PURVI FINVEST LTD.,INDORE V. ACIT CENTRAL CIRCLE, BILASPUR

ITA 265/RPR/2024

AI Insights

The case involves multiple appeals by M/s. Purvi Finvest Ltd., M/s. Trimurthi Finvest Ltd., and M/s. East West Finvest India Ltd. against the orders of the Assistant Commissioner of Income Tax and the Deputy Commissioner of Income Tax for various assessment years. The appeals were initially dismissed ex-parte due to non-compliance by the assessee in providing necessary submissions. The Tribunal noted the repeated adjournments requested by the assessee and the consequent delays in the judicial process. Citing precedents from the Supreme Court regarding the importance of not granting adjournments mechanically and the right to a speedy trial, the Tribunal decided to remand the cases for a fresh hearing on merits, emphasizing the need for the assessee to comply with the judicial process in this final opportunity.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 298547 (ITAT-RAIPUR)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 23-04-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB
• Assessment Year: 2015-2016
• Other Referred Cases: Ishwarlal Mali Rathod Vs. Gopal and Ors., Brajesh Singh Bhadoria Vs. Dy./ACIT, Central Circle-2, Naya Raipur, Vijay Shrinivasrao Kulkarni Vs. Income-tax Appellate Tribunal, Delhi Transport Corporation vs. DTC Mazdoor Union, Commissioner of Income Tax Madras v. Chenniyappa Mudiliar, Mc Dowell & Company Ltd. Vs. CTO
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: ASSESSEE GETTING; S.L ANURAGI; LD.
• Keywords: Set aside; Opportunity of being heard; Principle of natural justice; Sham transactions; Validity of assessment; Bogus
• Section: 13

Judgement Text

"आयकर अपीलȣय अͬधकरण Ûयायपीठ रायपुर मɅ। IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR BEFORE SHRI PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER AND SHRI ARUN KHODPIA, ACCOUNTANT MEMBER Sl. No. ITA No. Name of Appellant Name of Respondent Asst. Year 1-10. 259/RPR/2024 260/RPR/2024 261/RPR/2024 262/RPR/2024 263/RPR/2024 264/RPR/2024 265/RPR/2024 266/RPR/2024 267/RPR/2024 20/RPR/2025 M/s. Purvi Finvest Ltd. 552-B, Usha Nagar, Annapurna Road, Indore-452 009 PAN: AABCP6564C The Assistant Commissioner of Income Tax, Circle-1(1), Bilaspur (C.G.) 2010-11 2011-12 2011-12 2012-13 2013-14 2014-15 2015-16 2016-17 2017-18 2018-19 11-21. 245/RPR/2024 246/RPR/2024 247/RPR/2024 248/RPR/2024 249/RPR/2024 250/RPR/2024 251/RPR/2024 252/RPR/2024 253/RPR/2024 255/RPR/2024 257/RPR/2024 M/s. Trimurthi Finvest Ltd. 552-B, Usha Nagar, Annapurna Road, Indore-452 009 PAN: AAACT6383N The Deputy Commissioner of Income Tax, Circle-1(1), Bilaspur (C.G.) 2010-11 2010-11 2011-12 2012-13 2013-14 2013-14 2014-15 2015-16 2017-18 2018-19 2019-20 22-31. 269/RPR/2024 270/RPR/2024 271/RPR/2024 272/RPR/2024 273/RPR/2024 274/RPR/2024 275/RPR/2024 M/s.East West Finvest India Ltd. 552-B, Usha Nagar, Annapurna Road, Indore-452 009 PAN: AADCE1236G The Assistant Commissioner of Income Tax, Circle-2(1), Bilaspur (C.G.) 2010-11 2011-12 2012-13 2012-13 2013-14 2014-15 2015-16 2 M/s. Purvi Finvest Ltd. Vs. ACIT, Circle-1(1), Bilaspur M/s. Trimurthi Finvest Ltd. Vs. DCIT, Circle-1(1), Bilaspur M/s. East West Finvest Ltd. Vs. ACIT, Circle-2(1), Bilaspur 276/RPR/2024 277/RPR/2024 7/RPR/2025 2017-18 2018-19 2016-17 Assessee by : None (Adjournment Application) Revenue by : Shri S.L Anuragi, Ld. CIT-DR सुनवाई कȧ तारȣख / Date of Hearing : 21/22/23.04.2025 घोषणा कȧ तारȣख / Date of Pronouncement : 23.04.2025 आदेश / ORDER PER BENCH: All the captioned appeals preferred by the assessee emanates from the respective orders of the Ld.CIT(Appeals)/NFAC, dated 08.11.2024 for the assessment years 2010-11 to 2018-19 as per the grounds of appeal on record. 2. At the time of hearing, none appeared on behalf of the assessee company in all these appeals, however, adjournment applications have been filed. That as evident from the order sheet entries, the matter is going on since July, 2024 and there has been several occasions, in which, the assessee were provided opportunities of hearing. In such scenario, it cannot be said that reasonable opportunities were not provided to the assessee company. In other words, prolonged process of litigation and 3 M/s. Purvi Finvest Ltd. Vs. ACIT, Circle-1(1), Bilaspur M/s. Trimurthi Finvest Ltd. Vs. DCIT, Circle-1(1), Bilaspur M/s. East West Finvest Ltd. Vs. ACIT, Circle-2(1), Bilaspur providing adjournment unnecessary delays the process of justice which hampers the trust of the litigants in the judicial process. The fact of the matter is that the communication that these matters would be heard on 21.04.2025, 22.04.2025 and 23.04.2025 had been duly communicated to the assessee company. The Hon'ble Supreme Court in the case of Ishwarlal Mali Rathod Vs. Gopal and Ors., passed in Special Leave Petition (Civil) Nos. 14117-14118 of 2021, order dated 20.09.2021, held and observed that as on today the judiciary and the justice delivery system is facing acute problem of delay which ultimately affects the rights of the litigant to access to justice and speedy trial. Arrears are mounting because of such delay and dilatory tactics and asking of repeated adjournments by the advocates and mechanically and in routine manner being granted by the courts. It cannot be disputed that due to delay in access to justice and not getting the timely justice it may shake the trust and confidence of the litigants in the justice delivery system. Therefore, the Hon'ble Apex Court has directed specifically that adjournments should not be granted in a routine manner and mechanically and such grant of adjournment by the Courts should not be a cause for delay in dispensing justice. We are of the considered view that sufficient opportunities in all these cases have been already provided to the assessee and the department in these prolonged litigation. That, any further delay in disposing these matters would ultimately result in hindrance of justice and 4 M/s. Purvi Finvest Ltd. Vs. ACIT, Circle-1(1), Bilaspur M/s. Trimurthi Finvest Ltd. Vs. DCIT, Circle-1(1), Bilaspur M/s. East West Finvest Ltd. Vs. ACIT, Circle-2(1), Bilaspur would act as defiance to the directions given by the Hon'ble Supreme Court (supra) and we can never be a party to such an act and, therefore, in such factual scenario and observations even though the ld. AR had applied for adjournment, we reject the same and proceed to hear all these appeals on merits considering the documents on record and the submissions of the Ld. CIT-DR. 3. When these matters came up for hearing, it had been noted that the facts and circumstances and issues involved are absolutely similar and identical in all these appeals. Therefore, all these matters were heard together and were disposed of vide this consolidated order. 4. At the very outset, it is observed that as per Para 3 of the impugned orders for all the assessment years, the Ld.CIT(Appeals)/NFAC vide an ex- parte order had dealt with the appeals of the assessee due to non- compliance by the assessee. For the sake of clarity and illustration of facts on record, Para 3 of the Ld.CIT(Appeals)’s/NFAC order in ITA No.259/RPR/2024 for A.Y.2010-11 is culled out as follows: “3. The appeal was fixed for hearing on 09.03.2022, 05.07.2022, 07.11.2022, 10.08.2023 & 26.12.2023. Again, the appeal was fixed for hearing on 08.01.2024 vide this office notice dt.02.01.2024, in response submit through ITBA to the above notice the appellant had requested adjournment for submission. The request of appellant was duly considered & due to huge pendency of old appeals & Hon'ble Board's guidelines for prompt disposal of appeals pertains to various category. Hence the adjournment was granted and final 5 M/s. Purvi Finvest Ltd. Vs. ACIT, Circle-1(1), Bilaspur M/s. Trimurthi Finvest Ltd. Vs. DCIT, Circle-1(1), Bilaspur M/s. East West Finvest Ltd. Vs. ACIT, Circle-2(1), Bilaspur opportunity is accorded notice u/s.250 again issued vide dt. 18.01.2024 and the appeal was fixed for hearing on 25.01.2024. The assessee reply submit through ITBA in response to the above notice the appellant again requested adjournment for submission. Further, again adjournment cannot be granted due to huge pendency of old appeals. It is quite evident from the chronology of event that despite several opportunities being granted from time to time, there has been absolutely no compliance on part of the appellant to give detailed explanation regarding ground of appeal taken for A.Y.2010-11. This clearly shows that the appellant is not keen to pursue the above-mentioned appeal.” In so far as the remaining appeals for the respective assessment years are concerned, it is also evident from Para 3 of the respective orders of the Ld. CIT(Appeals)/NFAC order that since there was no compliance from the assessee, therefore, the Ld. CIT(Appeals)/NFAC adjudicated the appeals vide ex-parte orders. For the sake of brevity, the same are only referred to and are not being extracted. 5. In this regard, the Ld. CIT-DR has fairly conceded that the matters may be adjudicated denovo on merits before the first appellate authority providing one final opportunity to the assessee. 6. We have carefully considered the contents in the documents/material available on record. As per the aforesaid examination of the entire spectrum of the matter in the interest of natural justice, we deem it fit and proper to provide one final opportunity to the assessee to represent its case on merits before the Ld. CIT(Appeals)/NFAC. 6 M/s. Purvi Finvest Ltd. Vs. ACIT, Circle-1(1), Bilaspur M/s. Trimurthi Finvest Ltd. Vs. DCIT, Circle-1(1), Bilaspur M/s. East West Finvest Ltd. Vs. ACIT, Circle-2(1), Bilaspur 7. At this stage, we herein observe that the ITAT, “Division Bench”, Raipur in the cases of Brajesh Singh Bhadoria Vs. Dy./ACIT, Central Circle-2, Naya Raipur, IT(SS)A Nos.1 to 6, 8 & 9/RPR/2025, dated 20.03.2025 had dealt with similar issue on the same parameters of ex- parte order passed by the Ld. CIT(Appeals)/NFAC and remanded the matter back to the file of the Ld. CIT(Appeals)/NFAC observing as follows: “7. We have considered the submissions of the parties herein and analyzed the facts and circumstances involved in all the captioned appeals. After careful perusal of the documents on record, we find that the assessee had assailed the legal ground as aforestated, however, the fact of the matter is that on perusal of the respective orders of the Ld. CIT(Appeals) for all the years before us, it is also evident from Para 3 that there has been no compliance by the assessee before the said authority and as such, an ex-parte order was passed for the concerned years in appeal. Admittedly, as per record, sufficient opportunities had been provided to the assesse, however, there was no compliance by the assessee. In effect, rights and liabilities of the parties herein are yet to be adjudicated substantially at the level of the first appellate authority. Though in the impugned orders, discussion has been done as per material available on record by the Ld.CIT(Appeals) but they are only Form 35, statement of facts, grounds of appeal and the assessment order. However, due to non-compliance by the assessee, there are no submissions, evidence and documents submitted for adjudication by the assessee before the Ld. CIT(Appeals). That as per Para 3 of the Ld. CIT(Appeals) order, there has been no compliance on the part of the assessee for submitting detailed explanations regarding the grounds of appeal for the years under consideration which clearly shows that the grounds of appeal raised before the first appellate authority has not been substantiated on merits through corroborative evidence /submissions. 8. That in such scenario we are of the considered view that the Income tax Act is within the ambit of welfare legislation which are completely different from that of the penal legislation, therefore, benefit of doubt whenever arises, it has to be interpreted in favour of the assessee tax payer within the parameters of law and facts. There may be circumstances 7 M/s. Purvi Finvest Ltd. Vs. ACIT, Circle-1(1), Bilaspur M/s. Trimurthi Finvest Ltd. Vs. DCIT, Circle-1(1), Bilaspur M/s. East West Finvest Ltd. Vs. ACIT, Circle-2(1), Bilaspur beyond control of the assessee because of which, the assessee may not have been able to represent his case on the given dates of hearing before the Ld. CIT(Appeals). Though it is correct that there was no compliance from the side of the assessee, however, nothing is there on record which suggests any deliberate non-compliance or malafide conduct of the assessee. That further, if one final opportunity is provided to the assessee to represent his case before the first appellate authority, the position of the revenue will also not be jeopardized. 9. Recently, the Hon’ble High Court of Bombay in the case of Vijay Shrinivasrao Kulkarni Vs. Income-tax Appellate Tribunal (2025) 171 taxmann.com 696 (Bom.), dated 04.02.2025 observed that in the case the Assessing Officer had passed an ex-parte order and when the matter went on appeal before the Ld. CIT(Appeals)/NFAC, it had also dismissed the matter ex-parte due to non-compliance by the assessee’s authorized representative, when the matter came up before the ITAT, it had failed to address the infirmity regarding the fact that the assessee was not afforded proper opportunity of being heard and the matter was dismissed ex-parte by the Ld. CIT(Appeals)/NFAC which amounted to violation of principles of natural justice, and instead ITAT decided the case on merits, in such circumstances, the Hon’ble High Court of Bombay held that passing of an order on merits by the ITAT even when the impugned order was passed ex-parte amounts to violation of principles of natural justice and accordingly, the said matter was remanded to ITAT for passing a fresh order in accordance with law after hearing the parties. The legal principle as enshrined in the present judgment is crystal clear that the principles of natural justice i.e. the right to be heard is to be provided and accordingly, the matter had to be substantially adjudicated by the appellate authority. Therefore, if the impugned order of the Ld. CIT(Appeals)/NFAC is an ex- parte order, the only recourse in conformity with the aforesaid judicial pronouncement is to remand the matter back to the file of the Ld. CIT(Appeals)/NFAC for fresh adjudication in terms with the principles of natural justice providing one final opportunity to the assessee. 10. In the aforesaid case, the Hon’ble High Court of Bombay had referred to a judgment of the Hon’ble Supreme Court in the case of Delhi Transport Corporation vs. DTC Mazdoor Union AIR 1999 SC 564, wherein the Supreme Court inter-alia held that Article 14 guarantees a right of hearing to a person who is adversely affected by an administrative order. The principle of audi-alteram partem is a 8 M/s. Purvi Finvest Ltd. Vs. ACIT, Circle-1(1), Bilaspur M/s. Trimurthi Finvest Ltd. Vs. DCIT, Circle-1(1), Bilaspur M/s. East West Finvest Ltd. Vs. ACIT, Circle-2(1), Bilaspur part of Article 14 of the Constitution of India. In light of such decision, the petitioner ought to have been granted an opportunity of being heard which, partakes the characteristic of the fundamental right under Article 14 of the Constitution of India. 11. The Hon’ble High Court of Bombay in the aforesaid case had referred to a decision of the Hon’ble Supreme Court in the case of Commissioner of Income Tax Madras v. Chenniyappa Mudiliar 1969 1 SCC 591, wherein the Supreme Court in interpreting the section 33(4) of the Income Tax Act, 1922 has held that the appellate tribunal was bound to give a proper decision on question of fact as well as law, which can only be done if the appeal is disposed off on merits and not dismissed owing to the absence of the appellant. Reverting to the facts of the present case the grounds of appeal were simply filed before the Ld.CIT(Appeals) they were not substantiated or corroborated through submissions and filing of documentary evidences since the assessee had not complied before the Ld.CIT(Appeals) on the dates of hearing. Therefore, as per framework of the Act there must be adjudication on merits by the first appellate authority and one final opportunity be provided to the assessee to represent his matter on merits in the interest of natural justice. 12. There may even be a situation where the Ld. Counsel for the assessee may assail a legal ground before the Tribunal following the decision of the Hon’ble Supreme Court in the case of National Thermal Power Company Ltd. Ltd. Vs. CIT (1998) 229 ITR 383 (SC) with a contention that irrespective of the order of the Ld. CIT(Appeals) being ex-parte, the Tribunal may decide the legal issue that has been raised by the Ld. Counsel. In our view, the decision of the Hon’ble Supreme Court in the case of National Thermal Power Company Ltd. Ltd. Vs. CIT (supra) provides that any legal issue which goes to the root of the matter and is established through legal principles, the assessee can take up and raise such legal issue at any appellate forum irrespective of whether the assessee had raised such legal issue at the sub-ordinate level or not, however, it always depends on facts and circumstances of each case whether the Tribunal would decide the legal ground or in a case where the question is of natural justice and ex-parte order by the Ld. CIT(Appeals) the Tribunal would remand it back to Ld.CIT(Appeals) providing final opportunity to a bonafide assessee. The Tribunal as the highest fact finding authority must be certain enough that the impugned order before it has been passed on merits and is a speaking order where the assessee has also complied during the process of 9 M/s. Purvi Finvest Ltd. Vs. ACIT, Circle-1(1), Bilaspur M/s. Trimurthi Finvest Ltd. Vs. DCIT, Circle-1(1), Bilaspur M/s. East West Finvest Ltd. Vs. ACIT, Circle-2(1), Bilaspur litigation. In case, where the order of the Ld. CIT(Appeals) itself is ex-parte and some legal ground is raised and if the Tribunal decides such legal ground where in fact principles of natural justice is left unanswered due to the fact that the impugned order before the Tribunal is ex-parte and there was no compliance by the assessee in such scenario the Tribunal would also be usurping the power of the Ld. CIT(Appeals) which is also a statutory authority as per the Act. This is due to the reason that as per framework of the Act, Ld.CIT(Appeals) is the first appellate authority where an appeal by assessee it would be substantially decided through a speaking order by the Ld.CIT(Appeals). When this part is over and either party is aggrieved second appeal lies before the ITAT. Now if for every ex-parte order passed by the Ld. CIT(Appeals), of course due to non-compliance by the assessee, if the Tribunal adjudicates a legal ground, for instance validity of assessment or reassessment order and answers it in favour of the assessee then it would create an easy route for assessee getting redressal from Tribunal even without bothering to comply with hearing notices before the Ld. CIT(Appeals). This would dismantle the structure of the Act which is definitely not the intention of the legislature. Here in this situation, where the benefit of doubt is given to the assessee since he had not complied with the hearing notices before the Ld. CIT(Appeals) which resulted in passing of an ex-parte order by the Ld. CIT(Appeals), in such scenario, as per the scheme of the Act and following the principles of natural justice, the only course of action is to remand the matter back to the file of the Ld. CIT(Appeals) for adjudication on merits providing one final opportunity to the assessee. 13. In view thereof, we set aside the respective orders of the Ld. CIT(Appeals) for all the years and remand the same to their file for denovo adjudication on merits. At the same time, we direct the assessee that this being the final opportunity, there must be compliance on merits before the first appellate authority. Needless to say, the Ld. CIT(Appeals) shall provide reasonable opportunity of being heard to the assessee and pass an order in terms of Section 250(4) and (6) of the Act within three months from receipt of this order.” 8. Respectfully following the aforesaid order, we set-aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while complying with the principles of natural 10 M/s. Purvi Finvest Ltd. Vs. ACIT, Circle-1(1), Bilaspur M/s. Trimurthi Finvest Ltd. Vs. DCIT, Circle-1(1), Bilaspur M/s. East West Finvest Ltd. Vs. ACIT, Circle-2(1), Bilaspur justice as per similar terms. At the same time, it is directed that this being the final opportunity, the assessee shall duly comply with the hearing notices from the Ld. CIT(Appeals)/NFAC. The assessee at the time of denovo proceedings shall be at liberty to file documentary evidence, if any before the first appellate authority to substantiate its claim. The Ld. CIT(Appeal)/NFAC shall accordingly pass order in terms with Section 250(4) & (6) of the Act. 9. We also observe that the primary source from which all these matters have emanated is the investigation report of the department. It has been unearthed that the modus-oparandi adopted by the assessee is obtaining share application money a/w. premium from shell/bogus companies, which are having no credentials and only act as conduits to layer the transactions related to rotation of funds which are ultimately received by the beneficiary in the form of share application money/share premium. In other words, as per report of investigation, these practices are colourable device in order to defraud the revenue. We are of the considered view that these matters are not simply ex-parte matters but since formation/basis of these matters is investigation report, it is now the onus on the part of the Ld. CIT(Appeals)/NFAC to verify and examine in detailed manner whether any fraud has been committed by the assessee towards department. That though on the ground of natural justice, one final opportunity has been given to the assessee company but the genesis of the 11 M/s. Purvi Finvest Ltd. Vs. ACIT, Circle-1(1), Bilaspur M/s. Trimurthi Finvest Ltd. Vs. DCIT, Circle-1(1), Bilaspur M/s. East West Finvest Ltd. Vs. ACIT, Circle-2(1), Bilaspur entire facts and circumstances needs proper verification in light of the investigation report of the department so to find out whether any lawful taxes remain unpaid to the department due to sham transactions adopted which will be within purview of tax evasion amounting to fraud to the revenue and in such case, fraud vitiates everything including natural justice. 10. The application of principle of fraud was even considered by the Hon'ble Supreme Court in the case of Badami (deceased) by her LRs v. Bhali in Civil Appeal No.1723/2008, dated 22/05/2012 wherein the Hon'ble Supreme Court has held as follows:- \"20. In S. P. Chengalvaraya Naidu (dead) by L.Rs. v. Jagannath (dead) by L.Rs. and others AIR 1994 SC 853 this court commenced the verdict with the following words:- \"Fraud-avoids all judicial acts, ecclesiastical or temporal\" It had been held that the courts of law are meant for imparting justice between the parties and one who comes to the court, must come with clean hands. A person whose case is based on falsehood has no right to approach the Court. 11. In another decision of the Hon’ble Supreme Court in the case of Smt. Shrist Dhawan v. M/s. Shaw Brothers AIR 1992 SC 1555, it has been held that fraud and collusion vitiates even the most solemn proceedings in any civilized system of jurisprudence including natural 12 M/s. Purvi Finvest Ltd. Vs. ACIT, Circle-1(1), Bilaspur M/s. Trimurthi Finvest Ltd. Vs. DCIT, Circle-1(1), Bilaspur M/s. East West Finvest Ltd. Vs. ACIT, Circle-2(1), Bilaspur justice. Further, the Hon’ble Supreme Court in the case of Mc Dowell & Company Ltd. Vs. CTO [1985] 154 ITR 148 (SC) has held that \"Tax planning may be legitimate provided it is within the framework of law, Colourable devices cannot be part of tax planning....\". 12. Therefore, in our considered view, in all these matters, it is the responsibility of the revenue authorities to investigate the matter in detailed manner as per law whether there is tax planning or tax evasion as per the transactions entered into by the assessee. If tax evasion is determined by the revenue in such circumstances additions are to be sustained in the hands of the assessee. 13. As per the aforesaid terms, the grounds of appeal raised by the assessee stands allowed for statistical purposes. 14. In the result, all the appeals of the assessee are allowed for statistical purposes. Order pronounced in the open court on 23rd April, 2025. Sd/- Sd/- ARUN KHODPIA PARTHA SARATHI CHAUDHURY (ACCOUNTANT MEMBER) (JUDICIAL MEMBER) रायपुर/ RAIPUR ; Ǒदनांक / Dated : 23rd April, 2025. ***SB, Sr. PS आदेश कȧ ĤǓतͧलͪप अĒेͪषत / Copy of the Order forwarded to : 1. अपीलाथȸ /The Appellant. 13 M/s. Purvi Finvest Ltd. Vs. ACIT, Circle-1(1), Bilaspur M/s. Trimurthi Finvest Ltd. Vs. DCIT, Circle-1(1), Bilaspur M/s. East West Finvest Ltd. Vs. ACIT, Circle-2(1), Bilaspur 2. Ĥ×यथȸ /The Respondent. 3. The Pr. CIT-1, Raipur (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. "