P P CORPORATION,RAJKOT V. PRINCIPAL COMMISSIONER OF INCOME TAX, RAJKOT

ITA 245/RJT/2024

AI Insights

The case involves P P Corporation, which appealed against the order of the Principal Commissioner of Income Tax (PCIT) under section 263 of the Income Tax Act, 1961. The PCIT had set aside the assessment order passed under section 143(3) by the assessing officer, claiming it was erroneous and prejudicial to the interests of the revenue concerning unsecured loans received by the assessee. The tribunal examined the inquiries made by the assessing officer during the assessment proceedings and the responses provided by the assessee. It was concluded that the assessing officer had conducted sufficient inquiries and the assessment order was not erroneous or prejudicial to the interests of the revenue, leading to the quashing of the PCIT's order.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 126906 (ITAT-RAJKOT)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 24-04-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB
• Assessment Year: 2018-2019
• Other Referred Cases: CIT vs. Chandrashekhar Narsangli, CIT v. Gabriel India Lid., CIT v. Leisure Wear Exports Ltd., H. H. Maharaja Raja Pawer Dewas v. CIT, Malabar Industries Ltd. vs. CIT
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SANJAY PUNGALIYA; LD
• Assessee Lawyers: R.B. SHAH LD
• Keywords: Opportunity of being heard; Income from undisclosed sources; TDS; Revision of order
• Section: 143(3); 142(1); 263; 251; 133(6); 13

Judgement Text

"ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 1 IN THEINCOME TAXAPPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LALSAINI, AM. & DINESH MOHAN SINHA, JM आयकरअपीलसं./ITA No.245/RJT/2024 नधा\u000fरणवष\u000f / Assessment Year: (2018-19) (Hybrid Hearing) P P CORPORATION, Pradhyuman Royal Heights, Opp. Neel DA Dhaba, Kalawad Road, Rajkot 360005 Vs. Principal Commissioner of Income Tax, Aaykar Bhawan, Race Course Ring Road, Rajkot 360001 \u0013थायीलेखासं./जीआइआरसं./PAN/GIR No.: AAPFP9190H (Appellant) (Respondent) Appellant by : Shri R.B. Shah Ld. AR Respondent by : Shri Sanjay Pungaliya, Ld. CIT(DR) Date of Hearing :27/03/2025 Date of Pronouncement :24/04/2025 आदेश / O R D E R Per, Dr. A. L. SAINI- AM, By way of this appeal, the assessee has called into question correctness of impugned order passed by the learned Principal Commissioner of Income Tax( in brief “Ld. PCIT”) under section 263 of the Income tax Act, 1961, in the matter of assessment under section 143(3) of the Act for the assessment year 2018-19, on the following grounds: 1. That on the facts and in the circumstances of the case Learned PCIT has erred in initiatingand passing the revision order u/s 263 of the Act. ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 2 2. That on facts and in circumstances of the case the Learned PCIT has erred in setting aside the order passed u/s 143(3) r.w.s. 144B of the Income Tax Act, 1961 by the Learned assessing officer. 2.1 The PCIT has erred in holding that Assessment order passed by the Learned assessing officer is erroneous in so far as it is prejudice to the interest of the revenue, therefore setting aside the Assessment order to the Learned assessing officer to re- examine the issue of unsecured loan after making necessary verification, inquiries and investigation. 3.The Appellant crave leave to add, alter amend or delete all or any of the grounds of appeal any time before finalizing of appeal. 2.The relevant material facts, as culled out from the material on record, are as follows. The Assessee had filed its return of income for assessment year (A.Y.) 2018-19, on 10/08/2018, declaring total income of Rs. Nil. The case was selected for complete scrutiny by \"CASS\". The Assessment was finalised u/s 143(3) r.w.s. 144B of the Income-tax Act, 1961, on 08/05/2021, accepting returned income of Rs. NIL. 3.Later on, learned Principal Commissioner of Income Tax( in brief “Ld. PCIT”), exercised his jurisdiction, under section 263 of the Income tax Act 1961. On perusal of case records, it was noticed by the ld. PCIT that during the previous year 2017-18, relevant to assessment year (A.Y.) 2018-19, the assessee had received unsecured loans from 28 persons to the tune of Rs. 18,16,59,360/-. The Assessing officer called for the details of such loans along with confirmation of the party with his ITR, Bank Statement, Balance Sheet and Profit&Loss account. The assessee had submitted details like Acknowledgement of return of income for 09 persons for AY 2018-19 and Bank statements of the depositors. Considering such facts, notice u/s 263 of the Income-tax Act, 1961, was issued on 07.02.2023 and duly served upon the ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 3 assessee, which is reproduced by the ld. PCIT, in his order, vide page no.2 to 5 of the revision order under section 263 of the Act. 4. In response, the assessee submitted before the learned PCIT that during the assessment proceedings, the assessing officer issued notice under section 142(1) of the Act and in response to that notice, assessee had submitted name, address, PAN number and copy of the ledger account of the lenders from the assessee book and bank statement etc. Besides, the assessing officer also issued notice under section 133(6) of the Act to the lenders calling for the return of income and other details, which were submitted before the assessing officer. Therefore, assessing officer, having examined, these details and documents, took the plausible view about the genuineness of the Landers, and therefore order passed by the assessing officer after making due application of mind cannot be termed as erroneous and prejudicial to the interest of the revenue. 5. However, learned PCIT rejected the contention of the assessee, and observed that in some cases, the bank statements of the lenders have no any major transactions other than the transaction with the assessee- firm. For example in the case of (1) P.R.H Flats Owners Association-A. (2) P.R.H Flats Owners Association-B, (3) P.R.H Flats Owners Association-C, (4) P.R.H Flats Owners Association-D, (5) P.R.H Flats Owners Association-E and (6) P.R. Height Owners Association, amount credited by way of transferred was immediately i.e. on same day transferred to the assessee- firm. Further, it is also noticed that amount credited in the bank accounts of these associations were received from the same person/family and it can be evident from the copy of bank statement of these lenders. From the facts discussed above, it is clear that thesetransactions of unsecured loans were made to just a set up to bring unaccounted income in the books by taking the shade of unsecured loans. Further, on verification of documents submitted in the cases of (1) YogirajsinhJ. Jadeja (HUF) and (2) ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 4 Yogirajsinh Jayrajsinh Jadeja, the ,similar facts and nature of transactions have been noticed by the ld. PCIT. These are only few instances cited by the ld. PCIT of such glaring discrepancies. Therefore, learned PCIT was of the view that these mismatch/discrepancies between the source of income/funds and the capacity/creditworthiness for lending money in form of unsecured loanand these glaring discrepancies/mismatches should have examined and investigated by the assessing officer and assessing officer should have conducted necessary enquiries/verifications. However, the assessing officer accepted the unsecured loans without carrying out inquiry/verification that should have been done. Therefore, learned PCIT directed the assessing officer to frame the fresh assessment order, after making necessary enquiries and providing sufficient opportunity of being heard to the assessee. 6. Aggrieved by the order of the ld. PCIT, the assessee is in appeal before us. 7. Learned Counsel for the assessee, argued that during the course of assessment proceedings, the Assessing Officer issued notice u/s.142(1) of the Act dated 27/11/2020, asking the questions pertaining to lenders/ unsecured loan. In response to notice u/s.142(1) of the Act, the assessee submitted written submission before the assessing officer on 18/01/2021, which is placed at paper- book on page No.11. In this reply, the assessee has submitted the relevant documents and evidences, as asked by the assessing officer. In its reply, the assessee submitted the copy of the ledger account in respect of the long-term and short-term unsecured loan/ borrowings. The assessee also submitted the copy of the ledger account and bank statement for verification of the repayment of the loan, that is, loan was repaid in the subsequent years. The assessee has ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 5 also submitted during the assessment proceedings, the source of repayment of the loan stating that repayment of the loan was made out of the sale-proceeds received by the Firm. 8.The Ld.Counsel further stated that, during the course of assessment proceedings, the assessing officer again issued notice u/s.142(1) of the Act, dated 08/04/2021, which is placed at paper-book on page No.15, wherein the assessing officer has especially asked the assessee about the unsecured loans taken from various parties and to verify the genuineness of these unsecured loans taken by the assessee. The assessing officer issued notices u/s.133(6) of the Act to some of the parties. In response to notice u/s133(6) of the Act, most of the parties replied to the assessing officer. In response to the said notice, the assessee has also submitted its reply dated 13/04/2021 before the assessing officer. In the said reply, the assessee submitted that most of the parties have opening balances of unsecured loans which were verified by the assessing officer in the previous year and during the current year only one fresh loan was taken to the tune of Rs.74 lakhs and to prove the genuineness of the said loan, the assessee submitted copy of income-tax return, copy of computation of income, copy of bank statement, copy of balance-sheet and profit & loss account. The Ld.Counsel submitted that all the loans, which were picked up by the assessing officer were having the opening balances, which were examined by the assessing officer in the previous year and no fresh loan was taken in the assessment year under consideration. Apart from this, the repayment of the loans were made through “Account Payee” cheques and adequate interest were provided andas well as the adequate TDS were also deducted on the interest. Therefore, genuineness of these transactions should not be doubted. Moreover, these loans were re-paid by the assessee in the subsequent years, ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 6 therefore genuineness of these lenders should not be doubted. During the assessment year under consideration, the assessee took a fresh loan of Rs.74 lakhs only and the parties from whom the assessee took the fresh loan has been issued notice u/s.133(6) of the Act by the assessing officer and in response to the notice u/s.133(6) of the Act, the party has submitted required documents and evidences before the assessing officer. However, the assessee had also furnished the documents before the assessing officer, like, copies of income-tax returns, copies of computation of income-tax, copies of bank statements and copies of balance-sheets of these persons and the person from whom Rs.74 lakhs loan was taken has been assessed to tax and no addition was made by the assessing officer in the personal assessment of that lender. Besides, the loan was received through banking channel and re-payment was also made through banking channel and appropriate TDS, wherever applicable were deducted on the interest component. Therefore, the Ld.Counsel for the assessee submitted that, during the course of assessment proceedings, the assessing officer issued two notices u/s.142(1) of the Act and has conducted further enquiry also, therefore it cannot be said that there was no enquiry was made in the assessee’s case under consideration. In fact, sufficient enquiry was made by the assessing officer by issuing to notices u/s.142(1) of the Act and the assessee has also submitted its reply in response to these documents with documentary evidence. Therefore, assessment framed by the assessing officer should not be erroneous and prejudicial to the interests of the revenue and, therefore, the ld.Counsel for the assessee prayed before the Bench that order passed by the Ld.PCIT u/s.263 of the Act may be quashed. 9.On the other hand, the Ld.DR for the Revenue, submitted that in case of some loan-lenders/ unsecured loan, the assessee has not submitted the confirmations ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 7 and other details thereof. Although, in most of the cases, there are opening balances brought forward from the previous year, however, the assessing officer should examine these opening balances also. While examining the opening balances of the unsecured loans, the assessing officer has not conducted sufficient enquiry and AO has not received the entire details and the documents from some of the lenders. To deduct TDS on interest and to make the repayment of these loans in the subsequent years, do not mean that the assessee has proved the creditworthiness of the loans. Therefore, the Ld.DR stated that no doubt during the assessment proceedings, the assessing officer has issued two notices u/s.142(1) of the Act, wherein the assessing officer asked relevant documents and details,however, the AO has failed to examine the genuineness of these transactions. The ld. DR also relied on the case laws, which were relied on by ld PCIT in his revision order. Therefore, assessment order passed by the assessing officer is erroneous and prejudicial to the interests of the revenue, and therefore order passed by the Ld.PCIT u/s.263 of the Act, should be upheld. 10. The Ld. DR also submitted that in some cases, Flat Owners’ Association booked some flats in their names, and the assessing officer has not examined the issue properly,therefore, order passed by the assessing officer is not only erroneous but also prejudicial to the interests of the revenue. 11. In rejoinder, the Ld.Counsel for the assessee, submitted that there is no doubt about the identity of the Flat Owners’ Association, who have booked the flats and they made the payment through “Account Payee” cheques and there were no any instance seen by the assessing officer, where the flat owners’ have deposited the cash in their bank accounts relating to the assessee (P.P. Corporation). Therefore, just because the Flat Owners’ Association booked some flats, do not mean that the transactions are not genuine. These ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 8 transactions are at arm’s length and not tented by any extra commercial consideration. Therefore, the assessing officer has conducted thorough enquiry and, hence, taken the plausible view by due application of mind. Therefore, assessment order framed by the assessing officer is neither erroneous nor prejudicial to the interests of the revenue. 12.We have heard the rival contentions, perused the material on record and duly considered facts of the case in the light of the applicable legal position. First of all, we should examine what type of enquiries have been conducted by the assessing officer during the assessment proceedings and reply of the assessee during the assessment proceedings with documentary evidences, if any. We note that during the assessment proceedings the assessing officer issued notice u/s. 142(1) of the Act, wherein the assessee was asked to furnish the details in respect of Landers/Loan, which is reproduced below: ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 9 ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 10 ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 11 ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 12 ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 13 13. In response to the above notice, the assessee submitted its reply, before the assessing officer, the relevant portion of the reply is reproduced below: “We have no any other sister concern. Ledger in respect of long term and short term borrowings is attached here with. (Annex.4)We have taken three loan during the year, one is overdraft facility of Rs. 10 Crore to meet the cost of construct residential flat and two vehicle loan for the use of business. Statement of secured loan indicating interest paid, section letter attached here with (Annex.5) Loan ledger a/c is attached herewith for verification of repayment. The source of repayment is out of the Sales Receipt of the Firm.” 14. In order to conduct further enquiry, in respect of lenders/ unsecured loan, the assessing officer, during the assessment proceeding, issued second notice u/s 142(1) of the Act,which is placed at paper book page no. 15, the relevant portion( which is useful for our analysis) is reproduce below: “It has been further observed that the parties as appearing at Sl. No. 1, 2 and 3 above, did not respond to the notices under section 133(6) of the Income Tax Act, 1961. The party as appearing in Sr. No. 4, has submitted the details, however the same is not legible. In view of these facts, the transactions in respect of unsecured loans accepted by the assessee and repayment of unsecured loans by the assessee, remained unverified. In view of the facts mentioned above, the assessee is requested to prove the identity and creditworthiness of the lenders and also the genuineness of the transactions of unsecured loans taken from the above mentioned parties.” 15.In response to the above second notice u/s 142(1) of the Act, the assessee submitted the reply, before the assessing officer, which is reproduced below: “Sub.: Reply to notice u/s 142(1) of the income tax Act, 1961 for the A.Y 2018-19 in case of P. P. Corporation Ref. No.: ITBA/AST/F/142(1)/2021-22/1032301113(1) Dear Sir, Our scrutiny assessment proceedings for the year under consideration is going and we have submitted all the details as and when called for. Regarding Repayment of unsecured loan, you have issued the notice u/s 133(6) and it is duly served to the following parties. In this connection, we would like to submit the following documents for your kind and ready reference: ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 14 “Further, if your honour gone through the above table, it can be seen that for the first three parties, there was only repayment and no new loan taken during the year under consideration. All the repayment is through account payee cheques. Secondly, all the preceding years are being passed through Scrutiny assessment u/s 143(3) by assessing officer and genuineness and creditworthiness of all the unsecured loanee being verified by theAssessing Officer for the year in which the loans were taken. For Last Party Raviraj Jayrajsinh, there is an increase of Loan of Rs.74 lakh. The Party has already replied to the Notice issued u/s 133(6) with necessary documents and accepted the transactions. We are again furnishing the legible documents like ITR, COI, BANK STATEMENT AND BALANCE SHEET OF the person for your kind verification. The party is assessed to tax. The payment is received through Account payee cheque. The prime facie evidence required to justify the loan is being furnished. In case you need any more evidence, please intimate us, we shall furnish immediately.” 16. From the above facts, it is abundantly clear that during the assessment proceedings, not only enquiry was conducted by the assessing officer, but further enquiry was also conducted by the assessing officer to ascertain the ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 15 genuineness of the unsecured loan/Lenders. The assessee has also submitted its reply with documentary evidences, stating that most of the unsecured loans, were coming from the previous years, and these are only opening balances, therefore, during the previous assessment year under section 143(3) of the Act, the assessing officer had already examined these unsecured loan and did not make any addition. During the assessment year under consideration, the assessing officer examined the opening balances of these unsecured loans by conducting sufficient Enquiry and assessing officer was also informed that these unsecured loans were repaid by the assessee in the subsequent year. 17. Therefore, we find that ld.PCIT has wrongly assumed jurisdiction u/s 263 of the Act, as twin conditions Viz: (i) Order should be erroneous and (ii) It should be prejudicial to the interest of the Revenue; is not satisfied.The Assessment order passed u/s 143(3) of the Act, by the assessing officer is after adequate inquiry. Two notices were issuedduring the assessment proceedings, u/s 142(1) of the Act and voluminous details and documents in respect of all the issues which is required to complete full scrutiny, were submitted, and specific query was raised by the assessing officer with regard to unsecured loan/ creditors. The assessing officer, also asked details of the repayment and source of repayment of unsecured loan. Repayment ledger of unsecured loanwas furnished by the assessee in reply to query no. 8 raised by the assessing officer. The assessing officer was very well aware with the issue of unsecured loans and after due application of mind, the unsecured loan was accepted by the assessing officer, as genuine, and therefore did not make any addition. We find that during the assessment proceedings, the assessing officer issued to notices under section 142(1) of the Act, to conduct sufficient Enquiry,in our view, the order can be erroneous if the Assessing Officer fails to apply the law rightly on the facts of the case. As far as adequacy of inquiry is considered, there is no law which ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 16 provides the extent of inquiries that are required to be made by the Assessing Officer. It is Assessing Officer's prerogative to make inquiry to the extent he feels proper. The Commissioner of Income Tax by invoking revisionary powers under section 263 of the Act cannot impose his own understanding of the extent of inquiry.If there was any inquiry, even inadequate, that would not by itself, give occasion to the Commissioner to pass orders under section 263 of the Act, merely because ld. PCIT has different opinion in the matter. It is only in cases of \"lack of inquiry\", that such a course of action would be open. 18. We find that in order to justify identity and creditworthiness, the following documents were furnished by the assessee during the assessment proceedings, Viz: (1). Income Tax Return (2) Computation of total income, (3) Confirmation letter and contra ledger account (4) bankstatement of the lenders were furnished (5) Entire payment was received by account payee cheque (6) Repayment of loan was made by account payee cheque (7) Interest paid and due TDS was deducted. (8) On perusal of the Bank statement of the lenders, it can be seen that all the lenders were having sufficient bank balance, before giving the loan. Therefore, we find that assessee has explained the source of unsecured loan. 19. We note that the arguments of the Ld. DR for the revenue, to the effect that the AO has not conducted sufficient enquiry during the assessment proceedings,is not acceptable, as we have noted that the AO has issued notice u/s.142(1) of the Act dated 27/11/2020 and the assessee submitted its reply in response to the said notice on 18/01/2021. We find that in assessee’s case, the AO has conducted further enquiry on the same issue by issuing further notice u/s.142(1) of the Act, on 08/04/2021, and in response to the said notice, the assessee had submitted its reply on dated 13/04/2021 with necessary documents and evidences. Therefore, it reveals that the AO has conducted a thorough enquiry in assessee’s case year under consideration. Therefore, the arguments ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 17 advanced by the ld. DR for the revenue to the effect that it is case of “no enquiry” is baseless. The assessee during the course of assessment proceedings submitted its own bank statement of assessee (P.P. Corporation) from 01/04/2017 to 31/03/2018, which is placed at paper-book on page Nos.22 to 53. During the course of assessment proceedings, the AO has issued further show- cause notice dated 28/04/2021 and in response to that notice, assessee submitted further written submission dated 28/04/2021 with relevant documents and evidences. Therefore, after considering the above facts, we note that during the course of assessment proceedings, the AO has conducted sufficient enquiry and after being satisfied himself, the AO has applied his mind and then only farmed the assessment u/s.143(3) of the Act and, therefore, such assessment order passed by the AO should not be erroneous and prejudicial to the interests of the revenue. Moreover, the loan has been re-paid by the assessee in subsequent year and for that also, the assessee has submitted the relevant evidences, like bank statement, showing that loan has been re-paid in the subsequent year and for that we rely on the judgement of Hon’ble Gujarat High Court in the case of CIT vs. Chandrashekhar Narsangli reported at (2014) 42 Taxamann.com 251 (Guj.), wherein it was held that when the Income Tax Department had accepted the re-payment of loan in subsequent year, no addition should be made in the current year on account of cash credit.An order cannot be termed as 'erroneous' unless it is not in accordance with law. If an AO acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to him, the order should have been written more elaborately [CIT v. Gabriel India Lid. [1993] 71 Taxman 585 (Bom.)).Where two views are possible and the AO has taken one view with which the Commissioner does not agree, that cannot be treated as 'erroneous' order prejudicial to the interest of the revenue. It has to be shown that the order of the AO was not in accordance with law, to term it as 'erroneous' ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 18 [CIT v. Leisure Wear Exports Ltd. [2011] 11 taxmann.com 54]. Two pre- requisites must be present before the Commissioner can exercise the revisional jurisdiction conferred on him. First is that the order passed by the ITO must erroneous. Second is that the error must be such that it is prejudicial to the interests of the Revenue. If the order is erroneous but it is not prejudicial to the interests of the Revenue, the Commissioner cannot exercise the revisional jurisdiction u/s 263 of the Act.[H. H. Maharaja Raja Pawer Dewas v. CIT [1982] 138 ITR 518].In any event, we note that the Assessing Officer has adopted one of the courses permissible in law and even if it has resulted in loss to the revenue, the said decision of the Assessing Officer cannot be treated as erroneous and prejudicial to the interest of the revenue as held by Hon’ble Supreme Court in Malabar Industries Ltd. vs. CIT (243 ITR 83). Since the order of the Assessing Officer cannot be held to be erroneous as well as prejudicial to the interest of the revenue, in the facts and circumstances narrated above, the usurpation of jurisdiction exercising revisional jurisdiction by the Principal CIT is ‘’null’’ in the eyes of law and, therefore, we are inclined to quash the very assumption of jurisdiction to invoke revisional jurisdiction u/s 263 by the Principal CIT. Therefore, we quash the order of the Principal CIT dated 30.03.2024, being ab initio void. 20.In the result, the appeal of the assessee is allowed. Order pronounced in the open court on 24/04/2025. Sd/- Sd/- (DINESH MOHAN SINHA) (Dr. A.L. SAINI) JUDICIAL MEMBER ACCOUNTANT MEMBER Rajkot (True Copy) \u001bदनांक/ Date:24/04/2025 Copy of the Order forwarded to 1. The Assessee 2. The Respondent ITA NO. 245/RJT/2024 P.P. CORPORATION RAJKOT - 360005 Page | 19 3. The CIT(A) 4. Pr. CIT 5. DR/AR, ITAT, Rajkot 6. Guard File By Order Assistant Registrar/Sr. PS/PS ITAT, Rajkot "