SHRI DINESH MAN SINGH,HYDERABAD V. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- II, KANPUR

ITA 587/LKW/2018

AI Insights

The case involves an appeal by Shri Dinesh Man Singh against the addition of Rs.10,05,000 to his income, representing the value of silver bars found during a search operation under section 132 of the Income Tax Act, 1961. The search was conducted on 16.12.2015 at the residential premises of the assessee and his brother, Shri Shatrughan Man Singh. The silver bars were not disclosed in the Wealth Tax Returns of the assessee or his family members. The assessee claimed that the bars belonged to his brother and were covered by a surrender of undisclosed income made by his brother. However, both the Assessing Officer and the CIT(A) found the assessee's explanations unsatisfactory, leading to the confirmation of the addition.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 312532 (ITAT-LUCKNOW)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 01-05-2025
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: B
• Assessment Year: 2016-2017
• Other Referred Cases: P.R Metrani v. CIT, Pullangoda Rubber Produce Co Ltd. vs. State of Kerala, Dy. CIT vs. Sanmukhdas Wadhwani, ACIT v. Satyapal Wassan
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: SUNIL KUMAR RAJWANSHI
• Assessee Lawyers: VIKAS GARG
• Keywords: Corroborative evidences; Unexplained investment; Principle of natural justice; Search and seizure; Source of fund
• Section: 143(3); 142(1); 32; 132; 69

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH “B”, LUCKNOW BEFORE SHRI KUL BHARAT, VICE PRESIDENT AND SHRI ANADEE NATH MISSHRA, ACCOUNTANT MEMBER ITA No.587/LKW/2018 Assessment Year: 2016-17 Shri Dinesh Man Singh Shri Kanchan Khanna, 15/45- B, Civil Lines, Kanpur-208001. v. DCIT Central Circle-II Laxmi Niwas, 10/503, Allenganj, Kanpur- 208001. PAN:ACQPM1819H (Appellant) (Respondent) Appellant by: Shri Vikas Garg, Adv Respondent by: Shri Sunil Kumar Rajwanshi, Addl. CIT(DR) O R D E R PER ANADEE NATH MISSHRA, A.M.: (1). The present appeal has been filed by the assessee against the impugned appellate order dated 28.06.2018 passed by the Ld. Commissioner of Income Tax (Appeals)-IV, Kanpur under section 250(6) of the Income Tax Act, 1961 (hereinafter referred as to “the Act”) for the assessment year 2016-17-. The grounds of appeal of the assessee are as under: - “1. That the Authorities below have erred in law and on facts in making an addition of Rs.10,05,000/- on the account of silver found during the course of search. 2. That the authorities below failed to appreciate that the silver found during course of search was in his possession as head of the family and was duly covered by surrender of Rs.5.00 crores made by assessee’s younger brother staying jointly with the assessee. 3. That the said addition of Rs.10,05,000/- is wholly inconsistent with the facts of the case on record and has been made without appreciating the same. 4. That the learned AO has erred in law and on facts in making the said addition of Rs.10,05,000/- in an arbitrary manner. ITA No.587/LKW/2018 Page 2 of 10 5. That the impugned assessment is contrary to provisions of law and principles of natural justice equity and fair play. 6. That the assessee craves leave to modify any grounds of appeal herein before or take additional ground(s) during pendency of this appeal.” (2) In this case, assessment order dated 28.12.2017 was passed by the Assessing Officer, under section 143(3) of the Income Tax Act, 1961 (“the Act”, for short) whereby assessee’s total income was determined at Rs.47,01,960/- (Rounded off to Rs.47,01,960/-) as against returned income of Rs.36,96,955/-. This case pertains to Shri Deepak Kothari Group of cases in which search under section 132 of the Act was carried out on 16.12.2015. At the time of search at residential premises of the assessee, items of jewellery were found in addition to silver bars of the value of Rs.10,05,000/-. The Assessing Officer accepted the assessee’s explanation regarding jewellery found after giving due consideration to Wealth Tax Returns filed by the assessee and his family members. However, the aforesaid silver bars valued at Rs.10,05,000/- were not disclosed in Wealth Tax Returns of the assessee or his family members. The Assessing Officer made addition of the aforesaid amount of Rs.10,05,000/-. The relevant portion of the assessment order is reproduced as under: - “Shri Dinesh Man Singh was asked to explain the source of jewellery was found at the residence. He has stated that all the members of his family filed wealth tax returns and paid the tax accordingly. After verifying the wealth tax returns of the family members, gold, diamond jewellery was not seized except silver bars weighing 30 Kg. amounting to Rs.10,05,000/- which belong to Shri Dinesh Man Singh and was not declared in wealth tax returns. Shri Dinesh Man Singh in his statement recorded on oath stated that the silver bars valuing Rs.10,05,000/- has not been declared in the wealth tax returns. During the course of assessment proceedings the assessee was asked to explain the source of silver bars of Rs.10,05,000/-. The assessee in his reply has stated that silver bars weighing 30 Kg. found and seized during search proceedings at my premises belong to my brother Shri Shatrughan Lal Man Singh and they do not belong me. They have been separately explain by his brother Shri Shatrughan Lal Man Singh in his case. The reply of the assessee has been considered but not found acceptable as the assessee himself in his statement recorded u/s 132(4) of the I.T. Act, 1961 had admitted that the silver bars of 30 Kg. amounting to Rs.10,05,000/- belongs to him and had not been disclosed in his wealth returns.” ITA No.587/LKW/2018 Page 3 of 10 (2.1) The assessee filed appeal in the office of the Ld. CIT(A). Vide impugned appellate order dated 28.06.2018, the Ld. CIT(A) dismissed the assessee’s appeal by observing as under: - 5.2 In this regard, appellant has filed his written submission which is reproduced as under: - 1. That a search u/s 132(1) of the Income Tax Act, 1961 was carried out at the residential premises of the assessee and his younger brother Shri Shatrughan Man Singh at 15-6-280, Ranjeet Talim, Begum Bazaar, Hyderabad and at the business premises of the aforesaid two persons on 15/12/2015. 2. That statement on oath of both the assessee, Dinesh Man Singh, and that o his younger’ brother Shri Shatrushan Man Singh were recorded u/s 132(4) of the Income Tax Act, 1961 on 16/12/2015, Copy of the aforesaid statements are enclosed as Annexure and Annexure-2 respectively. 3. That during the course of search cash aggregating to Rs.346,85,400/- together with jewellery and silver bars were allegedly fund from the possession of the assessee at his residence, 4. The assessee in his statement u/s 132/d) stated that they are allowing six brother staying in a joint family at the aforesaid/searched residence i Jagdish Naravan ii Dines Mapsingh (assessee) iii. Sharvan Kumar iv, Rajendra Kumar v, Bharath lal vi, Shatrughan Lal Man Singh (the other searched person) (Kindly refer Q & A NO.2) That assessee also explained that the jeweller belongs to various family members but-way kept in his custody by them, as he is the head o the family, and is duly recorded in the Wealth Tax Return of respective family members (kind] refer Q & A 9). The assessee in response stated that the silver bars weighting 30 Kg were not disclosed in the Wealth Tax Return, In response to Q & A No, 10 the assessee explained that source of cash will be explained by his younger brother Shri Shatrughan Man Singh. 5. That Shri Shatrughan Man Singh in his statement recorded u/s 132(4), the recording of statement the assessee, accepted the ownership his of cash of Rs.3,46,85,400/- (kindly refer Q & A No. 13) and thereafter surrendered Rs.5Crore his undisclosed income for FY 2015-16 (Kindly refer Q & A No.18). 6. That in assessment proceedings u/s 143(3) for AY 2016-17, the assessee explained before the AO that the silver bars belonged to his brother Shri Shatrughan Man Singh and also filed an affidavit to that copy of reply dated 14/12/2017 along with copy of affidavit is enclosed as Annexure-3. It was also apparent the in the case of Shatrughan Man Singh the said silver bars were covered b the surrendered income 5. crore (In fact in assessment proceedings u/s 143(3), Shatrughan Man Singh vide his letter dates ' December 2017 categorically claimed ownership the silver bars and explained the source of same out of his surrendered income. Copy of reply dates 04/12/2017 filed by Shri Shatrughan man Singh during assessment proceedings u/s 143(3) is enclosed as Annexure-4, ITA No.587/LKW/2018 Page 4 of 10 7. However the AO without any cogent reason rejected the submission of the assessee and added a sum of Rs. 10,05,000/- to the income of the assessee being value of 30Kg of silver bars found during search u/s 69 of the Income Tax Act 1961. 8 Your honour the AO failed to appreciate that during search nowhere was the assessee required to explain the source of silver bars as was the case in cash of Rs.3,46,85 440/-. The officer the department only asked the assessee to explain the source of cash. A perusal of the statement of assessee will clearly bring forth the aforesaid fact. Further in the statement of Shri Shatrughan Man Singh also no question had been “asked from him regarding the source of silver bars, these questions been asked it would have been explained at time itself. Further the assessee had very clearly stated that ornaments etc recovered from his custody belong to his family members who have kept it in his custody. Under these circumstances the AO was wholly unjustified in treating the 30 Kg of silver bars as income of the assessee u/s 69 of the Income Tax Act, 1961. 9. That your kindself will appreciate that in the statement recorder u/s 32 4 nowhere has the assessee claimed ownership of the silver bars. The issue relating to presumption u/s 132(4A) has been resolved by the Hon'ble Supreme Court in the case of P.R Metrani v, CIT (2006) 287 ITR 209 by pointing out that the presumption for seizure u/s 132(4A) is a rebuttable one, since the expression used is “may be presumed”. Further the Hon'ble Apex Court has held that since section 132 is a self contained code confined search and seizure, the presumption for purpose of seizure cannot be held good for a regular assessment, there is no provision in the statue to carry over such presumption to a regular assessment. Your kindself will further appreciate that where a search u/s 132(1) of the Act is made on a premises occupied by several individual person of a family staying jointly, it is generally a practice to make surrender of undisclosed income/assets in case of one person assessee in statement recorded u/s 132(4) to avoid pletharo of cases and this practice s also generally accepted by the department. In the present case too surrender of income was made by Shatrughan Man Singh considering all assets found and it was the manner and inadvertent lack of clarity in which statement u/s 1 32(4) was recorded that the confusion has arisen. It is also a fact that if the silver bars were not sought to be covered by the surrender the assessee would have in his return for AY 2016217 disclosed the same to take benefit of penalty at-a lower rate u/s 271AAb (1)(b). 10. That in view of about it is stated that the presumption, if any, u/s 132(4A) stands rebutted by (a) Submissions dated 04/12/2017 filed by Shri Shatrughan Man Singh before the same AO in his proceedings w/s 143(2)/143(3) for AY 201617. (b) Affidavit filed by Mr. Shatrughan Man Singh in assessment proceedings of assessee ie. Dinesh Man Singh u/s 143(2)/143(3) for AY 2016-17. (c) The manner and inadvertent lack of clarity in which statement u/s 132{4) was recorded by the officers of the department both in the case of the assessee and his younger brother Shri Shatrughan Man Singh. ITA No.587/LKW/2018 Page 5 of 10 (d) Statement of assessee u/s 132(4) that all the jewellery/cash etc is kept in his custody brother family member, the assessee being the head of the family (Q & A No.9). (e) The manner-in which generally and usually income is surrendered by one person amongst various family member in search proceedings and also generally obtained and accepted by the department. (f) The manner in which the assessee filed his return of income being assured that the Said silver bars were covered by surrendered income in the hands of his younger brother Shatrughan Man Singh, which otherwise he would have disclosed to take benefit of lower penalty u/s 271AAB(I)(b) as the silver bars were not declared in wealth tax returns as accepted in the statement recorded u/s 132(4) of the assessee. It is therefore requested that since assessee thus rebutted the presumption u/s 132(4A) by giving plausible explanation as above that the silver bars belonged to his younger brother Shri Shatrughan Man Singh and duly covered by income surrendered by him, therefore the addition of Rs. 10,05,000/- made u/s 69 on account of 30 Kg of silver bars found may kindly be deleted and the appeal allowed. The assessee in support of its prayer places reliance on the decision of Hon'ble Jurisdictional High Court in the case of CIT v. Raj Pal Singh Ram Avatar 2007 288 ITR 494. Copy of aforesaid decision is enclosed as Annexure-5. The assessee in support of its averments herein before also finds support from following decisions: (i) The Hon'ble Supreme Court has in the case of Pullangoda Rubber Produce Co Ltd. vs, State of Kerala 91 ITR 18 have held that it would be open to the assessee making admission to show that it is incorrect. (ii) Separate additions cannot be made by assessing officer on account of investment in moveable property, source of which was already subjected to tax, even if the addition was made on the basis of statement of assessee recorded by ADI ws 132(4). -Dy. CIT vs, Sanmukhdas Wadhwani 85 ITD 734 (Nag). (iii) Decision of Hon'ble (ITAT Jabalpur Bench in the case of ACIT v, Satyapal Wassan (2007) 295 ITR (AT) 352. In the aforesaid case while deciding on presumption and its rebuttal the Hon'ble ITAT held as follows: \"That the document was bereft of necessary details about the year of transaction, ownership, nature of transaction, necessary code for deciphering the figures. The Assessing Officer presumed that the transaction belonged to the financial year 1988-89 relevant to the assessment year 1959-90, that the figures mentioned in the document were advances made by the assessee, that the transaction belonged to the assessee, and that the transactions were in a code of Lakhs and that the unit was the rupee. The Assessing Officer did not carry out any enquiry either during the course of search or during the course of assessment proceedings to find out the nature of transactions and the period in which those transactions were carried out the had simply presumed that advances without there being any material on record to support such presumption. If the assessee had affidavit denied the ownership of the document and the assessee's brother admitted that it belonged to her ITA No.587/LKW/2018 Page 6 of 10 husband, it could not be in erred without rebutting this evidence that the document and transactions recorded therein in act belonged to the assessee. The affidavits, even in regarded as self serving did not lose their evidential contra value as there was no material to the averments made in the affidavit Nothing was shown by the Assessing Officer that there was other material correlated with the document clearly showing that it belonged to the assessee. Under these circumstances, the assessee has successfully shifted the onus on to the Assessing Officer by filing the affidavits, Once the onus shifted to the Assessing Officer, he was duty bound to collect evidence so as to belie the contents o the’ affidavit “5.3 The undersigned has carefully gone through the assessment order, written submission as well as verbal arguments of the Id. A.R.. It is seen that A.O. added Rs. 10,50,000/- as unexplained investment in Silver Bars by giving finding that source of acquisition of Silver bars could not explain by the assessee, During the course of hearing, it was the argument of Ld AR that Silver Bars under question do ns pertain to the assessee and owner of these Silver Bari his brother Shri Satrughan Man Singh In support of his contention, Id. AR. submitted copy of statements u/s 132(4) of the Act given by the appellant and his brother Ld. A.R. also contended that in the assessment proceedings in the case of his brother, said Silver Bars were owned by his brother and A.O, accepted the same. Upon the above contentions and details of appellant, undersigned carefully perused the details and find difference in facts as submitted by Id. AR. In the statement u/s 132(4) of the Act, appellant never come out with the statement that he is not the owner of such Silver Bars and the same represent's the assets of his brother. Similarly, his brother, Shri Satrughan Man Singh in his statement u/s 132(4) of the Act did not give any statement for ownership of such Silver Bars. Moreover, at the time of surrender nowhere the ownership of Silver Bars were stated by Shri Satrughan Man Singh. Shri Satrughan Man Singh clearly explained the sources of income what he had surrendered. There is no mentioned in of these Silver Bars Silver Bars were found from the ownership of the appellant, it can be safely presumed that ownership of Silver Bar belongs to the appellant and it was the duty of the appellant to substantiate its source of acquisition with cogent evidence. In the present factual matrix of the case, appellant has failed to do so. Therefore, submission of Id, A.R, lack merit at this score. Further, the contention that in the assessment proceedings of his brother A.O, has accepted the Silver Bars owned by Shri Satrughan Man Singh is totally baseless and incorrect because, if A.O. had accepted such Silver Bars explained in the hands of Shri Satrughan Man Singh then certainly A.O. will not add the same: in the hands of appellant. It would be most - important to mention here that A.O. for the both the brother is same. Therefore, it appears, Id. A.R. tried to create an story to deviate the revenue from real facts. All submissions made by the appellant are contrary to the red facts of the case, thus, cannot be relied upon. In view of the above discussion undersigned is of the considered opinion that A.O. has correctly made the addition in respect of Silver Bars, which is hereby confirmed. Grounds of appeal of the appellant are dismissed.” ITA No.587/LKW/2018 Page 7 of 10 (2.2) The present appeal has been filed by the assessee against the aforesaid impugned appellate order dated 28.06.2018 of the Ld. CIT(A). In the course of appellate proceedings in Income Tax Appellate Tribunal (“ITAT”, for short), the assessee filed a paper book containing the following particulars: - S No. Particulars Name 1 Copy of written submission filed before CIT(Appeals)-4, Kanpur 2 Copy of written submission dated 14.12.2017 filed before the Assessing Officer, DCIT, Central Circle-2, Kanpur, during course of assessment proceedings 3 Copy of affidavit of Shatrughan Lal Man Singh filed before AO, DCIT, Central Circle-2, Kanpur, During course of assessment proceedings in case of Dinesh Mansingh, assessee. 4 Copy of written submission dated 04.12.2017 filed by Shatrughan Lal Mansingh before AO, DCIT, Central Circle-2, Kanpur in his assessment 5 Copy of statement of Dinesh Man Singh, recorded u/s 132(4) of the Act on 16.12.2015 6 Copy of statement of Shatrughan Lal ManSingh recorded u/s 132(4) of the Act on 17.12.2015 7 Copy of acknowledgement of filing return of income and computation of total income of Dinesh ManSingh for AY. 2016-17 8 Assessment order u/s 143(3), in the case of Shatrughan Lal Man Singh for AY 2016-17, dated 20.12.2017 9 Notice u/s 142(1) dated 18.08.2017 issued in the case of Shatrughan Lal Man Singh in respect of AY 2016-17 10 Notice u/s 142(1) dated issued in the case of Dinesh Man Singh in respect of AY 2016-17 11 Copy of decision of Hon'ble Madras High Court in the case of R. Bhoopathy v. Commissioner of Income Tax, Chennai (2019) 103 taxmann.com 283 12 Copy of decision of Hon'ble Delhi High Court in the case of Principal Commissioner of Income Tax Central-1 vs Surya Agrotech Infrastructure Ltd (2023) 154 taxmann.com 156 13 Copy of decision of Hon'ble ITAT Bench Jaipur in the case of SMS-AAMVV Tollways (P.) Ltd vs Deputy Commissioner of Income Tax (2022) 145 Taxmann.com 14 Copy of decision of Hon'ble ITAT bench Mumbai in the case of Uday C. Tamhakar vs Deputy Commissioner of Income Tax (OSD)-II, Central Circle- 7, Mumbai (2017) 88 Taxmann.com 408 15 Copy of decision of Hon'ble ITAT Bench Bangalore in the case of Gopal S. Pandith vs Deputy Commissioner of Income Tax Central Circle, Mangalore (2016) 74 Taxmann.com 273 16 Copy of decision in the case of Sri Satyapal Wassan L/H Sri Naresh vs ACIT (2007) 295 ITR (AT) 352. (2.3) At the time of hearing before us, the Ld. Counsel for the assessee repeated the same submissions and arguments as were raised by the assessee in the course of appellate proceedings in the office of the Ld. CIT(A). Further, he placed reliance on the paper books [already mentioned in foregoing paragraph no. (2.2) ITA No.587/LKW/2018 Page 8 of 10 of this order]. The Ld. Departmental Representative strongly relied on the assessment order as well as impugned appellate order of the Ld. CIT(A). In particular, he drew our attention to the following portion of the order of the Ld.CIT(A) which is reproduced below for the ease of reference:- “5.3 The undersigned has carefully gone through the assessment order, written submission as well as verbal arguments of the Id. A.R. It is seen that A.O. added Rs. 10,50,000/- as unexplained investment in Silver Bars by giving finding that source of acquisition of Silver bars could not explain by the assessee, During the course of hearing, it was the argument of Ld AR that Silver Bars under question do ns pertain to the assessee and owner of these Silver Bari his brother Shri Satrughan Man Singh In support of his contention, Id. AR. submitted copy of statements u/s 132(4) of the Act given by the appellant and his brother Ld. A.R. also contended that in the assessment proceedings in the case of his brother, said Silver Bars were owned by his brother and A.O, accepted the same. Upon the above contentions and details of appellant, undersigned carefully perused the details and find difference in facts as submitted by Id. AR. In the statement u/s 132(4) of the Act, appellant never come out with the statement that he is not the owner of such Silver Bars and the same represent's the assets of his brother. Similarly, his brother, Shri Satrughan Man Singh in his statement u/s 132(4) of the Act did not give any statement for ownership of such Silver Bars. Moreover, at the time of surrender nowhere the ownership of Silver Bars were stated by Shri Satrughan Man Singh. Shri Satrughan Man Singh clearly explained the sources of income what he had surrendered. There is no mentioned in of these Silver Bars Silver Bars were found from the ownership of the appellant, it can be safely presumed that ownership of Silver Bar belongs to the appellant and it was the duty of the appellant to substantiate its source of acquisition with cogent evidence. In the present factual matrix of the case, appellant has failed to do so. Therefore, submission of Id, A.R, lack merit at this score. Further, the contention that in the assessment proceedings of his brother A.O, has accepted the Silver Bars owned by Shri Satrughan Man Singh is totally baseless and incorrect because, if A.O. had accepted such Silver Bars explained in the hands of Shri Satrughan Man Singh then certainly A.O. will not add the same: in the hands of appellant. It would be most - important to mention here that A.O. for the both the brother is same. Therefore, it appears, Id. A.R. tried to create an story to deviate the revenue from real facts. All submissions made by the appellant are contrary to the red facts of the case, thus, cannot be relied upon. In view of the above discussion undersigned is of the considered opinion that A.O. has correctly made the addition in respect of Silver Bars, which is hereby confirmed. Grounds of appeal of the appellant are dismissed.” (3) We have heard both sides. We have perused the materials available on record. It is not in dispute that silver bars valued at ITA No.587/LKW/2018 Page 9 of 10 Rs.10,05,000/- were found at the residential premises of the assessee, at the time of search under section 132(4) of the Act. It is also not in dispute that the aforesaid silver bars have not been disclosed in Wealth Tax Returns of either the assessee or any of his family members. Further, the claim of the assessee that the aforesaid silver bars should be considered as part of disclosure of Rs.5 Cr. made by the assessee’s brother Shri Satrughan Man Singh, is based on affidavit of assessee’s brother (Shri Satrughan Man Singh) made on 05.12.2017 which is after substantial lapse of time since date of search. However, neither the assessee nor his brother Shri Satrughan Man singh in his earlier statements made any mention of the aforesaid silver bars being either owned by the assessee’s brother or being part of the aforesaid disclosure of Rs.5 Cr. There is no supporting evidence for the claim that the silver bars belonged to the assessee’s brother. An affidavit made after substantial lapse of time since date of search, aimed at helping the assessee does not have any credibility when weight of other evidences and facts is heavily against the assessee, and is to be treated as an after thought. Further, the Assessing officer of the assessee and the assessee’s aforesaid brother was the same. Therefore, the contention of the assessee that in the assessment proceedings had accepted the ownership of the aforesaid silver bars in the hands of Shri Satrughan Man singh, the assessee’s brother deserves to be rejected being baseless; because if the Assessing Officer had accepted the ownership of the silver bars in the hands of the assessee’s brother, then, the Assessing Officer would not have added the amount in the hands of the assessee. In view of the foregoing, we are of the view that the claim of the assessee that the silver bars found at his residence belonged to his brother, the claim being made solely on the basis of aforesaid affidavit is to be rejected in the absence of ITA No.587/LKW/2018 Page 10 of 10 any supporting evidences. The impugned appellate order of the Ld. CIT(A) is found to be just and reasonable and in accordance with law, having regard to the specific facts and circumstances of the present case. No interference is called for in the impugned order of the Ld. CIT(A) and the aforesaid addition of Rs.10,05,000/- is confirmed. Therefore, the appeal of the assessee is dismissed. In the result, the appeal of the assessee is dismissed. Order pronounced in the open Court on 01/05/2025. Sd/- Sd/- [KUL BHARAT] [ANADEE NATH MISSHRA] VICE PRESIDENT ACCOUNTANT MEMBER DATED: 01/05/2025 Vijay Pal Singh, (Sr. PS) Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. DR 5. Guard file By order //True Copy// Assistant Registrar "