ENTREPRENEURS ORGANISATION, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-3(1), RAIPUR, RAIPUR

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ITA 108/RPR/2025Status: DisposedITAT Raipur24 June 2026AY 2017-1820 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee is not a charitable institution and has consistently filed its returns as an AOP. Expenses incurred for earning income are deductible under Section 57(iii) of the Income Tax Act, irrespective of whether they strictly fall within the bye-laws, as long as they are genuine and incurred for the purpose of earning income.

What were the facts?

The assessee, Entrepreneurs Organisation, filed its income as an AOP and not as a charitable institution. The Assessing Officer disallowed expenses incurred on organizing events, considering them outside the society's bye-laws. The CIT(Appeals) upheld this disallowance.

What were the issues?

Whether expenses incurred by an AOP for organizing events are deductible even if not strictly within the bye-laws, when the assessee is not claiming charitable status.

Which sections of the Income-tax Act were involved?

Section 57(iii)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY & SHRI AVDHESH KUMAR MISHRA

For Appellant: Shri Praveen Jain, CA
For Respondent: Shri Piyush Tripathi, Sr. DR
Hearing: 22.06.2026Pronounced: 24.06.2026

आदेश / ORDER PER PARTHA SARATHI CHAUDHURY, JM: The present appeal preferred by the assessee emanates from the order of the Ld.CIT(Appeals)/NFAC dated 04.12.2024 for the assessment year 2017-18 as per the grounds of appeal on record.

2.

The assessee is a society filing return of income as AOP. At the time of hearing, the Ld. Counsel for the assessee demonstrated that the assessee has never claimed to be a charitable institution and has filed return of income as an AOP as evident from Pages 21 & 22 of the Paper Book wherein ITR-V is annexed for A.Y. 2017-18 and therein the status of the assessee that is entrepreneurs organization is AOP. The same is extracted as follows:

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3.

Further, the recent return also demonstrated the fact that the assessee always filed its return of income as an AOP as evident from Pages 31 & 32 which is the ITR for assessment year 2024-25, the same is extracted as follows:

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4.

The main source of income of the assessee society is organizing events and through the sale of tickets and sponsorship the assessee society earns its income. The events are attended by the members of the society for which they have to purchase the tickets and in all these events eminent speakers and dignitaries are invited sharing their knowledge and experience on various subjects. The expenses includes the professional fees paid to these speakers and also the expenses involved for comfortable stay of those eminent speakers without which they would not have attended the event. So, therefore, the earning of the society is from the sale of tickets and the sponsorship and the expenses include the payments to these various eminent personalities who are the speakers in the events and other expenses incurred for comfortable stay of such speakers which is essential as per their stature and social image. The Ld. A.O. had disallowed the expenses on the wrong premise that the assessee is a charitable institution. The same had been upheld by the Ld. CIT(A) also on the premise that being charitable institution the assessee could not have incurred such type of expenses. However, as a matter of fact, repeatedly the assessee had always submitted before the Department that they are a simple business organization and nothing to do with charity. That they are always filing their return in ITR-V and not in ITR-VII. They are filing return as AOP and assessed accordingly. That as businessman the assessee has right to incur expenses in order to earn income. Every business person is his best judge to decide the course

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of earning his income and what would be the nature of expenses it is up to the such assessee businessman so that eventually he can earn income. Therefore, in case of the assessee organizing these events, selling of tickets, getting sponsorships is nothing but the source of income. In order to earn such income the assessee has to incur the expenses without which such events won’t materialize, and without events, therefore, the assessee will not be able to earn income. The very facet of expenditure is for the purpose of earning income in the case of the assessee. The factual position of the assessee is enumerated as per the submissions placed on record by the Ld. Counsel which are as follows:

“Disallowance by AO: Assessee has Organised Spark Event in which Receipt from Spark Event by Sale of Tickets, Sponsorship, etc was Rs. 163.97 Lakh and Expenditure to conduct the said Spark Event was Rs. 190.24 Lakhs. AO has disallowed Expenses of Rs. 68.39 Lakhs out of total expenses towards Spark Event of Rs. 190.24 Lakh. Reason for Disallowance: As per Para 11 of Assessment Order, reason for making such a disallowance by the AO is that expenses to the tune of Rs. 68.39 Lakhs were spent on the purpose which were out of the purviews as per the bye-laws of the society. In this regards it is most respectfully submitted that: 1. AO has not doubted the genuinity or incurrence of the Expense disallowed. 2. While making the Disallowances, AO has stated that expenses incurred. are not Charitable, where-as the fact is that the Assessee is not registered. u/s 12A nor claiming any benefit of tax exemption. In fact Assessee never applied for Registration u/s 12A. Thus, Computation of Income of Assessee Society should be as applicable to AOP/BOI as per the Normal Provisions of the Act ie Income to be computed as per 2(24) after allowing deduction for all the expenses incurred for earning the Income u/s 57(iii).

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3.

Whether the Expenses are within the Power/ Object is not Relevant for determining taxability: AO has made disallowance stating that expenses have been incurred outside the purview of its Bye-laws, which is total incorrect. Although section 57(iii) nowhere states that only Expense as per the Bye laws will be deducted and entire gross receipt will be taxed, the presumption of the AO is incorrect. Your honor here I would like to post one single question to myself that if tomorrow without making any change in my object I start to manufacture Cement, can we say that receipts from Selling of Cement will be taxable but purchase of Raw-material or electricity cost incurred for manufacturing the Cement will not be allowed since the expenditure does not match with the object of the Assessee. Your honor it is settled law of the nation that only the real profit should be taxed and all the expenses incurred for earning the same should be allowed if it is genuine. In Indian income tax law, whether an expenditure falls "within" or "outside" the formal objects of an assessee (such as those stated in a Memorandum of Association or Trust Deed) is of no relevance for determining tax deductibility Case 1 Indian Steel & Wire Products Ltd. vs Commissioner Of Income-Tax on 3 July, 1967-[1968] 69 ITR 379 (CAL) 45. In the case of Kishan Prasad & Co, Ltd. v. Commissioner of Income- tax, the Supreme Court observed that whether a transaction was or was not within the company's power has no bearing on the nature of the transaction or the question whether the profits arising therefrom were capital accretion or revenue income. On the analogy of that authority, we think that in deciding whether a particular expenditure falls within the four corners of Section 10(2)(xv) of the Indian Income-tax Act, the question whether the expenditure was within or outside the powers of the company is of little consequence. 4. Condition for claiming deduction u/s 57(iii): Any genuine revenue expense incurred for earning the Income being taxed is allowable as deduction u/s 57(iii). Further there is no obligation that Either Income or expense incurred to earn such income should be covered within the objects of assessee or whether the quantum of expense is reasonable. Section 57(iii) lays no such restriction. Even if income is outside the the Objects, same will be taxable as per the provisions of the Income Tax Act. It is up to the assessee to decide the necessity of a such expenditure, AO cannot question its need if the expense are genuine.

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5.

Entire Expense incurred are directly Connected with the Object. Amongst Others, Assessee's Object is as under: II. It is to provide educational programs, opportunities, resources and training to the member entrepreneurs. III. It is to share the mutual interest of improving the skills of membership through access to educational programs, human and physical resources in support of their growing enterprises, and participating with others that have similar drives, goals and experiences. IV. To do all such other lawful things as may be incidental or conducive to the attainment of the above objects. Your Honor, In this event there were various Knowledge sharing as well as Entertainment Sessions/ Workshops for all the participants for entire 2 days. Kindly allow me to show leaflet of the Spark Event. Your hononr, For this event as many as 10 different eminent personalities from varied field were invited as Speakers to share their knowledge, their life experiences, their ups, their downs, the pressure they went through in their personal carrier and many more such things. The experiences of these speakers from their own mouth directly communicating with the participant face to face not only gives knowledge but boost inspiration and motivation, it also helps to take balanced decision and also helps in handling business pressures in better way from their experience. Overall it helps to have better work life balance so that the participants can excel not only in their business but have better quality of life and be better and responsible citizen. During the event the state Chief Minister Raman Singh also pitched Chhattisgarh as an entrepreneur-friendly destination. Other speakers include Bollywood stars like Irrfan Khan, Abhay Deol, cricketer Wasim Akram, Tata Sons Ltd director Gopal Krishnan, Zee TV's Subhash Chandra and member of parliament Meenakshi Lekhi. Thus entire Event was nothing but a resource and training program by Public Figures full of Opportunities (Object II) as it involved interaction with 2 days Captive participation of 300 Entrepreneurs having Turnover of about Rs. 3,50,000 Crores (Refer Leaflet) all of whom share Mutual Interest of Improving their Skills (Object III) as this was a totally Paid event for Tickets. Details as per Program Leaflet submitted during previous hearing.

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6.

Assessee has earned Commercial Income and has never claimed it to be Charitableas condended by the AO and CIT(A): Your Honor, during the year under consideration, assessee has earned commercial Income and has incurred expenditure to earn such Income. Same is Allowable u/s 57(iii) of the IT Act. Assessee has conducted a 2 day event (27th and 28th August) in the name of EO Spark by Selling Tickets with a starting price of Rs. 30,000 per participant and even ranging upto Rs. 1.00 Lakh per participant and also getting Sponsorship and to earn such Income Assessee has incurred Event Expenses. Entire bills and vouchers were verified by the AO. All the expenses disallowed by the AO pertain to Event Expenses. Entry in the said event is allowed only on purchase of Tickets. No person other that Ticket Holder, Speaker or Soponsoror were allowed to participate in the Event. The was attended by approximately 300 participants. The rates of tickets were: (Refer Page 45 to 49 pf Paper Book) Early Single Registration -Rs. 40,000/-+ Service Tax Early Couple Registration - Rs. 30,000/- + Service Tax Regular Single Registration - Rs. 55,000/-+ Service Tax Regular Couple Registration Rs. 45,000/- + Service Tax EO Raipur chapter Member - Rs. 1,00,000/- + Service Tax 7. ROI has been filed in ITR 5 under Income from Other Source u/s 56. Thus expenses incurred for the Event which directly connected for conducting the Event which have been verified by the AO and not held ingenuine should be allowed as Expenses u/s 57(iii). 8. Undisputed Fact Entire Expenses disallowed are related to Income earned from Spark Event conducted by the Assessee Your honor, In the present case AO has not disputed the Receipts earned by the assesse from Selling entry tickets of Spark Event to the participants which was around 96 Lakhs or the Sponsorship Income earned for the Spark Event of around Rs. 53 Lakhs received from various Sponsors but AO has disallowed some of the Expenditures incurred for the Spark Event which were necessary for the success of event like Payment made to 2 of the prominent Speakers and some entertainment Expenses forming integral part of the event, stating that the expenses do not match the Object of the Assessee.

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9.

Report of DR: Your honor as per the Report submitted by Hon. DR before the Hon. ITAT dated 15.09.2025, department states that Assessee is a Public charitable Organisation with "not for Profit" for Tax Purpose. This is the main reason for not allowing certain expenses incurred by the Assessee, which is totally incorrect. Infact, assessee is not registered u/s 12A nor claiming any sort of Tax exemption then disallowing expense which are directly relatable to the Income, without doubting genuinity of expenditure, is not at all justified. 10. Computation of Profit of Society not registered u/s 12A: Further since Assessee is Society not registered u/s 12A it would be treated as AOP and its Computation should be as per the Normal Provisions of the Act i.e after allowing all the expenses incurred for earning the Income u/s 57(iii) Case 2-Sanatan Dharam Mandir Sabha, New Delhi vs Ito Ward - 41(2), New Delhi on 13 April, 2022-ITA No.5791/DEL/2019: 9. I have considered the rival arguments made by both the sides, perused the orders of the CPC, Bangalore and the Ld. CIT(A) and the paper book filed on behalf of the assessee. I have also considered the various decisions cited before me. I find the assessee in the instant case has neither applied nor granted registration u/s 12A of the Act. It filed its return of income for the impugned Assessment Year declaring taxable income at Rs.2,18,060/- under the head "Income from Other Sources" after deducting application of income of Rs.4.85,564/- from the gross receipt of Rs.7,03,624/-, I find the CPC, Bangalore, processed the return u/s 143(1) of the Act and disallowed the expenses of Rs.4,85,564/- claimed in the return of income. I find the assessee filed rectification application before the AO, which was rejected by the AO and the Id. CIT(A) also dismissed the appeal filed by the assessee, the reasons of which have already been reproduced in the preceding paragraph. It is the submission of the Id. Counsel for the assessee that the adjustment so made by the CPC, Bangalore without assigning any reason is contrary to provisions of section 143(1) of the Act It is also his contention that in case of charitable society, even if benefit u/s 11 and 12 of the Act is denied and its income was brought to tax as "Income from Other Sources", all relevant expenditures are also to be allowed under section 57(iii) of the Act. 9.1. 1 find sufficient force in the above arguments of the ld. Counsel for the assessee. 6. Now, coming to the taxability of the income, it is seen that the appellants' return was filed reflecting the status as AOP. It is also an undisputable fact that it is not registered under section 12A of the I.T.

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Act. Therefore, it is necessary to see the applicability of rates of tax, at which the unregistered AOP will be taxed. As the appellant is a charitable trust (the Society and other institutions are treated as trust under the relevant provisions of Income Tax Act) which is registered under the Societies Registration Act, 1890, section 167B of the I.T. Act will not be applicable. Hence, the rate at which an unregistered charitable or religious trust or institution is taxed will be the rate that is applicable to individual assesse except for those that are covered u/s 13(1) of the I.T. Act. 11. It may be noted that as per the Income Tax Website (https://www.incometaxindia.gov.in/w/taxability-of-income-of charitable-or-religious-trusts) the Charitable Entities which were already registered u/s 12A whose Registration has been Cancelled shall be dealt as under: Consequences of cancellation of registration The following consequences may arise on the cancellation of the registration of a trust: (a) The exemption under Sections 11 and 12 would not be available; (b) The income will be computed under the normal provisions of the Act; (c) Any donation or aid to an individual will be regarded as his income taxable under Section 56(2)(x) if it exceeds the threshold limit of Rs. 50,000; (d) The approval granted under Section 80G may be cancelled; (e) Levy of accreted tax under Section 115TD. Thus all the entities which are not Registered u/s 12A or whose Registration has been cancelled shall be taxed to Income Tax as per Normal Provisions. Gross Receipt cannot be tax, Income/profit has to be taxed. 12. Commercial expediency to be adjudged from the viewpoint of Assessee- Case 3 In applying the test of commercial expediency for determining whether the expenditure was wholly and exclusively laid out for the purpose of the business, reasonableness of the expenditure has to be adjudged from the point of view of the assessee and not of the Revenue [CIT v. Walehand & Co. (P.) Ltd. [1967] 65 ITR 381 (SC)]. Case 4 - It is not open to the department to prescribe what expenditure an assessee should incur and in what circumstances he should incur that expenditure. Every businessman knows his interest best [CIT v. Dhanrajgirji Raja Narasingirji [1973] 91 ITR 544 (SC)].

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13.

Your honor, AO has not doubted the genuinity of expense he merely disallowed the same on one single contention that out of all the expenses incurred some of them which are disallowed by him does not match with object of assessee. 14. Amongst Others Reliance is Placed in the Case of: a. Case 5 - CIT vs Rajendra Prasad Moody -115 ITR 519 (SC). What section 57(iii) requires is that the expenditure must be laid out or expended wholly and exclusively for the purpose of making or earning income. It is the purpose of the expenditure that is relevant in determining the applicability of section 57(iii) and that purpose must be making or earning of income. Section 57(iii) does not require that this purpose must be fulfilled in order to qualify the expenditure for deduction. It does not say that the expenditure shall be deductible only if any income is made or earned. There is in fact nothing in the language of section 57(iii) to suggest that the purpose for which the expenditure is made should fructify into any benefit by way of return in the shape of income. The plain natural construction of the language of section 57(iii) irresistibly leads to the conclusion that to bring a case within the section, it is not necessary that any income should in fact have been earned as a result of the expenditure. b. Case 6 - Sunil Baradia vs ITO [2023] 155 taxmann.com 539 (Raipur -Trib.) - Relied on CIT vs Rajendra Prasad Moody c. Case 7 - DCIT (Exemption), Bhopal vs Shri Vaishnav Plolytechnic College - ITA No.469/Ind/2018 06/11/2020 10. Even for a while it is presumed that the assessee is not eligible for exemption u/s 10(23C)(iiiab) of the Act then also in view of the judgment of Hon'ble High Court of Delhi in the case of Petroleum Sports Promotion Board (supra) if the income is assessed under the residual head as the A.O denied exemption u/s 11 of the Act full play must be allowed to Section 57(iii) of the Act towards any expenditure incurred for the purpose of making or earning income. d. Case 8 - CIT vs SC Kothari -82 ITR 794 (SC). e. Case 9 - ITO(E) vs Mehta Charitable Prajanalaya Trust 6285/Del/2018 ITA No.” 5. That another ground taken by the Department for disallowing the expenditures were it does not fall within the objects of the assessee. The

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claim of the assessee has never been that it is a charitable organization. The Department has to look into the genesis of the objects and the expenses as per the objects if the assessee is claiming exemption. It is not the case here. The assessee is a simple businessman and it is deriving its income for which as an integral part of such earning of income it has to incur expenses without which it will not be able to earn its income. Therefore, the earning of income is deeply woven with the expenses that the assessee has incurred. That as a business organization the assessee has every right to determine the nature of expenses that it shall incur in order to earn its income. The Department in this case has never doubted the source of income of the assessee. The Department also has treated the return filed by the assessee as valid return and in the said return the assessee is an AOP and not a charitable institution. Therefore, the addition made by the A.O. and confirmed by the CIT(A) on the ground that the assessee is a charitable organization and that such expenditure does not match with the objects of the society is prima facie on a wrong premise which does not match with the facts pertaining to the business activity of the assessee as evident from return filed. In other words the very basis of earning income is the expenses that has been incurred by the assessee the Department cannot dictate what are the expenses the assessee should incur and what it should not since every business body has the right to decide its own course of action for earning its income. The Department only has to look into whether such

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expenses intricately woven with earning of income and to that extent there are no objections raised either by the A.O. nor by the CIT(A) that such expenses pertains to the event organized by the assessee which itself is the source of income of the assessee. In such scenario all these expenditures are nothing but business expenses hence allowable. The Hon’ble Apex Court in the case of CIT vs. Rajendra Prasad Moody (1978) 115 ITR 519 (SC) observed and held as follows: “What section 57 (iii) requires is that the expenditure must be laid out or expended wholly and exclusively for the purpose of making or earning income. It is the purpose of the expenditure that, is relevant in determining the applicability of section 57(iii) and that purpose must be making or earning of income. Section 57(iii) does not require that this purpose must be fulfilled in order to qualify the expenditure for deduction. It does not say that the expenditure shall be deductible only if any income is made or earned. There is in fact nothing in the language of section 57(iii) to suggest that the purpose for which the expenditure is made should fructify into any benefit by way of return in the shape of income. The plain natural construction of the language of section 57(iii) irresistibly leads to the conclusion that to bring a case within the section, it is not necessary that any income should in fact have been earned as a result of the expenditure. It may be pointed out that an identical view was taken by this Court in Eastern Investments Ltd. v. Commissioner of Income tax, where interpreting the corresponding provision in section 12(2) of the Income Tax Act, 1922 which was ipsissima verba in the same terms as section 57(iii), Bose, J., speaking on behalf of the Court observed: "It is not necessary to show that the expenditure was a profitable one or that in fact any profit was earned". It is indeed difficult to see how, after this observation of the Court, there can be any scope for controversy in regard to the interpretation of section 57(iii). It is also interesting to note that, according to the Revenue, the expenditure would disqualify for deduction only if no income results from such expenditure in a particular assessment year, but if there is some income, howsoever small or meagre, the expenditure would be eligible for deduction. This means that in a case where the expenditure is Rs. 1000/-, if there is income of even Re.1/-, the expenditure would

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be deductible and there would be resulting loss of Rs. 999/- under the head 'Income From Other Sources'. But if there is no income, then, on the argument of the Revenue, the expenditure would have to be ignored as it would not be liable to be deducted. This would indeed be a strange and highly anomalous result and it is difficult to believe that the Legislature could have ever intended to produce such illogicality. Moreover, it must be remembered that when a profit and loss account is cast in respect of any source of income, what is allowed by the statute as proper expenditure would be debited as an outgoing and income would be credited as a receipt and the resulting income or loss would be determined. It would make no difference to this process whether the expenditure is X or Y or nil; whatever is the proper expenditure allowed by the statute would be debited. Equally, it would make no difference whether there is any income and if so, what, since whatever it be, X or Y or nil, would be credited. And the ultimate profit or loss would be found. We fail to appreciate how expenditure which is otherwise a proper expenditure can cease to be such merely because there is no receipt of income. Whatever is a proper outgoing by way of expenditure must be debited irrespective whether there is receipt of income or not. That is the plain requirement of proper accounting and the interpretation of section 57(iii) annot be different. The deduction of the expenditure cannot, in the circumstances, be held to be conditional upon the making or earning of the income. It is true that the language of section 37(1) is a little wider than that of section 57(iii), but we do not see how that can make any difference in the true interpretation of section 57(iii). The language of section 57(iii) is clear and unambiguous and it has to be construed according to its plain natural meaning and merely because a slightly wider phraseology is employed in another section which may take in something more, it does not mean that section 57(iii) should be given a narrow and constricted meaning not warranted by the language of the section and in fact, contrary to such language. This view which we are taking is clearly supported by the observations of Lord Thankerton in Hughes v. Bank of New Zealand where the learned Law Lord said: "Expenditure in the course of the trade which is unremunerative is none the less a proper deduction, if wholly and exclusively made for the purposes of the trade. It does not require the presence of a receipt on the credit side to justify the deduction of an expense." We find that the same view has been taken by the Madras High Court in Appa Rao v. Commissioner of Income tax, and Mohamed Ghouse v. Commissioner of Income-tax, the Bombay High Court in Ormerods (India) Private Ltd. v. Commissioner of Income-tax, the Allahabad High

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Court in Chhail Beharilal v. Commissioner of Income-tax, the Madhya Pradesh High Court in Commissioner of Income-tax v. Dr. Fida Hussain G. Abhasi, the Kerala High Court in M. N. Ramaswamy Iyer v. Commissioner of Income-tax and the Orissa High Court in Commissioner of Income-tax v. Gopal Chand Patnaik. This view is eminently correct as it is not only justified by the language of section 57(iii) but it also accords with the principles of commercial accounting. The contrary view taken by the Patna High Court in Maharajadhiraj Sir Kameshwar Singh v. Commissioner of Income-tax and the Calcutta High Court in Madanlal Sohanlal v. Commissioner of Income-tax must in the circumstances be held to be incorrect. We accordingly answer the question referred to us for our opinion in each of these two references in favour of the assessee and against the Revenue. The Revenue will pay the costs of both the references to the assessee. S.R. References answered in favour of assessees.” 6. The aforestated is one of the best ruling in the subject of adjudication before us wherein the Hon’ble Supreme Court of India had held that what is relevant is the purpose of expenditure. The purpose of expenditure should determine as the qualifying factor for claiming such expenditures as deduction. Reverting to the facts of the present case repeatedly the assessee had been pleading before the Department that it is not a charitable institution nor they have claimed any exemption. They are simply doing business and the source of their income is through sale of tickets and sponsorship for the events which they organise. That in order to achieve such income the events are visited by various eminent personalities of the society and in order to hear them the members who are attending such events pay good amount of money for buying tickets and that is the source of earning of the assessee. The expenses are all incurred so that these celebrities attend the programme and in order to ensure suitable stay for

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such celebrities the expenses are made. The expenses are also done for paying these celebrities so, therefore, if these expenses are not incurred the assessee will not be able to earn any income. The purpose of incurring these expenses are intricately woven to earning of income by the assessee. In our considered view, the Revenue Authorities have erred in disallowing the expenditure and making addition in the hands of the assessee in this case. In view thereof, we set-aside the order of the Ld. CIT(A) and direct the A.O. to delete the additions from the hands of the assessee while providing appeal effect of this order.

7.

As per above terms, the appeal of the assessee is allowed.

Order pronounced in the open court on 24th June, 2026.

Sd/- Sd/- AVDHESH KUMAR MISHRA PARTHA SARATHI CHAUDHURY (ACCOUNTANT MEMBER) (JUDICIAL MEMBER) रायपुर/ RAIPUR ; �दनांक / Dated : 24th June, 2026. Tanmay, Sr. PS आदेश क� ��त�ल�प अ�े�षत / Copy of the Order forwarded to : 1. अपीलाथ� /The Appellant. 2. ��यथ� /The Respondent. 3. The CIT(Appeals)-1, Raipur (C.G.) 4. �वभागीय ��त�न�ध, आयकर अपील�य अ�धकरण, रायपुर ब�च, रायपुर / DR, ITAT, Raipur Bench, Raipur. 5. गाड� फ़ाइल / Guard File. आदेशानुसार / BY ORDER, // True Copy // Senior Private Secretary आयकर अपील�य अ�धकरण, रायपुर / ITAT, Raipur.

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