IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH "A" NEW DELHI
BEFORE SHRI R.P. TOLANI: JUDICIAL MEMBER
AND
SHRI J.S. REDDY : ACCOUNTANT MEMBER
ITA No. 2670/Del/2013
Asstt. Yr: 2009-10
Smt. Alpana Kirloskar Vs. ACIT Circle 31(1),
26, Ferozshah Road, New Delhi.
New Delhi-110001.
PAN: AARPK 0165 B
( Appellant ) ( Respondent )
Appellant by : Shri H. Mittar CA
Respondent by : Ms. Y. Kakkar Sr. DR
Date of Hearing: 05-02-2014
Date of order: 28th April, 2014.
ORDER
PER R.P. TOLANI, J.M::
This is assessee's appeal against the order dated 28-02-2013 passed by
the ld. CIT(A)-XXVI, New Delhi in appeal no. 412/2011-12, pertaining to A.Y.
2009-10. Assessee has challenged the levy of income tax again on beneficial
share received from a private discretionary " Fair Value Trust" which is already
assessed by department at maximum marginal rate u/s 164.
2. Various repetitive issues are raised, the controversy can be addressed by
one of the ground raised which is as follows:
(1) The learned AO having made the addition of Rs.
99,50,000/- u/s 56(2)(vi) holding the same as gift without
consideration received by the appellant from the trust and not
by exercising his option to assess the appellant as beneficiary
u/s 166 or otherwise, in respect of share of income received by
the appellant as a beneficial owner under the trust instead of
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assessing the same in the hands of the trustees as a
representative assessee u/s 161, the action of the learned
Commissioner (Appeals) in holding that the AO had assessed
the income not u/s 56(2)(vi) but as normal income u/s 166 or
otherwise and in confirming the addition on the ground that
section 56(2) had been inadvertently mentioned by the AO is
entirely wrong on facts and in law and the addition made u/s
56(2)(vi) should have been deleted."
3. Brief facts are: The assessee is one of the beneficiaries of a private
discretionary trust, known as "Fair Value Trust" ("FVT"), which has been
settled way back on 11-12-20000. The trust's income is from dividends,
which are exempt in this year under sec 10(34 ). As the nomenclature of the
trust suggests, the shares of the beneficiaries are indeterminate and trust
income is distributed among the respective beneficiaries at the end of the
year as per the discretion of trustees. The said FVT submitted its return of
income at Pune, offering the exempt dividend income. As already mentioned
the private discretionary trust income is assessed at maximum marginal rate
u/s 164 in the hands of the trustees as provided by sec. 164 vide assessment
order for impugned AY dated 23-03-2011.
3.1. In this year the assessee received her beneficial share out of said
dividend income of the trust, amounting of Rs. 1 crores and claimed it as
exempt u/s 10(34) having been already taxed in the hands of the trustees u/s
164. During the course of assessment proceedings ld. AO however, issued
show cause notice to explain how this income was claimed as exempt.
Assessee vide its reply dated 2-12-2011 submitted as under:
"Brief note on the taxability of Rs. 1 Crore received from
Fairvalue Trust along with the copy of Trust Deed and specific
provision under which this income has been treated as exempt
in the hands of the recipient is desired.
A detailed note on distribution of Rs. 1 Crore received during
the year from Fair Value Trust has already been submitted in
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my letter dated 15.11.2011. Your good self has wrongly
interpreted that distribution is an income of beneficiary
whereas distribution is out of Trust Fund. Income of trust has
already been offered for tax per provisions of Income Tax Act
1961 in respect of income of private discretionary Trust where
share of beneficiaries are indeterminate and not specified in
Trust instrument. Copy of Trust deed dated 11.12.2000 is
enclosed which shows that as per clause l.2(iii) myself being
wife of Sh. Kirloskar is a beneficiary and my share is not
defined in the trust instrument.
As per provisions of Section 164(1) Trustees as 'Representative
Assessee' u/s 160(1)(iv) of Fairvalue Trust has submitted its
return of income showing taxable income of Trust and paid tax
at Maximum Marginal Rate of tax. Copy of return of income of
Fairvalue Trust has already been submitted along with my
letter dated 15.11.2011. As explained above, my share in
Income from Fairvalue Trust as a beneficiary has already been
taxed as per provisions of Income Tax Act, 1961. Distribution
of surplus fund of Rs. 1 Crore is not an income hence it is not
taxable.
3.2. AO, however, was of the view that 164 interpretation provided that it
is only when no income is distributed amongst the beneficiaries by a private
discretionary trust then the trust income is taxable in the hands of the trust as
a separate taxable entity. However, when the surplus is distributed by such
trust, the receipt in the hands of beneficiary will be taxable as it becomes
"income from other sources" in the hands of the beneficiary. Therefore, it
was held to be in the nature of "income from other sources" in the hands of
the assessee in terms of sec. 56(2)(vi). Further, since the trust does not fall
within the meaning of the term `relative' as provided in the explanation
thereto, the same was taxed as taxable gift after giving a statutory deduction
of Rs. 50,000/-. Thus, the resultant beneficial share amounting to Rs.
99,50,000/- was added and taxed in the hands of the assessee. While doing
so ld. AO relied on various judgments mentioned in his order.
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3.3. Aggrieved, assessee preferred first appeal before the CIT(A), raising
mainly following contentions:
(i) The FVT was a discretionary trust in as much the share of
individual beneficiaries on whose behalf and for whose benefit the
income was receivable were indeterminate and u/s 164(1), the tax
was already charged to tax by department at the maximum marginal
rate in the hands of the trustees as representing the beneficiaries. Thus
the option of taxing the trust income in the hands of trustees stands
already exercised by the department.
(ii) Apart from exercising the option of directly taxing the income in
the hands of FVT, in the case of another beneficiary of the same trust
Shri Atul Kirloskar the beneficial share from the same trust has been
exempted by accepting assesses claim that the income has been taxed
in the hands of the trust. This is demonstrated by the return,
computation and assessment order in Atul Kirloskar's case u/s 143(3)
dated 1-12-2011. Both the assessment orders i.e. Trust and Shri Atul
Kirloskar are passed before assessee's order. The action of assessing
trust and beneficiaries income should be uniformly and correctly
exercised for all the beneficiaries in a uniform manner and not at the
whim and fancy of deferent officers assessing them.
(iii) The income distributed by the trust was the income received by
the trustees for and on behalf and for the benefit of beneficiaries and
the trustees were assessable only as 'representative assessees' on
behalf of the beneficiaries in respect such income. Such receipt could
not by any stretch of imagination be regarded as gift in the hands of
beneficiary. The share from a fiduciary arrangement is received by
the beneficiaries by virtue of the his/her rights as enshrined in the trust
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deed along with provisions of Indian Trust Act and that it was not a
gratuitous receipt.
(iv) The sum of Rs.1 crores received by the beneficiary (appellant)
was out of the trusts current year's total income i.e. Rs.20.84 crores,
which was received by way of dividend income, which is exempt u/s
10(34) of the Income-tax Act.
(v) That the amount received being not a gift, the addition of this
amount as an alleged gift u/s 56 of the Income-tax Act was totally
illegal, baseless, erroneous and unsustainable.
(vi) Without prejudice, even if it is held to be taxable income then
also for any reason the impugned addition, even otherwise is wholly
illegal and totally unwarranted in law and on facts. The income being
received under the trust for and on behalf of and for the benefit of the
beneficiaries could be assessed in accordance with the provisions of
section 161 to 166 of the Income-tax Act. An income which is
exempt in the hands of trust, on distribution, its share cannot be held
as taxable in the hands of beneficiary as it is part of the exempt
income.
(vii) U/s 166 of the Income-tax Act the revenue has an option to
assess the income either in the hands of the trustees as representative
assessees or directly in the hands of the beneficiary. The trustees has
been already assessed prior to beneficiaries assessment, as evidenced
by the aforementioned order of the trust, there is no provision in the
Act to review the option by beneficiary's AO, Besides there is no loss
to the revenue whether the income was assessed in the hands of the
trustees as representative assessees or in the hands of the individual
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beneficiaries as in both cases same provisions about maximum
marginal rate and exemption u/s 10(34) are applicable . The revenue
in all the earlier assessment years, has adopted this course of action
and exercised the option of assessing the entire trust income in the
hands of trustees and allowing claim of exemption of dividend income
and direct assessment has been made on the beneficiaries. The
exercise of option has been already exercised by department, which
cannot be reviewed under any provision of the Act. In the garb of
interpretation of sec 164 and 166 which is contrary to CBDT circulars
and settled legal position AO has taken a somersault and added the
income once again in the hands of assessee. This has resulted in
double assessment of the same very income which is wholly illegal,
unsustainable and unwarranted and also contrary to the Board's
Circular No. 157 (F.No.228/8/73-IT(A-II) dated 26.12.1974
specifically provided for this situation.
(viii) Without prejudice and even assuming for the sake of argument
that the income was directly taxable in the hands of the beneficiary
[appellant], the learned A.O. failed to appreciate that the income
distributed amongst the beneficiaries comprised of exempt dividend
income of Rs.20.84 crores. This income would be wholly exempt u/s
10(34) in the hands of beneficiaries also. Even if the fantastic
interpretation of AO is considered in any event the deduction u/s
10(34) in respect of exempt dividend income cannot be denied.
(ix) The various decisions referred to by the learned A.O. were
mostly rendered before the amendment of section 164(1) by the
Finance Act, 1980 which provided that instead of tax being charged in
the slab rate applicable to Association of Persons, the rate chargeable
was prescribed as maximum marginal rate which was most beneficial
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to the revenue. The issue, therefore, has to be read and understood in
the light of the amendment.
(x) In all the past years income of the Fair Value Trust has been
consistently assessed directly in the hands of trustees and the share of
income as and when received by the beneficiaries including the
appellant has not been assessed as exempt in their hands since the
setting up of the Trust.
(xi) During the assessment proceedings for assessment year 2006-
07, this very issue was raised by the learned A.O. and after
considering the assessee explanation about the share being exempt in
view of above submissions the assessment was completed u/s 143(3}
by treating the beneficial share income from dividends earned by
trust amounting to Rs.4 crores received on distribution by assessee as
exempt. This order is placed on record. Thus apart from the merits
assesses case is covered by principles of `rule of consistency'
enshrined by the courts which has been violated by the learned A.O.
despite there being absolutely no difference in facts and circumstances
of the case. On this score also the observations/findings of the learned
A.O. are liable to be set-aside.
(xii) The learned A.O. has illegally assessed this amount under the
head "Other Sources" under section 56(2)(vi} holding that the
beneficial receipt from trust as a gift. By any stretch of imagination
the beneficial share cannot be treated as a gift by the trust to the
appellant. This amount was received by the appellant by virtue of her
legal right as a beneficiary named in the Trust Deed. It is this very
income which has been assessed to tax in the hands of the trustees as
representative assessee at maximum marginal rate of tax. There is not
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a single case law or an authority to support the view that the income
received by beneficiary from a trust constituted a Gift.
(xiii) Without prejudice, even if the stand of the learned A.O. is
accepted that the beneficiaries could be directly assessed is accepted,
the dispute still remains only of academic interest. As perusal of
statement of accounts of the Fair Value Trust would show the trust
had derived only dividend income which was exempt from tax u/s
10(34) which has been distributed among beneficiaries. Even for the
sake of argument if this income is again directly sought to be assessed
in the hands of the beneficiaries, the same is still covered by
exemption u/s 10(34). The income whether assessed in the hands of
the trust or beneficiaries, retain the same character as assessable in the
hands of the trust. While directly assessing the beneficiaries in respect
of the income received by them on distribution, the amount of
dividend included therein is eligible for deduction/exemption in the
same manner as would have been done had the trustees been assessed
in respect of such amount. In this connection, reliance is placed upon
the decision of Hon'ble Gujrat High Court in CIT vs. (1) Dr. Anand
Sarabhai, (2) Executors and trustees of Dr. Vikram Sarabhai reported
in (1998) 231 ITR 529 which is on all the fours with the case of the
appellant. Therefore, even if the income is to be taxed in the hands of
the appellant, the same would be Nil in view of the exemption u/s
10(34) of dividend income. The appellant's claim is that even if the
inclusion of Rs. l crore in the hands of the appellant for any reason is
upheld, the exemption of Rs. l crores representing the exemption of
dividend income may kindly be allowed leaving the taxable amount of
Rs. l crore at Nil.
(xiv) It is well settled that there cannot be double assessment of the
same income. Income having been taxed and tax having been paid in
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the hands of the trust at maximum marginal rate the same income
could not again be brought to tax in the hands of the appellant. Double
assessment is barred by law. Circular No.157 dated 26.12.1974
reproduced in (1975) 98 ITR Statute 41, was relied on.
3.4. Besides, above submissions before ld. CIT(A), assessee filed
additional evidence which was duly admitted by him and a remand report
was called from AO. The assessing officer submitted remand report dated
5-10-2012 reiterating her stand. Assessee made following submissions
before ld. CIT(A).
3.5. After considering the material available on record, ld. CIT(A) did not
agree with treating the beneficial income as gift but confirmed the addition
by holding:
(1) Law created a fiction that if the income of the trust is not
distributed then it can be taxed in the hands of the beneficiaries.
There was no impediment in taxing the beneficiary of a
discretionary trust in this situation when the income is received by
beneficiary.
(2) The law provided a protection to revenue by creating a fiction that
the tax would be levied upon and recovered from right person in
right manner and to the same extent as it would be leviable upon
and recoverable from the person represented by trustees.
(3) Relying on the judgments in the cases of CIT Vs. Kamalini Khatau
(1994) 209 ITR 101 (SC); and CIT Vs. Dr. Anand Sarabhai Trust
(1998) 231 ITR 524 (SC), it was held that these judgments
supported the above interpretation.
(4) It was a settled law that revenue had a clear option to assess and
recover tax either from trustees or from the beneficiaries of a
discretionary trust in respect of income which has been distributed
and received by the beneficiaries. AO's order was thus upheld by
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holding that assessing officer had invoked right sections while
taxing the beneficial shares in assessee's hands.
(5) Thus, AO's application of sec. 56(2) was held to be inadvertent and
not tenable. AO's order was upheld qua the applicability of sec.
164 as interpreted by him and the reference to sec. 56(2) was held
to be inapplicable.
3.6. Aggrieved, assessee is before us.
4. Ld. Counsel for the assessee vehemently argues that it has not been
disputed by department that the FVT has been assessed to tax at Pune prior
to the assessment of the assessee. This clearly indicates that the department
has already exercised the option u/s 164 of assessing the trust income in the
hands of the trust/ trustees at the maximum marginal rate as provided u/s
164. Once that option is exercised by revenue then in the case of all the
beneficiaries its consequence will apply as a natural corollary. There is
absolutely no substance in the stand of the lower authorities that even though
the entire income of the trust has been assessed in the hands of the trustees
at maximum marginal rate still the option of sec. 164 remains open with the
department to again assess the beneficial share at the will and desire of the
AO in case of each beneficiary respectively. The stand is self contradictory,
illegal and against the circulated stand of the CBDT.
4.1. Thus, FVT having already been assessed at the maximum marginal
rate and the consequent assessment in the hands of Shri Atul Kirloskar
treating the beneficial share from same trust as exempt, the statutory option
of taxing u/s 164 stands foreclosed qua the assessee. To demonstrate his
point, our attention was invited to P.B. from the assessment orders are
passed as under:
(i) Fair Value Trust u/s 143(1) by ACIT Pune dated 23-3-2011.
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(ii) Another beneficiary Shri Atul Kirloskar, assessed by ACIT
Circle 9, Pune u/s 143(3) vide order dated 1-12-2011 for the same
year. By this order the beneficial share of Rs. 4 crores received from
FVT has been accepted to be exempt.
(iii) Assessment in assessee's on 29-12-2011.
4.2. Ld. Counsel for the assessee contends that if the department's
assessments action is holistically taken it demonstrates a totally absurd and
harsh approach adopted in the case of the assessee. In the FVT trust case, the
entire trust income is assessed as per law i.e. u/s 164. The option provided
by sec. 164 is thus clearly exercised by department in this manner. Section
164 does not provide that option once exercised, can be reviewed or reopted
by any officer assessing respective beneficiaries. Besides, the option cannot
be changed from one beneficiary to other beneficiary. On this account itself
the action of the department deserves to be quashed.
4.3. Ld. Counsel further submitted that the action is contrary to the
Board's Circulars and settled case law on the subject. Reliance is placed on
the ratio of decision in the case of CIT vs. Gargiben Trust (1981( 130 ITR
479 (Bom) for the proposition that mode of assessment provided u/s 161 to
166 of the I.T. Act, 1961 is alternative to each other and once the ITO brings
to tax an income in the hands of the either trustees or the beneficiaries, the
same cannot be brought to tax in the hands of other person.
4.4. It is pleaded that AO and CIT(A) both have wrongly applied the
decision of Hon'ble Supreme Court in the case of Kamalini Khatau (supra),
it rather helps the assessee `s case in as much as it also lays down that such
income can be either assessed in the hands of trust or beneficiary, it does not
authorize tax from both. It is clear from following observation:
"We hold accordingly that the revenue had the option to assess
and recover tax from either of the trustees or the beneficiaries
of a discretionary trust in respect of such income thereof as has
been distributed and received by the beneficiaries".
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4.5. Further reliance is placed on:
(i) Jyotindera Sinhji vs. S.L. Tripathi & others (1993) 201 ITR 611
(SC), holding that revenue has option to tax income in the
hands of either the beneficiaries or trustees. Double taxation of
income in the hands of trust and beneficiary is not permissible.
(ii) Nagappa (CR) Vs. CIT (1969) 73 ITR 626, holding that there
cannot be assessment of the same income once in the hands of
the representative assessee and again in the hands of
beneficiary.
4.6. It is alternatively submitted that assuming for the sake of argument
that the assessment was made u/s 166, the income received on distribution
by the trust included dividend income exempt u/s 10(34) of the I.T. Act. The
beneficial income to assessee being part of dividend income only same was
entitled to the exemption u/s 10(34) which has not been allowed by lower
authorities despite express provisions.
4.7. Section 4 of the Income-tax Act is chargeable section and provides
that income tax shall be charged for any assessment year at the prescribed
rates in respect of total income of the previous year of every person. Section
5 defines the scope of total income and how the income has to be arrived at
in the case of the residents and non residents etc. Section 10 of the Act
provides that in computing the total income of the previous year of any
person, any income falling within clauses laid down therein shall not be
included. Dividend income is exempt u/s 10(34). Thus what is chargeable to
tax is the total income which excludes exempt income. In support, reliance
has been placed on following judgments for respective propositions:-
(i) Jyotindera Sinhji Vs. S.L. Tripathi & others (1993) 201 ITR 611
(SC):
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The ITO may, therefore, assess the person represented in respect of
the income of the trust property and the appropriate provisions of
Income-tax Act relating to computation of total income and the
manner in which the income is to be computed will apply to that
assessment.
Apart from the rate of tax, the quantum of it can only be the same
as in the case of beneficiary. Thus in the assessment of the trustees
should be given all exemptions, abatements, deductions and relief
that the beneficiary would have been entitled to had he been
directly assessed.
(ii) CIT vs. Saurin S. Jhaveri (2002) 257 ITR 160.
Special deduction u/s 80C is available while computing the
beneficiary share of income from the trust.
(iii) CIT Vs. Bharti Devi Sarabhai (1998) 231 ITR 531 (Guj)
The amount of dividend income received by the trustee which was
allowable for deduction u/s 80K, when passed on to the beneficiary
would nonetheless be eligible to the same deduction.
(iv) CIT vs. Dr. Anand Sarabhai (1998) 231 ITR 529 (Guj)
The deductibility u/s 80K of the amount of dividend or its part
which is attributable to the profits and gains which the company is
entitled to deduction u/s 80J would remain the same when
computed either in the hands of the trustees or in the hands of the
beneficiary. Such dividend income passed on by the trustees to the
beneficiaries will still remain a dividend income in the hands of the
beneficiaries if the department opts to directly assess the
beneficiaries. Provisions of section 165 indicate that when part
only of the income of the trust is chargeable under the Act, the
beneficiary's share of income should be taken to be derived
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proportionately from the chargeable and non chargeable portions
of the trust income and should be assessed accordingly.
5. Ld. DR, on the other hand, relied on the order of CIT(A) and further
relied upon the ratio of decisions in the cases of Moti Trust Vs. CIT 236 ITR
37(SC); and CIT Vs. Dr. Anand Sarabhai Trust 231 ITR 524 (SC).
6. We have heard rival contentions and perused the material available
on record. The fact that the FVT was already assessed by the department at
Pune at the maximum marginal rate has not been denied by the ld. DR.
Similarly, the assessment in the case of another beneficiary of the same trust
Shri Atul Kirloskar having been finalized u/s 143(3) on 1-12-2011 i.e. prior
to the assessee's assessment dated 29-12-2011 also has not been disputed. In
his case, the beneficial share from the same trust has been allowed to be
exempt being already assessed in the hands of the trust.
6.1. In these circumstances, in our considered view it clearly emerges that
the department has already exercised the option to tax the trust income
directly in the hands of trustees in terms of sections 161 to 166. The fact
that in the case of another beneficiary of the same trust for the same year
i.e. Shri Atul Kirloskar his beneficial income from trust has been held to be
exempt as not includible having been taxed in the hands of trust. Both these
assessments stand testimony to the fact that option has not only been
exercised by the department but it has been also implemented in the case of
other beneficiary. In view of these undisputed facts on record we see no
justification in assessing the amount of beneficial share from trust at Rs.
99,50,000/- in the hands of the assessee again for following reasons:
(i) The assessee's stand is correct that as per the scheme of
assessment of private discretionary trust department has to opt
whether to assesses the income in the hands of trust or beneficiaries.
The option is clearly exercised first in the hands of trust as
demonstrated by its assessment order. This is reconfirmed by the
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assessment of Shri Atul Kirloskar. Thereafter department cannot take
a course to review, reopt or rewrite what has been statutorily exercised
and change its stand from beneficiary to beneficiary.
(ii) In any case it has not been disputed that entire trust income is
from dividends exempt u/s 10(34) and what comes in the hands as
beneficial share retains the same colour and is also exempt u/s 10(34).
Our view is fortified by Hon'ble Supreme court judgment in the case
of Jyotindera Sinhji and other case laws cited by assessee (supra).
Therefore, alternatively also, the beneficial share being part of exempt
dividend income, same is exempt from tax and is to be excluded while
computing the assessee.
(iii) The action taken by the department is contrary to the settled
scheme and interpretation of sections 161 to 164 and CBDT Circular.
the Hon'ble Supreme Court judgment in the case of Kamalini Khatau
(supra) does not support the proposition as applied by the revenue
authorities. In our considered view these undisputed facts support the
case of the assessee.
(iv) The rule of consistency favors the assessee, facts, circumstances
and legal position remaining same and department having already
accepted this position in assesses own case for AY 2006-07 u/s143(3),
we see no reason to break the rule of consistency in this case. Our
views are supported by Hon'ble Supreme court in the case of
Radhsoami Satsang
6.2. In view of the foregoing, on merits and on alternate submissions
assessee deserves to succeed. We, therefore, hold that the department having
already exercised the option to tax the income directly in the hands of the
trust, there is no provision to review the option taken in the case of trust and
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again to change the option from one beneficiary to another, the impugned
income is therefore held to be exempt in the hands of the assessee.
7. In the result, assessee's appeal is allowed.
Order pronounced in open court on 28-04-2014.
Sd/- Sd/-
( J.S. REDDY ) ( R.P. TOLANI )
ACCOUNTANT MEMBER JUDICIAL MEMBER
Dated: 28-04-2014.
MP
Copy to :
1. Assessee
2. AO
3. CIT
4. CIT(A)
5. DR
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