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From the Courts »
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 Deputy Director Of Income Tax Vs. Virage Logic International

ACIT, Circle -33(1) New Delhi. Vs. Shri Anil Nath, 302, Satyam Cinema Building, Ranjit Nagar, New Delhi 110 008.
August, 04th 2015
            IN THE INCOME TAX APPELLATE TRIBUNAL
                 (DELHI BENCH `A' : NEW DELHI)

         BEFORE SHRI R.S. SYAL, ACCOUNTANT MEMBER
                             and
             SHRI A.T. VARKEY, JUDICIAL MEMBER

                           ITA No.3805/Del./2013
                      (ASSESSMENT YEAR : 2007-08)

ACIT, Circle -33(1)            vs.   Shri Anil Nath,
New Delhi.                           302, Satyam Cinema Building,
                                     Ranjit Nagar,
                                     New Delhi ­ 110 008.

                                           (PAN : AAAPN0881A)

      (APPELLANT)                                (RESPONDENT)

                    ASSESSEE BY : Ms. Y. Kakkar, DR
                REVENUE BY : Shri P N Monga, Advocate and
                                Shri Manu Monga

            Date of Hearing                :   06.05.2015
            Date of Pronouncement          :   31.07.2015

                                     ORDER

PER A.T. VARKEY, JUDICIAL MEMBER :


      This appeal filed by the Revenue is directed against the Order dated

05.3.2013 passed by the Ld. CIT(A)-XXVI, New Delhi pertaining to assessment

year 2009-10.

2.    The Revenue has raised the following grounds in its Appeal:-
                                           2
                                                          ITA No.3805/Del./2013

     "1.   The CIT(A) has erred in deleting the addition of
     Rs.6,04,805/- made by the Assessing Officer on account of
     disallowances of bad debts.

     2     The CIT(A) has erred in deleting the addition of
     Rs.2,44,850/- made on account of sundry creditors without
     appreciating that in absence of proper confirmation, genuineness
     of the creditor is not established.

     3     The CIT(A) has erred in deleting addition of Rs.18,36,524/-
     made by the AO on account of proportionate disallowance of
     commission expenses.

     4.    The CIT(A) has erred in deleting addition of Rs.41,600/-
     made by the AO on account of contravention of provisions of
     section 40A(3).

     5.    The CIT(A) has erred in deleting addition of Rs.11,10,028/-
     made by the AO out of salary expenses.

     6.    The Ld. CIT(A) has erred in deleting the addition             of
     Rs.51,707/- made by the AO on account of negative cash balance.

     7.    The appellant craves leave to add, alter or amend any / all of
     the grounds of appeal before or during the course of the appeal."


3.   The brief facts of the case are that the assessee, an individual, is the

proprietor of two concerns namely M/s. Overseas Associates and M/s. Dyechem

Sales Corporation. M/s. Overseas Associates is engaged in the business of

trading in surgical instruments, whereas M/s. Dyechem Sales Corporation is

engaged in the activities of procuring orders on behalf of manufactures of
                                           2
                                        3
                                                            ITA No.3805/Del./2013

chemicals on commission basis. The assessee filed his return of income on

29.9.2009 declaring a total income of Rs.1,66,60,730/-. The case was selected

for scrutiny under CASS. In compliance to the statutory notices served on the

assessee, books of accounts were called for and were verified on test check

basis and the assessment was completed in terms of order u/s 143(3) of the Act

1961 (hereinafter `the Act') at an income of Rs.2,02,33,088/- as against the

returned income of Rs.1,66,60,730/- and made various additions vide order

dated 28.12.2011.


4.      Against the aforesaid order of the Assessing Officer, assessee appealed

before the Ld. CIT(A), who vide his impugned order dated 5.3.2013 has partly

allowed the appeal of the assessee.


5.      Now the Revenue is in appeal before us.


6.      Ld. DR relied upon the order of the AO.


7.      On the contrary, Ld. Counsel of the assessee has relied upon the order of

the Ld. CIT(A) and defended the same and does not want us to interfere in the

same.


8.   We have heard both the parties and perused the records. With regard to

ground no. 1 regarding deletion of addition of Rs. 6,04,805/- made by the AO

on account of disallowances of bad debts is concerned, we find that in the

course of assessment proceedings, the Assessing Officer noticed that the

                                        3
                                         4
                                                              ITA No.3805/Del./2013

assessee had debited a sum of Rs.9.23 lakhs as bad debts. The Assessing Officer

asked the assessee to show whether all the conditions for allowability of bad

debts as per the provisions of section 36(2) and 36(1)(vii) of the Act were

fulfilled. Pursuant to the said query of the AO, the assessee vide letter dated

19.12.2011 filed the details of the parties in whose accounts the amounts were

written off. On perusal of the details, the Assessing Officer noticed that in the

case of the three parties given below, the assessee could not demonstrate as to

how and where the following amounts claimed as bad debts were taken bill-

wise into account in computing assessable income :-


      S.No.         Name of the party                       Amount
      1.            Ajit Hospital                           Rs.    9,083/-
      2.            Aesculap                                Rs. 1,27,722/-
      3.            Gopal Surgical                          Rs. 4,68,000/-
                                                            Rs. 6,04,805/-


Accordingly, the Assessing Officer disallowed an amount of Rs.6,04,805/- the

aggregate of the three aforesaid amounts u/s 36(2) of the Act and added to the

income of the assessee. During the appellate proceeding, the Ld. CIT(A) on

perusal of the material on record, noticed that in response to the query relating

to bad debts amounting to Rs.9,23,393/- appearing in the P&L account, the

assessee had filed all the details of parties and also his explanations vide letters

dated 8.12.2011 and 15.12.2011. It was observed by the Ld. CIT(A) that after

taking on record the details and explanation filed by the assessee, the Assessing
                                         4
                                       5
                                                            ITA No.3805/Del./2013

Officer did not raise any further clarification or enquiry regarding these three

parties whose accounts were squared up by writing off the amounts outstanding

against their names. From the facts on record, Ld. CIT(A) observed that the

assessee had a long business relations with these parties and they were not only

old but valuable customers/suppliers of the assessee who given significant

business to the assessee. The Ld. CIT (A) takes note that the amounts written

off in the case of Ajit Hospital and Gopal Surgical were in respect of sales made

by the assessee to these parties. Whereas, in the case of Aesculap the amount

represented the excess payment made by the assessee to foreign supplier. The

assessee had filed details of bad debts written off with copies of accounts of

debtors of the amounts written off stating that they were business transactions

and we have perused the same which is placed in pages 1 to 19 of the paper

book and finds that the explanation of the assessee is corroborated by the

documents placed on record. Having considered all the facts of the case, we

find that the Assessing Officer was not justified in making the impugned

disallowance as the amounts in question were written off by the assessee in

accordance to section 36(2) and 36(1)(vii) of the Act. Accordingly, the addition

of Rs.6,04,805/- made by the Assessing Officer was rightly deleted by the Ld.

CIT(A), which does not need any interference from our part, hence, we uphold

the same by dismissing the Ground no.1 raised by the Revenue.




                                        5
                                        6
                                                            ITA No.3805/Del./2013

8.1    Apropos Ground 2 regarding the deletion of addition of Rs.2,44,850/-

made on account of sundry creditors. During the course of assessment

proceedings, the Assessing Officer asked the assessee to file confirmation

pertaining loan amount of Rs.2,44,850/- appearing as sundry creditor in the

name of Sh. Amitabh Mendiratta. The Assessing Officer observed that the

assessee merely stated that the amount in question does not pertain to the year

under consideration but did not furnish the confirmation of the creditor.

Therefore, the Assessing Officer treated this sundry creditor as not genuine and

accordingly added this amount to the income of the assessee by holding it as

bogus. During the appellate proceedings, the Ld. CIT(A) has observed that the

Assessing Officer referred to only a part of the reply filed by the assessee dated

15.12.2011 in the course of the assessment proceedings. The contents of the

letter of the assessee dated 15.12.2011 is reproduced :-

      "Your show cause notice in regard to submission of confirmation
      of amount due to Mr. Amitabh Mendirata amounting to
      Rs.2,44,850/- shown under the head Expenses payable.

      It is submitted that the amount pertains to the period 2007-08 and
      not pertain to the year under reference, Mr. Amitabh Mendiratta
      who was associated as retainer up to the period March 2008 and
      left w.e.f 01st April 2008 without getting the final dues which were
      subjected to reconciliation by the proprietor. The due TDS on the
      amount was deposited after deduction. The amount is still payable
      and will be paid immediately the moment the claim is made. Mr.





                                        6
                                       7
                                                          ITA No.3805/Del./2013

      Amitabh Mendiratta who at present is settled abroad and hence the
      confirmation in regard to the amount could not be obtained."


We find that the copy of the account of Amitabh Mendiratta for the period from

01.04.2005 to 31.03.2008 (page 22 of paper book) clearly reflects Rs.2,44,850/-

as due for payment to Amitabh Mendiratta (closing balance). Page 23 of the

paper book is the ledger account of Amitabh Mendiratta for the period

01.04.2008 to 01.03.2009 and it shows the same amount as opening balance.

And page 24 of paper book shows ledger account of Amitabh Mendiratta which

reflects opening balance as Rs.2,44,850/-. We also note that from a perusal of

page 20 reveals that Shri Amitabh Mendiratta had been paid an amount of

Rs.5,93,633/- for retainership in the FY 2005-06 and Rs.6,14,700/- for FY

2006-07; and for FY 2007-08 he was paid Rs.3,91,780/- and Rs.2,44,850/- was

due for him (page 22 of paper book). Thus, the AO's finding that this amount

due to Amitabh Mendiratta is bogus have to fail in the light of the aforesaid

evidences on record. A perusal of the above letter of assessee shows that

Amitabh Mendiratta was a retainer of the assessee who left the institution on

31.03.2008 and went abroad. The amount shown as sundry creditor by the

assessee is the amount due to said Amitabh Mendiratta.        Just because the

assessee could not give the confirmation about the said amount which is due for

Amitabh Mendiratta does not mean that it is a bogus entry made by the assessee.

We find that the AO mis-directed himself by not going through the entire


                                       7
                                       8
                                                           ITA No.3805/Del./2013

explanation given by the assessee in respect to his explanation in respect to the

sundry creditor as observed by the ld. CIT (A). Therefore, considering the facts

of the case, ld CIT(A) has concluded that that there is no justification for the

Assessing Officer to make the impugned addition. Accordingly, he deleted the

addition of Rs. 2,44,850/-, which does not need any interference on our part,

hence, we uphold the same       and dismiss the ground no. 2 raised by the

Revenue.

8.2   Apropos Ground 3 is regarding the deletion              of    addition of

Rs.18,36,524/- made by the AO on account of proportionate disallowance of

commission expenses is concerned, we find that in the course of assessment

proceedings, on perusal of the audit report the Assessing Officer noticed that

though the assessee maintained his accounts on mercantile basis, income from

commission was partly accounted for on receipt basis which was, according to

AO, evident from the commission earned in the account of M/s. Overseas

Associates which clearly showed credit entries of Rs.25,33,952/- dated

05.0.2008, Rs.40,48,271/- dated 27.01.2009, aggregating to Rs.65,82,239/-. The

Assessing Officer observed that this kind of accounting treatment had the effect

of suppressing taxable income while corresponding commission expenses paid

to the sub dealers were claimed on mercantile basis. Accordingly, the Assessing

Officer vide order sheet entry dated 19.11.2011 asked the assessee to show

cause as to why the corresponding commission expenses be not proportionally


                                       8
                                       9
                                                           ITA No.3805/Del./2013

disallowed because commission income was partly accounted for on receipt

basis, when accounts were maintained on mercantile basis. According to the

Assessing Officer, vide reply dated 8.12.2011, the assessee had accepted that

the said amounts were accounted for on receipt basis and stated that the same

were from overseas parties and that no commission was due from the overseas

parties as on 31.3.2009. The Assessing Officer observed that this reply of the

appellant was immaterial. The Assessing Officer observed that the commission

earned in the account of M/s. Overseas Associates clearly showed that the said

amounts of commission income were credited on receipt basis and not when

due. Accordingly, the Assessing Officer worked out proportionate commission

expenses and disallowed an amount of Rs.18,36,524/- out of commission

expenses and added the same to the income of the assessee. We find that the

Ld. CIT(A) has perused the reply of the assessee dated 8.12.2011 which has

been referred by the Assessing Officer in his order. On perusal of the said reply

of the assessee, she finds that the books of accounts were maintained on

mercantile basis in respect of incomes and expenditure; and any commission

due from the parties and any commission due to sub-dealers have been

accounted for on accrual basis. The ld. CIT (A) took note of the fact that the

assessee had fully explained the accounting of the impugned commission

income. According to the ld. CIT (A), the Assessing Officer had failed to

appreciate the correct factual position. The ld. CIT (A) has taken note that the

assessee had accounted for these two amounts in his books of account since
                                       9
                                       10
                                                           ITA No.3805/Del./2013

these had been actually received during the relevant year. The ld. CIT (A) has

observed in respect to commission expenses were concerned, they had been

paid to the assessee's agents in India who had rendered services to the assessee.

The ld. CIT (A) has made a finding that the payments of commissions were

made after deducting corresponding TDS as per law. In the said facts and

circumstances, ld. CIT (A) held that there was no justification for making any

proportionate disallowance out of commission expenses. We have gone through

the bank statement of the assessee i.e. of M/s. Overseas Associates with

Corporation Bank for the period from 01.04.2008 to 26.08.2008 and 24.01.2008

to 03.02.2009 which is placed at page 25 ­ 26 PB, and copy of commission

earned account in the books of the assessee (M/s. Overseas Associates) for the

period 01.04.2008 to 31.03.2009 ­ PB page 27 & 28 and copy of the letter dated

05.12.2011 from Soring, Germany for payment of commission at page 29 PB

and copy of commission paid account for the period 01.04.2008 to 31.03.2009

at page 30 -31 PB and finds no infirmity in the findings of the ld. CIT (A).

Therefore, she has rightly deleted the addition of Rs.18,36,524/- made by the

Assessing Officer out of commission expenses. In the light of the evidence on

record, we do not see any reason to interfere with it; hence, we uphold the same

and dismiss the ground no. 3 raised by the Revenue.


8.3   Apropos ground 4 is relating to deletion of addition of Rs.41,600/- made

by the AO on account of contravention of provisions of section 40A(3) of the


                                       10
                                       11
                                                            ITA No.3805/Del./2013

Act is concerned,   we find that in the assessment proceedings, on examination

of the cash book of M/s Overseas Associates, the AO noticed that the assessee

had made payment of Rs.41,600/- in cash without deducting TDS which was so

liable to be disallowed u/s. 40A(3) of the Act. Therefore, the AO asked the

assessee to show cause to why this payment be not disallowed u/s. 40A(3) of the

Act. The AO observed that the assessee had made only submissions in respect

of payment of Rs. 41,600/- for purchase of gifts for business promotion, so it

was not acceptable. The AO observes that since the assessee failed to furnish

any evidence to prove that these payments did not fall within any of the

exceptions of Rule 6DD, there was a contravention to the provisions laid down

in section 40A(3) of the Act. Therefore, he disallowed the amount of Rs.

41,600/-. However, we find that Ld. CIT(A) found fault with the AO for not

giving any reason as to how this payment contravened section 40A (3) for

purchase of gifts; and not a single payment, and has deleted the addition of

Rs.41,600/- relying upon the assessee's letter dated 8.12.2011 in respect of this

payment stating that the payment was made to an unknown local shop keeper

and it was for purchase of gifts for overseas business associates, as there was no

other alternative but to pay in cash. Ld. CIT(A), considering the practical

problem with the local and small time shopkeepers, justified the cash payment

for purchase of gift and she deleted the addition. In our opinion, the view

adopted by the Ld. CIT(A) is not correct because she was doubting whether the

gift purchase by assessee was for a single transaction on a given day. We find
                                       11
                                       12
                                                           ITA No.3805/Del./2013

on perusal of page 95 of PB, sale bill of gift for RS.41,600/- dated 08.08.2008,

which was paid in cash, so is in contravention of section 40A(3) of the Act.

Therefore, we find that the AO has disallowed the amount of Rs. 41,600/- on

valid ground. In our view, the AO rightly held that since the assessee failed to

furnish any evidence to prove that these payments did not fall within any of the

exceptions of Rule 6DD, there was a contravention to the provisions laid down

in section 40A(3) as stated before. Therefore, in our opinion, the addition made

by the AO amounting to Rs. 41,600/- needs to be upheld, accordingly, we

uphold the action of the AO on this account and allow the Ground No. 4 raised

by the Revenue.

8.4   Apropos ground 5 relating to deletion of addition of Rs. 11,10,028/- made

by the AO out of salary expenses is concerned, we find that in the course of

assessment proceedings, vide order sheet entry dated 29.11.2011, the Assessing

Officer asked the assessee to file the details in respect of salary expenses

amounting to Rs.18,88,656/- with necessary evidence. Since, the appellant did

furnish evidence in respect of salary expenses, vide order sheet entry dated

12.12.2011, the Assessing Officer issued a show cause to the appellant as to

why the salary expenses be not disallowed in the absence of evidence. The

appellant in his reply dated 15.12.2011 filed before the Assessing Officer had

submitted as under:




                                       12
                                       13
                                                           ITA No.3805/Del./2013

       "    It is submitted that the salary register which was being
       maintained on monthly basis for payment of salaries for the year
       under reference is not traceable at present. In support of which we
       are submitting herewith the copies of the appointment letters along
       with the details of payments made to employees on monthly basis
       giving the complete details of the cheque no. dates and bank and
       also salaries paid in cash to few of junior employees as well as
       payment on account of bonus and ex-gratia. That most of the
       payments towards salaries paid are through payees account cheques
       which can be verified with the Bank statement submitted.

              We hope the enclosed details will satisfy you in regard to be
       payment made on account of salaries/ex-gratia/bonus in the year
       under reference."


On perusal of the assessee's reply, the Assessing Officer noted that the

aggregate salary issued by the assessee through cheques worked out to

Rs.15,16,256/- as against Rs.18,88,656/- debited to the P&L account. Therefore,

vide order sheet entry dated 16.12.2011, the Assessing Officer again asked the

assessee to show cause as to why the salary not paid through cheques in respect

of which no evidence in the form of salary register/voucher is filed be not

disallowed. On perusal of the details filed, the Assessing Officer found that

salary aggregating to Rs. 7,82,628/- was paid in cash, which according to him

was liable to be disallowed. Therefore, the Assessing Officer disallowed an

amount of Rs.11,10,020/- (i.e. Rs.7,82,628/- paid in cash and the difference that

worked out amounting to RS.3,27,400/- (i.e. 18,88,656 - 15,61,256) was added
                                       13
                                      14
                                                           ITA No.3805/Del./2013

to the income of the assessee. We find that the Ld. CIT(A) has observed that

Assessing Officer had not made out of case for making the impugned

disallowance and that the Assessing Officer had made vague observation to

disallow a major part of the salary debited to the P&L A/c. According to the Ld

CIT(A) the Assessing Officer had also wrongly worked out the difference of

Rs.3,27,400/-. The Ld CIT(A) notes that the Assessing Officer had not taken

into account the names of all the employees while reproducing the names in

para 9 of his order. According to Ld CIT(A) the Assessing Officer did not give

any clear finding or reasons for making such a disallowance nor brought any

adverse material on record. In the absence of any such adverse material, Ld.

CIT(A) observed that there is no justification for the Assessing Officer to make

such an impugned addition. In the instant case, we find that the AO has

reproduced a chart presented by the assessee in page 5 & 6 of his order. From a

perusal of the said chart, we find that out of 14 employees to whom the assessee

claims to have paid the salary, only 3 were not given salary by cheque. Other 11

employees were paid by account pay cheque and cash.          The assessee had

produced the appointment letters of the said employees and confirmation from

them that they have received the said salary as claimed by the assessee. We

were taken through page 37-94 (PB) were the month wise chart showing details

of salary paid to employees of the assessee for the period from 1.04.2008 to

31.03.2009 along with confirmation and appointment letter of the employee are

on record. In the light of the said evidences, merely because few employees
                                      14
                                       15
                                                           ITA No.3805/Del./2013




have been paid salary as cash cannot justify disallowance unless the AO is able

to bring any adverse material to suggest that the claim of salary incurred by the

assessee is bogus. So the Ld CIT(A) righty deleted the addition of Rs.

RS.11,10,028/-, which does not need any interference on our part, hence, we

uphold the same by dismissing the ground no. 5 raised by the Revenue.


8.5   Apropos ground No. 6 relating to deletion of the addition of Rs. 51,707/-

made by the AO on account of negative cash balance is concerned, we find that

in the course of the assessment proceedings, on examination of the cash book

vis-a-vis bank account statements, the Assessing Officer noticed that the

assessee had shown a withdrawal from Corporation Bank amounting to

Rs.67,000/- dated 28.2.2009, when actually as per the bank statement, the

withdrawal was on 2.3.2009. Therefore, the Assessing Officer observed that the

assessee was trying to mask his negative cash balance with false entries. The

Assessing Officer also noted that the assessee had shown a withdrawal from

Corporation Bank on 2.3.2009 amounting to RS.25,000/-, whereas actually as

per bank statement the withdrawal was on 3.3.2009. Accordingly, the assessee

was asked to show cause as to why the negative cash balance due to cash

withdrawal shown in cash book earlier than the actual withdrawals made from

the banks, as per bank statement be not added to his income. Vide reply dated

8.12.2011, the assessee submitted that entries were made when cheques were

issued. This was observed by the Assessing Officer as the assessee's attempt to


                                       15
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                                                              ITA No.3805/Del./2013

misguide and in his opinion, the cash was to be debited when actually it came in

to cash book and the ensuing negative cash balances due to falsification of

entries were liable to be added to the income of the appellant. Therefore, the

Assessing Officer worked out the ensuing negative balances as under:

Date          Opening       Cash     Book Cash      book    Resultant daily balance
              Balance       debited on the credited    on
                            day by         the day by
28.2.2009     Debit         NIL            Rs. 46,600/-     Negative     balance        Rs.
              balance   Rs.                (Salary and      41,707/-
              4293/-                       imprest
                                           expenses)
1.3.2009      NIL           NIL            Rs. 10000/-      Negative    Balance    Rs.
                                           (Imprest         10,000+41,707=51,707/-
                                           expenses)
2.3.2009      Nil           Actual bank Nil                 Debit balance Rs. 67,200/-
                            withdrawal Rs.
                            67,200/-
3.3.2009                    Actual bank Rs. 20/-            Debit Balance Rs. 92,200/-
                            withdrawal Rs.
                            25,000



Hence, the Assessing Officer worked out the negative balance as aggregating to

(Rs.41,707 + Rs.10,000) Rs.51,707/- and added to the income of the assessee.

Ld. CIT(A) deleted the addition of Rs.51,707/- by relying on a letter of assessee

dated 8.12.2011 wherein she observed that AO did not appreciate the contents

of letter properly and failed to comprehend that what was done was only a

book entry for both credits and debits. According to Ld CIT(A)                        the

disbursement of Rs.46,600/- was only made on 2.3.2009 when the cheque was

encashed. Regarding the amount of Rs.10,000/- the Ld CIT(A) was of the

opinion that it was explained by the assessee that since 1.3.2009, being Sunday


                                        16
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                                                               ITA No.3805/Del./2013

and since the cash was urgently required for expense, the same was provided by

the assessee from his own pocket, therefore, ld. CIT(A) has deleted the addition

of Rs. 51,707/- on this account. Having considered the above factual matrix we

are of the opinion that the finding of CIT(A) cannot be countenanced. The

undisputed position is that there was negative cash balance on 01 November

2009 of Rs. 51,707/-. The basis of CIT (A) that expenditure incurred as per cash

book of Rs. 4,600/- was not actually expended on 28/Feb/2009 is unsupported

by any material. It is an afterthought of the assessee, as cash book has been

maintained and produced in the course of the proceedings. As regards the

explanation of Rs. 10,000/- that the same was incurred out of own sources does

not deserve any merit as it is a more self serving explanation without any basis.

We therefore reverse the conclusion of CIT(A) and uphold the action of AO in

bringing to tax a sum of Rs. 57,707/- as unexplained income of the assessee.

Hence, we confirm the action of the AO on this addition and allow ground no.

6 filed by the Revenue.


9.    In the result, the Revenue's Appeal is partly allowed.


      Order pronounced in the Open Court on 31/07/2015.

          Sd/-
    (R.S. SYAL)                                  (A.T. VARKEY)
ACCOUTNANT MEMBER                            ACCOUNTANT MEMBER

Dated the 31 day of July, 2015
TS


                                       17
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                                       ITA No.3805/Del./2013


Copy forwarded to:
      1.Appellant
      2.Respondent
      3.CIT
      4.CIT(A)-XXVI, New Delhi.
      5.CIT(ITAT), New Delhi.
                                               AR, ITAT
                                             NEW DELHI.




                                  18

 
 
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