�� ` ` in the income tax appellate tribunal ��d�� bench

आयकर अपीलीय अिधकरण,
ड’
अिधकरण, अहमदाबाद यायपीठ ‘ड
ड अहमदाबाद।
अहमदाबाद।
IN THE INCOME TAX APPELLATE TRIBUNAL
“D” BENCH, AHMEDABAD
BEFORE SHRI SHAILENDRA KUMAR YADAV, JUDICIAL MEMBER
AND SHRI N.S. SAINI, ACCOUNTANT MEMBER
ITA No.
AY
Appellant
Respondent
2315/Ahd/2010
2007-08
Shah Alloys Ltd.,
5/1, Shreeji House, 5th
Floor, B/h. M.J. Library,
Ashram Road, Ahmedabad
PAN : AADCS 0474 L
The JCIT,
Range-8,
Ahmedabad
2663/Ahd/2010
2007-08
Revenue
Assessee
3235/Ahd/2011
2008-09
Assessee
Revenue
CO No.
305/Ahd/2010
2007-08
Assessee
Revenue
(In ITA
No.2663/Ahd/2010)
Assessee(s) by :
Revenue by
:
Shri Anil R. Shah, AR
Shri B.L. Yadav, Sr. DR
सुनवाई क तारख/
/ D at e o f H e ari n g
:
1 0 / 0 3/ 2 01 5
घोषणा क तारख /Dat e o f Pro n o u n c em e n t :
27 / 03 / 20 1 5
आदे श/O R D E R
PER SHRI N.S. SAINI, ACCOUNTANT MEMBER:
ITA Nos. 2315/Ahd/2010 and 2663/Ahd/2010 are the cross
appeals filed by the assessee and Revenue respectively against the
order of the Commissioner of Income-tax (Appeals)-XIV, Ahmedabad
dated
14.06.2010
for
Assessment
Year
2007-08.
ITA
No.
3235/Ahd/2011 is the appeal filed by the assessee for Assessment
Year 2008-09 against the order of the Commissioner of Income-tax
(Appeals)-XIV, Ahmedabad dated 30.11.2011. CO No.305/Ahd/2010
is filed by the assessee for Assessment Year 2007-08.
2.
We first take up the appeals of the assessee.
ITA Nos. 2315, 2663/Ahd/ 2010
ITA 3235/Ahd 2011 & CO 305 Ahd 2010
Shah Alloys Ltd - AY 2007-08 & 08-09
-23.
The Authorized Representative of the assessee submitted that
the assessee has filed amended-cum-additional grounds of appeal for
Assessment Year 2007-08 vide its letter dated 17.01.2013 which
should be considered and decided by the Tribunal. The Departmental
Representative had no objection to admitting the amended-cumadditional grounds of appeal.
We, therefore, admit the amended-
cum-additional grounds of appeal of the assessee and adjudicate the
same as under:4.
The Ground No. 1 of the assessee’s appeal for Assessment Year
2007-08 is directed against the order of the CIT(A) confirming
disallowance of Rs.69,73,973/- out of interest paid on borrowings
disallowed by the Assessing Officer u/s 36(1)(iii) of the Act.
5.
The brief facts of the case are that on perusal of the Schedule
20 of the balance-sheet, the Assessing Officer observed that the
assessee
had
paid
Rs.11,96,81,912/-.
interest
on
working
capital
amounting
to
From the details furnished by the assessee, he
found that the assessee had advanced a sum of Rs.5,07,00,000/- to
various parties from whom no interest has been received/charged,
the details of which are as under:Sr.
No.
1
2
3
4
5
6
7
8
9
10
Name
Narendra S. Vohra
Harshadbhai M. Shah
Shreyanshbhai S. Shah
Aspass Investment Pvt Ltd
Anwesha Stock Trade Pvt Ltd
Nayanbhai G. Shah
Dilipbhai M. Gosalia
Kumudben D. SGosalia
Meenaben A Gosalia
Redwood Holding Pvt Ltd
Amount (Rs.)
50,000
20,000
41,53,973
2,00,000
2,00,000
1,00,000
15,000
20,000
15,000
2,00,000
69,73,973
Amount (Rs.)
5,00,000
2,00,000
4,25,00,000
20,00,000
20,00,000
10,00,000
1,50,000
2,00,000
1,15,000
20,00,000
5,07,00,000
ITA Nos. 2315, 2663/Ahd/ 2010
ITA 3235/Ahd 2011 & CO 305 Ahd 2010
Shah Alloys Ltd - AY 2007-08 & 08-09
-36.
The assessee submitted before the Assessing Officer that on a
similar background disallowance of interest was made by the
Assessing Officer on such advances and the matter was pending in
appeal before the CIT(A).
The Assessing Officer observed that
pending of appeal before the CIT(A) does not change the nature of
interest free advance to various parties and accordingly made
disallowance of interest of Rs.69,73,973/-.
7.
Before the CIT(A), it was argued that the Assessing Officer has
not proved the nexus between the utilization of borrowed funds by
the assessee for non-business purposes and therefore, the Assessing
Officer was not justified in making estimated disallowance of interest
@ 10% of the amount advanced as free of interest.
8.
The CIT(A), considering the submissions of the assessee,
observed that similar issue had come up for consideration in appeal
in Assessment Year 2005-06 where it was held that the Assessing
Officer has found that the assessee has diverted its interest bearing
funds for giving advances on which no interest has been charged. He
observed that when there was a direct nexus between the borrowed
funds and giving of interest free advance, it was irrelevant that the
assessee had sufficient interest free funds for making interest free
advance. The assessee had not established by giving evidences that
the
advances
were
given
for
business
purposes
or
for
any
commercial expediency. The CIT(A) observed that as the facts in the
year under appeal are identical to the facts of the Assessment Year
2005-06, the CIT(A) following the order of his predecessor for
Assessment Year 2005-06, confirmed the disallowance made by the
Assessing Officer.
9.
Before us, the Authorized Representative of the assessee
contended that it will be seen from page no.5 of the paper-book filed
ITA Nos. 2315, 2663/Ahd/ 2010
ITA 3235/Ahd 2011 & CO 305 Ahd 2010
Shah Alloys Ltd - AY 2007-08 & 08-09
-4by the assessee, which contain a chart showing own funds available
with the Company and shows that the assessee had own funds of
Rs.251.22 crores; whereas the interest free advances given by the
assessee was Rs.5.07 crores. Therefore, he relied on the decision of
Ahmedabad Bench of the Tribunal in the case of Torrent Financiers
vs. ACIT, reported in 73 TTJ 624 (Ahd) and the decision of the
Hon’ble Bombay High Court in the case of Reliance Utilities and
Power Ltd, reported in 313 ITR 340, wherein it was held that if there
were funds available both interest-free and over draft and/or loans
taken, then a presumption would arise that investments would be out
of the interest-free funds generated or available with the company if
the interest-free funds were sufficient to meet the investment.
He
also relied on the decision of the Hon’ble Supreme Court in the case
of Munjal Sales Corporation Vs CIT, reported in 298 ITR 298, wherein
it was held that since the opening balance of the profits of the
assessee-firm as on 1st April 1994 was Rs.1.91 crores, and the profits
were sufficient to cover the loan given to a sister concern of Rs.5
lakhs only, the Appellate Tribunal ought to have held that the loan
given was from the assessee’s own funds. Therefore, it was the
contention of the Authorized Representative of the assessee that as
the assessee’s own interest free funds available were to the tune of
Rs.251.22 crores and interest free advances given by the assessee
were Rs.5.07 crores, following the above decisions no disallowance of
interest could be made.
10.
On the other hand, the Departmental Representative supported
the order of the CIT(A).
11.
We find that in all the above three cases relied upon by the
Authorized Representative of the assessee, the disallowance was
made by the Assessing Officer without establishing nexus between
the interest bearing borrowed funds and interest free advance given
ITA Nos. 2315, 2663/Ahd/ 2010
ITA 3235/Ahd 2011 & CO 305 Ahd 2010
Shah Alloys Ltd - AY 2007-08 & 08-09
-5by the assessee. On the above facts, it was held by the courts that
when the interest free funds available with the assessee was more
than interest free advances given by the assessee, then it can be
presumed that interest free advances were given out of the interest
free funds available with the assessee and therefore, disallowance of
interest expenditure cannot be made.
However, in contradiction to
the facts of the above cases, in the instant case the CIT(A) has
recorded a finding to the effect that in the assessment of Assessment
Year 2005-06 the Assessing Officer has established a direct nexus
between the interest bearing loan taken by the assessee and the
interest free advance given by the assessee which was not for its
business purposes. The CIT(A) has followed its own order passed in
the case of the assessee in the Assessment Year 2005-06 for
confirming the disallowance made in the year under appeal.
The
Authorized Representative of the assessee has brought no material to
controvert the above findings of the CIT(A).
The Departmental
Representative also could not bring any material before us to show
that the finding of the CIT(A)
in the case of the assessee in the
Assessment Year 2005-06 was reversed in an appeal by any higher
authority.
In the above circumstances, we do not find any good
reason to interfere with the order of the CIT(A) which is hereby
confirmed and this ground of the appeal of the assessee is dismissed.
12.
Ground No.2 of the assessee’s appeal in Assessment Year
2007-08 and Ground No.1 of the assessee’s appeal in Assessment
Year 2008-09 are directed against the order of the CIT(A) confirming
the disallowance of expenditure of Rs.1,06,45,775/- in Assessment
Year 2007-08 and Rs.2,04,30,869/- in Assessment Year 2008-09 u/s
14A of the Act read with Rule 8D of the IT Rules.
ITA Nos. 2315, 2663/Ahd/ 2010
ITA 3235/Ahd 2011 & CO 305 Ahd 2010
Shah Alloys Ltd - AY 2007-08 & 08-09
-613.
The brief facts of the case are that the Assessing Officer
observed that the assessee had made huge investments in financial
instruments from which the income generated do not form part of
the total income.
On reply to the show-cause notice, the assessee
explained that it has not incurred any expenditure to earn nontaxable income and interest paid on borrowed funds was on the
amounts utilized by the assessee for the business of the assessee. In
the alternative, it was also submitted that as disallowance of
Rs.69,73,973/- out of interest expenditure was made by the
Assessing Officer, no further disallowance should be made u/s 14A of
the Act. The Assessing Officer held that the disallowance of
expenditure relating to exempt income was required to be made u/s
14A read with Rule 8D and accordingly, made a disallowance of
Rs.1,60,45,775/-
in
the
Assessment
Year
2007-08
and
Rs.2,04,30,869/- in the Assessment Year 2008-09.
14.
On appeal, the CIT(A) observed that the Assessing Officer,
after giving opportunity to the assessee to furnish the details
alongwith supporting documents, has rejected the working given by
the assessee. He observed that the Special Bench of the Tribunal in
the case of M/s Daga Capital Management Pvt Ltd and others vide
order dated 20.10.2008 has held that the Assessing Officer is bound
to adopt Rule 8D for making disallowance u/s 14A, where he is not
satisfied with the correctness of the claim of the assessee in respect
of such expenditure. Therefore, the disallowance made by the
Assessing Officer as per Rule 8D under section 14A was justified.
Further, the CIT(A) observed that the contention of the assessee that
as interest disallowance was made by the Assessing Officer on
account of funds not used for business purpose and therefore, no
disallowance should be made u/s 14A of the Act, he was not in
agreement with the contention of the assessee as it was not
ITA Nos. 2315, 2663/Ahd/ 2010
ITA 3235/Ahd 2011 & CO 305 Ahd 2010
Shah Alloys Ltd - AY 2007-08 & 08-09
-7mentioned in Rule 8D that such adjustment has to be made before
computing the disallowance.
15.
Before us, the Authorized Representative of the assessee
contended that it will be seen from page No.11, 12 and 13 of the
paper-book filed for the Assessment Year 2007-08 that the assessee
had not claimed any income as exempt from tax. Further, referring
to page nos. 27 and 28 of the paper-book, he pointed out that it will
be seen from the computation of income and the copy of the Return
of Income filed for the Assessment Year 2008-09 that the assessee
has not claimed any exempt income. He submitted that the Hon’ble
Gujarat High Court in the case of CIT vs. Corrtech Energy (P) Ltd,
reported in (2014) 272 CTR 262 (Guj.)(HC), has held that where the
assessee has not made any claim for exemption of any income from
payment of tax, no disallowance could be made u/s 14A of the Act.
Therefore, he submitted that no disallowance u/s 14A could be made
in view of the decision of the Hon’ble Gujarat High Court.
16.
The Departmental Representative, on the other hand, relied
upon the orders of the lower authorities.
17.
We have heard the rival submissions and perused the material
available on record. In the instant case, disallowance of expenditure
u/s 14A read with Rule 8D of Rs.1,06,45,775/- in Assessment Year
2007-08 and Rs.2,04,30,869/- in Assessment Year 2008-09 was
made
by
the
Assessing
Officer
as
the
assessee
had
made
investments, income from which was exempt from tax. The same
was confirmed in appeal by the CIT(A) by following the order of
Mumbai Special Bench of the tribunal in the case of M/s.Daga Capital
Management Pvt. Ltd. (supra) wherein it was held that the AO was
bound to adopt Rule 8D for making disallowance under section 14A
where he is not satisfied with the correctness of the claim of the
ITA Nos. 2315, 2663/Ahd/ 2010
ITA 3235/Ahd 2011 & CO 305 Ahd 2010
Shah Alloys Ltd - AY 2007-08 & 08-09
-8assessee
in
respect
of
such
expenditure,
and
therefore,
the
disallowance made by the AO, as per Rule 8D under section 14A was
justified. The Authorized Representative of the assessee has pointed
out from page nos. 11 to 13 of the paper-book for Assessment Year
2007-08 that the assessee had not claimed any income as exempt
from tax. He has also pointed out from page nos. 27 and 28 of the
paper-book for Assessment Year 2008-09 that no income was
claimed as exempt by the assessee in its Return of Income. The
Authorized Representative of the assessee has relied on the decision
of the Hon’ble Gujarat High Court in the case of
CIT vs. Corrtech
Energy (P) Ltd, reported in (2014) 272 CTR 262 (Guj.)(HC), wherein
it has been held that where the assessee has not made any claim for
exemption of any income from payment of tax, no disallowance could
be made u/s 14A of the Act. The Departmental Representative has
not disputed the submission of the assessee that during the
assessment years under consideration the assessee has not claimed
any income as exempt from tax in its Return of Income filed.
Therefore, respectfully following the decision of Hon’ble Gujarat High
Court in the case of Corrtech Energy (P) Ltd (supra), we delete the
disallowance of expenditure made u/s 14A read with Rule 8D of
Rs.1,60,45,775/-
in
the
Assessment
Year
2007-08
Rs.2,04,30,869/- in the Assessment Year 2008-09.
and
Thus, this
ground of appeal of the assessee is allowed in both the years under
appeal.
18.
Ground No.3 of the assessee’s appeal for Assessment Year
2007-08 is directed against the order of the CIT(A) upholding levy of
interest u/s 234 of the Act.
19.
At the time of hearing, no submissions were made by the
Authorized Representative of the assessee on this ground of appeal
taken in the appeal. Therefore, we hold that charging of interest is
ITA Nos. 2315, 2663/Ahd/ 2010
ITA 3235/Ahd 2011 & CO 305 Ahd 2010
Shah Alloys Ltd - AY 2007-08 & 08-09
-9consequential and accordingly dispose of this ground of appeal of the
assessee.
20.
Ground No.2 of the assessee’s appeal in Assessment Year
2008-09 is directed against the order of the CIT(A) in confirming
addition of Rs.30,46,655/- being income of prior period.
21.
Ground No.3 of the assessee’s appeal for Assessment Year
2008-09 is directed against the order of the CIT(A) on the ground
that the disallowance made by the Assessing Officer already takes
care of taxability of prior period of income of Rs.30,46,655/- as
income of the year under consideration and hence, enhancement of
the income of the assessee by the very same amount resulted into
double taxation which was against the principle of natural justice.
22.
The brief facts of the case are that the Assessing Officer
observed from the statement of total income that the assessee has
added back prior period expenses amounting to Rs.1,57,11,364/-.
He observed that the assessee-company had shown prior period
expenses at Rs.1,87,58,019/- out of which the assessee reduced an
amount of Rs.30,46,655/- stating it to be credit entries. The
Assessing Officer observed that, as the assessee was following
mercantile system of accounting, it had not been able to prove that
the said liability was crystallized during the year and therefore, the
claim of the assessee with regard to netting of prior period expenses
with prior period income was not acceptable; and accordingly made
addition of Rs.30,46,655/- to the income of the assessee.
23.
On appeal, the CIT(A) observed that the assessee had some
expenses that pertained to prior period and similarly, there were
some income which pertained to earlier years. The assessee reduced
the prior period expenditure by the amount of prior period income
ITA Nos. 2315, 2663/Ahd/ 2010
ITA 3235/Ahd 2011 & CO 305 Ahd 2010
Shah Alloys Ltd - AY 2007-08 & 08-09
- 10 and the net disallowance was made in the statement of income. The
Assessing Officer did not accept the claim of the assessee and made
addition of an amount equal to prior period expense that has been
reduced by the assessee. The assessee submitted that the income
and expenses of prior period cannot be given different treatment for
taxation. If the expenses of prior period was disallowed, the income
of the earlier period cannot be taxed. The CIT(A) has observed that
the submission of the assessee was not acceptable. It was clear that
the expenses pertained to the previous assessment year and the
expenses are to be allowed only on matching principle and therefore,
the same cannot be allowed as deduction from the current year’s
income.
The action of the assessee by reducing it from the prior
period’s income and disallowing the net prior period expenses was
not correct. The income has to be considered separately and cannot
be set off against prior period expenses. Therefore, he confirmed the
action of the Assessing Officer.
24.
We have heard rival submissions and perused the orders of the
lower authorities and material available on record. The undisputed
facts of the case are that the assessee added Rs.1,57,11,364/-as net
prior period expenses debited in profit & loss account in computing
its total income. The AO observed that net prior period expenses of
Rs.1,57,11,364/- is comprised of two elements viz. prior expenses of
Rs.1,87,58,019/According
to
and
the
prior
AO,
the
period
entire
income
prior
of
Rs.30,46,655/-.
period
expenses
of
Rs.1,87,58,019/- is not allowable to the assessee as deduction, as
the assessee’s system of accounting is mercantile.
He, therefore,
added the entire Rs.1,87,58,019/- in place of Rs.1,57,11,364/added by the assessee, and thus enhanced the assessee’s income by
Rs.30,46,655/-.
25.
On appeal, the CIT(A) confirmed the action of the AO.
ITA Nos. 2315, 2663/Ahd/ 2010
ITA 3235/Ahd 2011 & CO 305 Ahd 2010
Shah Alloys Ltd - AY 2007-08 & 08-09
- 11 -
26.
We find that it is not in dispute that Rs.30,46,655/- was
income of prior period. In our considered view, on the same analogy
on which expenses of prior period is not allowable, the income of
prior period also cannot be brought to tax for the year under
consideration.
The lower authorities in the garb of disallowance of
gross amount of prior period expenses, has in fact brought to tax
prior period income for the year under consideration. No material has
been brought before us to show that how and why the prior period
income of Rs.30,46,655/- is taxable in the year under consideration,
when the system of accounting of the assessee is mercantile.
Therefore, in our considered view, when the gross amount of prior
period expenses added to the income of the assessee, then lower
authorities
could
have
also
reduced
prior
period
income
of
Rs.30,46,655/- for computing the total income of the year under
consideration.
We,
therefore,
delete
the
disallowance
of
Rs.30,46,655/- and allow the grounds of the appeal of the assessee.
27.
Ground No.4 of the assessee’s appeal for Assessment Year
2008-09 is directed against the order of the CIT(A) in confirming adhoc disallowance of Rs.4,00,000/- out of interest paid.
28.
The brief facts of the case are that the Assessing Officer
observed that from the perusal of the Schedule 20 of the balancesheet, that the assessee had paid interest on working capital
amounting to Rs.18,86,80,017/-. The Assessing Officer required the
assessee to provide details of interest payments and advances made.
From the details, he found that the advances made to following
parties were for capital expenditure or otherwise there was no
business expediency and justification.
ITA Nos. 2315, 2663/Ahd/ 2010
ITA 3235/Ahd 2011 & CO 305 Ahd 2010
Shah Alloys Ltd - AY 2007-08 & 08-09
- 12 Sr.
No.
1
2
3
4
5
Name
Amount
Atulbhai P. P. (Advance for Land)
Chandrikaben Chudasma (Adv for land)
Dipti Deepakbhai Shah
Naynaben Girishkumar Shah
Sunderdeep Builders (Advance for land)
Total
500000
500000
400000
1000000
1600000
4000000
Therefore, the Assessing Officer made disallowance for interest
@ 10% of the amount advanced and made an addition of
Rs.4,00,000/- to the income of the assessee.
29.
On appeal, the CIT(A) held that in the earlier assessment year
2007-08 also similar disallowance was made by the Assessing Officer
and confirmed the same by his predecessor. Therefore, following the
same, he confirmed the addition made by the Assessing Officer.
30.
Before us, the Authorized Representative of the assessee
submitted that since these advances were made out of interest free
own
funds
of
the
assessee, no disallowance was
warranted.
However, no material could be brought before us by the AR to
substantiate the above addition.
31.
We find that the CIT(A) has confirmed the disallowance by
following order of his predecessor passed in the case of the assessee
itself in the immediately preceding year. The AR brought no material
to controvert the above findings of the CIT(A) or to show that this
order of the CIT(A) passed in the immediately preceding year was
reversed by any higher authority.
Therefore, we do not find any
good reason to interfere with the order of the CIT(A), which is
confirmed and the ground of the appeal of the assessee is dismissed.
32.
Now we take up Revenue’s appeal
ITA Nos. 2315, 2663/Ahd/ 2010
ITA 3235/Ahd 2011 & CO 305 Ahd 2010
Shah Alloys Ltd - AY 2007-08 & 08-09
- 13 33.
Ground No.1 of the Revenue’s appeal for Assessment Year
2007-08 is directed against the order of the CIT(A) deleting the
addition of Rs.73,623/- made u/s 41(1) of the Act.
34.
The brief facts of the case are that the Assessing Officer asked
the assessee to furnish the ageing analysis of the sundry creditors
having outstanding credit balance for the last 3 years. He observed
from the details furnished by the assessee that an amount of
Rs.73,623/- was still outstanding as on 31.03.2009.
Since the
amount was payable even after the lapse of more than 5 years, the
Assessing Officer treated the same as income as per the provisions of
Section 41(1) of the Act.
35.
On appeal, the CIT(A) observed that the Assessing Officer has
not brought out any material to show that the assessee derived any
money or benefit or otherwise such liability ceased and held that the
Assessing Officer was not justified in making such addition u/s 41(1)
of the Act.
36.
The DR simply relied upon the order of the AO and could not
point out any error in the order of the CIT(A). In the absence of any
material to show that the liability in question ceased to exist during
the year under consideration or any benefit was received by the
assessee during the year under consideration, we find no error in the
order of the CIT(A), which is confirmed, and the ground appeal of the
Revenue is dismissed.
37.
Ground No.2 of the Revenue’s appeal in Assessment Year
2007-08 is directed against the order of the CIT(A) in restricting the
disallowance u/s 14A to the extent of Rs.1,19,02,280/- as against
total disallowance of Rs.1,60,46,775/- made by the Assessing Officer.
ITA Nos. 2315, 2663/Ahd/ 2010
ITA 3235/Ahd 2011 & CO 305 Ahd 2010
Shah Alloys Ltd - AY 2007-08 & 08-09
- 14 38.
In view of our decision in Ground No.2 of the assessee’s appeal
in Assessment Year 2007-08, this ground of appeal of the Revenue is
dismissed.
39.
Since the Cross objection filed by the assessee is in support of
the order of the CIT(A) and as there was no grievance of the
assessee against the order of the CIT(A) in the cross objections filed
by the assessee, the same is infructuous and hence dismissed.
40.
In the result, appeals of the assessee for the Asstt.Year 2007-
08 and 2008-09 are partly allowed and the appeal of the Revenue for
the Asstt.Year 2007-08 is dismissed.
The Cross Appeal of the
assessee is dismissed.
Order pronounced in the Court on Friday, the 27th of March, 2015 at
Ahmedabad.
Sd/-
(SHAILENDRA KUMAR YADAV)
JUDICIAL MEMBER
Ahmedabad;
Sd/-
( N.S. SAINI)
ACCOUNTANT MEMBER
Dated 27/03/2015
*Biju T, PS
आदे श क ूितिल'प अमे'षत/Copy
of the Order forwarded to :
षत
1.
अपीलाथ* / The Appellant
2.
ू+यथ* / The Respondent.
3.
संबंिधत आयकर आयु- / Concerned CIT
4.
आयकर आयु-(अपील) / The CIT(A)- XIV, Ahmedabad
5.
'वभागीय ूितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad
6.
गाड2 फाईल / Guard file.
आदे शानुसार/ BY ORDER,
//TRUE COPY//
उप/
उप/सहायक पंजीकार (Dy./Asstt.Registrar)
आयकर अपीलीय अिधकरण,
अिधकरण, अहमदाबाद / ITAT, Ahmedabad

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