VALLABHBHAI BHAVANBHAI AMBALIYA,RAJKOT V. ACIT, CC-1, RAJKOT, RAJKOT

ITSSA 25/RJT/2024

AI Insights

The case involves an appeal by Vallabhbhai B. Ambaliya against the order of the Commissioner of Income-tax (Appeals)-11, Ahmedabad, which upheld an addition of Rs.1,00,000 to the assessee's income for the Assessment Year 2013-14. This addition was based on documents seized from a third party, which the assessee contested as being irrelevant to him. The Tribunal, referencing a similar case involving Shri Keshavjibhai Ramjibhai Busa, found that the additions were unjustified as there was no direct evidence linking the assessee to the seized documents. The Tribunal emphasized the need for corroborative evidence and the principle of natural justice, particularly the right to cross-examine witnesses whose statements are used against a party.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 360630 (ITAT-RAJKOT)
• Appeal Type: Income Tax (Search & Seizure) Appeal
• Pronouncement Date: 20-05-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Assessment Year: 2013-2014
• Other Referred Cases: Collector, Land Acquisition vs Mst. Katiji and others, Andaman Timber Industries Vs. Commissioner of Central Excise Kolkata, Praful I Chunila Patel Vs. M.J. Makwana, JCIT &Ors. Vs. George Willimson (Assam) Ltd., Kishanchand Chellaram V/s. CIT, Smt Neelam Nitin sankhe vs CIT(A), DCIT vs. Shri Himmatlal Gopal Patel Senghani, Krishnachand Chelaram Vs. CIT, Andaman Timber Industries Vs. Commissioner of Central Excise
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: DHEERAJ KUMR GUPTA
• Assessee Lawyers: MEHUL RANPURA
• Keywords: Condonation of delay; Document seized; Documents seized; Principle of natural justice; Loose papers; Bogus loan; Opportunity of cross examination
• Section: 143(3); 142(1)

Judgement Text

"IT(SS)A No. 25/Rjt/2024 A.Y 13-14 Vallabhbhai B. Ambaliya Page | 1 आयकर अपीलीय अिधकरण,राजकोट Ɋायपीठ, राजकोट। IN THE INCOME TAX APPELLATE TRIBUNAL, “SMC” RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER आ.(खो और ज).स. / IT(SS)A No.25/RJT/2024 Ǔनधा[रण वष[/Assessment Year : 2013-14 Shri Vallabhbhai Bhavanbhai Ambaliya Street No.6, New Thorala, Rajkot-360 003 बनाम/ Vs Assistant Commissioner of Income-tax, Central Circle-1, Rajkot, Aayakar Bhavan, Amruta Estate, 2nd Floor, M.G. Road, Rajkot-360 001 èथायीलेखासं./जीआइआरसं./PAN/GIR No.: ABXPA 4642 G (अपीलाथȸ/Appellant) (Ĥ×यथȸ/Respondent) Ǔनधा[ǐरती कȧ ओर से/Assessee by : Shri Mehul Ranpura, AR राजèव कȧ ओर से/Revenue by : Shri Dheeraj Kumr Gupta, Sr-DR सुनवाई कȧ तारȣख /Date of Hearing : 16/05/2025 घोषणा कȧ तारȣख /Date of Pronouncement : 20/05/2025 आदेश/Order Per Dr. Arjun Lal Saini, A.M Captioned appeal filed by the assessee, pertaining to Assessment Year 2013-14, is directed against the order passed under section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by Ld.Commissioner of Income-tax (Appeals)-11, Ahmedabad dated 21.03.2023, which in turn arises out of an order passed by Assessing Officer u/s 153C of the Act on 19.09.2021. 2. The grounds of appeal raised by the assessee are as follows: “1. The grounds of appeal mentioned hereunder are without prejudice to one another. 2. The learned Commissioner of Income-tax (Appeals)-11, Ahmedabad [CIT(A)] erred on facts as also in law in not appreciating the fact that the seized data/documents were found from the premises of third party, therefore, addition on IT(SS)A No. 25/Rjt/2024 A.Y 13-14 Vallabhbhai B. Ambaliya Page | 2 the basis of the said document cannot be made in the hands of the appellant u/s 153C of the Actin absence of any corroborative evidence. The AO may kindly be directed to delete the addition on this ground. 3. The ld. CIT(A) erred on fac as also in law in not deleting the addition mad on the basis of dumb data/documents stated to have been recovered from the premises of third party. The action o ld. CIT(A) in not allowing the ground of appeal is unjustified. The AO may kindly be directed to delete the addition. 4. The ld. CIT(A) erred on facts as also in law in confirming addition Rs.1,00,000/- being alleged unaccounted cash loan of Rs.1,00,000/- given to M/s Swastik Finance Corporation. The addition made is totally unwarranted and unjustified therefore deserves to be deleted and may kindly be deleted. 5. Your honour’s appellant craves leave to add, to amend, alter, or withdraw any or more grounds of appeal on or before the hearing of appeal.” 2. The appeal filed by the assessee before the Tribunal is barred by limitation of 545 days. The assessee moved a petition for condonation of delay requesting the Bench to condone the delay. The Ld. Counsel for the assessee explained the sufficient reasons stating that tax consultant of assessee received the order of Ld.CIT(A) in his e-mail and intimated same to his consultant, ultimately, consultant forgot to take action regarding order of Ld.CIT(A) for which the delay of 545 days has occurred. The Ld. Counsel for the assessee invited our attention to the affidavit filed by Shri Darshak Kamani, consultant of assessee, which is reproduced below: “1.That I am working as an accountant since last four years. 2.That Shri Vallabhbhai Bhavanbhai Ambaliya (PAN:ABXA4642G) is my relative and I used to give accounting & taxation related advise to him as per my best knowledge and understanding. 3. That I have been entrusted with the assignment related to income-tax assessment proceeding of Shri Vallabhbhai Bhavanbhai Ambaliya. The assessment in his case for AY 013-14 was finalized vide order u/s 153C r.w.s. 143(3) of the Income-tax Act, 1961 [hereinafter referred to as to the “Act”] dated 19.09.2021 assessing total income at Rs.2,28,442/- after making addition of Rs.1,00,000/- to the returned income of Rs.1,28,442/-. 4. That on receipt of assessment order, I have taken further advice of Chartered Accountant at Rajkot and as per his advice, I had managed to file appeal against the assessment order. In an appeal, Hon’ble Commissioner of Income-tax (Appeals)-11, IT(SS)A No. 25/Rjt/2024 A.Y 13-14 Vallabhbhai B. Ambaliya Page | 3 Ahmedabad vide order dated 21.03.2023 dismissed the appeal and consequently, addition made by the AO on the alleged ground of unexplained cash investment of Rs.1,00,000/- was upheld. 5. The above-stated order of Ld.CIT(A) was received on the registered email address of Shri Vallabhbhai Ambaliya, which was given to me for taking further course of action. However, trough oversight I forgot to take any action on the said order and also forgot to sent it to CA for filing further appeal. 6. Because of the circumstances as stated above, there has occurred delay in filing appeal before the Hon’ble Income-tax Appellate Tribunal. The delay in filing the appeal is not intentional but because of the inadvertent circumstances as stated above.” 4. On the other hand, Ld.Senior DR for the Revenue opposed the prayer of the assessee for condonation of delay and stated that delay should not be condoned on such flimsy reasons because it is the duty of the assessee to take care that the application should be filed and because of the carelessness of the assessee, the cost of Rs.10,000/- should be imposed on the assessee on account of negligence of the assessee. The Ld. Sr-DR also stated that assessee has failed to explain the sufficient cause for condonation of delay. Therefore, delay should not be condoned and appeal of assessee should be dismissed. 5. I have heard both the parties on the preliminary issue. I find that because of the mistake on the part of tax consultant, the assessee should not be penalized. I am of the considered view that assessee has explained sufficient cause and therefore delay needs to be condoned. 6. I am of the view that provisions of law have to be adhered strictly and that one cannot be allowed to act in leisure and make a mockery of enacted law, because law and provisions are laid down to benefit both sides of litigation. Be that as it may, we have to do justice and the Hon’ble Supreme Court in the case of Collector, Land Acquisition vs Mst. Katiji and others, reported in 167 ITR 471, (1988) SC 897) (7) observed as follows: “4. When substantial justice and technical considerations are pitted against each other, cause of substantial justice deserves to be preferred for the other side cannot IT(SS)A No. 25/Rjt/2024 A.Y 13-14 Vallabhbhai B. Ambaliya Page | 4 claim to have vested right in injustice being done because of a non- deliberate delay……...” 7. When we weigh these two aspects then the side of justice becomes heavier and casts a duty on us to deliver justice. I note that the reasons given in the affidavit for condonation of delay, was convincing, and the reason would constitute reasonable and sufficient cause for the delay in filing this appeal. Considering the above facts and circumstances of the case, as narrated above, I am of the considered opinion that in the interest of justice, the delay deserves to be condoned and appeal of the assessee should be decided on merits in accordance with law. Accordingly, I condone the delay and admit the appeal of the assessee to adjudicate on merit. 8. When this appeal was called out for hearing, Ld. Counsel for the assessee invited my attention towards the judgment of the Co-ordinate Bench of this Tribunal in group cases of Shri Keshavjibhai Ramjibhai Busa vs. ACIT CC-1, Rajkot in IT(SS)A Nos.35-36/RJT/2023, for assessment years 2017-18 and 2018-19, dated 28.06.2024, wherein the dumb data/document recovered from third party should not be used for addition, and unaccounted addition income from M/s Swastik Finance Corporation was deleted in the hands of assessee, as the Tribunal was not inclined to accept the contention of the Assessing Officer in any manner and hence the addition was deleted. 9. On the other hand, Learned Senior DR for the Revenue submitted that the issue is covered by the judgment of the Co-ordinate Bench of this Tribunal in group cases of Shri Keshavjibhai Ramjibhai Busa (supra). Therefore, he stated that the Bench may take the similar view as per the judgment of the Co-ordinate Bench of this Tribunal (supra). Nonetheless, the Ld.CIT-DR for the Revenue also relied on the findings of the Assessing Officer. IT(SS)A No. 25/Rjt/2024 A.Y 13-14 Vallabhbhai B. Ambaliya Page | 5 10. I have heard both the parties and carefully gone through the submissions put forth on behalf of the assessee. I do not take any other view then the view so taken by this Tribunal in the case of Shri Keshavjibhai Ramjibhai Busa (supra), wherein the detailed findings of the Tribunal is reproduced below: “18. 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. We note that assessment proceeding u/s 153C of the Act, was initiated by the assessing officer on the alleged ground of unaccounted cash interest receipt of Rs. 76,510/- on loan advanced by the assessee to M/s Swastik Finance Corporation in earlier years. We find that all the presumptions and assumptions are made solely on the basis of name “Keshubhai Busa” reflected in the loose papers seized from the possession of third party i.e., Shri Jayesh Donga. Therefore, there is no concrete evidence on the record, which proves that name reflected in the seized paper pertains to assessee’s name. There is no signature of the assessee on the seized papers. Further, it is not clear that on what basis i.e., seized document, the impugned addition of Rs. 76,510/- has been made, particularly when the seized material does not bear the signature and no other corroborative evidence was found by the search team, which indicates that there is an unaccounted cash interest receipt of Rs.76,510/-. Nowhere in the notice issued u/s 142(1) of the Act or in the show-cause notice, the assessing officer has provided, the relied upon document, which contains the noting of alleged cash loan. Therefore, addition made by the assessing officer without providing the primary data and confronting the same is totally against the principle of natural justice. 19. As regard the reliance placed by the assessing officer on the statement recorded from Shri Jayesh Donga as well as Shri Gunvant Bhadani (partner of Swastik Finance Corporation), we find that they have never stated in their statement that unaccounted cash loan has been accepted from the assessee. The statements recorded from the searched persons are generic, which does not throw light on the specific noting in the specific loose paper referred by assessing officer. Besides, during the course of assessment proceedings, the assessee has also requested for cross- examination of the deponent of statements, so as to enable the assessee to appraise with correct facts. The assessing officer however without providing the opportunity of cross-examination finalized the assessment proceeding. The ld Counsel for the assessee submitted before us that alleged statements of the deponent (Jayesh Donga and Gunvant Bhadani) relied upon by the assessing officer, were recorded behind the back of the assessee, and without allowing the cross-examination of assessee, either by the investigation wing or by the assessing officer. Therefore, such statements cannot be admissible as evidence against the assessee. Thus, it is abundantly clear that no opportunity of cross-examination was ever allowed to the assessee. We note that Hon'ble Supreme Court in the case of Andaman Timber Industries Vs. Commissioner of Central Excise Kolkata in Civil Appeal No.248 of 2006 held that in absence of cross-examination of parties, the assessment proceedings to j be quashed. Further, the Hon'ble Gujarat High Court in the case of Praful I Chunila Patel Vs. M.J. Makwana [236 1TR 832 (Guj)] and JCIT &Ors. Vs. George Willimson (Assam) Ltd. [258 ITR 126 (Guj)] has held that statement of third party cannot be relied upon without having any corroborative evidence. Similarly, Hon'ble Supreme Court in the IT(SS)A No. 25/Rjt/2024 A.Y 13-14 Vallabhbhai B. Ambaliya Page | 6 case of Kishanchand Chellaram V/s. CIT 125 ITR 713 (SC) has held that adverse inference cannot be drawn against the assessee from the statement of third parties. It is not clear from material on record as to how independently and impartially, the assessing officer could reach to the final conclusion to make addition in the hands of the assessee, without even bringing a single iota of any clinching evidence on record. Therefore, we find that assessing officer did not discharge his onus satisfactorily and entire addition was based on mere suspicion, conjunctures and surmises which have no place in tax jurisprudence. In sum and substance, action of the assessing officer is neither sustainable on facts nor in law on the basis of material available on record. 20. Moreover, in case the assessing officer wants to make reliance for making addition on the basis of the documents found during the course of search at 3rd party then presumption u/s 292C will not be available against the assessee. Such presumption, even in the case of the assessee in whose case the document has been found during the course search, is rebuttable. In view of the above, merely on the basis of alleged statement recorded from third party, action of the assessing officer to jump the conclusion by ignoring all other facts / surrounding circumstances is totally unjustified. Therefore, addition made by the assessing officer by taking cognizance on the statements recorded from Shri Jayesh Donga is totally bad in law. Further, it is also to be noted that the provision of Section 132(4A) of the Act, creates deeming fiction on the assessee, subjected to search, wherein it may be presumed that any such document found during the course of search from the possession or control of person searched belongs to such person and contents of such documents are true. However, in the case under consideration, it is an undisputed fact that the impugned loose papers were not found from the possession of assessee, but the same were found from the possession of third party, i.e., Shri Jayesh Donga / Swastik Finance Corporation. Also, that third party has nowhere claimed in his statement that the noting in the seized document is pertaining to or anyway related to the assessee. Therefore, noting made in such loose papers do not present a preponderance of probabilities so as to support the allegation of the assessing officer. While deciding the issue against the assessee, the assessing officer alleged that the searched person, namely Shri Jayesh Donga has clarified that the entries found in the diaries seized from his possession pertains to financing activities of M/s. Swastik Finance Corporation. In this connection, it is submitted that statement recorded from the deponent is binding to himself or his associated concern, but such statement cannot be made binding on assessee under consideration. Therefore, it may be correct that transactions in seized documents pertains to Swastik Finance Corporation, but it cannot be judged that counter party of such transaction is the assessee, in absence of any documentary evidence or the admission made by the deponent or cross-examination of such deponent. 21. We find that in the assessment order, the assessing officer further alleged that seized document contains details of transactions carried out by the assessee with Swastik Finance Corporation. Here, the assessing officer grossly failed in establishing live-link or nexus of the assessee with the impugned noting made by third party in the seized document recovered from his premises. The allegation of the assessing officer is merely name written on the seized diary of Jayesh Donga. However, this does not mean that there is only one person with the same name on this whole universe. This is completely guesswork of the assessing officer. Further, on perusal of the seized data, only a name, i.e., “Keshubhai Busa” is written. Apart from IT(SS)A No. 25/Rjt/2024 A.Y 13-14 Vallabhbhai B. Ambaliya Page | 7 that, not a single instance or evidence is correlated with the assessee. In this connection, ld Counsel for the assessee, vehemently submits that name appearing in the seized data is written or mentioned by the preparer of such data and the purpose / object / use of such name is best known to him. Therefore, the assessee cannot offer any comment on such name except that he is not the person who has carried out the transactions reflected under such name. In the assessment order, the assessing officer reproduced the statement recorded from Shri Jayesh Donga and on that basis, it is alleged that Shri Donga has given explanation on each entries in the seized documents. However, on verification of the statement reproduced by the assessing officer, nowhere the name of the assessee or transaction carried out by the assessee is visible. Therefore, statement relied upon by the assessing officer is of no use in the case of the assessee. Similarly, statement recorded from Shri Guvnant Bhadani reproduced in the assessment order does not throw any light on the allegation of the assessing officer in the case of the assessee. Therefore, such statement is also of no use in the assessee’s case and hence, reliance is placed on such statement is misplaced. We find that the assessee categorically submitted that he has not made any transactions (accounted or unaccounted) either with Shri Jayesh Donga or M/s. Swastik Finance Corporation. Further, in the statement recorded from the searched persons, they have not identified / recognized the assessee, as counter party of the transaction. No cross-examination of deponent of the statements have been allowed to the assessee. Also, there is no any documentary evidence or any type of corroborative material available with Department which shows that the assessee has made unaccounted cash advances to M/s Swastik Finance Corporation. There is no evidence which clearly demonstrate the cash exchanged the hands. 22. Therefore, it is not a case where the assessee had not submitted any documentary evidence, but on the contrary, the assessing officer failed to bring on record any documentary evidence or corroborative material in support of his allegation. The assessing officer alleged that Swastik Finance Corporation has filed an application before Hon’ble Income Tax Settlement Commission, wherein, they have offered additional income and taxes has been paid on the basis of these incriminating material. In this connection, it is submitted by the assessee that he has not been provided with the copy of settlement application filed by Swastik Finance Corporation and hence, no comments on such application can be made. Further, whatever additional income admitted and taxes paid by Swastik Finance Corporation may pertains to their case and hence, action taken by the assessing officer in the assessee’s case is not justified. We note that though the assessee has not made any unaccounted loans / advances, as alleged by the assessing officer, once the alleged transactions has already been considered by the author of seized document in its settlement application and once tax on such income has already been admitted / paid, there cannot be any addition in respect of same transactions in the hands of assessee as the same will tantamount to double effect, for that reliance can be placed on the decision of Hon’ble ITAT, Mumbai Bench in the case of DCIT vs. Shri Himmatlal Gopal Patel Senghani in ITA No. 688/Mum/2018 (CO No. 71/Mum/2019), order dated 11.12.2020, wherein, it was held as under: “5.2. From the aforesaid assessment order framed u/s 143(3) of the Act for the A.Y.2015-16 on 30.12/2016 in the hands of the Runwal Developers Pvt. Ltd., we find in para 8.6 reproduced supra that the Assessing Officer of Runwal Developers Pvt. Ltd., had given a categorical finding that Runwal Developers IT(SS)A No. 25/Rjt/2024 A.Y 13-14 Vallabhbhai B. Ambaliya Page | 8 Pvt. Ltd., had indeed made unaccounted cash payments of Rs.8.70 Crores to the assessee. Hence, the order of the Department itself explains the source of Rs.8.70 Crores for the assessee in respect of labour payments thereon by the assessee. Hence, there cannot be any addition that could be made in the hands of the assessee in the sum of Rs.8.70 Crores in the facts and circumstances of the instant case. We also find that both the assessee as well as Runwal Developers Pvt. Ltd., were assessed by the same Assessing Officer and by the same Circle namely DCIT, Central Circle 4(1), Mumbai. Accordingly, we have no hesitation in directing the ld. assessing officer to delete the addition made in the sum of Rs.8.70 Crores in the hands of the assessee.” 23. Conclusion: We note that assessing officer has not brought any corroborative evidence showing that the notings are related to the assessee except his name. The matching of name does not necessarily mean that there is only one person with the same name in this whole city/state/country. The third party has not identified that the name mentioned in the seized document is pertaining to the assessee. Further, there is no live-link. Thus, no addition can be made in case of assessee without establishing identity of the person mentioned in seized material. Reliance in this regard is placed on decision of Hon’ble Mumbai Tribunal in the case of Smt Neelam Nitin sankhe vs CIT(A) ITA NO. 3249/MUM/2022 (A.Y.2014-15). Third parties i.e. Jayeshbhai Donga and Gunvantrai Bhadani have never stated in their statement that unaccounted cash loan has been accepted from the assessee. There is no signature of the assessee on the seized documents. The assessing officer/Ld. CIT(A) themselves acknowledges that the searched party has not stated that the person mentioned in the seized material is of assessee. The assessing officer himself identified the assessee and has drawn adverse inference in case of assessee and that too without bringing any corroborative evidence on record and granting cross-examination. It is settled law that any additions made in absence of providing opportunity of cross examinations of persons, whose statement has been relied upon for making the additions is in violation of natural justice, hence cannot be sustained. The Hon'ble Supreme Court of India, in the case of Krishnachand Chelaram Vs. CIT 125 ITR 713 (SC) and Andaman Timber Industries Vs. Commissioner of Central Excise (2015) 281 CTR 0241 (SC) has held that additions without providing the opportunity of cross examination is in violation of natural justice. The assessee has not undertaken any transaction with Swastik Corporation or Jayesh Donga. The documents found in search action were dump documents. Therefore, based on the above facts and circumstances, we are not inclined to accept the contention of the Assessing Officer in any manner and hence the addition of Rs.76,510/- so made is deleted. Hence ground Nos.3 and 4 raised by the assessee, on merit, are allowed. 24. In the result, ground Nos. 3 and 4 raised by the assessee (in ITA No.35/Rjt/2023, are allowed. 25. As we have allowed ground Nos. 3 and 4, on merit, therefore all other issues on technical ground No.1 (153C satisfaction note), in the impugned assessment proceedings, are rendered academic and infructuous, hence we do not adjudicate. 26. Since, we have adjudicated the issue, on merit, in IT(SS)A No.35/Rjt/2023, for assessment year (AY) 2016-17, in the case of Shri Keshavibhai Ramjibhai Busa (lead case), similar issues, on merit, have been raised by other assessees in other captioned appeals namely, (IT(SS)A No. 36/Rjt/2023, IT(SS)A Nos. 86-87/Rjt/2023, IT(SS)A IT(SS)A No. 25/Rjt/2024 A.Y 13-14 Vallabhbhai B. Ambaliya Page | 9 Nos. 89-90/Rjt/2023, IT(SS)A Nos. 37/Rjt/2023, IT(SS)A No. 38/Rjt/2023, IT(SS)A No. 39/Rjt/2023, IT(SS)A No. 40/Rjt/2023 and IT(SS)A No. 91/Rjt/2023). The facts and issues involved in all these other appeals of different assessees are analogous to IT(SS)A No.35/Rjt/2023, for assessment year (AY) 2016-17, in the case of Shri Keshavibhai Ramjibhai Busa. Accordingly, our observations made in IT(SS)A No.35/Rjt/2023, for assessment year (AY) 2016-17, in the case of Shri Keshavibhai Ramjibhai Busa, shall apply mutatis mutandis to the aforesaid other appeals of assessees. For the parity of reasons, we allow the abovementioned other appeals of the assessees in terms of directions noted in IT(SS)A No.35/Rjt/2023, for assessment year (AY) 2016-17.” 11. Since the issue is squarely covered by the judgment of the Co-ordinate Bench of this Tribunal (IT(SS)A Nos. 86-87/Rjt/2023 in case of Shri Keshavjibhai Ramjibhai Busa) (supra) and Ld.Sr-DR for the Revenue is unable to controvert the finding of the Co-ordinate Bench of this Tribunal (supra). Therefore, respectfully following the binding precedent of the Co-ordinate Bench of this Tribunal in the case of Shri Keshavjibhai Ramjibhai Busa) (supra), I allow the grounds raised by the assessee. 12. In the result, the appeal of the assessee is allowed. Order pronounced in the open court on 20/05/2025. Sd/- (Dr. A.L. SAINI) लेखा सदÖय/ACCOUNTANT MEMBER राजकोट /Rajkot Ǒदनांक/ Date: 20/05/2025 DKP Outsourcing Sr.P.S आदेश कì ÿितिलिप अúेिषत/ Copy of the order forwarded to :  अपीलाथê/ The Appellant  ÿÂयथê/ The Respondent  आयकर आयुĉ/ CIT  आयकर आयुĉ(अपील)/ The CIT(A)  िवभागीय ÿितिनिध, आयकर अपीलीय आिधकरण, राजकोट/ DR, ITAT, RAJKOT  गाडªफाईल/ Guard File By order/आदेश से, // True Copy // सहायक पंजीकार आयकर अपीलȣय अͬधकरण, राजकोट "