RAHUL WIRE ROPES,GURGAON vs. ACIT CIRCLE-3(1), GURGAON

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ITA 1441/DEL/2026Status: DisposedITAT Delhi24 July 2026AY 2016-201715 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the surrenders made by the partner were in his individual capacity and not on behalf of the firm. There was no corroborative evidence to link these surrenders to the firm's income, and the partner's subsequent retraction was supported by facts.

What were the facts?

During a survey, a partner of the assessee firm, Shri K. K. Gandhi, made certain surrenders of income in his individual capacity. The Assessing Officer (AO) and CIT(A) confirmed additions to the firm's income based on these surrenders, which the assessee contested.

What were the issues?

Whether surrenders made by a partner in his individual capacity during a survey can be added to the income of the partnership firm, and the evidentiary value of such surrenders.

Which sections of the Income-tax Act were involved?

Section 133A,Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH “G”: NEW DELHI

Before: SHRI MAHAVIR SINGH & SHRI M. BALAGANESH

For Appellant: Shri Parikshit Agarwal, CA
For Respondent: Shri Manish Gupta, Sr. DR
Hearing: 12/05/2026Pronounced: 24/07/2026

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G”: NEW DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER ITA No. 1441/Del/2026 (Assessment Year: 2016-17) Rahul Wire Ropes, Vs. ACIT, 1707, Sector-4, Gurgaon, Circle-3(1), Haryana Gurgaon (Appellant) (Respondent) PAN: AAMFR9203J

Assessee by : Shri Parikshit Agarwal, CA Revenue by: Shri Manish Gupta, Sr. DR Date of Hearing 12/05/2026 Date of pronouncement 24/07/2026

O R D E R PER M. BALAGANESH, AM 1. The appeal in ITA No.1441/Del/2026 for AY 2016-17, arises out of the order of the ld ld. Commissioner of Income Tax (Appeals)-3, Gurgaon [hereinafter referred to as ‘ld. CIT(A)’, in short] dated 13.01.2026 against the order of assessment passed u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 26.12.2018 by the Assessing Officer, ACIT, Circle- 3(1), Gurgaon (hereinafter referred to as ‘ld. AO’).

2.

The only issue to be decided in this appeal is as to whether the ld CIT(A) was justified in confirming the addition of Rs. 4 crores based on the surrender made by the partner of the assessee firm in the facts and circumstances of the instant case.

3. We have heard the rival submissions and perused the materials available on record. The assessee is a partnership firm engaged in the business of manufacturing and trading of wire ropes and allied products. The return of income for the assessment year 2016-17 was filed declaring total income of Rs. 82,49,590/-. The books of accounts are regularly maintained by the assessee and duly subjected to audit u/s 44AB of the Act. The partners of the assessee firm are as under:-

a. Mrs. Kanchan Gandhi b. Shi K. K. Gandhi c. Shri Rahul Gandhi

4.

Sri K. K. Gandhi in his individual capacity is also proprietor of M/s. Koyo Automotive and M/s. Koyo Steels. A survey u/s 133A of the Act was conducted at the business premises of the assessee and aforesaid two proprietorship concerns on 07-10-2015. The address of the assessee firm and that of proprietary concerns are totally different and hence survey was carried out at different locations as under:-

S.No. Place Premises Main Premises M/s Koyo Automotive 1 163/7A, Kadepur, Industrial Area, Gurgaon Manufacturing Unit A-43, Kahrani Industrial Area, Bhiwadi, RIICO, 2 Rajasthan 3 Marketing Office 511, Sector 37, Pace City - II, Gurgaon, Haryana

5.

During the survey, statement of Sri K. K. Gandhi was recorded at the business premises of M/s. Koyo Automotive (proprietary concern of Sri K.K. Gandhi) at 163/7A, Kadarpur Industrial Area, Gurugram, wherein, in the letterhead of the assessee firm, Shri K K Gandhi agreed to make disclosure of

additional income of Rs. 4 crores. The copy of the statement recorded from Sri K. K. Gandhi is enclosed in pages 45 to 48 of the submissions placed on record by the assessee. On perusal of the said statement, it is noted that majority of the questions are posed on Shri K. K. Gandhi about his proprietary concerns and his personal investment in properties. The following are the questions that were posed to him by the survey team in connection with the assessee firm. The relevant questions and the answers given at the time of survey are reproduced below:-

“Q6 Please tell where the activities of Rahul wire ropes have been carried out and tell the names of the two companies whom Rahul wire purchases and sells to. Ans Rahul wire ropes is located at A-43, kehlrni industrial area, bhiwari and the activities are carried out by my son Rahul. It purchases good from Rimjhim industries Kanpur whose godawn is in palwal, m/s panchmahal Gujarat Faridabad, Aarti Steel, Kangroo Steels, brusal wires and B.S. Shakti, Rohtak. The parties to whom they sell to are M/s Ramson industries, m/s Ac Enggg and M/s Madhusudan.

Q. 12 I am showing you page nos. 27 and 28 of Hans Idea Slap PAD No. 44, wherein cash expenses amounting to Rs. 24,08,000/- relating to cement, steel, repairing, etc. have been recorded on 01.09.2015 and 02.09.2015. Further, on page no. 28, cash expenses amounting to Rs. 20,71,000/- relating to tiles, labour, shuttering, etc. have also been recorded. Thus, a total amount of Rs. 44,79,000/- appears to have been paid in cash. Please state whether the said handwriting belongs to you or not. Further, explain the purpose for which the aforesaid payments were made and also explain the source of investment for the same. Ans. I have made the cash payments amounting to Rs. 44,79,000/- as recorded on page nos. 27 and 28 of Annexure-3, and the handwriting on these pages is mine. However, I am unable to explain the source of investment for the said amount. Therefore, this amount of Rs. 47 lakhs (approx.) relating to repair work at the factory situated at Industrial Area, Bhiwadi, in the name of Rahul Wire, is being surrendered as unaccounted income under the head 'Repair'. The same may be added to my annual income. I request that no penalty proceedings may kindly be initiated in this regard."

Q.14 During the course of survey proceedings at M/s Rahul Wire. valuation of stock was carried out by the department and it was found that there was excess stock amounting to Rs. 62,00,000/- as compared to the books of account. You are hereby asked to explain the reasons for such difference and why the same should not be treated as unexplained investment in stock. Ans. It was submitted that the excess stock of Rs. 62 Lakhs is out of books and I am ready to the pay the tax on same and is hereby requested not to attract any penal charges.” 6. Sri K K Gandhi was also questioned about other discrepancies found in his transactions for which he had come forward to surrender the additional income in the survey statement u/s 133A of the Act, which are as under:-

“Q.11 I am showing you Document No. A-2 of the Handwriting Pad, from which page nos. 1 and 2 are being shown to you, wherein an amount of Rs. 70 lakhs was paid to Shri Ram Lal Ji towards purchase of land on 26.05.2015 and an amount of Rs. 76 lakhs was paid to Shri Kishori Lal. Please explain the nature of the advance given by you and also explain the source of investment for the said payments. Ans. I had made payment to Shri Ram Lal JI to the tune of Rs. 70 Lakh on 26.05.2015 and Shri. Kishori Lal to the tune of 76 Lakh but I am unable to explain the source. Therefore, I am surrendering the same amount to be taxed. Q. 13 I am showing you the back page no. 113 of A-4 in which you have made the cash payment of Rs. 1cr. on different dates from 17.04.2025 to 20.06.2025. Please explain us why this payment is made out of which 15 Lakh is made through cheque Ans. On 17.04.2015, I had received Rs. 15 lakhs in cash as advance against sale of property. The said cash payment of Rs. 15 lakhs was received from RTGS parties. However, at present, I am unable to explain the source of investment/payment made in cash. Therefore, to buy peace of mind and avoid litigation, I voluntarily surrender the said amount of Rs. 15 lakhs as my additional/unaccounted income for the current year and request that the same may kindly be added to my income. It is further requested that no tax penalty proceedings may kindly be initiated against me in this regard. Q.15 I am showing you the page no. 114 of the Annexure-I in which Rs. 22 Lakh was paid to the PC jewellers against the purchase of gold coin and same is not disclosed in books of accounts? Ans. I accepted that I had purchase the gold coin amounting to Rs. 22 Lakh in cash and I am ready to pay the tax on the same and is hereby requested not to attract any penal charges. Page | 4 Q.16 I am showing you the annexure no. Al to A. In these annexures there are some signatures on various pages. Please tell me about these pages which were found from your business premise and the same were belong to you or not and what do you want to say about the same? Ans. Yes, these signatures were found from my business premise M/s koyo Automobiles, Gurgaon and for the discrepancy found from these notings, I am ready to pay the additional Rs. 23 Lakh over the income and I am surrendering the same as an additional income.”

7.

From the above, it could be seen for all the discrepancies, Sri K. K. Gandhi in his individual capacity had come forward to offer the additional income in his hands. While this is so, it is not known how the disclosure of additional income of Rs. 4 crores got reflected by way of surrender in the letterhead of the assessee firm. When the transactions per se does not pertain to the assessee firm except with regard to repairs and renovation and valuation of stock as could be seen from the aforesaid statement, all those transactions had been stated to be carried out by Sri K K Gandhi either on his own behalf or on behalf of the assessee firm. For the purpose of income tax, the firm and its partners are separate and assessed to tax independently. The breakup of total disclosure of Rs. 4 crores made by Shri K.K. Gandhi are as under:-

a. Unaccounted purchases 62 lakhs b. Alleged cash advance given to certain parties 1.46 crores c. Expenditure on renovation and repairs of 47 lakhs building d. Amounts reflected in certain documents 23 lakhs impounded during survey e. Unexplained investment in jewellery 22 lakhs f. Unexplained cash payments from 17.04.2025 1 crore to 20.06.2025 Total 4 crores

8.

The ld AO completed the assessment u/s 143(3) of the Act on 26.12.2018 after making an addition of Rs. 4 crores based on the letter of surrender made by the assessee firm at the time of survey as detailed above. The ld AO also justified his addition on the ground that the aforesaid additions were rightly made in the hands of the assessee firm in view of the fact that the firm had also given post dated cheques for payment of tax immediately after the surrender at the time of survey. This action of the AO was upheld by the ld CIT(A).

9.

At the outset, we find that the entire basis of addition of Rs. 4 crores in the hands of the assessee firm were made based on the letter of surrender given in the letterhead of the assessee firm, which is reproduced at pages 4 and 5 of the assessment order. This letter of surrender was preceded by a statement recorded from Shri K.K. Gandhi, partner of the assessee firm, at the time of survey, wherein except two questions with regard to repairs and renovation of building and valuation of stock, all the questions that were posed to Shri KK Gandhi were only pertaining to his individual proprietary concerns and personal transaction, which are not at all connected in any manner whatsoever with the business of the assessee firm. Even for the transactions that pertained to the assessee firm, for which questions were posed to Shri KK Gandhi, surrender has been made by Shri KK Gandhi in his individual capacity and he in his individual capacity had come forward to pay the taxes. While this is so, it is not known why the addition is being made in the hands of the assessee firm herein. Further, we find that the assessee firm had filed a retraction letter dated 03.08.2016 and denied all the transactions listed out in (a) to (f) in the table mentioned in the earlier part of the order giving the breakup of Rs. 4 crores.

10. As stated earlier, there is absolutely no reason or logic for the assessee firm to come forward to surrender additional income for the personal transactions and business transactions carried out by Shri KK Gandhi in his individual capacity. In these circumstances, the retraction letter filed by the assessee firm dated 03.08.2016 is fully justified, even though it was filed after a period of gap of 22 months. It is also pertinent to note that the assessee firm had filed its return of income for assessment year 2016-17 on 16.03.2017, wherein the additional income of Rs. 4 crores was not offered, which was in consonance with the retraction letter dated 03.08.2016 filed by the assessee firm. During the course of assessment proceedings, the assessee has furnished the complete books of account, audited financial statements, explanations and documentary evidences in support of the return of income. Further, in the course of assessment proceedings, the assessee firm had given its explanation for each of the items that were subject matter of surrender by either stating that such items are non-existent or explainable out of disclosed sources in the individual capacity of the partner and not pertaining to the assessee firm at all.

11.

With regard to addition made on account of unaccounted purchases of GI steel wires in the sum of Rs. 62 lakhs, the assessee had submitted that it was imported material. We find the partner of the assessee firm, Shri KK Gandhi had agreed to pay the tax for the same by holding that excess stocks were purchased by him out of books and given to the assessee firm. Hence, the source for the stocks had stood explained by the disclosure made by the partner Shri KK Gandhi. While it is so, there is absolutely no reason for the addition being made for the same in the hands of the assessee firm. The partner has come forward to explain the source of excess stock found during survey. Further, as stated earlier, during the course of assessment proceedings, the assessee had furnished the entire books of accounts together with the audited financial statements and Page | 7

documentary evidences before the ld AO and the same were not sought to be rejected by applying the provisions of Section 145(3) of the Act.

12.

With regard to alleged advance paid in cash to Shri Ram Lal of Rs. 70 lakhs and to Shri Kishore Lal of Rs. 76 lakhs, the assessee stated that there were no transactions carried out with these parties at all and that the partner of the assessee Shri K.K. Gandhi was made to sign the slips at the time of survey, wherein it was recorded that cash of 70 lakhs and 76 lakhs was paid for purchase of land. There is no mention of assessee firm name in the said impounded documents which is reproduced in page 9 of the assessment order. Hence there is absolutely no reason for considering the said impounded document in the hands of the assessee firm and accordingly, the denial made by the assessee firm in the retraction letter dated 03.08.2016 deserve to be accepted. This is also strengthened by the fact that in the survey, no further corroborative document such as agreement for purchase of land from Kishore Lal and Ram Lal was found. Hence, the impounded document mentioned in page 9 of the assessment order need to be construed as merely a dumb document not supported with any other corroborative material.

13.

With regard to addition made in the sum of Rs. 47 lakhs on account of repairs and renovation allegedly carried out at the factory situated at Industrial Area, Bhiwadi belonging to the assessee firm based on impounded slips mentioned in page 10 of the assessment order, we find that the partner of the assessee firm Shri K.K Gandhi had come forward to surrender the said sum as having been incurred on behalf of the assessee firm. In fact, in response to Question No. 12 of the statement recorded during survey, he had specifically said that the said sum of Rs. 47 lakhs may be added to his annual income. Hence, the source for the incurrence of repairs and renovation work stands duly

explained by the surrender made by Shri K.K Gandhi in his individual capacity and no addition for the same could be made in the hands of the assessee firm herein. Further on perusal of the impounded slip reflected in page 10 of the assessment order, we also find that there is absolutely no mention of the assessee firm’s name in the said slips, which also raise suspicion to the veracity of those slips. No other corroborative evidence was found during the course of survey or thereafter by revenue to bring on record concrete evidences and proof as to whether at all any such repairs or renovation had been carried out in the factory premises of the assessee firm to the extent of Rs. 47 lakhs. Hence, the entire impounded document represented in page 10 of the assessment order need to be construed as a mere dumb document, not supported with any corroborative evidence, basis which no addition could be made in the hands of the assessee firm herein.

14.

With regard to addition made in the sum of Rs. 1 crore on account of unexplained cash investment in property, it was explained that Shri KK Gandhi, partner of the assessee firm, had entered into an agreement to sell with Shri Raghunath Sharma for purchase of Industrial Land situated at 161/7A, Kadipur, Industrial Area, Street No. 7, Gurgaon. The assessee also enclosed the copy of agreement to sell for the same before the ld AO. The payment of Rs. 1 crore pursuant to the said agreement to sell was stated to be made out of cash withdrawal by Shri KK Gandhi from his savings account and withdrawals from his proprietorship concerns, M/s. Koyo Automotive and M/s. Koyo Steels. In support of this, the assessee also enclosed the copy of savings bank account of Shri KK Gandhi showing cash withdrawals and the evidences for withdrawals made from proprietorship concerns together with the copies of balance sheets of proprietorship concerns. Hence the entire cash payment of Rs. 1 crore for purchase of land stands properly explained by sources emanating from the Page | 9

accounts of Shri KK Gandhi. Either way this transaction has got absolutely nothing to do with the assessee firm herein. Hence there is no reason for making an addition for the same in the hands of the assessee firm herein. Hence the said transaction had been rightly retracted by the assessee. Further, we find the impounded document for this where this sum of Rs. 1 crore is reflected, is reproduced by the ld AO in page 11 of his order. On perusal of the same, we find that the name of the assessee firm is nowhere reflected thereof. Hence, on this count also, the said transaction cannot be considered in the hands of the assessee firm and moreover the very same transaction has been owned up and explained by proper sources by Shri KK Gandhi partner of the assessee firm in his individual account. Accordingly, the addition made in the sum of Rs. 1 crore is hereby directed to be deleted in the hands of the assessee firm.

15.

With regard to addition made in the sum of Rs. 22 lakhs on account of investment in jewellery in cash, we find that this addition has been made based on impounded slip reflected in page 11 of the assessment order, wherein the name of the assessee firm is not at all mentioned therein. It was explained that the said investment was made in cash towards purchase of gold and silver coins by Shri KK Gandhi in his personal capacity out of sources emanating in the form of withdrawals from his two proprietorship concerns referred supra. This goes to prove that the transaction of alleged transaction of purchase of gold and silver coins for Rs. 22 lakhs has got nothing to do with the business of the assessee firm herein and hence there is no good reason for considering the same in the hands of the assessee firm and making addition therein. Hence, this addition of Rs. 22 lakhs deserve to be deleted in the hands of assessee firm.

16.

With regard to addition of Rs. 23 lakhs on the basis of documents impounded during survey, it is pertinent to note that the ld AO merely states that

certain recorded and out of books amounts were found/mentioned in the documents. When the ld AO was able to paste the impounded slips for each of the additions made hereinabove, no such impounded slip or document was pasted by the ld AO in the assessment order to support this addition of Rs. 23 lakhs. This goes to prove that no such impounding slip/ document actually exists. In any event, Shri KK Gandhi in response to Question No. 16 had categorically stated that he had come forward to surrender Rs. 23 lakhs as his income. When there is non-existent impounded slips/ documents thereon justifying the addition of Rs. 23 lakhs qua the assessee firm herein, we are unable to comprehend ourselves to accept to the situation as to how the same could at all be considered and added in the hands of the assessee firm herein. Hence, we have no hesitation to delete the said sum of Rs. 23 lakhs made in the hands of the assessee firm.

17.

From the aforesaid observations, it could be seen that the main basis for the revenue to make the addition in the hands of the assessee firm is based on survey statement recorded from Shri KK Gandhi, partner of the assessee firm based on impounded slips/ documents, wherever applicable, from the business premises of M/s. Koyo Automobiles, Gurgaon (being the proprietary concern of Shri KK Gandhi) and not from the business premises of assessee firm. At the cost of repetition, we would like to state that none of the impounded slips/ documents which are subject matter of additions made by the revenue, were impounded from the business premises of the assessee firm. In any event, it is trite law that statement recorded during survey has got no evidentiary value. Reliance in this regard was placed by the ld AR on the decision of Hon’ble Madras High Court in the case of S. Khader Khan Sons reported in 300 ITR 157 (Mad) wherein it was held as under:-

“An admission is an extremely important piece of evidence, but it cannot be said that it is conclusive and it is open to the person, who made it, to show it has incorrectly been made and the person, making the statement should be given proper opportunity to show that it does not show the correct state of facts.” 18. It is pertinent to note that the Hon’ble Supreme Court had dismissed the revenue’s appeal against this decision of Hon’ble Madras High Court, which is reported in 25 taxmann.com 413 (SC).

The ld DR before us vehemently relied on the decision of Hon’ble Punjab 19. and Haryana High Court in the case of Navdeep Dhingra Vs. CIT reported in reported in 232 taxman 425 (P &H) for supporting the case of evidentiary value of survey statement. In that case, certain photographs of construction having been carried out were taken and brought on record by the revenue and assessee even made surrender of income in his returns. Since corroborative materials were available, the Hon’ble Punjab and Haryana High Court had held that the survey statement duly supported by corroborative evidence would become conclusive piece of evidence and hence could be relied upon by the revenue for the purpose of making an addition. This case is factually distinguishable with the case of the assessee firm herein as it has been already held by us hereinabove that there is absolutely no corroborative evidence at all brought on record by the revenue for making any of the additions in order to implead the assessee firm herein. The reliance placed by the ld DR on the decision of Hon’ble Punjab and Haryana High Court referred supra would not advance the case of the revenue. In any event, when there is a decision of Hon’ble Supreme Court stating the evidentiary value of a survey statement, the decision of Hon’ble Punjab and Haryana High Court would not apply.

20.

With regard to the delayed retraction made by the assessee as argued by the ld DR, we find that survey statement was recorded from partner of the

assessee firm on 07-10-2015, wherein Shri KK Gandhi had surrendered Rs. 4 crores as his individual income and not on behalf of the assessee firm. We have already dealt in our order that there is absolutely no reason for taking the surrender in the letterhead of the assessee firm herein, which is reproduced in pages 4 and 5 of the assessment order. In the instant case, the retraction had been filed after a gap of 22 months. But, the said retraction has been duly supported with explainable facts and evidences and further strengthened by non- offering of the additional income in the return filed on 16.03.2017 by the assessee firm. Yet another argument advanced by the ld DR that post dated cheques were given along with the surrender letter at the time of survey. To buttress this, the ld AR submitted that those cheques were never presented by the revenue for encashment. This is a clinching evidence to prove that the assessee firm was duly justified in coming out with a retraction statement as none of the transactions pertained to the assessee firm. Hence, the argument advanced by the revenue with regard to delayed filing of retraction is hereby rejected.

21.

The assessee had raised certain additional grounds as under:-

“1. That impugned order passed u/s 250 by nfac/cita, dismissing appeal of assessee and sustaining impugned assessment order of Ld AO are totally unlawful as there is no valid service of jurisdictional notice u/s 143(2) on the assessee without which entire action of assessment is invalid; 2. That impugned order passed u/s 250 by nfac/cita, dismissing appeal of assessee and sustaining impugned assessment order of Ld AO liable to be quashed as assessment order served by the assessing officer is unsigned and therefore not valid as per section 282A and settled court rulings of jurisdictional high court, 3. That impugned order passed u/s 250 by nfac/cita, dismissing appeal of assessee and sustaining impugned assessment order of Ld AO liable to be quashed as assessment order is passed by the assessing officer in strangulation of principles of natural justice and violation of section 142 by not confronting any back /relied upon document before making additions against the assessee. Page | 13

4.

Without prejudice to main grounds LdCIT(A) utterly erred in upholding addition made by the AO of Rs.1,46,00,000/- Rs.1,00,00,000/- and Rs.22,00,000/- in hands of partnership firm for undisputed allegation of transaction of partner Mr. K.K.Gandhi in his Individual capacity as wrong person in self-contradicting manner in making approbate and reprobate without authority of law. i) Notably the payment of Rs.1,46,00,000/- has been admitted to be allegedly paid in individual capacity by partner not having any bearing on income of the partnership firm as self admitted in Q-11 relied upon by the respondent assessing officer. ii) Notably the payment of Rs.1,00,00,000/- has been added in the assessment order on basis of unregistered agreement between partner in individual capacity without any whisper of name of the firm. ⅲ) Notably the addition of Rs.22,00,000/- has been made in hands of partnership firm on account of personal jewellery of partner accepted in the statement as per question no.15 which can by no sermon of reasoning become income of partnership firm.

5.

Without prejudice to main grounds Ld CIT Appeals completely erred in upholding addition of Rs.23,00,000/- without bringing any logic, reason and document to support such addition completely made without any reason. 6. Without prejudice to main grounds; Ld AO erred in making additions of Rs.62,00,000/-for excess stock without confronting any document showing calculation of stock or list or valuation report etc and made additions in the air without bringing any single document for support of such arbitrary and illogical addition.”

22.

The additional grounds are legal issues and facts relevant for our adjudication are already on record. Hence, the same are hereby admitted. Since, the relief is granted to the assessee on merits, the adjudication of the aforesaid additional grounds become academic in nature. Either way, the additional ground No. 4 has already been considered by us while adjudicating the original grounds on merits of the additions.

23.

In the result, the appeal of the assessee is partly allowed.

Order pronounced in the open court on 24/07/2026. -Sd/- -Sd/- (MAHAVIR SINGH) (M. BALAGANESH) VICE PRESIDENT ACCOUNTANT MEMBER

Dated: 24/07/2026 A K Keot Copy forwarded to 1. Applicant 2. Respondent 3. CIT 4. CIT (A) 5. DR:ITAT ASSISTANT REGISTRAR ITAT, New Delhi

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