B.L. Rai , Bhopal V. ACIT 2 (1), Bhopal

ITSSA 94/Ind/2018

• Counselvise Citation: [2019] 117 COUNSELVISE.COM (IT) 5781 (ITAT-INDORE)
• Duration Of Justice: 11 month(s) 1 day(s)
• Appeal Type: Income Tax (Search & Seizure) Appeal
• Pronouncement Date: 09-05-2019
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: DB
• Assessment Year: 2009-2010
• Appeal Filed On: 08-06-2018
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Assessee Lawyers: S S DESH
• Keywords: Rejection of books of accounts; Unexplained investment
• Section: 142(1); 69; 132

Judgement Text

[IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] , , IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER AND SHRI MANISH BORAD, ACCOUNTANT MEMBER IT(SS)A NOS.89 TO 95/IND/2018 ASSESSMENT YEARS: 2004-05 TO 2010-11 B.L. RAI AH-14, RAJIV NAGAR AYODHYA BY PASS BHOPAL M.P. / VS. ACIT - 2(1) BHOPAL ( APPELLANT ) ( REVENUE ) P.A. NO. AHMPR6654E APPELLANT BY SHRI S.S. DESHPANDE, A.R. RESPONDENT BY SMT. ASHIMA GUPTA, CIT(DR) DATE OF HEARING: 06.05.2019 DATE OF PRONOUNCEMENT: 09.05.2019 / O R D E R PER KUL BHARAT, J.M: THIS BUNCH OF 7 APPEALS FILED BY THE ASSESSEE ARE AGAINST ORDER OF THE CIT(A)-1, BHOPAL DATED 15.5.2018 PERTAINING TO THE ASSESSMENT YEARS 2004-05 TO 2010-11. [IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] 2 THE IDENTICAL GROUNDS ARE RAISED EXCEPT FIGURES IN ALL THESE APPEALS. ALL THE APPEALS WERE HEARD TOGETHER AND ARE BEIN G DISPOSED OFF BY WAY OF CONSOLIDATED ORDER FOR THE SAK E OF CONVENIENCE. FIRST WE TAKE UP THE ASSESSEES APPEAL IN IT(SS)A NO.89/IND/2018 PERTAINING TO THE ASSESSMENT YEAR 2004-05. THE ASSESSEE HAS RAISED FOLLOWING GROUNDS OF APPEAL: 1. THAT ON FACTS AND IN THE CIRCUMSTANCES OF THE CASE OF THE ASSESSEE THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) 1 WAS NOT JUSTIFIED IN CONFIRMING THE ADDITION OF CASH BALANC E TO THE EXTENT OF RS.53,000/-. 2. THAT ON FACTS AND IN THE CIRCUMSTANCES OF THE CASE THE ASSESSEE THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) 1 WAS NOT JUSTIFIED IN CONFIRMING THE ADDITION OF RS.1,20,000/- TOWARDS UN EXPLAINED HOUSEHOLD EXPENSES. 3. THE ASSESSEE CRAVES LEAVE TO ADD, ALTER AMEND OR WI THDRAW ANY GROUND OF APPEAL ON OR BEFORE THE TIME OF HEARING. 2. BRIEF FACTS OF THE CASE ARE THAT A SEARCH U/S 132 OF T HE INCOME TAX ACT, 1961 (HEREINAFTER CALLED AS THE ACT) WAS CARRIED OUT AT THE RESIDENTIAL PREMISES OF THE ASSESSEE ON 23.7.2009. THE ASSESSEE HAS FILED RETURN OF INCOME O N 3.8.2011 DECLARING TOTAL INCOME OF RS.6,31,130/-. TH E CASE [IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] 3 WAS SELECTED FOR SCRUTINY AND NOTICES U/S 143(2) R.W. S. 142(1) OF THE ACT WERE ISSUED. IN RESPONSE TO THE ABOVE NOTICES, AUTHORISED REPRESENTATIVE OF THE ASSESSEE SUBMITTED CERTAIN DETAILS TO THE ASSESSING OFFICER. D URING THE COURSE OF ASSESSMENT PROCEEDINGS, THE ASSESSEE HAS SUBMITTED BALANCE SHEET, CASH BOOK AND OTHER ACCOUNTS BUT NO BOOKS OF ACCOUNTS WERE FOUND DURING THE COURS E OF SEARCH AT THE RESIDENCE OF THE ASSESSEE AND NO BOOKS OF ACCOUNTS ARE MAINTAINED BY HIM. FURTHER, AS AND WHEN ASSESSEE WAS SHORT OF CASH HE HAS SHOWN MISCELLANEOUS RECEIPTS, WHICH ARE SHOWN AS UNDER: S.NO. DATE AMOUNT (RS.) 1 04.01.2008 1,50,000/ - CASH 2 04.04.2008 78,000/ - CASH 3 05.05.2008 78,000/ - CASH 4 04.04.2009 2,42,000/ - CASH 5 05.05.2009 1,00,000/ - CASH 6 07.07.2009 1,00,000/ - CASH TOTAL 7,48,000/ - CASH [IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] 4 THE ASSESSEE HAS NOT SHOWN ANY AMOUNT WHATSOEVER, ON ACCOUNT OF HOUSEHOLD EXPENDITURE INCLUDING THE AMOUNTS SPENT ON EDUCATION OF CHILDREN, ELECTRICITY, MILK, VEGETABLES AND FRUITS, WATER CHARGES, MAINTENANCE OF HOUSE, MEDICINE, COMMUTING, ATTENDING SOCIAL FUNCTION S AND EXPENDITURE ON OUTINGS/ENTERTAINMENT ETC., WHICH ARE REQUIRED TO BE INCURRED. IN VIEW OF THE ABOVE, THE AS SESSING OFFICER STATED THAT IN VIEW OF THE SPECIFIC DEFECTS P OINTED OUT, HE REJECTED THE BOOKS OF ACCOUNTS FURNISHED BY THE ASSESSEE SINCE THOSE ARE NOT COMPLETE AND DO NOT GIVE A CORRECT PICTURE OF THE AFFAIRS OF THE ASSESSEE. THE A .O. HAS NOTED IN THE ASSESSMENT ORDER THAT IN THE BALANCE SHEET AS ON 1.4.2003, CASH IN HAND AMOUNTING TO RS.53,000/- IS SHOWN WHEREAS THE CASH IN HAND AS PER CASH BOOK AS ON 1.4.2003 IS SHOWN AT RS.1,33,000/-. THE A.O. REJECT ED THE CASH BOOK AND WAS OF THE VIEW THAT THE ASSESSEE COULD N OT PROVE CASH IN HAND OF RS.1,33,000/-, THE SAME WAS ADDED [IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] 5 U/S 69 OF THE ACT. DURING THE APPELLATE PROCEEDINGS, THE A.R. SUBMITTED THAT THE OPENING CASH BALANCE AS ON 1.4.2003 OF RS.53,000/- WAS TAKEN ON AN ESTIMATE BASIS AS THE ASSESSEE HAD WITHDRAWN RS.55,000/- FROM HIS BANK ACCOUNT. IT WAS ARGUED THAT OPENING CASH BALANCE AS ON 31.3.2003 WAS NEITHER ANY UNEXPLAINED INVESTMENT/EXPENSE NOR ANY UNRECORDED INCOME AND, THEREFORE, NO ADDITION SHOULD HAVE BEEN MADE FOR THE AMOUNT. IT WAS POINTED OUT THAT THE A.O. HAS COMMITTED AN ERROR IN TAKING THE CASH BALANCE OF RS.1,33,000/- AS P ER CASH BOOK WHEREAS IN FACT CASH IN HAND AS PER CASH BOOK WAS ONLY RS.53,000/-. 3. FURTHER, IN THE ASSESSMENT PROCEEDINGS, THE ASSESS EE WAS ASKED TO FURNISH DETAILS OF HIS FAMILY MEMBERS, THE IR ACTIVITIES, HOUSEHOLD EXPENSES AND SOURCES THEREOF. THE ASSESSEE SUBMITTED BEFORE THE A.O. THAT HE WAS LIVING IN JOINT FAMILY ALONG WITH HIS BROTHER IN HIS OWN HOUSE. THE [IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] 6 TELEPHONE WAS PROVIDED BY THE EMPLOYER. THE LADIES O F THE FAMILY AND PARENTS OF THE ASSESSEE WERE HAVING AGRICULTUR E LAND AND, HENCE, FOOD GRAINS WERE NOT REQUIRED TO BE PURCHASED FROM OUTSIDE. THE A.O. CONSIDERED THE RE PLY OF THE ASSESSEE. IT WAS NOTICED BY THE A.O. THAT DURING THESE YEARS THE ASSESSEE HAD ONE SCHOOL GOING CHILD AND THE AVERAGE MONTHLY FEES OF THEM WAS SHOWN BY THE ASSESSEE OF RS.150/- PER MONTH. THE ASSESSEE HAD NOT SHOWN ANY EXPENSES INCURRED ON ELECTRICITY, WATER CHARGES, MAINTENANCE OF HOUSE, MILK, VEGETABLES AND FRUITS, MEDICINE, COMMUTING, ATTENDING SOCIAL FUNCTION AND EXPENDITURE ON OUTGOINGS/ENTERTAINMENTS ETC. CONSID ERING THE LIFESTYLE AND STANDARD OF LIVING MAINTAINED BY THE ASSESSEE AND ESPECIALLY WHEN THE ASSESSEE HAD NOT FURNISHED ANY SPECIFIC DETAILS REGARDING THE EXPENDITU RE AS WELL AS SOURCES THEREOF, THE A.O. OBSERVED THAT HOUSE HOLD EXPENSES WERE REQUIRED TO BE ESTIMATED. IN THE CASH B OOKS [IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] 7 PREPARED BY THE ASSESSEE, THE ASSESSEE HAD NOT SHOWN ANY WITHDRAWALS FOR HOUSEHOLD EXPENSES. THUS, THE A.O. ESTIMATED HOUSEHOLD EXPENSES OF RS.1,20,000/- FOR A. Y. 2004-05; RS.1,50,000/- FOR A.Y. 2005-06; RS.1,80,00 0/- FOR A.Y. 2006-07; RS.2,10,000/- FOR A.Y. 2007-08; RS.2,40,000/- FOR A.Y. 2008-09, RS.2,70,000/- FOR A .Y. 2009-10; AND RS.3,00,000/- FOR A.Y. 2010-11 I.E. RANG ING FROM RS.10,000/- PER MONTH IN A.Y. 2004-05 TO RS.25,000/- PER MONTH IN A.Y. 2010-11. SINCE, THE ASSESSEE FAILED TO FURNISH ANY SATISFACTORY EXPLANATION REGARDING THE SOURCES OF AMOUNTS UTILIZED FOR HOUSEHO LD EXPENSES, THE A.O. MADE ADDITION OF THESE AMOUNTS IN RESPECTIVE ASSESSMENT YEARS ON ACCOUNT OF UNEXPLAINED HOUSEHOLD EXPENSES INCURRED BY THE ASSESSEE. 4. ASSESSEE WENT BEFORE THE LD. CIT(A) WHO AFTER CONSIDERING THE FACTS OF THE CASE STATED THAT THE ASSESS EE HAD SUFFICIENT AMOUNT AVAILABLE FROM HIS DISCLOSED SOU RCES [IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] 8 OF INCOME TO MAKE DEPOSITS IN THE BANK ACCOUNT, ESPECI ALLY WHEN NO WITHDRAWALS FOR HOUSEHOLD EXPENSES HAS BEEN CONSIDERED OUT OF THESE INCOMES. IN THE CASH BOOKS, THERE IS NO CREDIT ENTRY OF CASH WHICH CAN BE TREATED AS UNEXPLAINED. THEREFORE, THE LD. CIT(A) HELD THAT THE DEPOSITS IN CASH IN HIS BANK ACCOUNTS STAND EXPLAINED AN D, HENCE, NO ADDITION ON THIS ACCOUNT WAS CALLED FOR. 5. WITH REGARD TO HOUSE HOLD EXPENSES, LD. CIT(A) ST ATED THAT IT IS AN UNDISPUTED FACT THAT THE ASSESSEE HAS NOT SHOWN ANY AMOUNT OF WITHDRAWALS FOR MEETING HIS HOUSEHOLD EXPENSES FROM HIS DECLARED SOURCES OF INCO ME. AS POINTED OUT BY THE A.O., THE ASSESSEE WAS REQUIRED TO INCUR EXPENSES ON ELECTRICITY, WATER CHARGES, MAINTENAN CE OF HOUSE, MILK, VEGETABLES AND FRUITS, MEDICINES, CLO THES ATTENDING SOCIAL FUNCTIONS, EXPENDITURE ON ENTERTAINME NT ETC. THE ASSESSEE HAS CLAIMED HIS FATHER AND HE HIMSEL F WERE HAVING AGRICULTURAL INCOME BUT THE ASSESSEE HAD NOT [IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] 9 FURNISHED ANY EVIDENCE REGARDING THE AMOUNT OF INCOME RECEIVED FROM THE ALLEGED AGRICULTURAL LAND OWNED BY TH EM. THE ASSESSEE HAD ALSO NOT GIVEN ANY FIGURE OF THE AMOUNT OF HOUSEHOLD EXPENSES INCURRED BY HIM AND SPECIFIC SOUR CES THEREOF. THE ASSESSEE MAINTAINED A CAR WHICH WOULD REQUIRE SOME EXPENDITURE ON RUNNING AND MAINTENANCE. THE ASSESSEE HAS NOT PROVED THE SOURCE OF ANY HOUSEHOL D EXPENDITURE. IN THESE CIRCUMSTANCES, THE A.O. HAD NO OTHER OPTION BUT TO ESTIMATE THE HOUSEHOLD EXPENSES CONSIDERING THE SIZE OF THE FAMILY, LIFESTYLE AND ST ANDARD OF LIVING MAINTAINED BY THE ASSESSEE. THE A.O. HAD MADE VE RY MODERATE ESTIMATE OF HOUSEHOLD EXPENSES FROM RS.10,000/- TO RS.25,000/- PER MONTH FROM A.Y. 2004 -05 TO A.Y. 2010-11. LD. CIT(A) STATED THAT THE ESTIMATE OF HOUSEHOLD EXPENSES MADE BY THE A.O. WAS EXTREMELY FAIR AND REASONABLE AND WARRANTS NO INTERFERENCE. SINCE, THE ASSESEE FAILED TO FURNISH ANY SATISFACTORY [IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] 10 EXPLANATION/EVIDENCE REGARDING SOURCES OF THE AMOUNTS UTILIZED FOR HOUSEHOLD EXPENSES, THE ADDITIONS ON AC COUNT OF UNEXPLAINED HOUSEHOLD EXPENSES MADE BY THE A.O. ARE CONFIRMED. AGGRIEVED BY THE ORDER OF THE LD. CIT(A) , THE ASSESSEE IS IN APPEAL BEFORE THIS TRIBUNAL. 5. GROUND NO.1 IS AGAINST REJECTING THE CLAIM OF ASSESS EE IN RESPECT OF THE OPENING BALANCE OF RS.53,000/-. LD . COUNSEL FOR THE ASSESSEE SUBMITTED THAT BOTH THE AUTHORITIES BELOW HAVE FAILED TO APPRECIATE THE FACT THAT THE ASSESSEE IS A GOVERNMENT EMPLOYEE AND HAS BEEN DRAWING HIS SALARY. THEREFORE, HE WOULD HAVE BEEN SAVING SOME AMOUNT. 6. ON THE CONTRARY, LD. D.R. OPPOSED THESE SUBMISSIO NS AND SUPPORTED THE ORDER OF THE A.O. 7. WE HAVE HEARD THE RIVAL SUBMISSIONS, PERUSED THE MATERIALS AVAILABLE ON RECORD AND GONE THROUGH THE ORDERS [IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] 11 OF THE AUTHORITIES BELOW. AFTER CONSIDERING TOTALITY OF THE FACTS, THERE IS LIKELIHOOD OF SAVING SOME AMOUNT, THE REFORE, LOOKING TO THE SMALLNESS OF THE AMOUNT, WE DIRECT THE A.O. TO DELETE THIS ADDITION. 8. GROUND NO.2 IS AGAINST CONFIRMING THE HOUSEHOLD EXPENSES. LD. COUNSEL FOR THE ASSESSEE SUBMITTED TH AT THE AUTHORITIES BELOW HAVE FAILED TO APPRECIATE THE FACT THAT THE ASSESSEE HAS BEEN RESIDING WITH HIS BROTHER AND THE EXPENSES WERE MADE JOINTLY. 9. LD. D.R. OPPOSED THESE SUBMISSIONS AND SUPPORTED THE ORDERS OF THE AUTHORITIES BELOW. 10. WE HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. THE CONTENTION OF THE ASSESSEE IS THAT HE HAS BEEN RESIDING WITH HIS BROTHE R AND THE EXPENDITURE WAS INCURRED FOR HOUSEHOLD EXPENSES JOINTLY. THIS FACT IS NOT VERIFIED BY THE AUTHORITIE S BELOW. [IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] 12 FURTHER, THE ADDITION HAS BEEN MADE ON ADHOC ESTIMATE BASIS. CONSIDERING THE TOTALITY OF THE FACTS, WE REST RICT THE ADDITION TO THE EXTENT OF 50%. GROUND OF THE ASSESSE E IS PARTLY ALLOWED. 11. GROUND NO.3 IS GENERAL IN NATURE WHICH NEEDS NO SEPARATE ADJUDICATION. 12. NOW WE TAKE UP ITA NO.90/IND/2018 FOR THE A.Y. 2005-06. IN THIS APPEAL, GROUND NO.1 RAISED BY THE ASSESSEE IS IDENTICAL TO GROUND NO.2 RAISED BY THE ASSE SSEE IN ITA NO.89/IND/2018 EXCEPT FIGURES, WHICH WAS ALREAD Y ADJUDICATED IN PARA 10 FOR THE SAME REASONING THIS GROUND IS ALSO PARTLY ALLOWED. THE A.O. IS HEREBY DIRECTED T O DELETE THE 50% ADDITION MADE ON ACCOUNT OF LOW HOUSEHOLD EXPENSES. 13. GROUND NO.2 OF THE ASSESSEES APPEAL IS GENERAL IN NATURE AND NEEDS NO SEPARATE ADJUDICATION. [IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] 13 14. NOW WE TAKE UP ITA NO.91/IND/2018 FOR THE A.Y. 2006-07. IN THIS APPEAL, GROUND NO.1 RAISED BY THE ASSESSEE IS IDENTICAL TO GROUND NO.2 RAISED BY THE ASSE SSEE IN ITA NO.89/IND/2018 EXCEPT FIGURES, WHICH WAS ALREAD Y ADJUDICATED IN PARA 10 FOR THE SAME REASONING THIS GROUN D IS ALSO PARTLY ALLOWED. THE A.O. IS HEREBY DIRECTED T O DELETE THE 50% ADDITION MADE ON ACCOUNT OF LOW HOUSEHOLD EXPENSES. 15. GROUND NO.2 OF THE ASSESSEES APPEAL IS GENERAL IN NATURE AND NEEDS NO SEPARATE ADJUDICATION. 16. NOW WE TAKE UP ITA NO.92/IND/2018 FOR THE A.Y. 2007-08. IN THIS APPEAL, GROUND NO.1 RAISED BY THE ASSESSEE IS IDENTICAL TO GROUND NO.2 RAISED BY THE ASSE SSEE IN ITA NO.89/IND/2018 EXCEPT FIGURES, WHICH WAS ALREAD Y ADJUDICATED IN PARA 10 FOR THE SAME REASONING THIS GROUN D IS ALSO PARTLY ALLOWED. THE A.O. IS HEREBY DIRECTED T O DELETE [IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] 14 THE 50% ADDITION MADE ON ACCOUNT OF LOW HOUSEHOLD EXPENSES. 17. GROUND NO.2 OF THE ASSESSEES APPEAL IS GENERAL IN NATURE AND NEEDS NO SEPARATE ADJUDICATION. 18. NOW WE TAKE UP ITA NO.93/IND/2018 FOR THE A.Y. 2008-09. IN THIS APPEAL, GROUND NO.1 RAISED BY THE ASSESSEE IS IDENTICAL TO GROUND NO.2 RAISED BY THE ASSE SSEE IN ITA NO.89/IND/2018 EXCEPT FIGURES, WHICH WAS ALREAD Y ADJUDICATED IN PARA 10 FOR THE SAME REASONING THIS GROUND IS ALSO PARTLY ALLOWED. THE A.O. IS HEREBY DIRECTED T O DELETE THE 50% ADDITION MADE ON ACCOUNT OF LOW HOUSEHOLD EXPENSES. 19. GROUND NO.2 OF THE ASSESSEES APPEAL IS GENERAL IN NATURE AND NEEDS NO SEPARATE ADJUDICATION. 20. NOW WE TAKE UP ITA NO.94/IND/2018 FOR THE A.Y. 2009-10. IN THIS APPEAL, GROUND NO.1 RAISED BY THE [IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] 15 ASSESSEE IS IDENTICAL TO GROUND NO.2 RAISED BY THE ASSE SSEE IN ITA NO.89/IND/2018 EXCEPT FIGURES, WHICH WAS ALREAD Y ADJUDICATED IN PARA 10 FOR THE SAME REASONING THIS GROUND IS ALSO PARTLY ALLOWED. THE A.O. IS HEREBY DIRECTED T O DELETE THE 50% ADDITION MADE ON ACCOUNT OF LOW HOUSEHOLD EXPENSES. 21. GROUND NO.2 OF THE ASSESSEES APPEAL IS GENERAL IN NATURE AND NEEDS NO SEPARATE ADJUDICATION. 22. NOW WE TAKE UP ITA NO.95/IND/2018 FOR THE A.Y. 2010-11 IN THIS APPEAL, GROUND NO.1 RAISED BY THE ASSESSEE IS IDENTICAL TO GROUND NO.2 RAISED BY THE ASSE SSEE IN ITA NO.89/IND/2018 EXCEPT FIGURES, WHICH WAS ALREAD Y ADJUDICATED IN PARA 10 FOR THE SAME REASONING THIS GROUND IS ALSO PARTLY ALLOWED. THE A.O. IS HEREBY DIRECTED T O DELETE THE 50% ADDITION MADE ON ACCOUNT OF LOW HOUSEHOLD EXPENSES. [IT(SS)A NOS.89 TO 95/IND/2018] [B.L. RAI, BHOPAL] 16 23. GROUND NO.2 OF THE ASSESSEES APPEAL IS GENERAL IN NATURE AND NEEDS NO SEPARATE ADJUDICATION. 24. IN THE RESULT, THE APPEALS FILED BY THE ASSESSEE I .E. IT(SS)A NOS.89 TO 95/IND/2018 ARE PARTLY ALLOWED. ORDER WAS PRONOUNCED IN THE OPEN COURT ON 09 . 05.2019. SD/ - (MANISH BORAD) SD/ - (KUL BHARAT) A CCOUNTANT MEMBER JUDICIALMEMBER INDORE; DATED : 09/05/2019 VG/SPS COPY TO: ASSESSEE/AO/PR. CIT/ CIT (A)/ITAT (DR)/GUAR D FILE. BY ORDER ASSISTANT REGISTRAR, INDORE