF THE ACT; OR (B) IN THE COURSE OF THE ASSESSMENT PROCEEDINGS UND ER SECTION 158BC OF THE ACT; OR (C) IMMEDIATELY AFTER THE ASSESSMENT PROCEEDINGS AR E COMPLETED UNDER SECTION 158BC OF THE ACT OF THE SEARCHED PERS ON. 3. SEVERAL HIGH COURTS HAVE HELD THAT THE PR OVISIONS OF SECTION 153C OF THE ACT ARE SUBSTANTIALLY SIMIIAR/PARI-MATE RIA TO THE PROVISIONS OF SECTION 158BD OF THE ACT AND THEREFOR E, THE ABOVE GUIDELINES OF THE HONBLE SC, APPLY TO PROCEEDINGS U/S 153C OF THE IT ACT, FOR THE PURPOSES OF ASSESSMENT OF INCOME OF OTHER THAN THE SEARCHED PERSON. THIS VIEW HAS BEEN ACCEPTED BY CBD T. ITA NO.665(ASR)/2014 C.O.02(ASR)/2015 A.Y. 2009-10 9 4. THE GUIDELINES OF THE HONBLE SUPREME COUR T AS REFERRED TO IN PARA 2 ABOVE, WITH REGARD TO RECORDING OF SATISF ACTION NOTE, MAY BE BROUGHT TO THE NOTICE OF ALL FOR STRICT COMPLIAN CE. IT IS FURTHER CLARIFIED THAT EVEN IF THE AO OF THE SEARCHED PERSO N AND THE OTHER PERSON IS ONE AND THE SAME, THEN ALSO HE IS REQUIR ED TO RECORD HIS SATISFACTION AS HAS BEEN HELD BY THE COURTS. 5. IN VIEW OF THE ABOVE, FILING OF APPEALS ON THE I SSUE OF RECORDING OF SATISFACTION NOTE SHOULD ALSO BE DECID ED IN THE LIGHT OF THE ABOVE JUDGMENT. ACCORDINGLY, THE BOARD HEREBY D IRECTS THAT PENDING LITIGATION WITH REGARD TO RECORDING OF SATI SFACTION NOTE UNDER SECTION 158BD/153C SHOULD BE WITHDRAWN /NOT P RESSED IF IT DOES NOT MEET THE GUIDELINES LAID DOWN BY THE APEX COURT. 17. THUS, AS PER PARA 4 OF THE AFORESAID CBDT CIRCU LAR, EVEN IF THE AO OF THE SEARCHED PERSON AND THAT OF THE OTHER PERSO N IS ONE AND THE SAME, IT IS MANDATORY FOR HIM TO RECORD HIS SATISFA CTION. HENCE, THE LD. CIT(A)S OBSERVATION IN THIS REGARD IS UNSUSTAINAB LE. FURTHER, IN VIEW OF THE AFOREMENTIONED SETTLED LEGAL POSITION, THE DEF ECT IN QUESTION BEING A JURISDICTIONAL ONE, IT CANNOT GET CURED BY THE PROV ISIONS OF SECTION 292B OF THE ACT. 18. ACCORDINGLY, THE ORDER DATED 24.03.2014 PASSED UNDER SECTION 153C IS QUASHED. THE C.O. FILED BY THE ASSESSEE IS ACCEPTED. 19. SINCE WE HAVE DECIDED THE C.O. IN FAVOUR OF THE ASSESSEE, NOTHING ELSE SURVIVES FOR ADJUDICATION AND, THEREFORE, THE GROUNDS RAISED BY THE ITA NO.665(ASR)/2014 C.O.02(ASR)/2015 A.Y. 2009-10 10 DEPARTMENT DO NOT REQUIRE ANY ADJUDICATION AT OUR HANDS. THESE GROUNDS ARE REJECTED AS INFRUCTUOUS. 20. IN THE RESULT, THE APPEAL OF THE DEPARTMENT I S DISMISSED, WHEREAS THE C.O. OF THE ASSESSEE IS ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 13/0 6/ 2016. SD/- SD/- (T.S. KAPOOR) (A.D. JAIN) ACCOUNTANT MEMBER JUDICIAL MEMBER /SKR/ DATED: 13/06/2016 COPY OF THE ORDER FORWARDED TO: 1. THE ASSESSEE:SH. RIPAN DEEP TAKHAR, JALANDHAR. 2. THE ACIT, CC-I, JALANDHAR 3. THE CIT(A), JALANDHAR. 4. THE CIT, JALANDHAR. 5. THE SR DR, ITAT, AMRITSAR. TRUE COPY BY ORDER