INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH "C": NEW DELHI
BEFORE SHRI J.S.REDDY, ACCOUNTANT MEMBER
AND
SHRI A. T. VARKEY, JUDICIAL MEMBER
ITA No. 2262/Del/2011(Assessment Year: 2001-02)
ITA No. 2263/Del/2011(Assessment Year: 2003-04)
ACIT, Gillette Diversified Operations Pvt . Ltd.
Circle-12(1), 34, Okhla Industrial Estate,
New Delhi Vs. New Delhi
(Appellant) (Respondent)
ITA No. 1475/Del/2011
(Assessment Year: 2001-02)
Gillette Diversified ACIT,
Operations Pvt . Ltd. Circle-12(1),
34, Okhla Industrial Estate, Vs. New Delhi
New Delhi
(Appellant) (Respondent)
Appellant by : Shri R. S. Gill, CIT DR
Respondent by : Sh. Pradeep Dinodia, CA
Date of Hearing 29.12.2014
Date of pronouncement 26.03.2015
ORDER
PER A. T. VARKEY, JUDICIAL MEMBER
The revenue and the assessee is in cross-appeals against the order of
the ld CIT(A), XV, New Delhi dated 21.12.2011 for Assessment Year 2001-02.
The revenue is also in appeal against the order for Assessment Year 2003-04.
First of all we take up the revenue's appeal for Assessment Year 2001-02.
"1. On the facts and circumstances of the case and in law, the Ld.
CIT(A) has erred in deleting the disallowance of interest expenditure of
Rs. 43,87,500/- on account of notional interest cost made by the AO."
2. The facts in brief are that the assessee company is engaged in the
manufacture and sale of tooth brushes, dealing in Small Electrical
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appliances, trading and export of blades, razors, kitchen machines and
accessories. The assessee filed the return of income declaring a loss of Rs.
58,50,006/-. The case was processed u/s. 143(1) of the Income Tax Act, 1961
(herein after `the Act') on 06.06.2002. The case was later selected for scrutiny
and the notice u/s. 143(2) of the Act dated 28.10.2002 was served on the
assessee on 29.10.2002. After considering the submissions by the AR of the
assessee, the AO completed the assessment u/s. 143(3) of the Act vide his
order dated 29.3.2004 and made various additions.
3. Being aggrieved with the assessment order dated 29.3.2004, assessee
appealed before the Ld. CIT(A), who vide impugned order dated 21.2.2011
has deleted the addition by partly allowing the appeal of the Assessee.
4. Now the Revenue is aggrieved against the impugned order and filed
the present appeal before the Tribunal.
5. At the time of hearing Ld. CIT DR Sh. R. S. Gill relied upon the order of
the AO and reiterated the contentions raised by the Revenue in the grounds
of appeal and stated that the Appeal of the Revenue may be allowed.
6. On the other hand Ld. AR of the assessee Sh. Pradeep Dinodia relied
upon the order of the Ld. CIT(A) and stated that the same may be upheld.
7. We have heard both the parties and perused and considered the
relevant records available with us, especially the orders passed by the
Revenue Authorities. We find that Ld. First Appellate Authority has observed
that the AO vide his order in para 6.2 has held that the assessee was incurring
extra expenditure on interest to group company Gillette Group of India Pvt.
Ltd. by extending credit facility in respect of sales to them. According to the
AO, the credit period facility beyond three month was unreasonable and
accordingly he disallowed on estimate basis a sum of Rs.43,87,500/- being
65% of Rs. 45 crores for 1.5 months @12% per annum. The ld. CIT(A) observed
that the assessee had filed before the AO various distribution agreements
with Gillette Group of India Ltd. (formerly known as Indian Shaving Products
Ltd.). And the assessee had consistently maintained that the credit facility
was in the normal course of business with the distributor and no nexus
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whatsoever has been established by the AO u/s. 36(1)(iii) for the use of
interest bearing funds for non business purposes. According to the Assessee it
is not for the AO to decide as to how the assessee should run its business; and
how much credit facility should be granted in respect of sales made to the
distributors in the ordinary course of business which is in the exclusive domain
of the assessee and the AO erred on this account. The ld DR could not
dispute before us that the credit facility extended by the assessee is only in
respect of sales made to the distributor in the ordinary course of business. In
the assessment order AO could not rebut this claim of the assessee. The ld
CIT(A) has rightly relied on the decision of the Hon'ble Apex Court decision in
the case of the SA Builders ltd. Vs. CIT (2007) 288 ITR 1 (SC), wherein it has held
that "once it is established that there was nexus between the expenditure
and purpose of the business (which need not necessarily be the business of
the assessee itself) the revenue cannot justifiably claim to put itself in the arm
chair of the businessman or in the position of board of directors and assume
the role to decide how much is reasonable expenditure having regard to
the circumstances of the case. No business can be compelled to maximize
his profits." We concur with the finding of the ld. CIT(A) that a perusal of the
agreements which were also filed before the AO would show that all the
agreements are executed in the normal course of business of the assessee
company. And these are not diversification of interest bearing funds to sister
concern without interest. And the ld CIT(A) has rightly noted that the recovery
through ISPL is done in the normal course and, therefore, no notional interest,
whatsoever, should have been calculated thereon for disallowance. We find
that the assessee had submitted before the Ld. CIT(A) that no nexus has
been established by the AO between the interest bearing funds used for non
business purposes or diverted to associate concern, without interest and has
relied on CIT vs. Dalmia Cement Pvt Ltd. 121 Taxman 706 (Del), Madhav
Prasad Jatia vs. CIT 118 ITR 200 (SC), CIT vs. Sahni Silk Mills Pvt. Ltd. (2002) 253
ITR 294 (Del.), CIT vs. Orissa Cement (2003) 260 ITR 626 (Del), CIT vs. Tin Box
Company (2009) 260 ITR 637 (Del.),
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8. We find that the advances were made by the assessee during the
regular course of business. And the advances were in the nature of credit
facilities and the impugned advances were in the nature of the business
advances and were not bearing any interest. The AO had disallowed the
interest on notional basis only. We find that ld. CIT(A) has rightly held that
since these advances were not bearing any interest, the disallowance of
interest made by the AO on notional basis is not in accordance to law. Since
the assessee had interest free funds of Rs. 47.50 crores in excess of the
business advances, hence, in view of the Hon'ble Apex Court decision in the
case of SA Builders (Supra) wherein it was held that where an advance is
made for business purpose and commercial expediency no disallowance on
account of interest can be made, therefore, Ld. CIT(A) has rightly deleted the
addition on this account. In view of the above, we are of the view that no
interference is called for in the well reasoned order passed by the Ld. CIT(A),
hence, we uphold the same by dismissing the appeal filed by the Revenue.
9. In the result, the Appeal filed by the Revenue stands dismissed.
ASSESSEE'S APPEAL ITA NO. 1475/DEL/2011 (AY 2001-02)
10. Next let us take up the appeal preferred by the assessee against the
impugned order dated 21/2/2011 passed by the Ld. Commissioner of
Income Tax (Appeals)-XV, New Delhi on the following grounds:-
"1.0 On the facts and circumstances of the case, the Ld. CIT(A) has
erred in law in sustaining the disallowance of Rs. 13,57,45,000/- on
account of technical advisory fees, on wholly erroneous, illegal and
untenable grounds.
1.1. In the alternative and without prejudice to the above, the Ld.
CIT(A) has failed to allow depreciation thereon being expenditure of
capital nature eligible for depreciation u/s. 32(1) of the I.T. Act, 1961.
2.0 That the Ld. CIT(A) has erred in law and on facts in sustaining the
disallowance of Rs. 70,00,000/- on account of excise duty payment
deductible u/s 43B of the I.T. Act, on wholly erroneous, illegal and
untenable grounds.
3.0 That each ground is independent of and without prejudice to
the other grounds raised herein.
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11. The first grounds and 1.1 of appeal is regarding the contention of the
appellant that the ld CIT(A) had erred in disallowing an amount of
Rs.13,57,45,000/- which was claimed on account of payment of "technical
advisory fees" or in the alternative grant "depreciation" u/s 32(1) of the Act.
12. The facts in brief are that the assessee company is engaged in the
manufacture and sale of tooth brushes, dealing in Small Electrical
appliances, trading and export of blades, razors, kitchen machines and
accessories.
13. The assessee acquired movable and tangible assets of SISL vide
agreement dated 25.11.1998 for a consideration of Rs.3.5 crores and
immoveable properties vide agreement dated 02.03.1999 for a consideration
of Rs.6 crores. The rights in GEEP brand was acquired by M/s. Wilkinson Sword
India Ltd., a group concern of the assessee vide agreement dated 25.11.1998
for a consideration of Rs.55 crores. The assessee was manufacturing GEEP
brand products for Wilkinson Sword. It entered into an agreement with SISL on
10.4.2000.The assessee claimed expenditure of an amount of Rs.13,57,45,000/-
on account of payment of "Technical advisory Fees" to M/s Shervani
Industrial Syndicate (SSIL). According to the AO the assessee has not been
able to bring anything to the record to prove that the above company has
rendered any services.
14. In view of the above observations the AO has held that the onus was
on the appellant to prove the claim of expenditure and since the appellant
had failed to provide any evidences regarding the receiving of technical
advisory services, the expenditure on technical advisory fees claimed by the
appellant was disallowed vide his order dated 29.03.2004.
15. Being aggrieved with the assessment order dated 29.3.2004, assessee
appealed before the Ld. CIT(A), who vide impugned order dated 21.2.2011
has dismissed the said ground without giving any finding on the alternate
plea to consider depreciation u/s 32(1) of the Act.
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16. Now the Assessee is aggrieved against the impugned order and filed
the present appeal before the Tribunal.
17. At the time of hearing Ld. DR relied upon the order of the Revenue
Authorities and stated that the Appeal of the Assessee may be dismissed
18. On the other hand Ld. Counsel of the assessee controverted the
arguments made by the Ld. DR and stated that the Appeal of the Assessee
may be allowed.
19. We have heard both the parties and perused and considered the
relevant records available with us, we find that the assessee acquired
movable and intangible assets of M/s. SSIL in Assessment Year 1998-99 vide
agreement dated 25.111998 and 02.03.1999 for a total consideration of Rs.9.5
crores. The assessee was manufacturing GEEP Brand products Zinc (Batteries)
Wilkinson Sword from the said unit acquired (M/s. SSIL) and since the assessee
does not have the expertise to manufacture Zinc Batteries it has sourced the
same from M/s. SSIL for which the assessee has agreed and have claimed to
have made the payment for which it claimed expenditure.
20. We find that the assessee claimed an expenditure of Rs.13,57,45,000/-
under the Head "Technical and Advisory Fees". This "Technical and Advisory
Fees' has been claimed to be paid to M/S SISL under three agreements. In
the first agreement dated 13th April 2000, and is for the period 1st January
2000 to 31st December 2000 and total consideration is Rs.7 crores. The other
two agreements are dated 4th January 2001 and 15th February 2001 and are
for the period 1st January 2001 up to 31st December 2001 and the total
consideration under the two agreement is Rs.8.77 crores. Thus apparently
assessee could have claimed an expenditure of Rs. 7 crores + (¼ of Rs.8.77
crores) i.e. Rs.2.19 crores and as such the claim at best can be considered of
Rs.9.19 crores and the remaining is per-se not maintainable. Even with respect
to this expenditure, we find that despite a number of opportunities provided
by the AO and the ld CIT(A), the assessee has not been able to substantiate
on the basis of evidences as to what type of advisory services were provided
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to the assessee for which such payment had been made. The AO had clearly
brought on record after examining the agreement that no services had been
rendered by M/s SSIL to the assessee. We also find that during the appellate
proceedings also no evidence have been brought on record by the assessee
regarding the nature of services provided for which the payment had been
made. Hence, ld CIT(A) has rightly observed that the onus is on the assessee
to substantiate on the basis of evidences regarding business expenditure
which has been claimed u/s 37(1). This onus has not been discharged by the
assessee. We note that ld CIT(A) has rightly held that in the absence of any
evidences on record regarding the nature of services provided for which the
above expenditure has been incurred, the disallowance made by the AO is
as per law, hence, the ld CIT(A) has rightly dismissed this ground of appeal. In
view of the above we are of the view that no interference is called for in the
impugned order passed by the ld CIT(A), hence we uphold the same by
rejecting this ground of appeal as raised by the assessee in respect of
"Technical Advisory Fees" which amounts to Rs.7 crores and we confirm
disallowance of Rs.7 crores because assessee failed to substantiate its claim.
21. As regards the ground No.1.1 is concerned we would like to examine
the contention of the assessee that in the alternative, the ld CIT(A) erred not
to have allowed depreciation thereon being expenditure of capital nature
eligible for depreciation u/s 32(1) of the Act for which we have to look into
the relevant clauses of agreements.
22. The first agreement dated 10th April 2000 provides under clause 2 as
under:-
"2. PROVISION OF TECHNICAL SERVICES
2.1 SISL agrees to divulge and impart to GDOL all Technical Advisory
Services necessary for GDOL's existing manufacturing facilities.
2.2 All the Technical Advisory Services agreed to be divulged and
imparted to GDOL shall be subject to confidentiality terms
provided in Clause 5 hereof.
2.3 SISL will provide to GDOL all such Technical Advisory Services as
may reasonably be required by GDOL to draw up plans for
GDOL's manufacturing facilities in relation to the manufacture of
the Products.
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2.4 The Parties will jointly use their best efforts to ensure that GDOL
absorbs the Technical Advisory Services fully and speedily and
that the Products manufactured by GDOL properly utilize the
advice disclosed and imparted by SISL pursuant to this
Agreement.
2.5 SISL shall furthermore provide to GDOL the ongoing Technical
Advisory services set out in the Schedule hereto and shall advise
assist GDOL in the correct interpretation of the Technical
Advisory Services Documentation, if any."
23. Further agreement dated 04th January 2001 is akin to the agreement
dated 10th April 2000 but for the later period. However clause 2 of
supplement agreement dated 15th February 2001 provides as under:-
"C. By a Technical Advisory Services Agreement dated January 4th
2001 (hereinafter the "Agreement") entered between the parties
hereto, the parties have agreed to certain terms and conditions
as set out therein; and
D. The parties, being desirous of introducing a new technology to
produce "No Mercury Added" product, have reached certain
agreements supplemental to the Agreement dated January 4th
2001 as set forth hereinafter.
E. GDOL is desirous of introducing the latest technology for
production of "No Mercury Added" products.
1. THAT this Supplemental Agreement will be read in conjunction
with the Agreement dated January 4th, 2001.
2. THAT SISL has agreed to provide to GDOL technical know-how
and technical assistance in respect of manufacture of "No
Mercury Added" R20 batteries. It is agreed that SISL' s assistance
in this regard will include the following:
a. To advise GDOL to upgrade modify the manufacturing
processes to enable the Factory to produce "No Mercury
Added" R20 batteries.
b. To provide specifications for the manufacture and
development of new product for developing a "No
Mercury Added" product for R20 batteries.
c. To advise on all miscellaneous issues arising from the
aforementioned process."
24. From a perusal of the above agreement between the assessee and
the M/s. SSIL which is in conjunction with agreement dated 04.01.2001 which
terms and conditions as stated above are akin to that of agreement dated
10.04.2000 reproduced above. We find that vide the agreement dated
15.02.2001 read with 04.01.2001, M/s. SSIL has agreed to assessee that it will
provide "Technical know-how" and Technical Assistance in respect of
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manufacture of "No Mercury Added, R-20 Batteries" as per clause 2 of the
Supplementary Agreement. Similarly we find that in Page39 of PB, i.e. while
defining the products in 04.01.2001 agreement M/s. SISL has specifically
agreed to product meaning "Zinc Batteries having the specification of "D
Paper" and "AA" Metal. In the light of the said agreements with M/s. SISL we
find force in the contention of the assessee that the payments made to M/s.
SISL for acquiring the Technical know-how which being intangible asset
acquired after 01.04.1998 and owned by the assessee, shall be entitled to
deprecation u/s 32 of the Act, as expenditure on capital asset. We also note
that though the assessee had raised the said alternate claim before the ld
CIT(A) (Page 12 of ld CIT(A), he has not adjudicated on the issue. However
we find that the assessee vide the aforesaid agreement dated 15.02.2001
read in conjunction with agreement dated 04.01.2001 has acquired the
know-how to manufacture "No Mercury Added R-20 Batteries" and for
manufacture of technical documentation, drawing, design etc for "D Paper"
and "AA Meta", which are intangible asset qualifying for depreciation u/s
32(1)(ii) of the Act. As we had noted before the consideration for M/s SISL as
per the agreement dated 04.01.2001, is in force from 01.01.2001 up to
31.12.2001, which need to be read in conjunction with agreement dated
15.12.2001, so the agreement is in force from 01.01.2001 to 31.12.2001. And
the total consideration for the year is Rs.8.77 crores. So we can allow one-
fourth (1/4th) of the said consideration as capital expenditure for which
depreciation can be allowed. It amount to Rs.2.19 crores for which the AO is
directed to allow depreciation in accordance to law for the relevant
assessment year, which needless to say the rest of the amount i.e. Rs.6.58
crores will become the W.D.V for the subsequent Assessment Year
25. With regard to ground no. 2.0 concerned which relates to disallowing
of an amount of Rs. 70 lacs on account of excise duty payment which was
deductible u/s. 43B of the Act. We find that Ld. CIT(A) has observed that the
AO during the assessment proceedings has held that the payment of Rs. 70
lacs of excise duty was not in respect of the liability of the assessee and since
it was the liability of the different entity (M/s. Rialto), therefore, it was not
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allowable. We find that ld. CIT(A) has observed that the liability of payment
of excise duty of Rs. 70 lacs which was claimed by the assessee as the
deduction u/s. 43B did not belong to the assessee. The excise duty demand
of Rs. 70 lacs which was made by the excise authority related to a different
company M/s Rialto Enterprises Pvt. Ltd. These facts are also proved by the
company of excise challan which is in the name of M/s Rialto Enterprise Pvt.
Ltd. Moreover, the copy of the agreement which was submitted by M/s
Rialto Enterprises Ltd. to the AO it was seen that as per Article 11 and 18 of
the agreement, taxes and duties including excise duty on purchase of
material and sale of product and other activity was to be borne by M/s Rialto
Enterprises Pvt. Ltd.. On the basis of the above agreement, is very much
clear that the liability of Rs. 70 lacs on account of excise duty was not of the
assessee. Keeping in view of the said agreement, ld. CIT(A) has rightly held
that he concurred with the view of the AO that since the liability did not
belong to the assessee, hence, the claim of deduction u/s. 43B of Rs. 70 lacs
was not allowed, which does not call any interference on our part, hence,
we uphold the order of the Ld. CIT(A) on this issue. However, we find force in
the contention of the ld AR that the said levy of Rs.70 lakhs additional Excise
Duty was challenged and the same have been refunded back to M/s Rialto
which in turn has refunded it to the assessee in subsequent Assessment Year,
in that case that amount shall not taxed which will amount to double
taxation in the hands of the assessee. With the said observation we dismiss this
ground of the assessee's appeal.
REVENUE'S APPEAL - ITA NO. 2263/DEL/2011 (AY 2003-04)
26. The Revenue has filed the present appeal against the impugned order
dated 21/2/2011 passed by the Ld. Commissioner of Income Tax (Appeals)-
XV, New Delhi on the following grounds:-
"1. On the facts and circumstances of the case and in law, the Ld.
CIT(A) has deleted the addition of Rs. 2,07,89,275/- on account of
inventory written off made by the AO."
27. The facts in brief are that the assessee filed return of income declaring
total income of Rs. NIL after adjustment of brought forward loss on 21.11.2003.
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The return was processed under section 143(1) on 23.3.2004. The case of the
assessee was selected for scrutiny and notice under section 143(2) was sent
on 29.11.2004. Again notice under section 143(2) along with questionnaire
under section 142(1) was sent on 28.7.2005. The assessee company is
engaged in the manufacture and sale of kitchen appliances, hand blenders,
epilators, tooth brushes, toothpastes and manufacturing and trading in
grooming products and cell batteries. During the assessment proceedings ld.
Counsel of the assessee has produced computerized ledgers extracts which
have been test checked by the AO. During the year the assessee has sold all
assets of GEEP manufacturing business. Assessee company also discontinued
its braun domestic business activities but continued its braun export business.
After considering the submissions by the Ld. Counsel of the assessee, ld. AO
completed the assessment u/s. 143(3) of the Act vide his order dated
13.3.2006 and made addition of Rs. 2,07,89,275/- on account of inventory
written off.
28. Being aggrieved with the assessment order dated 13.3.2006, assessee
appealed before the Ld. CIT(A), who vide impugned order dated 21.2.2011
has deleted the addition by allowing the appeal of the Assessee.
29. Now the Revenue is aggrieved against the impugned order and filed
the present appeal before the Tribunal.
30. At the time of hearing Ld. DR relied upon the order of the AO and
reiterated the contentions raised by the Revenue in the grounds of appeal
and stated that the Appeal of the Revenue may be allowed.
31. On the other hand Ld. Counsel of the assessee relied upon the order of
the Ld. CIT(A) and stated that the same may be upheld.
32. We have heard both the Counsel and perused and considered the
relevant records available with us, especially the orders passed by the
Revenue Authorities and a Paper Book filed by the Assessee containing the
cases laws on which the assessee has relied upon; copy of submission made
before the CIT; Details of inventory write off and copy of judgment of Delhi
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ITA NO.2262& 2263/Del/2011
High Court in CIT vs. Tupperware India Pvt. Ltd. 2014-TIOL-610-HC-DEL-IT. We
find that Ld. First Appellate Authority has observed that the items of
inventories written off during the year were originally manufactured /
purchased for sale in the ordinary course of business and were held as regular
inventory items in the audited statement of accounts. Such write off of
damaged / unserviceable items of inventories as per standard policy of the
company, were written off and physically destroyed as a regular policy, and
such expenses was allowable deduction as revenue expenditure as having
been incurred wholly and exclusively for the purpose of business. Ld. Counsel
of the assessee further submitted before the Ld. CIT(A) that it was a settled
law that the losses or expenses incurred by the assessee by following
accounting system and method on year to year basis, which are in
accordance with mandatory accounting standard are allowable. In support
of this contention, assessee placed reliance on the following decisions before
the ld. CIT(A):
- CIT vs. British Paints 188 ITR 44 (SC)
- CIT vs. Alfa Label 295 ITR 491 (SC)
- CIT vs. Woodward Governor 312 ITR 254 (SC) and Digital
Equipment India Ltd. Vs. DCIT 103 TTJ 329.
33. We find that Ld. CIT(A) has further observed that the similar issue in
question has already been adjudicated by the CIT(A)-XII, New Delhi vide
order dated 12.1.2011 in Appeal NO. 165/09-10 for A.Y. 2004-05 in assessee's
own case. Therefore, the assessee has requested before the present Ld.
CIT(A)-XV, New Delhi that keeping in view of the aforesaid precedent the
disallowance made by the AO may be deleted. We find that the Ld. CIT(A)
has considered the submission and the findings of the AO and the facts on
record. We find that the Ld. CIT(A)-XV, New Delhi observed that the another
i.e. Ld. CIT(A)-XII, New Delhi in assessee's own case for the asstt. Year 2004-05
has decided the similar issue in assessee's favor by observing as under:-
"I have gone through the submissions filed by the appellant and
it is observed that the appellant has given complete details of
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inventory which have been written off as well as evidences in the
form of person before whom the said item were disposed off.
The appellant has pointed out that it being a Multi National
Company the company has to be maintained higher standard
of quality and these items are not sold in the second sale as
done by the many other firms. As the appellant has furnished
the complete details therefore, disallowance of Rs. 11643211/- is
hereby deleted and this issue is decided in favor of the
appellant."
34. We find that the Ld. CIT(A) in the instant case also found that the
assessee had filed the complete details of the inventory which have been
written off, as well as evidences in the form of persons before whom the said
items were disposed off. Therefore, Ld. CIT(A) has rightly held that as the
facts being similar, he has no reason to differ with the findings of the Ld.
CIT(A)-XII, New Delhi on the identical and similar issue involved in A. Y 2004-
05. Hence, following the earlier precedent, the Ld. CIT(A)-XV, New Delhi has
rightly deleted the addition of 2,07,89,275/- and decided the issue in favour
of the assessee. In view of the above facts discussed above we are of the
view that no interference is called for in the order passed by the Ld. CIT(A),
hence, we uphold the same by dismissing the appeal filed by the Revenue.
In the result, the Appeal filed by the Revenue stands dismissed.
35. In the result, the Appeal filed by the Assessee stands partly allowed. .
Order pronounced in the open court on 26.03.2015.
-Sd/- -Sd/-
(J.S.REDDY) (A. T. VARKEY)
ACCOUNTANT MEMBER JUDICIAL MEMBER
Dated:26/03/2015
*A K Keot
Copy forwarded to
1. Applicant
2. Respondent
3. CIT
4. CIT (A)
5. DR:ITAT
ASSISTANT REGISTRAR
ITAT, New Delhi
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