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ITO, Ward-271(1),Civic Centre, Minto Road, New Delhi vs. M/s. B2B Management, 5/47, Shyam Singh Street, Gopi Nath, New Delhi
March, 15th 2019
         IN THE INCOME TAX APPELLATE TRIBUNAL
              DELHI BENCH: "A", NEW DELHI

        BEFORE SHRI H.S. SIDHU, JUDICIAL MEMBER
                           AND
          SHRI O.P. KANT, ACCOUNTANT MEMBER

                    ITA No.5765/Del/2014
                   Assessment Year: 2011-12

ITO,                        Vs. M/s. B2B Management,
Ward-271(1),Civic   Centre,     5/47, Shyam Singh Street,
Minto Road, New Delhi           Gopi Nath, New Delhi
                                         PAN :AAJFB0165A
        (Appellant)                    (Respondent)

                Appellant by  Shri C.P. Singh, Sr.DR
                Respondent by Shri Harsh Kumar, CA

                       Date of hearing                28.02.2019
                       Date of pronouncement          14.03.2019


                            ORDER

PER O.P. KANT, A.M.:

     This appeal by the Revenue is directed against order dated
06/08/2014 passed by the Ld. Commissioner of Income-tax
(Appeals)-XXIV, New    Delhi   [in   short   `the   Ld.   CIT(A)']   for
assessment year 2011-12, raising following grounds:


   1.   Allowing the deduction of Rs.1,17,48,757/- u/s 10A of the
        I.T. Act, 1961 by holding that the CBDT's circular No.
        1/2005 dated 06.01.2005 with reference to Section 10B is
        equally applicable to Section 10A of the I.T. Act, 1961.
   2.   Holding that there was no reconstruction of business.
   3.   The appellant craves the right to add, alter or demand any
        ground of appeal.
                                     2
                                                   ITA No.5765/Del/2014




2.    Briefly stated facts of the case are that the assessee was
engaged in the business of ticketing; travel related activities using
software(s) supplied by       its principal by       undertaking such
activities of tickets etc. in/from India. The assessee was carrying
out its operations from its premises located at C-108, Lajpat
Nagar-I, New Delhi. During the year under consideration, the
assessee shifted its business premises to Software Technology
Park of India (STPI) located at Gurgaon and began its operation
w.e.f. 14/09/2010. The assessee filed return of income for the
year under consideration on 29/09/2011, declaring total income
of Rs.13,66,091/- after claiming deduction under section 10A of
Income-tax      Act,   1961   (in   short   `the   Act')   amounting      to
Rs.1,17,48,757/-in respect of the profit earned from the STPI
unit. The case was selected for scrutiny and notice under section
143(2) of the Act was issued and complied with. Before the
Assessing Officer, the assessee claimed that in view of Notification
SO-890(E) (i.e. Notification No. 11521) dated 26/09/2000, it was
a travel BPO and hence entitled for deduction under section 10A
of   the Act.    The   Assessing    Officer,   however,     rejected   this
contention on the ground that travel related activities or services
are not included in the said notification. According to him, the
assessee is not exporting any software but by using a system
oriented software, it has rendered travel related services of
booking tickets, hotel accommodation etc. for the employees of
the bestseller A/c and, thus, it cannot be equated with the
concern, who develops and export software. The Assessing Officer
also highlighted that FIRC (Foreign Inward Remittance Certificate)
mentioned that the amount charged by the assessee was toward
                                  3
                                               ITA No.5765/Del/2014

tour and travel and thus, assessee has not exported any software
or IT enabled services required as per the provisions of the Act as
well as the Notification (supra). The Assessing Officer also rejected
the claim of deduction under section 10A on the ground that the
assessee has violated the clauses (ii) and (iii) of section 10A(2) of
the Act, which stipulates that eligible business should not be
formed by splitting up or by transfer of plant and machinery to
new business, which was previously used by an assessee. The
Assessing Officer pointed out that the STP unit is nothing but a
continuation and transfer of existing business to an eligible unit
and such undertaking is not eligible for the benefit as per section
10A(2) of the Act. In view of the observations made, the Assessing
Officer disallowed the deduction claimed of Rs.1,17,48,757/-
under section 10A of the Act.
2.1 Aggrieved, the assessee filed appeal before the Ld. CIT(A)
and made detailed submissions supporting its claim of eligibility
of deduction under section 10A of the Act. The assessee made
detailed explanation as how the assessee qualifies the expression
"computer software" appearing in section 10A(1) and defined in
Explanation 2(ii) below the said section. According to the
assessee, any customized electronic data or any product or
service of similar nature as may be notified by the Board qualifies
for computer software. It was argued that first part of the above
Explanation pertain to any "customized electronic data" and the
second part to    any "product" or "service" of similar nature as
may be notified by the Board. The assessee submitted that the
Board has notified 15 Information Technology enabled products
of services, which includes back-office operations, call centres
and support centres. According to the assessee, it is in the
                                  4
                                                 ITA No.5765/Del/2014

business of back-office travel management for corporate. It was
also explained that it is service oriented unit which is servicing its
clients by providing support and services in the form of backward
operations and thus it is engaged in support service. The assessee
provided a detailed flowchart of its business process before the
Ld. CIT(A), which has been reproduced on page 9 and 10 of the
impugned order. It is claimed by the assessee that it offers end to
end travel BPO services, consulting and advisory services,
application development and maintenance, specifically designed
for   travel   management    companies.     On   the   basis    of   the
submissions, the assessee claimed that it is squarely covered
under categories    of back-office operations or support centres.
Regarding the violation of clauses (ii) and (iii) of section 10A(2) of
the Act, the assessee explained that in the CBDT circular No.
1/2005    dated 06/01/2005       it   has   been clarified that an
undertaking setup in Domestic Tariff Area (DTA) and deriving
profit from export of articles or things or computer software
manufacturer     produced by it, which is subsequently converted
into export-oriented unit, shall be eligible for deduction under
section 10B of the Act on getting approval as hundred percent
export oriented undertaking. The assessee claimed that aforesaid
circular is equally applicable in respect of Section 10A of the Act
as held by the Hon'ble High Court of Karnataka in the case of CIT
Vs. Export Outsource Private Limited, (2011) 358 ITR 518.
According to the assessee, there is neither reconstruction of the
firm nor setting up of by splitting up of an earlier firm. After
considering the submission of the assessee the Ld. CIT(A) allowed
the claim of the assessee of deduction under section 10A of the
Act observing as under:
                                   5
                                                    ITA No.5765/Del/2014

"5.      I have carefully considered the submission made by the A.R.
of the appellant and assessment order. It is noted that the appellant
firm was incorporated on 18.12.2008. The appellant firm was
carrying out the business providing services relating to ticketing and
travelling. Subsequently, it became an approved 100% export
oriented unit operating under software technology park scheme
(STPI) vide approval no. STPIN/APP/5262010/201340 dated
26.05.2010 and letter of permission was granted to it on
12.08.2010. The unit commenced manufacturing or production in
terms of Section 10A(1A) w.e.f. 14.09.2010. Thereafter, the appellant
claimed deduction u/s 10A for the relevant assessment year 2011-
12 i.e. the year in which it has got approval as 100% export oriented
undertaking for the period 15.09.2010 to 31.03.2011.






         It is further noted that the Assessing Officer has disallowed
the claim of deduction of the appellant u/s 10A on two grounds. The
Assessing Officer was of the view that the appellant firm has been
reconstructed as 100% export oriented unit for the purposes of
claiming deduction u/s 10A and secondly, the appellant is carrying
on the business of travel BPO (Business Process Outsourcing) and
therefore it is not entitled for deduction/exemption u/s 10A. It is
observed that the Assessing Officer has not given any reason for
treating the appellant firm as reconstructed. Admittedly the
appellant firm was engaged in the business of travel related services
in the domestic tariff area before 14.09.2010 i.e between the period
18.12.2008 to 14.09.2010. During the aforesaid period, the
appellant has not claimed any deduction u/s 10A. After 14.09.2010
the firm got the approval of STPI unit from the Director Software
Technology Park of India and relocated in a Software Technology
Park. Incircular No. 1/2005 dated 06.01.2005 the CBDT has
clarified that an undertaking set up in domestic tariff area (DTA) and
deriving profits from exports of articles or things or computer
software or manufactured or produced by it, which is subsequently
converted into a export oriented unit, shall be eligible for deduction
u/s 10B of the I T Act on getting approval as 100% export oriented
undertaking. The aforesaid circular is equally applicable in respect
of Section 10A of the I T Act as held by the Hon'ble High Court of
Karnataka in the case of CIT vs. Expert Outsource Pvt. Ltd. (Supra)
and ITO vs. Maxim India Integrated Circuit Design Pvt. Ltd. (Supra).
In this case, the appellant has merely transferred its business from
the domestic tariff area to the Software Technology Park. This fact
has also been admitted by the Assessing Officer in her order. There
is neither re-construction of the firm nor the setting up by
splitting up of any earlier firm. Therefore, conditions as mentioned in
Section 10A(2)(ii) & (iii) are not violated as there is neither splitting
up nor the reconstruction of the business already in existence
because conversion and splitting up or the reconstruction are
completely different terms. Reliance in this regard is placed on the
decision of Hon'ble ITAT Delhi in the case of Cadtrium Engineering
Solutions Pvt. Ltd. (Supra). Otherwise also, once the approval of STPI
                                      6
                                                      ITA No.5765/Del/2014

    is granted for conversion of an existing DTA Unit to a STP Unit, the
    conditions stipulated u/s 10A(2) of the Income Tax Act would stand
    complied with. The Assessing Officer has erred in her finding that
    the appellant firm has been reconstructed. On the contrary, it is
    noted that the appellant firm has only shifted its unit from the DTA
    to STP Area. Hence, in my opinion, the appellant firm is entitled for
    deduction/exemption u/s 10A of the IT Act.


             It is further noted that during the relevant assessment year
    the appellant had total turnover of Rs.3,77,38,067.53/-. However,
    from 14.09.2010 to 31.03.2011, the appellant had the turnover of
    Rs.2,59,12, 583.52/- and on the aforesaid export from the Software
    Technology Park, net profit of Rs.1,12,08,368.14/- was earned and
    claimed to be exempt u/s 10A. It is worthwhile to mention that
    during the relevant assessment year, the total profit derived from
    business on the turnover of Rs. 3, 77, 38, 067.53/- was Rs. 1, 25,
    01, 686.41/- out of which the appellant firm has shown export
    turnover of Rs. 2, 59, 12, 583/- and have shown profit of Rs. 1, 12,
    08, 368.14/-. The Assessing Officer has disallowed the aforesaid
    claim of deduction only on the ground that the travel related
    activities or services are not included in the list of approved IT
    enabled services by the CBDT in notification no. SO-890(E) dated
    26.09.2000. I do not agree with the aforesaid view of the Assessing
    Officer. The Assessing Officer has not controverted the claim of the
    appellant that its case is covered as the IT enabled service provider
    as BPO or the back office services. It is noted that the appellant has
    provided travel related services to only one concern namely Best
    Seller A/S Denmark and the aforesaid services has been provided
    with the help of computers. Further, computer software means any
    customised electronic data or any product or service of similar
    nature for the purposes of back office operations, call centers,
    website services. These services are duly covered in notification no.
    SO-890(E) dated 26.09.2000 issued by the CBDT. The CBDT has not
    excluded the travel BPO in the aforesaid notification. Therefore, I am
    of the considered opinion that the appellant was engaged in the
    business of providing IT enabled services in the form of a BPO or as
    a back office service provider and entitled for deduction u/s 10A.
    Hence, the Assessing Officer is directed to allow the impugned
    deduction claimed by the appellant u/s 10A of the I T Act."


2.2 Thus, the Ld. CIT(A) has rejected both the finding of the
Assessing    Officer   that    the   assessee     was    not    engaged      in
manufacturing or export of the computer software and violation of
clauses (ii) and (iii) of section 10A of the Act.
                                  7
                                               ITA No.5765/Del/2014

2.3 Aggrieved with the above finding of the Ld. CIT(A), the
Revenue is in appeal before the Tribunal raising the grounds as
reproduced above.
3.   Before us, the Ld. DR relied on the order of the Ld.
Assessing Officer and submitted that the assessee does not
qualify for the deduction under section 10A of the Act. He
submitted that assessee was engaged in providing services of
ticketing, hotel reservation and other associated services to its
sole client and those services cannot be termed as back-office
operations or support centres. He further submitted that no
documentary evidences have been submitted by the assessee
before the Ld. CIT(A) in support of its detailed explanation of the
business   process   and    Ld.   CIT(A)   without   providing   any
opportunity to the Assessing Officer for rebutting     those claims
and has decided the issue in dispute in violation of the principle
of natural Justice. He also submitted that apparently the assets
of the old existing unit have been transferred to the new unit at
STPI, and thus claim of no reconstruction of the firm or forming
of new unit by way of the splitting of the old unit need verification
by the Assessing Officer. He further submitted that in view of
section 10A(7B) of the Act the undertaking which has begun or
begins to manufacture or produce articles or things or computer
software during the previous year relevant to the assessment year
commencing on or after the 1st day of April, 2006 in any special
economic zone, the assessee is not eligible for deduction under
section 10A of the Act.
4.   On the contrary, Ld. counsel of the assessee filed a
paperbook containing pages 1 to 25 and submitted that it has
satisfied all the conditions required for claiming deduction under
                                 8
                                              ITA No.5765/Del/2014

section 10A of the Act. The Ld. counsel relied on the detailed
submission filed before the Ld. CIT(A) and also the case laws
relied upon by the Ld. CIT(A) for allowing the deduction to the
assessee. The Ld. counsel submitted that provisions of section
10A(7B) are with reference to section 2(zc) of the SEZ Act only i.e.
unit set up under Special economic zone(SEZ) on or after 1st
April, 2006 as w.e.f. the said date special provisions in respect of
newly established units in     any special economic zone section
10AA has been introduced. According to the Ld. counsel,
therefore, section 10A of the Act continues to apply on STPI
undertaking.
5.   We have heard the rival submissions and perused the
relevant material on record. The undisputed facts of the case are
that the assessee firm was incorporated on 18/12/2008 and has
been engaged in the providing services of ticketing, hotel booking
etc since then. The assessee became an approved 100% Export
Oriented Unit (EOU) operating under Software Technology Parks
Scheme vide approval of even number dated 20/06/2010. The
unit commenced its activity from the STP unit w.e.f. 14/09/2010.
The dispute is in respect two issues :
     1. whether the activity carried out at the STPI unit are
        eligible business under section 10A of the Act; and
     2. whether there is any violation of clause (ii) and (iii) of
        section 10A(2) of the Act.
6.   The Assessing Officer disallowed the deduction holding that
the assessee has not exported any software but using a system
oriented software and it has rendered travel related services of
booking tickets, hotel accommodation etc for the employees of its
sole client. The Assessing Officer also held the assessee for
                                   9
                                                 ITA No.5765/Del/2014

violation of the clauses (ii) and (iii) of section 10A(2) of the Act. We
find that before the Ld. CIT(A) the assessee has made detailed
representation about the business process to canvass its claim
that activities carried out at STPI units are eligible for deduction
under section 10A of the Act. The detailed submission filed by the
assessee are reproduced by the Ld. CIT(A) in the impugned order
from pages 4 to 19 of the impugned order. In para 4.1 to 4.1.1 of
the   impugned    order,   the   Ld.   CIT(A)   has   reproduced    the
explanation of the assessee that conversion of the existing DTA
into a STP unit was not in violation of clause (ii) and(iii) of section
10A(2) of the Act and it was nothing but continuation and
transfer of existing business to an eligible unit. In para 4.2 of the
impugned order, the Ld. CIT(A) has reproduced contention of the
assessee regarding eligibility of computer software manufacturing
and export. The Ld. CIT(A) has reproduced the entire business
process explained by the assessee claiming that it was in the
nature of back-office operations or support centres as notified by
the CBDT for the purpose of meaning of computer software. The
Ld. CIT(A) has nowhere mentioned about any                  documents
submitted by the assessee in support of the claim of the entire
business process of the assessee. Thus, it is evident that the Ld.
CIT(A) in this regard has relied mainly on the submission of the
assessee. Now, let us examine the eligibility of the assessee for
the deduction under section 10A of the Act. The section 10A
applies to undertakings established in free-trade zone, software
technology Park and special economic zone. The section 10A(1)
which prescribes requirement of export of articles or things or
computer software for claim of deduction is reproduced as under
for ready reference:
                                        10
                                                         ITA No.5765/Del/2014

      "Special provision in respect of                newly     established
      undertakings in free trade zone, etc.
      10A. (1) Subject to the provisions of this section, a deduction of such
      profits and gains as are derived by an undertaking from the export
      of articles or things or computer software for a period of ten
      consecutive assessment years beginning with the assessment year
      relevant to the previous year in which the undertaking begins to
      manufacture or produce such articles or things or computer software,
      as the case may be, shall be allowed from the total income of the
      assessee :"


7.     Thus, for eligibility of the deduction under section 10A, the
assessee is required not only to manufacture or produce but also
essentially required to export those articles, things or computer
software. For the purpose of this section, the word "computer
software" has been defined in Explanation 2(i) as under:
"(9A) [Omitted by the Finance Act, 2003, w.e.f. 1-4-2004.]
Explanation 1.--[Omitted by the Finance Act, 2003, w.e.f.1-4-2004.]
Explanation 2.--For the purposes of this section,--
     (i) "computer software" means--
           (a) any computer programme recorded on any disc, tape, perforated
               media or other information storage device; or
           (b) any customized electronic data or any product or service of similar
               nature, as may be notified by the Board, which is transmitted or
               exported from India to any place outside India by any means;"







8.     The assessee has claimed its eligibility under clause (b) of
the explanation. According to the assessee, it falls under any
product or service of similar nature as may be notified by the
Board. The assessee has submitted that the Central Board of
Direct Taxes (CBDT) has notified by way of notification (supra)
following services for the purpose of meaning of "computer
software":
      "In exercise of the powers conferred by clause (b) of item (i) of Explanation
      2 of section 10A, clause (b) of item (i) of Explanation 2 of section 10B and
      clause (b) of Explanation to section 80HHE of the Income-tax Act, 1961
      (43 of 1961), the Central Board of Direct Taxes hereby specifies the
                                          11
                                                     ITA No.5765/Del/2014

     following Information Technology enabled products or services, as the
     case may be, for the purpose of said clauses, namely :

     (i) Back-office Operations;

     (ii) Call Centres;

     (iii) Content Development or Animation;

     (iv) Data Processing;

     (v) Engineering and Design;

     (vi) Geographic Information System Services;

     (vii) Human Resource Services;

     (viii) Insurance Claim Processing;

     (ix) Legal Databases;

     (x) Medical Transcription;

     (xi) Payroll;

     (xii) Remote Maintenance;

     (xiii) Revenue Accounting;

     (xiv) Support Centres; and

     (xv) Web-site Services.

     [F. No. 142/49/2000-TPL]

9.    The claim of the assessee before us is that it was engaged in
providing back-office operations or support Centre provided in the
above list at Serial No. (i) and Serial No. (xiv).
10. Thus, when            we read the section 10A(1) along with the
Explanation 2(i), we find that the assessee was required to
manufacture or produce and export the services of back-office
operations or support Centre. But, according to the Assessing
Officer, the assessee has sold flight tickets and hotel reservations
and other amenities to its sole client. The Ld. Assessing Officer
                                 12
                                               ITA No.5765/Del/2014

has referred to FIRC certificates to support his stand that
proceeds were received from tour and travel activity. According to
the assessee, it has provided only back-office operations or
support Centre.
11. From the facts submitted before us, it is not clear whether
the proceeds received include the cost of the airfreight or hotel
accommodation, which in itself cannot be termed as proceed of
export of back-office operation or support Centre. It is also not
clear how much part of the services rendered would amount to
manufacture and export of computer software. Both these issue
are crucial for adjudicating the issue in dispute regarding
eligibility of the business of the assessee for deduction under
section 10A of the Act. Before us, the Ld. DR has submitted that
no documentary evidence in support of entire business process
explained before the Ld. CIT(A) has been filed either before the
Assessing Officer or before the Ld. CIT(A). We also note that an
agreement between the sole client of the assessee i.e. M/s
bestseller A/s was filed before the Ld. CIT(A). It is not clear
whether the said agreement was filed before the Assessing Officer
or not. In view of the above facts and circumstances of the case,
we feel it appropriate to restore this issue to the file of the
Assessing Officer for deciding afresh with the direction to the
assessee to produce all the documentary evidence in support of
its claim that its activities falls under the services of back-office
operation or support Centre as listed out in the notification
(supra) of the CBDT. The assessee shall be provided adequate
opportunity of being heard.
                                                   13
                                                                        ITA No.5765/Del/2014

12. As far as the issue of violation of clauses (ii) and (iii) of
section 10A(2) of the Act is concerned, the relevant provisions for
ready reference , are reproduced as under:
"Special provision in respect of newly established undertakings in free
trade zone, etc.
10A. (1) .................................................................................................
 (2) This section applies to any undertaking which fulfils all the following
conditions, namely :--
    (i) .................................................................................................
   (ii) it is not formed by the splitting up, or the reconstruction, of a business
         already in existence :
         Provided that this condition shall not apply in respect of any
         undertaking which is formed as a result of the re-establishment,
         reconstruction or revival by the assessee of the business of any such
         undertakings as is referred to in section 33B, in the circumstances and
         within the period specified in that section;
   (iii) it is not formed by the transfer to a new business of machinery or plant
         previously used for any purpose.
Explanation.--The provisions of Explanation 1 and Explanation 2 to sub-
section (2) of section 80-I shall apply for the purposes of clause (iii) of this sub-
section as they apply for the purposes of clause (ii) of that sub-section."


13. On the issue of violation of clause (ii) and (iii), The Ld. CIT(A)
has relied on the Circular No.1/2005 of the CBDT dated
06/01/2005 and decision of the Hon'ble High Court of Karnataka
in the case of CIT Vs. Expert outsourced private limited (supra)
and held that there is no splitting up or reconstruction of a
business already in existence. In the said circular, it has been
clarified that an undertaking setup in Domestic Tariff Area (DTA)
and deriving profit from export of articles or things or computer
software manufacturer or produce it, which is subsequently
converted into export-oriented unit, shall be eligible for deduction
under section 10B of the Act on getting approval as hundred
percent export oriented undertaking. The Hon'ble High Court of
Karnataka in the case of M/s Expert Outsourced Private Limited
                                      14
                                                       ITA No.5765/Del/2014

(supra) has held that aforesaid circular is equally applicable in
respect of section 10A of the Act. In view of the above, we do not
find any error in the order of the Ld. CIT(A) as far as the
conditions of clause (ii) of section 10A is concerned, but the
conditions of clause (iii) of              section 10A(2), whether any
machinery or plant previously used for any purpose has been
transferred to the STP unit is not clear from the facts available on
record. Since we have already restored the issue of eligibility of
the business of the assessee to the file of the Ld. Assessing
Officer, we feel it appropriate to restore this issue also to the file
of the Assessing Officer for verifying and then decide in
accordance with law. It is needless to mention that the assessee
shall be afforded adequate opportunity of being heard
14. As far as argument of the Ld. DR that, the assessee is not
qualified for deduction in view of section 10A(7B) of the Act, is
concerned, the said sub-section is reproduced as under :


"Section 10A(7B): The provisions of this section shall not apply to any
undertaking, being a Unit referred to in clause (zc) of section 2 of the Special
Economic Zones Act, 2005, which has begun or begins to manufacture or
produce articles or things or computer software during the previous year
relevant to the assessment year commencing on or after the 1st day of April,
2006 in any Special Economic Zone."


15. We find from section 10A(2)(i) that the section 10A applies to
undertakings which began or commenced manufacturing in free
trade zone, software technology Park or special economic
zone. The relevant part of the section 10A(2)(i) is reproduced as
under:
                                     15
                                                     ITA No.5765/Del/2014

"Section 10A(2) This section applies to any undertaking which fulfils all the
following conditions, namely :--
    (i) it has begun or begins to manufacture or produce articles or things or
        computer software during the previous year relevant to the assessment
        year--
        (a) commencing on or after the 1st day of April, 1981, in any free
            trade zone; or
        (b) commencing on or after the 1st day of April, 1994, in any
            electronic hardware technology park, or, as the case may be,
            software technology park;
        (c) commencing on or after the 1st day of April, 2001 in any special
            economic zone;


16. Since the section 10A(7B) is with reference to undertakings
in special economic zone, the same cannot be applied over the
units in Software Technology Park. Accordingly, we reject this
contention of the Ld. DR.
17. Accordingly, the ground of the appeal of the Revenue is
allowed for statistical purposes.
18. In the result, the appeal of the Revenue is allowed for
statistical purposes.
          Order pronounced in the open court on 14th March, 2019.




          Sd/-                                        Sd/-
      [H.S. SIDHU]                                [O.P. KANT]
   JUDICIAL MEMBER                            ACCOUNTANT MEMBER
Dated: 14th March, 2019.
RK/-[d.t.d.s]
Copy forwarded to:
1.    Appellant
2.    Respondent
3.    CIT
4.    CIT(A)
5.    DR


                                                Asst. Registrar, ITAT, New Delhi

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