Megacity Sales Private Limited, Ludhiana V. Pr.CIT-1, Ludhiana

MA 24/CHANDI/2022

AI Insights

The case involves Megacity Sales Private Limited, which filed a Miscellaneous Application against the order of the Income Tax Appellate Tribunal, Chandigarh, concerning an earlier appeal dismissed for the Assessment Year 2011-12. The original appeal challenged the reassessment proceedings initiated under section 147 based on information from the DDIT(Inv), Kolkata, alleging unaccounted cash deposits. The Tribunal had previously upheld the reassessment, agreeing with the Principal Commissioner of Income Tax (PCIT) that the Assessing Officer failed to conduct a proper examination of the transactions and relied solely on the assessee's submissions without independent verification. In the Miscellaneous Application, the assessee argued that the Tribunal had overlooked certain facts and legal precedents, but the Tribunal found that these were already considered in the original decision and dismissed the application.

• Counselvise Citation: [2023] 140 COUNSELVISE.COM (IT) 135455 (ITAT-CHANDIGARH)
• Duration Of Justice: 10 month(s) 15 day(s)
• Appeal Type: Miscellaneous Application
• Pronouncement Date: 27-08-2023
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: B
• Next Hearing Date: 24-08-2023
• Assessment Year: 2011-2012
• Appeal Filed On: 12-10-2022
• Other Referred Cases: Sh. Rajinder Chauhan Vs PCIT, Shimla, Ganga Acrowool Ltd., Paramjit Singh Vs CIT, Vikram Kaswan, Sh. Surinder Pal Singh, Mannesmann Demag A.G vs DC IT
• Laws Referred To: Income Tax Act
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Keywords: Revision of order; Share purchase agreement; Audit objection; Assessment record; Reassessment proceedings; Set aside
• Section: 147; 68; 263; 254(2); 119

Judgement Text

आयकर अपीलीय अिधकरण,चǷीगढ़ Ɋायपीठ “बी” , चǷीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “B”, CHANDIGARH ŵी आकाश दीप जैन, उपाȯƗ एवं ŵी िवŢम िसंह यादव, लेखा सद˟ BEFORE: SHRI. AAKASH DEEP JAIN, VP & SHRI. VIKRAM SINGH YADAV, AM Miscellaneous Application No. 24/Chd/2022 In (आयकर अपील सं./ ITA NO. 120/Chd/2021 िनधाŊरण वषŊ / Assessment Year : 2011-12 Megacity Sales Private Limited B-XXIV-4653/1, Sunder Nagar, Ludhiana बनाम The Pr. CIT-1 Ludhiana ̾थायी लेखा सं./PAN NO: AAECM7797F अपीलाथŎ/Appellant ŮȑथŎ/Respondent िनधाŊįरती की ओर से/Assessee by : Shri Sudhir Sehgal, Advocate राजˢ की ओर से/ Revenue by : Shri Dharam Vir, JCIT, Sr. DR सुनवाई की तारीख/Date of Hearing : 25/08/2023 उदघोषणा की तारीख/Date of Pronouncement : 28/08/2023 आदेश/Order PER VIKRAM SINGH YADAV, A.M. : The present miscellaneous application has been filed by the Assessee against the order passed by the Coordinate Bench dt. 03/08/2022 in ITA No. 120/Chd/2021 for Assessment Year 2011-12. 2. In the said Miscellaneous Application, it has been stated as under: “1. It is very humbly submitted that the assessee is in receipt of the order in above said case on 14.09.2022 and after going through the order of Hon'ble Bench, the following mistakes, according to the assessee has crept in and for which, the facts are as under:- a). In the order as passed by the Hon'ble Bench, the brief facts of the case have been discussed in para 2 of the order and in para 3, the arguments of the Counsel have been mentioned, alongwith the case laws and the arguments of the Ld. CIT(DR) have been discussed in para 4 of the order, starting from page 4 to page 7 and, then the finding of the Hon'ble Bench have been given from para 5, page 7 to page 11 and finally, on the issue of show cause notice, having been issued on the basis of audit objection, the same have been adjudicated from para 7, page 11 to page 16 of the order and finally, in para 9 and 10, the finding have been given and the appeal of the assessee have been dismissed. 2 b). It is submitted that as per the arguments recorded in the order of Hon'ble Bench of the Ld. CIT (DR), which have been discussed at page 5 to page 7 of the order, the Ld. CIT(DR) had stated that the reassessment- proceedings were initiated only on the basis of report received from the DDI, Investigation, Kolkata and there was no evidence that the Assessing Officer had made an attempt to verify such report as received from the Investigation Wing, Kolkata, meaning thereby that no independent examination of the said report was undertaken and reassessment proceedings were undertaken only on the basis of documents submitted by the assessee. c). Further, during the course of hearing, the Hon'ble Bench specifically raised a query to the Ld. CIT (DR) that whether there is any report available on record of the Assessing Officer of DDI, Investigation, Kolkata and the Ld.CIT (DR) could not substantiate and rather did not answer to this query. Further, the Hon'ble Bench Specifically asked the Ld.CIT (DR) as to whether the reopening has been made only on the basis of suspicion and to which, the Ld. CIT (DR) replied that it appears to be so. d). Thus, from the above said observation of the Ld. CIT (DR), the finding as recorded by the Hon'ble Bench does not appear to be correct since when there is no such specific report or information in the records, as agreed, to by the Ld. CIT (DR) during the course of hearing, it appears that this aspect has not been considered properly by the Hon'ble Bench. e). Further, it was specifically pointed out by the counsel that there Ld. PCIT has merely issued show cause notice from the observation as given in the audit memo, which is being pointed hereunder: - i). "On Page 32 of Paper Book, specific attention was invited to 4 th line as under:- "The assessee has failed to submit any affidavit from purchaser M/s Bholenath Dealers Pvt. Ltd. or any document regarding transfer of shares." ii). Then again, your kind attention was invited to the notice dated 04.03.2021 issued u/s 263 para 4, page 41 of Paper Book, which is reproduced as under: "From the examination of the assessment record for the A.Y. 2011-12, it is noticed that you have failed to submit affidavit from purchaser i.e. M/s Bholenath Dealers Pvt. Ltd.,or any documentary evidence regarding proof of transfer of shares/ share certificates which was called by A.O. at the time of assessment proceedings." Thus, it is absolutely clear that there was no independent satisfaction of the Ld. PCIT, which is sine quo for the purposes of assumption of jurisdiction u/s 263. iii). Your kind attention during the course of hearing was invited to "Annotated Report" placed in paper book page no. 34 & 35 dated 12.09.2019 in which, the Ld. Assessing Officer gave the complete details of "Audit Memo" and sent the same to CIT (Audit) Chandigarh. Your kind attention was also drawn to 'last para' also which is reproduced as under: - "In view of the above facts, the audit objection raised by the Audit Party is not accepted and the same may kindly be settled." iv). It was also further argued that A.O., Ludhiana had sent the factual report to the Ld. PCIT dated 18.01.2021 vide paper book page no. 36 to 39 for taking recourse to action u/s 263. 3 v). Further, in the Show Cause Notice and Audit report, the same wording has been mentioned. f). Thus, from the above sequence of arguments and evidences placed in the Paper Book. Such arguments and documents have not been considered at all and once the Ld. Assessing Officer had not agreed to the audit objections, the same becomes a debatable issue and on that, no action u/s 263 can be upheld and which aspect has totally been ignored by the Hon'ble Bench. g). The Hon'ble Bench has given a reference to ITA No. 318/Chd/2020, dated 21.07.2022, reported in [2022] 98 ITR (Trib.) 610 in the case of Sh. Rajinder Chauhan Vs PCIT, Shimla, wherein on merits of the case, the order u/s 263 was struck down and on the issue of audit objection, the finding has been given by the Hon'ble Bench at page 12 to page 13 of the order. h). From the above submissions of the humble assessee, when there is no material in the file of the Assessing Officer and reopening having made only on the basis of records provided by the assessee, coupled with the observation of the Ld. Assessing Officer, having not agreed to by 'audit objection and on merits, the view taken by the Hon'ble Bench is not in line with the earlier judgments of Jurisdictional Bench of the ITAT in the case of 'Ganga Acrowool Ltd. in ITA No. 196/Chd/2021, reported in 96 ITR (Trib.) 171' and other judgment of Chandigarh Bench in the case of 'Paramjit Singh Vs CIT in ITA No. 499/Chd/2016 vide order, dated 09.11.2016', in the case of 'Vikram Kaswan in ITA No. 419/Chd/2019, vide order, dated 08.03.2016' and in the recent judgment in the case of 'Sh. Surinder Pal Singh, reported in [2022] 94 ITR (Trib) 458' and, thus, when there are number of judgments of the jurisdictional Bench, the same could have been considered and followed. i). Lastly, it may be stated that certain judgments have been cited by the Hon'ble Bench of its own while passing the order of the Coordinate Bench, Delhi, in para 8 and of Sh. Rajinder Chauhan Vs CIT as cited supra, no such opportunity was given to rebut the same. In view of the above said facts and circumstances, it is humbly prayed that on account of the above said facts and circumstances, the above facts may, please be considered and suitable order may be passed as your honour deem fit and oblige.” 3. In this regard, both the parties were heard and the case records were perused including the order passed by the Coordinate Bench dt. 03/08/2022 and the relevant findings of the Coordinate Bench are at para 5 to 11 which read as under: “5. We have heard the rival contentions and purused the material available on record. Firstly, the order so passed by the ld PCIT has been assailed on the ground that the matter has been duly examined by the AO and it is therefore, not a case of lack of enquiry on part of the AO and thus, the jurisdiction u/s 263 has been wrongly invoked by the ld PCIT. In this regard, we find that it is a matter of record that reasons were recorded and the case of the assessee was reopened u/s 147 basis information received from DDIT(Inv), Unit 2(1) Kolkata that cash deposits have been made in the bank account of M/s Gupta Trading Co, M/s Adarsh marketing & Naresh Kumar Pareek and such cash deposits were routed through several layers before reaching the beneficiaries and on the basis of cash trail prepared, it is observed that assessee company had received a sum of Rs 25 lacs from M/s Bholenath Dealers Private Limited out of such explained sources. In this regard, the ld PCIT has recorded a categorical finding that the AO has neither considered the investigation 4 report at the time of framing the assessment nor called for any documents/information from the Investigation Wing and further, there is no evidence on record that the AO had made an attempt to collect evidence/papers from Kolkata in respect of layering of transactions. During the course of hearing before us, nothing has been brought to our notice to rebut the said findings of the ld PCIT. In our view, where the very foundation of reopening the assessment is receipt of certain information from the Investigation Wing, it is expected from the Assessing officer that such information and related documentation is examined by him vis-à-vis the source providing such information and further, cross-verify it with the assessee and where required, to carry out further examination to verify the claim of the assessee. In the instant case, there is nothing on record which demonstrate any such action ever initiated by the Assessing officer. Therefore, where the information available on record prima facie demand a deeper examination and investigation, mere acceptance of claim of the assessee and taking on record whatever has been submitted in support of its claim, the Assessing officer would be failing in his statutory duty to carry out necessary examination and verification and where the same is pointed out by the ld PCIT, the latter is well within his jurisdiction by invoking provisions of section 263 of the Act. 6. Further, the claim of the assessee before the Assessing officer was that the amount of Rs 25 lacs has been received through normal banking channel from M/s Bhole Nath Dealers Pvt. Ltd. towards sale of shares of M/s Booh Finance Pvt. Ltd. In order to examine the said claim of the assessee, the Assessing officer issued a show cause and in response, the assessee submitted that it had purchased 145000 equity shares of Rs 100 each through banking channel in the financial year ended 31.03.2007 and out of these shares, during the year under consideration, the assessee company sold 25000 shares at par to M/s Bhole Nath Dealers Pvt. Ltd. and received a sum of Rs 25 lacs through normal banking channel in its bank account maintained with Axis bank. Further, the assessee submitted copy of the bank statements for verification. The Assessing officer further called for copy of share certificates and in response, the assessee company shown its inability to produce the same for the reason that the assessee company is not in possession of the share certificates as the same has been handed over to the purchaser company. The submissions so filed were considered without any adverse inference by the Assessing officer. In this regard, the ld PCIT has stated that the Assessing officer has accepted the version of the assessee without any verification/confirmation from the purchaser or the broker in a routine manner and the mere fact that the payment has been made through normal banking channel is not enough to establish the genuineness of the transaction and the provisions of section 68 are clearly attracted. We agree with the findings of the ld PCIT and are of the considered view that merely issuing a show-cause and accepting the version of the assessee without any corroborative documentation to support the same and carrying out independent verification is clearly a case where the Assessing officer has failed to carry out necessary verification and examination. The factum and real nature of the transaction being a transaction of sale of shares is clearly not established in the instant case. Merely receiving the amount in the bank statement doesn’t demonstrate the nature of the transaction, it merely demonstrate the mode of discharge of payment. The real nature of the share transaction has to be demonstrated through documentation in terms of contract notes (where executed on stock exchange), broker notes, share certificates, Demat statements, share transfer forms, the acceptance of such transactions by the respective companies in their Board meetings by passing appropriate resolutions, necessary filings with the company law authorities, etc, and all these documentation are required to be examined at the time of initial purchase and subsequent sale. In the instant case, there is nothing on record which can even reasonably demonstrate that the transaction is in nature of sale of shares other than the name of the purchaser and the transaction amount remitted and received in the assessee’s bank account. Therefore, where the Assessing officer is accepting the version of the assessee without any corroborative documentation and without carrying out further enquiries/verification from so called purchaser of the shares, coupled with the fact that the basis of reopening of the assessment was information received from the Investigation Wing and our observation as 5 stated in para 5 above, it is clearly a case where the Assessing officer has failed to carry out necessary verification and examination. 7. Coming to other contention raised by the ld AR that the Ld. Pr.CIT has issued the show cause notice based on the audit objection received from the Audit Party and there is no independent application of mind by the Ld. Pr.CIT and in support, reliance was placed on the decision of the Hon’ble Punjab and Haryana High Court in case of CIT vs Sohana Woollen Mills (supra). Recently, in case of Shri Rajinder Chauhan vs PC IT , Shimla (ITA No. 308/CHD/2020 dated 21.07.2022), this Bench had an occasion to examine similar contention raised by the assessee in that case and our findings therein read as under: 8. Before parting, we deem it appropriate to also address the submissions of the ld. CIT-DR who has carefully in his inimitable style has argued that merely because the exercise was triggered on account of the Audit Objection, this fact by itself may not be a reason to quash the proceedings. For the said purpose, our attention has been invited to Instruction No .7 /2017 para 5.3 which has been reproduced in the earlier part of this order. On a consideration thereof and the proposition of law as cited before us, we find that objections of the ld. CIT-DR are valid. On a careful reading of the decision of the jurisdictional High Court in the case of C IT Vs Sohana Woollen Mills 296 ITR 238 (P&H) we find that the proposition of law as laid down by the jurisdictional High Court is that; “Mere Audit Objection and merely because a different view could be taken were not enough to say that the order of the AO was erroneous or prejudicial to the interests of the Revenue.” A plain reading of the said decision makes it clear that the two reasons being considered by the Hon'ble High Court i.e. Audit Objection and the possibility of the Revisionary Authority having a view different from the view taken by the AO were by itself not sufficient to warrant the exercise of Revisionary Powers u/s 263. The decision proceeds on the we ll accepted legal position of law, namely the order sought to be set aside by the ld . PC IT must necessarily meet the twin requirements of pointing out the error in the order passed and such an error which is also pre judicial to the interests of the Revenue. By merely citing an Audit Objection and setting out facts that a different v iew is also possible on the same set of facts has been held to be not a valid exercise of the Revisionary powers u /s 263 of the Act. Thus , we find that the Hon'ble High Court in the aforesaid decision did not lay down the proposition that in any case where there is an Audit Objection , the ld . PC IT is bar red to consider exercising powers u /s 263. For the sake of completeness, we reproduce para 7 from the aforesaid decision : "7. A reference to the provisions of s. 263 of the Act shows that jurisdiction thereunder can be exercised if the CIT finds that the order of the AO was erroneous and prejudicial to the interest of Revenue. Mere audit objection and merely because a different view could be taken, were not enough to say that the order of the AO was erroneous or prejudicial to the interest of the Revenue. The jurisdiction could be exercised if the CIT was satisfied that the basis for exercise of jurisdiction existed. No rigid rule could be laid down about the situation when the jurisdiction can be exercised. Whether satisfaction of the CIT for exercising jurisdiction was called for or not, has to be decided having regard to a given fact situation." 8.1 Thus, we are of the view that the argument canvassed on behalf of the assessee that merely because theres an Audit Objection , the exercise of powers u / s 263 is invalid , we hold cannot be accepted . What we understand from the aforesaid decision and various other decisions cited on this proposition is that a mechanical exercise of revisionary powers u/s 263 by the Revisionary Authority by merely citing the Audit Objection cannot be said to be a valid exercise of Revisionary Powers. The ld. PCIT is require to give an independent finding considering the record. The error in the order of the AO, that too such an error which is prejudicial to the interests of the Revenue, has to be pointed out by the Revisionary Authority in the order. The onerous power cannot be exercised mechanically 6 and arbitrarily. The sagacious arguments of the ld. CIT-DR to this extent, we find are well founded.” ( Emphasis supplied) 8. Similar view has been taken by the Coordinate Delhi Benches in case of Mannesmann Demag A .G vs DC IT (Supra) wherein it was held as under: “13. We have given our careful consideration to the rival contentions and have perused the records. The contention raised on behalf of the assessee that the action of the Commissioner of Income-tax under Section 263 based on the audit objection is invalid and contrary to law is not wellfounded. Whereas we agree with the learned counsel for the assessee that the powers under Section 263 are vested in the Commissioner of Income-tax and it is he who has to apply his mind before coming to the conclusion that the order passed by the Assessing Officer is erroneous and prejudicial to the interest of revenue, yet, that does not mean that the Commissioner of Income-tax has not to be assisted by anyone else in collecting information and in bringing to his notice any errors or omissions requiring action under Section 263 or under any other provision of the Act. It will be unreasonable to perceive that the Commissioner of Income-tax would himself examine the assessment records of all the assessees within his jurisdiction so as to arrive at a conclusion whether any action under Section 263 is required or not. It is humanly impossible. Therefore, setting up of a machinery known as internal audit which assists the Commissioner of Income tax in this regard is not improper as the said machinery only brings to the notice of the Commissioner of Income-tax the acts of omission, errors and matters of prejudice caused to the revenue. It has to be borne in mind that opinion or the information of the internal audit is not binding upon the CIT. It is a mode for excluding such cases not requiring the attention of the Commissioner for the purposes of consideration of any action under Section 263. Once the matter has been brought to the notice of the CIT, it is the Commissioner who has to exercise his powers under Section 263 and for that purpose it is necessary for him to apply his mind to the facts of the case taking into account the objection raised by the internal audit. Such a consideration would not be contrary to the spirit of the scheme of the Act and the powers of the CIT under Section 263. The learned D.R. has cited the decision of the Supreme Court in the case of Kasturbhai Lalbhai (supra) which as rightly pointed by Shri Ganeshan has been overruled by the Supreme Court in the case of Indian and Eastern Newspaper Society v. CIT [1979] 119 ITR 996. In any case that decision is inapplicable to the facts of this case. We are not called upon to decide as to whether the audit objection shall constitute information for the purposes of re- opening of an assessment under Section 147 as was the issue before the Supreme Court in the aforementioned case. The issue before us is limited as to whether the Commissioner of Income-tax would be justified in taking action under Section 263 when the matter is brought to his notice by the internal audit. In our view, the internal audit being a machinery under the administrative control of the CIT for the purposes of pointing out the acts of omissions, errors and prejudices caused to the revenue, they are doing so for and on behalf of the Commissioner of Income-tax. Such a report as already observed can form the basis for taking action under Section 263 provided the Commissioner of Income-tax applies his mind before deciding as to whether any action under Section 263 is warranted or not. He has not to merely act upon the audit objection in a mechanical manner but has to form his own opinion which would include information and opinion of the auditors. Considering the facts and circumstances of this case and the view expressed above, we do not find any fault with the Commissioner of Income-tax in having initiated action after the receipt of the objection from the internal audit, in so far as, we are satisfied that CIT has applied his mind before taking action under Section 263. This objection raised on behalf of the assessee in this regard is, therefore, rejected. 7 9. Therefore, in the instant case, merely because there is an Audit Objection, contention regarding the exercise of powers u/s 263 as invalid cannot be accepted. What is relevant to examine is whether there is a mechanical exercise of revisionary powers u/s 263 by the ld PCIT by merely citing the Audit Objection or there is due application of mind by him before exercise of such powers. In the instant case, we refer to para 2 of the impugned order wherein it was mentioned that the assessment records were called for by the ld PCIT and examined and thereafter on examination of the records, it was noted that the AO has not made proper and in depth enquiries and thereafter a show cause notice was issued by the Ld. Pr.CIT and the contents thereof read as under: “2. Assessment records were called for and examined. On examination of the record, it is seen that the assessment was completed under section 143(3)r.w.s. 147 of I.T. Act 1961 on 22.11.2018 for the assessment year 2011-12 which is found to have deformities and made without making proper and in depth enquiries. On examination, following issues have been noticed and highlighted in show cause Notice dated 04.03.2021 issued under DIN and notice No.ITBA/REV/F/REV1/2020- 21/1031231924 (1) through online: “4. From the examination of the assessment record for the A.Y. 2011-12, it is noticed that you have failed to submit affidavit from purchaser i.e. M/s BholeNath Dealers Pvt. Ltd. or any documentary evidence regarding proof of transfer of shares/share certificates which was called by the AO at the time of assessment proceedings. But you simply stated that the share certificate was not in possession of the assessee company. Moreover, no bank account statement was submitted by you to justify your contention that all the purchases of share transactions were routed through bank accounts. However in the absence of Share Certificate, any confirmation from purchaser/contract note or Share, Broker's Certificate, the transaction of sale of shares was not substantiated. The mere fact of payment by banking channel, by itself, is not enough to establish the genuineness of transactions. Genuineness of transactions in terms of section 68 of the Act has not been proved by you. 5. There is no evidence on record which can establish that the A.O. had made attempt to collect evidence/papers from Kolkata in respect of round tripping/layering of transactions. The A.O. has allowed the claim of the assessee without any proper verification. The A.O. has neither considered investigation report at the time of framing of assessment nor called any documents/information from Investigation Wing, Ludhiana. Hence, an amount of Rs. 25,00,000/- received on account of sale of shares of M/s Booh Finance Pvt. Ltd. to M/s Bholenath Dealers Pvt. Ltd. was remained unexplained." 10. We therefore do not agree with the contention of the Ld. AR that there is non- application of mind on the part of the Ld. Pr.CIT and the jurisdiction u/s 263 of the Act has been invoked merely on the basis of audit objection. Rather, we find that the ld PCIT has taken into considered the entirety of material on record including audit objection as well as investigation report and thereafter, has considered it appropriate to exercise his revisionary jurisdiction u/s 263 as the perusal of such records prima facie demonstrated that the order so passed by the AO was erroneous as well as prejudicial to the interest of the Revenue. We therefore don’t agree with the contention so advanced by the ld AR in this regard. 11. In light of aforesaid discussions and in the entirety of facts and circumstances of the case, we do not find any infirmity in the exercise of jurisdiction u/s 263 by the ld PCIT and the order so passed is upheld and the grounds of appeal taken by the assessee are dismissed. 8 4. In light of the above, we find that in the garb of misc. application under section 254(2) of the Act, the assessee is seeking review of the detailed and well reasoned order passed by the Coordinate Bench discussing various contentions raised by the assessee relating to audit objections, various legal authorities on the subject including the decision of the Hon’ble Punjab and Haryana High Court in case of Sohana Woollen Mills but at the same time, dismissing the appeal of the assessee. Where the assessee is aggrieved with the order passed by the Coordinate Bench, the statue has provided appropriate legal remedy by way of appeal before the Hon’ble High Court and where the assessee is so advised, he can avail the said legal remedy. However, as far as Tribunal is concerned, we cannot sit in judgment against the decision of the Coordinate Bench and carry out the review as sought by the assessee through its misc. application. We therefore do not find any legal and justifiable basis to act on the said application which is clearly beyond the limited scope of rectification as contemplated under section 254(2) of the Act. 5. In the result, Misc. Application filed by the assessee is dismissed. Order pronounced in the open Court on 28/08/2023 Sd/- Sd/- आकाश दीप जैन िवŢम िसंह यादव (AAKASH DEEP JAIN) (VIKRAM SINGH YADAV) उपाȯƗ / VICE PRESIDENT लेखा सद˟/ ACCOUNTANT MEMBER AG Date: 28/08/2023 आदेश की Ůितिलिप अŤेिषत/ Copy of the order forwarded to : 1. अपीलाथŎ/ The Appellant / 2. ŮȑथŎ/ The Respondent 3. आयकर आयुƅ/ CIT 4. आयकर आयुƅ (अपील)/ The CIT(A) 5. िवभागीय Ůितिनिध, आयकर अपीलीय आिधकरण, चǷीगढ़/ DR, ITAT, CHANDIGARH 6. गाडŊ फाईल/ Guard File आदेशानुसार/ By order, सहायक पंजीकार/ Assistant Registrar