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Income Tax Appellate Tribunal, RAJKOT
Before: SHRI RAJPAL YADAV & SHRI PRADIP KUMAR KEDIA
PER RAJPAL YADAV, JUDICIAL MEMBER :- Present four appeals are directed at the instance of the assessees against separate orders of ld.CIT(A) of even dated i.e. 20.8.2018 passed on the respective appeals of the assessees. All these appeals are disposed of by this common order for the sake of convenience.
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Sole grievance of the assessees is that the ld.CIT(A) has erred in confirming fine levied by the AO under section 234E of the Income Tax Act by holding that no appeal is maintainable against an order passed under section 234E of the Act.
Facts on all vital points are common in the case of all the appeals. Brief facts of the case are that the appellants were engaged in sale of scrap. According to the AO, as per section 206(C) every person being a seller at the time of debiting of the amount payable by the buyer to the accounts of buyer or at the time of receipt of such amount from such buyer in cash or by issuing cheque, collect an amount from such buyer specified in colum-2 of the table attached to the section. In other words, being a seller, assessee was required to collect taxes at source from the buyer at the time of sale of scrap. Section 206C(1A) further provide that seller will not be required to collect the tax from the buyer if such buyer furnishes to the seller a declaration in writing (in duplicate) in prescribed form and verified in the prescribed manner to the effect that goods referred to in column (2) of the aforesaid table are to be utilised for the purpose of manufacturing, processing or producing article or things. In other words, if the buyer was going to use goods purchased from the assessees in manufacturing activities, and they give a declaration in specified form at the time of buying the goods, then TCS will not require to be collected from such buyer. Apart from these two conditions, the assessee was required to prepare and submit a statement in form no.27EQ to the prescribed income-tax authority within the prescribed time under Rule 31AA of the Income Tax Rules 1962. Thus, according to the AO all these assessees have committed a default within the meaning of section 206C(6) and 206C(7) of the Act. Orders under sections 206C(6) and 206C(7) were passed holding the assessees as assessee-in-default on account of non-collection of taxes at the time of sale. For making a reference, we take note of the facts from
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M/s.Vishal Enterprise. According to the AO this concern sold scrap of Rs.22.68 crores in the F.Y.2012-13 relevant to the Asstt.Year 2013-14. It is required to collect TCS of Rs.22.68 lakhs. But failed to collect the TCS and also failed to submit Form No.27EQ for the year under consideration. Similarly, in the case of Shri Rakesh Basantilal Ladha scrap worth Rs.68.65 lakhs was sold and TCS of Rs.68,656/- was not collected, nor statement in form No.27EQ was submitted. Orders under sections 206C(6) and 206C(7) were passed on 17.3.2017 whereby TCS liability of Rs.68,656/- was determined in the case of Rakesh B. Ladha. In the case of Vishal Enterprises, such liability was determined at Rs.22,68,692/- vide order dated 30.3.2017. Dissatisfied with these orders, all these assessees went in appeals before the ld.CIT(A).
During the pendency of these appeals, the ld.AO has passed orders under section 234E in the case of assessees on 17.3.2017 except in the case of Vishal Enterprise, which was passed on 30.3.2017. The ld.AO has determined the delay in submitting form no.27EQ and levied fine at the rate of Rs.200/- per day. Such delay was 1402 days in the case of Vishal Enterprises and Rakesh b. Ladha; 1037 days delay in the cases of Shri Parag Makanbhai Pansara and Jayeshbhai K. Dangariya. The fine under section 234E could be levied either at the rate of Rs.200/- per day for the period of default or equivalent to the amount of TCS, whichever is lower. In the case of Vishal Enterprises, TCS amount was Rs.22,68,692/- whose fine under section 234E was determined at Rs.12,48,800/- on the basis of number of days calculated by the AO. However, in the case of Rakesh B. Ladha, TCS was Rs.68,656/-. Penalty was restricted equivalent to this amount. Similar exercise was carried out in respect of other assessees. Dissatisfied with this levy of penalty, all the assessees went in appeal before the CIT(A). The ld. First Appellate Authority, after detailed examination of facts, held that appeal against order under section 234E is not maintainable. The finding is verbatim same in the cases,
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except variation of amounts and dates. For the facility of reference, we take up the findings recorded in the case of Rakesh Basantilal Ladha as under:
“5. The order u/s. 234E as well as written submission of the AR of the appellant as reproduced in initial paragraphs of this appeal order have been considered. The ground of appeal of the appellant is reproduced in initial paragraph of this appeal order. However, this submission of AR of the appellant is not found to be acceptable. It is mentioned that the order passed u/s. 234E of the Act levying the fee for late filing of quarterly statement in form 27EQ for the period prior to 01/06/2015 is not appealable as per section 246A of the IT Act. Charging of fee u/s. 234E has been made by recasting clause (c) of sub-section (1) of section 200A so as to make intimation/order u/s. 200A rectifiable u/s. 154 of the Act and appealable u/s. 246A of the Act only after 01/06/2015.
5.1 The ITO TDS Wd-3, Jamnagar has passed the order in the case of assessee u/s. 234E and not u/s. 200A of the Act. The Hon'ble H igh Court of Gujarat in the case of Rajesh Kourani Vs Union of India (2017),83 taxmann.com 137 has held that With effect from 1/06/20 15, this provision (i.e. provisions of section 200A) specifically provides for computing the fee payable u/s. 234E. As per the Hon'ble High Court of Gujarat prior to 1/06/2015, the provision did not include any reference to the fee payable u/s. 234E of the Act. As per the hon'ble High Court of Gujarat by recasting sub-section(l), the new clause (c) permits the authority to compute the fee, if any, payable by the assessee u/s. 234E, and by virtue of clause (d), adjust the said sum against the amount paid under the various provisions of the Act. As per the hon'ble High Court of Gujarat If at all, the recasted clause (c) of sub-section (1) of section 200A would be in the nature of clarificatory amendment. As per the hon'ble High Court of Gujarat even in absence of such provision, as noted, it was always open for the revenue to charge the fee in terms of section 234E. As per the Hon'ble High Court of Gujarat by amendment, this adjustment was brought within the fold of section 234E and this would have one direct effect. As per the Hon'ble High Court of Gujarat an order passed u/s, 200A is rectifiable u/s. 154 and is also appealable u/s. 246A. As per the Hon'ble High Court of Gujarat in absence of power of authority to make such adjustment u/s. 200A, any calculation of the fee would not partake the character of the intimation under said provision and it would be argued that such an order would not be open to any rectification or appeal. From these observations of the Hon'ble High Court of Gujarat, it can be said that by amendment in section 200A, this adjustment (i.e. charging of fees u/s. 234E as per clause (c) of sub-section 1 of section 200A) was brought within the fold of section 234E and this would have one direct effect i.e. an order passed u/s. 200A is rectifiable u/s. 154 and is also appealable u/s. 246A. In absence of power of authority to make such adjustment u/s. 200A any calculation of the fee would not partake the character of the intimation under said provision and
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that such an order would not be open to any rectification or appeal. Thus from these observations of the Hon'ble High Court of Gujarat, it can be said that only order passed u/s. 200A is rectifiable under 154 and is also appealable under 246A and therefore, any separate order passed u/s. 234E of the Act levying the fee for late filing of quarterly statement in form 27EQ for the period prior to 01/06/2015 is not appealable as per section 246A of the IT Act. Charging of fee m/s. 234E has been made by recasting clause (c) of sub-section (1) of section 200A so as to make intimation/order u/s. 200A rectifiable u/s. 154 of the Act and appealable u/s. 246A of the Act only after 01/06/2015. 5.2 In view of the facts and legal position as discussed in just preceding paragraph of this appeal order, the appeal of the appellant as filed against the order u/s. 234E of the Act is here by dismissed.”
The ld. Counsel for the assessee while impugning orders of the Revenue authorities relied on the decision of Maharashtra Cricket Association Vs. DCIT, 74 taxmann.com 6 and also Gajanan Constructions V. DCIT, 73 taxmann.com 380 and contended that intimation generated after processing TDS statement is subject to rectification under section 154 and appealable under section 246A, since demand issued by the AO is deemed to be a notice of payment under section 156. The ld.CIT(A) has dismissed appeals of the assessees on the basis of surmises without examining legality of the issue. He further submitted that subsequently, the ld.CIT(A) has found that appellant was not liable to collect tax source under section 206C as the assessees have collected form no.27C and submitted the same though belatedly and the ld.CIT(A) deleted the demand raised under section 206C vide order dated 25.1.2019 and 28.1.2019 for the Asstt.Years 2013-14 and 2014- 15 respectively. It is therefore submitted that on that basis assessees are not liable to collect TCS and also not liable to file quarterly TCS returns in form 27EQ.
On the other hand, the ld.DR relied upon the order of the CIT(A) as well as judgment of Hon’ble Gujarat High Court in the case of Rajesh Kourani vs. Union of India, 83 taxmann.com 137 (Guj).
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We have duly considered rival submissions and gone through the orders passed under sections 206C(6) and 206C(7) of the Act. Assessees went in appeals before the ld.CIT(A). According to learned Counsel, the ld.CIT(A) allowed their appeals vide order dated 25.1.2019 and held that since all these assessees have collected form No.27C from the purchasers of scrap, disclosing therein that such scrap will be used in manufacturing or processing. Such declaration was taken in accordance with prescribed rules. Only lapse at the end of the assessees was that these forms were not submitted well in time, but they were submitted before the assessment proceedings and this fact was brought to the notice of the AO. As observed earlier, if the purchaser submits such declaration then the assessee being seller was not required to collect tax at source. Hence, if it was not required to collect TCS then submission of statement in form no.27EQ will be a procedural formality. Demand raised under sections 206C(6) and 206C(7) of the Act stand deleted. In the absence of such demand, non-filing of form no.27EQ is technical and venial breach only. The appellants could be under the impression that since there is no requirement to collect tax at source, or it was NIL TCS, therefore, there would not be any requirement to submit such forms. According to the ld.counsel for the assessee, these orders have become final because tax effect except in Vishal Enterprise is less than monetary limit for challenging orders of the CIT(A) in further appeal. On account of subsequent development i.e. after orders of the CIT(A) dated 25.1.2009 against the orders passed under sections 206C(6) and 206C(7) of the Act, foundation of order passed under section 234E stands extinguished. These orders are being depended upon the default of the assessee for collection of tax. In other words, if there was no TCS liability, the submission of the form stating zero tax collection in form no.27EQ will be merely a formality. It is more so that fine under section 234E could not exceed element of TCS liability required to be collected by the assessee. This development has taken place after order passed under section 234E as well as
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after decision of the ld.CIT(A). A perusal of the CIT(A)’s impugned orders would indicate that the appeals of the assessees have been dismissed for reasons that no appeal is being provided under the Act against the order passed under section 234E. The ld.CIT(A) has made reference to the decision of Hon’ble Gujarat High Court in the case of Rajesh Kourani (supra). Before considering this decision and appreciating the finding of the ld.CIT(A), we would like to take note of section 234E considered by the Hon’ble Gujarat High Court w.e.f. 1.7.2015 and section 200A(1). It reads as under:
"Fee for default in furnishing statements. 234E.(1) Without prejudice to the provisions of the Act, where a person fails to deliver or cause to be delivered a statement within the time prescribed in sub- section (3) of section 200 or the proviso to sub-section (3) of section 206C, he shall be liable to pay, by way of fee, a sum of two hundred rupees for every day during which the failure continues. (2) The amount of fee referred to in sub-section (1) shall not exceed the amount of tax deductible or collectible, as the case may be. (3) The amount of fee referred to in sub-section (1) shall be paid before delivering or causing to be delivered a statement in accordance with sub-section (3) of section 200 or the proviso to sub-section (3) of section 206C. (4) The provisions of this section shall apply to a statement referred to in sub- section(3) of section 200 or the proviso to sub-section (3) of section 206C which is to be delivered or caused to be delivered for tax deducted at source or tax collected at source, as the case may be, on or after the 1st day of July, 2012." *** **** *** “14. Section 200A(1) of the Act prior to 01.06.2015 provided as under: Section 200A(1) "Processing of statements of tax deducted at source. 200A. (1) Where a statement of tax deduction at source [or a correction statement] has been made by a person deducting any sum (hereafter referred to in this section as deductor) under section 200, such statement shall be processed in the following manner, namely:— (a) the sums deductible under this Chapter shall be computed after making the following adjustments, namely:— (i) any arithmetical error in the statement; or
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(ii) an incorrect claim, apparent from any information in the statement;
(b) the interest, if any, shall be computed on the basis of the sums deductible as computed in the statement; (c) the sum payable by, or the amount of refund due to, the deductor shall be determined after adjustment of amount computed under clause (b) against any amount paid under section 200 and section 201, and any amount paid otherwise by way of tax or interest; (d) an intimation shall be prepared or generated and sent to the deductor specifying the sum determined to be payable by, or the amount of refund due to, him under clause (c); and (e) amount of refund due to the deductor in pursuance of the determination under clause (c) shall be granted to the deductor: (f) the amount of refund due to the deductor in pursuance of the determination under clause (d) shall be granted to the deductor:] Provided that no intimation under this sub-section shall be sent after the expiry of one year from the end of the financial year in which the statement is filed. Explanation.—For the purposes of this sub-section, "an incorrect claim apparent from any information in the statement" shall mean a claim, on the basis of an entry, in the statement— (i) of an item, which is inconsistent with another entry of the same or some other item in such statement; (ii) in respect of rate of deduction of tax at source, where such rate is not in accordance with the provisions of this Act; (2) For the purposes of processing of statements under sub-section (1), the Board may make a scheme for centralised processing of statements of tax deducted at source to expeditiously determine the tax payable by, or the refund due to, the deductor as required under the said sub-section." With effect from 01.06.2015, sub-section (1) of section 200A was amended. In the amended form, the same provision reads as under: Section 200A(1) "Processing of statements of tax deducted at source. 200A. (1) Where a statement of tax deduction at source [or a correction statement] has been made by a person deducting any sum (hereafter referred to in this section as deductor) under section 200, such statement shall be processed in the following manner, namely:—
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(a) the sums deductible under this Chapter shall be computed after making the following adjustments, namely:— (i) any arithmetical error in the statement; or (ii) an incorrect claim, apparent from any information in the statement; (b) the interest, if any, shall be computed on the basis of the sums deductible as computed in the statement; (c) the fee, if any, shall be computed in accordance with the provisions of section 234E; (d) the sum payable by, or the amount of refund due to, the deductor shall be determined after adjustment of the amount computed under clause (b) and clause (c) against any amount paid under section 200 or section 201 or section 234E and any amount paid otherwise by way of tax or interest or fee; (e) an intimation shall be prepared or generated and sent to the deductor specifying the sum determined to be payable by, or the amount of refund due to, him under clause (d); and (f) the amount of refund due to the deductor in pursuance of the determination under clause (d) shall be granted to the deductor:] Provided that no intimation under this sub-section shall be sent after the expiry of one year from the end of the financial year in which the statement is filed. Explanation.—For the purposes of this sub-section, "an incorrect claim apparent from any information in the statement" shall mean a claim, on the basis of an entry, in the statement— (i) of an item, which is inconsistent with another entry of the same or some other item in such statement; (ii) in respect of rate of deduction of tax at source, where such rate is not in accordance with the provisions of this Act; (2) For the purposes of processing of statements under sub-section (1), the Board may make a scheme for centralised processing of statements of tax deducted at source to expeditiously determine the tax payable by, or the refund due to, the deductor as required under the said sub-section."
Relevant discussion made by the Hon’ble High Court reads as under: “17. In essence, section 234E thus prescribed for the first time charging of a fee for every day of default in filing of statement under sub-section (3) of
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section 200 or any proviso to sub-section (3) of section 206C. This provision was apparently added for making the compliance of deduction and collection of tax at source, depositing it with Government revenue and filing of the statements more stringent. 18. In this context, we may notice that section 200A which pertains to processing of statements of tax deducted at source provides for the procedure once a statement of deduction of tax at source is filed by the person responsible to do so and authorizes the Assessing Officer to make certain adjustments which are prima-facie or arithmetical in nature. The officer would then send an intimation of a statement to the assessee. Prior to 01.06.2015, this provision did not include any reference to the fee payable under section 234E of the Act. By recasting sub-section (1), the new clause-c permits the authority to compute the fee, if any, payable by the assessee under section 234E of the Act and by virtue of clause-d, adjust the said sum against the amount paid under the various provisions of the Act. 19. In plain terms, section 200A of the Act is a machinery provision providing mechanism for processing a statement of deduction of tax at source and for making adjustments, which are, as noted earlier, arithmetical or prima-facie in nature. With effect from 01.06.2015, this provision specifically provides for computing the fee payable under section 234E of the Act. On the other hand, section 234E is a charging provision creating a charge for levying fee for certain defaults in filing the statements. Under no circumstances a machinery provision can override or overrule a charging provision. We are unable to see that section 200A of the Act creates any charge in any manner. It only provides a mechanism for processing a statement for tax deduction and the method in which the same would be done. When section 234E has already created a charge for levying fee that would thereafter not been necessary to have yet another provision creating the same charge. Viewing section 200A as creating a new charge would bring about a dichotomy. In plain terms, the provision in our understanding is a machinery provision and at best provides for a mechanism for processing and computing besides other, fee payable under section 234E for late filing of the statements. 20. Even in absence of section 200A of the Act with introduction of section 234E, it was always open for the Revenue to demand and collect the fee for late filing of the statements. Section 200A would merely regulate the manner in which the computation of such fee would be made and demand raised. In other words, we cannot subscribe to the view that without a regulatory provision being found for section 200A for computation of fee, the fee prescribed under section 234E cannot be levied. Any such view would amount to a charging section yielding to the machinery provision. If at all, the recasted clause (c) of sub-section (1) of section 200A would be in nature of clarificatory amendment. Even in absence of such provision, as noted, it was always open for the Revenue to charge the fee in terms of section 234E of the Act. By amendment,
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this adjustment was brought within the fold of section 200A of the Act. This would have one direct effect. An order passed under section 200A of the Act is rectifiable under section 154 of the Act and is also appealable under section 246A. In absence of the power of authority to make such adjustment under section 200A of the Act, any calculation of the fee would not partake the character of the intimation under said provision and it could be argued that such an order would not be open to any rectification or appeal. Upon introduction of the recasted clause (c), this situation also would be obviated. Even prior to 01.06.2015, it was always open for the Revenue to calculate fee in terms of section 234E of the Act. The Karnataka High Court in case of Fatheraj Singhvi (supra) held that section 200A was not merely a regulatory provision, but was conferring substantive power on the authority. The Court was also of the opinion that section 234E of the Act was in the nature of privilege to the defaulter if he fails to pay fees then he would be rid of rigor of the penal provision of section 271H of the Act. With both these propositions, with respect, we are unable to concur. Section 200A is not a source of substantive power. Substantive power to levy fee can be traced to section 234E of the Act. Further the fee under section 234E of the Act is not in lieu of the penalty of section 271H of the Act. Both are independent levies. Section 271H only provides that such penalty would not be levy if certain conditions are fulfilled. One of the conditions is that the tax with fee and interest is paid. The additional condition being that the statement is filed latest within one year from the due date. 21. Counsel for the petitioner however, referred to the decision of Supreme Court in case of CIT v. B.C. Srinivasa Setty [1981] 128 ITR 294/5 Taxman 1 (SC), to contend that when a machinery provision is not provided, the levy itself would fail. The decision of Supreme Court in case of B C Srinivasa Setty (supra) was rendered in entirely different background. Issue involved was of charging capital gain on transfer of a capital asset. In case on hand, the asset was in the nature of goodwill. The Supreme Court referring to various provisions concerning charging and computing capital gain observed that none of these provisions suggest that they include an asset in the acquisition of which no cost can be conceived. In such a case, the asset is sold and the consideration is brought to tax, what is charged is a capital value of the asset and not any profit or gain. This decision therefore would not apply in the present case. 22. In the result, petition fails and is dismissed.” 9. A perusal of the judgment of Hon’ble High Court would indicate that the challenge before the Hon’ble Court was that a statement of tax deducted at source could be processed under Section 200A of the Act. It was contended that, prior to its amendment with effect from 01.06.2015, there was no
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mechanism to levy fine under Section 234E while processing the TDS statement under Section 200A of the Act. Thus, according to the petitioner, no fine could be levied under Section 234E of the Act. This contention of the assessee was rejected by the Hon’ble High Court and it was held that fine can be levied independently under Section 234E of the Act, because Hon’ble Court was of the view that Section 234E is a charging section and for a levy of fee is not depended upon machinery provision.
The impugned orders alleged to have been passed under Section 234E by the learned CIT(A) were passed on 30.03.2017. The learned CIT(A), while holding that these orders were passed independently under Section 234E and therefore no appeal is maintainable, failed to take note the amendment carried out in Section 200A(1) with effect from 1st June 2015. It is pertinent to note that Section 200 casts a duty upon the person deducting tax to deposit the same with the Central Government. Sub-section (3) requires to submit statement of such deduction in prescribed form within prescribed time limit as provided under Rule 31AA of the Income-tax Rules, 1962. Such statements are to be processed under Section 200A and, while carrying out this exercise of processing, the Assessing Officer can levy fine as per Section 234E of the Act. A procedure has been provided for processing the statement of deduction of tax under Section 200A. It is a machinery provision and the Assessing Officer is required to follow the procedure contemplated under this section. At the cost of repetition, we would like to note of clause (c) of sub- section (1) of Section 200A, which has been introduced with effect from 01.06.2015, as under:- “200A(1)(c) the fee, if any, shall be computed in accordance with the provisions of section 234E;” 11. The judgment of the Hon’ble High Court propounds that, in the absence of this procedure, a fine could be levied under Section 234E because it
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was a charging section; but, once a procedure has been provided by the legislature, then it does not give discretion to the Assessing Officer whether he is exercising such powers under Section 234E or he is exercising the powers while processing the statements. It is true that in the present case statements were not filed, but this fact came to the notice of the Assessing Officer while passing the order under Section 206C(6)/206C(7). He processed that fact from the date on which statements ought to be filed by the assessee. Once a procedure has been provided, then it is to be construed that the order has been passed by the Assessing Officer after following the procedures. Merely by mentioning Section 234E in the title of the order, it would not become an order passed under Section 234E in isolation - more particularly when subsequent development shows that these orders are patently invalid and not sustainable, because their foundation holding the assessee in-default and calculating fine from the date of default has been extinguished after the orders of the CIT(A) passed against the orders passed under Section 206C(6)/206C(7). The learned CIT(A) has held that the assessees were not liable to collect TCS. In that situation, subsequent orders passed under Section 234E r.w.s. 200A would become without any jurisdiction and invalid.
Before us, orders of the CIT(A) against the orders of the Assessing Officer under Section 206C(6)/206C(7) have been placed in the cases of Rakesh B. Laddha, Jayesh K. Dangariya and Parag M. Parsana. In the case of Vishal Enterprise, no such order has been placed. Therefore, taking cognizance of the orders of the CIT(A) in these three cases, we quash the impugned order passed by the Assessing Officer in their cases on 17.03.2007. So far as the order passed in the case of Vishal Enterprise is concerned, we remit this issue to the file of the Assessing Officer. In case the assessee produces the order of higher appellate authority holding that no tax was required to be collected, then learned Assessing Officer shall rectify his order.
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In other words, after taking cognizance of such new facts, he will readjudicate the issue in the case of Vishal Enterprise.
With the above observations, the appeals of Rakesh B Laddha, Jayesh K Dangariya and Parag M Parsana are allowed and the appeal of Vishal Enterprise is allowed for statistical purposes.
Pronounced in the Open Court on 31st May, 2019.
Sd/- Sd/- (RAJPAL YADAV) (PRADIP KUMAR KEDIA) JUDICIAL MEMBER ACCOUNTANT MEMBER Ahmedabad; Dated, 31 /05/2019 **vk/bt
आदेश क� ��त�ल�प अ े�षत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant 2. ��यथ� / The Respondent. 3. संबं�धत आयकर आयु!त / Concerned CIT 4. आयकर आयु!त(अपील) / The CIT(A) 5. $वभागीय �'त'न�ध, आयकर अपील�य अ�धकरण / DR, ITAT, Rajkot 6. गाड) फाईल / Guard file. आदेशानुसार/ BY ORDER, TRUE COPY उप/सहायक पंजीकार (Dy./Asstt.Registrar) आयकर अपील�य अ�धकरण / ITAT, Rajkot 1. Date of dictation- 30/05/2019 2. Date on which the typed draft is placed before the Dictating Member 30.05.2019 3. Date on which the approved draft comes to the Sr.P.S./P.S.-. …31.05.2019… 4. Date on which the fair order is placed before the Dictating Member for Pronouncement …31.05.2019….. 5. Date on which the file goes to the Bench Clerk…31.05.2019…..… 6. Date on which the file goes to the Head Clerk……………………………. 7. The date on which the file goes to the Assistant Registrar for signature on the order…………………….. 8. Date of Despatch of the Order………………