Late Smt.Laxmikanwar, Ahmedabad V. The Dy.CIT.,Cent.Circle-1(3), Ahmedabad

ITSSA 6/AHD/2008

• Counselvise Citation: [2010] 124 COUNSELVISE.COM (IT) 8759 (ITAT-AHMEDABAD)
• Duration Of Justice: 2 year(s) 11 month(s)
• Appeal Type: Income Tax (Search & Seizure) Appeal
• Pronouncement Date: 16-12-2010
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: A
• Next Hearing Date: 09-12-2010
• Assessment Year: misc
• Appeal Filed On: 16-01-2008
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Keywords: Unexplained cash credit; Block assessment
• Section: 143(3); 68

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD BENCH A BEFORE SHRI MUKUL KR. SHRAWAT, JUDICIAL MEMBER AND SHRI D.C. AGRAWAL, ACCOUNTANT MEMBER DATE OF HEARING : 09/12/2010 DRAFTED ON: 1 0/12/2010 IT(SS)A NO.06/AHD/2008 BLOCK PERIOD : 01/04/1985 TO 31/03/1995 & UPTO 05/09/1995 LATE SMT. LAXMIKANWAR U.CHAMPAWAT REPRESENTED BY HER LEGAL HEIR SHRI UMEDSINGH CHAMPAWAT 358, CHINUBHAI FARM HOUSE NR.FIRING RANGE HANSOL, AHMEDABADE VS. THE DCIT CENTRAL CIRCLE-1(3) AHMEDABAD PAN/GIR NO. : AAOPC 6179 L ( APPLLELANT ) .. ( RESPONDENT ) ASSESSEE BY : SHRI S.N. SOPARKAR, A.R. REVENUE BY : SHRI ANIL KUMAR, D.R. O R D E R PER SHRI MUKUL KR. SHRAWAT, JUDICIAL MEMBER : THIS IS AN APPEAL AT THE BEHEST OF THE ASSESSEE W HICH HAS EMANATED DIRECTLY FROM AN ASSESSMENT ORDER PASSED U/S.158BC R.W.S. 143(3) AND 254 OF THE I.T.ACT DATED 26/12/2007. 2. AS PER THE GROUNDS OF APPEAL AS MANY AS FIVE G ROUNDS HAVE BEEN RAISED, HOWEVER, GROUND NO.2 IS THE SUBSTANTIVE GRO UND WHICH WAS ARGUED AND, THEREFORE, REPRODUCED BELOW:- IT(SS)A NO.6/AH D/2008 LATE SMT.LAXMIKANWAR U.CHAMPAWAT L/H.SHRI UMEDSINGH CHAMPAWAT VS. DCIT BLOCK PERIOD : 01.04.1985 TO 31.03.95 & UPTO 05.09. 95. - 2 - 2. IN LAW AND IN THE FACTS AND CIRCUMSTANCES OF TH E APPELLANTS CASE, THE LEARNED A.O. HAS ERRED IN ASSESSING THE A MOUNT OF RS.10,61,949/- RECEIVED BY THE APPELLANT BEING UNSECURED LOANS FROM DIFFERENT PERSONS AS APPELLANTS UNDISCLOSED INCOME ON THE GROUND THAT THE SAME WAS UNEXPLAINED CREDITS ASSESSABLE U/S.68 OF THE INCOME-TAX ACT. 2.1. THE LEARNED A.O. HAS FAILED TO APPRECIATE THAT THE AMOUNTS UNDER CONSIDERATION HAVING ALREADY BEEN CONSIDERED FOR THE PURPOSE OF COMPUTING UNDISCLOSED INCOME IN THE CASE OF UMEDSINGH CHAMPAVAT IN THE BLOCK ASSESSMENT ORDER DATED 29/12/2006 ON SUBSTANTIVE BASIS , THERE WAS NOT QUESTION OF TREATING THE SAME AS THE UNDISCLOSED INCOME OF THE APPELLANT EVEN ON PROTECTIVE BASIS. 3. THE ASSESSING OFFICER HAS OBSERVED THAT A NIL R ETURN WAS FILED FOR THE BLOCK PERIOD. AN ASSESSMENT WAS MADE U/S.158B C VIDE AN ORDER DATED 30/09/1996 DETERMINING THE UNDISCLOSED INCOME AT RS.29,36,972/-. THE ADDITION CONSISTED OF AN AMOUNT OF UNEXPLAINED CASH CREDIT OF RS.26,78,041/- STATED TO BE RECEIVED FROM 17 PERSON S. HOWEVER, VIDE AN ORDER OF THE TRIBUNAL DATED 25/10/2010 THE SAID ASS ESSMENT ORDER WAS SET ASIDE. IN CONSEQUENCE, AN ORDER U/S.158BC R.W.S.2 54 WAS MADE VIDE AN ORDER DATED 27/03/2002 AND IN THAT ORDER AS WELL TH E SAME UNDISCLOSED INCOME IN RESPECT OF THE UNEXPLAINED CASH CREDIT WA S IDENTICALLY REPEATED. AGAIN, ASSESSEE HAD GONE IN APPEAL AND THE TRIBUNAL VIDE AN ORDER DATED 04/08/2006 HAD ONCE AGAIN SENT THE ASSESSMENT BACK TO ASSESSING OFFICER WITH CERTAIN DIRECTIONS. THE PRESENT ORDER NOW U NDER APPEAL IS THE CONSEQUENCE OF THE AFOREMENTIONED ORDER OF THE TRIB UNAL. IN THE PRESENT ORDER, AN ADDITION OF RS.10,61,949/- WAS MADE BY IN VOKING THE PROVISIONS OF SECTION 68 OF THE I.T.ACT, HOWEVER, ON PROTECTIVE BASIS. THE IT(SS)A NO.6/AH D/2008 LATE SMT.LAXMIKANWAR U.CHAMPAWAT L/H.SHRI UMEDSINGH CHAMPAWAT VS. DCIT BLOCK PERIOD : 01.04.1985 TO 31.03.95 & UPTO 05.09. 95. - 3 - ASSESSING OFFICER HAS GIVEN A LIST OF NINE PERSONS WHO HAVE BEEN CONSIDERED AS UNEXPLAINED CASH CREDITORS AND THE IM PUGNED ADDITION WAS MADE AS PER THE FOLLOWING OBSERVATIONS:- IN RESPECT OF FOLLOWING PERSONS, AS NO EVIDENCES W ERE FILED EXPLAINING THEIR INVESTMENT, THE ASSESSING OFFICER HAS TREATED THE INVESTMENT AS UNEXPLAINED IN THE CASE OF SHRI U.P.C HAMPAVAT FOR THE BLOCK PERIOD FOR THE REASONS DISCUSSED IN DETAI L THEREIN. SUCH REASONS IN BRIEF ARE REPRODUCED HEREIN IN THE FOLLO WING TABLE: SR.NO. NAME AMOUNT (RS.) REASONS 1. SMT.DARIYAKANWAR KHUSHALSINGH BHAT 70,493 SUMMONS RECEIVED BACK AND INCOMPLETE ADDRESS 2. SHRI CHELSINGH PRAHLADSINGH 1,67,495 DENIED TRANSACTION 3. SHRI JABARSINGH BHAWARSINGH 38,165 SUMMONS RECEIVED BACK AND INCOMPLETE ADDRESS 4. LATE SHRI AMARSINGH SATIDANSINGH 2,00,735 NEITHER ATTENDED NOR REPLY FILED 5. SHRI BHAWANSINGH GORDHANSINGH 1,68,837 SUMMONS RECEIVED BACK AND INCOMPLETE ADDRESS 6. LATE GORDHANSINGH SATIDANSINGH 1,69,190 -DO- 7. SHRI SHIVKANWAR VIRAMSINGH 73,388 -DO- 8. SMT.GULABKANWAR SUMERSINGH 1,42,348 -DO- 9. SMT.LADKANWAR LALSINGH 31,298 NEITHER ATTENDED NOR REPLY FILED TOTAL 10,61,949 AS AN AMOUNT OF RS.10,61,949/- HAS BEEN ADDED ON SU BSTANTIVE BASIS IN THE CASE OF SHRI UMMEDSINGH P.CHAMPAWAT, T HE SAME IS PROPOSED TO BE ADDED IN THE CASE OF ASSESSEE ON PRO TECTIVE BASIS BECAUSE THE CASH CREDITS ARE APPEARING IN THE BOOKS OF ACCOUNT OF IT(SS)A NO.6/AH D/2008 LATE SMT.LAXMIKANWAR U.CHAMPAWAT L/H.SHRI UMEDSINGH CHAMPAWAT VS. DCIT BLOCK PERIOD : 01.04.1985 TO 31.03.95 & UPTO 05.09. 95. - 4 - ASSESSEE IN THE NAMES OF SUCH PERSONS. THE ASSESS EE VIDE HIS WRITTEN SUBMISSIONS DATED 06.11.2007 STATED THAT NO PROTECTIVE ADDITIONS CAN BE MADE IN THE CASE OF ASSESSEE AS TH E NORMS PRESCRIBED BY THE HON'BLE SUPRME COURT IN THE CASE OF ITO V. BACHULAL KAPOOR 60 ITR 74(SC) ARE NOT SATISFIED. THE FACTS OF THE CASE CITED BY THE ASSESSEE ARE NOT APPLICABLE TO TH E FACTS OF THE ASSESSEES CASE. IN THE CASE OF BACHULAL KAPOOR, THE ISSUE INVOLVED WAS ASSESSMENT OF HUF AND THE MEMBERS OF T HE HUF. THUS THE FACTS OF THE ASSESSEES CASE ARE DISTINGUI SHABLE AND THEREFORE THE CONTENTION OF THE ASSESSEE IS REJECTE D. THE ASSESSEE HAS FAILED TO PROVE THE CASH CREDITS IN THE NAME OF THESE PERSONS DESPITE HAVING BEEN GIVEN VARIOUS OPPORTUNITIES DUR ING THE COURSE OF THREE ROUNDS OF ASSESSMENT PROCEEDINGS. SINCE T HE IDENTIFY, CAPACITY AND GENUINENESS OF THE CREDITORS HAVE NEIT HER BEEN PROVED DURING THE COURSE OF ASSESSMENT PROCEEDINGS OF SHRI U.P.CHAMPAVAT NOR DURING THESE PROCEEDINGS, THE CAS H CREDIT AS COMPUTED ABOVE IS ADDED TO THE TOTAL INCOME OF THE ASSESSEE U/S.68 OF THE ACT ON PROTECTIVE BASIS. 3.1. FROM THE ABOVE REPRODUCTION, IT IS EVIDENT THA T A SUBSTANTIVE ADDITION HAVE ALREADY BEEN MADE IN THE CASE OF ON E SHRI UMEDSINGH CHAMPAVAT AND THE ADDITION IN THE HANDS OF THE ASSESSEE WAS O N PROTECTIVE BASIS. 4. WE HAVE HEARD BOTH THE SIDES. WE HAVE CAREFULL Y PERUSED THE RECORDS OF THE CASE. NOW BEFORE US AN ORDER OF ITAT A BENCH AHMEDABAD PRONOUNCED IN THE CASE OF UMEDSINGH CHAM PAWAT VS. ACIT BEARING IT(SS)A 18/AHD/2007 FOR THE BLOCK PERI OD 1.4.1985 TO 5.9.1985 DATED 29/02/2008 IS PLACED ON RECORD. IN THIS JUDGEMENT IN ALL THERE WAS AN ADDITION OF RS.1,17,12,060/- AND THOSE HAVE INCLUDED THE NINE PERSONS WHO HAVE BEEN ASSESSED ON PROTECTIVE BASIS IN THE HANDS OF IT(SS)A NO.6/AH D/2008 LATE SMT.LAXMIKANWAR U.CHAMPAWAT L/H.SHRI UMEDSINGH CHAMPAWAT VS. DCIT BLOCK PERIOD : 01.04.1985 TO 31.03.95 & UPTO 05.09. 95. - 5 - THE ASSESSEE. THE TRIBUNAL HAS FINALLY DELETED TH E ADDITION OF RS.1,17,12,060/- FROM THE HANDS OF SHRI UMEDSINGH C HAMPAWAT I.E. THE HUSBAND OF THE ASSESSEE AND THE RELEVANT PARAGRAPH IS REPRODUCED BELOW:- KEEPING IN VIEW THE ABOVE ORDER OF THE TRIBUNAL IN THE INSTANT CASE, WE FIND THAT THE AO HAS MADE THE ADDITION MA INLY ON THE ADMISSION MADE BY THE ASSESSEE AND HIS ACCEPTANCE I N THE STATEMENT RECORDED U/S.132(4)/131 OF THE ACT. HOW EVER, THE TRIBUNAL HAS ALREADY HELD IN THE INSTANT CASE THAT ADDITION CANNOT BE MADE ON THE BASIS OF THE SAID ADMISSION FOR THE REASONS MENTIONED IN DETAIL IN THE SAID ORDER QUOTED ABOVE. THE TRIBUNAL DIRECTED TO EXAMINE THE VARIOUS PERSONS AND ONLY ON THE BASIS OF THE MATERIAL GATHERED ON EXAMINATION OF THOSE PERSO NS AND AFTER CONFRONTING THOSE MATERIALS TO THE ASSESSEE, THE AD DITION COULD HAVE BEEN MADE IN THE HANDS OF THE ASSESSEE. WE FI ND THAT IN THE INSTANT CASE, NO ADVERSE MATERIAL COULD BE BROUGHT ON RECORD EXCEPT IN THE CASE OF 15 PERSONS, WHO DENIED THE TR ANSACTIONS WITH THE ASSESSEE AND IN RESPECT OF 7 PERSONS IT HAS BEE N STATED THAT SUMMONS COULD NOT BE SERVED BY THE DEPARTMENT. FUR THER IN RESPECT OF THOSE 15 PERSONS, WHO DENIED THE TRANSAC TIONS, THE ASSESSEE EXPLAINED BEFORE THE AO THAT THESE PERSON S HAVE RIGHTLY STATED THAT THEY DO NOT HAVE ANY FINANCIAL TRANSACT IONS WITH THE ASSESSEE AS THEY HAD INVESTED IN THE VARIOUS GROUP CONCERNS OF THE ASSESSEE AND DID NOT HAVE ANY TRANSACTIONS WITH THE ASSESSEE AS AN INDIVIDUAL. THUS, THE STATEMENTS OF THESE FIFTEEN PERSONS CANNOT BE READ AGAINST THE ASSESSEE FOR MAKING ANY ADDITION I N THE HANDS OF THE ASSESSEE. WE FIND THAT THE AO COULD NOT CONTR OVERT THE ABOVE EXPLANATION OF THE ASSESSEE. WE FIND THAT THE EXPL ANATION OF THE ASSESSEE WAS THAT THESE PERSONS HAVE DENIED THE TRA NSACTIONS WITH THE ASSESSEE AND NOT WITH THE COMPANIES WHERE THEY HAVE MADE THE INVESTMENT. THE LEARNED DR COULD NOT BRING AN Y MATERIAL ON RECORD TO SHOW THAT THE ASSESSEE HAD CLAIMED TO HAV E MADE ANY TRANSACTIONS WITH THESE 15 PERSONS IN HIS INDIVIDUA L CAPACITY. THUS, IN OUR CONSIDERED OPINION, THE AO HAS MADE T HE ADDITION WITHOUT PROPERLY APPRECIATING THE EXPLANATION OF TH E ASSESSEE AND THE STATEMENTS OF THESE FIFTEEN PERSONS. IN OUR VI EW, NO ADVERSE IT(SS)A NO.6/AH D/2008 LATE SMT.LAXMIKANWAR U.CHAMPAWAT L/H.SHRI UMEDSINGH CHAMPAWAT VS. DCIT BLOCK PERIOD : 01.04.1985 TO 31.03.95 & UPTO 05.09. 95. - 6 - INFERENCE FROM MERELY SUCH DENIAL IN THE STATEMENTS CAN BE DRAWN AGAINST THE ASSESSEE. IN RESPECT OF SEVEN PERSONS, ON WHOM THE SUMMONS COULD NOT BE SERVED, THE ASSESSEE EXPLAINED THAT THESE SUMMONS COULD NOT BE SERVED EITHER BECAUSE OF INCOM PLETE ADDRESS OR CHANGE IN ADDRESS. HE SUBMITTED THAT THE NEW AN D COMPLETE ADDRESS IN RESPECT THREE PERSONS WERE PROVIDED TO T HE AO ON 22.11.2006 BY WAY OF AFFIDAVIT OF THOSE PERSONS AND SIMILARLY COMPLETE ADDRESS OF FURTHER THREE PERSONS WERE PROV IDED TO THE AO BY WAY OF AFFIDAVIT ON 27.11.2006. HOWEVER, AFTER THIS THE AO HAD NOT ISSUED ANY FRESH SUMMONS TO THESE SIX PERSO NS. IN RESPECT OF THEE ONE PERSON LEFT, THE ASSESSEE POINTED OUT T HAT THIS PERSON APPEARED BEFORE THE A.O. ON 1.3.2006 AND HIS STATEM ENT WAS RECORDED AT THAT TIME WHEREIN HE AFFIRMED THE TRANS ACTION. WE FIND THAT THE EXPLANATION OF THE ASSESSEE COULD NOT BE C ONTROVERTED BY THE REVENUE. IN SUCH CIRCUMSTANCES, IN OUR CONSIDE RED OPINION, THE AO WAS NOT JUSTIFIED IN DRAWING AN ADVERSE INFE RENCE AGAINST THE ASSESSEE. THUS, ON PERUSAL OF MATERIAL ON RECO RD, WE FIND THAT NO ADVERSE MATERIAL COULD BE BROUGHT ON RECORD BY T HE REVENUE AFTER EXAMINING THE PERSONS IN PURSUANCE TO THE TRI BUNALS ORDER DT. 7.4.1998. IN THESE CIRCUMSTANCES, IN OUR CONSI DRED VIEW, IN VIEW OF THE CATEGORICAL DIRECTION OFHTE TRIBUNAL CO NTAINED IN THE ORDER DT. 7.4.1998 THE AO OUGHT NOT TO HAVE MADE A DDITION AGAIN ONLY ON THE BASIS OF THE STATEMENT RECORDED U/S.132 (4)/131 OF THE ACT. HENCE, WE DELETE THE ADDITION OF RS.1,17,12,0 60 IS DELETED. GROUNDS NO.1 AND 2 OF THE APPEAL ARE ACCORDINGLY AL LOWED. 5. WITH THIS BACKGROUND, WE HAVE NOTHING MUCH TO AD D BUT TO FOLLOW THE ORDER OF THE TRIBUNAL AS CITED ABOVE WHEREIN TH E IMPUGNED AMOUNT OF ADDITION WHICH WAS UNDISPUTEDLY MADE ON PROTECTIVE BASIS IN THE HANDS OF THE ASSESSEE NOW STOOD DELETED FROM THE HANDS OF THE HUSBAND, WHEREIN IT WAS ASSESSED ON SUBSTANTIVE BASIS . IN VIEW OF THIS, WE HEREBY HOLD THAT THERE WAS NO OCCASION ON THE PART OF THE REVENUE TO IT(SS)A NO.6/AH D/2008 LATE SMT.LAXMIKANWAR U.CHAMPAWAT L/H.SHRI UMEDSINGH CHAMPAWAT VS. DCIT BLOCK PERIOD : 01.04.1985 TO 31.03.95 & UPTO 05.09. 95. - 7 - ASSESS THE IMPUGNED AMOUNT ON PROTECTIVE BASIS IN THE HANDS OF THE ASSESSEE, THEREFORE, WE HEREBY DIRECT TO DELETE THE ADDITION. THIS GROUND IS ALLOWED. 6. GROUND NO.3 3. IN LAW AND IN THE FACTS AND CIRCUMSTANCES OF T HE APPELLANTS CASE, THE LEARNED A.O. HAS ERRED IN MAKING THE ADDI TION OF RS.37,524/- AS UNEXPLAINED CASH CREDIT WITH REFERENCE TO TWO PERSONS ON THE GROUND THAT THE SAME WERE NOT COVERED IN THE LIST OF PERSONS CONSIDERED IN THE CASE OF UMEDSINGH CHA MPAVAT. HE HAS FAILED TO APPRECIATE THAT THE APPELLANT HAD FUR NISHED NECESSARY DETAILS AND CONFIRMATION WITH REFERENCE TO THESE TW O PERSONS IN THE COURSE OF PRESENT ASSESSMENT PROCEEDINGS AS ALSO EA RLIER ASSESSMENT PROCEEDINGS AND HAVING REGARD TO SUCH DE TAILS THE ADDITION WAS UNWARRANTED. 6.1. IN RESPECT OF THIS GROUND AS WELL THE PAST HIS TORY IS IDENTICAL THAT EARLIER VIDE AN ORDER OF THE TRIBUNAL DATED 25/10/2 000 AND ORDER DATED 04/08/2006, THE ISSUE WAS SET ASIDE AND THE PRESENT ASSESSMENT ORDER IS NOW PASSED CONSEQUENCE UPON THE DIRECTION OF THE TR IBUNAL. THERE WAS SLIGHT VARIATION IN THE SENSE THAT IN THE PAST THE TRIBUNAL HAS RESTORED THE MATTER IN RESPECT OF UNEXPLAINED CASH CREDITS IN TH E NAME OF 67 PERSONS. HOWEVER, THERE WERE TWO MORE PERSONS, NAMELY SHRI M AHENDRA SINGH KAUSHAL SINGH HUF AND SHRI KAUSHAL SINGH JOGSINGH H UF. THEIR CREDITWORTHINESS AND THE IDENTITY, ETC. AS REQUIRED U/S.68 WAS NOT THE SUBJECT MATTER OF THE AFOREMENTIONED APPEALS, THERE FORE, THE ASSESSING OFFICER HAS PROCEEDED TO TAX THE SAME IN THE ABSENC E OF ANY EXPLANATION BEING NOT EARLIER COVERED BY THE ORDER OF THE TRIBU NAL. THE ASSESSING OFFICER HAS, THUS, CONCLUDED THAT THE ASSESSEE HAS FAILED TO PROVE THE IT(SS)A NO.6/AH D/2008 LATE SMT.LAXMIKANWAR U.CHAMPAWAT L/H.SHRI UMEDSINGH CHAMPAWAT VS. DCIT BLOCK PERIOD : 01.04.1985 TO 31.03.95 & UPTO 05.09. 95. - 8 - IDENTITY AND GENUINENESS OF THOSE PERSONS, THEREFOR E, THE DEPOSITS WERE UNEXPLAINED CASH CREDIT IN THE HANDS OF THE ASSESSE E. BEFORE US, THE ONLY ARGUMENT OF THE LEARNED AUTHORISED REPRESENTATIVE O F THE ASSESSEE IS THAT THEIR CONFIRMATION LETTERS WERE ON RECORD AND THE ASSESSING OFFICER SHOULD NOT HAVE TREATED THE AMOUNT AS UNEXPLAINED C ASH CREDIT IN THE HANDS OF THE ASSESSEE. COPIES OF THOSE CONFIRMATIO NS ARE IN THE COMPILATION. ON CAREFUL EXAMINATION OF THOSE CONFI RMATIONS, WE HAVE NOTICED THAT THEY ARE CONFIRMATION OF ACCOUNTS WH EREIN AT THE END A SIGNATURE HAS BEEN OBTAINED SIMPLY CONFIRMING THE T RANSACTIONS RECORDED IN THE ACCOUNT STATEMENT. APART FROM THIS, THERE IS NO OTHER EVIDENCE THROUGH WHICH A PROPER IDENTITY, CREDITWORTHINESS A ND THE OTHER INGREDIENTS AS REQUIRED U/S.68 OF THE I.T.ACT AS AL SO THE GENUINENESS OF THE TRANSACTIONS COULD BE ESTABLISHED. IN THE AB SENCE OF SUCH DETAILS, WE ARE UNABLE TO ACCEPT THE EXPLANATION OF THE ASSESSE E AND HEREBY CONFIRM THE ACTION OF THE ASSESSING OFFICER. THIS GROUND IS DISMISSED. 7. IN THE RESULT, THE APPEAL OF THE ASSESSEE I S PARTLY ALLOWED. ORDER SIGNED, DATED AND PRONOUNCED IN THE COURT ON 16/ 12 /2010. SD/- SD/- ( D.C. AGRAWAL) ( MUKUL KR. SH RAWAT ) ACCOUNTANT MEMBER JUDICIAL MEMBE R AHMEDABAD; DATED 16 / 12 /2010 T.C. NAIR, SR. PS IT(SS)A NO.6/AH D/2008 LATE SMT.LAXMIKANWAR U.CHAMPAWAT L/H.SHRI UMEDSINGH CHAMPAWAT VS. DCIT BLOCK PERIOD : 01.04.1985 TO 31.03.95 & UPTO 05.09. 95. - 9 - COPY OF THE ORDER FORWARDED TO : 1. THE ASSESSEE. 2. THE DEPARTMENT. 3. THE CIT CONCERNED 4. THE LD. CIT(APPEALS)-CONCERNED 5. THE DR, AHMEDABAD BENCH 6. THE GUARD FILE. BY ORDER, //TRUE COPY// (DY./ASSTT.REGISTRAR), ITAT, AHMEDABAD 1. DATE OF DICTATION..10/12/2010 2. DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 10/12/2010 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 THE D ICTATING MEMBER FOR PRONOUNCEMENT 5. DATE ON WHICH THE FAIR ORDER COMES BACK TO THE SR.P .S./P.S16/12/10 6. DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 16/12/10 7. DATE ON WHICH THE FILE GOES TO THE HEAD CLERK . 8. THE DATE ON WHICH THE FILE GOES TO THE ASSISTANT RE GISTRAR FOR SIGNATURE ON THE ORDER.. 9. DATE OF DESPATCH OF THE ORDER