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From the Courts »
  Vatsala Shenoy vs. JCIT (Supreme Court)
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 ITO vs. Vikram A. Pradhan (ITAT Mumbai)

Income Tax Officer, Ward-8(1), Room No. 197-A, C.R. Bldg., I.P. Estate, New Delhi Vs. M/s Shakti Securities Pvt. Ltd., 3948, 2nd Floor, Naya Bazar, Delhi
September, 11th 2015
                                                    ITA NO.3475/Del/2009 & 3129/DEL/2010



               IN THE INCOME TAX APPELLATE TRIBUNAL
                      DELHI BENCH "G", NEW DELHI
              BEFORE SHRI H.S. SIDHU, JUDICIAL MEMBER
                                  AND
                SHRI O.P. KANT, ACCOUNTANT MEMBER


                    I.T.A. No. 3475/DEL/2009
                            A.Y. : 2001-02
INCOME TAX OFFICER,                     M/S SHAKTI SECURITIES PVT.
WARD-8(1),                          VS. LTD.,
ROOM NO. 197-A, C.R. BLDG.,             3948, 2ND FLOOR, NAYA BAZAR,
I.P. ESTATE,                            DELHI
NEW DELHI

(APPELLANT)                               (RESPONDENT)

                                  AND
                     I.T.A. NO. 3129/DEL/2010
                            A.Y. : 2002-03
M/S SHAKTI SECURITIES PVT. LTD.,           INCOME    TAX    OFFICER,
3948, 2 ND FLOOR, NAYA BAZAR,         VS. WARD-8(1),
DELHI                                      ROOM   NO.   197-A,  C.R.
                                          BUILDING,
                                          I.P. ESTATE,
                                          NEW DELHI
(APPELLANT)                               (RESPONDENT)

         Assessee by                 :   Shri Kapil Goel, Advocate
        Department by                :   Sh. Sujit Kumar, Sr. DR


                      Date of Hearing : 17-08-2015
                      Date of Order    : 10-09-2015


                             ORDER
PER H.S. SIDHU : JM
     These are two Appeals, one is filed by the Revenue which is
against the Ld. CIT(A) 's   order dated 4.5.2009 for the asstt. year
2001-02 and another is filed by the Assessee aggrieved with the
order of the Ld. CIT(A) 12.5.2010 for the asstt. year 2002-03.                Since

                                    1
                                                   ITA NO.3475/Del/2009 & 3129/DEL/2010




the issues involved in both the appeals            are related to one
assessee,    hence, these appeals are being consolidated by this
common order for the sake of convenience.

2.   The following grounds have been raised in the Revenue's
Appeal for the asstt. year 2001-02.

                 "1.   Ld. CIT(A) erred, in      law and on the facts
                       circumstance of the case, in deleting the
                       addition of Rs. 17,00,000/- made by the AO
                       u/s. 68 of the I.T. Act, 1961.

                 2.    The appellant craves to amend, modify, alter,
                       add or forego    any ground of appeal at any
                       time before or during the hearing of this
                       appeal."

3.   The assessee has raised the following grounds in its Appeal for
the asstt. year 2002-03

     1.     Whether the CIT(A) has failed to appreciate that the
            reassessment proceedings for the year are based on re-
            verification of records submitted in the course of original
            assessment proceedings completed after due scrutiny
            under sec 143 (3) of IT Act, thus not valid.

     2.     Whether the order of the CIT(A) is just and reasonable in
            the facts and circumstances to confirm the order of A.O.
            even when it is pointed out that it is a case of "Change of
            Opinion" on the information already submitted.

     3.     Whether    CIT(A)     has   passed    the      order         without
            appreciation of information already on record, reasons of
            satisfaction   recorded     for    reopening,           and          the


                                    2
                                                       ITA NO.3475/Del/2009 & 3129/DEL/2010




             reassessment order passed by A.O. are all not connected
             with each other.

     4.      Whether the assessee having discharged obligations and
             filed all necessary documents, confirmations at the time
             of original assessment sufficient to meet the satisfaction
             under section 148 proceedings when the assessing officer
             having accepted those confirmation and information in
             original assessment proceedings.

     5.      Whether in the reassessment proceedings the entire
             assessment is thrown open for enquiry or the                       AO is
             required to confirm himself to the reasons recorded for
             the reopening of the assessment.

     6.      Whether the order passed by CIT(A) in the facts and
             circumstances is just, fair and legal."

REVENUE'S APPEAL (A.Y. 2001-02) (ITA NO. 3475/DEL/2009)

4.   The brief facts of the case are that the assessee is an investor
company which is engaged in the business of dealing in shares and
securities. For this year return declaring total income of Rs. 16,290/-
was filed on 31.10.2011. The return was processed u/s. 143(1) but
no scrutiny assessment was made.             Subsequently on the basis of
information received from the office of DIT(Inv.) a notice u/s. 148
was issued after recording of reasons and served on the assessee on
26.3.2008.        In response to that the assessee requested to treat
the original return as the return in response to notice u/s. 148. The
assessment      was   made      u/s.   147   by   order    dated         5.12.2008
determining the total income of Rs. 26,16,290/- and addition of Rs.
26,00,000/- passed u/s. 148/143(3) of the Income Tax Act, 1961.




                                       3
                                                ITA NO.3475/Del/2009 & 3129/DEL/2010




5. Aggrieved with the aforesaid assessment order dated 5.12.2008,
Assessee was in appeal before the      Ld. CIT(A), who vide impugned
order dated 4.5.2009 has deleted the addition in dispute by partly
allowing the appeal of the assessee.

6.   Against the aforesaid order of the Ld. CIT(A), Revenue is in
appeal before the Tribunal.

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

8.    On the other hand, Ld. Counsel for the assessee relied upon
the order of the Ld. CIT(A) and requested that impugned order may
be upheld.

9.    We have heard both the counsel and perused the relevant
records available with us, especially the orders passed by the
Revenue Authority. We find that the Ld. CIT(A) has considered the
Written Submissions of the assessee as well as the documentary
evidence filed by the assessee and decided the issue in dispute in
favour of the assessee. The relevant paragraph i.e. para no. 3.1 to
3.3 at pages 3 to 7 of the impugned order are reproduced hereunder
for the sake of convenience.

             "3.1 The other issue under dispute is addition of Rs 26
             lacs made by the AO u/s 68. On the basis of information
             received from the office of DIT(Inv) the AO was of the
             view that the appellant had received accommodation
             entries from a number of parties. Accordingly the
             appellant was asked to prove the genuineness of
             transaction of receipt of money from Onyx Exim & Sales
             Pvt Ltd, Aay Kay Investments, Deeksha Fincap Securities
             Pvt Ltd, M V Marketing Pvt Ltd, Polo Leasing & Finance
             Pvt Ltd. The appellant's AR filed confirmation, copy of


                                  4
                                                ITA NO.3475/Del/2009 & 3129/DEL/2010




           accounts, share application & some other documents
           with various letters before the AO. The AO required the
           appellant to produce the parties for examination. A show
           cause notice was also issued as to why these amounts
           should not be treated as income of the appellant in
           absence of further explanation. The appellant replied to
           the AO by letter dated 12/11/08 that it was not able to
           produce these parties and the AO may exercise powers
           as provided in law to call the parties directly. The AO
           issued summons to these parties but none of them
           attended. The AO accordingly noted that the appellant
           failed to comply with the requirements of notices and did
           not discharge its onus to prove the genuineness of these
           entries. Therefore he added aggregate amount of Rs 26
           lacs received in respect of seven parties namely Sh
           Shujjit Hussain Mall, Amit Kr Singh, Onyx Exim & Sales
           Pvt Ltd., Krishna Cinema (India), Aay Kay Investment, M V
           Marketing Pvt Ltd and Polo Leasing & Finance P Ltd as
           unexplained credit u/s 68.




                3.2 In the appeal proceedings the appellant's AR
           furnished the details of payments which the AO had
           noted in the order two reasons recorded by him for
           reopening as under:-

S.No.   Party Name                    Amount   Cheque             Date
                                               No.
1       Onyx Exim & Sales Pvt. 300000          61786              05/05/00
        Ltd.
2       Onyx Exim & Sales Pvt. 300000          61786              05/05/00
        Ltd.


                                  5
                                                 ITA NO.3475/Del/2009 & 3129/DEL/2010




3    Swastic         Advertisement 100000       39349              05/05/00
     Agencies
4    Swastic         Advertisement 100000       39349              05/05/00
     Agencies
5    AAY Kay Investment                200000   159478             05/05/00
6    Maa      Shakumbarii      Stone 400000     916362             22/03/00
     Crusher Pvt. Ltd.
7    Maa      Shakumbarii      Stone 400000     916362             22/03/00
     Crusher Pvt. Ltd.
8    Deeksha Fincap Securities 100000           131809             27/03/01
     Pvt. Ltd.
9    Deeksha Fincap Securities 100000           131809             27/03/01
     Pvt. Ltd.
10   MV Marketing                      300000   915527             03/02/01
11   Polo Leasing & Finance Pvt. 300000         535820             13/02/01
     Ltd.



                 It was submitted that all the payment except for Sr
         No 5, 10 & 11 have been considered by the AO twice
         which amounts to double addition. The appellant had in
         fact not received the amount of Rs 26 lacs as alleged by
         the AO but only 17 lacs if the double entries are ignored.
         As      about   the   individual   payments     received           from
         difference parties following explanation was filed:-

         Onyx Exim

                 The sum of Rs 1,50,000 was received against sale
         of 15000 shares of a company Eexpressly Oriental
         Express Pvt Ltd. Total 25000 shares of this company were
         reflected in the balance sheet of the appellant as on

                                   6
                                    ITA NO.3475/Del/2009 & 3129/DEL/2010




31/3/00 and all were sold during the year. The balance
amount of Rs 1,50,000 was repaid to Onyx Exim as
excess amount received. Confirmation and copy of
account was enclosed.

Swastic Advertisement

     Out of 25000 shares of Eexpressly Oriental Express
Pvt Ltd held by the appellant 15000 shares were sold to
Onyx Exim as explained above and balance 10000 shares
were sold to this party. The payment of Rs 1 lac was
received against the sale of these shares. Confirmation
and copy of account was enclosed.

AAY KAY INVESTMENT

     The payment of Rs 2 lacs against sale of shares of
another company KSB holding Pvt Ltd. Shares of this
company were also reflected in the balance sheet of the
appellant as on 31.3.00 which were sold during the year.
Confirmation & copy of account was enclosed.

Maa Shakumbari Stone, M V Marketing Pvt Ltd & Polo
Leasing

     The amount of Rs 4 lacs, 3 lacs & Rs 3 lacs
respectively was received from these parties towards
share application money. Copy of share application form,
confirmation and acknowledgement of return of the said
party was filed.

Deeksha Fincap Securities Pvt Ltd

     Payment from company was also received by way
of share application money. Copy of share application

                        7
                                        ITA NO.3475/Del/2009 & 3129/DEL/2010




form and confirmation was enclosed. , However this
amount was returned to that party by account payee
cheque in the next year on 28/08/01 which fact is also
mentioned in the confirmation letter.

      It was submitted that the relevant documents in
support of the transaction were filed before the AO during
the   assessment    proceedings.   The         appellant's             AR
contended that the AO's observation that the appellant
failed to comply with the notice u/s 142(1) was in correct
because the details required by the AO were duly filed
before him. On the other hand it was contended that the
AO has mentioned in the names of Sujjit Husain Mallick,
Krishna 'Cinema India Ltd and Amit Kr Singh without any
relevance because no payments were received from
these parties during the, year. These parties do not find
mention in the reasons recorded by the AO. This shows
non-application of mind on part of the AO. It was also
contended that in the 147 proceedings the primary onus
was upon the AO to produce some material 0:-
information which could prove that these receipts were
accommodation entries. The assessee has to be given
opportunity to counter or rebut such material or
evidence. However the AO did not confront the appellant
with any evidence or material which could show that the
appellant company had received accommodation entries.
To sum up it was contended that a part of the payment
was towards sale of assets which were reflected in the
balance sheet of the appellant company in the earlier
years and some part was towards share application
money for which necessary evidence was filed. The

                       8
                                      ITA NO.3475/Del/2009 & 3129/DEL/2010




amounts were received by account payee cheques and
were duly reflected in the ledger account of the relevant
parties. Reliance was placed on a number of decisions
including Lovely Exports by Supreme Court to contend
that once the identity of the part was proved addition in
respect of share application money or share capital could
not be made in the case of company.

     3.3 I have carefully considered the submissions
made on behalf of appellant. It is seen from the copy of
reasons recorded in respect of escapement of Rs 20 lacs
that the four instrument Nos have been repeated twice
by the AO. The AO has not mentioned specific amounts
against the parties or the instruments Nos according to
which they have been received. The appellant has
tabulated this information which is shown in para 3.2
above. It is very clear that in respect of four parties at S
No 1, 3, 6 & 8 of     the table, the amounts have been
considered twice. Since the instrument No is same it is
obvious that the entries has been repeated by the AO.
Therefore I agree with the appellant's contention that the
correct amount received by it only Rs 17 lacs and not Rs
23 lacs. Hence addition to the extent of Rs 9 lacs is
deleted forthwith. As regards explanation about the
remaining amount of Rs 17 lacs it is noted that the part
of the amount aggregating to Rs 6 lacs was received
towards sale of shares. which were held by the company
and were duly reflected in its balance sheets. Since it was
not loan/ advance or any credit received by the appellant,
section 68 was not applicable to these receipts. The
balance amount was received towards share application

                       9
                                              ITA NO.3475/Del/2009 & 3129/DEL/2010




money from different parties to one of the parties it was
returned in subsequent years. I agree with the appellant's
contention that in 147 proceedings primary onus was
upon the AO to confront the appellant with evidence or
material   on    the      basis    of    which    allegation           about
escapement of income is made. The appellant has to give
opportunity to rebut or counter the said material. This
has been held by Delhi High Court in the case of Pradeep
Kumar Gupta 207 CTR 115. However the AO did not bring
on record any material or evidence proves that the
various payments received were in the nature of
accommodation entry. Simply the explanation was called
for in response to which the appellant submitted various
documents in support of the transactions. All the
transactions have been carried out through account
payee cheque and confirmations, share application
forms, written acknowledgement of these parties have
been filed. The AO rejected the said explanation merely
on the ground that the summons issued by him was not
responded to. Since the concerned parties were assessed
to   tax   and    their     return      acknowledgements                 were
submitted, the facts could have been verified from their
assessment       records.        The    appellant      has       furnished
sufficient documents to prove the identity of the parties
and therefore in view of the decision of Supreme Court in
the case of Lovely Exports no additions in the company
have been made as regards share application money.
Therefore entire addition of Rs 17 lacs is deleted"




                            10
                                                       ITA NO.3475/Del/2009 & 3129/DEL/2010




9.1   We have thoroughly gone through the aforesaid finding of the
Ld. CIT(A) and we are of the considered view that Ld. CIT(A) has
deleted the addition in dispute after considering             all the relevant
evidences    produced      by   the   assessee,   as      discussed            above.
Therefore, we are of the considered view that no interference is
called for in the well      reasoned order passed by the Ld. CIT(A),
hence, we uphold the order on the issue in dispute by dismissing the
appeal filed by the Revenue.

10.   In the result, the Appeal filed by the Revenue stands
dismissed.

ASSESSEE'S        APPEAL      NO.     3129/Del/2010        (A.Y.          2002-03)-
SHAKTI SECURITIES P LTD.

11.   The brief facts of the case are that the assessee company was
incorporated on 2.5.1996 and has been engaged in the business of
sale and purchase of shares as stock in trade and also as
investments. The return of income was filed on 11.11.02 declaring
total income of Rs. 4,000/-.    The return was processed u/s. 143(1) of
the Act and thereafter the case was selected for scrutiny. The
assessment was completed u/s. 143(3) on 28.2.2005 computing
total income at Rs. 4000/- i.e. as declared by the assessee in its
returned of income. Subsequently, the case was reopened u/s 147
of the Act   by duly     recording reason u/s 148(2) of the Act.                    The
submission   of    the     assessee   were   examined         and        thereafter
assessment was completed u/s. 147/143(3) of the Act on 30.12.2009
computing total income at Rs. 16,04,000/- as against returned
income of Rs. 4000/-.        The only addition include Rs. 16,00,000/-
received from 9 person (including 3 Pvt. Ltd. company and 1 Ltd.
Company and 5 individuals) u/s. 68 of the Act as share application
money, which resulted a demand of Rs. 11,30,940/-.


                                      11
                                                   ITA NO.3475/Del/2009 & 3129/DEL/2010




12.     Aggrieved with the same, assessee filed the Appeal before
the Ld. CIT(A) who vide impugned order dated 12.5.2010 dismissed
the appeal of the assessee.

13.   Against the order of the Ld. CIT(A) dated 12.5.2010, the
assessee is in appeal before the Tribunal.

14.     Ld. Counsel of the assessee reiterated the contention raised in
its Appeal wherein he stated that the reassessment proceedings for
the year are based on re- verification of records submitted in the
course of original assessment proceedings completed after due
scrutiny under sec 143(3) of IT Act, thus not valid. He further
submitted that whether the order of the Ld. CIT(A) is just and
reasonable in the facts and circumstances to confirm the order of
A.O. even when it is pointed out that it is a case of "Change of
Opinion" on the information already submitted; the order passed by
the authorities below is passed without appreciation of information
already on record, reasons of satisfaction recorded for reopening,
and the reassessment order passed by A.O. are all not connected
with each other. He further submitted that assessee had discharged
obligations and filed all necessary documents, confirmations at the
time of original assessment sufficient to meet the satisfaction under
section 148 proceedings when the assessing officer having accepted
those    confirmation   and    information   in   original        assessment
proceedings. To support his contention, he referred the various case
laws of the Delhi High Court by which the         present case of the
assessee is covered including the case of Signature Hotel Pvt. Ltd.
(2011) 338 ITR 51. He further relied upon the ITAT, `C' Bench, Delhi
in which on the similar facts and circumstances the issue in dispute
has been dealt by the Tribunal in the case of Shri Govind Kripa
Builders and Promoters vs. ITO passed in ITA No. 304/Del/2013 (AY
2008-09) vide order dated 19.12.2014 in which Hotel Signatures Pvt.

                                   12
                                                  ITA NO.3475/Del/2009 & 3129/DEL/2010




Ltd. decision (supra) was followed.      Later the Department went in
Appeal before the Delhi High Court, in ITA No. 486/2015 in the case
of Pr. CIT vs. Sh. Govind Kripa Builders Pvt. Ltd. which was dismissed
on 4.8.2015 by the Hon'ble High Court of Delhi.                   Hence, he
requested that the reassessment proceedings may be quashed.

15.   On the other hand, Ld. DR relied upon the order passed by the
Ld. CIT(A) on the issue in dispute.

16.   We have heard both the parties and perused the records. We
find that the AO has recorded the reasons for belief that income
has escaped assessment as under. The same is attached with the
Paper Book filed by the assessee.

           "Reasons for belief that income has escaped assessment:

           Return of income declaring an income of Rs. 4,000/- was
           filed on 11.11.2002. The assessment was completed u/s.
           143(3) on 28.2.2005 in the income declared accepted.
           However, an information was received from DIT(Inv.) that
           the assessee was a beneficiary of in respect of Rs. 34.50
           lacs received from various parties which were in the
           nature of accommodation entries. A copy of the extract of
           information is enclosed for ready reference.




                I have, therefore, reasons to believe that the
           income to the extent of Rs. 24.50 lacs has escaped
           assessment by reason of         failure on the part of the
           assessee to disclose fully and truly all material facts
           necessary for assessment. In view of the above, it is
           requested to kindly accord approval u/s. 151 of the I.T.
           Act for issuance of notice u/s. 148 for AY 2002-03."




                                    13
                                                           ITA NO.3475/Del/2009 & 3129/DEL/2010




16.1 We find considerable cogency in the submissions of the Ld.
Counsel of the assessee that the facts and circumstances of the
present case are similar and identical to that of case of Shri Govind
Kripa Builders and Promoters vs. ITO,               decided by the `C' Bench,
ITAT, New Delhi in ITA No. 304/Del/2013 (AY 2008-09) vide order
dated 19.12.2014 (in which one of the Judicial Member was the
Party), wherein the Hotel Signatures Pvt. Ltd. (Supra) decision of
the    Delhi High Court was followed.                Against the order dated
19.12.2014 of the Tribunal, the Department went in Appeal before
the Hon'ble Delhi High Court, in ITA No. 486/2015 in the case of Pr.
CIT vs. Sh. Govind Kripa Builders Pvt. Ltd. and the Hon'ble High
Court of Delhi vide its order dated 04.8.2015 has observed as
under:-

            "3.     It is seen that the ITAT has in the impugned order
                    dated 19th December, 2014 passed in ITA No.
                    304/Del/2013 for the Assessment Year 2008-09
                    relied upon the judgment of this Court in Signature
                    Hotels P. Ltd., vs. ITO [2011] 338 ITR 51 (Delhi) and
                    come to the conclusion that the AO did not apply his
                    own mind to the information and the materials
                    forming the basis of the information.

            4.      The Court finds        no legal error whatsoever in the
                    ITAT coming to the above conclusion. In the facts
                    and     circumstances      of    the   present           case,        no
                    substantial question of law arises for determination
                    by the Court."

16.2   We    also    find    from    the    records     that     earlier        scrutiny
assessment u/s. 143(3) was completed vide order dated 28.2.2005
and (ii) four years have elapsed on date of instant reopening


                                       14
                                                     ITA NO.3475/Del/2009 & 3129/DEL/2010




(23.3.2009) and (iii) in reasons recorded allegation was made for
income escaping assessment of Rs. 24.50 lacs as mentioned on
page no. 1 of the impugned order also whereas income escaping
assessment was found to be Rs. 16 lacs in the very same order. On
these reasons merely based on investigation wing information
without surveillance of substantiation and without any statement
being mentioned therein and without nature of transaction being
narrated therein and without tangible material, and further without
application of mind on amount of income escaping assessment,
shows that the reopening is bad in law and needs to be quashed.

16.3 In the background of the aforesaid discussions, we are of the
considered view that only effective ground in this appeal is
reassessment proceedings u/s. 148 of the I.T. Act, the Assessee has
reiterated that reassessment    proceedings are illegal and without
jurisdiction in the absence of any tangible evidence or material in
respect of any undisclosed income and recording of requisite
satisfaction in respect of any such undisclosed income. After hearing
both the parties on the issue in dispute as well as after going
through   the orders passed by the Revenue Authorities alongwith
order   dated 21.7.2011 passed by the Hon'ble Jurisdictional High
Court in the case of Signature Hotels P. Ltd. vs. Income Tax Officer
[2011] 338 ITR 0051 wherein the Hon'ble             High Court has held
matter as under:-

                "Held, allowing the petition, that the reassessment

                proceeding     were     initiated    on      the        basis        of

                information received from the Director of Income

                Tax   (Investigation)     that      the     petitioner            had

                introduced money amounting to Rs. 5 lacs during


                                 15
                                                     ITA NO.3475/Del/2009 & 3129/DEL/2010




                  the financial year 2002-03 as stated in the

                  Annexure.     According to the information, the

                  amount received from a company, S, was nothing

                  but an accommodation entry and the assesee was

                  the beneficiary.      The reasons did not satisfy the

                  requirements of Section 147 of the Act. There was

                  no reference to any document or statement, except

                  the annexure. The annexure could not be regarded

                  as a material or evidence that prima facie showed

                  or established        nexus or link which disclosed

                  escapement of income.          The annexure was not a

                  pointer and did not indicate escapement of income.

                  Further, the Assessing Officer did not apply his own

                  mind to the information and examine the basis and

                  material of the information. There was no dispute

                  that the company, S, had a paid-up capital of Rs. 90

                  lakhs and was incorporated on January 4, 1989, and

                  was also allotted a permanent account number in

                  September, 2001. Thus, it could not be held to be a

                  fictitious person.        The reassessment proceedings

                  were not valid and were lliable to be quashed."

17.     In view of above, we are of the considered view that above

issue    is exactly the   similar to the issue involved in the present

                                       16
                                                     ITA NO.3475/Del/2009 & 3129/DEL/2010




appeal and is squarely covered by the aforesaid decision of the

Hon'ble High Court of Delhi delivered in Hotel Signatures Ltd.

(Supra). Hence, respectfully following the above precedent, we

decide the legal issue in dispute in favour of the Assessee and

against the Revenue and accordingly quash the reassessment

proceedings. The other issues are not dealt with as the same have

become academic in nature.


18.   In the result, the Revenue's Appeal No. 3475/Del/2009 (AY

2001-02)        stands   dismissed   and   the   Assessee's        Appeal          No.

3129/Del/2010 (AY 2002-03) stands allowed.


      Order pronounced in the Open Court on 10/9/2015.

      Sd/-                                                      Sd/-

[O.P. KANT]                                           [H.S. SIDHU]
ACCOUNTANT MEMBER                                  JUDICIAL MEMBER

Date 10/9/2015
"SRBHATNAGAR"
Copy forwarded to: -
1.    Appellant -

2.    Respondent -
3.    CIT
4.    CIT (A)
5.    DR, ITAT            TRUE COPY
                                                      By Order,



                                                      Assistant Registrar,
                                                      ITAT, Delhi Benches


                                      17

 
 
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