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 Income Tax Addition Made Towards Unsubstantiated Share Capital Is Eligible For Section 80-IC Deduction: Delhi High Court

Shri Sunil Gupta, B-346, Rajendra Nagar, Bareilly. vs Shri Sunil Gupta, B-346, Rajendra Nagar, Bareilly.
May, 07th 2019

Subject: For the sake of convenience, all the three appeals were heard together and are being disposed of by this common order.

Referred Sections:
Section 68 of the IT Act.
Section 153B of the Act

Referred Cases / Judgments
ACITvs. Sarvmangalam Builders & Developers Pvt. Ltd., vide ITA No.196 to 198/Del/2011

         IN THE INCOME TAX APPELLATE TRIBUNAL
               DELHI BENCH : F : NEW DELHI

     BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER
                         AND
        MS SUCHITRA KAMBLE, JUDICIAL MEMBER
                        ITA Nos.3245, 3248 & 3250/Del/2013
                    Assessment Years: 2005-06, 2009-10 & 2010-11

Ramprastha Builders Pvt. Ltd.,             Vs     DCIT,
B-23-25, Kailash Colony,                          Central Circle-14,
New Delhi.                                        New Delhi.

PAN: AADCR3877N

      (Appellant)                           (Respondent)

            Assessee by              :      Shri Rajesh Jain, CA
            Revenue by               :      Shri Kanwaljit Singh, CIT, DR

            Date of Hearing       :         14.02.2019
            Date of Pronouncement :         07.05.2019

                                         ORDER

PER R.K. PANDA, AM:

      The above three appeals filed by the assessee are directed against the separate

orders of the CIT(A)-23, New Delhi, relating to assessment years 2005-06, 2009-10

and 2010-11, respectively. For the sake of convenience, all the three appeals were

heard together and are being disposed of by this common order.

ITA No.3245/Del/2013 (A.Y. 2005-06)

2.    Facts of the case, in brief, are that the assessee is a company. A search and

seizure operation u/s 132 of the IT Act, 1961 was conducted by the Investigation Wing
                                                           ITA Nos.3245, 3248 & 3250/Del/2013


of the Department on 30th July, 2009 in the Ramprastha group of cases. The business

premises of the assessee company situated at B-23-25, Kailash Colony, New Delhi,

Gurgaon was also covered u/s 132(1) of the IT Act. In response to notice u/s 153A of

the IT Act issued on 11th May, 2011, the assessee filed its return of income declaring

an income of Rs.1,01,98,710/- on 31st May, 2010.

3.    The Assessing Officer noted that during the examination of books of account

and seized material, it was noticed that as per page 114 to 118, Annexure A-6/Party

A.O.-6 which is a summary of draft verification report by Company Law Board

auditors on the issue of     diversion/siphoning of funds of Ramprastha group of

companies, in the heading of sum of money mentioned in the agreements/documents

verified by the auditor but not reflected in the books of account, it was mentioned that

RBPL has given advance to Shyam Sunder Charitable Trust for purchase of land in

Village Chajarsi, Gautam Budh Nagar. The said trust did not transfer the land as per

the agreement and M/s Ramprastha Builders Pvt. Ltd., has filed a case in the Court of

Civil Judge, Gautam Budh Nagar.        On going through the Petition filed by Shri

Balwant Singh on behalf of the assessee company, it was noticed that M/s Ramprastha

Builders Pvt. Ltd., has paid a sum of Rs.50 lakhs on 20th January, 2005 to the said

Trust which is not reflected in the books of M/s Ramprastha Builders Pvt. Ltd. It has

further been mentioned that M/s Ramprastha Builders pvt. Ltd. has purchased land

measuring 1 Bigha, 15 Biswa at Village Chajarsi, District Gautam Budh Nagar.

However, all the documents of purchase of land are in favour of Shri Surat Singh,


                                           2
                                                           ITA Nos.3245, 3248 & 3250/Del/2013


Director of M/s Ramprastha Builders Pvt. Ltd. The Assessing Officer, therefore,

asked the assessee to explain as to why the amount of Rs.50 lakhs advanced to M/s

Shyam Sunder Charitable Trust towards advance for purchase of land and not reflected

in the books of account may not be added to its income. He further mentioned in the

said notice that this payment has been made on 20th January, 2005. The assessee in its

reply submitted that it has made a payment of advance of Rs.50 lakhs to M/s Shyam

Sundar Charitable Trust towards advance for purchase of land. The matter is pending

in the Court of law. The advance amount was received from other party and the

journal entry could not be passed due to some oversight.


4.    The Assessing Officer noted from the reply filed by the assessee that the

assessee has received the advance amount from other party and journal entry could not

be passed due to some oversight, but, no evidence in support of this contention was

furnished. He, therefore, treated the argument of the assessee as vague and without

any support. Since the advance of Rs.50 lakhs has been given to Shyam Sundar

Charitable Trust on 20th January, 2005 and has been admitted by the assessee and

since no source of this money/advance was explained, the Assessing Officer made

addition of Rs.50 lakhs invoking the provisions of section 68 of the IT Act. The

Assessing Officer has also made another addition of Rs.1,98,060/-. However, the

assessee is not in appeal on this issue. Therefore, we are not concerned with the same.

Thus, the Assessing Officer determined the total income of the assessee at

Rs.1,53,96,770/-.


                                          3
                                                              ITA Nos.3245, 3248 & 3250/Del/2013


5.    Before the CIT(A), the assessee challenged the validity of the assessment on the

ground that no incriminating documents has been seized u/s 132(1) of the Act and the

documents relied by the Assessing Officer for making the addition in the assessment

u/s 153A/143(3) of the Act were duly accounted for in the regular books of account.

The assessee has also challenged the addition on merit. However, the ld.CIT(A)

rejected both the issues. So far as the legal ground is concerned, he held that there is

incriminating seized documents on the basis of which the addition of Rs.50 lakhs was

made. Therefore, the legal ground raised by the assessee is not sustainable. So far as

the merit of the case is concerned, he also dismissed the ground raised by the assessee

by observing as under:-

     "I have considered the assessment order and written submission of Ld. AR. As
     per the document seized referred in the assessment, namely, page no. 114 to 118,
     Annexure A6/Party AO-6, which is the verification report of Company Law
     Board stating that the appellant company has paid Rs. 50 lacs on 20.01.2005 to
     M/s Shyam Sunder charitable Trust. Therefore, payment made by the appellant
     company is conclusive. During assessment proceedings, the appellant company
     has not objected the truthfulness of the payment. The appellant company has
     contended that it has received advance from various persons for making advance
     of Rs. 50 lacs to M/s Shyam Sunder Charitable Trust and necessary entries could
     not be made. Now, at appellant stage, Ld. AR is taking the stand that Rs. 50 lacs
     was only paid and the matter is subjudice and balance Rs. 50 lacs was not paid.
     As per seized material the payment is Rs 50 lacs alongwith specific date.
     Therefore, the question of total payment and balance payment does not arise. The
     fact is Rs. 50 lacs as per the seized document was paid by the appellant company
     which is not recorded in the books of accounts. Hence, the source remains
     unexplained. Keeping the entire facts and circumstances of the case, I confirm
     the addition made by A.O. to the tune of Rs. 50 lacs. This ground of appeal is
     hereby dismissed."




                                             4
                                                              ITA Nos.3245, 3248 & 3250/Del/2013


6.     Aggrieved with such order of the CIT(A), the assessee is in appeal before the

Tribunal by raising the following grounds:-

     "1.      That the learned CIT(A) erred in upholding the validity of the
     Assessment Order passed u/s 153A/143(3) of the Act in spite of the fact that no
     search u/s132(1) of the Act was initiated on the appellant or documents or any
     assets of the appellant were requisitioned u/s 132A of the Act

     Without Prejudice to Ground No.1 above,

     2.      That the Learned CIT(A) fails to appreciate the fact that the appellant
     company has already been assessed u/s 143(3) of the Act vide Assessment Order
     dt.02 Nov, 2007 and addition of Rs.3,49,475/- was made on account of
     unexplained creditors and therefore, assessment now made u/s153A /143(3) of
     the Act on different income, without reference to any seized document, is not
     valid and against the various judicial precedents.

     3.       That the Learned CIT(A) erred in upholding addition of Rs.51,98,060/-
     in spite of the fact that no incriminating document has been seized u/s 132(1) of
     the Act and the documents relied by the Assessing Officer for making addition in
     the Assessment u/s 153A/143(3) of the Act, were duly accounted for in the
     regular books of accounts.

     4.      That the Learned CIT(A) erred in upholding addition of Rs.50,00,000/-
     on account of advance to M/s Shyam Sunder Charitable Trust without
     considering the facts of the case and without giving adequate opportunity to the
     appellant to justify its claim.

     5.      That the Learned CIT(A) erred in upholding the contentions of
     Assessing Officer in challenging the genuineness of the various liabilities
     amounting to Rs.1,98,060/- shown under the head "Current Liabilities" by the
     appellant as the said amounts were received in the preceding years.

     6.      That the Learned CIT(A) erred in upholding the Assessment u/s
     153A/143(3) of the Act without giving reasonable opportunity of being heard to
     the appellant.






     7.      That there was no justification for levying of interest u/s 234A and 234B
     of the Act on the facts and circumstances of the case and as per Law.

     8.      Without prejudice to the Ground No. 7, interest u/s 234A and 234B of
     the Act has been wrongly calculated as the starting date for calculation should
     have been the date of Assessment Order u/s 143(3) of the Act. The credit for the
     tax paid has been given only for Rs.35,38,184/- against Rs.38,67,221/-(including
     Rs. 2,71,929/- paid as regular assessment.

                                             5
                                                               ITA Nos.3245, 3248 & 3250/Del/2013




     9.       That the appellant craves leave to add to, alter, amend, modify,
     substitute, delete and/or rescind all or any of the Grounds of Appeal on/or before
     the final hearing.

     10.     That the Orders of the Assessing Officer & CIT(Appeals) are not based
     on the facts of the case & as per law and hence additions sustained by the
     CIT(Appeals) are totally illegal and not based on binding judicial precedents."

7.    The ld. counsel for the assessee strongly challenged the order of the CIT(A).

He submitted that the original assessment in this case was completed u/s 143(3) of the

Act on a total income of Rs.1,01,98,710/- on 2nd November, 2007 against the returned

income of Rs.96,69,150/-. A search and seizure operation u/s 132(1) of the Act was

conducted on 30th July, 2009 on Ramprastha Group of Companies whose registered

offices were located at C-10, C Block Market, Vasant Vihar, New Delhi and their

corporate office at 114, Sector-44, Gurgaon. He submitted that the registered office of

the assessee company i.e., Ramprastha Builders Pvt. Ltd. is at B-23, 25 Kailash

Colony, New Delhi and corporate office is at C-165, Ramprastha Colony, Ghaziabad.

There is no other place of business of the said company in Delhi or any other place in

India. He submitted that only a survey action u/s 133A of the Act was conducted at B-

23, 25 Kailash Colony, New Delhi and at corporate office at C-165, Ramprastha

Colony, Ghaziabad. Therefore, when there was no search at the premises of the

assessee at B-23, 25 Kailash Colony, New Delhi, u/s 132(1) of the Act as there is no

Panchnama other than the Panchnama prepared u/s 133A, therefore, the Assessing

Officer could not have completed the assessment u/s 153A/143(3). He submitted that

during the appellate proceedings before the CIT(A), the assessee has challenged the


                                             6
                                                            ITA Nos.3245, 3248 & 3250/Del/2013


validity of the assessment order u/s 153A as there was no search u/s 132(1) of the Act

on any of the business premises of the assessee company and only survey proceedings

u/s 133A of the Act was conducted. However, the ld.CIT(A) without any valid

reasons, has upheld the action of the Assessing Officer.


7.1   Referring to the decision of the Delhi Bench of the Tribunal in the case of ACIT

vs. Sarvmangalam Builders & Developers Pvt. Ltd., vide ITA No.196 to 198/Del/2011

and vice versa, he submitted that the Tribunal has held that since no search was

conducted in the premises of the assessee and the search conducted on the premises

not owned by the assessee therefore the proceedings u/s 153A of the Act are invalid

and bad in law. He submitted that the above decision of the Tribunal has been upheld

by the Delhi High Court vide ITA 943 to 945/2015. He also relied on various other

decisions filed in the paper book and submitted that when there is no search took place

and only survey u/s 133A was conducted, the assessment u/s 153A/143(3) is invalid,

illegal and void ab initio.

7.2   So far as the merit of the case is concerned, he submitted that the audit report as

mentioned by the Assessing Officer is only a draft audit report without any signature

which was found during the course of the survey. He submitted that the original

assessment u/s 143(3) was completed before the survey took place, therefore, that

assessment order can be disturbed only when some incriminating material or

document is found or comes to the notice of the Assessing Officer. He submitted that

the draft audit report cannot be called as an incriminating document at all because it is

                                           7
                                                             ITA Nos.3245, 3248 & 3250/Del/2013


an unsigned document or audit report and, therefore, much credence cannot be given

to the same. Referring to page 129 of the paper book, he submitted that the auditors

M/s K.C. Jain & Co. has written to the directors of Ramprastha Builders Pvt. Ltd. that

it is only a draft report and they have asked for the comments on the same. He

accordingly submitted that the draft audit report cannot be called as incriminating

material. Otherwise also, the ld. counsel for the assessee submitted that the audit report

was found and seized during the course of survey u/s 133A of the Act on the corporate

office of the assessee situated at C-165, Ramprastha Colony, Ghaziabad. Referring to

page 108 of the paper book, he submitted that as per the petition filed by Shri Balwant

Singh, Director, on behalf of the RBPL, it is mentioned therein that a total sum of Rs.1

crore has been paid to the said trust the details of which are as under:-

     Cheque No./Pay Order           Date                      Amount (Rs.)
     898503 (Cheque)                27/01/2005                5,000,000
     589557 (Pay Order)             27/01/2005                1,000,000
     589558 (Pay Order)             27/01/2005                1,000,000
     589559 (Pay Order)             27/01/2005                1,000,000
     589560 (Pay Order)             27/01/2005                1,000,000
     589561 (Pay Order)             27/01/2005                1,000,000


8.    The above amount of Rs.50 lakhs paid by five pay orders has not been found to

be recorded in the books of account of RBPL. Referring to the audit report, he

submitted that neither any document has been seized during the course of survey

which incorporates such details nor the draft audit report explains from which



                                            8
                                                           ITA Nos.3245, 3248 & 3250/Del/2013


document the said details were procured. He accordingly submitted that both legally as

well as factually the addition is not sustainable.


9.    The ld. DR, on the other hand, heavily relied on the order of the CIT(A). He

submitted that the name of the assessee is appearing in the warrant of authorization u/s

132 of the Act. As per the Panchnama prepared after execution of search warrant at

the premises 7/27, South Patel Nagar, New Delhi, the name of the appellant is not

appearing in the Panchnama. He submitted that the statement of the director was

recorded u/s 132(4) with respect to all group concerns including the assessee wherein

he surrendered the undisclosed income of Rs.52 crores in various entities including the

assessee. Survey action u/s 133A has been conducted at the other premises of the

assessee. Therefore, it cannot be said that no search has taken place in the case of the

assessee. Further, the issue of validity of search was never raised in the assessment

proceedings. Referring to various decisions, he submitted that the assessee just wants

to scuttle the search proceedings by creating a technical issue which cannot be

considered at this stage. He submitted that the draft audit report was found during the

course of survey where the auditors have mentioned regarding the payment of Rs.50

lakhs made to the Trust for purchase of land. The above land is not reflected in the

books of account of the assessee, therefore, when the assessee was unable to explain

the source of such payment, the addition made u/s 68 of the Act of Rs.50 lakhs by the

Assessing Officer and upheld by the CIT(A) is fully justified in the facts and

circumstances of the case.


                                             9
                                                          ITA Nos.3245, 3248 & 3250/Del/2013


10.   We have considered the rival arguments made by both the sides and perused the

orders of the authorities below. We find when the appeals for assessment years 2004-

05, 2006-07 and 2008-09 were argued by the counsel for the assessee before the

Tribunal, it was argued that the additions made in the assessment without having any

reference to any incriminating material seized during the course of search, such

additions cannot be sustained. Once the assessee has argued before the Tribunal that

no incriminating material was found during the course of search, no addition can be

made for which it got relief. Now it cannot backtrack and say that no search has taken

place in the case of the assessee and only survey action was conducted u/s 153A. We,

therefore, dismiss the legal ground raised by the assessee challenging the validity of

assessment framed u/s 153A/143(3).


11.   So far as the merit of the case is concerned, no doubt, the same is made on the

basis of a draft verification report. We find some force in the argument of the ld.

counsel for the assessee that it is not understood as to from where the auditors got

these figures and they have not explained from which document the said details were

procured. No such document was also seized during the course of search which

incorporates such details. The auditors have simply asked for some comments from

the assessee. However, what comments were given by the assessee was neither found

in the draft audit report nor the Assessing Officer asked during the course of

assessment proceedings regarding the comments of the assessee. It is also pertinent to

mention here that during the course of assessment proceedings, the assessee had


                                         10
                                                                ITA Nos.3245, 3248 & 3250/Del/2013


submitted that he had obtained certain amount from others which was given to the

trust towards purchase of land and journal entries could not be passed. Since such

details were not provided during the course of assessment proceedings, the Assessing

Officer made addition u/s 68 of the IT Act which has been upheld by the CIT(A).

Considering the totality of the facts of the case and in the interest of justice, we deem

it proper to restore the issue to the file of the Assessing Officer with a direction to give

an opportunity to the assessee to substantiate the source of the amount of Rs.50 lakhs

paid as advance towards purchase of land. The Assessing Officer shall decide the

issue as per fact and law, after giving due opportunity of being heard to the assessee.

We hold and direct accordingly. The grounds on merit are accordingly allowed for

statistical pruposes.


ITA No.3248/Del/2013 (A.Y. 2009-10)

12.    The grounds raised by the assessee are as under:-

      "1.      That the learned CIT(A) erred in upholding the validity of the
      Assessment Order passed u/s 153A/143(3) of the Act in spite of the fact that no
      search u/s132(1) of the Act was initiated on the appellant or documents or any
      assets of the appellant were requisitioned u/s 132A of the Act






      Without Prejudice to Ground No.1 above,

      2.       That the Learned CIT(A) erred in upholding addition of Rs.8,94,487/-
      (actual total of different amounts mentioned in the assessment order comes to
      Rs.4,40,012/-) in spite of the fact that no incriminating document has been seized
      u/s 132(1) of the Act and the documents relied by the Assessing Officer for
      making addition in the Assessment u/s 153A/143(3) of the Act, were duly
      accounted for in the regular books of accounts.

      3.      That the Learned CIT(A) erred in upholding the contentions of
      Assessing Officer for challenging the genuineness of the various liabilities

                                              11
                                                                  ITA Nos.3245, 3248 & 3250/Del/2013


      amounting to Rs.8,94,487/- (Actual total of different amounts mentioned is the
      Assessment order comes to Rs.4,40,012/-) shown under the head "Current
      Liabilities" by the appellant as the said amounts were received in the preceding
      years.

      4.      Without prejudice to ground No.2 &3, that the ld. CIT(A) erred in not
      giving relief even in relation to arithmetical error of addition of Rs.8,94,487/- in
      place of Rs.4,40,012/- (actual total of different amounts mentioned in the
      Assessment Order comes to Rs.4,40,012/-)

      5.      That the Learned CIT(A) erred in upholding the Assessment u/s
      153A/143(3) of the Act without giving reasonable opportunity of being heard to
      the appellant.

      6.      That there was no justification for levying of interest u/s 234A and 234B
      of the Act on the facts and circumstances of the case and as per Law.

      7.       Without prejudice to the Ground No. 6, interest u/s 234A and 234B of
      the Act has been wrongly calculated as the starting date for calculation should
      have been the date of Intimation Order 143(1) of the Act. The credit for the tax
      paid has been given only for Rs.2,14,22,938/- against Rs.2,28,75,485/- paid by
      the assessee.

      8.       That the appellant craves leave to add to, alter, amend, modify,
      substitute, delete and/or rescind all or any of the Grounds of Appeal on/or before
      the final hearing.

      9.      That the Orders of the Assessing Officer & CIT(Appeals) are not based
      on the facts of the case & as per law and hence additions sustained by the
      CIT(Appeals) are totally illegal and not based on binding judicial precedents."


13.    So far as ground of appeal No.1 is concerned, the same is inter-connected to the

ground raised in assessment year 2005-06. We have already decided the issue against

the assessee. Following the same reasoning, this ground raised by the assessee is

dismissed.


14.    So far as the second ground is concerned, i.e., the addition of Rs.8,94,487/- is

concerned, it is the case of the ld. counsel that there is a calculation error. We,


                                               12
                                                                  ITA Nos.3245, 3248 & 3250/Del/2013


therefore, restore this issue to the file of the Assessing Officer with a direction to

verify the arithmetical error in addition and pass suitable order. Needless to say, the

Assessing Officer shall decide the issue after affording a reasonable opportunity of

being heard to the assessee and decide the issue as per fact and law. So far as levy of

interest u/s 234A and 234B is concerned, it is the case of the ld. counsel for the

assessee that there is some calculation error and less credit of tax. We, therefore,

deem it proper to restore this issue also to the file of the Assessing Officer with a

direction to verify the correctness of the interest calculation after giving due

opportunity of being heard to the assessee. The grounds raised by the assessee are

accordingly partly allowed for statistical purposes.


ITA No.3250/Del/2013 (A.Y. 2010-11)

15.    The grounds raised by the assessee are as under:-

      "1.     That the learned CIT(A) erred in upholding the validity of the
      Assessment Order passed u/s 143(3) of the Act in accordance with Section 153B
      of the Act in spite of the fact that no search u/s132(1) of the Act was initiated on
      the appellant or documents or any assets of the appellant were requisitioned u/s
      132A of the Act

      Without Prejudice to Ground No.1 above,

      2.       That there was no justification for levying of interest u/s 234B of the Act
      on the facts and circumstances of the case and as per Law.

      3.      Without prejudice to the Ground No. 2, interest u/s 234A and 234B of
      the Act has been wrongly calculated as credit of seized cash of Rs.50 lacs which
      was to be adjusted as advance tax as requested by the appellant was not
      considered.

      4.        Without prejudice to ground No.3 above, that the ld. CIT(A) erred in
      not adjudicating ground of appeal wherein the appellant was aggrieved as the
      Assessing Officer erred in not providing credit for the tax paid against

                                               13
                                                                ITA Nos.3245, 3248 & 3250/Del/2013


      Rs.2,11,95,392/- (including Rs.50,00,000/-) seized by the search party for which
      adjustment for advance tax was made by the assessee.

      5.       That the appellant craves leave to add to, alter, amend, modify,
      substitute, delete and/or rescind all or any of the Grounds of Appeal on/or before
      the final hearing.

      6.      That the Orders of the Assessing Officer & CIT(Appeals) are not based
      on the facts of the case & as per law and hence additions sustained by the
      CIT(Appeals) are totally illegal and not based on binding judicial precedents."


16.    The ld. counsel for the assessee did not press ground Nos.1, 2 and 3 for which

ld. DR has no objection. Accordingly, these grounds are dismissed.


17.    So far as ground No.4 is concerned, it is the grievance of the assessee that credit

for tax paid against Rs.2,11,95,392/- seized by the search party was not treated as

advance tax. In view of the CBDT Circular issued on 12th June, 2017 and decision of

various High Courts as well as the coordinate Benches of the Tribunal whenever any

amount is seized during the course of search and the assessee moves an application for

treating such amount seized as payment towards advance tax, the same has to be

considered as tax paid by the assessee as advance tax from the date of making such

application. Since, in the instant case, the assessee has moved an application for

treating the seized cash as payment towards advance tax, therefore, we are of the

considered opinion that the grievance of the assessee is justified.              We find the

ld.CIT(A) has not adjudicated this ground although specifically raised before him.

We, therefore, deem it appropriate to restore this issue to the file of the CIT(A) with a

direction to decide the issue as per fact and law, after giving due opportunity of being



                                              14
                                                             ITA Nos.3245, 3248 & 3250/Del/2013


heard to the assessee. We hold and direct accordingly. The grounds raised by the

assessee are accordingly partly allowed for statistical purposes.


18.      In the result, all the three appeals filed by the assessee are partly allowed for

statistical purposes.

        The decision was pronounced in the open court on 07.05.2019.

             Sd/-                                                           Sd/-

(SUCHITRA KAMBLE)                                              (R.K. PANDA)
 JUDICIAL MEMBER                                           ACCOUNTANT MEMBER

Dated: 07th May, 2019

dk

Copy forwarded to :

1.    Appellant
2.    Respondent
3.    CIT
4.    CIT(A)
5.    DR
                                                     Asstt. Registrar, ITAT, New Delhi




                                           15


 

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