MINING OFFICER, BALODABAZAR,BALODABAZAR V. DCIT (TDS), RAIPUR , RAIPUR

ITA 69/RPR/2025

AI Insights

The case involves multiple appeals by the Mining Officer, Baloda Bazar, against the orders of the Deputy Commissioner of Income Tax (TDS), Raipur, concerning the non-collection of tax at source (TCS) on various illegal mining activities and contributions to the DMF and NMET. The tribunal referenced a prior decision in the case of District Mining Officer, Bemetara Vs. DCIT (TDS), Raipur, which had similar circumstances. The tribunal found that the Mining Officer was required to collect TCS on the compounding fees from illegal miners and transporters and on the contributions to DMF and NMET unless it was demonstrated that these were paid directly by the leaseholders.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 36549 (ITAT-RAIPUR)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 28-02-2025
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: 2019-2020
• Other Referred Cases: District Mining Officer, Bemetara Vs. DCIT (TDS), Raipur (C.G) & Ors, 152 Taxmann.com 583
• Laws Referred To: Income-tax Act, 1961
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: PRIYANKA PATEL
• Assessee Lawyers: N.C GUPTA
• Keywords: Condonation of delay; Capital asset; Opportunity of being heard; Retrospective amendment; TDS; Search and seizure; Non-deduction of tax

Judgement Text

"आयकर अपीलȣय अͬधकरण Ûयायपीठ रायपुर मɅ। IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR BEFORE SHRI RAVISH SOOD, JUDICIAL MEMBER AND SHRI ARUN KHODPIA, ACCOUNTANT MEMBER आयकर अपील सं. / ITA Nos. 63, 64, 65, 66, 67, 68 & 69/RPR/2025 Ǔनधा[रण वष[ / Assessment Years: 2013-14 to 2019-20 Mining Officer, Mining Office, Collectorate Campus, Baloda Bazar (C.G.)493 332 TAN: JBPM08870B .......अपीलाथȸ / Appellant बनाम / V/s. The Deputy Commissioner of Income Tax (TDS), Raipur (C.G.) ……Ĥ×यथȸ / Respondent Assessee by : Shri N.C Gupta Advocate Revenue by : Dr. Priyanka Patel, Sr. DR सुनवाई कȧ तारȣख / Date of Hearing : 28.02.2025 घोषणा कȧ तारȣख / Date of Pronouncement : 28.02.2025 2 Mining Officer Vs. DCIT (TDS), Raipur ITA Nos. 63 to 69/RPR/2025 आदेश / ORDER PER BENCH: The captioned appeals filed by the assessee are directed against the respective orders passed by the Commissioner of Income-Tax (Appeals), National Faceless Appeal Center (NFAC), Delhi, dated 22.08.2024, which in turn arises from the respective orders passed by the A.O under Sec.206C(1C) and (6) & (7) of the Income-tax Act, 1961 (in short ‘the Act’) dated 01.07.2019 for the assessment years 2013-14 to 2019-20. As the facts and issues involved in the captioned appeals are common, therefore, the same are being taken up and disposed off by way of a consolidated order. 2. We shall first take up the appeal filed by the assessee in ITA No.63/RPR/2025 for assessment year 2013-14, wherein the assessee has assailed the impugned order on the following grounds of appeal before us: “1) That under the facts and the law, appellant denied his liability for making TCS on compounding fees received from illegal miners, illegal transporters and for illegal storage of minerals on which royalty is payable. Prayed that the Appellant is a Department of Chhattisgarh Government and is a regulatory authority for mining in the district and that there is no default in making TCS u/s. 206C(1C), the demand kindly be cancelled. 2. That under the facts and the law, the learned CIT (Appeals) erred in confirming the order of learned AO who held that appellant was liable to make TCS on compounding fees received for illegal mining & illegal transportation of Rs.70,363/- comprising of Rs.38,875/- towards Short TCS and Rs.31,488/- towards interest. Prayed that compounding fees is not Royalty and there was no liability to make TCS u/s. 206C(1C) of Income Tax Act, 1961. Above demand be cancelled.” 3 Mining Officer Vs. DCIT (TDS), Raipur ITA Nos. 63 to 69/RPR/2025 3. Shri N.C. Gupta, Ld. Authorized Representative (for short ‘AR’) for the assessee at the threshold of hearing submitted that the captioned appeals involved a delay of 41 days. The Ld. AR had filed an application seeking condonation of delay a/w. “affidavit”, dated 24.02.2025. After perusing the application filed by the assessee a/w. an “affidavit” filed in support thereof, we find that there are justifiable reasons explaining to the delay of 41 days which even otherwise is not inordinate. At this stage, it would be relevant to point out that the Hon’ble Supreme Court in the case of Vidya Shankar Jaiswal Vs. ITO, Ward-2, Ambikapur, Civil Appeal Nos……………../2025 [Special Leave Petition (Civil) Nos. 26310-26311/2024, dated 31.01.2025, had observed that a justice oriented and liberal approach ought to be adopted while considering the aspect of condoning the delay involved in filing of the appeal. Also, the Hon’ble High Court of Chhattisgarh in the case of Jagdish Prasad Singhania Vs. Additional Commissioner of Income Tax (TDS), Raipur (C.G.), TAX Case No.17/2025, dated 24.02.2025, after relying on the judgment of the Hon’ble Supreme Court in the case of Vidya Shankar Jaiswal Vs. ITO, Ward-2, Ambikapur (supra) had held that a justice oriented and liberal approach be adopted while considering the application filed by the assessee for condonation of delay. Accordingly, the delay of 41 days involved in the captioned appeals is condoned. 4 Mining Officer Vs. DCIT (TDS), Raipur ITA Nos. 63 to 69/RPR/2025 4. Succinctly stated, the A.O vide his order passed u/s. 206C(1C) and (6) & (7) of the Act, dated 01.07.2019 had, inter alia, held viz. (i) the assessee was to be held as being default for not collecting tax at source (TCS) a/w. interest on illegal mining, illegal storage and illegal transportation u/s. 206C(1C) and (6) & (7) of the Act; and (ii) for its failure to deduct tax at source in respect of contribution towards District Mining Fund (DMF). Accordingly, the A.O vide his order passed u/s.206C(1C) and (6) & (7) of the Act, dated 01.07.2019 raised a demand of Rs.5,20,32,389/-. 5. Aggrieved, the assessee carried the matter in appeal before the CIT(Appeals). The CIT(Appeals) after taking cognizance of the fact that the issues involved in the present appeal were squarely covered by the order of the ITAT, Raipur in the case of District Mining Officer, Bemetara Vs. DCIT (TDS), Raipur (C.G) & Ors, 152 Taxmann.com 583, dated 21.07.2023, therefore, finding no infirmity in the view taken by the A.O upheld the same. For the sake of clarity, the observation of the CIT(Appeals) are culled out as under: “6. Decision : All the grounds of appeal raised by the appellant are covered by the decision of the Hon'ble Jurisdictional ITAT, Raipur as per its order dt.21.07.2023 in the case of District Mining Officer, Bemtara, 152 Taxmann.com 583, in which the Hon'ble ITAT, Raipur has held as under : \"26. Considering the aforesaid multi-facet contentions of Shri G.S. Agrawal, Ld. AR, we shall now deal with the issue that as to whether or not any obligation was cast upon the assessee to 5 Mining Officer Vs. DCIT (TDS), Raipur ITA Nos. 63 to 69/RPR/2025 collect tax at source (TCS) on the amounts that were received by it as compounding fees (as claimed by the assessee) from the illegal miners/transporters of minerals in the backdrop of the mandate of Section 206C(1C) of the Act r.w. Section 2(47) of the Act, i.e. definition of the term \"transfer\". 27. At the very outset, it may be observed that what is relevant and determinative as regards the obligation of the assessee, i.e. DMO to collect tax at source (TCS) u/s. 206C(1C) of the Act, is as to whether any right or interest, either in whole or in part in the mine was transferred to another person for use of the same for the purpose of business. Existence of a valid lease or license or contract is not a sine qua non, but rather on construing as per the principle of noscitur a sociis the term \"... or otherwise...\" used by the legislature in all its wisdom in section 206C(1C) of the Act, it can safely be concluded that even in absence of any lease or license or contract, if there is any transfer by the assessee of any such right or interest in the mine, then, the case of the assessee would clearly fall within the meaning of sec. 206C(1C) of the Act. 28. Now this takes us to the scope and gamut of the term \"transfer\" in so far the facts involved in the case of the assessee are concerned. As observed by us hereinabove the \"Explanation 2\" to section 2(47) of the Act, as had been made available on the statute vide the Finance Act, 2012 with retrospective effect from 1-4-1962 would be applicable to the case of the assessee for the year under consideration. As per the \"Explanation 2\" (supra) the term \"transfer\" includes and shall be deemed to have always included disposing of or parting with an asset or any interest therein, or creating any interest in any asset in any manner whatsoever, directly or indirectly, absolutely or conditionally, voluntarily or involuntarily or otherwise, by way of an agreement or otherwise. Now a bare perusal of the aforesaid meaning of the term \"transfer\" reveals that the same not only takes within its sweep parting of any interest in an asset or creating any interest in any asset in any manner... .voluntarily or involuntarily, but also dispenses with the existence of an agreement. In fact, the term \"or otherwise\" as used in the aforesaid statutory provision can also be traced in section 206C(1C) of the Act. 29. On the basis of the aforesaid broad meaning of the term \"transfer\" as had been made available on the statute vide the Finance Act, 2012 w.r.e.f 1-4-1962, we shall now look into the aspect that as to whether or not the assessee i.e. DMS:0 had transferred to the illegal miners/transporters of minerals any interest in the mine. 6 Mining Officer Vs. DCIT (TDS), Raipur ITA Nos. 63 to 69/RPR/2025 30. Although it is the claim of the Ld. AR that there is no transfer either of the asset i.e. land or any interest in the same by the assessee i.e. DMO in favour of the illegal miners/transporters of minerals, but a careful perusal of the manner of computing and receipt of compounding fees by the assessee from such illegal miners/transporters of minerals clearly militates against the said claim. As observed by us hereinabove the report of the Mining Officer, Bemetara w.r.t a person, viz. Shri. Dinesh Kothari (supra) who was found extracting and transporting, minerals in contravention of the provisions of CMMR in itself reveals that the illegal miner/transporter of minerals was called upon by the assessee to pay 10 times of the amount of royalty in the form of compounding fees. In sum and substance the illegal miner/transporter of minerals as per Rule 71(5) of the CMMR was required to make payment of market value of mineral so extracted or transported a/w such fine which may extend to double the market value of minerals so extracted or transported but the same in no case was to be less than Rs.5000/- or 10 times of royalty of minerals so extracted, whichever was higher. As per Rule 71(5) of the CMMR an amount i.e. 10 times of royalty of minerals so extracted is collected by the assessee from the illegal miners/transporters of minerals. Our observation is fortified by the aforesaid instance referred to by the Ld. AR wherein an amount of Rs.90,000/- i.e. 10 times of royalty of Rs.9000/- had been collected by the assessee from the illegal miner/transporter of minerals i.e. Shri Dinesh Kothari (supra), Page 24 of APB. Apart from that a reference to a letter dated 12-1-2018 of the Deputy Collector, District-Bemetara i.e. DMO which is addressed to the Police Officer, P.S.-District: Bemetara (as reproduced by us hereinabove), Page 40 of APB, the assessee had itself stated that as the royalty/fine for the illegal mining/transportation of minerals had been received from the illegal miners/transporters, viz. Shri Dinesh Kothari (supra), therefore, his vehicles may be released. 31. On a perusal of the aforesaid facts, we are of the considered view that the assessee by receiving the aforesaid amount i.e. 10 times of, royalty from the illegal miners/transporters of minerals had, in turn, clearly vested/parted with the interest and right in the mine in their favour, which the latter had undeniably used for the purpose of her business. Considering the fact that the orders w.r.t amounts collected by the assessee i.e. DMO from illegal miners/transporters of minerals in itself states that an amount i.e. 10 times of the royalty amount is to be recovered from the illegal miners/transporters, therefore, we are unable to comprehend that as to on what basis it is averred by the Ld. AR that the said amounts so received by the assessee would not fall within the realm of section 206C(1C) of the Act. As the assessee 7 Mining Officer Vs. DCIT (TDS), Raipur ITA Nos. 63 to 69/RPR/2025 in the case before us had not only received royalty from the illegal miners/transporters of minerals as it would have in the normal course received in case of a regular lease or license, but in fact was in receipt of 10 times of royalty amount from them, therefore, the contention of the Ld. AR that the assessee was not exigible for collection of tax at source (TCS) on the amounts received from the illegal miners/transporters of minerals being devoid and bereft of any substance is liable to be rejected. We, thus, in terms of our aforesaid observations, finding no infirmity in the view taken by the lower authorities that the assessee who was liable to collect tax at source (TCS) on the amounts received from illegal miners/transporters, having failed to do so, was to be treated as 'assessee-in-default' u/s. 206C(6) of the Act, uphold the same. Thus, the Ground of appeal No. 1 raised by the assessee is dismissed in terms of our aforesaid observations. 34. Although we are principally clear that as per sec. 9B of the Mines and Minerals (Development and Regulation) Act, 1957 the lease holders remained under an obligation to pay the specified amount of DMF, and no involvement of the assessee can be traced in the scheme of the MMDR Act, but we are afraid that the said factual position cannot be gathered on a perusal of the accounts of the assessee as had been placed before us. We, say so, for the reason that a perusal of the \"Receipts and Payments account\" of the assessee i.e. DMO for the year ending 31-3-2017 reveals reference of 'District Mineral Foundation Trust\" on the same, Page 38 to 41 of APB. Also, a similar position prevails in the audited accounts of the assessee for the immediately succeeding year ending 31-3-2018. Apart from that, we find that in the accounts of the assessee i.e. DMO for the immediately succeeding year i.e. F.Y.2017-18 the payments made by the lease holders towards \"Contribution funds\" are reflected. As the accounts of the assessee prima facie militates against the aforesaid observations arrived at by us by looking into the provisions of section 98 of the Mines and Minerals (Development and Regulation) Act, 1957, therefore, in our considered view the matter in all fairness requires to be revisited by the A.O. The A.0 is directed to verify as to whether the assessee was in receipt of contributions towards DMF from the leaseholders; or as claimed by the assessee the amounts were paid by the respective lease holders directly to the DMF. In case the claim of the assessee i.e. the lease holders were directly making payments to DMF is found to be in order, then as observed by us hereinabove no obligation would be cast upon the assessee to collect tax at source (TCS) on the contributions made by the lease holders to DMF. Needless to say, the A. 0 shall in the course of the set-aside proceedings afford a reasonable opportunity of being heard to the assessee. 8 Mining Officer Vs. DCIT (TDS), Raipur ITA Nos. 63 to 69/RPR/2025 37. Although we are principally clear that as per sec. 9C of the Mines and Minerals (Development and Regulation) Act, 1957 the lease holders remained under an obligation to pay the specified amount of the NMET, and no involvement of the assessee can be traced in the scheme of the MMDR Act, but we are afraid that the said factual position cannot be gathered on a perusal of the accounts of the assessee as had been placed before us. We, say so, for the reason that a perusal of the \"Receipts and Payments account\" of the assessee i.e. DMO for the year ending 31-3-2017 reveals reference of \"District Mineral Foundation Trust\" on the same, Page 38 to 41 of APB. Also, a similar position prevails in the audited accounts of the assessee for the immediately succeeding year ending 31-3-2018. Apart from that, we find that in the accounts of the assessee i.e. DMO for the immediately succeeding year i.e. F. Y. 2017-18 the payments made by the lease holders towards \"Contribution funds\" are therein reflected. As the accounts of the assessee prim-facie militates against the aforesaid observations arrived at by us by looking into the provisions of section 9C of the Mines and Minerals (Development and Regulation) Act, 1957, therefore, in our considered view the matter in all fairness requires to be restored to the file of the A.O. The A.O is directed to verify as to whether the assessee was in receipt of contributions towards NMET from the lease holders; or as claimed by the assessee the amounts were paid by the respective lease holders directly to NMET. In case the claim of the assessee, that the lease holders were directly making payments to NMET is found to be in order, then as observed by us herein above, no obligation would be cast upon the assessee to collect tax at source (TCS) on the amounts paid by the lease holders to NMET. Needless to say, the A.O shall in the course of the set- aside proceedings afford a reasonable opportunity of being heard to the assessee.\" 6.1 Hence, all the grounds of appeal raised by the appellant are dealt in the above referred decision of the Hon'ble Jurisdictional ITAT, Raipur, which is binding on the first Appellate Authority. Hence, following the decision of the Hon'ble ITAT, Raipur, the various issues raised by the appellant are adjudicated as discussed in subsequent paras. 6.2 As held by the Hon'ble ITAT, Raipur in the above referred decision, the appellant was required to collect tax at source on illegal mining and transportation and by not complying the same, the appellant violated provisions of sec.206C(1C) r.w.s.206C(6), 206C(6A) and 206C(7) of the Income Tax Act, 1961. Hence, the order of the A.O. on the issue is confirmed and the demand raised by the A.O. on short TCS and interest thereon u/s.206C(1C) r.w. 206C(6), 206C(6A) and 206C(7) of the Act in respect of illegal 9 Mining Officer Vs. DCIT (TDS), Raipur ITA Nos. 63 to 69/RPR/2025 mining an transportation is confirmed and the appeal raised by the appellant on this issue is dismissed. 6.3 As regards collection of tax at source on amount collected for District Mining Fund (DMF), as per the above referred order of the Hon'ble ITAT, Raipur, the A.O is directed to verify as to whether the appellant was in receipt of contributions towards DMF from the leaseholders; or the amounts were paid by the respective lease holders directly to the DMF. In case the lease holders were directly making payments to DMF, there was no obligation on the appellant to collect tax at source (TCS) on the contributions made by the lease holders to DMF. However, if the appellant was in receipt of contributions towards DMF from the lease holders, the appellant was liable to collect tax at source on these amounts. 6.3.1 Hence, wherever the lease holders had directly made payment to the District Mining Fund, the demand raised by the A.O. including interest thereon u/s.206C(1C) r.w.s. 206C(6), 206C(6A) and 206C(7) of the Act is deleted. 6.3.2 However, wherever the appellant had received contribution from the lease holders towards the District Mining Fund, the demand raised by the A.O including interest thereon u/s.206C(1C) r.w.s.206C(6), 206C(6A) and 206C(7) of the Act is confirmed. 6.3.3 The A.O. is directed to verify as to whether the appellant was in receipt of contributions towards DMF from the leaseholders; or the amounts were paid by the respective lease holders directly to the DMF and give effect to the directions as per para 6.3.1 and 6.3.2 above. Hence, this ground of appeal is adjudicated, subject to the directions as above. 6.4 As regards collection of tax at source on amount collected for National Mineral Exploration Trust (NMET), as per the above referred order of the Hon'ble ITAT, Raipur, the A.O is directed to verify as to whether the appellant was in receipt of contributions towards NMET from the leaseholders; or the amounts were paid by the respective lease holders directly to the NMET. In case the lease holders were directly making payments to NMET, there was no obligation on the appellant to collect tax at source (TCS) on the contributions made by the lease holders to NMET. However, if the appellant was in receipt of contributions towards NMET from the lease holders, the appellant was liable to collect tax at source on these amounts. 10 Mining Officer Vs. DCIT (TDS), Raipur ITA Nos. 63 to 69/RPR/2025 6.4.1 Hence, wherever the lease holders had directly made payment to the National Mineral Exploration Trust, the demand raised by the A.O. including interest thereon u/s.206C(1C) r.w.s. 206C(6), 206C(6A) and 206C(7) of the Act is deleted. 6.4.2 However, wherever the appellant had received contribution from the lease holders towards the National Mineral Exploration Trust, the demand raised by the A.O. including interest thereon u/s.206C(1C) r.w.s. 206C(6), 206C(6A) and 206C(7) of the Act is confirmed. 6.4.3 The A.O. is directed to verify as to whether the appellant was in receipt of contributions towards NMET from the leaseholders; or the amounts were paid by the respective lease holders directly to the NMET and give effect to the directions as per para 6.4.1 and 6.4.2 above. Hence, this ground of appeal is adjudicated, subject to the directions as above. 7. In the result, the appeal is partly allowed.” 6. The assessee being aggrieved with the order of the CIT(Appeals) has carried the matter in appeal before us. 7. We have heard the Ld. Authorized Representatives of both the parties and perused the orders of the lower authorities, as well as considered the order of the Tribunal passed in the case of District Mining Officer, Bemetara Vs. DCIT (TDS), Raipur (C.G) & Ors, 152 Taxmann.com 583. 8. Shri N.C Gupta, Ld. Authorized Representative (for short ‘AR’) for the assessee at the threshold submitted that the issues involved in the present appeal are squarely covered by the order of the Tribunal in the case of District Mining Officer, Bemetara Vs. DCIT (TDS), Raipur (C.G) & Ors, 152 Taxmann.com 583. 11 Mining Officer Vs. DCIT (TDS), Raipur ITA Nos. 63 to 69/RPR/2025 9. Per contra, Dr. Priyanka Patel, Ld. Departmental Representative (for short ‘DR’) submitted that both the issues involved in the present appeal, viz. (i) the assessee’s default in not collecting tax at source (TCS) a/w. interest on illegal mining, illegal storage and illegal transportation u/s. 206C(1C) and (6) & (7) of the Act; and (ii) for its failure to deduct tax at source in respect of contribution towards District Mining Fund (DMF), had been deliberated at length by the ITAT, Raipur while disposing of the appeals in the cases of District Mining Officer, Bemetara Vs. DCIT (TDS), Raipur (C.G) & Ors, 152 Taxmann.com 583, therefore, no infirmity did emerge from the order of the CIT(Appeals) who had rightly followed the same and dismissed the appeal. 10. We have given thoughtful consideration to the contentions advanced by the Ld. Authorized Representatives of both the parties in the backdrop of the order passed by the Tribunal in the case of District Mining Officer, Bemetara Vs. DCIT (TDS), Raipur (C.G) & Ors, 152 Taxmann.com 583. As the CIT(Appeals) had followed the view taken by the Tribunal qua the identical issues, therefore, finding no infirmity in the same, we uphold his order. 11. In the result, the appeal of the assessee in ITA No.63/RPR/2025 for A.Y.2013-14 is dismissed in terms of our aforesaid observations. 12 Mining Officer Vs. DCIT (TDS), Raipur ITA Nos. 63 to 69/RPR/2025 ITA Nos. 64, 65, 66, 67, 68 & 69/RPR/2025 A.Ys: 2014-15 to 2019-20 12. As the facts and issues involved in the captioned appeals remains the same as were there before us in ITA No.63/RPR/2025 for A.Y.2013-14, therefore, our findings recorded while disposing of the appeal in ITA No.63/RPR/2025 for A.Y.2013-14 shall mutatis mutandis apply for disposing off the captioned appeals, i.e. ITA Nos. 64, 65, 66, 67, 68 & 69/RPR/2025, A.Ys: 2014-15 to 2019-20. Accordingly, we dispose off the captioned appeals on the same terms as were recorded by us while adjudicating the respective issues in ITA No.63/RPR/2025 for A.Y.2013-14. 13. In the result, appeals of the assessee in ITA No. ITA Nos. 64, 65, 66, 67, 68 & 69/RPR/2025, A.Ys: 2014-15 to 2019-20 are dismissed in terms of our aforesaid observations. 14. Resultantly, all the appeals of the assessee are dismissed in terms of our aforesaid observations. Order pronounced in open court on 28th day of February, 2025. Sd/- Sd/- RAVISH SOOD ARUN KHODPIA (JUDICIAL MEMBER) (ACCOUNTANT MEMBER) रायपुर/ RAIPUR ; Ǒदनांक / Dated : 28th February, 2025. SB, Sr. PS आदेश कȧ ĤǓतͧलͪप अĒेͪषत / Copy of the Order forwarded to : 1. अपीलाथȸ / The Appellant. 13 Mining Officer Vs. DCIT (TDS), Raipur ITA Nos. 63 to 69/RPR/2025 2. Ĥ×यथȸ / The Respondent. 3. The Pr. CIT, Raipur-1 (C.G) 4. ͪवभागीय ĤǓतǓनͬध, आयकर अपीलȣय अͬधकरण, रायपुर बɅच, रायपुर / DR, ITAT, Raipur Bench, Raipur. 5. गाड[ फ़ाइल / Guard File. आदेशानुसार / BY ORDER, // True Copy // Senior Private Secretary आयकर अपीलȣय अͬधकरण, रायपुर / ITAT, Raipur. "