MANOJ ANAND,GUWAHATI V. ITO W-2(2) GHY, GUWAHATI

ITA 273/GTY/2024

AI Insights

The case involves Manoj Anand, who appealed against the order of the National Faceless Appeal Centre, Delhi, which confirmed the addition of 3,43,50,000 as unexplained cash credit to his income for the Assessment Year 2018-19. The addition was initially made by the AO after discovering that M/s Urch Trader (P) Ltd. had transferred a substantial amount to Anand's account, which was deemed suspicious. The Tribunal found that the authorities had not adequately considered the evidence provided by Anand, including the confirmation of transactions by M/s Urch Trader (P) Ltd. and the lack of any direct evidence linking Anand to any wrongdoing. The Tribunal emphasized the need for a fair opportunity for cross-examination and the examination of all relevant documents before making such a significant addition to a taxpayer's income.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 792509 (ITAT-GUWAHATI)
• Duration Of Justice: 11 month(s) 28 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 02-12-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB
• Assessment Year: 2018-2019
• Appeal Filed On: 04-12-2024
• Other Referred Cases: Kale Khan Mohammad Hanif Vs. CIT, Roshan-Di-hatti Vs. CIT, Nemi Chand Kothari Vs. CIT, PCIT Vs. Sreeleathers, Andaman Timber Industries Vs. CIT
• Laws Referred To: Income Tax Act
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SANJAY JHA
• Assessee Lawyers: MIRAJ D SHAH
• Keywords: Set aside; Question of law; Unexplained cash credit; Onus to prove; Principle of natural justice; Accommodation entries; Bogus loan; Borrowed satisfaction; Bogus
• Section: 147; 148; 143(3); 68; 133(6)

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL GUWAHATI BENCH, GUWAHATI (Through virtual hearing at Kolkata) BEFORE SHRI RAJESH KUMAR, AM AND SHRI MANOMOHAN DAS, JM ITA No.273/GTY/2024 (Assessment Year: 2018-19) Manoj Anand Flat 4D, Garima Grand, Departmental Representative B. Baruah road, Guwahati-781007, Assam Vs. ITO W-2(2), GHY Aaykar Bhawan, Christian Basti, G.S. Road, Guwahati-781005, Assam (Appellant) (Respondent) PAN No. AGBPA9883C Assessee by : Shri Miraj D Shah, AR Revenue by : Shri Sanjay Jha, DR Date of hearing: 02.12.2025 Date of pronouncement: 02.12.2025 O R D E R Per Rajesh Kumar, AM: This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 08.10.2024 for the AY 2018-19. 2. The issues raised in ground no.1 and 2 are general in nature and are not requiring any specific adjudication. 3. The ground no.3 is against the order of ld. CIT (A) confirming the addition of ₹3,43,50,000/- as made by the ld. AO as unexplained cash credit u/s 68 of the Act. Printed from counselvise.com Page | 2 ITA No.273/GTY/2024 Manoj Anand; A.Y. 2018-19 3.1. The facts in brief are that the assessee filed the return of income on 30.08.2018, declaring the total income of ₹9,42,440/-. The case of the assessee was reopened u/s 147 of the Act by issuing notice u/s 148 of the Act on 30.03.2022, after the ld. AO received the information through insight portal, which revealed that M/s Urch Trader (P) Ltd. has transferred a sum of ₹3,43,15,000/- in the account of the assessee. It was also stated that during the course of inquiry by the investigation wing into the financials of Urch Trader (P) Ltd. that the said party was not having any creditworthiness and these transactions were of suspicious nature. The assessee filed the return of income on 26.05.2022 in compliance to notice u/s 148 of the Act, declaring the same income as shown in the original return. The statutory notices were issued to the assessee along with questionnaire which were duly served on the assessee. The assessee replied the questionnaire vide written submissions dated 22.12.2022. Thereafter, the assessee filed the details/ information before the ld. AO and the ld. AO on the basis of said details/ information and also the information available on the insight portal of the department noted that the assessee was a salaried employee and only declared income of ₹9,42,440/- for the instant instant assessment year and thus, doubted the amount advanced by Urch Trader (P) Ltd. of ₹3,43,50,000/- to the assessee. Finally, the loan taken was treated as unexplained cash credit/ bogus credit and added to the income of the assessee u/s 68 of the Act in the assessment framed u/s 147 read with section 144B of the Act dated 25.03.2023. 3.2. In the appellate proceedings, the ld. CIT (A) also confirmed the order of the ld. AO by dismissing the appeal of the assessee by observing and holding as under:- Printed from counselvise.com Page | 3 ITA No.273/GTY/2024 Manoj Anand; A.Y. 2018-19 “The sole issue involved in the appellant's appeal is that during the relevant previous year the appellant received unsecured loans of Rs. 3,43,50,000/- from M/s. Urch Trader Pvt. Ltd. and on verification the AO found that the creditworthiness of M/s. Urch Trader Pvt. Ltd. and transaction of said loan is not genuine and hence this sum of Rs. 3,43,50,000/- is added to the total income of appellant u/s. 68 of the Act. Briefly stated the fact of the case is that the AO was in possession of information that during the relevant previous year, appellant has received sum of Rs. 3,43,50,000/- from M/s. Urch Trader Pvt. Ltd. and as per the report of investigation wing of the department, the creditworthiness of M/s. Urch Trader Pvt. Ltd. was suspicious and the said sum received by the appellant is in the nature of accommodation entry, after routing through various shell companies. During the course of assessment proceedings, the appellant was offered various opportunities to prove the creditworthiness of M/s. Urch Trader Pvt. Ltd. and genuineness of transaction, however the explanation offered by the appellant is found not satisfactoryto the AO and hence the said amount of loan received was brought to tax as income of the appellant u/s.68 of the Act. During the course of appellate proceedings also the appellant made similar submission as made before the AO during the assessment proceedings. The appellant submitted that he is a salaried person working as journalist and columnist with Deccan chronicles Pvt. Ltd and during the relevant previous year received sum of Rs. 3,43,50,000/- from M/s. Urch Trader Pvt. Ltd. as unsecured loan, said to be for the purpose of investment in his educational venture in the name of AARDA Education wherein he is one of the trustees/manager. The appellant also filed copy of bank statements of M/s. Aarda Education and M/s. Urch Trader Pvt. Ltd. The written submission alongwith documentary evidence provided by the appellant have been carefully perused and considered. It is an admitted fact that during the relevant previous year the appellant has received the sum of Rs. 3,43,50,000/- from M/s. Urch Trader Pvt. Ltd. as unsecured loan. On enquiries and investigation carried out by the investigation wing of the department, it is found that loan received from M/s. Urch Trader Pvt. Ltd. is in the nature of accommodation entry. It is further found that the sum of money received by the appellant from M/s. Urch Trader Pvt. Ltd. was routed through two shell companies namely Shree Sai Smelters India Ltd. and Shree Sai Rowling India Ltd. against which the government agencies are carrying out proceedings in respect of financial irregularities. Further M/s. Urch Trader Pvt. Ltd. an NBFC was declared as high risk NBFC on account of violation of PMLA and PML rulesby the RBI vide order dated 31.01.2018. It is also noted that the appellant is a salaried person who had declared total income of Rs. 9,42,440/- for the year under consideration and thus is not having sufficient creditworthiness to repay such a huge amount of unsecured loan taken. It is further noted that no security/ asset of whatsoever nature has been mortgaged with M/s. Urch Trader Pvt. Ltd. as security against such a huge amount of loan taken. Further, M/s. Urch Trader Pvt. Ltd did not charge any interest on such ahuge amount of unsecured loan taken. It is further seen from the copies of appellant’s ledger account for the FY 2016-17 to 2023-24 as appearing in the books of M/s. Urch Trader Pvt. Ltd. filed by the appellant during the appellate proceeding that total loan of Rs. 3,43,50,000/- was taken during the period from 8 th May 2017 to 30th June 2017 and Printed from counselvise.com Page | 4 ITA No.273/GTY/2024 Manoj Anand; A.Y. 2018-19 thenafter this entire loan amount of Rs. 3,43,50,000/- was outstanding till 13th December 2022, when payment of Rs.53,00000/- is shown to have been made by the appellant. Thus loan of Rs. 3,43,50,000/- was outstanding for more than 5 years and even after that a small amount of repayment is shown from the appellant. It is not possible that any NBFC which generally carries on the business of advancing loan on interest shall advance such a huge amount of loan to any person, without charging interest, without taking any security and is not concerned about therepayment of even principle amount. All these facts clearly indicate that the said loan received by the appellant is not a genuine loan. It is also noted from the copies of bank statements of Urch Trading Pvt. Ltd. that whatever sum of money is credited, the equivalent amount is transferred either to Aarda Foundation or the appellant Mr. Manoj Anand on the same day. This also shows the suspicious nature of activity being carried out by M/s Urch Trading Pvt. Ltd. without any business rationale. Considering the above facts of the case and in law, I fully concur with the findings given by the AO in the assessment order that the transaction of unsecured loans of Rs. 3,43,50,000/- taken by the appellant from Urch Trading Pvt. Ltd. is not genuine. Even otherwise, the appellant failed to justify the creditworthiness and genuineness of said Loan transaction with M/s Urch Trading Pvt. Ltd. The addition of Rs. 3,43,50,000/- made by the AO in the assessment order is thereforeupheld. This ground of appeal raised by the appellant is thus dismissed.” 3.3. The ld. AR vehemently submitted before us that both the authorities below have failed to appreciate the facts in the correct perspective. The ld. AR submitted that the assessee has filed all the details qua the lender comprising ITR, audited accounts, confirmation bank statement and assessment order u/s 143(3) of the Act for A.Y. 2017-18. The ld. AR submitted that the assessee has explained the said loan as taken for some specific purpose and back-to-back given it for investment in one educational institution AARDA Education, which has used the same to set up a school called DPS School in Basistha Chariali DPS, Kamrup, Assam. The ld. AR also referred to the reply filed by the loan creditor in response to notice u/s 133(6) of the Act, thereby affirming the transactions with the assessee. The ld. AR submitted that the assessee has discharged its onus cast upon him by filing all the documents and even sought cross-examination of the parties who has made adverse statements, however the same was not allowed. The ld. AR stated that at the time of proceeding u/s Printed from counselvise.com Page | 5 ITA No.273/GTY/2024 Manoj Anand; A.Y. 2018-19 148A(d) of the Act, no material / evidences as relied on by the ld. AO were provided to the assessee. Therefore, the same could not be used against the assessee to make the additions. In defense of his argument the ld. AR relied on the decision of Hon'ble Apex Court in the case of Kale Khan Mohammad hanif Vs. CIT (1963) 50 ITR 1 (SC) and Roshan-Di-hatti Vs. CIT (1977) 107 ITR 938, Nemi Chand Kothari Vs. CIT (2003) 264 ITR 254, PCIT Vs. Sreeleathers (2022) 448 ITR 332. 3.4. The ld. AR also submitted that the assessment framed by the ld. AO is bad in law even on the ground of violation of natural justice. The ld. AR submitted that the ld. AO collected the material and statement behind back of the assessee which were used against him in making addition but no opportunity was provided to the assessee to examine the adverse material or adverse witnesses. The ld. AR submitted that it is a well settled law that if cross examination is not allowed then material collected by the AO cannot be used against the assessee and no adverse inference can be drawn for the purpose of making disallowance/ addition. In defense of his arguments the ld. AR relied on the decision of Hon'ble Apex court in the case of Andaman Timber Industries in Civil Appeal No.4228 of 2006 (2015) (324) ELT 641 (SC). 3.5. The ld. DR on the other hand relied on the orders of the authorities below by submitting that the assessee has taken accommodation entries from M/s Urch Trading Pvt. Ltd., which is a shell company engaged in the business of providing the bogus loans/ accommodation entries to various entities. The ld. DR submitted that the ld. AO has rightly acted on the basis of report of the investigation wing and the information available on the insight portal of the Printed from counselvise.com Page | 6 ITA No.273/GTY/2024 Manoj Anand; A.Y. 2018-19 departments and made addition. Therefore, the appeal of the assessee may be dismissed by upholding the order of the ld. CIT (A). 3.6. After hearing the rival contentions and perusing the materials available on record, we find that the assessee raised a loan of ₹3,43,50,000/- from M/s Urch Trading Pvt. Ltd. and immediately thereafter it was advanced to educational institution namely; AARDA Education and the money was used for setting up a DPS School in Kamrup, Assam. We note that Aarda Education was a Section 8 company jointly promoted by the assessee and the lender for setting up the DPS School at Baihata Chariali, Assam. This clearly demonstrates the clear commercial rationale and bona fide nature of the transaction and therefore we are not in agreement with the conclusion of the ld. CIT(A) that it is an accommodation entry or colorable device. We note that the assessee furnished before both the authorities below all the evidences proving the identity and creditworthiness of the lenders and genuineness of the transactions. During the course of assessment proceedings as well as in the appellate proceedings, the assessee had filed all the documents before the authorities comprising ITR, audited balance sheet, loan confirmation, bank statement and even assessment order u/s 143(3) of the Act foray 2017-18 in case of the lender. We also note that the ld. AO in order to independently verify the transactions issued notice u/s 133(6) of the Act to M/s Urch Trading Pvt. Ltd., which was duly replied by the said party by confirming the transactions as is apparent from the records before us. The authorities below have not pointed out any defect or deficiency in the documents furnished by the assessee as well as by the lender by doing any further enquiry. Therefore, we are not in a position to sustain the order passed by the Printed from counselvise.com Page | 7 ITA No.273/GTY/2024 Manoj Anand; A.Y. 2018-19 ld. CIT (A). The case of the assessee is squarely supported by the decision of the jurisdictional High Court in the case of Calcutta High Court in the case of PCIT Vs Sreeleathers (2022)448 ITR 332(Cal) wherein in it has been held as under: “4. Before we examine the correctness of the order passed by the Tribunal and consider whether a substantial question of law arises for consideration in this appeal we need to take note of section 68 of the Act. This provision deals with cash credits. It states that where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about the nature and source thereof or the explanation offered by him is not in the opinion of the Assessing Officer, satisfactory, the sum so credited may be charged to income tax as the income of the assessee of that previous year. The crucial words in the said provision are \"assessee offers no explanation\". This would mean where the assessee offers no proper, reasonable and acceptable explanation as regard the amount credited in the books maintained by the assessee. No doubt the Income-tax Act places the burden of proof on the tax payer. However, this is only the initial burden. In cases where the assessee offers an explanation to the credit by placing evidence regarding the identity of the investor or lender along with their conformations, it has been held that the assessee has discharged the initial burden and, therefore, the burden shifts on the Assessing Officer to examine the source of the credit so as to be justified in referring to section 68 of the Act. After the Assessing Officer puts the assessee on notice and the assessee submits the explanation with regard to the cash credit, the Assessing Officer should consider the same objectively before he takes a decision to accept or reject it. In Sreelekha Banerjee v. CIT [1963] 49 ITR 112 (SC), it was held that if the explanation given by the assessee shows that the receipt is not of income nature, the department cannot convert good proof into no proof or otherwise unreasonably reject it. On the other hand, if the explanation is unconvincing, the same can be rejected and an inference shows that the amount represents undisclosed income either from a disclosed or an undisclosed source CIT v. P. Mohanakala [2007] 161 Taxman 169/291 ITR 278/210 CTR 20 (SC). The explanation given by the assessee cannot be rejected arbitrarily or capriciously, without sufficient ground on suspicion or on imaginary or irrelevant grounds Lal Mohan Krishna Lal Paul v. CIT [1944] 12 ITR 441 (Cal.) and Anil Kumar Singh v. CIT [1972] 84 ITR 307 (Cal.). 5. Further to be noted that where the assessee furnishes full details regarding the creditors, it is up to the department to pursue the matter further to locate those creditors and examine their creditworthiness. It has been further held in A.S. Sivan Pillai v. CIT [1958] 34 ITR 328 (Mad.) that while drawing the inference, it cannot be assumed in the absence of any material that there has been some illegalities in the assessee's transaction. Thus, more importantly, as held by the Hon'ble Supreme Court in CIT v. Daulat Ram Rawatmull [1973] 87 ITR 349 (SC), the onus of proving that the appellant was not the real was on the party who claims it to be so. Bearing the above legal principles in mind, if we examine the case on hand, it is clear that the assessing officer issued show cause notice only in respect of one of the lender M/s. Fast Glow Distributors. The assessee responded to the show cause notice and submitted the reply Printed from counselvise.com Page | 8 ITA No.273/GTY/2024 Manoj Anand; A.Y. 2018-19 dated 22-12-2017.The documents annexed to the reply were classified under 3 categories namely: to establish the identity of the lender, to prove the genuineness of the transactions and to establish the creditworthiness of the lender. The assessing officer has brushed aside these documents and in a very casual manner has stated that mere filing PAN details, balance sheet does not absolve the assessee from his responsibility of proving the nature of transaction. There is no discussion by the assessing officer on the correctness of the stand taken by the assessee. Thus, going by the records placed by the assessee, it could be safely held that the assessee has discharged his initial burden and the burden shifts on the assessing officer to enquire further into the matter which he failed to do. In more than one place the assessing officer used the expression \"money laundering.\" We find such usage to be uncalled for as the allegations of money laundering is a very serious allegations and the effect of a case of money laundering under the relevant Act is markedly different. Therefore, the assessing officer should have desisted from using such expression when it was never the case that there was any allegations of money laundering. Paragraphs 5.4 and 5.5 of the assessment order are all personal perception and opinion of the assessing officer which needs to be ignored. Much reliance was placed on the statement of Shri Ashish Kumar Agarwal, which statement has been extracted in full in the assessment order and it cannot be disputed that there is no allegation against the assessee company in the said statement. There is no evidence brought on record by the assessing officer to connect the said entry operator with the loan transaction done by the assessee. Therefore, the statement is of little avail and could not have been the basis for making allegations. The assessing officer ignored the settled legal principle and in spite of the assessee having offered the explanation with regard to the loan transaction, no finding has been recorded as regards the satisfaction on the explanation offered by the assessee. Therefore, the assessing officer ignored the basic tenets of law before invoking his power under section 68 of the Act. Fortunately, for the assessee, CIT(A) has done an elaborate factual exercise, took into consideration, the creditworthiness of the 13 companies the details of which were furnished by the assessee. More importantly, the CIT noted that all these companies responded to the notices issued under section 133 (6) of the Act which fact has not been denied by the assessing officer. On going through the records and the net worth of the lender companies, the CIT has recorded the factual findings that the net worth of those companies is in crores of rupees and they have declared income to the tune of Rs. 45,00,000/- and 75,00,000/-. Therefore, the assessing officer if in his opinion found the explanation offered by the assessee to be not satisfactory, he should have recorded so with reasons. We find that there is no discussion on the explanation offered by the assessee qua, one of the lenders. Admittedly, the assessee was not issued any show cause notice in respect of other lenders. However, they are able to produce the details before the CIT(A) who had in our view rightly appreciated the facts and circumstances of the case. As pointed out earlier, the assessing officer brushed aside the explanation offered by the assessee by stating that merely filing PAN details, balance sheet does not absolve the assessee from his responsibilities of proving the nature of transactions. It is not enough for the assessing officer to say so but he should record reasons in writing as to why the documents which were filed by the assessee along with the reply dated 22-12-2017 does not go to establish the identity of the lender or prove the genuineness of the transaction or establish the creditworthiness of the lender. In the absence of any such finding, we have to hold that the order passed by the assessing Printed from counselvise.com Page | 9 ITA No.273/GTY/2024 Manoj Anand; A.Y. 2018-19 officer was utterly perverse and rightly interfered by the CIT(A). The Tribunal re- appreciated the factual position and agreed with the CIT(A). The tribunal apart from taking into consideration, the legal effect of the statement of Ashish Kumar Agarwal also took note of the fact that the notices which were issued by the assessing officer under section 133(6) of the Act to the lenders where duly acknowledged and all the lenders confirmed the loan transactions by filing the documents which were placed before the tribunal in the form of a paper book. These materials were available on the file of the assessing officer and there is no discussion on this aspect. Thus, we find that the tribunal rightly dismissed the appeal filed by the revenue. 6. For all the above reasons, we find that no question of law much less, substantial question of law arises for consideration in this appeal. 7. Accordingly, the appeal fails and is dismissed. 3.7. We note that the addition made by the Assessing Officer is based solely on suspicion, generalized allegations relating to third parties, and reliance on purported statements recorded in unrelated search proceedings none of which were ever furnished/confronted to the assessee or subjected to cross-examination without enquiring or dealing with the evidences furnished by the assessee. Further in our opinion the reliance on untested, undisclosed material is a direct violation of the fundamental principles of natural justice as enunciated by the Hon'ble Supreme Court in Andaman Timber Industries(Supra). We also note that no adverse material, no cash trail, rotation of funds, or incriminating evidencesrelating to the assessee's transaction was brought on records by the authorities below. We further note that no enquiry has been conducted into the documents/evidences furnished by the assessee. The reassessment itself is based on borrowed satisfaction arising merely from FIU alerts and Investigation Wing references, without any application of mind to the assessee's own facts or records. Moreover no cross examination was allowed to the assessee to examine the material and the person whose statement was relied by the AO which in violation of natural Printed from counselvise.com Page | 10 ITA No.273/GTY/2024 Manoj Anand; A.Y. 2018-19 justice. The case of the assessee is squarely covered by the decision of Andaman Timber Industries (supra), held as under:- “\"According to us, not allowing the assessee to cross-examine the witnesses by the Adjudicating Authority though the statements of those witnesses were made the basis of the impugned order is a serious flaw which makes the order nullity inasmuch as it amounted to violation of principles of natural justice because of which the assessee was adversely affected It is to be borne in mind that the order of the Commissioner was based upon the statements given by the aforesaid two witnesses. Even when the assessee disputed the correctness of the statements and wanted to cross-examine, the Adjudicating Authority did not grant this opportunity to the assessee. It would be pertinent to note that in the impugned order passed by the Adjudicating Authority he has specifically mentioned that such an opportunity was sought by the assessee. However, no such opportunity was granted and the aforesaid plea is not even dealt with by the Adjudicating Authority As far as the Tribunal is concerned, we find that rejection of this plea is totally untenable. The Tribunal has simply stated that cross- examination of the said dealers could not have brought out any material which would not be in possession of the appellant themselves to explain as to why their ex-factory prices remain static. It was not for the Tribunal to have guess work as to for what purposes the appellant wanted to cross-examine those dealers and what extraction the appellant wanted from them. As mentioned above, the appellant had contested the truthfulness of the statements of these two witnesses and wanted to discredit their testimony for which purpose it wanted to avail the opportunity of cross-examination. That apart, the Adjudicating Authority simply relied upon the price list as maintained at the depot to determine the price for the purpose of levy of excise duty. Whether the goods were. in fact, sold to the said dealers/witnesses at the price which is mentioned in the price list itself could be the subject matter of cross-examination. Therefore, it was not for the Adjudicating Authority to presuppose as to what could be the subject matter of the cross- examination and make the remarks as mentioned above. We may also point out that on an earlier occasion when the matter came before this Court in Civil Appeal No. 2216 of 2000, order dated 17.03.2005 was passed remitting the case back to the Tribunal with the directions to decide the appeal on merits giving its reasons for accepting or rejecting the submissions. In view the above, we are of the opinion that if the testimony of these two witnesses is discredited, there was no material with the Department on the basis of which it could justify its action, as the statement of the aforesaid two witnesses was the only basis of issuing the Show Cause We, thus, set aside the impugned order as passed by the Tribunal and allow this appeal.\" 3.8. Considering the facts and circumstances of the case and also the ratio laid in the above decisions, we are inclined to set aside the Printed from counselvise.com Page | 11 ITA No.273/GTY/2024 Manoj Anand; A.Y. 2018-19 order of learned CIT (A) and direct the AO to delete the addition. The appeal of the assessee is allowed. 4. In the result, the appeal of the assessee is allowed. Order pronounced in the open court on 02.12.2025. Sd/- Sd/- (MANOMOHAN DAS) (RAJESH KUMAR) (JUDICIAL MEMBER) (ACCOUNTANT MEMBER) Guwahati, Dated: 02.12.2025 Sudip Sarkar, Sr.PS Copy of the Order forwarded to: BY ORDER, True Copy// Sr. Private Secretary/ Asst. Registrar Income Tax Appellate Tribunal, Guwahati 1. The Appellant 2. The Respondent 3. CIT 4. DR, ITAT, 5. Guard file. Printed from counselvise.com "