SHRI NIRMAL KUMRAWAT, Indore V. THE ACIT-2(1), Indore

ITSSA 156/IND/2016

• Counselvise Citation: [2019] 118 COUNSELVISE.COM (IT) 2846 (ITAT-INDORE)
• Duration Of Justice: 2 year(s) 7 month(s) 10 day(s)
• Appeal Type: Income Tax (Search & Seizure) Appeal
• Pronouncement Date: 28-02-2019
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: DB
• Next Hearing Date: 28-02-2019
• Assessment Year: 2007-2008
• Appeal Filed On: 18-07-2016
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: ASHIMA GUPTA
• Assessee Lawyers: S N AGRAWAL; PANKAJ MOGRA A RS
• Keywords: Income from undisclosed sources

Judgement Text

[IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] , , IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI MANISH BORAD, ACCOUNTANT MEMBER IT(SS)A NOS.154 TO 156/IND/2016 ASSESSMENT YEARS: 2004-05, 2006-07 & 2007-08 SHRI NIRMAL KUMRAWAT AGGRIEVED-76, SCHEME NO.54 INDORE / VS. ACIT - 2(1) INDORE ( APPELLANT ) ( REVENUE ) P.A. NO. AHOPK2626F APPELLANT BY SHRI S.N. AGRAWAL & SHRI PANKAJ MOGRA, A.RS RESPONDENT BY SMT. ASHIMA GUPTA, D.R. DATE OF HEARING: 28.02.2019 DATE OF PRONOUNCEMENT: 28.02.2019 / O R D E R PER V. DURGA RAO, J.M: THESE APPEALS FILED BY THE ASSESSEE ARE DIRECTED AGAINST ORDER OF THE CIT(A)-I, INDORE DATED 11.3.2016 FOR THE ASSESSMENT YEARS 2004-05, 2006-07 & 2007-08. SINCE T HE [IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] 2 ISSUE IS COMMON THE APPEALS WERE HEARD TOGETHER AND DISPOSED OFF IN COMMON ORDER FOR THE SAKE OF CONVENI ENCE AND BREVITY. FIRST WE TAKE UP APPEAL NO.154/IND/2016 F OR THE A.Y. 2004-05 FOR ADJUDICATION. ITA NO.154/IND/2016: 2. FACTS ARE IN BRIEF THAT IN THE ASSESSMENT ORDER THE A.O. HAS NOTED THAT DURING THE COURSE OF THE SEARCH, A SUIT CASE WAS FOUND IN WHICH 120 COUPONS WERE FOUND. THESE ARE LOTTERY COUPONS ISSUED FOR INVESTMENT IN SMALL SAVING S SCHEME OF RAJASTHAN. ONE COUPON IS GIVEN TO EVERY INVESTOR WHO INVESTS MORE THAN RS.5000/-. IT IS NOT ED BY THE A.O THAT SHRI NIRMAL KUMRAWAT WAS HOLDING 120 COUPONS, THEREFORE, THE TOTAL INVESTMENT WORKS OUT T O RS.6 LAKHS, WHICH WAS NOT REFLECTED IN THE RETURN OF INCOM E. THE A.O. HAS ASKED THE ASSESSE TO EXPLAIN THE SAME. DURING THE COURSE OF SEARCH, THE ASSESSE HAS SUBMITTED THAT NO INVESTMENT IS MADE. SO FAR AS COUPONS ARE CONCERNED, N O [IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] 3 EXPLANATION IS GIVEN. EVEN DURING THE ASSESSMENT PROCEEDINGS, THE ASSESSEE HAS ONLY SUBMITTED THAT HE H AD NOT MADE ANY INVESTMENT AND SO FAR AS COUPONS ARE CONCERNED, NO EXPLANATION IS GIVEN. THEREFORE THE A. O. HAS MADE ADDITION OF RS.6 LAKHS IN THE HANDS OF THE ASSESSEE . BEFORE THE LD. CIT(A), IT WAS SUBMITTED THAT ASSESSEE HAS NOT MADE ANY INVESTMENT INTO SMALL SAVINGS SCHEME OF RAJASTHAN AND SUBMITTED THAT NO ADDITION CAN BE MADE. LD. CIT(A) HAS NOT ACCEPTED THE EXPLANATION OF THE ASSES SEE AND CONFIRMED THE ADDITION MADE BY THE A.O. 3. ON APPEAL BEFORE US, THE LD. COUNSEL FOR THE ASSES SEE HAS SUBMITTED THAT THE ASSESSEE HAS NOT MADE ANY INVESTMENT IN THE SMALL SAVINGS SCHEME OF RAJASTHAN AND THEREFORE, ADDITION CANNOT BE MADE. 4. ON THE OTHER HAND, LD. .D.R. STRONGLY SUPPORTED T HE ORDER PASSED BY THE AUTHORITIES BELOW. [IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] 4 5. WE HAVE HEARD THE RIVAL SUBMISSIONS, PERUSED THE MATERIALS AVAILABLE ON RECORD AND GONE THROUGH THE ORDERS OF THE AUTHORITIES BELOW. GROUND NOS.1 & 2 ARE NOT PRESSED AND THE SAME ARE DISMISSED AS NOT PRESSED. THE ONLY I SSUE INVOLVED IN THIS APPEAL RELATES TO ADDITION OF RS. 6 LAK HS. THERE IS A SEARCH CONDUCTED AND IN THE COURSE OF SEARCH , A SUIT CASE BELONGING TO THE ASSESSEE WAS FOUND. IN THE SUIT CASE 120 LOTTERY COUPONS OF RAJASTHAN STATE GOVERNMENT WERE FOUND. IT WAS SUBMITTED DURING THE COURSE OF S EARCH THAT ASSESSEE HAS NOT MADE ANY INVESTMENT IN THE SMALL SAVINGS SCHEME OF THE RAJASTHAN GOVERNMENT AND THEREFOR E NO ADDITION CAN BE MADE. DURING THE COURSE OF ASSESSME NT PROCEEDINGS, THE AO. HAS ASKED THE ASSESSEE THAT THERE WERE 120 LOTTERY COUPONS BELONGING TO YOU AND THOSE COUPONS ARE ISSUED FOR INVESTMENT OF RS.5000/- PER O NE COUPON. THEREFORE, ASSESSEE MUST HAVE INVESTED RS.6 LAKHS TO RECEIVE 120 COUPONS, THEREFORE ASKED THE [IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] 5 EXPLANATION. THE ASSESSEE HAS SUBMITTED THAT HE HAS NOT INVESTED ANYTHING IN THE SMALL SAVING SCHEME OF RAJAST HAN GOVERNMENT. THE ASSESSEE HAS NOT GIVEN ANY EXPLANATION NEITHER BEFORE THE LD. CIT(A) NOR BEFORE THE A.O. R EGARDING THE COUPONS. THEREFORE, THE A.O. HAS CONCLUDED THAT THE ASSESSEE HAS INVESTED AN AMOUNT OF RS. 6 LAKHS AND RECEIVED 120 COUPONS, THEREFORE ADDITION IS MADE TO THE EXTENT OF RS.6 LAKHS IN THE HANDS OF THE ASSESSEE AND T HE LD. CIT(A) HAS CONFIRMED THE SAME. THE ARGUMENT OF TH E LD. COUNSEL FOR THE ASSESSEE IS THAT HE HAS NOT MADE ANY INVESTMENT. THEN WE ASKED THE LD. COUNSEL FOR THE ASSESSEE THAT THE COUPONS BELONGS TO WHOM? HE IS NOT ABLE TO EXPLAIN. WE FIND THAT 120 COUPONS ARE IN POSSESSION OF THE ASSESSEE FOR WHICH THE ASSESSEE HAS NOT GIVEN ANY EXPLANATION. IT IS A FACT THAT IF ANYONE INVES TS MORE THAN RS.5000/- IN RAJASTHAN STATE SMALL SAVINGS SCHEME, ONE COUPON WILL BE ISSUED. THEREFORE, IT C AN BE [IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] 6 SAFELY CONCLUDED THAT THE ASSESSEE IS HAVING WITH HIM 1 20 COUPONS AND HE OUGHT TO HAVE INVESTED RS.6 LAKHS, OTHERWISE THE RAJASTHAN GOVERNMENT, DEPARTMENT OF SMALL SAVINGS CANNOT ISSUE A SINGLE COUPON WITHOUT INVESTMEN T. WE FIND THAT THERE IS A PROXIMITY BETWEEN THE COUPONS AND INVESTMENT. UNDER THESE ABOVE FACTS AND CIRCUMSTANCES OF THE CASE, WE ARE OF THE OPINION THAT THE A.O. HAS RIGH TLY GIVEN THE CONCLUSION THAT THE ASSESSEE HAS INVESTED RS .6 LAKHS AND RECEIVED 120 COUPONS. THE SAME IS CONFIRM ED BY THE LD. CIT(A). WE FIND NO REASON TO INTERFERE W ITH THE ORDER OF THE LD. CIT(A) AND THE SAME IS CONFIRMED. 6. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IS DISMISSED. IT(SS)A NOS.155 & 156/IND/2016: 7. GROUND NOS. 1 & 2 ARE NOT PRESSED AND HENCE THE GROUNDS ARE DISMISSED AS NOT PRESSED. [IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] 7 8. GROUND NO.3 IS THE ADDITION RELATES TO RS.45,000/- . IN THE ASSESSMENT ORDER THE A.O. HAS NOTED THAT THERE IS ACCOUNT STATEMENT DATED 30.6.2005 OF PUNJAB NATIONAL BANK, PRINCIPAL ASSET MANAGEMENT MUTUAL FUND ADDRESSED TO NIRMAL KUMRAWAT, THE ASSESSEE SHOWING INITIAL INVESTMENT OF RS45,000/- AT RS.10/- PER UNIT. THIS INVESTMENT IS MADE THROUGH BROKER M/S. SAFRON INVESTMENTS FOR SAVINGS BANK ACCOUNT NO.4041000004077 HDFC BANK, INDORE. THE AFORESAID INVESTMENT IS NOT REFLECTED IN THE RETURN OF INCOME OF THE ASSESSEE. IN RESPONSE, THE ASSESSEE HAS REPLIED THAT THESE MUTUAL F UNDS ARE PURCHASED BY MOTHER OF THE ASSESSEE IN THE NAME OF THE ASSESSEE. ON VERIFICATION FROM IT RETURN OF MOTHER O F SHRI NIRMAL KUMRAWAT, THE A.O. NOTED THAT IT DOES NOT APPEAR THAT SHE HAS REGULAR SOURCE OF INCOME FROM WHICH SHE H AS EARNED SO MUCH OF LIQUID FUNDS THAT COULD BE ADVANCED T O ANY OF THE PERSONS NEITHER ANY OUTSTANDING BALANCE IS [IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] 8 REFLECTED IN THE BALANCE SHEET NOR THE SAME HAS BEEN RE PAID THE AMOUNT OF CASH TAKEN FROM HIS MOTHER. THEREFORE, THE ASSESSEES SUBMISSIONS ARE NOT GENUINE, TENABLE. APART FROM THIS, CHEQUES TO PURCHASE SUCH MUTUAL FUNDS SO ISSUED FROM THE BANK ACCOUNT OF SHRI NIRMAL KUMRAWAT. THESE INVESTMENTS MADE BY SHRI NIRMAL KUMRAWAT ARE TREATED TO BE HIS INCOME FROM UNDISCLOSED SOURCES ADD ED TO HIS TOTAL INCOME ON SUBSTANTIVE BASIS IN CASE OF LEGAL DESCENDANT OF LATE SMT. ROZINA KUMAWAT ON PROTECTIVE BASIS. 9. THERE IS ONE MORE ADDITION MADE BY THE A.O. IN RES PECT OF RS.45,000/-. THE A.O. NOTED THAT AS PER THE ACCOUN TS STATEMENT DATED 30.6.2005 OF THE PUNJAB NATIONAL BANK PRINCIPAL ASSET MANAGEMENT MUTUAL FUND ADDRESSED TO MARRY ROZINA KUMRAWAT SHOWING INITIAL INVESTMENT OF RS.45,000/- FOR UNITS 4500 AT RS.10/- PER UNIT. THE [IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] 9 INVESTMENT VALUE OF RS.45000/- IN THE NAME OF MARRY ROZINA KUMRAWAT IS NOT REFLECTED IN THE RETURN OF INC OME. THE ASSESSEE REPLIED DURING THE ASSESSMENT PROCEEDING S THAT THESE MUTUAL FUNDS ARE PURCHASED BY MOTHER OF HER HUSBAND SHRI NIRMAL KUMRAWAT IN THE NAME OF SMT. ROZINA KUMRAWAT. THE SAME IS SHOWN IN THE RETURN OF INCOME OF THE ASSESSEES MOTHER SMT. ROZINA KUMRAWAT. ON VERIFICATION FROM THE RETURN OF THE ASSESSEES MOT HER SMT. ROZINA KUMRAWAT, IT DOES NOT APPEAR THAT SHE HAS REGULAR SOURCE OF INCOME FROM WHICH SHE HAS SO MUCH F OR LIQUID FUNDS THAT COULD BE ADVANCED TO ANY OF THE PERSON S, NEITHER ANY OUTSTANDING BALANCE IS REFLECTED IN THE BALAN CE SHEET NOR THE SAME HAS BEEN REPAID TO THE AMOUNT OF CAS H TAKEN FROM HIS MOTHER, THEREFORE, ASSESSEES SUBMISSI ONS ARE NOT GENUINE OR TENABLE. APART FROM THESE, CHEQUES TO PURCHASE SAID MUTUAL FUNDS WAS ISSUED FROM THE BANK ACCOUNT OF SHRI NIRMAL KUMRAWAT. THESE INVESTMENTS [IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] 10 MADE BY SMT. ROZINA KUMRAWAT ARE TREATED TO BE IN THE INCOME OF SHRI NIRMAL KUMRAWAT FROM UNDISCLOSED SOURC E AND ADDED THE SAME TO THE TOTAL INCOME OF THE ASSESSEE O N SUBSTANTIVE BASIS AND IN THE CASE OF SMT. ROZINA KUMRA WAT ON PROTECTIVE BASIS. IN SO FAR AS ADDITION OF RS.40,0 00/- IS CONCERNED THE A.O. HAS NOTED THAT THE ACCOUNT STATEMENT REGARDING MAGNUM FUND OF THE SBI MUTUAL FUND IN THE NAME OF SHRI NIRMAL KUMRAWAT BEARING FOLIO NO.5388615 IT IS NFO PURCHASE DATED 8.8.2005 FOR RS.40000/-. THE ASSESSEE IS SILENT ABOUT THE SOURCE OF SUCH INVESTMEN TS. THESE INVESTMENTS MADE BY SMT. NIRMAL KUMRAWAT ARE TREATED AS INCOME OF THE UNDISCLOSED SOURCE OF THE ASSESSEE. SAME IS ADDED. IN SO FAR AS THE INVESTMENT I N RESPECT OF PNB PRINCIPAL ASSET MANAGEMENT FUND IS CONCERNED, IT IS SUBMITTED THAT HIS MOTHER HAS INVES TED IN THE NAME OF THE ASSESSEE, THEREFORE, IF AT ALL ADDITION IS MADE, IT HAS TO BE MADE IN THE NAME OF HIS MOTHER. THE [IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] 11 ASSESSEE HAS FAILED TO EXPLAIN SOURCE OF THE INVESTMENT OF HIS MOTHER. HE HAS ONLY SIMPLY SAID THAT HIS MOTHER H AS INVESTED IN HIS NAME. THE LD. CIT(A) CONFIRMED THE ORDER OF THE A,O. IN THIS CASE, THE ASSESSEE FAILED TO DISCHARG E THE BURDEN CAST UPON HIM BY PRODUCING THE RELEVANT MATERIAL THAT HIS MOTHER HAS MADE AN INVESTMENT. WE FIND NO REASON TO INTERFERE INTO THE ORDER OF THE LD. CIT(A) AND THE GROUND RAISED BY THE ASSESSEE IN THIS APPEAL IS DISMISS ED. SO FAR AS THE INVESTMENT IN PNB PRINCIPAL ASSET MANAGEMENT MUTUAL FUND RELATES TO RS.45,000/- IN THE NAME OF SMT. MARY RAZINA KUMAWAT WIFE OF THE ASSESSE IS CONCERNED, THE MOTHER OF THE ASSESSE HAS PURCHASED AND FURTHER PURCHASED THE MUTUAL FUNDS.HOWEVER, THEY HAV E NOT FILED ANY DETAILS SUCH AS SOURCE OF INVESTMENT, E TC. THE A.O. MADE AN ADDITION. LD. CIT(A) CONFIRMED THE SAME. EVEN BEFORE US, THE ASSESSE HAS NOT FILED ANY DETAILS B EFORE US IN RESPECT OF INVESTMENTS MADE BY THE ASSESSEES M OTHER [IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] 12 BY PURCHASE OF PNB PRINCIPAL ASSET MANAGEMENT MUTUAL FUND IN THE NAME OF WIFE OF THE ASSESSE SMT. MARY REZ INA KUMAWAT. WE FIND NO REASON TO INTERFERE AND DISMISS T HE APPEAL 10. IN SO FAR AS INVESTMENT MADE IN SBI MUTUAL FUNDS IN THE NAME OF SMT. MARRY ROZINA KUMRAWAT, WIFE OF THE ASSESSEE IS CONCERNED, IT WAS SUBMITTED THAT THE ASSESS EES MOTHER HAS PURCHASED THE UNITS IN THE NAME OF THE ASSESSEES WIFE MARRY ROZINA KUMRAWAT. NEITHER BEFORE THE A.O. NOR BEFORE THE LD. CIT(A) THE ASSESSEE IS ABLE T O SUBSTANTIATE THAT THE HIS MOTHER IS HAVING SUFFICIENT F UNDS TO PURCHASE THE UNITS. THEREFORE, BOTH THE A.O. AND LD. CIT(A) DISBELIEVED THE INVESTMENT MADE BY HIS MOTHER AND ADDITION IS MADE IN THE HANDS OF THE ASSESSEE. EVEN B EFORE US, ASSESSEE FAILED TO DISCHARGE BURDEN CAST UPON HIM TO SHOW THAT INVESTMENT WAS ACTUALLY MADE BY HIS MOTHER. [IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] 13 WE FIND NO REASON TO INTERFERE WITH THE ORDER OF THE LD. CIT(A). THIS GROUND OF THE ASSESSEE IS DISMISSED, 11. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IN IT(SS)A NO.154/IND/2016 IS DISMISSED. IT(SS)A NOS.155 & 156/IND/2016: 12. LD. COUNSEL FOR THE ASSESSEE HAS NOT PRESSED GROU ND NOS.1 & 2. HENCE, GROUND NOS.1 & 2 IN BOTH THE APPE ALS ARE DISMISSED AS NOT PRESSED. 13. ADDITION OF RS.45,000/- IS IN RESPECT OF INVEST MENT IN SBI ONE INDIA FUND ISSUED BY SBI MUTUAL FUNDS. IN TH E ASSESSMENT ORDER, THE A.O. HAS NOTED THAT THERE IS AN INVESTMENT OF RS.45,000/- IN THE NAME OF SMT. ROZINA KUMRAWAT IN SBI ONE INDIA FUND OF SBI MUTUAL FUNDS AND SAME IS NOT REFLECTED IN THE RETURN OF INCOME OF SMT . ROZINA KUMRAWAT. WHEN THE A.O. HAS ASKED THE ASSESSEE, IT W AS SUBMITTED THAT THIS MUTUAL FUND IS PURCHASED BY MOTHER OF THE ASSESSE SMT. ROZINA KUMRAWAT. ON VERIFICATION OF TH E [IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] 14 RETURNS OF THE ASSESSEES MOTHER SMT. ROZINA KUMRAWAT, NO SUCH INVESTMENT IS REFLECTED AND SHE HAS NO CAPACITY TO INVEST THAT AMOUNT. THE ASSESSEE HAS ALSO NOT PRODUCED ANY SOURCE OF HER INCOME, THEREFORE, THE A.O. HAS MAD E AN ADDITION IN THE HANDS OF THE ASSESSEE ON SUBSTANTIVE BAS IS. EVEN BEFORE THE LD. CIT(A), NO MATERIAL HAS BEEN PLACED TO SHOW THAT INVESTMENT IS MADE BY HER MOTHER. EVEN BE FORE US, NO MATERIAL HAS BEEN PLACED AND NOTHING WAS PRODUCED TO SHOW THAT INVESTMENT IS MADE BY HER MOTHER. WE FI ND NO REASON TO INTERFERE AND CONFIRM THE ORDER OF THE A .O. GROUND RAISED BY THE ASSESSEE IS DISMISSED. 14. WITH REGARD TO GROUND NO.4, IN THE ASSESSMENT ORD ER, THE A.O. HAS NOTED THAT THE ASSESSEE HAS MADE A CASH DEPOSIT INTO HIS BANK OF BARODA ACCOUNT NO.3245 OF RAVI SHANKAR BRANCH FOR ASSESSMENT YEAR 2007-08. THE CASH DEPOSIT IS RS.1,48,000/-. DURING THE COURSE OF ASSE SSMENT [IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] 15 PROCEEDINGS, THE ASSESSEE WAS ASKED TO EXPLAIN SOURCE OF SUCH CASH DEPOSITS FOR WHICH THE ASSESSEE HAS NOT OFF ERED ANY EXPLANATION, THEREFORE THE SAME IS ADDED IN THE HANDS OF THE ASSESSEE. 15. ON APPEAL, NO MATERIAL IS PLACED TO SHOW THE SOURCE FOR THE ABOVE DEPOSITS IN THE BANK ACCOUNT, THEREFORE , THE LD. CIT(A) CONFIRMED IT. BEFORE US, ASSESSEE HAS FIL ED A CASH FLOW STATEMENT, WHICH DOES NOT SHOW THAT THERE IS A SOURCE OF RS.1,48,000/- TO DEPOSIT IN THE BANK ACCOUN T. THE ASSESSEE HAS NOT PLACED ANY MATERIAL TO SUBSTANTIATE THAT THERE IS A SUFFICIENT SOURCE TO DEPOSIT IN THE B ANK ACCOUNT OF RS.1,48,000/-. THEREFORE, BY CONSIDERING THE ENTIRE FACTS AND CIRCUMSTANCES OF THE CASE, WE FIND NO ERROR IN THE ORDER PASSED BY THE LD. CIT(A). THIS GROUND OF THE ASSESSEE IS DISMISSED. [IT(SS)A NOS.154 TO 156/IND/2016] [SHRI NIRMAL KUMAWAT, INDORE] 16 16. IN THE RESULT, THE APPEALS FILED BY THE ASSESSEE A RE DISMISSED. ORDER WAS PRONOUNCED IN THE OPEN COURT ON 28 . 02.2019. SD/- (MANISH BORAD) SD/- (V. DURGA RAO) A CCOUNTANT MEMBER JUDICIALMEMBER INDORE; DATED : 28/02/2019 VG/SPS COPY TO: ASSESSEE/AO/PR. CIT/ CIT (A)/ITAT (DR)/GUAR D FILE. BY ORDER ASSISTANT REGISTRAR, INDORE