M/S MANAGING COMMITTEE, KAPURTHALA V. COMMISSIONER OF INCOME TAX, (EXAMPTION), CHANDIGARH

ITA 678/ASR/2017

• Counselvise Citation: [2019] 116 COUNSELVISE.COM (IT) 9326 (ITAT-AMRITSAR)
• Duration Of Justice: 1 year(s) 7 month(s) 27 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 21-06-2019
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB
• Next Hearing Date: 20-05-2019
• Assessment Year: misc
• Appeal Filed On: 25-10-2017
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: DR DEVENDER SING H LD
• Section: 12AA; 12

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR BEFORE SH. N.S.SAINI, ACCOUNTANT MEMBER AND SH. N.K.CHOUDHRY, JUDICIAL MEMBER ITA NO.678(ASR)/2017 ASSESSMENT YEAR: 2017-18 MANAGING COMMITTEE, HINDU KANYA COLLEGE, AMRITSAR ROAD, KAPURTHALA. [PAN:AAAAH 7737C] VS. THE CIT (EXEMPTIONS), CHANDIGARH. (APPELLANT) (RESPONDENT) APPELLANT BY: SH. SUDHIR SEH GAL RESPONDENT BY: DR. DEVENDER SIN GH (LD. CIT-DR) DATE OF HEARING: 20/05/2019 DATE OF PRONOUNCEMENT: 21/06/2019 ORDER PER N.K.CHOUDHRY, JM: THIS APPEAL HAS BEEN PREFERRED BY THE ASSESSEE SOCIETY AGAINST THE ORDER IMPUGNED DATED 27.09.2017 PASSED BY THE LD. CIT(EXEMPTIONS), CHANDIGARH U/S 12AA (1)(B)(III) OF THE I.T. ACT, 1961 (HEREINAFTER CALLED AS THE ACT). 2. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE SOCIETY IS AN ONGOING ENTITY AND IS IN OPERATION SINCE 03/05/197 2 AND HAD APPLIED FOR REGISTRATION U/S 12AA OF THE ACT ON 06/03/ 2017 BEFORE THE LD. CIT(E), WHICH WAS TAKEN INTO CONSIDERAT ION BY THE LD. CIT(E) WHILE FIXING THE DATE OF HEARING ON 02/0 8/2017 AND THE APPLICANT SOCIETY WAS REQUESTED TO FILE CERTAIN DETAILS/CLARIFICATIONS ON OR BEFORE 17/08/2017 AS MEN TIONED IN ITA NO.678/ASR/2017 MANAGING COMMITTEE VS. CIT(E ) 2 PARA-5 OF THE IMPUGNED ORDER HEREIN. THE SAID NOTICE /QUERY WAS REPLIED BY THE APPELLANT SOCIETY ON DATED 17/08/2017 THEREAFTER THE APPLICATION OF THE ASSESSEE SOCIETY WAS REJECTED BY THE LD. CIT(E) WHILE OBSERVING AS UNDER: THE RESPONSE OF THE APPLICANT HAS BEEN EXAMINED THOROUGHLY. IT WAS CLAIMED THAT THE APPLICANT HINDU KANYA COLLEGE IS RUN BY THE SOCIETY MANAGING COMMITTEE, HIN DU KANYA COLLEGE, KAPURTHALA AND THAT THE SOCIETY HAS B EEN CREATED ON 03/05/1972 AND HAS NOT FILED ANY RETURN OF INCOME IN THE PAST. 3. THE ASSESSEE ON BEING AGGRIEVED PREFERRED THE INSTANT APPEAL AND IN ADDITION TO ARGUING THE CASE ALSO SUBMIT TED WRITTEN SUBMISSIONS TO THE SPECIFIC OBSERVATIONS OF THE WORTHY CIT(E ). OBSERVATION OF WORTHY CIT(EXEMPTION) SUBMISSIONS OF APPLICANT 1. IN PARA 1 AND 2 OF THE IMPUGNED ORDER, IT HAS BEEN MENTIONED THAT HINDU KANYA COLLEGE IS A APPLICANT WHICH IS RUN BY MANAGING COMMITTEE, HINDU KANYA COLLEGE AND ALSO IT HAS BEEN STATED THAT NO EVIDENCE OF MANAGING COMMITTEE REGISTERED AS SOCIETY HAS BEEN GIVEN BEEN GIVEN IN THIS REGARD, IT IS SUBMITTED THAT MANAGING COMMITTEE, HINDU KANYA COLLEGE AND HINDU KANYA COLLEGE IS ONE AND THE SAME THING. IT IS A SINGLE ASSESSEE WHOSE CORRECT NAME IS MANAGING COMMITTEE, HINDU KANYA COLLEGE. FURTHER, IT IS PERTINENT TO MENTION HERE THAT FORM NO.10A WAS ALSO FILED IN RESPECT OF MANAGING COMMITTEE, HINDU KANYA COLLEGE ONLY. (PAGE NO. 1- 3 OF THE PAPER BOOK. IT IS, FURTHER SUBMITTED THAT THE COPY OF REGISTRATION CERTIFICATE WAS DULY FILED BEFORE CIT(EXEMPTION) EVIDENCING THE REGISTRATION OF THE ASSESSEE SOCIETY AS MANAGING COMMITTEE, ITA NO.678/ASR/2017 MANAGING COMMITTEE VS. CIT(E ) 3 HINDU KANYA COLLEGE (AS EVIDENT FROM POINT NO. (III) OF REPLY PLACED AT PAGE 86 OF PAPER BOOK-II AND PAGE NO.4 OF THE PAPER BOOK-1 . 2. IT HAS BEEN STATED THAT THERE IS NO MEMORANDUM OF ASSOCIATION OF THE MANAGING COMMITTEE HAS BEEN FURNISHED. KINDLY REFER TO PAGE 5 - 10 OF THE PAPER BOOK PART-1 IN WHICH RULES AND REGULATION OF THE SAID SOCIETY HAS BEEN MENTIONED AND IN FACT, THE HINDU KANYA COLLEGE AND MANAGING COMMITTEE ARE ONE AND THE SAME THING. THEREFORE THIS FINDING OF THE CIT (EXEMPTION) IS NOT CORRECT. 3. NOT ONLY ARE THE CUMULATIVE RECEIPTS FAR IN EXCESS OF 1 CRORE BUT ALSO IN THE ABSENCE OF 10(23C)(VI) APPROVAL THE FACT OF NOT FILING RETURNS IS A POINTER TOWARDS A SERIOUS INFRACTION OF LAW WHICH SHALL BE SEEN BY THE ASSESSING OFFICER SEPARATELY. THIS OBSERVATION OF THE CIT IS NOT CORRECT BECAUSE FOR THE PURPOSES OF GRANTING 12AA ONLY TWO THINGS ARE TO BE SATISFIED I.E. OBJECTS OF THE SOCIETY AND GENUINENESS OF ACTIVITIES. THE OTHER ASPECTS ARE TO BE TAKEN INTO CONSIDERATION AT THE TIME OF FILING THE RETURN OF INCOME. THE SAME FINDING HAD BEEN APPROVED BY THE P&H-HC IN THE CASE OF JUDGMENT PLACED AT PAGES 1 TO 4 AND 5 TO 9 OF THE JUDGMENT SET ALREADY FILED. 4. THE FACT OF THE HINDU KANYA COOEGIATE SCHOOL ALSO BEING RUN BY THE COLLEGE (HAS BEEN CLAIMED) IS NOT BORNE BY EVIDENCES. THERE IS NO EVIDENCE PROVIDED IN RESPECT OF AFFILIATIONS GRANTED EITHER TO THE COLLEGE OR THE SCHOOL. IT REMAINS. TOTALLY UNCORROBORATED AS TO HOW THE SCHOOL (WHICH NORMALLY SHOULD BE A SEPARATE ENTITY GIVEN THE FACT THAT MANAGING COMMITTEE WAS FORMED FOR THE COLLEGE) CAN BE CLAIMED TO BE RUN BY A COLLEGE BOTH BEING SEPARATE ENTITIES CATERING TO DIFFERENT CATEGORIES OF STUDENTS. THE INCOME AND EXPENDITURE ACCOUNTS OF THE SCHOOL PROVIDED SEPARATELY POINTS TO TWO STARK PLEASE REFER TO PAGE 4 OF THE PAPER BOOK- 1 WHICH IS A CERTIFICATE OF REGISTRATION OF SOCIETY AND IT IS ALSO AFFILIATED TO PUNJAB SCHOOL BOARD AT PAGES 11-12 OF THE PAPER BOOK-1 AND FURTHER ALL THE QUERIES WHICH RAISED BY THE CIT IN PARA 5 HAVE BEEN REPLIED AS PER PARA 6 OF THE ORDER ANPK THEN THE BALANCE SHEET FOR DIFFERENT YEARS HAD BEEN FILED AND FOR WHICH HE HAS ONLY RAISED CERTAIN DOUBTS IN A GENERAL WAY WITHOUT SPECIFICALLY STATING ANYTHING AGAINST THE AIMS AND 'OBJECTS AND ACTIVITIES OF THE SOCIETY. THE JUDGMENTS OF P&H- HC AS CITED ABOVE WOULD APPLY. ITA NO.678/ASR/2017 MANAGING COMMITTEE VS. CIT(E ) 4 INCONSISTENCIES THAT GENERATE DOUBTS WITH REGARD TO THE VERACITY OF THE CLAIMS. 5. THERE IS NO AMOUNT DEBITED AS SALARIES. IT IS BEFUDDLING HOW IN THE ABSENCE OF TEACHERS A SCHOOL IS BEING RUN. THE SALARIES HAVE BEEN CLEARLY DEBITED IN ALL THE YEARS AND REFERENCE MAY BE MADE TO PAGE 15, 25 AND 42 OF THE PAPER BOOK- 1 AND BESIDES THE OTHER DETAILS AT PAGES 45 TO 51 OF THE PAPER BOOK-1. 6. THERE ARE LARGE SCALE TRANSFERS TO THE COLLEGE DEBITED AS EXPENDITURE. FOR E.G IN THE FY 2015-2016 IF RECEIPTS FROM FEES IS AROUND 74 LAKHS THE TRANSFER TO THE COLLEGE IS NEARLY 71 LAKHS. HOW A SCHOOL HAS THE ONLY SUBSTANTIAL EXPENSE IN THE SHAPE OF A TRANSFER TO A COLLEGE IS NOT UNDERSTOOD. PLEASE REFER TO PAGE 27 OF THE PAPR BOOK-1 AND THESE ARE ONLY TRANSFER ENTRIES FROM SCHOOL TO COLLEGE AND THE OBSERVATION OF THE CIT THAT THIS IS AN EXPENSE IS TOTALLY MISPLACED. 7. ALSO, THE RATIONALE FOR LARGE CREDITS IN THE MANAGEMENT ACCOUNT HAS ALSO NOT BEEN BROUGHT OUT. IT IS SEEN THAT THERE ARE LARGE SCALE TRANSFERS FROM AT LEAST THREE ACCOUNTS NAMELY THE COLLEGE ACCOUNT, THE SCHOOL ACCOUNT AND THE GRANTS ACCOUNT IN THE SHAPE OF 5% SHARE OF MANAGEMENT. THE RATIONALE FOR THE SAME HAS NOT BEEN BROUGHT OUT. FURTHER, THE GRANT ACCOUNT REVEALS LOANS IN ITS BALANCE SHEET (WHY A GRANTS ACCOUNT HAS A SEPARATE BALANCE SHEET IS AGAIN UNCLEAR) FROM BOTH THE SCHOOL AND THE COLLEGE. THIS FINDING OF THE CIT (EXEMPTION) IS AGAIN NOT RELEVANT TO THE GRANT OF REGISTRATION U/S 12AA. 8. NO CONSOLIDATED PICTURE EMERGES ABOUT THE MANAGING COMMITTEE THE COLLEGE AND THE SCHOOL WHO RUNS WHOM IS ALSO NOT BROUGHT OUT. THE EXISTENCE OF THE SCHOOL PER SE IS DOUBTFUL IN THE WAKE OF ABSENCE OF ANY SALARY BEING PAID TO ANYONE. PLEASE REFER TO THE RULES AND REGULATIONS OF THE SOCIETY WHICH HAS BEEN PLACED AT PAGE 6 TO 10 OF THE PAPER BOOK-1 AND THE OBSERVATION OF THE CIT (EXEMPTION) IS NOT CORRECT AND FURTHER ABOUT ABSENCE OF SCRUTINY BY THE DEPARTMENT IN THE PAST IS NO FAULT OF THE ASSESSEE. ITA NO.678/ASR/2017 MANAGING COMMITTEE VS. CIT(E ) 5 9. THERE IS NO EVIDENCE PROVIDED OF THE COLLEGE BEING REGISTERED AS A SOCIETY OR TRUST (NO REGISTRATION CERTIFICATE FROM THE REGISTRAR OF SOCIETIES HAS BEEN APPENDED EITHER IN THE CASE OF THE COLLEGE OR THE SCHOOL OR THE MANAGING COMMITTEE). THE PAPERS IN RESPECT OF THE MANAGING COMMITTEE ARE ALSO INCOMPLETE IN THE ABSENCE OF MEMORANDUM OF ASSOCIATION. IN VIEW OF ALL THE ABOVE, THE APPLICATION FOR GRANT OF REGISTRATION U/S 12AA IS REJECTED. THE CERTIFICATION OF REGISTRATION IS FILED WHICH THERE ARE AT PAGE 4 MEMORANDUM OF ASSOCIATION IS ALSO THERE AND THERE ARE MANY JUDGMENTS WHICH ARE BEING RELIED UPON. 3.1 FIRST OBJECTION BY THE LD. CIT(E) FOR REJECTION O F THE APPLICATION THAT HINDU KANYA VIDALAYA THAT NO EVIDENCE OF MANAGING COMMITTEE REGISTERED AS SOCIETY HAS BEEN GIVEN . IN RESPONSE TO THIS, IT WAS CLAIMED BY THE ASSESSEE SOCIETY THA T MANAGING COMMITTEE, HINDU KANYA COLLEGE AND HINDU KA NYA COLLEGE IS ONE AND THE SAME THING. IT IS A SINGLE ASSESSEE WHOSE CORRECT NAME IS MANAGING COMMITTEE, HINDU KANYA COLLEGE . THE LD. AR ALSO DRAWN OUR ATTENTION TO THE REGISTRATION C ERTIFICATE NO.34/1972 (PAGE NO.4 OF THE PB) ISSUED ON 3 RD MAY,1972 WHEREIN THE NAME OF THE ASSESSEE SOCIETY HAS BEEN WRITTEN AS MANAGING COMMITTEE, HINDU KANYA COLLEGE, KAPURTHALA , HOWEVER FROM FROM NO.10A IT REFLECTS THAT THE THE NA ME OF THE TRUST/INSTITUTION IN FULL HAS BEEN WRITTEN AS HINDU KANYA COLLEGE AND FROM MEMORANDUM OF ASSOCIATION ALSO NAME OF SOCIETY REFLECT AS HINDU KANYA COLLEGE , HENCE IN OUR CONSIDERED VIEW, IT WOULD BE APPROPRIATE FOR PROPER ADJUDICATION OF THE CASE THAT THE APPLICANT SOCIETY SHALL MAKE THE A PPROPRIATE AMENDMENT IN THE APPLICANT QUA NAME OF THE APPLICANT SOCIETY SUBJECT TO THE SATISFACTION OF THE LD. CIT(E), IF REQUIR ED IF ANY. ITA NO.678/ASR/2017 MANAGING COMMITTEE VS. CIT(E ) 6 3.2 THE SECOND OBJECTION RELATES TO NOT FILING THE RETU RN OF INCOME PRIOR TO F.Y.2016-17 WHICH HAS BEEN OBSERVED BY THE LD. CIT(E) SUFFERS FROM A SERIOUS INFRACTION. FURTHER THE LD. CIT(E) ALSO OBSERVED THAT NOT ONLY ARE THE CUMULATIVE RECEIPTS FAR IN EXCESS OF 1 CRORE BUT ALSO IN THE ABSENCE OF 10(23C)(VI) APPROVAL THE FACT OF NOT FILING RETURNS IS A POINTER TOWARDS A S ERIOUS INFRACTION OF LAW WHICH SHALL BE SEEN BY THE ASSESSING OFFI CER SEPARATELY. IT WAS FURTHER OBSERVED BY THE LD. CIT(E) THAT THE ACTIVITIES OF THE APPLICANT GET SEVERELY MUDDLED BY SEV ERAL INTER- UNIT TRANSFERS WHOSE RATIONALE HAS NOT BEEN BROUGHT OUT . IT IS A WELL SETTLED LAW THAT THE LD. CIT (E) WHILE CONSIDERI NG THE APPLICATION U/S 12AA OF THE ACT IS NOT SUPPOSED TO ACT L IKE AN ASSESSING OFFICER BUT ONLY HAS TO SEE THE CRITERIA SET OUT IN THE PROVISIONS I.E. SEC.11 & 12 OF THE ACT, HENCE IN OUR CONSID ERED VIEW THIS GROUND OF REJECTION IS UN-SUSTAINABLE . 3.3 NEXT GROUND OF REJECTION RELATES TO THE NON-PROVI DING OF EVIDENCE IN RESPECT OF AFFILIATION GRANTED EITHER TO T HE COLLEGE OR THE SCHOOL. THEREFORE IT REMAIN TOTALLY UN-CORROBORATE AS TO HOW THE SCHOOL CAN BE CLAIMED BE RUN BY AN COLLEGE BOTH BEIN G SEPARATE ENTITIES CATERING TO DIFFERENT CATEGORIES OF STUDENTS. IT WAS FURTHER OBSERVED BY THE LD. CIT(E) THAT INCOME AND EXPENDITURE ACCOUNTS OF THE SCHOOL THAT SEPARATE INCOME AN D EXPENDITURE ACCOUNTS IN THE SCHOOL PROVIDED SEPARATELY PO INTS TO TWO STARK INCONSISTENCIES THAT GENERATE DOUBTS WITH RESPEC T TO THE VERACITY OF THE CLAIMS. OUR ATTENTION WAS DRAWN BY THE LD. AR TO THE CERTIFICATE OF REGISTRATION OF SOCIETY (PAGE 4 OF PB) AND AFFILIATION WITH PUNJAB SCHOOL BOARD (PAGE NO.11&12 OF PB) AND THE BALANCE SHEET IN DIFFERENT YEARS WHICH STRENGTHEN TH E CLAIM ITA NO.678/ASR/2017 MANAGING COMMITTEE VS. CIT(E ) 7 OF THE APPLICANT SOCIETY. HENCE IN OUR CONSIDERED VIEW TH IS GROUND OF REJECTION IS ALSO NOT SUSTAINABLE. 3.4 NEXT GROUND OF REJECTION WHEREBY THE LD. CIT(E) HAS OBSERVED THAT THERE IS NO AMOUNT DEBITED AS SALARIES. I T IS BEFUDDLING HOW IN THE ABSENCE OF TEACHERS A SCHOOL IS BEI NG RUN. IN RESPONSE TO THIS OBJECTION, OUR ATTENTION WAS DRAWN B Y THE LD. AR TO (PAGE NO.15, 25 AND 42 OF THE PB-1) (45 TO 61 OF THE PB- 1) WHEREFROM IT IS CLEAR THAT THE ASSESSEE SOCIETY IS P AYING SALARIES TO THE TEACHING AND NON TEACHING STAFF, HENCE TH IS OBJECTION ALSO UN-SUSTAINABLE . 3.5 THE LD. CIT(E) ALSO OBSERVED THAT THERE IS LARGE SCALE TRANSFER TO THE COLLEGE, DEBITED AS EXPENDITURE. FOR E XAMPLE IN THE FINANCIAL YEAR: 2015-16, IF RECEIPTS FROM FEES ARE AROUND 74 LACS, THE TRANSFER TO THE COLLEGE IS NEARLY 71 LACS. HOW A SCHOOL HAS THE ONLY SUBSTANTIAL EXPENSE IN THE SHAPE OF A TRA NSFER TO A COLLEGE IS NOT UNDERSTOOD. AS WE HAVE ALREADY OBSERVED THAT LD. CIT(E) AT THE TIME OF CONSIDERING THE APPLICATION U/S 1 2AA IS NOT SUPPOSED TO ACT LIKE AN ASSESSING OFFICER AND IT IS IN THE D OMAIN AND WISDOM OF ASSESSING OFFICER NOT TO GRANT THE BENEFIT OF REGISTRATION IN CASE OF ANY DISCREPANCIES AND/OR NOT FOLL OWING THE RELEVANT PROVISIONS OF LAW APPLICABLE THERETO, EVEN OT HERWISE THE ENTRIES AS OBSERVED BY THE LD. CIT(E) ARE ONLY TRANSFER ENTRIES FROM SCHOOL TO COLLEGE AND THEREFORE IT CANNOT BE TERME D AS EXPENSES. 3.6 IT WAS FURTHER OBSERVED BY THE LD. CIT(E) THE RAT IONALE FOR LARGE CREDITS IN THE MANAGEMENT ACCOUNT HAS ALSO NOT BE EN BROUGHT OUT. IT IS SEEN THAT THERE IS LARGE SCALE TRANSF ER FROM AT ITA NO.678/ASR/2017 MANAGING COMMITTEE VS. CIT(E ) 8 LEAST THREE ACCOUNTS NAMELY THE COLLEGE ACCOUNT, THE SCHOOL ACCOUNT AND THE GRANTS ACCOUNT IN THE SHAPE OF 5% SHARE OF MANAGEMENT. AGAIN WE ARE REMINDING THAT THE ASSESSING O FFICER SHALL BE AT LIBERTY TO EXAMINE THE BALANCE SHEETS AND CO MPLETE DETAILS QUA FINANCIAL TRANSACTIONS OF THE ASSESSEE SOCIETY THEREFORE THIS GROUND IS ALSO NOT SUSTAINABLE. 3.7 THE LD. CIT(E) FURTHER OBSERVED THAT NO CONSOLIDAT ED PICTURE EMERGES ABOUT THE MANAGING COMMITTEE, THE COL LEGE AND THE SCHOOL. THE EXISTENCE OF THE SCHOOL PER SE IS DOUBTFUL IN THE WAKE OF ABSENCE OF ANY SALARY BEING PAID TO ANYONE. AS WE HAVE ALREADY REFERRED THE RELEVANT PAGES NUMBERS 15 AND 45 TO 51 WHEREFROM IT IS CLEARLY REFLECTS THE NAME OF THE TEACHI NG AND NON TEACHING STAFF AND SALARY PAID TO THEM THEREFORE THIS OBJECTION IS ALSO BASELESS. 3.8 THE LD. CIT(E) ALSO OBSERVED IN LAST PARA THAT THE RE IS NO EVIDENCE PROVIDED OF THE COLLEGE BEING REGISTERED AS SOC IETY OR TRUST NO REGISTRATION CERTIFICATE FROM THE REGISTRAR OF SOCIETY HAS BEEN APPENDED EITHER IN THE CASE OF THE COLLEGE OR SCHOO L OR THE MANAGEMENT COMMITTEE. THE PAPERS IN RESPECT OF MANAGING COMMITTEE ARE ALSO INCOMPLETE IN THE ABSENCE OF MOA. I T IS CLEARLY REFLECTS FROM THE RELEVANT DOCUMENTS AVAILABLE O N RECORD, SPECIFICALLY THE PAGE NO. 4 WHICH IS CERTIFICATE OF REGISTR ATION OF THE SOCIETY AND PAGE NO.5 TO 10 COPY OF THE MOA OF SOCIE TY WITH AIMS AND OBJECTS OF THE SOCIETY, HENCE, THIS OBJECTION IS AL SO CONTRARY TO FACTS AND MATERIAL AVAILABLE ON RECORD . 3.9 BY TAKING INTO CONSIDERATION OVERALL FACTS AND CIRCUMSTANCES AND DOCUMENTS, WE FEEL IT APPROPRIATE TO REM AND ITA NO.678/ASR/2017 MANAGING COMMITTEE VS. CIT(E ) 9 THIS CASE TO THE FILE OF THE LD. CIT(E) TO DECIDE AFRESH WHILE CONSIDERING THE ANALYZATION/OBSERVATIONS MADE ABOVE WIT HIN TWO MONTHS FROM THE RECEIPT OF THE ORDER . THE ASSESSEE SOCIE TY SHALL CLARIFY AND/OR MODIFY/RECTIFY THE NAME OF THE A PPLICANT SOCIETY TO THE SATISFACTION OF THE LD. CIT(E) , REQUIRED IF ANY AS PER LAW. 4. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE/APPELLA NT STANDS ALLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 21.06.2019. SD/- SD/- (N.S.SAINI) (N.K.CHOUDHRY) ACCOUNTANT MEMBER JUD ICIAL MEMBER DATED: 21.06.2019 /PK/ PS. COPY OF THE ORDER FORWARDED TO: (1) MANAGING COMMITTEE, HINDU KANYA COLLEGE, AMRITSAR ROAD, KAPURTHALA. (2) THE CIT(EXEMPTIONS), CHANDIGARH. (3) THE SR DR, I.T.A.T., AMRITSAR TRUE COPY BY ORDER