Referred Sections: 
Section 143(2) of the Act
Section 292BB
Section 124(3) of the Act.
Section 127 of the Act
Sub-section-3
Section 148 of the Act
Section 149 (b) of the Act.
Section 147 and 148 of the Act

Referred Cases / Judgments:
M/s. Micro Space matrix Solution Pvt. Ltd., vs ITO in ITA No.669/Del/2012
CIT vs Lunar Diamonds Ltd. (ITA No.62 of 2005),
ACIT vs Hotel Blue Moon (2010) 321 ITR 362 (SC).
CIT vs Kapil Jain in ITA No.613 of 2009
Abhishek Jain vs ITO 94 taxmann.com 355 (Del.)
Shri Harvinder Singh Jaggi vs ACIT in ITA No.672/Del/2013
KIE Infrastructures & Projects (P.) Ltd. vs ITO in IT Appeal No.23(Del) of 2012.
Cabbana Infrastructure Pvt. Ltd. vs DCIT (ITA No.183 and 526/Asr./2017).
Tata Sons Ltd. vs ACIT (ITA No.4497 and 4542/Mum/2005) (Mum. Trib.)
CIT vs Atlanta Capital Pvt.
KIE Infrastructures & Projects (P.) Ltd. vs ITO in IT Appeal No.23(Del)
M/s Bajrang Bali Industries vs ACIT in ITA No.724/LKW/2017

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI `F' BENCH,
                     NEW DELHI

  BEFORE SHRI T.S. KAPOOR, ACCOUNTANT MEMBER, AND
    SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER,

                     ITA No.1184/DEL/2019
                   [Assessment Year: 2014-15]

 Rajeev Goel,                       ACIT,
 M/s S.B.G. & Co. Chartered         Circle-47(1),
 Accountants, 9, Atta-ur-           New Delhi,
 rehman Lane, Civil Lines,
 Delhi-110054
 PAN-AWMPG2245H
           Appellant                           Respondent

              Appellant by        Shri   Ved Jain,
                                  Shri   Akshit Goeal &
                                  Shri   Nishchay Kantoar
              Respondent by       Shri   Surendra Pal-Sr. DR

      Date of Hearing                        23/09/2019
      Date of Pronouncement                  26/09/2019

                               ORDER

 PER T.S. KAPOOR, ACCOUNTANT MEMBER
         This appeal has been filed by the assessee against the order

 of the Ld. CIT(A)-16, New Delhi, dated 18/12/2018, for Assessment

 Year 2014-15. The assessee has taken a number of grounds both on

 legal issues and on merits of the case. However, during the course of

 proceedings before us, only ground No.1, which is on legal issue of

 non-service of notice u/s 143(2) of the Income Tax Act, 1961

 (hereinafter `the Act') was argued which for the sake of completeness

 is reproduced below.
                                    2
                                                      ITA No. 1184/Del/2019




     "That no notice u/s 143(2), of the Income Tax Act, 1961,
     issued by the Assessing Officer having jurisdiction over the
     assessee, was served upon the assessee on or before the
     time limit stipulated in the proviso to section 143(2) of the Act
     and, therefore, the assessment order is illegal, unjustified
     and void ab initio.

2.      The Ld. AR at the outset, submitted that assessee in this

case has been assessed by the Assessing Officer, Circle-47(1), New

Delhi who is the Assessing Officer of the assessee and who has not

issued and served the statutory notice u/s 143(2) of the Act. The Ld.

AR submitted that during the course of assessment proceedings itself,

the assessee had objected to the assessment proceedings being

without statutory notice u/s 143(2) and had filed affidavit before the

Assessing Officer claiming therein that no notice u/s 143(2) was

served and in this respect our attention was invited to page 3 of the

assessment order where the Assessing Officer himself has reproduced

the affidavit filed by the assessee. It was submitted that the Assessing

Officer claimed that notice u/s 143(2) was duly issued and was

served upon the assessee and he has scanned the receipt of the speed

post along with tracking history of the envelope containing notice and

has reproduced the same in the assessment order itself. The Ld. AR

submitted that the address mentioned in the notice is B-37,

Maharana Pratap Enclave, Pitampura Delhi-110034, which means

that the said notice was to be dispatched at the above noted address.
                                  3
                                                   ITA No. 1184/Del/2019


In this respect, the Ld. AR took us to page 253, where a copy of said

notice was placed. The Ld. AR then took us to paper book page 254

where the tracking report of India Post was placed and in which the

destination Pin Code 110006, was mentioned. The Ld. AR submitted

that instead of sending the notice at Pin Code-110034 to the

assessee, the Assessing Officer   had sent the notice at some Delhi

address with Pin Code-110006, therefore there is discrepancy in the

address noted in the notice u/s 143(2) of the Act and address on

which delivery is made. Further, it was argued that the name of the

assessee is Rajeev Goel and not Ranjeev Goel as bearing in the postal

receipt and therefore in such circumstances, it cannot be presumed

that the Ld. Assessing Officer had discharged its onus.


3.       It was submitted that the case of the assessee is squarely

covered by the order of the Delhi ITAT in the case of M/s. Micro Space

matrix Solution Pvt. Ltd., vs ITO in ITA No.669/Del/2012 wherein, it

has been held that if there are discrepancies in the address stated in

the notice, envelope containing notice and the address noted by the

Post Officer, then there cannot be any presumption as to the valid

service of notice.


4.    The Ld. AR further placed his reliance on judgments of Hon'ble

Delhi High Court in the case of CIT vs Lunar Diamonds Ltd. (ITA

No.62 of 2005), wherein, the Hon'ble High Court under similar facts
                                   4
                                                    ITA No. 1184/Del/2019


and circumstances had dismissed the appeal of the Revenue. It was

submitted that in that case also, the assessee had filed affidavit

regarding non-receipt of notice u/s 143(2) and there was difference in

the address on the receipt issued by post office and therefore, the

Hon'ble Tribunal had allowed the appeal of the assessee which the

Hon'ble High Court had upheld. The Ld. AR also relied upon a

number of case laws as listed in the brief synopsis filed by him. The

Ld. AR further submitted that the in view of the above facts and

circumstances, the assessee was not served noticed u/s 143(2) of the

Act and therefore, any assessment order passed without service of

notice u/s 143(2) is null and void as held by the Hon'ble Supreme

Court in the case of ACIT vs Hotel Blue Moon (2010) 321 ITR 362

(SC). It was submitted that in that case, the Hon'ble Supreme Court

has clearly held that in absence of service of notice u/s 143(2) of the

Act, the assessment becomes null and void. It was submitted that

Hon'ble Supreme Court even dealt with the provisions of section

292BB and has held that even section 292BB cannot cure the defect

of not serving of notice u/s 143(2) of the Act. It was submitted that in

the present case, the assessee before the Assessing Officer itself had

objected to the assessment proceedings, because of non-service of

notice and therefore, section 292BB is also not applicable to the

assessee.
                                   5
                                                    ITA No. 1184/Del/2019


5.   Without prejudice, it was argued that the notice issued by the

Assessing Officer of Ward 34(1) u/s 143(2) was not issued by the

jurisdictional Assessing Officer. It was submitted that official address

of assessee is 1705, 3rd Floor, Onkar Bhawan, Bhagirath Place, Delhi-

110006 and jurisdiction of which lies with Circle 47(1), New Delhi and

the jurisdiction at the time of issuance of notice also lied with such

Circle 47(1) and our attention was invited to copy of jurisdiction chart

extracted from the website of Income Tax Department placed at paper

book page no. 301 to 327. It was submitted that the Assessing Officer

of Circle 34(1) does not hold jurisdiction even over the residential

address of the assessee for which the Assessing Officer of Circle 39(1)

holds the jurisdiction and therefore it was argued that the notice

issued by non-jurisdictional Assessing Officer is liable to be quashed.







6.   Regarding the contention of the Ld. CIT(A) that assessee should

have raised the issue within one month of notice, it was submitted

that the assessee could not have known that the notice has been

issued by a non-jurisdictional Assessing Officer as the notice itself

was not served and thus could not have filed the objection in this

regard. It was submitted that the notice u/s 142(1) was duly issued

by Circle 47(1) only and accordingly no objection was filed and further

the order was passed by the Assessing Officer Circle 47(1) and thus

no objection was filed. It was submitted that the aforesaid fact came
                                     6
                                                    ITA No. 1184/Del/2019


to light of assessee after receiving the remand report and immediately

thereafter objection was raised vide rejoinder to the remand report.

Thus, there is no breach of section 124(3) of the Act. As regards the

case laws relied upon by the Ld. CIT(A), it was submitted that the

these are distinguishable on facts as in the case of Mega Corporation

Ltd. in ITA No.128/2016 and CIT vs Kapil Jain in ITA No.613 of 2009

and Abhishek Jain vs ITO 94 taxmann.com 355 (Del.) notice had

been served upon the assessee and assessee had failed to raise the

objections within the stipulated period prescribed u/s 124(3) of the

Act, whereas, in the present case no notice was served upon the

assessee as already demonstrated.


7.    The Ld. AR, further, argued that no order u/s 127 for transfer of

case from one Assessing Officer to another Assessing Officer was

passed, whereas the Commissioner of both the Assessing Officer are

different. It was submitted that such order has to be passed by Chief

Commissioner or Commissioner from whose jurisdiction, the case is

to be transferred. It was submitted that Circle-34 and Circle 47 are

under the jurisdiction of different CCITs, therefore, the order u/s 127

was   mandatory.    The   Ld.   AR   further   argued   that   the   Chief

Commissioner of Circle 34 also did not pass any order u/s 127 to

transfer the case back to the Circle 34 and therefore there is violation

of the provisions of section 127 of the Act and therefore, the order
                                   7
                                                    ITA No. 1184/Del/2019


passed by the Assessing Officer, Circle 47(1) is not valid and liable to

be quashed. In this respect, reliance was placed on the following

cases:-


 i.    Shri Harvinder Singh Jaggi vs ACIT in ITA No.672/Del/2013

ii.    KIE Infrastructures & Projects (P.) Ltd. vs ITO in IT Appeal
       No.23(Del) of 2012.

iii.   Cabbana Infrastructure Pvt. Ltd. vs DCIT (ITA No.183 and
       526/Asr./2017).

iv.    Tata Sons Ltd. vs ACIT (ITA No.4497 and 4542/Mum/2005)
       (Mum. Trib.)

8.     The Ld. DR on the other hand, vehemently argued that the

arguments raised by the Ld. AR are baseless and are aimed at

depriving the Revenue of its legitimate share. The Ld. DR filed a copy

of letter written by the Assessing Officer, Circle 47(1) and also stated

that complete assessment record was available with him. The Ld. DR

filed a print out of PAN directory showing the address of the assessee

and submitted that while filing PAN application, the assessee duly

mentioned its address as B-37, Maharana Pratap Enclave, Pitampura

Delhi-110034 and therefore as per the PAN records, notice u/s 143(2)

was generated by the Assessing Officer where the PAN of the assessee

lied which in the present case was Assessing Officer Circle-34(1).

Inviting our attention to the copy of notice, the Ld. AR submitted that

the same was generated by the same Assessing Officer where the PAN

of the assessee was laying and the assessee filed returns of income
                                     8
                                                     ITA No. 1184/Del/2019


stating therein different address and in this respect, invited our

attention to paper book page 5 where a copy of return along with

address mentioned on it was placed. The Ld. DR stated that assessee

did not inform the Assessing Officer for change of address and

therefore raising of such plea of notice by a different Assessing Officer

does not hold good. The Ld. DR placed his reliance on a decision of

Hon'ble Bombay High Court in the case of Sky Light Hospitality LLP

(2018) 405 ITR 296 wherein, the Hon'ble Court had held that where

the name and even the PAN number mentioned were incorrect,

human    errors   and     mistakes   cannot   and   should   not   nullify

proceedings which are otherwise valid and where no prejudice had

been caused. The ld. DR further placed his reliance on order of the

Hon'ble Delhi High Court in the case of Abhishek Jain vs ITO (2018)

405 ITR 1, where the Hon'ble High Court has held that sub-section-3

of section 124 clearly states that no person can call in question

jurisdiction of an Assessing Officer in case of non-compliance and/or

after the stipulated in clause (a) and (b), and therefore, it was argued

that at this stage, the arguments of the assessee cannot be accepted

and it was therefore argued that the Ld. CIT(A) has rightly dismissed

this grounds of appeal.


9.   The Ld. AR in this rejoinder submitted that the assessee is not

under any obligation to inform the Assessing Officer regarding change
                                    9
                                                    ITA No. 1184/Del/2019


of address and in this respect relied upon the judgment of Hon'ble

Delhi High Court in the case of Pr. CIT vs Atlanta Capital Pvt. Ltd.

and filed a copy of the decision.       The Ld. AR submitted that the

arguments of the ld. DR that notice u/s 143(2) is generated by the

Assessing Officer where the PAN number lies also goes in favour of

the assessee as the Assessing Officer while issuing notice u/s 143(2)

has not applied his mind whereas the section itself requires that the

Assessing Officer should have been satisfied before issuing of notice

u/s 143(2) and if the Assessing Officer issued notice u/s 143(2)

without taking into account the return filed by the assessee, such

notice itself is also bad in law.


10.   We have heard rival parties and have gone through the material

placed on record. We find that it is correct that the assessee obtained

his PAN number by stating residential address as B-37, Maharana

Pratap Enclave, Pitampura Delhi-110034. Print out of PAN directory

showing the address and PAN number of the assessee is placed in

page-4 of paper book filed by Revenue. Further, it is also correct that

the assessee filed his return of income by stating therein address as

1705, 3rd Floor, Onkar Bhawan, Bhagirath Place, Delhi-110006,

therefore, it is an undisputed fact that there is difference between the

address mentioned in PAN data base as well as in the return of

income filed by assessee. As per jurisdiction chart of Income Tax
                                  10
                                                  ITA No. 1184/Del/2019


Department in Delhi, extracted from the website of Income Tax

Department, placed at page book page 301 to 327, the jurisdiction of

assessee as per his address in PAN application is with Assessing

Officer Ward 39(1). The jurisdiction of the Assessing Officer, as per

the address mentioned in the return of income is with Assessing

Officer Circle No.47(1) who has passed the assessment order.       The

notice issued u/s 143(2) has been issued by the Assessing Officer

Circle 34(1) who is neither the Assessing Officer of assessee on the

basis of address in PAN application nor is the Assessing Officer of

assessee as per address mentioned in the returns of income.


11.   The jurisdiction chart placed in paper book page 308 reflects

the area covered under Circle 34(1) which includes Sarai Pepal Thala,

Shalimar Bagh(south), Ashok Vihar, Wazir Pur, Sawan Park, Nimri

Colony, Malka Ganj. At none of the places mentioned above, the

assessee resides or does his business. Therefore, the notice issued by

the Assessing Officer of Circle 34(1) is held to be illegal as the

Assessing Officer of Circle 34(1) had no jurisdiction on the assessee

either on the basis of his residential address or on the basis of his

business address. The Ld. DR also could not produce any order

passed u/s 127 of the Act either by the Commissioner of Circle 34(1)

or Commissioner of Circle 47(1) of the Act. As regards, the contention

raised by the Ld. DR that the assessee should have approached the
                                         11
                                                               ITA No. 1184/Del/2019







Assessing Officer for change of address also does not hold good in

view of the decision of the Hon'ble Delhi High Court in the case of Pr.

CIT vs Atlanta Capital Pvt. Ltd., where, the Hon'ble Court has held as

under:-


     "7. On the facts of the present case, it is seen that notice dated 27th
     March 2008 under Section 148 of the Act was issued to the Assessee by
     the Assessing Officer ('AO') at the address at B-231, Okhla Industrial
     Area, Phase-I, New Delhi. Admittedly, the Assessee had shifted from that
     address with effect from 1st February 2005 to a new address at B-115,
     Sarvodaya Enclave, New Delhi. For AY 2005-06 and the subsequent AYs,
     the Assessee disclosed his address as B-115, Sarvodaya Enclave, New
     Delhi. Even the AO had sent letters to the Assessee at the same address
     on 8 th August 2007. The intimation under Section 143(1) of the Act
     dated 25 th January 2008 for AY 2006-07 was also sent by the AO to the
     Assessee at the same changed address i.e. B-115, Sarvodaya Enclave,
     New Delhi. There is nothing to show that the notice under Section 148 of
     the Act was in fact issued by the AO showing the aforementioned
     changed address.

     8. It is the contention of Mr. N.P. Sahni, learned Senior Standing counsel
     for the Revenue, that the notice satisfied the requirement as to limitation
     under Section 149 (b) of the Act. However, as noted by the ITAT, the
     notice itself was not issued at the correct address. The fact that the said
     notice, sent by speed post, was not returned unserved, would be to no
     avail since the address given in the notice was not the last known address
     of the Assessee.

     9. Mr. Sahni then submitted that it was incumbent on the Assessee to
     have got his changed address entered in the PAN Data Base failing
     which the AO would only go by the address given in the record of the
     relevant AY which in the case is AY 2001-02.

     10. The Court is unable to agree with this submission. No provision in
     the Act has been shown to the Court which obliges the Assessee to ensure
     that his changed address is entered in the PAN Data Base failing which
     he is precluded from insisting on the notice under Section 148 being
     issued to him at the known address and being served upon him. In the
     present case, on facts, it is not in dispute that the AO was aware of the
     change of address of the Assessee and yet the notice under Section 148 of
     the Act was issued at the older address.
                                           12
                                                                 ITA No. 1184/Del/2019


       11. Mr. Sahni submitted that the order of the CIT (A) notes the fact that a
       photocopy of the notice was given to the Assessee during the re-
       assessment proceedings and that by itself should constitute sufficient
       service of notice on the Assessee. In light of the law explained by the
       Supreme Court in R.K. Upadhyaya v. Shanbhai P. Patel (1987) 3 SCC 96
       which has in turn been followed by this Court in Chetan Gupta (supra),
       the requirement of both the issuance and the service of such upon the
       Assessee for the purposes of Section 147 and 148 of the Act are
       mandatory 'jurisdictional requirements'.

       The mere fact that an Assessee participated in the re-assessment
       proceedings despite not having been issued or served with the notice
       under Section 148 of the Act in accordance with law will not constitute a
       waiver of the said jurisdictional requirement.

       12. On facts, therefore, the Court finds no legal error committed by the
       ITAT in holding that there was no proper service of notice on the
       Assessee under Section 148 of the Act."

12.     Even otherwise, we have observed that the Assessing Officer of

Circle 34(1) did not have jurisdiction over the assessee neither on the

basis of residential address nor on the basis of business address.

Therefore, the notice issued by Assessing Officer of Circle-34(1)

cannot be said to be legal as it has been issued by a non

jurisdictional Assessing Officer and that too without any order u/s

127 of the Act. The Hon'ble Delhi ITAT in the case of KIE

Infrastructures & Projects (P.) Ltd. vs ITO in IT Appeal No.23(Del) of

2012 has held as under:-


      "Where in case of assessee, Assessing Officer at ward 4 Agra himself
      transferred jurisdiction of case to Assessing Officer at ward 5(3), New
      Delhi and there being no transfer order passed by Chief Commissioner or
      Commissioner, it was a case of violation of provisions of section 127 and,
      therefore, impugned assessment order passed by Assessing Officer, ward
      5(3), New Delhi was to be regarded as void ab intio."
                                           13
                                                                  ITA No. 1184/Del/2019


13.   Similarly, Lucknow Bench of the Tribunal in the case of M/s

Bajrang Bali Industries vs ACIT in ITA No.724/LKW/2017, order

dated 30/11/2018 has held as under:-


       "6. In the present case, the return of income was furnished on 30.09.2013.
       The financial year in which the return was filed expired on 31.03.2014 and
       therefore, last date for issue of notice was 30.09.2014. The statutory period
       for issuance of notice u/s 143(2) expired on 30.09.2014 and by 30.09.2014
       the notice u/s 143(2), which was within the prescribed period of time, was
       issued only by DCIT-IV, Kanpur who had no jurisdiction over the case, as
       the DCIT-IV himself had transferred the case to DCIT-2, Kanpur vide memo
       dated 20.08.2015, a copy of which is placed at paper book Page 3.
       Therefore from the above facts and circumstances, it become apparent that
       the first Assessing Officer who issued notice on 30.09.2014 had no
       jurisdiction to assess the assessee and, therefore, he transferred the case to
       DCIT-2, Kanpur who though had jurisdiction to assess the assessee but
       issued notice u/s 143(2) only on 07.09.2015 by which date period for
       issuance of notice had expired. We further find that no order u/s 127 of the
       Act was passed by the Assessing Officer to transfer the case from Kanpur-4
       to Kanpur-2. The Assessing Officer who had jurisdiction to assess the
       assessee issued notice u/s 143(2) only on 07.09.2015 which was beyond the
       prescribed time limit for issuance of such notice. Therefore, the notice
       issued u/s 143(2) by DCIT, Kanpur-2 beyond the statutory period of time is
       without jurisdiction and therefore, any order passed in consequence of such
       notice is also liable to be quashed. Therefore, we are in agreement with the
       argument of Ld. AR. Accordingly, additional grounds of appeal 5 to 8 are
       allowed. Since we have decided the legal issues, in favour of assessee the
       grounds on merits of the case have become infructuous and have not been
       adjudicated."

In view of the above facts and circumstances & judicial precedents

the arguments of the Ld. AR is accepted & notice issued by Assessing

Officer of Circle-34(1) is held to be void-ab-intio.


14.   Moreover, if for a moment, we presume that the notice issued by

Circle 34(1) Assessing Officer was valid then its service was not

proper as the address mentioned on the notice placed in paper book

page 253 is B-37, Maharana Pratap Enclave, Pitampura Delhi-
                                          14
                                                                ITA No. 1184/Del/2019


110034, whereas as per India Post tracking report, the notice has

been delivered at Delhi address to one Ranjeev Goel with Pin Code

110006. There is difference between the address mentioned in the

notice which is Pin Code 110034 and tracking report which is 110006

and also there is difference in the name mentioned in the notice

which is Rajeev Goel and that mentioned in the tracking report which

is Ranjeev Goel. The copy of tracking report is placed at paper book

page 254. Therefore, in view of these facts, the notice, even if

presumed to be by jurisdictional Assessing Officer has not been

served properly. The Hon'ble Delhi High Court in the case of CIT vs

Lunar Diamonds Ltd. (281 ITR 1) has dealt with similar situation. The

facts of the case and its decision is reproduced below:-


     ". On appeal before the CIT(A), it was contended by the assessee that it
     had not received under section 143(2) of the Income Tax Act, 1961
     allegedly sent by registered post. An affidavit to this effect was filed. It
     was contended that the receipt issued by the post office did not bear the
     address of the assessee but only its name. It was, therefore, submitted
     that there was a possibility that the correct address of the assessee might
     not have been written on the envelope and, therefore, the question of
     service of notice on the assessee did not arise. The contention of the
     assessee was accepted by the Commissioner (Appeals) and it was held
     that there was no valid service of notice on the assessee and, therefore,
     the assessment framed was invalid. On appeal to the High Court, held
     dismissing the appeal filed by the revenue:

          "We may also point out that there appears to be some doubt
          whether the notice was at all sent to the assessee because, as
          observed by the Commissioner of Income-tax (Appeals), the
          receipt showing that an envelope was sent by registered post
          merely contained the name of the assessee without its address.
          Consequently, it is quite possible that the notice may have been
          sent to the assessee at some wrong or even some incomplete
          address. However, it is not necessary for us to go into this
          question at all because the assessee had filed an affidavit
                                           15
                                                                 ITA No. 1184/Del/2019


            stating that it had not received the notice and the Tribunal
            rightly held that under these circumstances, the burden was
            upon the appellant to prove that notice was served upon the
            assessee within the prescribed time. The appellant had failed to
            prove its case in this regard."

      The above case squarely applies to the facts of the instant case. In the
      instant case also, there is no reason to believe that the notice was sent to
      the assessee because the postal receipt showingthat an envelope was sent
      by speed post merely contained the name of the assessee without its
      address. Consequently, it is quite possible that the notice may have been
      sent to the assessee at some wrong or even some incomplete address. The
      assessee has filed an affidavit stating that he had not received the notice.
      Hence, applying the ratio, the notice u/s 143(2) is void.

      Therefore, on this ground also the assessee succeeds as in this

case also the service of notice was not proper.

15.    In view of the above facts and circumstances, the legal ground

taken by the assessee is allowed. Nothing was argued on the merits of

the case and therefore, merits of the case has not been adjudicated.

16.    In the result, appeal is allowed.

      Order pronounced in the open court on 26/09/2019.

             Sd/-                                                 Sd/-

[SUDHANSHU SRIVASTAVA]                                [T.S. KAPOOR]
   JUDICIAL MEMBER                                 ACCOUNTANT MEMBER

Delhi; Dated: 26/09/2019.
f{x~{tÜ? fÜA P.S
Copy forwarded to:
1.  Appellant
2.  Respondent
3.  CIT
4.  CIT(A)
5.  DR
                                                                     Asst. Registrar,
                                                                    ITAT, New Delhi