INCOME TAX OFFICER, WARD 3 3 5, AHMEDABAD vs. VASANI INFRASTRUCTURE, AHMEDABAD

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ITA 2303/AHD/2025Status: DisposedITAT Ahmedabad06 August 2026AY 2010-1113 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the decision of the CIT(A) that the reassessment order was time-barred as it was passed beyond the period prescribed under Section 153 of the Income-tax Act. Consequently, the addition made in the reassessment order was quashed.

What were the facts?

The Assessing Officer (AO) made an addition of Rs. 18,16,00,121/- as unexplained investment based on documents seized during a search on a third party. The assessee challenged the reassessment order as being barred by limitation.

What were the issues?

Whether the reassessment order passed by the AO was barred by limitation as per Section 153 of the Income-tax Act. Whether the addition made under Section 69A was valid when the reassessment itself was time-barred.

Which sections of the Income-tax Act were involved?

Section 153,Section 69A,Section 147,Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “C” BENCH, AHMEDABAD

Before: DR. B.R.R. KUMAR, VICE-SHRI RAHUL CHAUDHARY

For Appellant: Shri Vartik Choksi, AR
For Respondent: Shri Jai Singh, CIT-DR &, Shri C. Darni Nath, Sr. DR, Shri Vartik Choksi, AR
Hearing: 16.06.2026Pronounced: 06.08.2026

Heard together (2 matters)

ITA No. 2303/Ahd/2025
CO No. 100/Ahd/2025

Read from the judgment's own cause title. This page is filed under one of them.

PER DR. B.R.R. KUMAR, VICE-PRESIDENT:

-

This appeal has been filed by the Revenue and the corresponding Cross Objection has been filed by the assessee against the order dated 01.09.2025, passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as “Ld. CIT(A)”] under section 250 of the Income-tax Act, 1961 [“the Act”] for the Assessment Year (AY) 2010-11. 2. The Revenue has raised following grounds of appeal:- “(1) The Ld. CIT(A) erred in law and on facts in calculating the number of days available before the AO for completion of the order passed u/s 153(2) of the IT Act, 1961. (2) The Ld. CIT(A) erred in law and on facts in deleting the addition made on account of unexplained investment u/s 69A of the IT. Act, 1961 amounting to Rs. 18,16,00,121/-. (3) The Ld. CIT(A) erred in law and on facts by not appreciating the facts of the case that the department had seized the documents (during the course of - 2– search & seizure at Venus Group) which clearly showed receipt of on-money of Rs.18,16,00,121/- from the assessee. (4) The Ld. CIT(A) erred in law and on facts by relying on the decisions which are not relevant, especially reliance on the decision of the Hon'ble Supreme Court of India in the case of Radhasoami Satsang v. CIT(1992) ITR 321(SC). (5) The Ld. CIT(A) erred in law and on facts by stating that no further appeal was filed by the Revenue against the orders of Ld. CIT(A) in the following cases of other co-owners of the same land, which are enumerated below along with the corresponding ITA numbers for the appeals filed by the Revenue against the orders of Ld. CIT(A), which are pending in ITAT:

S N Name AY ITA No. 1 Hareshbh¡i Ravjibhai Vasani 2010-11 ITA 1297/AHD/2019 2 Ritaben H Vasani 2010-11 ITA 1292/AHD /2019 3 Ravjibhai Popat Vasani 2010-11 ITA 1296/AHD/2019 4 Babubhai Popatbhai Vasani 2010-11 ITA 1293/AHD/2019 5 Kailashben Madhubhai Vasani 2010-11 ITA 1298/AHD/2019 6 Madhubhai Popatbhai Vasani 2010-11 ITA 1294/AHD /2019 7 Ravjibhai P Vasani, L/H Smt. 2010-11 ITA 1291/AHD/2019 Savitaben R Vasani (6) The appellant craves leave to add, alter and or to amend all or any the ground before the final hearing of the appeal.”

3.

Ground No. 5 – These Revenue’s appeals have already been dismissed by the Tribunal owing to low tax effect.

4.

On receipt of notice in the Revenue’s appeal, the assessee has filed Cross Objection bearing CO No.100/Ahd/2025 for AY 2010-11, wherein the following grounds have been raised:- “1. In the law and in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) has erred in confirming the validity of the assessment order, failing to appreciate that the impugned order passed by the Assessing Officer under section 143(3) r.w.s 147 of the Act dated 19.07.2018 is bad in law, void ab initio, and lacks juri iction.

2.

In the law and in the facts and circumstances of the case, the Ld. CIT(A) has erred in not holding that since the assessment proceedings were initiated solely on the basis of incriminating material/documents seized during a search conducted on a third party (Venus Group) the Assessing Officer was mandatorily required to assume juri iction u/s 153C of the Act, and - 3– consequently, the proceedings initiated u/s 147 are void ab initio and bad in law.”

5.

Briefly stated facts, as culled out from the records for AY 2010-11, are that the assessee filed its return of income declaring Nil income. Subsequently, on the basis of information received from the Investigation Wing consequent to a search conducted u/s 132 in the case of Venus Group on 10.03.2015, notice u/s 148 of the Act was issued on 31.03.2017. According to the Assessing Officer, certain seized documents, cash vouchers, unaccounted day cash books and other incriminating material allegedly revealed that the assessee had made cash payment of Rs.18,16,00,121/- to the Venus Group towards purchase of land situated at Sargasan/Tarapur during Financial Year 2009-10. The Assessing Officer observed that despite issuance of notices u/s 142(1), 143(2), 129 and repeated show cause notices, the assessee failed to satisfactorily explain the seized material. Accordingly, vide order dated 19.07.2018 passed under section 143(3) read with section 147 of the Act, the Assessing Officer treated the aforesaid amount as unexplained investment u/s 69A of the Act and added the same to the total income of the assessee.

6.

Aggrieved by the order of the Assessing Officer, the assessee preferred an appeal before the Ld. CIT(A), challenging the validity of the reassessment on the ground that the reassessment order had been passed beyond the limitation prescribed u/s 153 of the Act. The Ld. CIT(A), after examining the chronology of events, the statutory provisions contained in section 153 and Explanation 1 thereto as well as the judicial precedents relied upon by the assessee, held that the reassessment order dated 19.07.2018 was barred by limitation. Consequently, the reassessment was annulled and the addition was deleted.

7.

Aggrieved by the order of the Ld. CIT(A), the Revenue is now in appeal before the Tribunal, whereas the assessee has filed Cross Objections challenging the assumption of juri iction u/s 147/148 of the Act.

- 4–

8.

Before us, the Ld. DR relied upon the assessment order and submitted that the reassessment was validly completed on the basis of incriminating material seized during the search in the case of Venus Group. He contended that the Ld. CIT(A) erred in holding the reassessment to be barred by limitation and prayed that the order of the Assessing Officer be restored.

9.

The Ld. AR, on the other hand, supported the order of the Ld. CIT(A) and submitted that the reassessment order dated 19.07.2018 was admittedly passed beyond the limitation prescribed u/s 153 of the Act. He relied upon the findings of the Ld. CIT(A) and the judicial precedents cited therein, and submitted that once the reassessment is held to be time-barred, the addition on merits does not survive.

10.

We have heard the rival submissions and carefully perused the material available on record. We have also gone through the assessment order, the impugned appellate order and the judicial precedents cited before us. It is pertinent to note the observation made by the Ld. CIT(A) with regard to the reassessment u/s 147/148 of the Act. By a detailed order dated 01.09.2025, he held that the reassessment order was barred by limitation in terms of the provisions of section 153 of the Act and the relevant observations of the Ld. CIT(A) are reproduced below::-

“6.2 Vide Ground No. 2 : The appellant has challenged that the reassessment order has been passed after the expiry of time limit prescribed u/s 153 of the Act. The fact on the record is that the appellant has filed return of income on 30/09/2010 declaring total income at NIL. A notice under Section 148 was issued on 31/03/2017. The reassessment order was passed on 19/07/2018 under Section 143(3) read with Section 147, determining the total assessed income as Rs. 18,16,00,121/-. The entire addition was made out of unexplained investment in land. The appellant objected to the assessment order on the ground that such order is time-barred, as it was not completed within the period provided under Section 153 of the Act. During appellate proceedings, the appellant has submitted that it had filed objections to the reassessment notice via a letter dated 24/11/2017, and made assertion that the notice issued by the A.O was legally invalid. The AO disposed the objections by letter dated 01/12/2017, stating that the objections could not - 5– be entertained after 60 days had lapsed, as the reasons for reassessment were provided to the appellant. Further, Show Cause Notice was issued on 04/12/2017, to which the appellant has responded on various dates (paper book pages 24–67). The appellant has submitted that the AO completely ignored these detailed/replies filed by the appellant and failed to address the objections while completing the re-assessment . The Appellant in the course of the appeal proceeding has submitted that reassessment order is time-barred as per the provision of Section 153 of the Income Tax Act, 1961. The appellant has referred to provision of Section 153 of the Act, which sets the time limit for completing assessments, reassessments, and re-computations. Specifically, Explanation 1 to Section 153 excludes certain periods when computing the limitation period, including: (i) Time taken for reopening proceedings or giving the assessee an opportunity to be reheard under Section 129. (ii) Periods during which assessment proceedings are stayed by a court order or injunction. The appellant has submitted that he had obtained an interim stay from the Hon’ble Gujarat High Court on 21/12/2017, which prevented the AO from passing the final assessment order without court permission. The Hon'ble High Court dismissed the appellant’s writ petition on 02/04/2018, and the stay was vacated. The Appellant has provided a detailed chart at para 3.6 of its submission dated 17/06/2025 to submits that reassessment order is time barred. The table is produced below:

Sr. No. Particulars Dates 1 Date of issuing notice u/s 148 31.03.2017 2 Date on which notice u/s 148 was served on the 31.03.2017 Appellant 3 End of the Financial Year in which the notice was 31.03.2017 served 4 Nine months from the end of the Financial Year in 31.12.2017 which notice was served Time limit given for Assessing Officer to pass order u/s. 147 (as per section 153(2)) 5 Stay order passed by the Gujarat High Court against 21.12.2017 Writ Petition filed by the Appellant 6 Days remaining for AO to complete the assessment 10 after HC order [4-5 7 Final order passed by the Gujarat High Court and stay 02.04.2018 vacated against Writ Petition filed by the Appellant 8 Number of days which will be excluded in computing the time limit (As per expl. 1 to sec 153(4)) [7-5]

- 6– Since the time remaining is less than 60 days, time 60 period is extended to 60 days [As per proviso to Expl. 1 to Sec 153(4)] 10 Date within which order u/s. 147 has to be passed and 02.06.2018 served upon the Assessee [7+9]

The appellant has relied upon several judicial Authority to support the argument that the reassessment order is time-barred. The appellant has also submitted that on similar issue, in the case of another family member, Shobbaben Kirankumar Vasani (one of the co-owner of the property purchased by appellant firm), the Ld. CIT(Appeals) ruled in favor of the assessee on 25/03/2019, confirming that the reassessment order was time- barred. On strength of this submission, the Appellant has strongly contended that the reassessment order passed by AO is time barred and hence the same needs to be upheld accordingly.

Having carefully considered the reassessment notice, reassessment order, submission filed by the Appellant along with paper-book, it is noted that Section 153 of the Act prescribes the time limits for completing assessments, reassessments, and re-computations. Specifically, Section 153(2) governs the time limit for reassessments under Section 147 of the Act. For A.Y, 2010-11, as per provisions of the Act, the reassessment must be completed within one year from the end of the financial year in which the notice under Section 148 was served, subject to certain exclusions. Explanation 1 to Section 153 provides for the exclusion of specific periods when computing the limitation period, including: (i) The time taken in reopening the whole or any part of the proceeding or giving an opportunity to the assessee to be reheard under the proviso to Section 129. (ii) The period during which the assessment proceeding is stayed by an order or injunction of any court. Further, the first proviso to Explanation 1 states that where, after excluding the periods mentioned above, the remaining period available for assessment is less than 60 days, such remaining period shall be extended to 60 days, and the period of limitation shall be deemed to be extended accordingly.

The appellant has submitted the following timeline, which is critical to determining the limitation period:

1.

Date of Notice under Section 148 of the Act- 31/03/2017

2.

Interim Stay by Hon'ble Gujarat High Court- Stayed on 21/12/2017 which prohibited the AO from passing the final re-assessment order.

3.

Vacation of Stay: The Hon'ble Gujarat High Court dismissed vacated the stay on 02/04/2018. Hence, as per Section 153(2), the reassessment order should have been completed by 31/03/2018 (one year from the end of the financial year in which the notice was served). It is found that that time limit for passing - 7– reassessment order was 31/12/2017 but Hon'ble Gujarat High Court had stayed such proceedings vide order dated 21/12/2017 which means that 10 days remained for the AO to complete the assessment. Since this was less than 60 days, the limitation period was extended to 60 days from the date the stay was vacated (02/04/2018), i.e., until 02/06/2018. However, the re- assessment has been completed on 19/07/2018. Hon'ble Ahmedabad ITAT in the case of ACIT v. M/s Sun Pharmaceutical Industries Ltd. [ITA No. 1688/AHD/2015, dated 05/05/2017] has held that the limitation period for reassessment begins from the date the High Court vacates the stay, not when the AO receives the order. The Hon’ble Tribunal has held that Explanation 1(ii) to Section 153 excludes the entire period of the stay, and the limitation period restarts immediately upon vacation of the stay. As per the Hon'ble Tribunal, if any order is passed beyond the time limit prescribed u/s 153 of the Act, consequential order would be time barred/invalid order. As per the Hon’ble Tribunal decision in case of ACIT v. M/s Sun Pharmaceutical Industries Ltd (supra), the time limit to pass the order ends on 02/06/2018. Hon’ble ITAT, Ahmedabad in case of ITO v/s MGF Growth Research & Investment Limited in ITA No. 166/Ahd/2016, dated 08/06/2018has reiterated that assessment order passed beyond the time limit prescribed u/s 153 of the Act is invalid. Further, the Hon'ble Allahabad High Court in the case of CIT v. DRS X-ray and Pathology Institute Pvt. Ltd. [2013] 358 ITR 27hasheld that the limitation period under Section 153 does not depend on the communication of the court’s order to the AO. The period of exclusion begins from the date the stay is granted and ends on the date it is vacated. The court rejected the Revenue’s argument that the limitation period should start from the date the AO receives the order, affirming that the statutory scheme under Explanation 1 to section 153 of the Act. Hence, above mentioned judgment clearly establishes the judicial view of period of limitation as prescribed under the Act in clear terms.

It is equally relevant and pertinent to note the findings of Ld. CIT (A)- 7, Ahmedabad in the case of Shobhaben Kirankumar Vasani (one of the co- owners of the property), wherein it is held as under:

“.........................5.4 The Appellant has also contended that Hon'ble Gujarat High Court in its interimorder ha irected AOto continuewith the Assessment Proceedings and held that no final order would be passed without leave of the Court. The AO has not passed any order till 31st December, 2017 which means that present order passed on 30thJuly, 2018 is time barred because as per provisions of Section 153 (2) AO only gets period of nine months for passing the reassessment order since notice is issued on 31st March, 2017. Thereafter the - 8– Appellant has objected that even as per Explanation -1 to Section 153 (4) of the Act, AO ought to have passed the reassessment order on or before 2nd June, 2018 and in support of such contention Appellant has submitted following tabular chart:

Sr. No. Particulars Dates

1.

Date of issuing notice u/s 148 29/03/2017

2.

Date on which notice u/s 148 was served 29/03/2017 on the Appellant

3.

End of the Financial Year in which the notice 31/03/2017 was served 4 Nine months from the end of the Financial Year 31/12/2017 in which notice was served – Time limit given for Assessing Officer to pass order u/s. 147 (as per section 153(2)) 5 Stay order passed by the Gujarat High Court 07/12/2017 against Writ Petition filed by the Appellant 6 Days remaining for AO to complete the 24 assessment after HC order [4 - 5 ] 7 Final order passed by the Gujarat High Court 02/04/2018 and stay vacated against Writ Petition filed by the Appellant 8 Number of days which will be excluded in 116 computing the time limit (As per expl. 1 to sec 153(4)) [7- 5] 9 Since the time remaining is less than 60 days, 60 time period is extended to 60 days [As per proviso to Expl. 1 to Sec 153(4)] 10 Date within which order u/s. 147 has to be 02/06/2018 passed and served upon the Assessee [ 7 + 9 ]

In support of above claim the, Appellant has relied upon following decisions:

i) ACIT, CIR.2(1)(1), Barodaversus M/s. Sun Pharmaceutical Industries Ltd., Baroda 2017 (5) TMI 355 - ITAT AHMEDABAD ii) Allahabad High Court in the case of CIT V/s Chandra Bhan Bansal[2014] 46 taxmann.com 108 (Allahabad) iii) Commissioner of Income-tax V/s DRS X-ray and Pathology Institute Pvt. Ltd. 2013 (11) TMI 19 - Allahabad High Court- Other Citation:[2013] 358 ITR 27 iv) Hon'ble Ahmedabad Tribunal inthe case of ITO Ward- 2(1)(4)Ahmedabad Vs. M/s M.G.F. Growth Research and Investment Ltd in ITA No. 166/Ahd/2016 dated 08/06/2018 - 9– The above referred contention was also taken by Appellant before Assessing Officer vide letter filed on 27th July, 2018 (copy of such letter was provided in Appellate Proceedings) but while passing the Assessment Order on 30th July, 2018, AO has not dealt with such objection and passed the order within three days of receipt of such objection.

5.

5 As Appellant has challenged the validity of reassessment order on the ground that such order has become time barred, the copy of such workin g submitted by Appellant was forwarded to AO for his comments wherein AO has stated that present reassessment order has not become time barred for which following tabular chart was given:

Incidents / particulars Dates

Stay granted by the High Court in this case 07/12/2017 Final order of the High court dated 02/04/2018 was 07/05/2018 received in this office Total no. of days lapsed between grant of stay order 151 days and its vacating order Date of order of High Court vacating stay in this case 02/04/2018 Date within which order u/s 147 has to be passed 31/08/2018 (after adding period of lapse

In above letter, the AO has stated that as there was gap of 151 days before stay order passed by High Court and final order, he gets further period of 151 days from date of order of High Court and on that basis reassessment order gets time barred on 31sqt August, 2018 and he has passed the order on 30th July, 2018 which is within the provisions of the Act. 5.6………..……………….. It can be seen from provisions of Section 153 (2) that AO need to pass Assessment Order or reassessment order within the nine months from end of Financial Year in which notice under Section 148 is served. In present case, AO has issued notice under Section 148 of the Act on 29th March, 2017 hence AO is required to pass the order on or before 31st December, 2018. In such reassessment proceedings Appellant has challenged the validity of reassessment notice before the Hon'ble Gujarat High Court and the Hon'ble High Court has passed an interim order on 7th December, 2017. The copy of said order reproduced in preceding para clearly states that AO can pass reassessment order subject to approval by the High Court. However, in present case AO has not passed any such order nor sought any leave of the High Court till Hon'ble Gujarat High Court has passed final order on 2nd April, 2018. As per the order of Hon'ble Gujarat - 10– High Court there is no blanket stay on reassessment proceedings but such stay is subject to condition therein. Further as per provisions of Section 153 there is an Explanation - 1 attached to such Section which provides period to be excluded while computing period of limitation provided in various sub-sections of Section 153. As per clause - (ii) of such Explanation, period during which Assessment Proceedings is stayed by an order of any Court, such period need to be excluded. In the present case, time barring date of reassessment proceedings for current year was 31st December, 2018 and High Court has passed an interim stay order on 7th December, 2017 which means that AO was deprived from passing the reassessment order for 24 days. It is pertinent to note that further proviso attached to Explanation - 1 which is reproduced herein above, it is clear that if after excluding the period of exclusion as provided in Explanation - 1 (which in present case is24 days), the period of limitation referred in Section 153 (2) available to AO for passing reassessment order is less than 60 days (in present case it is less than 60 days as stated supra), such remaining period shall be extended to 60 days and aforesaid period of limitation shall be deemed to be extended accordingly. From the plain reading of provisions of Section 153 of the Act it is clear that if AO was left with less than60 days for passing the reassessment order in view of the fact that proceedings initiated by him is stayed by Court, he gets period of 60 days and if such period is more than60 days, he gets such more period.

In the present case, as stated supra, AO was deprived from passing reassessment order by 31st December, 2017 by 24 days which means that AO gets further period of 60 days for passing the order from date of passing the order by Hon'ble Gujarat High Court i.e. 2nd April, 2018 and as per such working, AO ought to have passed Assessment Order on or before 2nd June, 2018. In the remand proceeding AO has considered the period of 151 days available with him after considering the date on which High Court has interim stay and the date on which High Court has passed final order. However, while working out such period of 151 days, the AO has completely ignored the material aspects stated in Section 153 (2), clause -(ii) of Explanation - 1 and proviso to said Explanation, which is discussed herein above. The period of limitation need to be computed considering the date on which High Court has given interim stay to due date of passing the reassessment order as provided in Section 153(2). It is pertinent to note that Appellant has raised such argument in reassessment proceeding vide letter dated 27th July, 2018 but same was not rebutted by AO and he proceeded to pass reassessment order on 30th July, 2018 i.e. within a period of 3 days of receipt of objection by the Appellant.

- 11– 5.7……………The above view is supported by the decision of Hon'ble Ahmedabad ITAT in the case of ACIT V/s Sun Pharmaceutical Industries Limited – wherein it is held as under:…… …………………………. The above decisions have extensively dealt with the provisions of Section 153 along with the decisions of various High Courts, as discussed therein, which makes abundantly clear that in present case AO ought to have passed the reassessment order on or before 2nd June, 2018 whereas AO has passed the order on 30th July, 2018 which is nothing but which makes entire order time barred as per provisions of the law discussed herein above. As the reassessment order passed order has become time barred, consequential addition made in such order does not survive. Thus, Ground No. 1 and 2 are allowed and Ground No. 3 is dismissed.”

It is observed that the department has not filed appeal before Hon'ble ITAT against this order.

Based on the detailed discussion and binding judicial precedent cited above, it is held that present reassessment order is time barred in view of provisions of Section 153 of the Act. The AO’s failure to pass the order within limitation period violates the statutory limit. Consequently, the reassessment order is annulled as being barred by limitation. Hence, the consequent addition Rs. 18,16,00,121 also does not survive, arising out of invalid reassessment order.”

11.

From the aforesaid findings of the Ld. CIT(A), it is evident that the notice u/s 148 was admittedly issued and served on 31.03.2017. Therefore, in terms of section 153(2), the reassessment was required to be completed by 31.12.2017. It is also an admitted position that the reassessment proceedings remained stayed pursuant to the interim order passed by the Hon'ble Gujarat High Court on 21.12.2017 and that the said stay stood vacated upon dismissal of the writ petition on 02.04.2018. Thus, on the date of grant of interim protection, only ten days remained for completion of the reassessment. Explanation 1(ii) to section 153 provides that the period during which assessment proceedings remain stayed by any Court shall stand excluded while computing the period of limitation. Therefore, the Assessing Officer had only ten days remaining as on 21.12.2017. ITA Nos. 2303 & 2304 and CO No. 100 & 101/Ahd/2025 - 12– Consequently, after the stay stood vacated on 02.04.2018, the Assessing Officer was entitled only to the extended statutory period of sixty days, which expired on 02.06.2018. However, the reassessment order came to be passed only on 19.07.2018. The Revenue has not brought any material before us to demonstrate that the computation made by the Ld. CIT(A) is contrary to the statutory provisions. The assessment order itself is silent on the issue of limitation and does not disclose any legal basis for passing the reassessment order after 02.06.2018. 12. In view of the foregoing discussion, having re-examined the limitation, we find no infirmity in the well-reasoned order of the Ld. CIT(A) holding that the reassessment order for the assessment year 2010-11 is barred by limitation prescribed u/s 153 of the Act. Since the reassessment has been held to be invalid and is accordingly quashed, the additions made in the reassessment order cease to exist. In such circumstances, it is neither necessary nor expedient to examine the merits of the additions.

Accordingly, the appeal of the Revenue bearing ITA No. 2303/Ahd/2025 is dismissed.

13.

In view of our findings above, the corresponding cross-objection filed by the assessee is dismissed as infructuous.

14.

In the result, the appeal filed by the Revenue and Cross-Objection filed by the assessee, both are dismissed.

The order pronounced in the open Court on 06.08.2026 (RAHUL CHAUDHARY) VICE-PRESIDENT Ahmedabad; Dated 06.08.2026 **btk - 13–

आदेश की "ितिलिप अ"ेिषत / Copy of the Order forwarded to : अपीलाथ"/ The Appellant

1.

""थ"/ The Respondent. 2. संबंिधतआयकरआयु"/ Concerned CIT 3. 4. आयकरआयु"(अपील) /The CIT(A)- 5. िवभागीय"ितिनिध, आयकरअपीलीयअिधकरण, अहमदाबाद/ DR, ITAT, Ahmedabad 6. गाड"फाईल /Guard file. आदेशानुसार/ BY ORDER,सहायकपंजीकार (Dy./Asstt.

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