M/S.ASIT DIXIT,JABALPUR vs. INCOME TAX OFFICER WARD2(2), JABALPUR

ITA No. 19/Jab/2020 (AY 2005-06) Asit Dixit v. ITO IN THE INCOME TAX APPELLATE TRIBUNAL, JABALPUR BENCH, JABALPUR (SMC) (through Video Conferencing) BEFORE SH. SANJAY ARORA, HON'BLE ACCOUNTANT MEMBER ITA No. 19/JAB/2020 Assessment Year : 2005-06 Asit Dixit, Income Tax Officer, vs. Ward-2(2), Jabalpur (M.P.) Jabalpur [PAN: AANFM 5798A] (Appellant) (Respondent) Appellant by Sh. Sanjay Seth, CA Respondent by Sh. S.K. Halder, Sr. DR Date of hearing 16/09/2021 Date of pronouncement 07/10/2021

ORDER Per Sanjay Arora, AM This is an Appeal by the Assessee directed against the Order by the Commissioner of Income Tax (Appeals)-28, Mumbai (Camp at Jabalpur) (‘CIT(A)’ for short) dated 02/01/2014, dismissing the assessee’s appeal contesting its’ assessment under section 144 of the Income Tax Act, 1961 (‘the Act’ hereinafter) for the Assessment Year (AY) 2005-06 vide Order dated 24/11/2010. 2. The appeal raises two grounds, as under, which shall be taken up in seriatim: ‘1. That the assessee had filed ITR declaring loss of Rs. 26,130 and the AO has estimated profit at Rs. 6,44,516 by estimating the net profit of 2% on sales turnover of Rs. 3,22,25,835. Commissioner of Income Tax (Appeals) has upheld the order passed by the AO and dismissed the appeal of the assessee. Estimation of net profit by AO 1

ITA No. 19/Jab/2020 (AY 2005-06) Asit Dixit v. ITO and CIT(A) is not correct and returned loss as declared by the assessee may kindly be accepted. 2. That the AO has made the addition of Rs. 37,80,000 on account of unexplained capital introduced by the partners, Sh. Santosh Jaiswal Rs. 37,00,000 and Sh. Asit Dixit Rs. 80,000. Assessee has submitted the details of capital introduced by both the partners before AO and CIT(A) but both have not accepted and addition made by AO which is confirmed by CIT(A) same is not correct and may kindly be deleted.’ 3. The brief facts of the case are that the assessee, a partnership firm selling country liquor under licence from the State Excise Department, returned it’s income for the year at Rs. (-) 26,130, i.e., after deducting interest to partners at Rs. 4,45,680. The assessee did not produce books of account during assessment proceedings, i.e., in response to notice u/s. 143(2), and it was found by the Assessing Officer (AO) that it had failed to maintain verifiable evidences in respect of sales, sealing and bottling charges, and lease money, the latter two being expenses, claimed at Rs. 51.31 lacs and Rs. 258.99 lacs respectively (PB pg. 74). Rejecting the disclosed book results, he estimated the assessee’s net profit at 2% of the disclosed turnover of Rs. 322.26 lacs, i.e., at Rs. 6,44,516 (refer para 3 of the assessment order). It is this estimation, since confirmed in first appeal, that is being challenged as excessive by the assessee per its’ Gd. 1. Arguments 4. It was contended by Sh. Seth, the ld. counsel for the assessee, that the payment of lease money and sealing & bottling charges are to the agencies of the State Government, and that therefore there is no question of any inflation therein. The non-maintenance of sale bills was though admitted by him, justifying the same on the basis of being a ‘trade practice’; the cash collection for the day being regarded as sale. The AO, it was further submitted, had not cited any comparable case. The ld. Sr. DR, Sh. Halder, would in response rely on the concurrent findings by the assessing and the first appellate authority.

ITA No. 19/Jab/2020 (AY 2005-06) Asit Dixit v. ITO 5. I have heard the parties, and perused the material on record. 5.1 My first observation in the matter is that the assessee has not, at any stage, including before the Tribunal, disputed the invocation of sec. 144, and for which reference is also made to the assessee’s submissions dated 18/6/2012 before the ld. CIT(A) (PB pgs. 66-68), also reproduced in the impugned order (IO) (pgs. 3-5). In fact, as a reading of the assessment order shows, there has been non-compliance of notice/s u/s. 143(2) as well as u/s. 142(1), leading to the best judgment assessment. Reference to sec. 145(3), which also results in the same consequence, thus becomes an additional ground for the application of sec. 144. Further, as regards sec. 145(3), a sale bill is a primary document of any business entity selling goods or services, also having legal implications. It is the sale bill that evidences the sale, raising a charge on the buyer, and on the basis of which the sale consideration can be correlated with the good sold there- against, including the quantity thereof. Yielding thus its sale price, excess of which over the cost thereof is profit by definition. This is irrespective of whether the sale consideration is received/receivable wholly or partly in cash (legal tender) and, further, of whether the buyer demands his copy thereof or not. As regards lease money and sealing & bottling charges, surely one would not normally expect inflation therein, however, there is nothing on record to exhibit the reconciliation of the payments with the amounts claimed, which are in no insubstantial sums. The non-acceptance of the assessee’s book results, and completing the assessment as a best judgment assessment, is, under the circumstances, unexceptional. 5.2 As regards the reasonability of the estimation of profit, in the absence of past history; the current being the first year of the assessee’s business, a comparable case/s becomes the only manner of testing the assessee’s declared results. The ld. CIT(A) has rebutted the comparable case cited by the assessee before him (refer pg. 9 of the IO). A perusal of the said order by the Tribunal (in 3

ITA No. 19/Jab/2020 (AY 2005-06) Asit Dixit v. ITO ITA No. 159/Jab/2009, dated 13/7/2012), placed at pgs. 3-10 of the assessee’s paper-book, though not adverted to during hearing, shows that in that case the assessee disclosed a net profit of Rs. 1,74,530 on a sale of Rs. 328.72 lacs, justifying the same – which found acceptance by the Tribunal, on the basis of loss on account of unutilized lease money at Rs. 8,09,338, stock against which could not be lifted due to dull market conditions. No such claim obtains in the instant case, which pertains to the preceding year. The normal profit, i.e., but for the said loss, is thus Rs.9,79,868, or about 3% of sales, the quantum of which approximates that by the assessee for the relevant year. It is this profit rate that is therefore relevant and comparable. The said case, which is thus comparable, favours the Revenue’s estimation rather than being supportive of the assessee’s case. Rather, normal market conditions, as against dull, which obtained in that year, would yield a still higher profit rate. Why, the assessee’s disclosed profit is at 1.3%, as against 3% in the cited case. The Hon’ble jurisdictional High Court in Badri Prasad Bhagwandas & Co. v. CIT [1995] 82 Taxman 109 (MP) approved a net profit rate of 5% of sales. The estimation of the net profit of the liquor business at 2% of sales is, thus, reasonable, and upheld. I decide accordingly, and the assessee fails on its’ Gd. 1. 6. Gd. 2 agitates the addition of Rs. 37.80 lacs, credited by the assessee in its’ accounts in the name of its’ two partners, i.e., Sh. Santosh Jaiswal and Sh. Asit Dixit, at Rs. 37 lacs and Rs. 0.80 lacs respectively. The assessee’s case is that Sh. Asit Dixit participated in a lottery system in February, 2004 to obtain Country Liquor Shop (CLS) of the Government of MP, and was successful in getting three such shops for f.y. 2004-05. As the same involved capital, i.e., toward earnest money; arranging bank guarantee, etc., which he did not have, Sh. Dixit (AD) made Sh. Jaiswal (SJ) his partner with 75% share, and who provided the necessary capital. Accordingly, the balance-sheet of the firm as on 31/3/2004 is as under: (PB pg. 65) 4

ITA No. 19/Jab/2020 (AY 2005-06) Asit Dixit v. ITO M/s. Asit Dixit - Balance-Sheet as on 31.03.2004 Sr. Liability Amount (Rs.) Sr. Credit Amount (Rs.) 1. Capital A/c. 37,00,000 1. Earnest Money 18,00,000 Partner deposited with Excise Santosh Department Jaiswal 2. FDR (Allahabad Bank) 11,87,100 2. Capital A/c. 80,000 Partner Asit 3. Bank Guarantee 1,18,730 Dixit expenditure 4. Advance Local duty 2,00,000 5. Cash-in-hand 47,960 Total 37,80,000 Total 37,80,000 The same, however, did not find acceptance with the AO for the following reasons: i) Sh. Jaiswal was stated to have introduced capital by way of Bank FDR in 2004, but no such FDR was found in his balance-sheet; ii) He was further stated to have withdrawn capital from his Sand business, but no withdrawals were found in M/s. Santosh Jaiswal (Sand Contract) (PB pgs. 36-49, at pg. 48); iii) No date-wise details of withdrawal of Rs. 37 lacs, nor his personal books, were furnished; iv) No evidence to substantiate the built-up or otherwise of savings by Sh. Asit Dixit, was provided. These findings were endorsed by the ld. CIT(A). His decision, at para 3.3 (pgs. 8-10) of his order, read out during hearing, is based on and comprises the following reasons: a). the assessee-firm came into existence only vide partnership deed dated 26/4/2004, w.e.f. 01/4/2004. How could it be then said that the capital was 5

ITA No. 19/Jab/2020 (AY 2005-06) Asit Dixit v. ITO introduced by the partners in the firm during the preceding year, i.e., fy 2003- 04?; b). no documents to show the huge cash withdrawal of Rs. 145 lacs by Sh. Santosh Jaiswal (in fy 2003-04) had been submitted, nor its break-up so as to exhibit its investment, furnished despite being called for; c). no linkage had been established between the cash withdrawn and the investment in the assessee-firm; d). no evidence/details as to savings, the stated source of capital attributed to Sh. Asit Dixit, had been produced, nor his tax returns furnished. Arguments 7. The assessee’s case before me remained the same. The withdrawal (Rs. 145 lacs) by SJ was from M/s. Santosh Jaiswal (Ratlam), also in liquor business (as evidenced from its’ Balance-Sheet (PB pgs. 20-35, at pg. 32)), and not his Sand business, as stated by the AO. The amount was withdrawn cash, and introduced in the assessee-firm from 18/2/2004 to 31/3/2004 by way of partner’s capital. It is for this reason that the same is reflected as the closing capital in the names of its’ two partners as on 31/3/2004 (PB pg. 65) and as opening capital (on 01/4/2004), the latter sought to be explained thus by way of a CA certificate dated 27/8/2012 furnished in the remand proceedings. Sh. Dixit, prior to venturing into this business, worked as a sales manager in a liquor firm, drawing a salary of Rs. 10,000 to Rs. 12,000 per month, and which explains the nominal capital of Rs. 80,000 attributed to him. The Revenue’s case, again not assailed before me with any material, also remains the same. Decision 8. I have heard the parties, and perused the material on record. 8.1 At the very outset, it may be clarified that the fact of the profit of the business having been estimated is by itself no bar for regarding a credit in the books of the business as unexplained and, thus, as its’ income, as explained by the Apex Court per its’ decisions, as in Kale Khan Mohd. Hanif v. CIT [1963] 6

ITA No. 19/Jab/2020 (AY 2005-06) Asit Dixit v. ITO 50 ITR 1 (SC); CIT v. Devi Prasad Vishwanath Prasad [1969] 72 ITR 194 (SC). This legal aspect, though to be fair was not canvassed before me, is yet clarified in view of it continuing to be raised before the Tribunal. In fact, irrespective of a pleading being assumed by either party before it, the Tribunal is duty bound to decide an appeal, being a continuation of the assessment proceedings, in accordance with law. Why, in the facts of the case, it is abundantly clear that the amounts under reference have no relation with the trading profit arising to the assessee on the sale of liquor. 8.2 The first aspect of the matter, which would relate to both the sums under reference, is that the firm came into existence only w.e.f. 01.04.2004 and, therefore, cannot have any opening capital, which implies a carry forward of closing capital, i.e., as on 31/3/2004. Further, inasmuch as the different assets, viz. Earnest Money, FDR, etc. cannot be said to be of the assessee-firm, being non-existent on that date, the balance-sheet as on 31.03.2004 also cannot be said to be of the assessee-firm. Per contra, the firm claiming to be the owner of the assets as reflected in its’ Balance-Sheet as on 01/4/2004, the first day of it’s existence, even as it cannot be said to be the owner thereof as at the close of 31/3/2004, nor has shown any receipt of funds on 01/4/2004, it is liable to satisfactorily explain the nature and source thereof, failing which the same could be assessed as its’ income chargeable to tax. The Revenue’s argument is valid, and is precisely the reason why the assessee is being called upon to explain the credits in its’ accounts, which, therefore, can only be regarded as on 01.04.2004, the beginning of the year, i.e., even if investments by the concerned creditors were made during the preceding year, enjoining the assessee to explain the nature and source thereof, which otherwise could only be enquired into, and in the event of the same being not explained, brought to assessment as income for the preceding year. Sh. Seth would during hearing explain this by stating that the partnership was in 7

ITA No. 19/Jab/2020 (AY 2005-06) Asit Dixit v. ITO existence during f.y.2003-04, albeit per an oral contract, and came to be evidenced vide an instrument only on 26.4.2004, effective 01.04.2004 (at PB pgs. 61-64). The contention is untenable. The partnership deed, in that case, would clearly record this fact, stating of the partnership being effective from an earlier date. That apart, the different assets stated as held by the firm as on 31.03.2004, would be in the name of the firm, which is neither claimed, much less shown, at any stage, including before me. Why, the license issued by the State Excise Department, not furnished despite being called for by the Revenue, would also be in the name, or endorsed in favour, of the assessee-firm. Rather, the claim of an oral arrangement (i.e., prior to 01.04.2004) itself clarifies that there was no instrument of partnership, i.e., in writing, for the said period, which could have been furnished to the respective Departments, viz. Excise Department, Collector, Bank, State Warehouse (for sealing and bottling), etc. by the firm toward registration and monies paid to/deposited, therewith, by, or for or on behalf of, the assessee-firm. The matter, it may be appreciated, has serious implications qua the genuineness of the impugned credits. Why would anyone, one may ask, invest without consideration, even if only in the form of a firm arrangement, which casts a serious shadow of doubt on the genuineness of the impugned credits, being ostensibly toward capital contribution by the partners. Continuing further, the tax collection at source on the purchases made during the year (at Rs. 2,50,487/PB pg. 73), which are from the State Excise Deptt., is to the account of the assessee-firm (PAN:AANFM 5798A), in which the creditors are partners. This would allay all doubts with regard to the genuineness of the impugned credits. The nature thereof as partners’ capital, i.e., as contribution toward the capital of the partnership, can thus be said to have been established. The only import of this fact, i.e., of the firm being not in existence up to 31/3/2004, that therefore obtains is that the assessee has been validly called 8

ITA No. 19/Jab/2020 (AY 2005-06) Asit Dixit v. ITO upon to explain the credits (which can extend only to sums credited during the relevant year) in the names of its’ partners, and in the event of non (or non- satisfactory) explanation thereof as to their source, deemed as its’ income chargeable to tax u/s. 68 of the Act. The law makes no difference on the basis of the date, the first or the last day of the previous year, whereat a sum comes to be credited in the books of the assessee; the premise being of the assessee being the beneficiary of the sum/s credited (Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC); Kale Khan Mohamed Hanif v. CIT [1963] 50 ITR 1 (SC), affirming the decision by the Hon’ble jurisdictional High Court in [1958] 34 ITR 609 (MP)). This is irrespective of whether the credit in the assessee’s books is to the account of a partner or another (Govindarajulu Mudaliar (supra); CIT v. Metachem Inds. [2000] 245 ITR 160 (MP); CIT v. Kishorilal Santoshilal [1995] 216 ITR 9 (Raj)). 8.3 I may next consider both the sums credited on the merits of the explanation/s furnished: (a) Rs.80,000/- ( Sh. Asit Dixit) The source of this sum stated to be the savings (capital) of AD, built-up over the period of his service as a sales Manager in a liquor firm, drawing Rs. 10,000 to Rs.12,000 per month. The claim is wholly unsubstantiated, which is the principal reason for its’ non-acceptance by the Revenue, being otherwise a plausible explanation, particularly considering its’ quantum, value of which though, given the current price levels, cannot be equated with the same amount today. There is no bank account or otherwise anything to demonstrate the savings over a period of time. Why, even the name of the concern where he was working, or the period of his service, both relevant from the standpoint of the truth of the explanation, have not been stated, much less shown. Even if the salary, as stated, was received, and held, in cash, not impractical, particularly considering its volume, all that 9

ITA No. 19/Jab/2020 (AY 2005-06) Asit Dixit v. ITO was required was to obtain a letter to that effect or a salary certificate from the said firm. In fact, the utility or the value of money is not constant across all persons, and it depends largely on the quantum of the sum under question with reference to his total capital at the relevant time. In the instant case, going by the explanation furnished, the same perhaps represents the total capital (or at least that represented by movable property) of the creditor, so that it is surprising that he holds the entire of it in cash, which, apart from being non- remunerative, is a very risky proposition. Further, savings would, apart from income, the stated source thereof, also depend on the financial obligations of the concerned person, viz. toward family, etc. He may, for all we know, have parents, siblings, or even children to support, including their education, or may have financed assets on EMI, etc. This is no whisper, much less exhibition, qua this relevant aspect in the assessee’s explanation. In fact, a savings bank account, not exhibited, is, apart from safe-keeping, a very enabling instrument for savings, as one could deposit Rs. 1000 or 2000 (say) from his monthly salary, i.e., assuming so, withdrawing or retaining the balance in cash for meeting his household/day-to-day expenses. The explanation, totally un-evidenced, accordingly fails on all fours. There is in fact no explanation, i.e., in the eyes of law. That adjudication by any authority, including the Tribunal, the final fact-finding body, is to be based on, and with reference to, the material on record, is well-settled (viz. CIT v. Radha Kishan Nandlal [1975] 99 ITR 143 (SC); CIT v. Daulat Ram Rawatmull [1973] 87 ITR 349 (SC)). The said credit has, under the circumstances, been rightly regarded by the Revenue as not proved. (b) Rs.37,00,000/- (Sh. Santosh Jaiswal) The source has, again, been ascribed to the creditors’ capital, withdrawn from another partnership firm, Santosh Jaiswal (Ratlam), also a Jabalpur based liquor dealer. 10

ITA No. 19/Jab/2020 (AY 2005-06) Asit Dixit v. ITO The reason for its’ non-acceptance is two-fold. There is nothing to show that the said withdrawal has been in cash and, two, no date-wise breakup of the same has been provided. Also, and equally, in the absence of any break-up of the withdrawal, stated to be in cash, it cannot be linked with the investment in his name in the assessee-firm, the stated avenue of the said withdrawal. How, pray, are these objections by the Revenue to be faulted with, even as no explanation toward the same was forthcoming during hearing as well? In case of a direct transfer of funds, each debit to his capital account in Santosh Jaiswal (Ratlam) would get reflected as a corresponding credit in his account with either the assessee-firm (or, rather, the payee-entity inasmuch as the assessee was not in existence up to 31.03.2004), or any other entity/investment avenue, as indeed credited to the capital account in M/s. SJ (Sand) (PB pg. 48). However, that being not the case, it is only the cash account in the (personal) books of SJ, reflecting the cash amounts withdrawn by him (from any source) that would exhibit the source and, correspondingly, the application of cash with him. The summary of his capital account in the books of M/s. Santosh Jaiswal (Ratlam) for f.y. 2003-04 (PB pg.32), as indeed at PB pg. 48, does not exhibit date-wise withdrawal nor of it being in cash and, rather, reflects another withdrawal of Rs.74 lacs as well as a capital introduction at Rs.80 lacs, again emphasizing the need for the cash account aforesaid, which would include all these entries, thereby explaining the investment in the assessee-firm. This would further also include another withdrawal (for FDR) at Rs.2,42,786, which may be relevant; the assessee stating before the AO of SJ having introduced capital (in the assessee-firm) in the form of FDR in 2004 out of his past capital. The assessee, who has thus though made out a prima facie case, cannot be said to have discharged the burden of proof cast on it by law. The matter is accordingly set aside to the file of the AO to provide an opportunity to the assessee to state its’ case before him. Surely, it is extremely 11

ITA No. 19/Jab/2020 (AY 2005-06) Asit Dixit v. ITO undesirable that matters should get remitted back after years. An appeal, however, is to be decided based on the evidence on record and consistent with the justice of the case. All that was required; the accounts of the firm/s from which the cash was withdrawn and the firm/s it stands invested in, being, as apparent (PB pgs. 20-49), audited, was to give a date-wise account of the cash available with SJ, from whatever source, summarized extract of which, in other firms, is placed on record. Why, one wonders, the ledger account of SJ in these firms was not provided, which would exhibit both the date and the manner of the withdrawal, which could then be matched with his ledger account with the assessee-firm, only on the basis of which he is stated by the assessee to have invested therein from 18/2/2004 to 31/3/2004? While on facts one finds that the assessee did not even produce its’ own books of account before the AO. It would therefore only be fair to allow the assessee a final opportunity toward proving its’ case. I am conscious that the assessment being a best judgment assessment, which continues to obtain, a remission would amount to in effect overturning the same. This is as only materials furnished by the assessee or otherwise gathered by the AO could form the basis of such an assessment. It is the best judgment of the assessing authority and not of any other, so that it would, unless shown to be vitiated, hold (CIT v. Rayala Corporation (P.) Ltd. [1995] 215 ITR 883 (Mad)). The addition under reference however is not based on or the result of any estimate by the AO based on the material on record. But one made in view of an unsatisfactory explanation inasmuch as it is not substantiated. Not producing the evidence which the assessee is expected to be possessed of would even otherwise entail an adverse inference (Union of India v. Rai Deb Singh Bist [1973] 88 ITR 200 (SC)). The question that therefore obtains is whether the assessee is under the given facts and circumstances of the case; the matter already having traversed through assessment, remand and first appellate stage, 12

ITA No. 19/Jab/2020 (AY 2005-06) Asit Dixit v. ITO to be allowed a further opportunity. It is this question that needs to be addressed, and qua which this Tribunal considers the answer as in affirmative. Further, even as such a remission would usually be at a cost, particularly considering the non-cooperation before the AO, it is being abstained from in the facts and circumstances of the case. I am conscious, I may add, that SJ has a negative capital in the firm Santosh Jaiswal (Ratlam), which in fact exceeds his investment in the assessee-firm. Rather, the said firm itself has no capital. In view of his negative balance therein, there is no question of his withdrawing his capital therefrom, and which therefore is not a correct description of the source of his investment in the assessee-firm. That, however, would not materially alter the assessee’s explanation as to source, which, thus, is to be regarded as a borrowing from SJ (Ratlam), a firm in which he is a 30% partner (PB pgs. 20- 21). In fact, it has been already clarified that the immediate source of investment by SJ can only be said to be the cash available with him, on the relevant dates, from any source, accounts of all of which, as it appears, are audited. In fact, that all the relevant accounts stand maintained and, further, audited, is itself a reason for remission inasmuch as it indicates the existence of the relevant evidence with the assessee, while at the same time though it does make it unfathomable that the same were not produced and relied upon in evidence, and despite abundant opportunity provided to do so. Needless to add, the AO, in the event of the assessee being not cooperative, shall be at liberty to draw all permissible inferences in law. He shall adjudicate afresh per a speaking order, in accordance with law, taking into account all the explanations and materials furnished by the assessee before him. 8.3 I decide accordingly. 9. Sh. Seth also made an oral plea for allowance of interest to partners, disallowed in assessment. The same is indefensible in view of the clear, not disputed, application of sec. 144 (also refer para 5.1), so that a firm, though 13

ITA No. 19/Jab/2020 (AY 2005-06) Asit Dixit v. ITO assessable as a firm, is yet not entitled to deduction, inter alia, in respect thereof (s. 184(5) r/w s. 185). This is irrespective of the fact that the assessee-firm, despite not holding the licence, may yet be validly carrying on the liquor business, as sought to be canvassed with reference to the provisions of the Akbari Rules as applicable for f.y. 2004-05 (PB pgs. 84-91). Another aspect of the matter, which therefore needs to be clarified, is that to the extent the firm’s capital is regarded as unexplained and, thus, as its’ income, no claim qua interest on partner’s capital would even otherwise survive thereon. 10. In the result, the assessee’s appeal is partly allowed for statistical purposes. Order pronounced in the Open Court on October 07, 2021 Sd/- (Sanjay Arora) Accountant Member Dated: 07/10/2021 Aks/ Copy of the Order forwarded to: 1. The Appellant: M/s. Asit Dixit c/o Kartik Hotel, Napier Town, Jabalpur (M.P.) 2. The Respondent: Income Tax Officer, Ward-2(2), Jabalpur (M.P.) 3. The Pr. CIT-1, Jabalpur 4. The CIT(Appeals), Jabalpur 5. The Sr. DR, ITAT, Jabalpur 6. Guard File // True Copy //