BHAGWANDAS H JUMANI,CHENNAI vs. ITO N.C. WARD 10(1), CHENNAI

PER MAHAVIR SINGH, VP:

These three appeals by the assessee are arising out of

separate orders passed by the Ld Commissioner of Income

Tax (Appeals)-12, Chennai, in ITA Nos. 255/CIT(A)-12 / 2013-

14, dated 11.07.2018; 254/CIT(A)-12 / 2013-14, dated

27.12.2017 & 253/CIT(A)-12 / 2013-14, dated 20.03.2018

The assessments were completed by the Assistant

Commissioner of Income Tax, Circle-XIII, Chennai for the

relevant assessment year 2003-04 u/s.143(3) r.w.s 147 /

142(2A) of the Income Tax Act, 1961 (hereinafter “the Act”) vide

order dated 01.07.2008; for the assessment year 2004-05 vide

2 ITA Nos.2701, 774 & 2253/Chny/2018

order dated 28.12.2006 & for the assessment year 2005-06

vide order dated 01.07.2008. Since, the facts & issues involved

in these appeals are common, for the sake of convenience, we

proceed to dispose off the above appeals by this consolidated

order.

ITA No.2701/Chny/2018 (A.Y.2003-04): 2. The first issue in this appeal of the assessee is as regards

to order of the CIT(A) confirming action of the Assessing

Officer in making addition of unexplained investments in mutual

funds / deposits amounting to Rs.20,03,417/- u/s.69 of the Act.

trades in shares and mutual funds and a survey u/s.133A of the

Act was conducted by the Income-tax department on

assessee’s business premises on 09.02.2005. During the

course of survey, the Revenue noticed that the assessee has

made unaccounted investments in shares and mutual funds in

the name of Vishwambar Jumani (a fictitious name) and

Mrs.A.Sumathi, assessee’s maid servant. According to the

Revenue, fictitious bank accounts were maintained and

transactions were routed through these accounts. The

3 ITA Nos.2701, 774 & 2253/Chny/2018

Department also found during the course of survey, certain

cheque books, passbooks and other documents pertaining to

various banks held in the name of the assessee Mr.

Bhagawandas H.Jumani, his family members and others,

including Mr. Vishwambar Jumani and Mrs. A.Sumathi, who

were inventorised vide Ann/PC/Bank Accts/NS dated

09.02.2005. The assessee could not provide any details of

Vishwambar Jumani, including address or any other contract

number or could not provide any details regarding transactions held in the name of Vishwambar Jumani. Similarly,

Mrs.A.Sumathi, who worked with the assessee as servant

maid. The Assessing Officer noted during course of

assessment proceedings that the assessee could not explain

any of the account held in the name of Vishwambar Jumani in

State Bank of Trivancore and in the assessee’s bank account in

HDFC Bank in the name of Bhagawandas H.Jumani and

hence, he treated deposits in these bank accounts as

unaccounted income and assessed u/s.69 of the Act. The

following are the details of unaccounted income deposited in the banks:-

Name Bank account Amount Rs.

4 ITA Nos.2701, 774 & 2253/Chny/2018

Vishwambar State Bank of 3,13,401 Jumani Trivancore BhagawanJumani HDFC, Anna Salai 16,82,060 BhagawanJumani HDFC, Anna Salai 7,956 Total 20,03,417

CIT(A). The CIT(A) also confirmed action of the Assessing

Officer. Aggrieved, now the assessee is in appeal before the Tribunal.

and circumstances of the case. We noted that the assessee

before the Assessing Officer as well as CIT(A) made

submissions that the assessee had opening balance of

Rs.22,73,000/- in D.S.P Merril Lynch Mutual Fund in the name

of the assessee and another amount of Rs.9,36,000/- in

Grindlays Supersaver Mutual Fund in the name of Latha

Bhagawandas Jumani as on 31.03.2002. The assessee before

the lower authorities contended that these amounts were withdrawn and invested in different names i.e., Vishwambar

Jumani and Bhagawandas Jumani. But, neither the Assessing

Officer nor the CIT(A) accepted explanation of the assessee.

Now, the learned counsel for the assessee filed details of

5 ITA Nos.2701, 774 & 2253/Chny/2018

redemption of GSSIF– IP- Growth Option and I Flex IPO on

09.06.2002 of Rs.3,06,200/- and deposited in HDFC bank

account of Anna Nagar branch. Similarly, the assessee also

filed details of 460 shares of I Flex allotted for a sum of

Rs.2,43,800/-. The learned counsel for the assessee again

drew our attention to the submissions made before the CIT(A)

in regard to redemption of GSSIF – IP annual option that

contains opening balance as on 01.04.2002 at Rs.6,36,000/-,

out of which invested a sum of Rs.99,000/- on 15.04.2002 in the name of Lata B.Jumani. Similarly, redemption of D20 DSP

Merrill Lynch Bond fund - retail growth having opening balance

of units 10,923.546 were available, out of which a sum of

Rs.5,000/-was received. Similarly, another amount of

redemption of GSSIF ST Growth on 30.03.2003 for

Rs.3,25,534/-, out of which entire funds were available. When it

was pointed out to learned counsel for the assessee, entire

investment of Rs.5.50 lakhs is out of redemption in I Flex IPO,

another redemption of shares of I Flex of Rs.2,43,800/- and

another redemption of GSSIF ST Growth on 30.03.2003 for Rs.3,25,534/- is available and explained before us. But, for

balance amount, the assessee could not explain / produce any

6 ITA Nos.2701, 774 & 2253/Chny/2018

evidence or any details before us. This means that the

assessee has source of Rs.11,19,334/- is available with the

assessee to explain the source of deposits. The total

investment in the bank deposits are to the tune of

Rs.20,03,417/-, out of which the assessee is able to explain

only Rs.11,19,334/- and balance amount of Rs.8,84,083/-

remains unexplained. Hence, this amount is to be treated as

unexplained investment u/s.69 of the Act. When these facts

were confronted to ld.Sr.DR, he left the issue on Bench, but

made submissions that evidences can be sent back to the

Assessing Officer for verification. We noted that this being a

very old matter pertains to assessment year 2003-04 and going

by nature of evidences, it is better to partly accept here and

allow relief to the extent the assessee is able to explain.

Hence, we treat the amount of Rs.11,19,334/- as explained and

balance amount of Rs.Rs.8,84,083/- as unexplained. Therefore,

we confirm addition to the extent of Rs.8,84,083/-. Accordingly,

this issue of the assessee is partly allowed.

7 ITA Nos.2701, 774 & 2253/Chny/2018

regards to order of the CIT(A) in confirming addition of

Rs.2,53,400/- u/s.69 of the Act.

proceedings, as noted above the issue, the Assessing Officer

noted that out of seized bank accounts, there is a d-mat

account in the name of Vishwambar Jumani, where

unexplained investments of Rs.2,53,400/- is treated as unexplained investments u/s.69 of the Act, because, the

assessee is unable to prove this amount.

assessment has not accepted contention of the assessee that

investments in shares were not from the above unaccounted

mutual funds, as the assessee failed to explain trail of funds.

The Assessing Officer treated this amount of Rs.2,53,400/- as

unexplained investment u/s.69 of the Act. The CIT(A) also

confirmed action of the Assessing Officer by observing in para 13 & 14 of his order as under:-

8 ITA Nos.2701, 774 & 2253/Chny/2018

“13. 0n the addition of Rs.2,53,400/- being related to the shares acquired in the name of Vishamber Jumani, (600 shares of Union Bank), the Assessing Officer observed that the same was allotted in the above name for Rs.9,600/- and there was a refund of Rs.6,400/- as is evident from the SB A/c no.102850. Flex shares of Rs.2,43,800 (460 shares) were allotted which are unaccounted.

circumstances of the case, we note that the assessee has

available funds on account of Application for I Flex IPO on

09.06.2002 for Rs.5.50 lakhs. The assessee claimed that it has

received refund application I Flex IPO on 31.07.2002 for an

amount of Rs.3,06,000/- and balance is allotment of 460

shares in I Flex Rs.2,43,800/- . The assessee claimed that this

refund of application in I Flex IPO on Rs.3,06,200/- was re-

deposited in D-mat account to the extent of Rs.2,53,400/-. We

noted that the assessee made submissions and gave some

9 ITA Nos.2701, 774 & 2253/Chny/2018

details, but could not file any direct evidence that this amount is

the same amount which is re-deposited in assessee’s D-mat

account. Hence, this cannot be treated as explained and the

Assessing Officer as well as CIT(A) has rightly treated this as

unexplained and we confirm orders of the lower authorities on

this issue. Therefore, this ground of appeal is dismissed.

ITA No.774/Chny/2018 (AY : 2004-05): 11. The first issue in the appeal of the assessee is as regards

to order of the CIT(A) confirming action of the Assessing

Officer in changing ‘head of income’ of trading in business,

instead of taxing surplus arising out of sale and purchase of

shares as long term capital gain. For this, the assessee has

raised seven grounds which are argumentative and factual,

hence, need not be reproduced.

shares, units in addition to investment in equity and units. The

assessee for the relevant assessment year 2004-05 declaring

long term capital gain at Rs.1,43,58,040/- in the return of

10 ITA Nos.2701, 774 & 2253/Chny/2018

income on account of surplus arising out of sale of shares and

mutual fund units. During the course of survey u/s.133A in the

business and residential premises of the assessee on

09.02.2005, the Department noted that the assessee was

indulging in large scale trading in shares and units of mutual

funds, but not maintaining any books of account. Based on the

report of investigation wing and documents found during the

course of survey, the Assessing Officer completed assessment

and assessed surplus arising out sale of shares as business

profit, as against long term capital gain declared by the

assessee amounting to Rs.1,43,58,040/-. The assessee

claimed before the Assessing Officer that the assessee is

engaged in trading of equity shares and mutual funds along

with he is also an investor in equity shares and mutual funds.

The assessee before the Assessing Officer claimed that he has

purchased shares under the head ‘investment’ and from sale

of those shares, he has earned surplus of Rs.1,43,58,040/-

which is declared as long term capital gain, because holding

period is more than one year. He explained before the

Assessing Officer that these shares are kept in D-Mat account.

The assessee before the Assessing Officer also explained that

11 ITA Nos.2701, 774 & 2253/Chny/2018

the assessee is engaged in trading also for which also a

separate account is maintained and he has declared profit

arising out of purchase and sale of shares in trading account

as business income. But, the Assessing Officer re-drawn the

entire activities of the assessee and assessed surplus as

business profit by observing as under:-

“In the light of the above decisions and also In the light of the facts admitted by the assessee that his full time occupation was in trading in shares and in mutual funds and the volume of business carried on by the assessee will clearly indicate that the surplus derived from the activity could not have been created had the assessee treated the stocks as investments only. It has thus become clear that the surplus earned by the assesseefrom out of the trading in shares will constitute income from business and not Long Term Capital Gains as claimed by the assessee. I shall therefore, hold that the profit received by the assessee from out of the trading in shares has to be treated as income from business. and this will be taxed as such at the rates applicable to income from business.”

Aggrieved, the assessee preferred an appeal before the CIT(A).

Officer observing as under:-

“9.1 The appellant has merely argued that he has maintained two separate books of accounts for Investment and Trading which are not substantiated. In case, the appellant had done

12 ITA Nos.2701, 774 & 2253/Chny/2018

trading in shares as a business, he was supposed to maintain the relevant books of accounts as required which are exclusive. It is not enough to enter the data at the time of scrutiny assessment and take a print out of the same and submit to the Income Tax Department. Especially in a case where the appellant claims to have done investment in shares, cash flow should be from his own bank accounts. Strangely the appellant has invested money in benami accounts and transacted in shares as found out by the Investigation Wing and the AO. Further, the transactions by the appellant are intermingled not only between the trading and investment, but also in respect of fund flow from the bank accounts held by him, and from accounts held in the name of others. 9.2 ……. 9.3……. 9.4 On the basis of facts of the appellant's case, I hold that the AO has rightly assessed Rs.1,43,58,040/- as Income from trading in business and the same is confirmed.”

Aggrieved, now the assessee is in appeal before the Tribunal.

and circumstances of the case. We also noted facts from case

records, including assessment order, order of the CIT(A),

written submissions filed by the assessee and other documents

filed. From all sides, it is gathered the assessee does trade in

shares, but also purchases equity shares and hold the same as

investment in its books of account. The assessee is getting

books audited, as is evident from the audit report. The

13 ITA Nos.2701, 774 & 2253/Chny/2018

assessee claimed that he has maintained accounts in tally

software and at the time of survey, laptop containing tally data

was under repair and hence, at that particular point of time

books of account could not be produced and that became

basis of Assessing Officer’s finding that the assessee is not

maintaining books of account. The assessee is following a

consistent method of accounting and there is no dispute in

respect of this aspect that in earlier years also the assessee

is investor. Basically, the assessee is investor in shares and

assessed to income-tax, since 1972-73 and declaring surplus

arising out of sale and purchase of shares as long term capital

gain, because he is holding shares for long term. The

assessee in the present case has kept his shares in investment

account and also these were available in D-mat account as

narrated before the Assessing Officer, CIT(A) and even now

before us. Hence, according to us, the assessee has rightly

declared surplus arising out of sale of shares, which were held

as investment, as long term capital gain. Therefore, we reverse

findings of the lower authorities on this issue holding that

surplus arising out of sale of shares as business income and

accept the plea of the assessee.

14 ITA Nos.2701, 774 & 2253/Chny/2018

the CIT(A) confirming addition made by the Assessing Officer

of consultancy service charges received in the shape of units

from Birla group of companies amounting to Rs.23 lakhs as

undisclosed income u/s.68 of the Act.

invested amount with Birla Mutual Fund group in its Birla Cash

Plus scheme. The assessee invested two amounts one for

amount of Rs.25.00 lakhs and another for an amount of

Rs.2,00,000/- with the fund on 25.01.2000. But, the fund was

erroneously credited into assessee’s account with two amounts

of Rs.25.00 lakhs each, thereby resulting in excess credit to

his account of Rs.23.00 lakhs during the year ended

31.03.2000. It was explained by the assessee that

corresponding units was also credited to the assessee’s

account, a copy of fund account statement was enclosed in

assessee’s paper book at pages 35 & 36 along with bank

statement at page 37 of the paper book, which shows that

15 ITA Nos.2701, 774 & 2253/Chny/2018

credit was given wrongly twice for this amount of Rs.25.00

lakhs. The assessee before the Assessing Officer explained

that this amount of Rs.23.00 lakhs was earned by the assessee

in assessment year 2000-01 to 2003-04 and claimed same on

account of rendering consultancy service and purchase units of

Birla group cases in this year. The assessee received units

from Birla group of companies and redeemed the units

subsequently. The assessee during the course of survey,

agreed to admit this income for assessment year 2004-05, but

not offered the income in this year. Hence, the Assessing

Officer treating the income as undisclosed income assessable

u/s.68 of the Act for amount of Rs.23.00 lakhs. Aggrieved, the

assessee preferred an appeal before the CIT(A).

Officer observing as under:-

“9.5 Hence, the Assessing Officer added the above

in AY 2004-05. Since the above addition is based on

appellant’s own admission and the same is nothing

but income of the appellant, the addition of

Rs.23,00,000/- is confirmed.”

16 ITA Nos.2701, 774 & 2253/Chny/2018

Aggrieved, now the assessee is in appeal before the Tribunal.

and circumstances of the case. We noted that the assessee

filed return of income for the assessment year 2000-01 to 2003-

04, but no income rendering consultancy services to Birla

Mutual Fund group for a sum of Rs.23 lakhs was disclosed.

The assessee has received units from Birla group and

redeemed units subsequently, because the assessee was not

obliged to repay the amount to Birla group of companies as

unit has been allotted to the assessee on account of services

rendered by him to the said company. We noted that the

assessee has disclosed any income and now, on the redeem of

Birla Mutual Fund units, the assessee has not declared any

income. The assessee admitted during the course of survey

and stopped further enquiry. We noted that the assessee

cannot escape from assessment of this amount of Rs.23 lakhs,

because, he has redeemed Birla Mutual Fund units in the very

same year, whereas there is no investment. Hence, the entire

redeemed amount is to be assessed as taxable. The

17 ITA Nos.2701, 774 & 2253/Chny/2018

Assessing Officer has rightly assessed the same and we

confirm the said addition.

ITA No.2253/Chny/2018 (AY : 2005-06):

various grounds of additions numbering into 1 to 9 which are

inter-mixed and hence, the assessee has filed a chart of

issues for consideration and additions made by the Assessing

Officer and confirmed by the CIT(A) . The assessee has given

chart in accordance with grounds of appeal and relevant issues

raised in regard to additions are given in the chart which we will

discuss point-wise.

of the Act is in regard to deposits made in bank account

amounting to Rs.45,83,262/- and unexplained investment

u/s.69A of the Act being deposits made in D-mat accounts.

The assessee has given complete details of nature of addition

which are to be considered read as under:-

Unexplained Investments u/s 69A in BANK ACCOUNTS - Rs. 45,83,262 The entire investments were made (1) Investment in the name of Vishwamber out of the accounted funds of Jumani- Rs. 21,75,390/- the Assessee in different names

18 ITA Nos.2701, 774 & 2253/Chny/2018

(partly sustained to the tune of Rs. to increase the possibility of 12,66,532/-) allotment of IPOs. The consolidated cash book showing (2) Investment in the name of A. Sumathi- the trail of investments were Rs. 1,09,594/- placed before the lower authorities and enclosed herewith. (3) Investment in the name of BagwandasJumani - Rs. 22,97,846/- Unexplained Investments u/s 69A in D-MAT ACCOUNTS (1) Investment in the name of Vishwamber Jumani- Rs. 18,14,992/- (2) Investment in the name of A. Sumathi- Rs. 34,718

Assessing Officer during verification of de-mat account of the

assessee noticed that a list of shares as reported in page 3 of

point 5(a) of audit report amounting to Rs.4,17,384/- were not

recorded in the books and hence, he treated the same as

unexplained investment of the assessee. Subsequently, the

Assessing Officer noticed that the assessee has made

unaccounted investments in the name of Mr. Vishwambar

Jumani, Mrs. A.Sumathi and Mr. Bagwandas Jumani i.e.,

deposits made in bank accounts which were quantified by the

Assessing Officer as under:-

19 ITA Nos.2701, 774 & 2253/Chny/2018

investment in d-mat account maintained with Integrated

Enterprises in the name of Mr. Vishwambar Jumani

amounting to Rs.18,14,992/- and D-mat account maintained

with Appollo Sindoori in the name of A. Sumathi of Rs.

Rs.34,718/-, which was treated as unexplained investment

and added as income from other sources. The Assessing

Officer also required to explain investments made in the name

of Mr. Vishwambar Jumani, Mrs. A.Sumathi and assessee

himself Mr.Bagwandas Jumani amounting to Rs.21,75,390/-,

1,09,594/- and Rs.22,97,846/- respectively aggregating to

Rs.45,82,830/-. The assessee before the Assessing Officer

contended that the assessee is unable to prove that these

amounts were used for circulating in investments,but could not

file any evidences to prove inter-linking of investments. The

Assessing Officer also rejected claim of the assessee that these

shares were declared under VDIS’ 1997, as the assessee

failed to file any proof or any evidence to explain source.

Similarly, the CIT(A) also confirmed addition just on the basis

20 ITA Nos.2701, 774 & 2253/Chny/2018

of his findings. Aggrieved, now the assessee is in appeal before

the Tribunal.

accounts for interlinking transactions to which ld. Sr.DR

objected, because according to him, these are fresh evidences,

but the learned counsel for the assessee contended that these

are not fresh evidences, even these were filed before the

Assessing Officer as well as CIT(A), but none of the authorities

has gone into these details. We noted from written submissions

filed before the CIT(A) on 18.08.2017 and noted that the

assesseehas tried to explain these investments by filing various

evidences. We have taken a close look on the evidences filed

and noted that we have no mechanism to verify the

transactions individually or we have no mechanism to

ascertain veracity of the documents, hence, in the interest of

justice, without speaking on merit, we remit this issue back to

the file of the Assessing Officer for fresh adjudication, after

considering all the evidences filed before the CIT(A) or even

now filed before us. The Assessing Officer will also examine

shares declared under VDIS’1997 and whatever sale

proceeds out of the same, he can decide explanation of the

21 ITA Nos.2701, 774 & 2253/Chny/2018

assessee as per law. In term of the above, we restore the

above issue back to the file of the Assessing Officer for fresh

adjudication.

regards to order of the CIT(A) confirming action of the

Assessing Officer in treating surplus arising out of sale of

shares as business income, instead of short term capital gain

amounting to Rs.20,13,370/-.

and circumstances of the case. We noted that the Assessing

Officer from the tax audit report noted that the assessee has

claimed profit from the following IPOs:-

TCS Ltd Rs.11,21,359

NTPC Rs. 8,92,021

Total Profit : Rs.20,13,380/-

According to the Assessing Officer, the assessee has disclosed

income under head ‘short term capital gain’, but the

Assessing Officer has treated the same as business income, just on the basis that SLP filed by the department against the

22 ITA Nos.2701, 774 & 2253/Chny/2018

decision of the Hon’ble Madras High Court in the case of

Trishul Investments Ltd is pending. No citation of Trishul

Investments Ltd., or any details were given and even now,

nothing was argued neither by the learned counsel for the

assessee nor learned D.R. The CIT(A) also confirmed action

of the Assessing Officer in assessing surplus arising out of sale

of shares at Rs.20,13,770/- as income from trading on

business as against declared by the assessee as income from

short term capital gain.

into detail and hence, we cannot decide this issue at this level.

Hence, we remand this issue back to the file of the Assessing

Officer, who will consider what is actual nature of transaction

and facts and then decide whether income is from short term

capital gain or income from trading of shares. Hence, this issue

is remitted back to the file of the Assessing Officer.

regards to shares of HDFC and investments made in the same

was considered in the present assessment year amounting to

23 ITA Nos.2701, 774 & 2253/Chny/2018

Rs.2,35,500/. The learned counsel for the assessee before us

stated that these shares were purchased in earlier years.

of the CIT(A), we could not find such issue in the orders of the

lower authorities. Further, no argument was advanced by either

side on this issue. Hence, the same is dismissed.

regards to order of the CIT(A) confirming addition of unexplained investments made u/s.69 of the Act amounting to

Rs.10,20,000/-.

and find that there is no such addition, but while going

through order of the CIT(A),we noted that the CIT(A) has

identified this credit amount of Rs.10,20,000/- and has

confirmed this addition by observing as under:-

“9.1.5 On 10.04.2004, there was a credit of Rs.10,20,000/-. In the written submission the assessee has stated that this amount was added which is from redemption. On verification of this amount with reference to the evidence for investment a sum of Rs.10,20,000/- was refunded to Shri Vishamber Jumani and hence, the Assessing Officer

24 ITA Nos.2701, 774 & 2253/Chny/2018

has rightly added the same to the income of the assessee.”

was raised by the CIT(A) for the first time, we remit this issue

back to the file of the Assessing Officer, who will verify and

then decide according to law whether this particular entry of

Rs.10,20,000/- on 10.04.2004 is explained or not. Accordingly,

this issue is remitted back to the file of the Assessing Officer.

regards to investments made in the name of Smt. A.Sumathi

for Rs.36,332/-. We noted that we have already considered this

amount while sending back the issue of main ground of

unexplained investments u/s.69 of the Act in the bank account

and set aside this issue back to the file of the Assessing

Officer, the same ratio will apply to this issue. Hence, this

issue is already set aside to the file of the Assessing Officer and

allowed for statistical purposes.

regards to disallowance of interest paid to Parameshwari Trust

25 ITA Nos.2701, 774 & 2253/Chny/2018

to the extent of Rs.48,600/- on the ground that no TDS was

deducted on the payment. The CIT(A) simply confirmed action

of the Assessing Officer and even before us, no explanation

was submitted by the assessee as to how this interest paid is

allowable. Hence, the same is dismissed.

regards to order of the CIT(A) not reducing income by Rs.23

lakhs as declared in the revised return of income. We noted

that on the very same issue, we have already confirmed the

addition hereinabove in ITA No.774/Chny2018 for the

assessment year 2004-05 vide para no. 18 of this order. Hence,

this cannot be sustained, because that will tantamount to

double addition. Hence in this year, we delete the addition.

Hence, this issue is allowed.

regards to order of the CIT(A) confirming claim of expenses of

Rs.2,63,240/-. After hearing both sides and on going through

facts, we noted that the assessee neither before the Assessing

Officer nor before the CIT(A) , even nor before us, could not file

26 ITA Nos.2701, 774 & 2253/Chny/2018

any evidence in support of this expense. Hence, the same is

dismissed.

statistical purposes .

Order pronounced in the open court on 19th April, 2023

Sd/- Sd/- ( महावीर िसंह ) (अ!ण खोडिपया) ( Arun Khodpia ) ( Mahavir Singh) लेखा सद�य लेखा सद�य / Accountant Member लेखा सद�य लेखा सद�य उपा�य� उपा�य� उपा�य�/ Vice-President उपा�य�

चे�ई/Chennai, �दनांक/Date: 19.04.2023 DS

आदेश क� �ितिलिप अ�ेिषत/Copy to: 1. Appellant 2. Respondent 3. आयकर आयु� (अपील)/CIT(A) 4. आयकर आयु�/CIT 5. िवभागीय �ितिनिध/DR 6. गाड� फाईल/GF.