ITO WARD 2(1)(1) AHMEDABAD, AHMEDABAD V. ILESH INFRACAP PRIVATE LIMITED, AHMEDABAD

ITA 2115/AHD/2024

AI Insights

The case involves two appeals by the Revenue against Ilesh Infracap Private Limited concerning the assessment years 2014-15 and 2015-16. The core issue was the validity of reassessment notices issued under Section 148 of the Income Tax Act, which were challenged as being time-barred. The Tribunal examined the timeline of events, including the issuance of initial notices, compliance by the assessee, and subsequent actions by the Assessing Officer. The Tribunal's decision was heavily influenced by the Supreme Court's directives in the cases of Ashish Agarwal and Rajeev Bansal, which clarified the procedural requirements and time limits for issuing reassessment notices under the new regime following the amendment by the Finance Act 2021.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 789111 (ITAT-AHMEDABAD)
• Duration Of Justice: 11 month(s) 9 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 25-11-2025
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Assessment Year: misc
• Appeal Filed On: 16-12-2024
• Other Referred Cases: Ashish Agarwal vs. Union of India, Union of India vs. Rajeev Bansal
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: R. P. RASTOGI; ABHIJIT
• Assessee Lawyers: ASEEM THAKKAR
• Keywords: Set aside; Invalid notice; Period of limitation; Accommodation entries; Time period of passing order; Bogus
• Section: 147; 148

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “B” BENCH, AHMEDABAD BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND SHRI NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER ITA Nos.2114 & 2115/Ahd/2024 Assessment Years: 2014-15 & 2015-16 Income Tax Officer, Ward – 2(1)(1), Aayakar Bhawan, Vejalpur, 100 Ft. Anandnagar Road, Ahmedabad – 380 015. (Gujarat). Vs. Ilesh Infracap Private Limited, House No.1, Sigma Commerzone, Near Gallops Mall, ISCON Cross Road, S.G. Highway, Ahmedabad – 380 015. (Gujarat). [PAN – AABCI 7211 H] (Appellant) (Respondent) Assessee by Shri Aseem Thakkar, AR Revenue by Shri R.P. Rastogi, CIT-DR & Shri Abhijit, Sr. DR Date of Hearing 06.10.2025 Date of Pronouncement 25.11.2025 O R D E R PER NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER: These two appeals are filed by the Revenue against the separate orders of the National Faceless Appeal Centre (NFAC), Delhi (in short “the CIT(A)”), both dated 27.10.2024, for the Assessment Years (A.Y.) 2014- 15 & 2015-16 in the proceedings under Section 147 r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’). 2. As the facts involved in these two cases are identical, both the matters were heard together and are being disposed of vide this common Printed from counselvise.com ITA Nos.2114 & 2115/Ahd/2024 (Assessment Years: 2014-15 & 2015-16) ITO vs. Ilesh Infracap Private Limited Page 2 of 13 order for the sake of convenience. We will first take up the appeal of the Revenue for the A.Y. 2014-15. ITA No.2114/Ahd/2024 for A.Y. 2014-15 3. The brief facts of the case are that the assessee had filed its return of income for the A.Y. 2014-15 on 02.08.2022 declaring Nil income. The case of the assessee was reopened vide issue of notice u/s 148 of the Act dated 30.06.2021, to examine the credit entries of Rs.4,34,67,000/- appearing in the bank account of the assessee with IDBI Bank. The assessee had approached the Hon’ble Gujarat High Court against the said notice u/s 148 of the Act, which was quashed by the Hon’ble High Court. Thereafter, the Department in consequence to the direction of the Hon’ble Supreme Court in the case of Ashish Agarwal and others that the notice u/s 148 of the Act issued under the old provisions shall be treated as show cause notice in terms of Section 148A(b) of the Act, had acted further. The Assessing Officer had issued a notice u/s 148A(b) of the Act on 24.05.2022 which was complied by the assessee. Thereafter, a fresh notice u/s 148 of the Act was issued by the Assessing Officer on 27.07.2022, after passing an order u/s 148A(d) of the Act on the same day. In the course of assessment proceeding, the Assessing Officer had treated the entire credit entries appearing in the bank account of the assessee as unexplained and completed the assessment u/s 147 r.w.s. 144B of the Act on 29.05.2023 at total income of Rs.4,34,67,000/-. 4. Aggrieved with the order of the Assessing Officer, the assessee had filed an appeal before the First Appellate Authority which was decided by Printed from counselvise.com ITA Nos.2114 & 2115/Ahd/2024 (Assessment Years: 2014-15 & 2015-16) ITO vs. Ilesh Infracap Private Limited Page 3 of 13 the Ld. CIT(A) vide the impugned order and the addition made by the Assessing Officer was deleted. 5. Now, the Revenue is in appeal before us. The following grounds have been taken in this appeal: - “1. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the addition of Rs.4,34,67,000/- on account of unexplained money u/s.69A of the Act, without appreciating the facts of the case? 2. Whether on the facts and in the circumstances of the case and in law, the Id. CIT(A) has erred in ignoring the fact that the assessee engaged into transaction with entities which are bogus and are facilitators of accommodation entries? 3. The appellant craves leave to amend or alter any ground or add a new ground, which may be necessary. 4. It is, therefore, prayed that the order of Ld. CIT(A) may be set aside and that of the Assessing Officer be restored?” Application under Rule 27 by the Assessee 6. The assessee has filed an application under Rule 27 of the Income Tax (Appellate Tribunal) Rules, 1963. Shri Aseem Thakkar, Ld. AR of the assessee, explained that the assessee had raised a legal ground against the reopening of the case u/s 147 of the Act before the Ld. CIT(A), which was dismissed. He submitted that the assessee is entitled to support the order on the ground decided against him and accordingly the assessee had raised the issue that the notice u/s 148 of the Act issued by the Assessing Officer was time barred. Considering the fact that the legality of the notice issued u/s 148 of the Act goes to the root of the matter of jurisdiction, we deem it proper to first examine the issue raised by the assessee under Rule 27 of the Income Tax (Appellate Tribunal) Rules. Printed from counselvise.com ITA Nos.2114 & 2115/Ahd/2024 (Assessment Years: 2014-15 & 2015-16) ITO vs. Ilesh Infracap Private Limited Page 4 of 13 7. The Ld. AR submitted that the initial notice u/s 148 of the Act was issued on 30.06.2021, which was within the extended time limit as per Taxation and Other Laws Ordnance, 2020 (TOLA). As per the decision of Hon’ble Supreme Court in the case of Union of India vs. Ashish Agarwal (2023) (1 SSC 617), all the notices issued u/s 148 of the Act during the period from 01.04.2021 to 30.06.2021, were deemed to be notice issued u/s 148A(b) of the Act, as amended by the Finance Act 2021. Further, directions were issued to supply the materials within 30 days and grant further 15 days’ time to the assessee to reply to such notice before passing the order u/s 148A(d) of the Act. The Ld. AR explained that in the present case, the assessee was supplied materials on 31.05.2022 in terms of Section 148A(b) of the Act to which the assessee had submitted reply on 07.06.2022. Thereafter, the order u/s 148A(d) of the Act was passed by the Assessing Officer on 27.07.2022. According to the assessee, this order u/s 148A(d) of the Act and the fresh notice u/s 148 of the Act issued on 27.07.2022, were barred by limitation. 7.1 The Ld. AR explained that as per the decision of Hon’ble Supreme Court in the case of Union of India vs. Rajeev Bansal (2024) 167 taxmann.com 70 (SC), the order u/s 148A(d) of the Act was required to be passed and notice u/s 148 of the Act under the new regime was required to be issued within the time limit surviving under the Income Tax Act read with TOLA. He explained that since the original notice u/s 148 of the Act was issued on 30.06.2021, the Assessing Officer had only one-day surviving limit under the Income Tax Act read with TOLA. Therefore, new notice u/s 148 of the Act was required to be issued within one day, which was extended to 7 days, from the date of response of the assessee to the notice u/s 148A(b) of the Act. The Ld. AR submitted that Printed from counselvise.com ITA Nos.2114 & 2115/Ahd/2024 (Assessment Years: 2014-15 & 2015-16) ITO vs. Ilesh Infracap Private Limited Page 5 of 13 as the notice u/s 148 of the Act was issued in this case beyond the time limit surviving under the Income Tax Act read with TOLA, the same was barred by limitation. 8. Per contra, Shri Abhijit, Ld. Sr. DR relied upon the orders of the lower authorities. He submitted that as per provision of section 148A(d) of the Act, the AO was required to pass the order under that section within a period of one month from the end of the month in which the reply of the assessee to the show cause notice u/s 148A(b) of the Act, was received. The Ld. Sr. DR explained that the order u/s 148A(d) passed in this case was within the time limit as prescribed under the Act and the notice u/s 148 of the Act was also issued within the time period. Therefore, there was no infirmity with the notice of the AO. 9. We have carefully considered the rival submissions. It will be relevant to tabulate the chronology of the events in the present case, which is as under: - Date Event 30.06.2021 Notice issued u/s.148 of the Act 28.08.2021 Return filed in response to the notice u/s.148 13.10.2021 Letter of request made for providing reasons for reopening of the assessment 07.12.2021 Stay order of the Hon’ble Gujrat High Court in WP No.18208/2021 06.05.2022 Final Order of the Hon’ble Gujarat High Court in WP No.18208/2021 31.05.2022 Notice issued u/s.148A(b) of the Act 07.06.2022 Reply to notice u/s.148A(b) of the Act 27.07.2022 Order passed u/s.148A(d) of the Act 27.07.2022 Notice issued u/s.148 of the Act Printed from counselvise.com ITA Nos.2114 & 2115/Ahd/2024 (Assessment Years: 2014-15 & 2015-16) ITO vs. Ilesh Infracap Private Limited Page 6 of 13 10. The contention of the assessee is that the Assessing Officer was required to pass order under Section 148A(d) of the Act and also issue notice under Section 148 of the Act within the surviving period of one day (which was extended to seven days) of filing its reply on 07.06.2022. Thus, the Assessing Officer had time limit till 14.06.2022 only to take these actions. However, the order under Section 148A(d) of the Act and the notice under Section 148 of the Act was issued on 27.07.2022 i.e. beyond the period of seven days from its reply on 07.06.2022 and thus the notice was barred by limitation. 11. The Hon’ble Supreme Court, in the case of Ashish Agarwal (supra), had directed that all the notices u/s 148 of the Act issued under the old provision shall be treated as show cause notice issued u/s 148A(b) of the Act of the new provisions. Further, the Hon’ble Court had directed the assessing officers to supply the assesses with the relevant material and information relied upon by the Revenue within thirty days from the date of the judgment. The effect of this direction was summarized by the Apex Court in the case of Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) as under: 106. …..To summarize, the combined effect of the legal fiction and the directions issued by this Court in Ashish Agarwal (supra) is that the show cause notices that were deemed to have been issued during the period between 1 April 2021 and 30 June 2021 were stayed till the date of supply of the relevant information and material by the assessing officer to the assessee. After the supply of the relevant material and information to the assessee, time begins to run for the assesses to respond to the show cause notices. [Emphasis supplied.] 12. The interplay of the directions in the case of Ashish Agrawal with TOLA was examined by the Hon’ble Supreme Court in the case of Rajeev Bansal (supra). The Hon’ble Court had held that only the time surviving Printed from counselvise.com ITA Nos.2114 & 2115/Ahd/2024 (Assessment Years: 2014-15 & 2015-16) ITO vs. Ilesh Infracap Private Limited Page 7 of 13 under the Income Tax Act read with TOLA will be available to the Revenue to complete the remaining proceedings in furtherance of such deemed notice, including issuance of notice u/s 148 of the new regime. The surviving or balance time limit was required to be calculated by computing the number of days between the date of issuance of deemed notice and 30th June, 2021. The reasoning and the relevant part of the judgement of the Court is as under: 110. The effect of the creation of the legal fiction in Ashish Agarwal (supra) was that it stopped the clock of limitation with effect from the date of issuance of Section 148 notices under the old regime [which is also the date of issuance of the deemed notices]. As discussed in the preceding segments of this judgment, the period from the date of the issuance of the deemed notices till the supply of relevant information and material by the assessing officers to the assesses in terms of the directions issued by this Court in Ashish Agarwal (supra) has to be excluded from the computation of the period of limitation. Moreover, the period of two weeks granted to the assesses to reply to the show cause notices must also be excluded in terms of the third proviso to Section 149. 111. The clock started ticking for the Revenue only after it received the response of the assesses to the show causes notices. After the receipt of the reply, the assessing officer had to perform the following responsibilities: (i) consider the reply of the assessee under Section 149A(c); (ii) take a decision under Section 149A(d) based on the available material and the reply of the assessee; and (iii) issue a notice under Section 148 if it was a fit case for reassessment. Once the clock started ticking, the assessing officer was required to complete these procedures within the surviving time limit. The surviving time limit, as prescribed under the Income Tax Act read with TOLA, was available to the assessing officers to issue the reassessment notices under Section 148 of the new regime. 112. Let us take the instance of a notice issued on 1 May 2021 under the old regime for a relevant assessment year. Because of the legal fiction, the deemed show cause notices will also come into effect from 1 May 2021. After accounting for all the exclusions, the assessing officer will have sixty-one days [days between 1 May 2021 and 30 June 2021] to issue a notice under Section 148 of the new regime. This time starts ticking for the assessing officer after receiving the response of the assessee. In this instance, if the assessee submits the response on 18 June 2022, the assessing officer will have sixty-one days from 18 June 2022 to issue a reassessment notice under Section 148 of the new regime. Thus, in this illustration, the time limit for issuance of a notice under Section 148 of the new regime will end on 18 August 2022. Printed from counselvise.com ITA Nos.2114 & 2115/Ahd/2024 (Assessment Years: 2014-15 & 2015-16) ITO vs. Ilesh Infracap Private Limited Page 8 of 13 113. In Ashish Agarwal (supra), this Court allowed the assesses to avail all the defences, including the defence of expiry of the time limit specified under Section 149(1). In the instant appeals, the reassessment notices pertain to the assessment years 2013-2014, 2014-2015, 2015-2016, 2016-2017, and 2017-2018. To assume jurisdiction to issue notices under Section 148 with respect to the relevant assessment years, an assessing officer has to: (i) issue the notices within the period prescribed under Section 149(1) of the new regime read with TOLA; and (ii) obtain the previous approval of the authority specified under Section 151. A notice issued without complying with the preconditions is invalid as it affects the jurisdiction of the assessing officer. Therefore, the reassessment notices issued under Section 148 of the new regime, which are in pursuance of the deemed notices, ought to be issued within the time limit surviving under the Income Tax Act read with TOLA. A reassessment notice issued beyond the surviving time limit will be time-barred. [Emphasis supplied.] 13. The Hon’ble Supreme Court had thus categorically held that the assessing officers were required to issue the reassessment notice under Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA and that all notices issued beyond the surviving period were time barred and liable to be set aside. This time-line was also demonstrated in para 112 of the order with an illustration. In the present case, the original notice u/s 148 of the Act was issued on 30.06.2021 which was treated as deemed notice u/s 148A(b) of the Act. Since this notice was issued on 30.06.2021, the surviving time period available to the Assessing Officer to complete the further proceedings, including the issue of notice u/s 148 of the Act, was one day only, which was extended to seven days. Accordingly, the Assessing Officer was required to pass the order a u/s 148A(d) of the Act and also to issue notice u/s 148 of the Act in this case within a period of seven days from the date of receipt of reply of the assessee. As the assessee had filed its reply on 07.06.2022, the time limit available to the Assessing Officer to issue the notice u/s 148 of the Act was till 14.06.2022 only. As the notice in the present case was issued Printed from counselvise.com ITA Nos.2114 & 2115/Ahd/2024 (Assessment Years: 2014-15 & 2015-16) ITO vs. Ilesh Infracap Private Limited Page 9 of 13 on 27.07.2022, the same is found to be beyond the limitation period. In view of the explicit direction of the Hon’ble Supreme Court to complete the remaining proceedings within the surviving or balance time period, the provision of section 148A(d) of the Act was overridden to that effect. 14. The Hon’ble Supreme Court in the case of Rajeev Bansal (supra) had examined the scope of Article 142 and observed as under: 82. Article 142 empowers this Court to pass such decree or make such order as is necessary for doing complete justice in any cause or matter pending before it. The discretionary jurisdiction exercised by this Court under Article 142 is of the widest amplitude. The Constitution has left it to the judicial discretion of this Court to decide the scope and limits of its jurisdiction to render substantial justice in matters coming before it. The expression “any cause or matter” mentioned under Article 142 includes every kind of proceeding pending before this Court. Article 142 allows this Court to give precedence to equity over law, provided the exercise of the discretion is consistent with constitutional provisions and after due consideration of substantive provisions in statutory law. The Hon’ble Court further held that the exercise of the jurisdiction under Article 142 is meant to supplement the existing legal framework to do complete justice between the parties. Further that in a given circumstance, the Apex Court can supplement a legal framework to craft a just outcome when strict adherence to a source of law and exclusive rule-based theories creates inequitable results. Therefore, the law as declared by the Supreme Court in the case of Rajeev Bansal (supra) overrides the provisions of section 148A(d) of the Act and the Revenue had surviving time period only to complete the remaining proceedings u/s 148A(d) of the Act and to issue notice u/s 148 of the Act as per new provisions. Printed from counselvise.com ITA Nos.2114 & 2115/Ahd/2024 (Assessment Years: 2014-15 & 2015-16) ITO vs. Ilesh Infracap Private Limited Page 10 of 13 15. It is found that identical issue was decided by the Hon’ble Gujarat High Court in the case of Dhanraj Govindram Kella [2025] 177 taxmann.com 194 (Gujarat). The findings given by the Hon’ble Court on this issue are reproduced below: 65. The alternative contention of the petitioner as to whether notices would be valid notice or invalid notice considering 'surviving time' between the date of the issuance of notices under TOLA and 30th June, 2021 or not is required to be considered and for that each matter has to be considered separately on the basis of the facts of case considering the date of issuance of notices under section 148 under TOLA by the Revenue and thereafter date of supplying information to the assessee and date of passing of order under section 148A(d) and date of issuance of notice under section 148 of the Act so as to consider whether issuance of notice under section 148 of the Act is within 'surviving time' as per the direction of Hon'ble Apex Court in case of Rajeev Bansal (supra) or not. 66. So far as Assessment Years 2013-2014 and 2014-2015 are concerned, the period of three years from the end of the assessment year would be over prior to 20.03.2020 and the period of six years would be over between 20.03.2020 and 30.06.2021. Therefore, the notices issued under section 148 of the Act under old regime between 01.04.2021 and 30.06.2021 as per TOLA, will be a valid notice if the notice under section 148 of the Act under new regime is issued within the period of 'surviving time' as per the directions issued by Hon'ble Apex Court in case of Rajeev Bansal (supra). For the Assessment Years 2016-2017 and 2017-2018 are concerned, the notice issued under section 148 of the Act under old regime between 01.04.2021 and 30.06.2021 under TOLA would be considered to be issued within three years from the end of the relevant assessment year as three years would complete within the period of 20.03.2020 and 30.06.2021. 67. Therefore, in facts of these petitions, following data is required to be considered to find out 'surviving time' to decide as to whether the impugned notices under section 148 of the Act issued under the new regime as per the decision of Hon'ble Apex Court in case of Ashish Agarwal (supra) would be valid notice or not in view of the decision of the Hon'ble Apex Court in case of Rajeev Bansal (supra): SCA NO AY Date of notice under section 148 under TOLA No of days of surviving time available till 30.06.2021 Date of providing information under section 148A(b) 6387/2023 2013-2014 17.06.2021 13 26.05.2022 5688/2023 2014-2015 09.06.2021 21 23.05.2022 22260/2022 2016-2017 30.06.2021 1 23.05.2022 996/2023 2017-2018 30.06.2021 1 24.05.2022 Printed from counselvise.com ITA Nos.2114 & 2115/Ahd/2024 (Assessment Years: 2014-15 & 2015-16) ITO vs. Ilesh Infracap Private Limited Page 11 of 13 SCA NO Due date of filing reply Date of reply:- Date of order under section 148A(d) and notice under section 148:- Last date for issuance of notice under section 148 as per surviving time:- 6387/2023 09.06.2022 04.06.2022 29.07.2022 22.06.2022 5688/2023 06.06.2022 - 27.07.2022 27.06.2022 22260/2022 07.06.2022 06.07.2022 30.07.2022 14.06.2022 996/2023 11.06.2022 10.06.2022 19.07.2022 18.06.2022 68. It is apparent from the above details that impugned notice under section 148 of the Act is issued beyond the period of 'surviving time' as per the direction of Hon'ble Apex Court in case of Rajeev Bansal (supra)and therefore, such notices would be invalid notices. 69. The impugned notices issued under section 148 of the Act are accordingly quashed and set aside being invalid having been issued beyond the 'surviving time'. Accordingly, impugned orders passed under section 148A(d) of the Act would also not survive and are accordingly, quashed and set aside. Subsequent proceedings, if any, undertaken by the respondent would not survive and are also quashed and set aside. The Hon’ble Court held that since the notices under section 148 were issued beyond period of 'surviving time' as per direction of Supreme Court in Union of India v. Rajeev Bansal (supra), such notices were invalid. 16. In view of the facts discussed above and the judgement of the Hon’ble Supreme Court as well as the jurisdictional High Court, the impugned notice dated 27.07.2022 issued u/s 148 of the Act is held to be invalid as the same was issued beyond the surviving period as per the decision of Hon’ble Supreme Court in the case of Rajiv Bansal (supra). Accordingly, the proceeding initiated u/s 148 of the Act is quashed being time-barred. As a consequence, the impugned assessment order dated 29.05.2023 does not survive and the same is quashed and set aside. The legal ground taken by the assessee is allowed. Printed from counselvise.com ITA Nos.2114 & 2115/Ahd/2024 (Assessment Years: 2014-15 & 2015-16) ITO vs. Ilesh Infracap Private Limited Page 12 of 13 17. Since the legal ground taken by the assessee has been allowed, and the assessment order has been consequently quashed and set aside, the grounds taken by the Revenue has become infructuous. Accordingly, the appeal of the Revenue is dismissed. ITA No. 2115/Ahd/2024 for A.Y. 2015-16 18. The facts involved in the A.Y. 2015-16 are identical to A.Y. 2014-15. The chronology of the events pertaining to A.Y. 2015-16 is as under: - Date Event 30.06.2021 Notice issued u/s.148 of the Act 13.10.2021 Letter of request made for providing reasons for reopening of the assessment 07.12.2021 Stay order of the Hon’ble Gujrat High Court in WP No.18208/2021 06.05.2022 Final Order of the Hon’ble Gujarat High Court in WP No.18208/2021 24.05.2022 Notice issued u/s.148A(b) of the Act 06.06.2022 Reply to notice u/s.148A(b) of the Act 27.07.2022 Order passed u/s.148A(d) of the Act 27.07.2022 Notice issued u/s.148 of the Act 19. In this year also, the notice under Section 148 of the Act was issued beyond the surviving period. Hence, the finding and the decision in ITA No.2114/Ahd/2024 for the A.Y. 2014-15 will apply mutatis mutandis to ITA No.2115/Ahd/2025 for A.Y. 2015-16 as well. Accordingly, the legal ground taken by the assessee is allowed and the appeal of the Revenue is dismissed. 20. In the final result, both the appeals of the Revenue are dismissed. Order pronounced in the open Court on this 25th November, 2025. Sd/- Sd/- (SANJAY GARG) (NARENDRA PRASAD SINHA) Judicial Member Accountant Member Ahmedabad, the 25th November, 2025 Printed from counselvise.com ITA Nos.2114 & 2115/Ahd/2024 (Assessment Years: 2014-15 & 2015-16) ITO vs. Ilesh Infracap Private Limited Page 13 of 13 PBN/* Copies to: (1) The appellant (2) The respondent (3) The PCIT (4) The CIT(A) (5) Departmental Representative (6) Guard File By order TRUE COPYE COPY Assistant Registrar Income Tax Appellate Tribunal Ahmedabad benches, Ahmedabad Printed from counselvise.com "