THE ACIT, CC-1(3), Ahmedabad V. SHRI JOHNSON PHILIP, Ahmedabad

ITSSA 331/AHD/2002

• Counselvise Citation: [2012] 124 COUNSELVISE.COM (IT) 7827 (ITAT-AHMEDABAD)
• Duration Of Justice: 9 year(s) 1 month(s) 19 day(s)
• Appeal Type: Income Tax (Search & Seizure) Appeal
• Pronouncement Date: 25-01-2012
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Next Hearing Date: 24-11-2011
• Assessment Year: misc
• Appeal Filed On: 06-12-2002
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: ALOK JOHRI
• Assessee Lawyers: PF JAIN
• Keywords: Loose papers; Document seized; Documents seized

Judgement Text

, , , , IN THE INCOME TAX APPELLATE TRIBUNAL B BENCH, AHMEDABAD BEFORE SHRI G.C.GUPTA VICE-PRESIDENT(AZ) AND SHRI A. MOHAN ALANKAMONY, ACCOUNTANT MEMBER ./ I.T.(SS)A. NO.331/AHD/2002 (BLOCK ASST.PERIOD : 1989-90 TO 1998-99 & UPTO 10/9 9) THE ACIT CENTRAL CIRCLE-1(3) AHMEDABAD / VS. SHRI JOHNSON PHILIP 306, AWAS APTS., BAIKAKANAGAR THALTEJ, AHMEDABAD ./ ./ PAN/GIR NO. : AAZPP 4459 P ( ! / // / APPELLANT ) .. ( '#! / RESPONDENT ) ! $ / APPELLANT BY : SHRI ALOK JOHRI, CIT-D.R. '#! % $ / RESPONDENT BY : SHRI P.F. JAIN &'( % )* / / / / DATE OF HEARING : 24/11/2011 +,- % )* / DATE OF PRONOUNCEMENT : 25/01/2012 . / O R D E R PER SHRI A. MOHAN ALANKAMONY, AM : THIS APPEAL OF THE REVENUE IS DIRECTED AGAINST THE IMPUGNED ORDER OF THE LD. CIT (A)-I, AHMEDABAD IN APPEAL NO. CIT(A)-I /CC 1(3)/162/2001-02 DATED 27.9.2002 FOR THE BLOCK PERIOD FROM 1989-90 T O 98-99 (UP-TO 10/99). 2. THE REVENUE HAS RAISED EIGHT GROUNDS. GROUND NOS.7 AND 8 BEING GENERAL IN NATURE AND NO SPECIFIC ISSUES INVOLVED, THEY HAVE BECOME NON- CONSEQUENTIAL. THE REMAINING GROUNDS ARE REFORMULA TED AS UNDER: THE LD. CIT (A) HAS ERRED IN LAW AND IN FACTS IN DELETING THE ADDITION OF: IT(SS))A NO.331/AHD/2002 THE ACIT VS. SHRI JOHNSON PHILIP BLOCK PERIOD 89-90 TO 98-99 & UPTO 10.99 - 2 - (1) RS.11,49,500/- MADE ON ACCOUNT OF PURCHASE OF T HE PROPERTY AT SHYAMVAN RACHARDA; (2) RS.8,35,000/- BASED ON ENTRIES IN PAGE NO.17 OF SEIZED FILE BEARING NO.A-3; (3) RS.5,50,000/- BASED ON ENTRIES IN PAGE NO.18 OF SEIZED FILE BEARING NO.A-3; (4) RS.87,100/- BASED ON NOS.10, 11 & 12 OF THE SEI ZED FILE BEARING NO.A-3; (5) RS.92,010/- ON ACCOUNT OF UNEXPLAINED PURCHASE OF PROCURED THREAD RUBBER; & (6) RS.50,000/- ON ACCOUNT OF DEMAND DRAFTS PREPARE D IN THE NAME OF MRS. ANNAMMA CHAKO. 3. BEFORE VENTURE TO TAKE UP THE ABOVE GROUNDS FOR ADJUDICATION, WE WOULD LIKE TO RECOUNT THE EVENTS WHICH TOOK PLACE D URING THE INTERVENING PERIOD. THE EARLIER BENCH IN ITS INITIAL FINDINGS DATED: 23.2.2010 CONSIGNED THE REVENUES APPEAL TO RECORD WITH LIBERTY TO MAKE ALL RELEVANT CORRECTIONS IN THE APPEAL PAPERS IN ITS APPEAL AND THEN MAKE A REQUEST FOR REVIVAL OF THE APPEAL FOR DISPOSAL AND ITS SUBSEQUENT MISC. ORDER DATED 1 1.2.2011, THE BENCH RECALLED ITS EARLIER ORDER DATED 23.2.2010 ON THE D .RS PREMISE THAT ALL THE PAPERS ARE CORRECTED AND, THEREFORE, THE DEPARTMENT AL APPEAL MAY BE REVIVED. ACCORDINGLY, THE REGISTRY WAS DIRECTED TO FIX THE D EPARTMENTAL APPEAL FOR HEARING. THUS, THE PRESENT APPEAL OF THE REVENUE H AS NOW COME UP BEFORE THIS BENCH FOR ADJUDICATION. 4. WE SHALL NOW PROCEED TO ADJUDICATE THE ISSUES CH RONOLOGICALLY AS UNDER: BRIEFLY STATED, THE ASSESSEE, A N INDIVIDUAL, WAS IN THE BUSINESS OF ELECTRONIC GOODS. THERE WAS AN ACTION U/S 132(1) O F THE ACT IN HIS PREMISES IT(SS))A NO.331/AHD/2002 THE ACIT VS. SHRI JOHNSON PHILIP BLOCK PERIOD 89-90 TO 98-99 & UPTO 10.99 - 3 - WHICH HAD RESULTED IN THE INITIATION OF PROCEEDINGS FOR THE BLOCK PERIOD BY ISSUANCE OF NOTICE U/S 158BC OF THE ACT. 4.1. AFTER DUE CONSIDERATION OF THE ASSESSEES CONT ENTIONS, AS RECORDED IN HIS IMPUGNED ORDER UNDER DISPUTE, THE AO HAD MADE T HE FOLLOWING ADDITIONS: (1) PURCHASE OF PROPERTY AT SHYAMVAN, RACHARDA OF RS.11,49,500/- , TRANSACTIONS APPEARING ON PAGES 17 & 18 OF LOO SE PAPER FILE A-3 OF RS. 8,35,000 & RS.5,50,000 RESPECTIVELY: ( I ) AN ADDITION OF RS.11,49,500/- WAS MADE FOR THE PU RCHASE OF PROPERTY AT SHYAMVAN RACHERDA ON THE BASIS OF LOOSE PAPERS UNEARTHED BY OBSERVING THAT THE ASSESSEE HAD ACQUIR ED 2 PLOTS; THAT BY HOLDING THAT THE TOTAL PAYMENT OF RS.8,47,000/- (BL ACK) AND RS.3,02,500/- (WHITE) WAS MADE BY THE ASSESSEE OUT OF HIS UNDISCLOSED SOURCES. ( II ) AN ADDITION OF RS.8,35,000/- WAS MADE ON THE BASI S OF PARTICULARS OF PAYMENTS TO KMS AS CONTAINED IN PAGE 17 OF ANNEX URE A-3 ON THE GROUND THAT NEITHER ANY DISCUSSION EMERGED IN RESPE CT OF SPECIFIC DATE- WISE PAYMENTS TO KMS NOR THE IDENTITY OF KMS. ( III ) THERE WERE RECEIPT OF AMOUNT FROM ONE GK ON FOUR OCCASIONS, AMOUNTING TO RS.5,50,000/- WHICH WAS CONTENDED BY T HE ASSESSEE THAT HE HAD BORROWED THE MONEY FROM GEORGE KUTTY. HOWEV ER, THE ASSESSEE HAD FAILED TO PROVE THAT THESE BORROWINGS WERE ACCOUNTED FOR AND TO EVIDENCE THE CREDITWORTHINESS OF GK, THE SAM E WAS TREATED AS UNEXPLAINED INCOME FOR THE BLOCK PERIOD. IT(SS))A NO.331/AHD/2002 THE ACIT VS. SHRI JOHNSON PHILIP BLOCK PERIOD 89-90 TO 98-99 & UPTO 10.99 - 4 - ( A ) IT WAS CONTENDED BY THE ASSESSEE DURING THE COUR SE OF APPELLATE PROCEEDINGS THAT THE AO ERRED IN RELYING ON PRESUMP TION U/S 132(4A)(II) BECAUSE THE CONTENTS OF SAID DOCUMENT OF ANNEXURE A -3 PAGE 9 AND 18 DID NOT EXPLAIN AND THE SAID DOCUMENT NOT CONTAI NED REGARDING OWNERSHIP OF PLOT OF LAND AND ALSO THE AO HAD NOT M ADE ANY INVESTIGATION AS TO THE OWNERSHIP OF PLOT WHEN EVID ENCE IN THE FORM OF DD WAS GIVEN BY WHICH THE BURDEN OF PROVING THAT TH E PLOT WAS OF THE ASSESSEE GOT TRANSFERRED TO THE REVENUE. ( B ) WITH REGARD TO ADDITION OF RS.8.35 LAKHS, IT WAS CONTENDED BY THE ASSESSEE THAT THE AO HAD IGNORED THE SUBMISSION MA DE BY THE ASSESSEE DURING THE COURSE OF ASSESSMENT PROCEEDING S. ( C ) IN RESPECT OF ADDITION OF RS.5,50,000/- IT WAS S UBMITTED THAT THE AO MADE THE ADDITION ON THE BASIS OF DOCUMENTS AT PAGE 18 OF FILE A-3 WHICH DID NOT SHOW EITHER PAYMENT OR RECEIPT. HE H AD MERELY STATED IN HIS ORDER RECEIVED FROM GK. AFTER DUE CONSIDERATION OF THE ASSESSEE S CONTENTIONS AS DETAILED IN HIS IMPUGNED ORDER UNDER DISPUTE, THE CIT (A) IN HI S COMMUNICATION DATED 23.8.2002 REQUIRED THE AO TO FURNISH HIS REPORT ON THE QUERY THAT: (ON PAGE 16) IT IS SEEN THAT ADDITIONS OF RS.11,49 ,500/-, RS.8,35,000/- AND RS.5,50,000/- ARE IN FACT RELATED TO THE SAME ITEM I.E., PURCHASE OF PROPERTY. IT APPEARS THAT SAME I TEMS WHICH ARE INCLUDED IN THE SUM OF RS.11,49,500/- HAD BEEN ADDE D TWICE OVER. BESIDES THIS, IT IS CLEAR THAT BOTH THE PROPERTIES ARE OWNED BY OTHER PERSONS WHO ARE SEPARATELY ASSESSED TO TAX. YOU WOULD, THEREFORE, PLEASE SUBMIT YOUR REPORT ON THE MERITS AS WELL AS QUANTUM OF ADDITIONS. IT(SS))A NO.331/AHD/2002 THE ACIT VS. SHRI JOHNSON PHILIP BLOCK PERIOD 89-90 TO 98-99 & UPTO 10.99 - 5 - THE AO IN HIS COMPLIANCE DATED 19.9.200 2, AMONG OTHERS, REVEALED THAT THE ASSESSEES SUBMISSION MAY, HOWEVER, BE CONSIDER ED ON MERITS AND THE FACTS OF THE CASE AS MENTIONED IN THE ASSESSMEN T ORDER. AFTER CONSIDERING THE ISSUE IN DEPTH, THE CIT (A) OBSERVED THAT: (ON PAGE 16)FIRST OF ALL, IT HAS TO BE POINTE D OUT THAT IF AT ALL ANY ADDITION WAS REQUIRED TO BE MADE THEN ON LY THE HIGHEST OF THE THREE AMOUNTS COULD HAVE BEEN ADDED AS THE O THER TWO AMOUNTS ARE ONLY PART AND PARCEL OF THE SAME TRANSA CTIONS AT TWO OTHER PLACES. HOWEVER, THE BASIC ISSUE IS THAT TH E PLOTS DO NOT BELONG TO THE APPELLANT AS THEY BELONG TO TWO OF TH E FAMILY MEMBERS WHO ARE LIABLE TO BE ASSESSED SEPARATELY AS FROM NONE OF THE DETAILS IT IS SEEN THAT ANY INVESTMENT WAS M ADE BY THE APPELLANT. IN HIS REPORT, THE ASSESSING OFFICER CO ULD NOT POINT OUT ANY DEFECTS OR MIS-STATEMENT OF FACTS IN APPELLANT S SUBMISSIONS. HENCE ADDITION, IF REQUIRED TO BE MADE, COULD BE MA DE ONLY IN THE HANDS OF REAL OWNERS WHOSE NAMES AND ADDRESSES ARE VERY WELL WITHIN THE ASSESSING OFFICERS KNOWLEDGE. THUS, TH ESE ADDITIONS ARE HELD TO BE UNJUSTIFIED IN APPELLANTS HANDS AND ALL THESE THREE ADDITIONS ARE DELETED. DURING THE COURSE OF HEARING BEFORE THI S BENCH, NO DISCREET DOCUMENTARY WAS PRODUCED TO REBUT THE FINDING OF TH E CIT (A) EXCEPT ASSERTING THAT THE CIT (A) ERRED IN LAW AND ON FACT S IN DELETING THE ADDITIONS MADE BY THE AO. ON THE OTHER HAND, IT WAS EXPLAINED ON B EHALF OF THE ASSESSEE THAT THOSE TWO PLOTS WERE OWNED BY JOHN MATHEW ALIAS GEO RGE KUTTY AND ANOTHER BY MISS SALLY JOHNSON AND THE PAYMENTS WERE MADE TH ROUGH CHEQUES, THE DETAILS OF WHICH WERE ENLISTED IN THE CIT(A) IMPUG NED ORDER. AFTER DUE CONSIDERATION OF SUBM ISSIONS OF EITHER PARTY, PERUSAL OF THE RELEVANT CASE RECORDS AND ALSO THE OBSERVATIONS OF THE CIT (A), WE ARE OF THE FIRM VIEW THAT THE TWO PLOTS ALLEGED TO HAVE BE EN BELONGED TO THE IT(SS))A NO.331/AHD/2002 THE ACIT VS. SHRI JOHNSON PHILIP BLOCK PERIOD 89-90 TO 98-99 & UPTO 10.99 - 6 - ASSESSEE WERE, IN FACT, BELONGED TO JOHN MATHEW ALI AS GEORGE KUTTY AND MISS. SALLY JOHNSON AND THE PAYMENTS WERE EVIDENCED TO BE THROUGH CHEQUES. INCIDENTALLY, THE AO IN HIS REPORT DATED 19.9.2002 CONCEDED THAT THE ASSESSEES SUBMISSION MAY, HOWEVER, BE CONSIDER ED ON MERITS. TAKING ALL THESE ASPECTS INTO CONSIDERAT ION, WE ARE OF THE FIRM VIEW THAT THE AO WAS NOT JUSTIFIED IN MAKING THE ADDITIONS OF RS.11.49 LAKHS, RS.8.35 LAKHS AND RS.5.50 LAKHS IN A ROUTINE MANNER WITHOUT ESTABLISHING WITH THE DOCUMENTARY EVIDENCES TO PROVE THAT THE ASSESSEE HA D, IN FACT, ACQUIRED TWO PLOTS. WE, THEREFORE, SUSTAIN THE FINDING OF THE C IT (A) ON THIS SCORE. ACCORDINGLY, THE THREE GROUNDS OF THE REVENUE ARE D ECIDED AGAINST IT. ( 2 ) ADDITION OF RS.87,100/ -: THE ADDITION OF RS.87,100/- WAS MADE BY T HE AO ON THE GROUND THAT AN EXPENDITURE OF RS.87,100/- HAS BEEN INCURRED BY THE ASSESSEE FOR WHICH NO DOCUMENTARY EVIDENCE TO ESTAB LISH ITS SOURCE WAS FORTHCOMING. HOWEVER, IT WAS EXPLAINED BY THE ASSESSEE BEFORE TH E CIT (A) THAT THERE WERE TWO BILLS NO.105 DT. 20.2 12.95 FOR RS.52,700/- AND BILL NO.187 DT.126.2.96 FOR RS.34,400/- IN THE NAME OF THE ASSESSEE WHEREIN IT HAS BEEN MENTIONED THAT THOSE BILLS BEING HYPOTHECATED WITH UNION BANK OF INDIA AND BOMBAY ME RCANTILE BANK RESPECTIVELY. IT WAS, FURTHER, EXPLAINED THAT THOS E WERE CREDIT BILLS FOR WHICH PAYMENTS WERE TO BE MADE BY THE RESPECTIVE BA NKS DIRECTLY TO THE SUPPLIERS AND, HENCE, THE ADDITION OF THESE BIL LS AS UNDISCLOSED EXPENDITURE BEING ERRONEOUS. IT(SS))A NO.331/AHD/2002 THE ACIT VS. SHRI JOHNSON PHILIP BLOCK PERIOD 89-90 TO 98-99 & UPTO 10.99 - 7 - AFTER CONSIDERING THE ASSESSEES EXPLANATION AND PE RUSING THE COPIES OF SEIZED DOCUMENTS, THE CIT (A) HAD OBSERVE D THAT (ON PAGE 20) IF THE HEAD NOTES ON THESE BILL NOS.105 AND 187 IS SEEN, IT IS FOUND THAT IT SHOWS THAT THESE ARE FOR HYPOTHECATIO N WITH BANKS AS THIS FACT IS CATEGORICALLY MENTIONED. THIS ITSEL F SHOWS THAT THE AMOUNT IN QUESTION HAS TO BE PAID BY THE RESPECTIVE BANKS AND NOT APPELLANT... NO DOCUMENTARY EVIDENCE HAS BEEN BROUGHT ON RECORD BY THE REVENUE TO REBUT THE FINDING OF THE CIT (A) ON THIS POINT. IN THESE CIRCUMSTANCES, WE HAVE BEEN LEFT WITH NO OPTION EXC EPT TO SUSTAIN THE FINDING OF THE CIT (A) ON THIS SCORE. IT IS ORDERE D ACCORDINGLY. ( 3 ) ADDITION OF RS.92,010/ -: BRUSHING ASIDE THE ASSESSEES CONTENTION THAT IT W AS A MEMORANDUM OF RUBBER SENT BY A.M. RAJU OF KERALA FOR SALES ON HIS BEHALF; THAT THE AMOUNT OF RS.40000/- COLLECTED WAS GIVEN TO RAJU AN D FOR THE BALANCE AMOUNT, THE MATERIAL HAS BEEN TAKEN BACK BY HIM ETC ., THE AO TOOK A VIEW THAT NO EVIDENCE WAS FURNISHED IN SUPPORT OF T HE CONTENTION THAT THOSE SALES HAVE BEEN EFFECTED ON BEHALF OF RAJU. IT WAS, FURTHER, OBSERVED THAT NO NAME APPEARED ON THE PAPER SEIZED FROM THE ASSESSEES PREMISES AND THE ASSESSEE HAD FAILED TO EXPLAIN SATISFACTORILY THAT THE SALES WERE EFFECTED ON BEHA LF OF SOMEONE-ELSE, THE SALE PROCEED OF RS.92,010/- WAS, THEREFORE, TRE ATED AS UNDISCLOSED INCOME OF THE ASSESSEE. IT(SS))A NO.331/AHD/2002 THE ACIT VS. SHRI JOHNSON PHILIP BLOCK PERIOD 89-90 TO 98-99 & UPTO 10.99 - 8 - IT WAS EXPLAINED BEFORE THE CIT (A) THAT THE RUBBER RECEIVED FROM A.M. RAJU OF KERALA WAS SOLD TO THE WORTH OF RS.40000/- AND THE BALANCE BEING UNSOLD WAS RETURNED TO RAJU. THIS HA S BEEN CONFIRMED BY RAJU IN HIS LETTER. THE ABOVE FACT WAS CONFRONT ED WITH THE AO WHO IN HIS REPORT STATED THAT THE MATTER BE DECIDED ON MERITS. CONSIDERING THE CONFIRMATION LETTER OF RAJU WHI CH CONTAINED HIS COMPLETE ADDRESS AND ALSO THE AO HAD NOT COMMENTED ADVERSELY, THE CIT (A) HAD ACCEPTED THE ASSESSEES VERSION ON THE ISSUE AND, ACCORDINGLY, DELETED THE ADDITION OF RS.92,010/-. SINCE NO FRESH DOCUMENTARY EVIDENCE HAS BEEN ADDUC ED BY THE REVENUE TO CHALLENGE THE FINDING OF THE CIT (A) AND ALSO THE AO HAD NOT, IN HIS REPORT, REFUTED THE ASSESSEES CLAIM, W E AGREE WITH THE FINDING OF THE CIT(A) ON THIS POINT. ( 4 ) ADDITION OF RS.50,000/ -: IT WAS THE CASE OF THE AO THAT COPIES OF DEMAND DRA FTS PREPARED IN THE NAME OF MRS. ANNAMMA CHACKO WERE SEIZED AND THE ASSESSEE WAS REQUIRED, VIDE ORDER SHEET ENTRY DATED 14.10.20 01, TO EXPLAIN THE PURPOSE OF THE DDS SENT TO MRS. CHACKO AND SINCE TH ERE WAS NO SUBMISSION ON THE ISSUE, THE DRAFT AMOUNT OF RS.500 00/- WAS TREATED AS UNEXPLAINED INCOME OF THE ASSESSEE. IT WAS CONTESTED DURING THE COURSE OF APPELLATE PRO CEEDINGS BEFORE THE CIT (A) THAT NO EXPLANATION WHATSOEVER W AS SOUGHT BY THE AO; THAT WITH REGARD TO THE DEMAND DRAFTS STOOD IN THE NAME OF MRS. CHAKO, IT WAS EXPLAINED THAT THE CERTIFICATE OF IND IAN OVERSEAS BANK IT(SS))A NO.331/AHD/2002 THE ACIT VS. SHRI JOHNSON PHILIP BLOCK PERIOD 89-90 TO 98-99 & UPTO 10.99 - 9 - DT.22.6.2002 CONFIRMS THAT THE DEMAND DRAFT WAS PUR CHASED BY ABEY MATHEW JACOB FOR RS.19,000/- AND THE CERTIFICATE DT .27.6.2002 OF INDIAN OVERSEAS BANK, ASHRAM ROAD BRANCH CONFIRM TH AT THE DEMAND DRAFT OF RS.19000/- PURCHASED BY SHISU B.SAM AND AN OTHER DEMAND DRAFT OF RS.12,000/- PURCHASED BY V. YASUDAS AND, T HUS, THE THREE DEMAND DRAFTS AGGREGATING TO RS.50000/- DID NOT PER TAIN TO THE ASSESSEE AT ALL. ON CONSIDERING THE ASSESSEES EXPLANATION AND ALSO PERUSING THE AOS COMMENTS ON THE ISSUE, THE CIT (A) HAS OBSERVE D: (PARA 10 ON PAGE 26) ON PERUSAL OF ORDER, I FIND THAT THOUGH THE ASSESSING OFFICER HAS MENTIONED THAT APPELLANT WAS ASKED TO EXPLAIN THESE DRAFTS VIDE ORDER SHEET ENTRY DT: 14. 10.2001, BUT, I FIND THAT THERE IS NO SUCH ENTRY DT: 14.10.2001 ON THE O RDER THAT AND VIDE ENTRY DATED 15.10.01, NO SUCH EXPLANATION WAS SOUGH T. IT IS CLEAR THAT THIS ADDITION HAS BEEN MADE WITHOUT CONFRONTIN G THE APPELLANT. BANK CERTIFICATES ALSO PROVE THAT NONE OF THESE DRA FTS WERE PURCHASED BY THE APPELLANT. AS POINTED OUT EARLIER, SINCE NO FRESH DOCUMENTARY EVIDENCE HAS BEEN BROUGHT ON RECORD BY THE REVENUE TO REPUDI ATE THE FINDING OF THE CIT (A) AND ALSO THE AO ALSO REPORTED, IN HIS R EPORT, THAT THE MATTER MAY BE DECIDED ON MERITS, THE FINDING OF THE CIT(A) ON THIS POINT REQUIRES TO BE SUSTAINED. IT IS ORDERED ACCORDINGL Y. 5. IN THE RESULT, THE REVENUES APPEAL IS DISMISSED. ORDER PRONOUNCED IN THE COURT TODAY ON 25/ 1 /2012. SD/- SD/- ( G.C. GUPTA ) ( A. MOHAN ALANKAMONY) VICE PRESIDENT [AZ] ACCOUNTANT MEMBER AHMEDABAD; DATED / /2012 IT(SS))A NO.331/AHD/2002 THE ACIT VS. SHRI JOHNSON PHILIP BLOCK PERIOD 89-90 TO 98-99 & UPTO 10.99 - 10 - /*.., '.../ T.C. NAIR, SR. PS . % ')0 10-) . % ')0 10-) . % ')0 10-) . % ')0 10-)/ COPY OF THE ORDER FORWARDED TO : 1. ! / THE APPELLANT 2. '#! / THE RESPONDENT. 3. ) &2 / CONCERNED CIT 4. &2() / THE CIT(A)-I, AHMEDABAD 5. 0'56 ') , , / DR, ITAT, AHMEDABAD 6. 678 9( / GUARD FILE. .& .& .& .& / BY ORDER, #0) ') //TRUE COPY// : :: :/ // / (DY./ASSTT.REGISTRAR) , , , , / ITAT, AHMEDABAD 1. DATE OF DICTATION.. 2. DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE T HE DICTATING MEMBER OTHER MEMBER 3. DATE ON WHICH THE APPROVED DRAFT COMES TO THE SR.P.S./P.S.. 4. DATE ON WHICH THE FAIR ORDER IS PLACED BEFORE TH E DICTATING MEMBER FOR PRONOUNCEMENT 5. DATE ON WHICH THE FAIR ORDER COMES BACK TO THE SR.P.S./P.S.25.1.12 6. DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 25.1.12 7. DATE ON WHICH THE FILE GOES TO THE HEAD CLERK . 8. THE DATE ON WHICH THE FILE GOES TO THE ASSISTANT REGISTRAR FOR SIGNATURE ON THE ORDER.. 9. DATE OF DESPATCH OF THE ORDER