Shri Chandresh R.Jain, Godhra V. The ACIT.,Panchmahal Circle, Godhra

ITSSA 20/AHD/2015

• Counselvise Citation: [2019] 117 COUNSELVISE.COM (IT) 7661 (ITAT-AHMEDABAD)
• Duration Of Justice: 4 year(s) 2 month(s) 18 day(s)
• Appeal Type: Income Tax (Search & Seizure) Appeal
• Pronouncement Date: 04-04-2019
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Assessment Year: misc
• Appeal Filed On: 16-01-2015
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: S K DEV
• Keywords: Gross profit estimation; Corroborative evidences; Documents seized; Set aside

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL A BENCH, AHMEDABAD BEFORE SHRI PRAMOD KUMAR, VICE PRESIDENT & MS. MADHUMITA ROY, JUDICIAL MEMBER IT(SS)A. NO.20/AHD/2015 (BLOCK PERIOD 1988-89 TO 18.11.97) SHRI CHANDRESH R. JAIN, 44, PRABHAKUNJ, SOCIETY, GODHRA-389 001. VS. ACIT, PANCHMAHAL CIRCLE, GODHRA [PAN NO. ACGPJ 4712 J] ( APPELLANT ) .. ( RESPONDENT ) APPELLANT BY : SHRI URVASHI SODHAN, A.R. RESPONDENT BY : SHRI S. K. DEV, SR. D.R. DATE OF HEARING 08/01/2019 DATE OF PRONOUNCEMENT 04/04/2019 O R D E R PER MS. MADHUMITA ROY - JM: THE INSTANT APPEAL FILED BY THE ASSESSEE IS AGAINST THE ORDER DATED 14.11.2014 PASSED BY THE COMMISSIONER OF INCOME TAX (APPEALS)- I, BARODA WHEREBY AND WHEREUNDER THE ORDER DATED 30.01.2012 ISSUED BY THE ACIT, PANCHMAHAL CIRCLE, GODHRA PASSED UNDER SECTION 158 BFA(2) OF THE INCOME TAX A CT, 1961 (HEREINAFTER REFERRED AS TO THE ACT) IN LEVYING THE PENALTY OF RS.7,50,492/- FOR THE BLOCK PERIOD 1988-89 TO 18.11.97 HAS BEEN CONFIRMED. 2. THE BRIEF FACTS LEADING TO THE CASE IS THIS THAT A SEARCH OPERATION WAS CARRIED OUT AT THE RESIDENTIAL AND BUSINESS PREMISES OF THE ASSESS EE AT GODHRA ON 18.11.1997. SEVERAL INCRIMINATING DOCUMENTS WERE SEIZED FROM THE RESIDE NTIAL AND/OR BUSINESS PREMISES OF THE ASSESSEE REFLECTING NUMBERS OF INVESTMENTS MADE BY THE ASSESSEE AS ALSO THE PROFIT EARNED BY HIM ON SALE OF LANDS. A NOTICE U/S 158BC OF THE ACT WAS ISSUED ON 27.01.1998 UPON - 2 - IT(SS)A NO.20/AHD/2015 SHRI CHANDRESH R. JAIN VS. ACIT BLOCK PERIOD 1988- 89 TO 18.11.97 WHICH THE ASSESSEE FILED RETURN OF UNDISCLOSED INCO ME FOR THE BLOCK PERIOD 1988-89 TO 18.11.1997 ON 30.03.1998 AND AN INCOME TO THE TUNE OF RS. 26,00,241/- WAS DECLARED AS UNDISCLOSED. THE LEARNED AO ON 29.11.1999 FINALIZED THE ASSESSMENT ORDER U/S 158 BC(C) R.W.S. 158 BG(B) OF THE ACT ON THE BASIS OF M ATERIALS SIZED FROM THE RESIDENCE AND/OR BUSINESS PREMISES OF THE ASSESSEE. ADDITION TO THE TUNE OF RS.43,88,572/- WAS MADE; UNDISCLOSED INCOME FOR THE BLOCK PERIOD WAS D ETERMINED AT RS. 69,88,813/-. PENALTY PROCEEDING U/S 158 BFA(2) WAS INITIATED BY ISSUING NOTICE U/S 274 R.W.S. 158 BFA(2) UPON THE ASSESSEE. THE QUANTUM APPEAL THEREA FTER SO FILED BY THE ASSESSEE WAS PARTLY ALLOWED DETERMINING THE TOTAL INCOME AT RS. 30,55,998/- UPON WHICH APPEAL BEFORE THE LEARNED TRIBUNAL WAS PREFERRED BY THE ASSESSEE. THE HONBLE TRIBUNAL WAS PLEASED TO SET ASIDE THE MATTER OF CERTAIN ADDITIONS TO THE FI LE OF LEARNED AO WHO INTERN U/S 158 BC R.W.S. 158 BG AND 254 OF THE ACT PASSED AN ORDER DA TED 30.12.2006 DETERMINING THE UNDISCLOSED INCOME OF THE ASSESSEE AT RS. 63,52,000 /-. FURTHER APPEAL AGAINST SAID ORDER WAS PREFERRED BEFORE THE LEARNED CIT(A) WHEREBY AND WHEREUNDER THE MAJOR ADDITIONS WERE DELETED. FURTHER THAT, UNDISCLOSED INCOME WAS REVISED AND REDUCED TO THE TUNE OF RS. 38,51,060/-. 3. IN PENALTY PRECEDING THE ASSESSEE HAS GIVEN AN O PPORTUNITY TO SHOW-CAUSE ON 21.12.2011 AS TO WHY PENALTY U/S 158 BFA(2) SHOULD NOT BE IMPOSED UPON HIM FOR CONCEALMENT OF UNDISCLOSED INCOME UPON WHICH THE AS SESSEE SUBMITTED AS FOLLOWS: 'FROM THE SAID ORDER, YOU WILL OBSERVE THAT ALL THE ADDITIONS HAVE BEEN MADE ON ESTIMATED BASES ONLY. YOU WILL OBSERVE THAT MAJOR A DDITION HAS BEEN MADE FOR PROFIT EARNED FROM LAND TRANSACTION @ 1.5% OF THE T URNOVER. FOR THESE BOTH THE TURNOVER OF LAND TRANSACTION AS WELL AS PROFIT EARN ED ON SUCH HAS BEEN ESTIMATED. IT HAS BEEN ASSUMED THAT ON THE AMOUNT RECEIVED AND AMOUNT PAID, THE ASSESSEE HAS EARNED 1.5% PROFIT FURTHER IN THE CALCULATION T HE TURNOVER LOT OF ASSUMPTION AS WELL AS DUPLICATION OF THE FIGURES ARE THERE IN ABS ENCE OF COMPLETER CORROBORATIVE EVIDENCES. IN SUPPORT TO THE ABOVE, THE ASSESSEE CITED VARIOUS JUDICIAL DECISIONS. FURTHER, THE A.R. OF THE ASSESSEE SUBMITTED MOST HUMBLY THAT THE RE IS NO QUESTION OF LEVY OF - 3 - IT(SS)A NO.20/AHD/2015 SHRI CHANDRESH R. JAIN VS. ACIT BLOCK PERIOD 1988- 89 TO 18.11.97 PENALTY FOR CONCEALMENT OF ANY INCOME OR ITS PARTIC ULARS AND REQUESTED TO DROP THE ACTION INITIATED IN TERM OF THE NOTICE''. ULTIMATELY, THE SUBMISSIONS MADE BY THE ASSESSEE WA S CONSIDERED AND REJECTED UNDER A PENALTY OF RS. 7,50,492/- IMPOSED UPON THE ASSESSEE WHICH WAS CONFIRMED BY THE LEARNED CIT(A). HENCE, THE INSTANT APPEAL BEFORE US . 4. AT THE TIME OF HEARING OF THE MATTER, THE LEARNE D COUNSEL APPEARING FOR THE ASSESSEE AND VEHEMENTLY ARGUED IN SUPPORT OF HIS CL AIM BY CONTENDING THAT THE QUANTUM ORDER WAS PASSED ON ESTIMATED BASIS AND HENCE NO PE NALTY IS LIABLE U/S 158 BF OF THE ACT. IN SUPPORT OF HIS CASE, SHE ALSO RELIED UPON THE JU DGMENT PASSED IN THE MATTER OF COMMISSIONER OF INCOME TAX-VS-DR. GIRIRAJ AGARWAL G IRI [2013] 33 TAXMANN.COM 536 (RAJASTHAN), ACIT-VS-SHANTI BAI YADAV, 25 TAXMANN.C OM 462. ON THE CONTRARY, THE LEARNED DR RELIED UPON THE ORDER PASSED BY THE AUTH ORITIES BELOW. FURTHER THAT, HE CONTENDED THAT THE ORDER PASSED BY THE AUTHORITIES BELOW IN QUANTUM PROCEEDING WAS NOT ON ESTIMATED BASIS BUT RATHER ON THE BASIS OF THE I NCRIMINATING DOCUMENTS SEIZED FROM THE RESIDENCE AND BUSINESS PREMISES OF THE ASSESSEE DUR ING THE SEARCH CONDUCTED BY THE REVENUE. 5. WE HAVE HEARD THE RESPECTIVE PARTIES, WE HAVE CA REFULLY CONSIDERED THE RELEVANT MATERIALS AVAILABLE ON RECORDS. WE HAVE ALSO GONE T HROUGH THE ORDER OF QUANTUM PASSED BY THE LEARNED AO AND CAREFULLY CONSIDERED THE JUDG MENTS RELIED UPON BY THE LEARNED AO. IT IS A FACT THAT THE LEARNED ITAT BY ORDER DAT ED 25.01.2007 SET ASIDE THE ISSUE TO THE FILE OF THE ASSESSING OFFICER IN RESPECT OF CERTAIN ADDITIONS FOR DECIDING THE SAME AFRESH BUT AGAIN LEARNED AO PASSED AN ORDER U/S 158 BC R.W .S. 158 BG AND 254 OF THE ACT ASSESSING THE TOTAL INCOME AT RS. 63,52,000/-. IN A PPEAL, THE LEARNED CIT(A) DELETED MAJOR ADDITIONS AND FOUND UNDISCLOSED INCOME AMOUNT ING TO RS.12,50,820/- ONLY. THE - 4 - IT(SS)A NO.20/AHD/2015 SHRI CHANDRESH R. JAIN VS. ACIT BLOCK PERIOD 1988- 89 TO 18.11.97 OBSERVATION AND/OR DECISION RENDERED BY THE LEARNED CIT(A)-VI, BARODA IN APPEAL NO. CAB/VI=519/07-08 DATED 30.10.2008 IS REPRODUCED HER E FOR READY REFERENCE: '5.3.2 WITHOUT PREJUDICE TO ABOVE, THE APPELLANT C ONTENDS THAT IN THE ORIGINAL ORDER THE DCIT WHILE WORKING OUT THE TURNOVER OF TH E LAND TRANSACTIONS ENTERED AFTER THE PEAK DATE, HAS CONSIDERED THE VARIOUS AMO UNT GIVEN AND RECEIVED FROM THE DIARY SEIZED VIDE ANNEXURE. B-13 AND IN THE SAI D DIARY VARIOUS RECEIPTS AND PAYMENTS ARE REFLECTED BUT IT DOES NOT AMOUNT TO PU RCHASE OF LAND BY THE APPELLANT TO THE TUNE OF RS. 412.06 LACS BUT THERE ARE NUMBER OF TRANSACTION OF RECEIPTS AND PAYMENTS WHICH ARE DUPLICATED AND IT INCLUDES VARIO US RECEIPTS FOR WHICH BANAKHATS ARE CANCELLED. IT IS POINTED OUT THAT THE ENTRIES IN ANNEXURE-B13 ARE DUPLICATES OF ANNEXURE-A1-7 OF SEIZED BANAKATS AND THAT DUPLICATION IS TO BE EXTENT OF RS.85,52,822/- AND THESE SHOULD BE REMOVE D FROM THE TURNOVER OF RS.4,12,06,125/-. IT IS A/SO ARGUED THAT THE BROKER AGE INCOME @ 1.5% ONLY SHOULD BE CONSIDERED AND NOT 8% AS ESTIMATED BY LEARNED A. O. AS THE APPELLANT IS ACTING AS BROKER AND AS PER TRADE PRACTICE HE EARNS ONLY 1 .5%. FURTHER AS A SECOND ALTERNATIVE IT IS SUGGESTED THA T IF THE INCOME IS TO BE CONSIDERED AT 8% OF THE GROSS TURNOVER, THEN, THE P EAK INVESTMENT SHOULD BE TELESCOPED AGAINST THE INCOME FROM LAND TRANSACTION S AFTER THE PEAK DATE. ATTENTION IS ALSO INVITED TO PARA 5.4 ON PAGE 10 OF THE ITAT ORDER REPRODUCED BELOW: 'FURTHER STILL, A PART OF THE ASSESSEE'S TURNOVER I S ALSO, ADMITTEDLY, PRIOR TO THE DATE OF THE PEAK INVESTMEN T- THE PEAK DATE- AND WHICH WOULD ALSO BE REQUIRED TO BE T AKEN INTO CONSIDERATION. NO DOUBT, THE SAID PROFIT, TO THE EXTENT INCLUDED IN THE PEAK INVESTMENT WOULD BE REQUIRED TO EXCLUDED, TO AVOID IT'S DOUBLE TAXATION , BY ALLOWING TELESCOPING BENEFIT THERE AGAINST', 5.4 I HAVE CONSIDERED THE CONTENTIONS OF THE APPEL LANT AND THE ASSESSMENT ORDER. THE HON'BLE ITAT HAS APPROVED THE METHOD OF COMPUTATION OF INCOME I.E. THE PEAK INVESTMENT AND THE PROFIT FROM THE LAND TR ANSACTIONS AFTER THE PEAK DATE. THE HON'BLE ITAT WAS OF VIEW THAT THE PROFIT ELEMEN T IN RESPECT OF THE COMPLETED TRANSACTIONS MAY BE BROUGHT TO TAX. DURING THE SE-A SIDE PROCEEDINGS AND IN THE APPELLATE PROCEEDINGS BEFORE ME. IT WAS STRESSED TH AT NO SALE TRANSACTION WAS COMPLETED AFTER THE PEAK DATE. HOWEVER, IT IS ALSO FAIRLY ADMITTED THAT THE APPELLANT WAS ACTING AS A BROKER AND WAS PURCHASING AND SELLING BANAKATS AND WAS ALSO RECEIVING PAYMENTS IN INSTALLMENTS FROM TH E BUYERS AND IN TURN MAKING PAYMENTS IN INSTALLMENTS TO THE SELLERS OF THE LAND . IT IS ALSO ADMITTED THAT IN - 5 - IT(SS)A NO.20/AHD/2015 SHRI CHANDRESH R. JAIN VS. ACIT BLOCK PERIOD 1988- 89 TO 18.11.97 RESPECT OF BOTH THESE TRANSACTIONS, COMMISSION INCO ME WAS EARNED AND THE SAME WAS RECEIVED IN CASH. THUS, EVEN IF THE APPELLANT'S CLAIM THAT NO SALE TRANSACTION WAS COMPLETED IS ADMITTED, BROKERAGE WAS EARNED IN RESPECT OF THE RECEIPTS FROM BUYERS AS WELL AS PAYMENTS TO SELLERS. IT IS ALSO N OTICED THAT IN. THE ORIGINAL ASSESSMENT ORDER AT PAGE-16 (PARA-4), THE AO HAD AC CEPTED THE BROKERAGE RATE @ 1.5% ON SALE OF BANAKAT. ACCORDINGLY, IN MY VIEW IN RESPECT OF ALL THE RECEIPTS AND PAYMENTS AFTER THE PEAK DATE INCOME MAY BE COMPUTED @ 1.5% ON THE TOTAL PAYMENTS AND RECEIPTS. THE APPELLANT HAD FURNISHED THE DETAILS OF SUCH PAYMENTS AS RS. 3,86,32,591/- AND RECEIPTS OF RS. 4,12,06,12 5/-. HOWEVER, IT IS IMPRESSED DURING THE APPELLATE PROCEEDINGS THAT PAYMENTS OF R S. 74,96,027/- AND RECEIPTS OF RS. 85,52,822/- RELATE TO THE DUPLICATE ENTRIES IN THE CASH-FLOW STATEMENT AND SHOULD ACCORDINGLY BE REDUCED FOR PURPOSE OF COMPUT ING THE BROKERAGE INCOME. THE A.O. IS ACCORDINGLY DIRECTED TO VERIFY THE DETA ILS RELATING TO DUPLICATE ENTRIES AND TO THE EXTENT FOUND CORRECT, THE SAME BE REDUCE D FROM THE PURCHASE AND SALE FIGURES. THE GROUND IS PARTLY ALLOWED SUBJECT TO VE RIFICATION BY A.O.' 6. DURING THE PENALTY APPEAL, THE ASSESSEE IN SUPPO RT OF HIS CLAIM SUBMITTED THAT ADDITION WAS MADE ON ESTIMATED BASIS AND THEREFORE PENALTY DOES NOT LIE RELEVANT PORTION WHEREOF IS AS FOLLOWS: 1.11 AS FAR AS LEGAL POSITION IS CONCERN, THE APP ELLANT RELIES ON THE FOLLOWING DECISIONS: THE HON'BLE RAJASTHAN HIGH COURT IN CASE OF CIT VS DR. GIRIRAJ AGRAWAL GIRI 33 TAXMANN.COM 536 HAS HELD THAT WHEN THE ADDI TION IS MADE ON ESTIMATION WITHOUT ANY DOCUMENTS/EVIDENCES FOUND DU RING THE COURSE OF SEARCH, NO PENALTY U/S 158BFA CAN BE LEVIED. HON'BLE MUMBAI TRIBUNAL IN THE CASE OF VASANT THAKO OR VS ACIT 40 TAXMANN.COM 153 HAD HELD THAT WHEN THE ASSESSEE'S E XPLANATION IS SUBSTANTIALLY ACCEPTED AND MARGINAL ADDITION HAS BE EN MADE, NO PENALTY U/S 158BFA CAN BE LEVIED. HON'BLE DELHI BENCH IN CASE OF AJAY SHARMA VS DCIT 30 TAXMANN.COM 109 HAS HELD THAT WHERE THE ADDITION HAS BEEN MADE IN A BSENCE OF CONCLUSIVE PROOF, NO PENALTY U/S 158BFA CAN BE LEVIED. HON'BLE JAIPUR TRIBUNAL IN CASE OF ACIT VS SHANTI B AI YADAV 25 TAXMANN.COM 462 HAD HELD THAT NO PENALTY U/S 158BFA CAN BE LEVIED, - 6 - IT(SS)A NO.20/AHD/2015 SHRI CHANDRESH R. JAIN VS. ACIT BLOCK PERIOD 1988- 89 TO 18.11.97 WHERE THE ADDITION HAS BEEN MADE WITHOUT ANY EVIDEN CE FOUND DURING COURSE OF SEARCH. THE APPELLANT ALSO SUBMITS THAT IN THE CASE OF CIT VS NAMICHAND 11 TAXMAN.COM 190 HON'BLE KARNATAKA HIGH COURT HAS HEL D THAT WHERE THE DIFFERENCE BETWEEN RETURNED INCOME AND ASSESSED INC OME IS VERY NEGLIGIBLE, NO PENALTY U/S 158BFA CAN BE LEVIED. THE APPELLANT ALSO RELIES ON THE FOLLOWING DECISION S: CIT V. SATYEBNDRA KUMAR DOSI 315 ITR 172 (RAJ) SMT. BITOLI DEW V. ACIT 31 SOT 30 - ESTIMATION OF I NCOME CH. SURESH KUMAR REDDY 128 ITD 428 - ESTIMATION OF INCOME DCIT V. SURESH KUMAR 97 ITD 527 - ESTIMATION OF INC OME BEENA RANI V. DCIT 11 ITR 106(TRIB.) - GP ADDITION SMT. MALA DAYANITHI V. DCIT 91 ITD 46 DIFFERENCE IN ESTIMATION GANDHI SERVICE STATION V. ACIT 100 TTJ 1143 (AHD) JASHWANT D PARMAR VS. ACIT 109 TTJ 56 (AHD) NO I NCRIMINATING DOCUMENTS ACIT V. SHANTI KUMAR CHABARA 121 TTJ 985 - ESTIMATI ON OF INCOME SADHURAM GOEL V DCIT 128 ITD 436 GP ESTIMATION - DI FF. OF OPTION DR. HAKEEM S.A. SYED SATHAR V. ACIT 123 TTJ 573 - E STIMATION OF INCOME. 1.12 THE APPELLANT MOST HUMBLY SUBMITS THAT THE IM POSITION OF PENALTY U/S 158BFA(2) OF THE ACT IS NOT MANDATORY. THERE ARE NO . OF DECISIONS WHEREIN IF HAS BEEN HELD THAT IMPOSITION OF PENALTY U/S 158 BFA(2) AS NOT MANDATORY. THE RELIANCE IS PLACED ON THE FOLLOWING DECISIONS: CIT VS. BECHERBHAI PARMAR 341 ITR 499 (GUJ) CIT V. HARKARAN DAS VED PAL 336 ITR 8 (DELHI) CIT V. SATYENDRA KUMAR DOSI 315 ITR 172 (RAJ) IN VIEW OF THE ABOVE FACTS AND CIRCUMSTANCES OF THE CASE AND AS WELL AS THE VARIOUS DECISIONS ON THE SUBJECT, THE APPELLANT MOST HUMBLY SUBMITS THAT NO PENALTY U/S 158BFA(2) OF THE ACT CAN BE LEVIED AND PRAYS THAT Y OUR HONOUR BE PLEASED TO HOLD SO NOW AND DELETE THE SAME. THE APPELLANT SHALL BE GRATEFUL IF THE ABOVE SUBMIS SIONS ARE CONSIDERED FAVORABLY WHILE DISPOSING FOR THE ABOVE APPEALS, FOR WHICH AC T OF KINDNESS IT SHALL REMAIN GRATEFUL. - 7 - IT(SS)A NO.20/AHD/2015 SHRI CHANDRESH R. JAIN VS. ACIT BLOCK PERIOD 1988- 89 TO 18.11.97 7. IT APPEARS FROM THE RECORDS THAT THE ENTIRE ADDI TION HAS BEEN MADE ON ESTIMATED BASIS ONLY. ADDITION AS UNDISCLOSED INCOME HAS BEEN MADE FOR NET PROFIT EARNED FROM THE LAND TRANSACTION ON THE PRESUMPTION THAT THESE TRAN SACTIONS HAVE BEEN COMPLETED AND INCOME HAS ACCRUED TO THE APPELLANT. THEREFORE, THE ADDITION HAS BEEN WORKED OUT BY ESTIMATING TURNOVER, EXPENSES AND THE NET INCOME ES TIMATED. THE NET PROFIT INITIALLY WAS ESTIMATED BY THE LEARNED AO AT 8%. THE LEARNED CIT( A) IN APPEAL DIRECTED TO ESTIMATE INCOME EARNED FROM LAND TRANSACTION AT 1.5% OF THE TURNOVER. IT WAS FURTHER ASSUMED THAT ON THE AMOUNT RECEIVED AND THE AMOUNT PAID THE ASSE SSEE HAS EARNED 1.5% PROFIT. FURTHERMORE, WHILE CALCULATING THE TURNOVER IT IS O N RECORD THAT THE ESTIMATION AS WELL AS DUPLICATION OF FIGURES WERE THERE IN THE ABSENCE OF COMPLETE CORROBORATIVE EVIDENCES. WHEN THE ADDITION IS MADE ON ESTIMATION WITHOUT ANY CORROBORATING EVIDENCES FOUND DURING THE COURSE OF SEARCH CONDUCTED BY THE REVENU E, THE PENALTY MADE ON SUCH ADDITION IS NOT SUSTAINABLE IN THE EYE OF LAW IN VIEW OF THE RATIO LAID DOWN BY THE JUDGMENT RELIED UPON BY THE LEARNED AR AS CITED HEREINABOVE. WE, AR E THUS OF THE CONSIDERED VIEW TO DELETE THE PENALTY AS LEVIED AGAINST THE ASSESSEE W ITH THE OBSERVATIONS AS ABOVE. HENCE, THE PENALTY IS DELETED. 8. IN THE RESULT, ASSESSEES APPEAL IS ALLOWED. THIS ORDER PRONOUNCED IN OPEN COURT ON 0 4 / 0 4 /201 9 SD/- SD/- ( PRAMOD KUMAR ) ( MS. MADHUMITA ROY ) VICE PRESIDENT JUDICIAL MEMBER AHMEDABAD; DATED 04/04/2019 PRITI YADAV, SR.PS - 8 - IT(SS)A NO.20/AHD/2015 SHRI CHANDRESH R. JAIN VS. ACIT BLOCK PERIOD 1988- 89 TO 18.11.97 / COPY OF THE ORDER FORWARDED TO : 1. / THE APPELLANT 2. / THE RESPONDENT. 3. / CONCERNED CIT 4. () / THE CIT(A)-1, BARODA. 5. , ! ' , #$%% / DR, ITAT, AHMEDABAD 6. &' () / GUARD FILE. / BY ORDER, //TRUE COPY// / (DY./ASSTT.REGISTRAR) !, #$ / ITAT, AHMEDABAD 1. DATE OF DICTATION 24.01.2019 (DICTATION PAGES 6) 2. DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 25.01.2019 3. OTHER MEMBER 4. DATE ON WHICH THE APPROVED DRAFT COMES TO THE SR.P. S./P.S 28/01/2019 5. DATE ON WHICH THE FAIR ORDER IS PLACED BEFORE THE D ICTATING MEMBER FOR PRONOUNCEMENT 6. DATE ON WHICH THE FAIR ORDER COMES BACK TO THE SR.P .S./P.S. 7. DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 8. DATE ON WHICH THE FILE GOES TO THE HEAD CLERK ... 9. THE DATE ON WHICH THE FILE GOES TO THE ASSISTANT RE GISTRAR FOR SIGNATURE ON THE ORDER.. 10. DATE OF DESPATCH OF THE ORDER