SHARAD SHAMRAO SAWANT ,SANGLI V. ASSESTANT COMISSIONER OF INCOME TAX CENTRAL CIRCLE KOLHAPUR, KOLHAPUR

ITA 2626/PUN/2024

AI Insights

The case involves Sharad Shamrao Sawant, a doctor and owner of Aaditya Hospital, who appealed against the order of the Commissioner of Income Tax (Appeals), Pune-11, which pertained to the Assessment Year 2019-20. The appeal was against the addition of Rs. 14,85,300 as deemed income under section 69A of the Income Tax Act, 1961, following a survey operation where unaccounted receipts were found. The assessee argued that these receipts were legitimate business incomes from consultancy services, which were duly recorded in the audited financial statements. However, both the Assessing Officer and the CIT(A) upheld the addition, leading to the current appeal before the Tribunal.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 653223 (ITAT-PUNE)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 20-06-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: B
• Assessment Year: 2019-2020
• Other Referred Cases: Fakir Mohmed Haji Hasan vs CIT, Kim Pharma Pvt Ltd vs. CIT, SVS Oils Mills vs. ACIT, Bajargan Traders vs. CIT, Lovish Singhal vs ITO, Oberoi Motors vs ACIT, DCIT vs Ram Narayan Birla, Kale Khan Mohammad Hanif vs CIT
• Laws Referred To: Income Tax Act 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: MANISH MEHTA
• Assessee Lawyers: UMESH KUMAR M. MALI
• Keywords: Condonation of delay; Business income; Opportunity of being heard; Corroborative evidences; Unexplained expenditure; Unexplained investment; Salary income; Capital Gains; Source of fund; Deemed to accrue or arise in india
• Section: 143(3); 142(1); 68; 69; 69C; 133A

Judgement Text

" आयकर अपीलीय अधिकरण “बी” न्यायपीठ पुणे में । IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, PUNE BEFORE SHRI MANISH BORAD, ACCOUNTANT MEMBER AND MS. ASTHA CHANDRA, JUDICIAL MEMBER आयकर अपील सं. / ITA No.2626/PUN/2024 धििाारण वर्ा / Assessment Year : 2019-20 Sharad Shamrao Sawant, Aaditya Hospital, Main Chowk, Vishrambag, Sangli-416416 PAN : AQAPS3739G Vs. Assistant Commissioner of Income Tax, Central Circle, Kolhapur अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee by : Shri Umeshkumar M. Mali Department by : Shri Manish Mehta Date of hearing : 14-05-2025 Date of Pronouncement : 20-06-2025 आदेश / ORDER PER ASTHA CHANDRA, JM : The appeal filed by the assessee is directed against the order dated 28.08.2024 of the Ld. Commissioner of Income Tax (Appeals), Pune-11 [“CIT(A)”] pertaining to Assessment Year (“AY”) 2019-20. 2. The assessee has filed this appeal with a delay of 42 days. The assessee has filed an application for condonation of delay along with a sworn affidavit stating therein the reasons for delay in filing of the appeal. On perusal of the same, we are satisfied that the delay in filing of appeal is not intentional or deliberate but has occurred for the reasons mentioned in the affidavit. After hearing both the sides, we are of the view that the delay is attributable to the sufficient cause. We, therefore, condone the said delay and proceed to decide the appeal. 3. The assessee has raised the following grounds of appeal : “1) On the facts and circumstances of the case and in Law, the Ld. Assessing officer erred in making addition of Rs. 14,85,000/-by invoking provisions of section 69A of Income Tax Act 1961.on the basis of declaration made in survey action. 2 ITA No.2626/PUN/2024, AY 2019-20 1.1) Appellant is an individual working as an doctor and regularly assessed to tax. A survey Action U/s 133A was conducted on 06/03/2019. Assessee has made an voluntary declaration of Rs. 14,85,300/- as profession fees receipts. 1.2) Noteworthy fact is that Return of Income for AY 2019-20 was not filled as the due date to file return of income is yet to come. As the income in dairy was pertaining to financial year 2018-19 appellant has reconciled all details and filled correct income tax return of income for AY 2019-20 within prescribed due date and paid necessary taxes thereon. Learned AO considered declaration of Rs. 14,85,000/- (over and above the return income) as deemed income U/s 69A. 1.3) This declared income being an professional fees appellant has credited the same to his audited income expenditure account. Same has been produced during the course of assessment hearing but learned AO has not considered the same” 4. Facts of the case in brief, are that the assessee is an individual. He is running a hospital in the name of “Aaditya Hospital” in Sangli. A survey operation u/s 133A of the Income Tax Act, 1961 (the “Act”) was conducted at the business premises of the assessee on 06.03.2019. During the course of survey, a diary was impounded wherein certain unaccounted receipts amounting to Rs. 14,85,300/- were found which the assessee declared as an additional income on account of professional/consultation charges, remained to be recorded in the books of account. Thereafter, the assessee filed his return of income on 12.12.2019 declaring total income at Rs.1,77,36,950/-. The case of was selected for scrutiny under CASS. Accordingly, statutory notice(s) under section 143(2) and 142(1) along with questionnaire were issued and served upon the assessee from time to time. In response thereto, the assessee‟s authorized representative appeared and furnished the relevant details/ documents as required/ called upon such as details regarding the nature of business, ITR & computation, P&L, Balance Sheet, bank accounts held during FY 2018-19 etc. The Ld. AO noted that the diary named „Sutures INDIA Dairy 2018‟ impounded during the survey action had the details of consultancy charges received by cash from 2nd April 2018 to 5th March 2019. As per the diary those receipts were consultancy charges and was not containing any details of patients, date of checking, date of rechecking etc. The Ld. AO also noted that the main source of the assessee‟s income is from the consultancy fees given to various companies i.e. National Insurance, Bajaj Allianz, CMRF, ESIC receipts, ICICI insurance, Police department, United India Insurance etc. and from OPD and IPD receipts of the above companies. These receipts 3 ITA No.2626/PUN/2024, AY 2019-20 were accounted for in the books of account but the receipts in cash to the tune of Rs.14,85,300/- from consultancy to other than the above company‟s patients were not recorded in the regular books of account by the assessee. The Ld. AO completed the assessment on 30.09.2021 u/s 143(3) of the Act treating such additional income which was in the form of unaccounted cash sales of Rs. 14,85,300/- declared by the assessee as deemed income of the assessee, taxable under the provisions of section 69A with the applicability of section 115BBE of the Act. 5. Aggrieved, the assessee filed an appeal before the Ld. CIT(A). However, there was no compliance to various notice(s) issued by the Ld. CIT(A). He, therefore, proceeded to adjudicate the appeal on the basis of documents submitted by the assessee as part of the appeal memo i.e. grounds of appeal and statement of facts. The Ld. CIT(A) dismissed the appeal of the assessee on the ground that both the nature and source of undisclosed income surrendered during the survey operation remained unexplained by the assessee during the assessment as well as appellate proceedings. He, therefore, upheld the action of Ld. AO in taxing the undisclosed income u/s 69A r.w.s. 115BBE of the Act by observing as under : “8. The only issue involved in this appeal is that when there is a survey or search action wherein certain undisclosed income is found, under which head can it be brought to tax and at what rate, the tax should be charged. This issue has been discussed by various High Courts and Tribunals from time to time and depending on the facts of the case, it was decided as to whether such income was taxable as „business income‟ or „deemed income assessable u/s 68, 69 or 69A to 69D of the Act. Some of these decisions are discussed as under: Decisions where it was held that the surrendered income is taxable under the provisions of section 68, 69, 69A to 69D of the Act: 9.1 The Hon‟ble Gujrat High Court in case of Fakir Mohmed Haji Hasan vs CIT 120 TAXMAN 11 (Gujarat) had to decide question whether value of gold found during search is to be included in income where no explanation about source of investment made is provided. The Hon‟ble High Court was also concerned with the question whether any deduction in relation to confiscated gold is to be given. The relevant assessment year was AY 1984-85 (i.e. prior to introduction of section 115BBE in the Act). The facts disclosed in customs proceedings, which were relied on in the income tax proceedings were that specific information was received by the Customs Department indicating that the taxpayer would bring imported gold in his car and would make delivery thereof. The car was seized and at that time during search gold bars of foreign markings were recovered. A bag containing currency notes was also recovered. The statements which were recorded under section 108 of the Customs Act were considered in the adjudication proceedings. The Hon‟ble High Court upheld the decision of Tribunal that the value of gold was liable to be included in the income of the assessee as the source of investment in 4 ITA No.2626/PUN/2024, AY 2019-20 the gold or of its acquisition was not explained and that the assessee was not entitled to claim that the value of the gold should be allowed as a deduction from his income. The relevant portion of the judgement is as under:- 6. Under section 4 of the Act, income-tax is to be charged in accordance with the provisions of the Act in respect of the total income of the previous year of every person. As provided by section 5 of the Act, total income of any previous year of a person would, inter alia, include all income from whatever source derived which is received or is deemed to be received by such person, subject to the provisions of the Act. It will be seen from section 69A that where the bullion, jewellery or other valuable article is not recorded in the books of account and there is no explanation about the nature and source of its acquisition, or the explanation is not satisfactory, the value thereof may be deemed to be the income of the assessee of the financial year immediately preceding the assessment year in which the assessee is found to be the owner of such bullion, etc. 6.1 The scheme of sections 69, 69A, 69B and 69C of the Act would show that in cases where the nature and source of investments made by the assessee or the nature and source of acquisition of money, bullion, etc., owned by the assessee or the source of expenditure incurred by the assessee are not explained at all, or not satisfactorily explained, then the value of such investments and money, or value of articles not recorded in the books of account or the unexplained expenditure may be deemed to be the income of such assessee. It follows that the moment a satisfactory explanation is given about such nature and source by the assessee, then the source would stand disclosed and will, therefore, be known and the income would be treated under the appropriate head of income for assessment as per the provisions of the Act. However, when these provisions apply because no source is disclosed at all on the basis of which the income can be classified under one of the heads of income under section 14 of the Act, it would not be possible to classify such deemed income under any of these heads including \"Income from other sources\" which have to be sources known or explained. When the income cannot be so classified under any one of the heads of income under section 14, it follows that the question of giving any deductions under the provisions which correspond to such heads of income will not arise. If it is possible to peg the income under any one of those heads by virtue of a satisfactory explanation being given, then these provisions of sections 69, 69A, 69B and 69C will not apply, in which event the provisions regarding deductions, etc., applicable to the relevant head of income under which such income falls will automatically be attracted. 6.2 The opening words of section 14 „Save as otherwise provided by this Act‟ clearly leave scope for „deemed income‟ of the nature covered under the scheme of sections 69, 69A, 69B and 69C being treated separately, because such deemed income is not income from salary, house property, profits and gains of business or profession, or capital gains, nor is it income from „other sources‟ because the provisions of sections 69, 69A, 69B, and 69C treat unexplained investments, unexplained money, bullion, etc., and unexplained expenditure as deemed income where the nature and source of investment, acquisition or expenditure, as the case may be, have not been explained or satisfactorily explained. Therefore, in these cases, the source not being known, such deemed income will not fall even under the head, „Income from other sources‟. Therefore, the corresponding deductions, which are applicable to the incomes under any of these 5 ITA No.2626/PUN/2024, AY 2019-20 various heads, will not be attracted in case of deemed incomes which are covered under the provisions of sections 69, 69A, 69B and 69C in view of the scheme of those provisions. 7. It is, therefore, clear that, when the investment in or acquisition of gold, which was recovered from the assessee was not recorded in the books of account and the assessee offered no explanation about the nature and source of such investment or acquisition and the value of such gold was not recorded in the books of account, nor the nature and source of its acquisition explained, there could arise no question of treating the value of such gold, which was deemed to be the income of the assessee, as a deductible trading loss on its confiscation, because such deemed income did not fall under the head of income „Profits and gains of business or profession‟. 8. In our opinion, therefore, the Tribunal was perfectly right in holding that the value of the gold was liable to be included in the income of the assessee as the source of investment in the gold or of its acquisition was not explained and that the assessee was not entitled to claim that the value of the gold should be allowed as a deduction from his income. 9.2 The Hon‟ble Punjab and Haryana High Court in case of Kim Pharma Pvt Ltd vs. CIT [2013] 216 Taxman 153 (P&H), has held that where amount surrendered during survey was not reflected in books of account and no source of income from where it was derived declared by the taxpayer then it was assessable as deemed income of the assessee u/s 69A of the Act and not as business income. 9.3 The Hon‟ble Madras HC in case of M/s. SVS Oils Mills vs. ACIT [2020] 113 taxmann.com 388 (Madras), has held that where there was a clear admission by assessee firm that excess stock found during survey was added in its stock register but no corresponding entry was passed in books of account, it could be considered that investment in such stock was made out of undisclosed source. Thus, addition was to be made under section 69B in respect of such excess stock. Decisions where it was held that sections 68, 69, 69A to 69D are not applicable 10. On the other hand, in following decisions, it was held that sources of surrendered/ undisclosed income are explained, deemed income provisions under sections 68, 69, 69A to 69D are not applicable and consequently, tax rate u/s 115BBE is also not applicable. 10.1 The Hon‟ble Rajasthan High Court in case of CIT vs Bajargan Traders [2017] 86 taxmann.com 295 (Rajasthan)has held that when the assessee is dealing in sale of food grains, rice and oil seeds and the excess stock which is found during survey is stock of rice then, it can be said that investment in procurement of such stock of rice is clearly identifiable and related to the regular business stock of the assessee. Therefore, the investment in the excess stock is to be brought to tax under head “business income” and not under the head income from other sources. 10.2 In case of Shri Lovish Singhal vs ITO (ITA No 142 to 146/Jodh/2018 for AY 2014-15 dated 25 May 2018), the Jodhpur Tribunal applying the proposition of law laid down by the Hon‟ble Rajasthan High Court in the Bajargan Traders (supra), held that the lower authorities were not justified in taxing the surrender made on account of excess stock and excess cash found U/s 69 of the Act and accordingly held that there is no justification for taxing such income U/s 115BBE of the Act. 6 ITA No.2626/PUN/2024, AY 2019-20 10.3 In case of Oberoi Motors vs ACIT [ITA No. 3512/Del/2018 AY 2012-13 dated 16 July 2021], the taxpayer had declared surrendered income after set-off of business loss. The lower authorities did not accept the above treatment and held that the surrendered amount is deemed income and does not fall under any of the head of income and therefore no set off of business losses could be allowed. The Hon‟ble Tribunal held that as the assessee had already introduced the transactions in books of accounts, it would not be reasonable to say that such income does not fall under any of the head of income or that such deemed income does not allow any set off of business losses. Accordingly, the Tribunal accepted that the surrendered income amounts to business income. 10.4 In case of DCIT vs Ram Narayan Birla (ITA No. 482/JPR/2015 for AY 2011-12 dated 30 September 2019), also on the surrendered stock during search or survey action, it was held that the Revenue had not pointed out that the excess stock had any nexus with any other receipts found. Hence, the surrendered excess stock considered at par with the other business stock. 11. It can be seen from the above judicial precedents that whether the undisclosed income found during the search or survey action is taxable under any of the five heads of income as specified in section 14 of the Act or it is to be taxed as „deemed income taxable under section 68 to 69D of the Act‟,is essentially a question of fact and it entirely depends on whether the assessee has been able to satisfactorily explain the source of such undisclosed income or not. If, a satisfactory explanation is provided about the nature and the source, in that case the source would stand explained and therefore, the income would be computed under the appropriate head of income as per the provisions of the Act. However, when no source is explained based on which the income can be classified under any of the heads of income specified under section 14, then it would be classified as deemed income and shall be taxed as per the rates provided under section 115BBE of the Act. 12. It is also important to mention here that the Hon‟ble Supreme Court in case of Kale Khan Mohammad Hanif vs CIT [1963] 50 ITR 1 (SC) held that onus of proving the source of a sum of money found to have been received by the assessee is on him. However, if the taxpayer disputes the levy of tax on the same then it is up to him to show either the receipt is not income, or it is exempt from taxation under the provisions of the Act. In the absence of proof, the tax officer is entitled to treat the same as taxable income. Thus, the onus of explaining the source of undisclosed income found during search or survey is on the assessee and not the other way. In other way, the onus of proving that the income detected is not taxable under sections 68, 69, 69A to 69D read with section 115BBE is on the assessee. 13. To sum up, before assessing the surrendered income under sections 68, 69, 69A to 69D and levy of higher rate of tax u/s 115BBE, following factors are required to be considered–  Whether nature of income is clearly explained during the survey or during assessment proceedings.  Whether income can be classified under a particular head of income based on nature so as to demonstrate that it is flowing from one of the specific sources of income of the assessee.  Whether supporting evidences for the above are available because the onus to satisfactorily explain the nature and source is on the assessee. 7 ITA No.2626/PUN/2024, AY 2019-20 14. In the present case, during the survey, the appellant made a declaration of additional income amounting to Rs. 14,85,300/- towards undisclosed receipts. The appellant is claiming that the said income was on account of professional receipts which remained to be accounted for in the books of accounts. However, during the appellate proceedings, the appellant has not filed any explanation supporting his claim. The appellant has also not filed any evidence to suggest that these receipts are from his regular business or profession. 15. As discussed earlier in this order, the onus of explaining the specific source from which such unexplained income is flowing, is on the assessee and not on the department. In the present case, the appellant has miserably failed to discharge the said onus. The contention of the appellant is that the undisclosed income discovered during the survey operation should be taxed as business income even without explaining the manner in which so-called business income was earned. Acceptance of the contention of the appellant may lead to a situation where a tax payer having undisclosed income from a source other than from business or profession, can claim that the same is taxable at normal rate, being his business income. This situation is clearly against the intentions of legislature wherein the legislature has mandated that such undisclosed income should be taxed at special rates provided u/s 115BBE of the Act. 16. In the present case, since, the nature of income is not clearly explained during the assessment proceedings. Even during the appellate proceedings, the appellant has not demonstrated that the said income is flowing from business, with the help of supporting evidences. In this manner, both nature and source of undisclosed income surrendered during the survey operation remained unexplained. In such situation, the additional income of Rs. 14,85,300/- is taxable u/s 69A of the Act. Therefore, the action of the assessing officer in taxing the undisclosed income as per the provisions of sec. 115BBE of the Act, is upheld. The ground nos. 1.1 to 1.3 raised by the appellant are DISMISSED.” 6. Dissatisfied, the assessee is in appeal before the Tribunal and all the grounds of appeal relate thereto. 7. The Ld. AR at the outset submitted that the impugned income of Rs. 14,85,300/- alleged to be taxed as deemed income under section 69A r.w. section 115B of the Act arises out of cash sales, the source of which is the earning of the assessee from his business/profession. He submitted that the impugned additional/deemed income is not an unaccounted receipt but a legitimate business income which was properly included in the audited books of account and financial statements for the relevant period. It is a part of the regular business operations of the assessee who is a doctor engaged in providing consultancy services which include medical consultancy services rendered under the Government schemes, insurance receipts and from private patients, and therefore the same should not be treated as unexplained money u/s 69A. The amounts in question were 8 ITA No.2626/PUN/2024, AY 2019-20 duly disclosed and accounted for in the audited financial statements filed with the income tax return for the AY 2019-20. Referring to the diary which was found during the survey proceedings, on the basis of which the impugned addition has been made by the Ld. AO, the Ld. AR submitted that the said diary contained entries about consultancy charges received in cash but the same was duly disclosed by the assessee as part of the business receipts. He therefore submitted that when the sources of income in relation to surrendered income are explained, then such income is to be taxed as regular business income and invoking deeming provisions under section 69, 69A etc. is not warranted and consequently, the higher rate of tax under section 115BBE is also not applicable. In support thereof, he relied on the decision of the Pune Tribunal in the case of Vasantrao Jayavantrao Mugale Vs. DCIT (Pune ITAT, 2023 ITL/2381) wherein under the similar set of facts where the Tribunal relying on the ratio laid down of the Hon‟ble Rajasthan High Court in the case of Pr. CIT Vs. Bajargan Traders in D.B. Income Tax Appeal No. 258/2017 held that where the excess cash found during survey was linked to unrecorded receipts from business income, the same is not taxable under the provisions of section 69A r.w.s. 115BBE of the Act. 8. The Ld. DR relied on the order of the Ld. AO/CIT(A). 9. We have heard the Ld. Representatives of the parties and perused the material on records. We have also considered the judicial precedents relied upon by the Ld. AR. The facts of the case are not in dispute. Admittedly, the impugned receipts are arising out of the cash sales generated by the provision of consultancy services by the assessee during the relevant AY. These receipts were duly disclosed and accounted for in the audited financial statements filed with the income tax return for AY 2019-20. The Ld. AO considered these receipts being in the form of unaccounted cash sales as deemed income of the assessee taxable under the provisions of section 69A with the applicability of section 115BBE of the Act. The Ld. CIT(A) confirmed the action of the Ld. AO holding that the assessee failed to offer explanation as to the source of the cash receipts declared by him. Perusal of the Ld. CIT(A)‟s order reveals that the assessee failed to comply to various notice(s) issued by the Ld. CIT(A) which resulted in an ex-parte order passed by the Ld. CIT(A) on the basis of documents 9 ITA No.2626/PUN/2024, AY 2019-20 available on record i.e. grounds of appeal and statement of facts. It is the case of the Ld. Counsel for the assessee that the return of income for AY 2019-20 was not filed as the due date for filing return of income had still not expired as the alleged receipts mentioned in the diary impounded during the survey operation by the Ld. AO was pertaining to Financial Year 2018-19. The assessee reconciled all the details and filed correct income tax return for the AY 2019-20 within the prescribed due date and also paid necessary taxes thereon. The impugned income being professional fee was credited and duly reflected in the audited income & expenditure account of the assessee and the same was produced before the Ld. AO during the assessment proceedings, however, were not considered by him. We have also perused the judicial precedents cited above relied by the Ld. AR and find some force in the argument advanced by him. However, at the same time, it is an admitted fact that there was no appearance before the Ld. CIT(A). The Ld. CIT(A) has observed that the assessee‟s claim that the impugned income was on account of professional receipts which remained to be accounted for in the books of account of the assessee, has not been supported by any explanation/evidence to suggest that these receipts are from his regular business/profession. The Ld. CIT(A) has further observed that the onus of explaining the specific source from which such unexplained income is flowing is on the assessee which has not been discharged in the present case and therefore the same is taxable under the provisions of section 115BBE of the Act at special rates. He has therefore upheld the order of the Ld. AO concluding that the nature of income has not been clearly explained during the assessment as well as appellate proceedings before. As the assessee failed to demonstrate that the impugned receipts are flowing from business with the help of supporting evidences, he dismissed the appeal of the assessee. 10. Considering the totality of the facts and in the circumstances of the case enumerated above, we deem it fit and proper, in the interest of justice and fair play, to restore the matter to the file of the Ld. CIT(A) with a direction to decide the impugned issue afresh on merits by passing a speaking order on each of the grounds of appeal raised by the assessee before him as per facts and law, after affording reasonable opportunity of being heard to the parties. Needless to say, the assessee shall provide the requisite support in terms of filing the relevant submissions and 10 ITA No.2626/PUN/2024, AY 2019-20 supporting documents/evidence as may be required/called upon, without seeking adjournment under any pretext unless required for sufficient cause, failing with the Ld. CIT(A) shall be at liberty to pass an appropriate order as per law. The assessee is also directed to remain vigilant and provide the Department with his latest contact details/email id for receiving notice(s) of hearing through Departments‟ portal and making compliance thereof. We direct and order accordingly. The grounds of appeal raised by the assessee are therefore allowed for statistical purposes. 11. In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced in the open court on 20th June, 2025. Sd/- Sd/- (Manish Borad) (Astha Chandra) ACCOUNTANT MEMBER JUDICIAL MEMBER पुणे / Pune; दिन ांक / Dated : 20th June, 2025. रदि आदेश की प्रधिधलधप अग्रेधर्ि / Copy of the Order forwarded to : 1. अपील र्थी / The Appellant. 2. प्रत्यर्थी / The Respondent. 3. The Pr. CIT concerned. 4. दिभ गीय प्रदिदनदि, आयकर अपीलीय अदिकरण, “बी” बेंच, पुणे / DR, ITAT, “B” Bench, Pune. 5. ग र्ड फ़ इल / Guard File. //सत्य दपि प्रदि// True Copy// आिेश नुस र / BY ORDER, िररष्ठ दनजी सदचि / Sr. Private Secretary आयकर अपीलीय अदिकरण ,पुणे / ITAT, Pune "