JENTIBHAI SAMBHUBHAI PRAJAPATI,MEHSANA vs. ACIT, CENTRAL CIRCLE-1(4), AHMEDABAD

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ITSSA 92/AHD/2025Status: DisposedITAT Ahmedabad17 December 2025AY 2014-1513 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 directions issued by the Ld. CIT(A) under Section 150(1) for the assessment years under consideration could not be sustained. The Tribunal noted the undisputed chronology of events, including the assessment order in the brother's case being passed on 28.12.2019 and the Ld. CIT(A)'s order in his case on 23.04.2021, while notices under Section 153C were issued to the assessee only on 15.11.2021, with assessments completed on 28.12.2021. This inordinate delay in initiating proceedings against the assessee rendered the assessments vulnerable on the ground of limitation. The Tribunal further held that this delay could not justify making substantive additions in the hands of the assessee's brother, especially since the Ld. CIT(A) had already adjudicated the issue on merits in the brother's case, deleting additions by holding him as a custodian. The Tribunal also found no occasion for the Ld. CIT(A) to issue directions regarding Sections 269SS and 269T, stating that it was always open for the Assessing Officer to examine these provisions independently. Consequently, the appeals of the assessee were allowed.

What were the facts?

The assessee, Jentibhai Shambhubhai Prajapati, is appealing against the orders of the Commissioner of Income Tax (Appeals) for Assessment Years 2011-12 to 2014-15 and 2016-17. These appeals stem from assessment proceedings initiated under Section 153C read with Section 144 of the Income Tax Act, following a search in the case of his brother, Vishnubhai Shambhubhai Prajapati. Incriminating documents found during the search were linked to the assessee. The assessee had filed an affidavit admitting that the transactions noted in these documents belonged to him. Despite this, the assessee did not file returns in response to Section 153C notices and failed to comply with assessment notices, leading to ex-parte assessments. The Assessing Officer made additions based on the assessee's affidavit, treating them as substantive income in the assessee's hands and protective in his brother's.

What were the issues?

1. Whether the Ld. CIT(A) erred in law and facts by issuing directions under Section 150(1) of the Income Tax Act. 2. Whether the Ld. CIT(A) erred in law and facts by directing that transactions noted in incriminating documents be considered for taxation on a substantive basis in the hands of Shri Vishnubhai Shambhubhai Prajapati. 3. Whether the Ld. CIT(A) erred in law and facts by directing initiation of action against the appellant for attempting to mislead the Revenue with a false affidavit. 4. Whether the Ld. CIT(A) erred in law and facts by directing verification of the applicability of Sections 269SS and 269T in the hands of the appellant and initiating proceedings accordingly. Assessee's Contentions: The assessee argued that the Ld. CIT(A) erred in issuing directions under Section 150(1) and other directions, particularly in light of the facts that the Ld. CIT(A) in the brother's case had deleted additions, holding him as a custodian. The assessee also highlighted the delay in initiating proceedings against him, rendering them vulnerable on grounds of limitation. Revenue's Contentions: The Ld. DR relied on the observations made by the Ld. CIT(A) in his order.

Which sections of the Income-tax Act were involved?

Section 150(1),Section 153C,Section 144,Section 269SS,Section 269T

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, AHMEDABAD

Before: DR. BRR KUMAR & SHRI SIDDHARTHA NAUTIYAL

For Appellant: Shri Rushin Patel, AR
For Respondent: Shri R P Rastogi, CIT-DR
Pronounced: 17.12.2025

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR. BRR KUMAR, VICE PRESIDENT & SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER I.T(SS).A. Nos.89 to 93/Ahd/2025 (Assessment Years: 2011-12 to 2014-15 & 2016-17) Jentibhai Shambhubhai Prajapati Vs. Assistant Commissioner of 18, Om Bunglows, B/h Ashirvad Income Tax, Flats, Dharam Cinema road, Central Circle-1(4), Mehsana-384002 Ahmedabad [PAN No.EBBPP6731D] (Appellant) .. (Respondent) Appellant by : Shri Rushin Patel, AR Respondent by: Shri R P Rastogi, CIT-DR 24.11.2025 Date of Hearing Date of Pronouncement 17.12.2025 O R D E R PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER: These appeals have been filed by the Assessee against the common order passed by the Ld. Commissioner of Income Tax (Appeals)-11, (in short “Ld. CIT(A)”), Ahmedabad vide order dated 16.07.2025 passed for A.Ys. 2011-12 to 2014-15 & 2016-17. Since common facts and issues for consideration are involved for all years under consideration before us, all appeals are being disposed of by way of a common order.

2.

The Assessee has raised the following grounds of appeal:

IT(SS)A No. 89/Ahd/2025 (A.Y. 2011-12) “1. The ld. CIT(A) has erred in law and on facts of the case, in giving directions u/s 150(1). 2. The ld. CIT(A) has erred in law and on facts of the case, in giving direction to consider the transactions noted in the incriminating documents for taxation on substantive basis in the hands of Shri Vishnubhai Shambhubhai Prajapati.

ITA Nos. 89 to 93/Ahd/2025 Jentibhai Shambhubhai Prajapati vs. ACIT Asst. Years–2011-12 to 2014-15 & 2016-17 - 2–

3.

The ld. CIT(A) has erred in law and on facts of the case, in giving direction to initiate actions as per law against the appellant for attempts to mislead Revenue by giving false affidavit. 4. The ld. CIT(A) has erred in law and on facts of the case, in giving direction to verify applicability of provisions of section 269SS/269T in the hands of the appellant and to record necessary satisfaction while giving effect to the order and initiate proceedings accordingly. 5. The appellant craves liberty to add, amend, alter or delete the grounds of appeal at the time of hearing, if need arise.” IT(SS)A No. 90/Ahd/2025 (A.Y. 2012-13) “1. The ld. CIT(A) has erred in law and on facts of the case, in giving directions u/s 150(1). 2. The ld. CIT(A) has erred in law and on facts of the case, in giving direction to consider the transactions noted in the incriminating documents for taxation on substantive basis in the hands of Shri Vishnubhai Shambhubhai Prajapati. 3. The ld. CIT(A) has erred in law and on facts of the case, in giving direction to initiate actions as per law against the appellant for attempts to mislead Revenue by giving false affidavit. 4. The ld. CIT(A) has erred in law and on facts of the case, in giving direction to verify applicability of provisions of section 269SS/269T in the hands of the appellant and to record necessary satisfaction while giving effect to the order and initiate proceedings accordingly. 5. The appellant craves liberty to add, amend, alter or delete the grounds of appeal at the time of hearing, if need arise.” IT(SS)A No. 91/Ahd/2025 (A.Y. 2013-14) “1. The ld. CIT(A) has erred in law and on facts of the case, in giving directions u/s 150(1). 2. The ld. CIT(A) has erred in law and on facts of the case, in giving direction to consider the transactions noted in the incriminating documents for taxation on substantive basis in the hands of Shri Vishnubhai Shambhubhai Prajapati. 3. The ld. CIT(A) has erred in law and on facts of the case, in giving direction to initiate actions as per law against the appellant for attempts to mislead Revenue by giving false affidavit. 4. The ld. CIT(A) has erred in law and on facts of the case, in giving direction to verify applicability of provisions of section 269SS/269T in the hands of the appellant and to record necessary satisfaction while giving effect to the order and initiate proceedings accordingly.

ITA Nos. 89 to 93/Ahd/2025 Jentibhai Shambhubhai Prajapati vs. ACIT Asst. Years–2011-12 to 2014-15 & 2016-17 - 3–

5.

The appellant craves liberty to add, amend, alter or delete the grounds of appeal at the time of hearing, if need arise.” IT(SS)A No. 92/Ahd/2025 (A.Y. 2014-15) “1. The ld. CIT(A) has erred in law and on facts of the case, in giving directions u/s 150(1). 2. The ld. CIT(A) has erred in law and on facts of the case, in giving direction to consider the transactions noted in the incriminating documents for taxation on substantive basis in the hands of Shri Vishnubhai Shambhubhai Prajapati. 3. The ld. CIT(A) has erred in law and on facts of the case, in giving direction to initiate actions as per law against the appellant for attempts to mislead Revenue by giving false affidavit. 4. The ld. CIT(A) has erred in law and on facts of the case, in giving direction to verify applicability of provisions of section 269SS/269T in the hands of the appellant and to record necessary satisfaction while giving effect to the order and initiate proceedings accordingly. 5. The appellant craves liberty to add, amend, alter or delete the grounds of appeal at the time of hearing, if need arise.” IT(SS)A No. 93/Ahd/2025 (A.Y. 2016-17) “1. The ld. CIT(A) has erred in law and on facts of the case, in giving directions u/s 150(1). 2. The ld. CIT(A) has erred in law and on facts of the case, in giving direction to consider the transactions noted in the incriminating documents for taxation on substantive basis in the hands of Shri Vishnubhai Shambhubhai Prajapati. 3. The ld. CIT(A) has erred in law and on facts of the case, in giving direction to initiate actions as per law against the appellant for attempts to mislead Revenue by giving false affidavit. 4. The ld. CIT(A) has erred in law and on facts of the case, in giving direction to verify applicability of provisions of section 269SS/269T in the hands of the appellant and to record necessary satisfaction while giving effect to the order and initiate proceedings accordingly. 5. The appellant craves liberty to add, amend, alter or delete the grounds of appeal at the time of hearing, if need arise.” 3. The brief facts of the case are that the assessee, Shri Jentibhai Shambhubhai Prajapati, was subjected to assessment proceedings under section 153C read with section 144 of the Income-tax Act (“the Act”) for

ITA Nos. 89 to 93/Ahd/2025 Jentibhai Shambhubhai Prajapati vs. ACIT Asst. Years–2011-12 to 2014-15 & 2016-17 - 4– Assessment Years 2011–12, 2012–13, 2013–14, 2014–15 and 2016–17. The proceedings were initiated pursuant to a search conducted in the case of third parties, wherein certain incriminating documents were found and seized. These documents were stated to be connected with the assessee. The searched party was Shri Vishnubhai Shambhubhai Prajapati (VSP), who is the brother of the assessee. During the course of proceedings arising out of the search in the case of his brother, the assessee furnished a notarised affidavit admitting that the amounts reflected in the incriminating documents belonged to him and not to his brother.

4.

Based on the seized material and the affidavit filed by the assessee, the Assessing Officer recorded satisfaction under section 153C of the Act and issued notices for the relevant assessment years. The assessee, however, did not file returns of income in response to the notices under section 153C, and did not properly comply with the notices issued during assessment proceedings. Consequently, the Assessing Officer proceeded to frame the assessments ex parte under section 144 read with section 153C of the Act. In the assessment orders, the Assessing Officer treated the amounts appearing in the seized documents as income of the assessee, primarily relying on the affidavit of admission given by the assessee, and made additions on that basis. Since the assessee had owned up the transactions, the Assessing Officer limited himself to making protective assessment in the hands of the brother and substantive assessment in the hands of the assessee.

ITA Nos. 89 to 93/Ahd/2025 Jentibhai Shambhubhai Prajapati vs. ACIT Asst. Years–2011-12 to 2014-15 & 2016-17 - 5– 5. Aggrieved by the assessment orders, the assessee preferred appeals before the Commissioner of Income-tax (Appeals), Ahmedabad, for all the aforesaid assessment years. The CIT(Appeals) first took up the appeals for Assessment Years 2011–12 to 2014–15 together, as the grounds of appeal and issues involved were common and the assessee had also filed common written submissions.

6.

Before the CIT(Appeals), the assessee raised a legal ground challenging the validity of proceedings under section 153C, relying on the judgment of the Hon’ble Supreme Court in CIT v. Jasjit Singh (2023) 458 ITR 437 (SC). The assessee contended that, as per the law laid down by the Hon’ble Supreme Court, the deemed search year for the purposes of section 153C would be the year in which the seized material was received by the Assessing Officer of the assessee. In the present case, the notice under section 153C was issued on 15.11.2021, which fell in Financial Year 2021–22 relevant to Assessment Year 2022–23. It was therefore contended that only six assessment years preceding AY 2022– 23 could be validly reopened under section 153C, particularly since the quantum of additions in each of the impugned years was less than ₹50 lakhs. On this basis, it was argued that the assessments for AYs 2011–12, 2012–13, 2013–14 and 2014–15 were beyond the permissible period and were liable to be quashed.

7.

After considering the submissions, the CIT(Appeals) accepted this legal contention. Relying squarely on the decision of the Hon’ble Supreme Court in Jasjit Singh (supra), the CIT(Appeals) held that the deemed

ITA Nos. 89 to 93/Ahd/2025 Jentibhai Shambhubhai Prajapati vs. ACIT Asst. Years–2011-12 to 2014-15 & 2016-17 - 6– search year in the assessee’s case was Assessment Year 2022–23, and therefore proceedings under section 153C could be sustained only for Assessment Years 2016–17 to 2021–22, subject to fulfilment of statutory conditions. Since the assessments for AYs 2011–12 to 2014–15 fell outside the permissible period, the CIT(Appeals) held that these assessments were invalid on technical grounds. The CIT(Appeals) accordingly allowed the appeals for AYs 2011–12, 2012–13, 2013–14 and 2014–15, clarifying that the issues on merits were left open. These appeals were allowed for statistical purposes.

8.

The CIT(Appeals) thereafter separately dealt with the appeal for Assessment Year 2016–17. For this year, the assessee raised a legal ground that the assessment framed under section 144 read with sections 153B(1)(a) and 153C was barred by limitation. The assessee also argued that a substantive assessment must precede a protective assessment, relying on the decision of the jurisdictional ITAT in Pravinkumar Valjibhai Pujara HUF v. ITO (ITA No. 142/Ahd/2016). While adjudicating this ground, the CIT(Appeals) accepted the plea regarding limitation. The CIT(Appeals) observed that even after granting the benefit of time exclusion in view of the Hon’ble Supreme Court’s orders in Suo Motu Writ Petition (Civil) No. 3 of 2020 relating to the COVID-19 pandemic, the assessment for AY 2016–17 ought to have been completed on or before 30.09.2021. Since the assessment order was passed beyond the permissible time limit, the CIT(Appeals) held that the assessment for AY 2016–17 was time barred. Consequently, Ground No. 1 for AY

ITA Nos. 89 to 93/Ahd/2025 Jentibhai Shambhubhai Prajapati vs. ACIT Asst. Years–2011-12 to 2014-15 & 2016-17 - 7– 2016–17 was allowed, the assessment was quashed on limitation, and the remaining grounds on merits were held to be academic and not adjudicated, with issues on merits left open.

Directions u/s 150(1) of the Act:

9.

The CIT(Appeals) issued directions under section 150(1) of the Act, keeping in view the peculiar facts of the case and the conduct of the assessee. The CIT(Appeals) recorded that the assessee, Shri Jentibhai Shambhubhai Prajapati, had himself created an estoppel against proper adjudication of the assessment in the case of his brother, Shri Vishnubhai Shambhubhai Prajapati (VSP), by filing a duly notarised affidavit during the assessment proceedings. In that affidavit, the assessee categorically claimed that the amounts reflected in the incriminating documents seized during search proceedings belonged to him and were owned by him. Relying on this admission, the Assessing Officer restricted himself to making only a protective assessment in the hands of the brother and proposed to tax the amounts substantively in the hands of the assessee as the alleged owner of the money. However, the CIT(Appeals) found that despite such a serious admission made on oath, the assessee failed to produce any corroborative evidence to substantiate the claim made in the affidavit. The CIT(Appeals) observed that although an affidavit is a binding document, it cannot be treated as conclusive evidence in income-tax proceedings, particularly when it is not supported by independent material. It was specifically noted that the assessee did not

ITA Nos. 89 to 93/Ahd/2025 Jentibhai Shambhubhai Prajapati vs. ACIT Asst. Years–2011-12 to 2014-15 & 2016-17 - 8– furnish any documentary proof to establish that the amounts admitted in the affidavit actually belonged to him. Even during the appellate proceedings, the assessee was unable to adduce any evidence to support his sworn statement. At the same time, the assessee also failed to effectively rebut or controvert the factual findings recorded by the Assessing Officer in the assessment order.

10.

In view of the complete absence of corroborative material, the CIT(Appeals) held that the affidavit filed by the assessee could not be relied upon and was liable to be rejected. Consequently, the CIT(Appeals) directed the Assessing Officer to treat the amounts reflected in the incriminating documents as taxable on a substantive basis in the hands of the searched person, namely Shri Vishnubhai Shambhubhai Prajapati (VSP), instead of the assessee. Since the appellate relief for Assessment Years 2011-12 to 2016-17 had been granted on legal grounds and the issues on merits were left open, the CIT(Appeals) clarified that the conclusion regarding the actual substantive ownership of the money would apply uniformly for all the assessment years in the case of Shri VSP.

11.

In addition, the CIT(Appeals) directed the Assessing Officer to examine the applicability of sections 269SS and 269T of the Act in the hands of the assessee, to record the necessary satisfaction, and to initiate proceedings in accordance with law while giving effect to the appellate order. It was also observed that similar satisfaction had already been recorded in the assessment order of Shri Vishnubhai Shambhubhai

ITA Nos. 89 to 93/Ahd/2025 Jentibhai Shambhubhai Prajapati vs. ACIT Asst. Years–2011-12 to 2014-15 & 2016-17 - 9– Prajapati. All these directions were expressly stated to be directions issued under section 150(1) of the Income-tax Act, 1961, thereby empowering the Assessing Officer to take consequential action notwithstanding limitation. Finally, the CIT(Appeals) clarified that while the appeals for Assessment Years 2011-12 to 2014-15 and 2016-17 were allowed for statistical purposes, the relief was granted subject to the specific and binding directions issued under section 150(1) of the Act. Accordingly, the CIT(Appeals) allowed the appeals for Assessment Years 2011–12 to 2014–15 on the legal issue relating to invalidity of proceedings under section 153C, and also allowed the appeal for Assessment Year 2016–17 on the ground of limitation, while issuing detailed consequential directions under section 150(1) of the Act with respect to all above assessment years.

12.

The assessee is in appeal before us against the order passed by CIT(Appeals) particularly with reference to directions issued u/s 150(1) of the Act.

13.

Before us, the Counsel for the assessee has challenged the validity of directions issued by CIT(Appeals) u/s 150(1) of the Act (notably, CIT(Appeals) has already allowed the appeal of the assessee on grounds of limitation for all assessment years under consideration before us). The Counsel for the assessee reproduced before us the copy of order of CIT(Appeals) in the case of the assessee’s brother VSP for assessment years 2011-12, 2012-13 and 2013-14. The CIT(Appeals) examined the explanation of the assessee’s brother VSP, who contended that he was

ITA Nos. 89 to 93/Ahd/2025 Jentibhai Shambhubhai Prajapati vs. ACIT Asst. Years–2011-12 to 2014-15 & 2016-17 - 10– merely acting as a custodian for his elder brother, Shri Jayantilal S. Prajapati. The assessee’s brother VSP submitted before CIT(Appeals) that all the transactions recorded in the seized material were owned up by his brother through a duly sworn affidavit. In the affidavit, Shri Jayantilal S. Prajapati had clearly admitted that the transactions belonged to him and that the interest income arising therefrom also pertained to him and his family members. The CIT(Appeals) in the assessee’s brother VSP’s case further noted that the debit entries in the seized papers showed withdrawals made by Shri Jayantilal S. Prajapati and his family for social and personal purposes such as mameru, jiyana ceremonies, life insurance premiums and medical expenses. These entries, according to the CIT(Appeals), clearly established that the transactions were not inter se financial dealings between two brothers but were handled by the assessee’s brother VSP only in the capacity of a custodian. The CIT(Appeals) also observed that once the assessee’s brother VSP had furnished the affidavit of his brother owning up the transactions, the onus shifted to the Assessing Officer to disprove the same by conducting appropriate inquiries. However, the Assessing Officer failed to bring any material on record to contradict the contents of the affidavit. The affidavit was neither rebutted nor disproved by the Assessing Officer and, therefore, it carried legal sanctity. The CIT(Appeals) held that merely because Shri Jayantilal S. Prajapati had not disclosed these transactions in his return of income, the addition could not be made in the hands of the assessee’s brother VSP. If the transactions represented unaccounted income, the same could be examined and brought to tax in the hands of the person who owned the transactions, namely Shri

ITA Nos. 89 to 93/Ahd/2025 Jentibhai Shambhubhai Prajapati vs. ACIT Asst. Years–2011-12 to 2014-15 & 2016-17 - 11– Jayantilal S. Prajapati, and not in the hands of the assessee’s brother VSP who acted only as a custodian. In view of these facts and findings, the CIT(Appeals) deleted the protective addition made in the hands of the assessee’s brother VSP. Accordingly, the Counsel for the assessee submitted that CIT(Appeals) had erred in facts and in law in giving directions u/s 150(1) of the Act in light of the above facts.

14.

In response, the Ld. DR placed reliance on the observations made by the Ld. CIT(Appeals) in his order.

15.

We have heard the rival contentions and perused the material on record.

16.

We find that the chronology of events is undisputed and assumes significance for adjudication of the present appeal. The assessment order in the case of the assessee’s brother, Shri Vishnubhai Shambhubhai Prajapati, was passed on 28.12.2019 and the order of the Ld. CIT(Appeals) in his case was passed on 23.04.2021. It is also an admitted position that the assessee, Shri Jentibhai Shambhubhai Prajapati, was issued notice under section 153C of the Act for all the years only on 15.11.2021 and the assessments for all the years under consideration were thereafter completed on 28.12.2021.

17.

We are of the considered view that once Shri Vishnubhai Shambhubhai Prajapati, the assessee’s brother, had brought on record an affidavit stating that the transactions recorded in the seized material

ITA Nos. 89 to 93/Ahd/2025 Jentibhai Shambhubhai Prajapati vs. ACIT Asst. Years–2011-12 to 2014-15 & 2016-17 - 12– were owned up by his brother, namely the assessee, the Revenue authorities ought to have taken immediate and timely steps to initiate proceedings in the hands of the assessee. The inordinate delay in initiating proceedings against the assessee has rendered the present assessments vulnerable on the ground of limitation. Such delay cannot be cured at a later stage by invoking consequential or ancillary directions.

18.

At the same time, we are also of the view that this delay by itself could not justify making substantive additions in the hands of the assessee’s brother, Shri Vishnubhai Shambhubhai Prajapati, particularly when the Ld. CIT(Appeals), in the case of the said brother, has already examined the seized material, the affidavit and the surrounding facts in detail and has deleted the additions by holding that he was only acting as a custodian and that the transactions could not be taxed in his hands. Once the issue has been examined and adjudicated by the Ld. CIT(Appeals) on merits in the case of the assessee’s brother, there was no justification for issuing further directions which, in effect, unsettle a concluded finding.

19.

We further hold that, in the facts of the present case, there was no occasion for the Ld. CIT(Appeals) to issue directions with regard to the applicability of sections 269SS and 269T of the Act. If at all such provisions are attracted, it is always open to the Assessing Officer to examine the same independently and initiate proceedings strictly in accordance with law, subject to fulfilment of statutory conditions. Such

ITA Nos. 89 to 93/Ahd/2025 Jentibhai Shambhubhai Prajapati vs. ACIT Asst. Years–2011-12 to 2014-15 & 2016-17 - 13–

directions were neither necessary nor germane for disposal of the appeals for Assessment Years under consideration before us.

20.

In view of the above discussion and considering the totality of facts and circumstances, we hold that the directions under Section 150(1) of the Act by Ld. CIT(A) for Assessment Years under consideration cannot be sustained. Accordingly, the appeals of the assessee for impugned Assessment Years before us are allowed. This Order pronounced in Open Court on 17/12/2025

Sd/- Sd/- (DR. BRR KUMAR) (SIDDHARTHA NAUTIYAL) VICE PRESIDENT JUDICIAL MEMBER Ahmedabad; Dated 17/12/2025 TANMAY, Sr. PS TRUE COPY आदेश की �ितिलिप अ�ेिषत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant 2. ��थ� / The Respondent. 3. संबंिधत आयकर आयु� / Concerned CIT 4. आयकर आयु�(अपील) / The CIT(A)- 5. िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad गाड� फाईल / Guard file. 6. आदेशानुसार/ BY ORDER, उप/सहायक पंजीकार (Dy./Asstt.Registrar) आयकर अपीलीय अिधकरण, अहमदाबाद / ITAT, Ahmedabad 1. Date of dictation 15.12.2025 (Hon’ble Member dictated on his dragon software) 2. Date on which the typed draft is placed before the Dictating Member 15.12.2025 3. Other Member………………… 4. Date on which the approved draft comes to the Sr.P.S./P.S 15.12.2025 5. Date on which the fair order is placed before the Dictating Member for pronouncement 17.12.2025 6. Date on which the fair order comes back to the Sr.P.S./P.S 17.12.2025 7. Date on which the file goes to the Bench Clerk 17.12.2025 8. Date on which the file goes to the Head Clerk…………………………………... 9. The date on which the file goes to the Assistant Registrar for signature on the order…………… 10. Date of Dispatch of the Order……………………………………

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