IT : Where remand report submitted by Assessing Officer clearly revealed that amount in question was received prior to relevant assessment year, addition could not be made under section 68 during relevant assessment year
IT : Where assessee produced five loan creditors out of seven loan creditors before Assessing Officer who confirmed to have given amount in question to assessee by demand draft, addition made under section 68 to that extent was to be deleted
■■■
[2013] 33 taxmann.com 407 (Pune - Trib.)
IN THE ITAT PUNE BENCH 'A'
Harish Kawadmal Bajaj
v.
Income-tax Officer, Ward-2(2)*
SHAILENDRA KUMAR YADAV, JUDICIAL MEMBER
AND R.K. PANDA, ACCOUNTANT MEMBER
AND R.K. PANDA, ACCOUNTANT MEMBER
IT APPEAL NO. 518 (PUNE) OF 2011
[ASSESSMENT YEAR 2006-07]
[ASSESSMENT YEAR 2006-07]
JANUARY 11, 2013
I. Section 68 of the Income-tax Act, 1961 - Cash credits [Year in which taxable] - Assessment year 2006-07 - Assessee was having agency of HPCL for LPG - It had shown liability of a sum under head 'sub dealers deposits' from sub-dealers - Assessing Officer having found that there was no such sub-dealers appointed by assessee nor was there any deposit paid by them to assessee, made addition of said amount to income of assessee under section 68 - Before Commissioner (Appeals) assessee submitted that amount on account of sub-dealer deposit was received during financial years 2002-03 and 2003-04 and, therefore, no addition could have been made during impugned assessment year - Commissioner (Appeals) called a remand report from Assessing Officer who supported submission of assessee and admitted that addition was wrongly made - Whether in view of remand report, Commissioner (Appeals) was not justified in confirming addition made by Assessing Officer - Held, yes [Para 8] [In favour of assessee]
II. Section 68 of the Income-tax Act, 1961 - Cash credits [Loan] - Assessment year 2006-07 - Assessee claimed to have taken unsecured loans from seven persons - Assessing Officer added entire loan amount to total income of assessee on ground that assessee could not substantiate identity, creditworthiness and genuineness of transactions - Whether since assessee had produced five loan creditors before Assessing Officer who recorded their statements and creditors had confirmed to have given loan to assessee by demand draft, loan amounts received from such parties were to be accepted as genuine - Held, yes - Whether, however, in respect of a loan creditor who did not appear before Assessing Officer despite summons issued under section 131 and identity and creditworthiness having not been established, addition made by Assessing Officer was to be upheld - Held, yes [Paras 17 to 21] [Partly in favour of assessee]
CASE REVIEW-II
Mrs. Neha Rathi v. Asstt. CIT [IT Appeal No. 307/(Pune) of 2010, dated 27-7-2011] [Para 17] followed.
CASES REFERRED TO
Mrs. Neha Rathi v. Asstt. CIT [IT Appeal No.307(Pune) of 2010, dated 27-07-2011] (para 14.1) and Nemi Chand Kothari v. CIT [2003] 264 ITR 254/[2004] 136 Taxman 213 (Gau.) (para 14.1).
Sunil Ganoo for the Appellant. Ms. Ann Kapthuama for the Respondent.
ORDER
R.K. Panda, Accountant Member - This appeal filed by the assessee is directed against the order dated 07-03-2011 of the CIT(A)-II, Nashik relating to Assessment Year 2006-07.
2. In Grounds of appeal No.1 the assessee has challenged the order of the CIT(A) in confirming the addition of Rs.4,29,000/- made by the AO u/s.68 of the I.T. Act.
3. Facts of the case, in brief, are that the assessee is having agency of HPCL for LPG. During the course of assessment proceedings the AO noted from the balance sheet that the assessee has shown liability of Rs.4,29,000/- under the head "Sub dealers deposit" from 39 sub dealers @ Rs.11,000/- each. The AO deputed the ward inspector to conduct enquiries and contact some of the sub dealers on sample basis who recorded their voluntary statements. From the report of the inspector the AO noted that there are no such sub dealers appointed by the assessee nor is there any deposit paid by them to the assessee. He, therefore, confronted the same to the assessee. In absence of any satisfactory explanation from the assessee the AO made addition of Rs.4,29,000/- to the total income of the assessee u/s.68 of the I.T. Act.
4. Before the CIT(A) the assessee submitted that the AO did not give proper opportunity to the assessee to cross examine those sub dealers and drew adverse inferences and conclusions. It was further submitted that an amount of Rs.3,08,000/- was received as sub dealer deposit during F.Y. 2002-03 and Rs.1,21,000/- was received during F.Y. 2003-04 and therefore no addition could have been made during the impugned assessment year.
5. Based on the arguments advanced by the assessee the learned CIT(A) called for a remand report from the AO who reported as under vide his remand report dated 14-06-2010 :
"The assessee vide his submissions dt. 14-05-2010 has filed further submissions wherein it is stated that he had received sub-dealers deposits of Rs.3,08,000/- in F.Y. 2002-03 and in the F.Y. 2003-04 Rs.1,21,000/-. However, the addition has been made amounting to Rs.4,29,000/- in A.Y. 2006-07. The assessee has also filed copies of balance sheets for F.Y. 2002-03 and 2003-04. The same have been verified and noted that the addition was erroneously made. The same may kindly be considered, if approved."
6. However, the learned CIT(A) was not satisfied with the arguments advanced by the assessee and the remarks in the remand report of the AO and dismissed the ground raised by the assessee by holding as under:
"8.2 I have carefully considered the assessment order and report of the A.O, so also the submissions of the appellant on the issue under appeal. The AO in the remand report has stated that appellant had received sub-dealers' deposits of Rs. 3,08,000/- in F.Y.2002-03 and Rs.1,21,000/- in F.Y.2003-04. However, the addition has been made amounting to Rs. 4,29,000/- in A.Y.2006-07. Assessee has also filed copies of Balance sheets for F.Y.2002-03 and 2003-04. The same have been verified and noted that the addition was erroneously made. A perusal of the remand report suggests that addition on account of deposits are shown in the balance sheet for A.Ys 2003-04 (Rs.3,08,000/-) and 2004-05 (Rs.1,21,000/-). But that does not absolve the appellant of proving the correctness and genuineness of the said deposits. AO had taken statements from 3 persons namely Shri Ravindra Narayan, Shri Sharad Anand Wani and Shri Shaikh Rajjak S. Kamruddin (appearing in the list of sub-dealers at SN 22,31, and 33), while all 3 above persons confirmed having purchased gas connection from the appellant, they flatly denied having paid Rs.11,000/- each to become sub-dealer. They also denied having worked as sub-dealers for the appellant. The AO during the assessment proceedings confronted the appellant on this issue and provided him repeated opportunity to present his views on the subject. The appellant, however, did not offer any comments in this regard. The appellant during the appellate proceedings have filed copies of receipt vouchers showing receipt of Rs.11,000/- each from the sub-dealers. The appellant has also submitted payment vouchers showing repayment of Rs.11,000/- each to the sub- dealers in 2009 along with their confirmations. I have randomly seen some of the cash payment vouchers details of which are as follows :
| Date | Cash payment voucher receipt | |
| 19/03/2009 | 854 | |
| 24/03/2009 | 858 | |
| 24/03/2009 | 836 | |
| 25/03/2009 | 861 | |
| 26/03/2009 | 827 | |
| 16/06/2009 | 833 | |
| 04/07/2009 | 839 |
The sequence of the S.N. of the vouchers vis-a-vis date of payment itself shows discrepancy Voucher No. 854 was issued on 19/03/2009 while voucher No 839 was issued on 04/07/2009. Further, most of the payments were made in cash Taking into consideration the findings of the A0 in his assessment order and the fishy payment vouchers, I am of the considered opinion that the entire transaction i.e. receipt as well as payment is fictitious and concocted. While addition made by AO on account of sub-dealers receipt u/s.68 of the I.T Act cannot be technically made in the year under consideration, AO is directed to look into the issue in its entirety. I dismiss this ground of the appellant as well".
6.1 Aggrieved with such order of the CIT(A) the assessee is in appeal before us.
7. The learned counsel for the assessee submitted that since the AO in the remand report has accepted the same as genuine and since the sub dealer deposit amount was received during F.Y. 2003-04 and 2004-05 and do not relate to the impugned assessment year, therefore, the learned CIT(A) was not justified in confirming the addition.
7.1 The learned DR on the other hand heavily relied on the order of the AO.
8. We have considered the rival arguments made by both the sides, perused the orders of the AO and the CIT(A) and the Paper Book filed on behalf of the assessee. We find the AO in the remand report, after verification of the sub dealer deposit account, has noted that the addition was erroneously made. He has also reported that such deposits were received in A.Y. 2003-04 and 2004-05 for which the balance sheets for those years were filed. Further, the learned CIT(A) himself admits that technically the addition cannot be made u/s.68 during the year, still he had confirmed the addition, which in our opinion is not proper. Under these circumstances, the CIT(A), in our opinion, was not justified in confirming the addition made by the AO. Whatever remedy available with the department could have been utilised in the preceding years. However, the same cannot be a ground to make the addition during this year. In this view of the matter, we set-aside the order the CIT(A) and direct the AO to delete the addition.
9. The next issue in the grounds raised by the assessee relates to the order of the CIT(A) in confirming the addition of Rs.11,99,200/- on account of unexplained loan credits for non-business purposes.
10. Facts of the case, in brief, are that the AO during the course of assessment proceedings noted that the assessee has taken unsecured loans amounting to Rs.11,99,200/- during the impugned assessment year from the following persons :
| (a) Seema Rajkumar Deoyani, of Yeotmal | Rs.2,00,000/- |
| (b) Mr. Ashokkumar Nandiram Chandwani | Rs.2,00,000/- |
| (c) Komal Sevalram Sewlani, Pachora | Rs.3,00,000/- |
| (d) Mr. Gopichand Premchandani | Rs.1,00,000/- |
| (e) Mr. Ravisabasingh Sahajsinghani | Rs.99,600/- |
| (f) Mr. Sabasingh Sahajsinghani | Rs.99,600- |
| (g) Vimla Girdharilal Manmani | Rs.2,00,000/- |
| TOTAL | Rs.11,99,200/- |
10.1 To verify the credit worthiness of the loan creditors and genuineness of the transactions the AO asked the assessee to produce all the loan creditors and also to supply the complete address of Sri.Gopichand Premchandani. However, under some pretext or the other the assessee failed to produce the loan creditors before the AO. He, therefore, held that the loan creditors are bogus. The AO, further noted that even as per the statement of the assessee these funds were utilised for making payment to his Ex-wife as alimony and the same has not been utilised for business purposes and have been utilised for non-business purposes. He, therefore, added the entire amount of Rs.11,99,000/- to the total income of the assessee.
11. Before the CIT(A) it was submitted that all the amounts were received by the assessee by Account Payee Cheque or Demand Draft. The amount of Rs.1,00,000/- received from Sri Giopichand Premchandani was received during F.Y. 1995-96 relevant to A.Y. 2006-07, therefore, the same could not have been added. The assessee enclosed the bank passbook of some of the loan creditors and submitted that the loans have been repaid subsequently.
12. Based on the arguments advanced by the assessee the learned CIT(A) called for a remand report from the AO who submitted that despite issue of summons u/s.131 Smt. Seema Rajkumar Deoyani, Yeomatmal did not appear before him nor any reply was received from her. Therefore, the assessee failed to discharge the onus of proving the existence, credit worthiness and genuineness of the loan obtained from Smt. Seema Rajkumar Deoyani, Yeomatmal amounting to Rs. 2,00,000/- So far as the loan obtained from Sri Ashok Kumar Nandiram Chandwani, Kolhapur amounting to Rs. 2 lakhs and Smt. Komal Sevaldas Rejwani, Pachora amounting to Rs.3 lakhs he reported that the credits in the name of the above 2 parties are genuine in view of the statement recorded u/s.131 from these loan creditors and on the basis of their bank passbook submitted before him and their confirmations. So far as the amount received from Smt. Ravi Sobasingh Sahajsinghani, Ambarnath amounting to Rs.99,600/- and Sri Shoba Singh R. Sajsinghani amounting to Rs.99,600/- the AO noted that although they appeared before him, however, they could not produce any proof and source of the said amount. Therefore, it can be decided on merit by the CIT(A). So far as the amount received from Sri Gopichand Premchandani amounting to Rs.1,00,000/- the AO reported that the summons u/s.131 could not be served on the above person. The assessee also did not bother to produce this creditor and nothing has been filed by the assessee to prove the genuineness of the credit in this case. He accordingly reported that this addition should be confirmed.
13. Based on the arguments advanced by the assessee and on the basis of the remand report received from the AO the learned CIT(A) upheld the addition made by the AO. While doing so, he was of the opinion that the affidavits filed by the assessee in case of the loan creditors were stereotype and have been filed at the insistence of the assessee in a stereotyped fashion. Further some of the creditors are not assessed to tax. The assessee has also not produced the bank account of some of the creditors and the creditors have no source of income or had very small income from private jobs. Some of them even stated to have borrowed money to lend the money to the assessee. He accordingly held that the assessee could not satisfactorily explain the credit worthiness of the loan creditors and the genuineness of the transaction. Aggrieved with such order of the CIT(A) the assessee is in appeal before us.
14. The learned counsel for the assessee referring to the copy of the remand report drew the attention of the Bench to the observation of the AO regarding the loan obtained in case of Mr. Ashokkumar Nandiram Chandwani amounting to Rs. 2,00,00/- and Smt. Komal Sevalram Sewlani, Pachora amounting to Rs.3,00,000/- as genuine. He submitted that once the AO in the remand report has accepted the credit as genuine the learned CIT(A) should have accepted the same. So far as the loan from Mr. Gopichand Premchandani amounting to Rs. 1,00,000/- he submitted that the said loan was obtained during F.Y. 1995-96 and does not relate to this F.Y. and therefore the same should not have been added at all and the learned CIT(A) made a great mistake by confirming the addition of Rs.1,00,000/- being loan obtained from Gopichand Premchandani. He submitted that although the loan creditor Smt. Seema Rajkumar Deoyani, of Yeotmal did not attend the office of the AO, however, she had filed confirmation stating that she had given the loan of Rs. 2,00,000/- to the assessee by account payee cheque/DD and the same have been refunded subsequently by account payee cheque/DD. So far as other loan creditors are concerned he submitted that they had appeared before the AO and have confirmed to have given the loan to the assessee. He submitted that all the loans except the loan in the case of Gopichand Premchandani have been repaid during F.Y.2008-09 to 2009-10 by account payee cheques. Therefore, the same should have been accepted.
14.1 Referring to the decision of the Pune Bench of the Tribunal in the case of Mrs. Neha Rathi v. Asstt. CIT [IT Appeal No.307(Pune) of 2010, dated 27-07-2011] he submitted that the Tribunal in the said decision has held that u/s.68 of the Act, the onus is on the assessee to prove the identity, credit worthiness of the creditor and genuineness of the transaction and the same cannot be extended to prove the source of the creditors to the hilt. Referring to the decision of the Hon'ble Gauhati High Court in the case of Nemichand Kothari v. CIT [2003] 264 ITR 254/[2004] 136 Taxman 213 he submitted that the Hon'ble High Court in the said decision has held that burden of the assessee to prove the genuineness of the transactions as well as credit worthiness of the creditor is confined to the transactions which have taken place between the assessee and the creditors and it is not the burden of the assessee to show the source(s) of his creditor or to prove the credit worthiness of the source(s) of the sub creditors. He accordingly submitted that the entire addition made by the AO and confirmed by the CIT(A) should be deleted.
15. The learned DR on the other hand heavily relied on the order of the CIT(A). He submitted that the affidavits filed by the loan creditors are stereotyped. Further the so called repayments made by the assessee to the loan creditors are after the completion of the assessment. Therefore, it does not inspire confidence regarding the genuineness of the transactions. It was only after the AO disallowed the loan amount that the assessee started making the payments. He submitted that for accepting any cash credits as genuine, the onus is on the assessee to substantiate with evidence to the satisfaction of the AO regarding the identity and credit worthiness of the creditor and the genuineness of the transaction. In the instant case, the assessee has failed to discharge the burden cast on him. Therefore, the learned CIT(A) was justified in upholding the addition made by the AO u/s.68 of the I.T. Act He accordingly submitted that the order of the CIT(A) should be upheld.
16. We have considered the rival arguments made by both the sides, perused the orders of the AO and the CIT(A) and the Paper Book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find the AO disallowed an amount of Rs.11,99,200/- on account of loan from 7 loan creditors on the ground that the assessee could not substantiate the identity, credit worthiness and the genuineness of the transactions. We find the assessee filed certain details before the CIT(A) who called for a remand report from the AO. From the copy of the remand report we find the AO had accepted the loan of Rs.2 lakhs from Mr. Ashokkumar Nandiram Chandwani and Smt.Komal Sevalram Sewlani, Pachora amounting to Rs.3 lakhs as genuine by observing as under :
"Sri Ashokkumar Nandiram Chandwani, Kolhapur :
In order to find out the genuineness of the credits, a summons u/s.131 of the I.T. Act was issued on 03-03-2010 requesting the creditors to attend this office on 12-03-2010. The assessee attended this office on 12-03-2010 and his statement has been received on oath. The creditor is a relative of the assessee and the assessee has filed the copies of demand drafts as mentioned below :
| 1. Bank of Maharashtra, Kolhapur D.D.No.811676 | Rs.40,000/- | |
| 2. United Western Bank, Br. Kolhapur D.D.No.029891 | Rs.40,000/- | |
| 3. The Central Bank of India, Br. Kolhapur D.D.No.126904 | Rs.40,000/- | |
| 4. State Bank of Mysoor, Kolhapur | Rs.20,000/- | |
| 5. Bank of Baroda, Br. Kolhapur | Rs.40,000/- | |
| 6. State Bank of Mysoor, Br. Kolhapur | Rs.40,000/- (correct figure Rs.20,000/-) |
The assessee has returned the loan of Rs.2,00,000/- by account payee cheque on 13-04-2009. Copy of Bank Pass Book of P.M.C. Bank Br. Kolhapur. If the above position/documentary evidences are considered, the credit in this case appears to be genuine.
Smt. Komal Sevaldas Rejwani, Pachora Rs.3,00,000/-
The statement of this lady has been recorded wherein she has confirmed about the credit. She has also filed account extract from Pachora Peoples Co.op Bank Ltd. The transaction is genuine and the same may kindly be considered."
16.1 We find despite the comments of the AO accepting the transactions as genuine the learned CIT(A) confirmed the addition. Since the assessee has produced the loan creditors before the AO who recorded their statements and since the loan creditors filed their bank accounts and the AO was satisfied regarding the genuineness of the transaction and their credit worthiness, therefore, we find no reason as to why the same should not be accepted. We therefore set-aside the order of the CIT(A) on these 2 loans and direct the AO to allow these 2 loans as genuine.
17. So far as the loan of Rs.99,600/- received from Mr. Ravisobasingh Sahajsinghani and Rs.99,600/- from Shoba Singh Sahajsinghani we find the assessee has produced the loan creditors before the AO who recorded their statements and the creditors have confirmed to have given the loan of Rs. 99,600/- each to the assessee by Demand Draft. The loan creditors have not filed the source of Rs. 99,600/- each for which the revenue authorities disbelieved the credit worthiness of the loan creditors and made the addition. We find the Pune Bench of the Tribunal in the case of Mrs. Neha Rathi(Supra) while dealing with such type of a case has allowed the cash credit and held that the onus is on the assessee to prove the identity, credit worthiness of the creditor, genuineness of the transaction and the same cannot be extended to prove the source of the creditor to the hilt. The relevant observation of the Tribunal at Para 6 of the order reads as under :
"6. We have carefully considered the rival submissions. In this case, the only reason for invoking provisions of section 68 of the Act is that according to the Assessing Officer the assessee has failed to discharge the burden of proving creditworthiness of the creditor. In coming to such inference, it is made out by the Revenue that the creditor during examination by the Assessing Officer did not satisfactorily explain the source of cash deposits in his bank account. Secondly, it has also been pointed out that the creditor M/s Global Marketing did not carry on business during the year and neither was it holding any fixed assets and, therefore, the assessee failed to prove the creditworthiness of the said creditor to give a loan of Rs 8 lakhs to the assessee We have carefully considered the fact-situation in the present case and find that the assessee has prima facie discharged the onus cast on him in terms of section 68 of the Act. In this regard, we have perused the statement of Shri Vinay Setia, partner of M/s Global Marketing recorded by the Assessing Officer, a copy of which has been placed in the Paper Book at pages 4 to 10. In the course of examination, the said partner has explained the sources of his income out of which the amount of Rs 8 lakhs has been advanced to the assessee. The activities carried out by the creditor have also been explained and there is no material to say that the explanation furnished by the creditor is false. In fact, the creditor has confirmed and adequately explained the amount of loan advanced to the assessee. Merely the assessee to discharge the onus cast on him under section 68 of the Act. Quite clearly, the onus on the assessee is to prove the identity, creditworthiness of the creditor, genuineness of the transaction and the same cannot be extended to prove the source of the creditors to the hilt. Therefore, having regard to the totality of facts and circumstances of the case, in our view, the invoking of section 68 of the Act to make an addition of Rs 8 lakhs representing loan received from M/s Global Marketing in this case is misplaced. Resultantly, we set aside the order of the Commissioner of Income-tax (Appeals) and direct the Assessing Officer to delete the impugned addition.
7. In the result, the appeal of the assessee is allowed."
Respectfully following the decision of the coordinate Bench of the Tribunal in the case cited above and since the assessee has produced the loan creditors before the AO who have confirmed to have given the loan of Rs.99,600/- each, therefore, the same in our opinion should be allowed. We direct accordingly.
18. So far as the loan received from Smt. Seema Rajkumar Deoyani, of Yeotmal we find despite summons issued u/s.131 neither the creditor attended the office of the AO nor the assessee could produce the said loan creditor before the AO. The loan creditor also did not make any correspondence with the AO regarding the transaction. Under these circumstances, the identity of the loan creditor is not established so also the credit worthiness. Therefore, the addition made by the AO and confirmed by the CIT(A) being justified is upheld.
19. So far as the amount of Rs.1,00,000/- obtained from Mr.Gopichand Premchandani the assessee submitted before the AO during remand proceedings as well as before the CIT(A) that the loan was obtained during F.Y.1995-96 which is still outstanding and does not relate to this year. The above submission of the learned counsel for the assessee could not be controverted by the learned DR. Even the copy of the remand report is silent about the year of receipt and the AO simply states that nothing was filed to prove the genuineness of the credit in this case. If the genuineness of the credit is doubtful it could have been added in the year of receipt but certainly not during this year. In this view of the matter, we set-aside the order of the CIT(A) on this loan and direct the AO to delete the addition of Rs. 1 lakhs on account of loan obtained from Mr. Gopichand Premchandani.
20. So far as the amount of Rs. 2 lakhs obtained from Sau. Vimla Girdharilal Manmani we find the AO has not given any comment in respect of this creditor in his remand report. Similarly the assessee has also not produced this creditor before the AO. Since the loan creditor was not produced before the AO and the remand report of the AO is also silent on this issue, therefore, we, in the interest of justice deem it proper to restore the issue to the file of the AO with a direction to give one more opportunity to the assessee to substantiate with evidence to his satisfaction regarding the identity and credit worthiness of this loan creditor and the genuineness of the transaction.
21. So far as the various decisions relied on by the learned counsel we find the same are distinguishable and not applicable to the facts of the present case where additions are sustained. No doubt the assessee is not required to prove the source of the source in view of the decision of the Hon'ble Gauhati High Court in the case of Nemi Chand Kothari (supra). However, in that case the loan creditors were produced before the Assessing Officer whose statements were recorded u/s.131 of the I.T. Act. However, in the instant case despite opportunity given by the AO the loan creditor Smt. Seema Rajkumar Deoyani, Yeotmal neither appeared before the AO nor produced by the assessee. Therefore, the decision of Hon'ble Gauhati High Court as well as the decision of the Pune Bench of the Tribunal in the case of Mrs. Neha Rathi (supra) are not applicable to the facts of the Smt. Seema Rajkumar Deoyani. Accordingly, the loan amounts to the extent of Rs.2 lakhs from Mr. Ashokkumar Nandiram Chandwani and Rs.3 lakhs from Komal Sevalram Sewlani, Pachora, Rs.99,600/- each from Ravi Sobasingh Sahajsinghani and Shobasingh R. Sahajsinghani and Rs.1 lakh from Gopichand Premchanani are accepted as genuine. The loan amount of Rs.2 lakhs from Smt. Seema Rajkumar Deoyani of Yeotmal is confirmed and the amount of Rs.2 lakhs from Vimla Girdharilal Manmani is restored to the file of the AO for fresh adjudication. Grounds of appeal No.2 by the assessee is accordingly partly allowed.
22. In the result, the appeal filed by the assessee is partly allowed for statistical purposes.
Regards
Prarthana Jalan
__._,_.___
No comments:
Post a Comment