Amitaben Kanjibhai Patel, Ahmedabad V. The Income Tax Officer, Ward-7(2)(1), Ahmedabad

MA 114/AHD/2020

• Counselvise Citation: [2020] 110 COUNSELVISE.COM (IT) 1477 (ITAT-AHMEDABAD)
• Duration Of Justice: 6 month(s) 12 day(s)
• Appeal Type: Miscellaneous Application
• Pronouncement Date: 09-12-2020
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: SMC
• Assessment Year: 2010-2011
• Appeal Filed On: 27-05-2020
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Assessee Lawyers: PF JAIN
• Keywords: Reopening of assessment; Business income; Wrong claim; Corroborative evidences; Reassessment proceedings; TDS
• Section: 142(1); 139(1); 254(2); 13; 147; 148

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD SMC BENCH (VIRTUAL COURT) BEFORE: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER AND MS. MADHUMITA ROY, JUDICIAL MEMBER SMT. AMITABEN KANJIBHAI PATEL, C/O. PARAS F. JAIN AND CO. 102, DWARKESH COMPLEX, OPP. PATEL VAS MITHAKHALI GAM, MITHAKAHALI, AHMEDABAD PAN: ASZPP4927E (APPELLANT) VS THE ITO, WARD-7(2)(1), AHMEDABAD (RESPONDENT) REVENUE BY: SHRI VIDHYUT TRIVEDI, SR. D.R. ASSESSEE BY: SHRI P.F. JAIN, A.R. DATE OF HEARING : 16-10-2020 DATE OF PRONOUNCEMENT : 09-12-20 20 /ORDER PER : AMARJIT SINGH, ACCOUNTANT MEMBER:- THE ASSESSEE HAS FILED THIS MISCELLANEOUS APPLICAT ION IN RESPECT OF ORDER OF ITAT VIDE ITA NO. 1198/AHD/2017 DATED 28 TH JAN, 2020. IN THE MISCELLANEOUS APPLICATION, THE ASSESSEE HAS MAINLY SUBMITTED THAT JUDICIAL DECISIONS RELIED UPON HAVE NOT BEEN CONSIDERED WHIL E ADJUDICATING THE APPEAL. M.A. NO. 114/AHD/2020 (IN ITA NO. 1198/AHD/2017) ASSESSMENT YEAR 2010-11 M.A. NO. 114/AHD/2020 (IN I.T.A NO. 1198/AHD/2017) A.Y. 2010-11 PAGE NO SMT. AMITABEN KANJIBHAI PATEL VS. ITO 2 2. HEARD BOTH THE SIDES AND PERUSED THE MATERI AL ON RECORD. REGARDING OBJECTION TO RE-ASSESSMENT PROCEEDINGS IN RESPECT O F GROUND NO. 1 & 2 AT THE LEVEL OF THE ASSESSING OFFICER, THE ASSESSEE HAS NO T FILED THE RETURN OF INCOME WITHIN THE TIME PRESCRIBED U/S. 139(1) OF TH E ACT TILL 31 ST MARCH, 2014. THERE WAS A SPECIFIC INFORMATION WITH THE AS SESSING OFFICER THAT ASSESSEE HAD DEPOSITED CASH TO THE AMOUNT OF RS. 13 ,11,000/- IN HER SAVING BANK ACCOUNT MAINTAINED WITH THE ICICI BANK. THE ASSESSING OFFICER HAS ALSO ISSUED A LETTER DATED 19 TH DECEMBER, 2013 TO THE ASSESSEE THAT AS PER INFORMATION RECEIVED BY THE INCOME TAX DEPARTMENT, SHE HAS NOT FILED INCOME TAX RETURN FOR ASSESSMENT YEAR 2010-11 & 2011-12. THE ASSESSEE HAS NOT MADE ANY RESPONSE TO THE AFORESAID LETTER AND NOTIC ES ISSUED BY THE ASSESSING OFFICER. THEREFORE, A NOTICE U/S. 142(1) OF THE AC T WAS ISSUED ON 30 TH DECEMBER, 2013 ALONG WITH BLANK RETURN FORM HOWEVER THE ASSESSEE HAD NOT MADE ANY RESPONSE. THEREAFTER, ON 13 TH MARCH, 2014 A NOTICE U/S. 148 WAS ISSUED TO THE ASSESSEE TO FILE THE RETURN OF INCOME WITHIN 30 DAYS FROM THE RECEIPT OF THE NOTICE. THE ASSESSING OFFICER VIDE LETTER DATED 19 TH DECEMBER, 2013 HAD BROUGHT TO THE NOTICE OF THE ASSESSEE THAT INCOME TAX DEPARTMENT HAS RECEIVED INFORMATION RELATING TO FINANCIAL ACTI VITY OF THE ASSESSEE AND PROVIDED INFORMATION SUMMARY PERTAINING TO THE PAN OF THE ASSESSEE WHICH ALSO CONTAINED THE INFORMATION THAT F.Y. 2008-09 TH ERE WAS A CASH DEPOSIT OF MORE THAN 10 LACS IN THE SAVING BANK ACCOUNT OF THE ASSESSEE. IT WAS ALSO BROUGHT TO THE NOTICE VIDE LETTER DATED 19 TH DECEMBER, 2013 THAT AS PER INFORMATION SUMMARY PERTAINING TO THE TDS, THERE WA S ALSO TRANSACTION WITH THE PAN OF THE ASSESSEE ON INTEREST OTHER THAN THE INTEREST ON SECURITIES. HOWEVER THE ASSESSEE HAS NOT MADE ANY COMPLIANCE EV EN WITH THE NOTICE ISSUED U/S. 142(1) OF THE ACT. THEREFORE, ON 13 MA RCH, 2014 A NOTICE U/S. M.A. NO. 114/AHD/2020 (IN I.T.A NO. 1198/AHD/2017) A.Y. 2010-11 PAGE NO SMT. AMITABEN KANJIBHAI PATEL VS. ITO 3 148 WAS ISSUED TO THE ASSESSEE TO FILE THE RETURN O F INCOME WITHIN 30 DAYS FROM THE RECEIPT OF THE NOTICE. THEREFORE, NO IN FIRMITY IN THE DECISION OF LD. CIT(A) IN UPHOLDING THE REOPENING OF THE ASSESSMENT WAS FOUND AND THE CASES REFERRED BY THE ASSESSEE WERE DISTINGUISHABLE FROM THE FACTS OF THE CASE OF THE ASSESSEE. IT IS CLEAR FROM THE FACTS ELABORATED BY THE ASSESS ING OFFICER THAT AT THE ASSESSMENT STAGE, THE ASSESSEE HAS VEHEMENTLY CLAIM ED THAT THE CASH DEPOSITED IN THE SAVING BANK ACCOUNT MAINTAINED WIT H THE ICICI BANK WAS FROM HER BUSINESS OF TRADING IN IRON AND STEEL. DU RING THE COURSE OF ASSESSMENT, THE ASSESSEE HAS TRIED TO LINK THE SOUR CE OF CASH PROVIDED IN THE SAID BANK ACCOUNT WITH THE LEDGER ACCOUNT MAINTAINE D IN THE CASE OF M/S. HARI KRISHNA STEEL TRADER ( A DEALER FROM WHOM THE ASSESSEE HAS PURCHASED STEEL & IRON) AND THE ASSESSEE HAS CLAIMED THAT CA SH DEPOSITED IN HER BANK ACCOUNT WAS HER BUSINESS RECEIPT FROM THE AFORESAID BUSINESS OF TRADING IN IRON AND STEEL AFTER MAKING REFERENCE TO THE LEDGER ACCOUNT. HOWEVER, ON VERIFICATION AND INVESTIGATION, THE ASSESSING OFFIC ER HAS ESTABLISHED THAT THE ASSESSEE COULD NOT SUBSTANTIATE HER CLAIM WITH RELE VANT SUPPORTING EVIDENCES. SUBSEQUENTLY, BEFORE THE LD. CIT(A) THE ASSESSEE H AS COMPLETELY CHANGED THE FACTS OF HER OWN CLAIM MADE BEFORE THE ASSESSING OFFICER STATING THAT THE SAID BANK ACCOUNT IN THE ICICI BAN K WAS NOT OPENED BY HER AND IT WAS OPENED BY A TRAVEL AGENT AND ALL THE TRA NSACTIONS WITH THE BANK WERE ALSO MADE BY HIM. AS BRIEFLY STATED, THE ASSE SSEE CLAIMED BEFORE THE ASSESSING OFFICER THAT THE SAID DEPOSIT IN HER SAVI NG ACCOUNT HAD BEEN MADE OUT OF CASH RECEIVED FROM HER BUSINESS OF TRADING I N IRON AND STEEL. AS REPORTED AT PAGE 5 & 6 OF THE ASSESSMENT ORDER BEFO RE THE ASSESSING OFFICER THE ASSESSEE HAS CLAIMED THAT THE CASH DEPOSITED IN HER BANK ACCOUNT WAS OUT M.A. NO. 114/AHD/2020 (IN I.T.A NO. 1198/AHD/2017) A.Y. 2010-11 PAGE NO SMT. AMITABEN KANJIBHAI PATEL VS. ITO 4 OF HER BUSINESS TRANSACTIONS AND ALSO SUBMITTED LED GER ACCOUNT IN THE CASE OF M/S. HARI KRISHNA STEEL TRADERS CLAIMING AS DEALER FROM WHOM THE ASSESSEE HAS PURCHASED STEEL/IRON. THE ASSESSEE HAS FAILED TO SUBSTANTIATE THE GENUINENESS OF THE TRANSACTIONS OF PAYMENT MADE OF RS. 13,39,791/- REPORTED IN THE SAID LEDGER ACCOUNT. WITHOUT CO-RELATING TH E TRANSACTION REPORTED IN THE LEDGER ACCOUNT WITH THE CASH DEPOSITED OF RS. 1 3,71,000/-, THE ASSESSEE HAS SIMPLY STATED THAT IT WAS HER BUSINESS CASH. A FTER VERIFICATION AND EXAMINATION OF THE TRANSACTIONS REPORTED IN THE LED GER ACCOUNT, THE ASSESSING OFFICER FOUND THAT THE ASSESSEE HAS FAILED TO PROVE HER CLAIM OF HAVING CASH IN HAND TO THE AMOUNT OF RS. 13,11,000/- HOWEVER, WHEN THE SAME COULD NOT BE SUBSTANTIATED WITH RELEVANT SUPPORTING EVIDENCES BEFORE THE ASSESSING OFFICER, THE ASSESSEE HAS MADE CONTRADICTORY CLAIM BEFORE THE LD. CIT(A) THAT THE SAID BANK ACCOUNT DID NOT BELONG TO HER. HOWE VER AFTER VERIFICATION AND EXAMINATION OF THE DOCUMENT AS ELABORATED IN THE FI NDING OF THE LD. CIT(A) AT PARA NO. 5.3.1 IT WAS CLEARLY ESTABLISHED WITH T HE SUPPORT OF THE EVIDENCES THAT THE SAID BANK ACCOUNT WAS BELONGED TO THE ASSE SSEE AND ASSESSEE HAD REPEATEDLY MADE FALSE CLAIM. IN ADDITION TO ABOVE , THE ITAT HIGHEST FACT FINDING AUTHORITY AFTER VERIFICATION OF THE PAPER B OOK FILED BY THE ASSESSEE HAD NOTICED THAT ASSESSEE HAS DECLARED AND OWNED UP THE SAID SAVING BANK ACCOUNT IN THE RETURN OF INCOME FILED BY HER. THE ASSESSEE HAS FAILED TO PRODUCE ANY MATERIAL TO SUBSTANTIATE HER CONTRADIC TORY CLAIM MADE BEFORE THE LD. CIT(A). FURTHER THE ALTOGETHER DIFFERENT C LAIM MADE BEFORE THE LD. CIT(A) THAT THE BANK ACCOUNT WAS NOT BELONGED TO HE R FOUND TO BE FALSE CLAIM. CONSIDERING THESE SPECIFIC FACTS WHICH ARE DISTINGUISHABLE FROM THE CASES REFERRED BY THE ASSESSEE, THE ITAT HAS NOT FO UND ANY INFIRMITY IN THE M.A. NO. 114/AHD/2020 (IN I.T.A NO. 1198/AHD/2017) A.Y. 2010-11 PAGE NO SMT. AMITABEN KANJIBHAI PATEL VS. ITO 5 DECISION OF LD. CIT(A). THE RELEVANT FINDING OF T HE ITAT IS REPRODUCED AS UNDER:- 6. WE HAVE HEARD BOTH THE SIDES AND PERUSED THE M ATERIAL ON RECORD. GROUND NOS. I & 2 ARE AGAINST THE DECISION OF ID. CIT(A) IN UPHOLDING REASSESSMENT PROCEEDINGS U/S. 147 OF THE ACT. ON PERUSAL OF THE MATERIAL ON RECORD, IT IS NOTICED THAT ASSESSEE HAS NOT FILED THE RETURN OF INCOME WITHIN THE TIME LIMIT PRESCRIBED U/S. 139(1) OF THE ACT TILL 31 S ' MARCH, 2014. THERE WAS A SPECIFIC INFORMATION WITH THE ASSESSING OFFICER THAT ASSESSE E HAD DEPOSITED CASH TO THE AMOUNT FOR RS. 13,11,0007- IN HER SAVING BANK ACCOUNT MAINTAINED W ITH THE ICICI BANK. SINCE THE ASSESSEE HAS NOT FILED ANY RETURN OF INCOME WITHIN THE TIME LIMI T U7S. 139(1) OF THE ACT, THEREFORE, NOTICE U/S. 14 8 OF THE ACT WAS ISSUED. THE ASSESSING OFFICER HAS IS SUED A LETTER DATED 19 TH DECEMBER, 2013 TO THE ASSESSEE STATING THAT AS PER INFORMATION RECEIVED B Y THE INCOME TAX DEPARTMENT YOU HAVE NOT FILED INCOME TAX RETURN FOR ASSESSMENT YEAR 2010-I 1 AND 2011-12. A COPY OF THE SAID LETTER ISSUED BY THE ASSESSING OFFICER WAS PLACED AT PAGE NO. 10 OF THE PAPER BOOK FILED BY THE ASSESSEE WHEREIN INFORMATION PERTAINING TO THE PAN ASZPP4927E OF THE ASSESSEE ALSO REFLECTED THAT CASH DEPOSIT OF RS. 10 HIES WAS MADE IN HER SAVING BANK ACCOUNT. TH E ASSESSEE HAS NOT RESPONDED TO THE SAID LETTER. THEREFORE, A NOTICE U/S. 142(1) OF THE ACT ON 30'' DECEMBER, 2013 WAS ISSUED ALONG WITH BLANK RETURN FORM HOWEVER THE ASSESSEE HAS NOT RESP ONDED. THEREAFTER, ON 13 TH MARCH, 2014 A NOTICE U/S. 148 WAS ISSUED TO THE ASSESSEE TO FILE THE RETURN OF INCOME WITHIN 30 DAYS FROM THE RECEIPT OF THE NOTICE. IT IS CLEAR FROM THE FACTS R EPORTED ABOVE THAT ASSESSEE HAS NOT FILED ANY RETUR N OF INCOME U/S. 139(1) OF THE ACT. IT IS UNDISPUTED FACT THAT HUGE CASH DEPOSIT WAS FOUND IN THE S.B. ACCOUNT NO. 093001502470 OF THE ASSESSEE MAINTAINED WITH THE ICICI BANK, THE ASSESSING OFFICER VIDE LETTER DATED 19-12-2013 HAD BROUGHT TO THE NOT ICE OF THE ASSESSEE THAT INCOME TAX DEPARTMENT HAS RECEIVED INFORMATION RELATING TO FIN ANCIAL ACTIVITIES OF THE ASSESSEE AND PROVIDED INFORMATION SUMMARY PERTAINING TO THE PAN OF THE AS SESSEE WHICH ALSO CONTAIN THE INFORMATION THAT DURING F.Y. 2008-09 THERE WAS A CASH DEPOSIT O F MORE THAN 10 LACS IN THE SAVING BANK OF THE ASSESSEE. NO COMPLIANCE WAS MADE BY THE ASSESSEE UN TIL ISSUING OF NOTICES AND REMINDERS AS REFERRED IN THIS ORDER. IT WAS ALSO BROUGHT TO THE NOTICE OF THE ASSESSEE VIDE LETTER THAT 19-12-2013 THAT AS PER INFORMATION SUMMARY PERTAINING TO THE T DS THERE WAS ALSO TRANSACTIONS WITH THE PAN OF THE ASSESSEE INTEREST OTHER THAN THE INTEREST ON SECURITIES. EVEN THE ASSESSEE HAD FAILED TO MAKE COMPLIANCES WITH NOTICE U/S. 142(1) OF THE ACT ISSU ED BY THE ASSESSING OFFICER. IT IS CLEAR FROM THE ABOVE FACT THAT THE ASSESSING OFFICER HAD GIVEN DUE OPPORTUNITY TO THE ASSESSEE BUT THERE WAS NO COMPLIANCE FROM. THE CASE LAWS RELYING UPON BY TH E ASSESSEE ARE DISTINGUISHABLE ON FACTS AND ARE OF NO HELP TO THE ASSESSEE IN THE PRESENT CASE. IN THE LIGHT OF THE ABOVE FACTS AND CIRCUMSTANCES, WE DO NOT FIND ANY REASON TO INTERFERE IN THE DECIS ION OF ID. C1T(A) IN JUSTIFYING THE ACTION OF THE ASSESSING OFFICER IN REOPENING THE ASSESSMENT. THER EFORE, WE UPHOLD REOPENING OF ASSESSMENT - UNDER SECTION 148 OF THE ACT. ACCORDINGLY, GROU ND NOS. 1 & 2 OF THE ASSESSEE ARE DISMISSED. GROUNDS OF APPEAL NO. 3 TO 6:- IN ADDITION TO THE F ACTS AS ELABORATED ABOVE, THE ASSESSEE HAS FILED THE INCOME TAX RETURN ONLY ON 8' DECEMBER, 2014 DEC LARING INCOME OF RS. 1,09,626/-. THE ASSESSEE HAS CLAIMED IN THE RETURN OF INCOME THAT SHE HAS EA RNED BUSINESS INCOME OF RS. 80,984/- FROM THE BUSINESS OF TRADING IN IRON AND STEEL, HOWEVER, ON VERIFICATION THE ASSESSING OFFICER NOTICED THAT ASSESSEE HAS CLAIMED PURCHASES MADE FROM ONE PARTY M/S. HARIKRISHNA TRADER BUT THE SAID PARTY WAS NOT EXISTED AT THE GIVEN ADDRESS. THE ASSESSEE COULD NOT SUBSTANTIATE WITH RELEVANT EVIDENCES THAT SHE WAS ENGAGED IN ANY BUSINESS. SUBSEQUENTLY BEFORE THE ID. CIT(A) THE ASSESSEE HAD CLAIMED THAT SHE HAD NOT SIGNED THE ACCOUNT OPENING FORM AND THE BANK ACCOUNT WAS OPERATED BY HER TRAVEL AGENT. THE ASSESSEE HAS FAILED TO FURNIS H ANY COMMUNICATION FROM THE BANK STATING THAT THIS ACCOUNT WAS NOT PERTAINED TO HER. IN THIS REGA RD, WE HAVE VERIFIED THE PAPER BOOK SUBMITTED BY THE ASSESSEE AND IT IS NOTICED THAT AT PAGE NO. 29 TO 31 THE ASSESSEE HAS PLACED THE COPY OF INCOME TAX RETURN FILED BY THE ASSESSEE FOR THE YEAR UNDER CONSIDERATION ON 8 TH DECEMBER, 2014 WITH THE INCOME TAX RETURN W-7(2)(L) AND IN THE RETURN OF IN COME THE ASSESSEE HERSELF HAS DECLARED AND OWNED UP THE IMPUGNED SAVING BANK ACCOUNT NO, 09300 1502470 MAINTAINED WITH THE ICICI BANK IN WHICH THE IMPUGNED CASH WAS DEPOSITED. IN VIEW O F THE ABOVE FACTS AND CIRCUMSTANCES, IT IS CLEAR THAT ASSESSEE HAS HERSELF CLAIMED AND OWNED U P THE ABOVE REFERRED SAVING BANK ACCOUNT IN M.A. NO. 114/AHD/2020 (IN I.T.A NO. 1198/AHD/2017) A.Y. 2010-11 PAGE NO SMT. AMITABEN KANJIBHAI PATEL VS. ITO 6 INCOME TAX RETURN FILED BY HER. IT IS DEMONSTRATED FROM THE ABOVE CITED MATERIAL FACT THAT ASSESSEE HAD DISCLAIMED THIS BANK ACCOUNT WITHOUT ANY BASIS AND INEXACTLY STATED THAT IT WAS PERTAINED TO TRAVEL AGENT. THE ASSESSEE HAS GIVEN CONTRADICTORY STATEMENT FIRST AT THE LEVEL OF ASSESSING OFFICER THAT SHE HAS EARNED THE CASH DEPOSITED IN THE SAID SAVING BANK ACCOUNT FROM HER BUSINESS OF TRADING IN IRON AND STEEL WHEN SHE HAS FAILED TO SUBSTANTIATE HER CLAIM WITH RELEVANT EVIDENCES THEN SHE HAS MADE NEW SUBMISSION BEFORE THE ID. CIT(A) THAT THE SAID SAVING BANK ACCOUNT WITH ICICI WAS NOT OPENED AND OPERATED BY HER AND IT WAS NOT PERTAINED TO HER. HOWEVER, SHE HAS FAILED TO SUBSTANTIATE HER NEW CLA IM WITH ANY RELEVANT EVIDENCES AND MATERIAL. AS DISCUSSED ABOVE IN THIS ORDER ON PERUSAL OF THE RELEVANT MATERIAL ON RECORD, IT IS NOTICED THAT ASSESSEE HAS HERSELF REPORTED UNDER HER SIGNATURE I N HER INCOME TAX RETURN FILED AFTER REPLYING THE NOTICES FROM THE ASSESSING OFFICER THAT THE IMPUGNE D BANK ACCOUNT WITH THE ICICI BANK WAS PERTAINED TO HER. IN THE LIGHT OF THE ABOVE FACTS A ND CIRCUMSTANCES, WE CONSIDER THAT THE ASSESSEE HAS FAILED TO SUBSTANTIATE THE SOURCE OF CASH DEPOS IT DETECTED IN THE SAVING BANK ACCOUNT, THEREFORE, WE DO NOT FIND ANY INFIRMITY IN THE DECI SION OF ID. CIT(A). IN VIEW OF THE DISCUSSION MADE ABOVE, WE DO NOT FIND ANY MERIT IN THE GROUNDS OF A PPEAL 3 TO 6 OF THE ASSESSEE, THEREFORE, ALL THESE GROUNDS OF APPEAL STAND DISMISSED. IT IS PERTINENT FROM THE AFORESAID BRIEFLY REPORTED FINDINGS THAT IT WAS A VERY LONG ADJUDICATED ORDER PASSED AFTER TAKING INTO CON SIDERATION ACTUAL FACTS DISTINGUISHABLE FROM THE FACTS IN THE CASE LAWS REF ERRED BY THE ASSESSEE. KEEPING IN VIEW THE ABOVE FACTS AND CIRCUMSTANCES, WE CONSIDER THAT THE POWER OF RECTIFICATION U/S. 254(2) OF THE ACT CAN B E EXERCISED ONLY WHEN THE MISTAKE WHICH IS SUBJECT TO BE RECTIFIED IS AN OBVI OUS PATENT MISTAKE, WHICH IS APPARENT FROM RECORD AND NOT A MISTAKE WHICH IS REQUIRED TO BE ESTABLISHED BY ARGUMENT AND LONG DRAWN PROCESS OF REASONING ON POINTS ON WHICH THERE MAY CONCEIVABLY BE TWO OPINION. IN THE LIGHT OF FACTS AND CIRCUMSTANCES, WE DO NOT FIND ANY MERIT IN THE MISCELLANEOUS APPLI CATION OF THE ASSESSEE AND THE SAME IS DISMISSED. 3. IN THE RESULT, THE MISCELLANEOUS APPLICATIO N FILED BY THE ASSESSEE IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 09-12-2020 SD/- SD/- (MADHUMITA ROY) (AMARJIT SINGH) JUDICIAL MEMBER A CCOUNTANT MEMBER M.A. NO. 114/AHD/2020 (IN I.T.A NO. 1198/AHD/2017) A.Y. 2010-11 PAGE NO SMT. AMITABEN KANJIBHAI PATEL VS. ITO 7 AHMEDABAD : DATED 09/12/2020 / COPY OF ORDER FORWARDED TO:- 1. ASSESSEE 2. REVENUE 3. CONCERNED CIT 4. CIT (A) 5. DR, ITAT, AHMEDABAD 6. GUARD FILE. BY ORDER/ , / ,