T I ASSOCIATES,PANAJI vs. PR. CIT, BENGALURU

IN THE INCOME TAX APPELLATE TRIBUNAL PANAJI BENCH “DB”, PANAJI BEFORE SHRI MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. / ITA No.48/PAN/2022 िनधा�रण वष� / Assessment Year : 2017-18 T. I. Associates, Vs. PCIT (Central), 1st Floor, Manek Chambers, Bangalore. Opp. Municipal Gardens, Panaji- 403001. PAN : AAIFT8000H Appellant Respondent Assessee by : Shri S. J. Kamat Revenue by : Shri Naveen Kumar B. Date of hearing : 14.08.2026 Date of pronouncement : 28.10.2026 आदेश / ORDER PER VINAY BHAMORE, JM: This appeal filed by the assessee is directed against the order dated 28.03.2022 passed by Ld. Pr. CIT (Central), Bangalore [‘Ld. PCIT’] u/s 263 of the IT Act for the assessment year 2017-18. 2. The appellant has raised the following grounds of appeal :- “1) The order of the Learned Principal Commissioner of Income Tax is opposed to law and facts of the case. 2) In the facts and circumstance of the case, the Learned Principal Commissioner of Income Tax has no jurisdiction and is not entitled under section 263 of the Income Tax Act 1961, to revise the order u/s 143(3) dated 20/12/2019 passed by the Learned AO specifically after appropriate inquiry.

2 ITA No.48/PAN/2022 3) In the facts and circumstance of the case, the Commissioner of Income-tax is not justified in holding that the order of the Assessing Officer was erroneous and prejudicial to the interests of the Revenue. 4) The Commissioner of Income-tax had failed to appreciate that the view taken by the Assessing Officer in the order under revision was sustainable in law and a plausible view under the law and thus, the said order cannot be treated as erroneous and prejudicial to the interest of Revenue. 5) In the facts and circumstance of the case, the Learned Principal Commissioner of Income Tax has no jurisdiction and is not entitled under section 263 of the Income Tax Act 1961, to revise as erroneous or prejudicial to the interest of Revenue, the order u/s 143(3) dated 20/12/2019 passed after inquiry, without the Learned Principal Commissioner of Income Tax himself embarking on any further inquiry. Additional grounds: 6) The Learned Principal Commissioner of Income Tax is not entitled to revise the assessment order on a ground different from the ground contained in the show cause notice. 7) The order passed by the Ld. PCIT is null and void as it fails to mention any DIN number on its body or adhere to Circular No.19/2019 by the CBDT. The impugned order is therefore void ab initio. 8) The order passed by the Ld. PCIT is null and void as it is passed without any valid show cause notice; as the show cause notice fails to mention any DIN number on its body or adhere to Circular No.19/2019 by the CBDT. The impugned order is therefore void ab initio. 9) The impugned order is entirely based on borrowed satisfaction based on audit objection and the initiation of the revision is at the instance of the proposal submitted by the AO. The impugned order is therefore void ab initio for either of these reasons. 10) The impugned order is based on a ground which was not included in the show was noticed issued by the respondent. The impugned order is therefore void ab initio. 11) The Appellant craves leave to add to, delete from or modify the above grounds at the time of hearing.” 3. Facts of the case, in brief, are that the assessee is a partnership firm engaged in the business of running restaurants (Niyaz

3 ITA No.48/PAN/2022 Restaurant) and takeaways. A survey u/s 133A of the IT Act was conducted on 18.07.2017 at the business premises of the assessee and it was found that for Financial Year 2016-17 sales of Rs.3,54,59,750/- were reported in the IDS software maintained by the assessee. During the survey proceedings, the statement of the partner’s and of manager were recorded wherein in response to question no.4 it was answered – that I confirm that the sales of Rs.3,54,59,750/- are taken from the IDS software in which the day to day sales of T.I. Associates (Niyaz Restaurant) are maintained. The assessee subsequent to survey got its books of accounts audited on 31-10-2017 & filed its return of income on 31.10.2017 by declaring income of Rs.6,44,480/- for Asstt Year 2017-18 which is the period under consideration. The case was selected for scrutiny under compulsory manual selection and during the course of assessment proceedings it was found by the Assessing Officer that the assessee partnership firm has disclosed sales turnover of Rs.2,36,16,629/- only in its audited Trading Profit and loss account as against the sales turnover of Rs.3,54,59,150/- found & admitted during survey as per the IDS software maintained by the assessee. The Assessing Officer observed that the survey took place on

4 ITA No.48/PAN/2022 18.07.2017 wherein turnover of Rs.3,54,59,750/- was admitted by the assessee, however, in the books of account duly audited on 30.10.2017 the sales of only Rs.2,36,16,629/- were declared. When the Assessing Officer pointed out this fact to the assessee, the assessee agreed to declare net profit on the differential turnover of Rs.1,18,42,521/- (3,54,59,150 – 2,36,16,629) (which was not declared in the books of accounts) @ 12% which comes to Rs.14,21,100/-. Accordingly, the Assessing Officer vide order dated 20.12.2019 completed the assessment proceedings u/s 143(3) of the IT Act by determining the income of the assessee firm at Rs.20,65,582/- as against the income of Rs.6,44,480/- returned by the assessee. The above assessed income includes addition of Rs.14,21,100/- being the amount of net profit agreed and offered by the assessee at the rate of 12% on un accounted sales of Rs.1,18,42,521/-. 4. Subsequently, on examination of the assessment case records it was found by Ld. PCIT that there was no finding during the survey proceedings conducted u/s 133A of the IT Act that expenses were also under reported and since all the expenses were already claimed in the audited Trading & P & L Accounts the expenses

5 ITA No.48/PAN/2022 were wrongly allowed by the Assessing Officer by adopting NET PROFIT @ 12% on suppressed sales. 5. Apart from above, it was also found by Ld. PCIT that during demonetization period the assessee has deposited cash of Rs.77,69,040/- in Kotak Mahindra Bank, however, the Assessing Officer did not verify the sources of above cash deposit & did not made any enquiry on this issue during assessment proceedings. Accordingly, Ld. PCIT invoked the provisions of section 263 of the IT Act & issued show-cause notice u/s 263 of the IT Act & after considering the reply of the assessee held that the order passed by the Assessing Officer is erroneous in so far as it is prejudicial to the interest of the Revenue as per the provisions of clause (a) of Explanation (2) of section 263 of the IT Act & therefore, he set aside the assessment order dated 20-12-2019 passed by the Assessing Officer & restored the matter back to the file of the Assessing Officer for passing a fresh assessment order after making thorough enquiry into cash deposit during demonetization period & after verification of the issues with regard to suppression of sales found during survey proceedings & also after providing reasonable opportunity of hearing to the assessee by observing as under :-

6 ITA No.48/PAN/2022 “2. Consequent upon a Survey u/s. 133A of the Act conducted in the premises of the assessce Firm it was found that there was suppression of sales from IDS software to the extent of Rs. 1,18,45,521/- and the assessment u/s. 143(3) was completed on 20.12.2019 with additions on account of net profit @12% of the difference in turnover of Rs. 1,18,45,521/-. 3. Examination of case records revealed that there were no findings during the Survey proceedings and that expenses were also underreported. Since all the expenses were already claimed in the Return of income filed by the assessee, the expenses were erroneously allowed by the AO by adopting net profit @12% on the suppressed receipts leading to excess allowance of expenses to the tune of Rs. 1,04,24,418/-. 4. Accordingly, Show cause notice U/s. 263 for revision of the order passed U/s. 143(3) for the AY 2017-18 was issued to the assessee vide letter dated 02.03.2022 (DIN & Document No. ITBA/REV/S/91/2021-22/11040275542(1) giving the assessee an opportunity of being heard and to show cause as to why the impugned order should not be enhanced / modified or set aside for a fresh assessment U/s. 263 of the IT Act, 1961. The notice is reproduced below for ready reference: “2. Survey u/s 133A was conducted in your case on 18.07.2017 and suppression of sales from IDS software of Rs. 1,18,45,521/-was found. Assessment was completed by ITO ward 1(5), Panaji u/s 143(3) of IT Act on 20.12.2019 after making additions on account of net profit @12% of difference in turnover of Rs. 1,18,45,521/-. On examination of records it is observed that there was no finding during survey proceedings that expenses were also underreported. Since all the expenses were already claimed in the return of income filed, the expenses were wrongly allowed by AO by adopting net profit percentage @12%. On verification of the records, it was found that the assessing officer had erroneously allowed the expenses on suppressed receipts leading to excess allowance of expenses to the tune of Rs. 1,04,24,418/-. 3. Further, as per statement of financial transactions, it is seen that there were cash deposits of Rs. 77,69,040/- during specified period of 09.11.2016 to 30.12.2016 in Kotak Mahindra Bank in account no. 9312083183. The source of cash deposits was not verified during assessment proceedings. The AO did not verify and make any enquiry on these issue during assessment proceedings. 4. Considering the facts and circumstances of the case since the Assessing Officer has passed the assessment order without making any verification or enquiry, the assessment order is erroneous in so far as it

7 ITA No.48/PAN/2022 is prejudicial to the interest of the revenue, I propose to invoke the Provisions of Section 263 of the Income Tax Act.” 5. In response to the notice, the assessee vide letter dated 25.03.2022 has furnished his submissions. The gist of the assessec's submission is as under :- (i) The Learned AO has adopted a profit to 12 percent on the alleged suppressed sale, which action of the assessing officer is entirely as per the law on the subject as pronounced by the Honourable Income tax Appellate Tribunal and Honourable High Courts and the Learned Assessing Officer followed the said binding precedents from higher authorities which he was mandatorily bound to do. There was, therefore no error in his action. Your honour will thus find that the order sought to be revised is not erroneous of prejudicial to the interest of Revenue on account of above first contention at all. (ii) The Learned Assessing Officer had asked the following details and documents during the assessment proceedings. The deposits in Kotak Mahindra Bank A/c. No. 9312083183 (appearing at 2(g) d of the above reply to notice u/s. 1423(1) which is the alleged basis of the proposed revision were very much found in the cash book(appearing at 2(1) above), recorded in the ordinary course of business and in compliance with all the accounting tenets and principles of double entry, so much so that no person versed in accounts could draw any imputation that the nature or source of these deposits in Kotak Mahindra Bank A/c. No. 9312083183 were unexplained or unrecorded. Kindly note that the source of these deposits into Kotak Mahindra Bank A/c. No. 9312083183 were out of the regular business receipts/sales of the business of the assessee and these deposits were found duly accounted in the payment side of the cash book maintained in the regular course of business in which cash book of the aforesaid regular business receipts/sales were found on the receipt side. We reiterate that no prudent Assessing Officer, versed in accounting after having asked and verified the cash book in which the deposits into the Kotak Mahindra Bank Account No. 9312083183 were duly found recorded as outgoings and the incoming receipts in which very cash book were already offered to Income tax could draw any

8 ITA No.48/PAN/2022 conclusion other than that these deposits were duly explained. No further inquiry was therefore called for on the part of Leaned Assessing Officer, as wrongly contemplated in the show cause notice. 6. I have considered the assessee's submissions and have gone through the assessment records. 6.1 Suppression of sales of Rs. 1,18,45,521/- in accounts of assessce was found during survey proceedings. The assessee had already filed its return of income and claimed the due expenses. There was no finding to the fact that any expenses were not claimed by the assessee hence the action of the AO to complete assessment proceedings @12% of the suppression amount found during survey is erroneous and prejudicial to the revenue. 6.2 The assessee has claimed that the AO has already verified the books of accounts like cash book etc during assessment proceedings hence revision of the proceedings is not required. The CBDT had issued various checklists for assistance of AOs for framing of assessment order in demonetisation related case and issued guidelines to follow the same. However on examination of the case records, it is observed that the guidelines are not followed, which makes the assessment order erroneous and prejudicial to the interest of revenue. 7. In view of the above facts, it is held that the Assessment Order passed by the Assessing Officer is erroneous so far as it is pre-judicial to the interest of the Revenue as per the provisions of Clause (a) of Explanation (2) to the Section 263 of the Income Tax Act, 1961. The claims of the assessee made during current proceedings require in depth enquiry and examination by the Assessing Officer. Hence, the assessment order dated 20.12.2019 is hereby set-aside to the file of the Assessing Officer for passing a fresh assessment Order after making thorough enquiry into cash deposits during demonetization period and after verification of the issues with regard to suppression of sales found during survey proceedings. 8. It is further directed that the Assessing Officer will provide sufficient opportunity of being heard to the assessce during the course of the set-aside proceedings.” 6. It is the above order against which the assessee is in appeal before this Tribunal.

9 ITA No.48/PAN/2022 7. We have heard Ld. counsels from both the sides and perused the material available on record including the paper book furnished by the assessee. In this regard, we find that the assessee has raised additional legal grounds with regard to DIN however, the same were not pressed during the course of hearing, accordingly, the same are dismissed as not pressed. 8. In sum & substance all the grounds challenged the action of Ld. PCIT wherein he set aside the assessment order & remanded the matter back to the Assessing Officer to pass fresh assessment order after conducting thorough enquiry into cash deposit during demonetization & after verification of the issues with regard to suppression of sales found during survey proceedings. 9. In this regard, we find that Ld. PCIT in the light of clause (a) of Explanation (2) to section 263 of the IT Act has exercised his revisionary powers since according to him the order is passed without making inquiries or verification which should have been made. 10. In this regard, we also find that the Assessing Officer has not done any enquiry with regard to cash deposit of Rs.77,69,040/- in Kotak Mahindra Bank during demonetization period & also did not

10 ITA No.48/PAN/2022 conducted any enquiry regarding suppressed sales found during the course of survey & without conducting any verification accepted the contention of the assessee regarding application of 12% net profit rate on suppressed sales. In this regard, we find that CBDT has issued standard operating procedure ( SOP ) for conducting the enquiry with regard to cash deposit during demonetization period and admittedly the Assessing Officer has not conducted any such enquiry which is apparent from the assessment order & also from the perusal of copy of notice issued by the Assessing Officer u/s 142(1) of the IT Act. Accordingly, in our considered opinion Ld. PCIT has rightly initiated the revisionary proceedings & there is no error in his order wherein it was held by him that the assessment order passed is erroneous as well as prejudicial to the interest of the revenue, since admittedly the Assessing Officer has not conducted such enquiries which he was supposed to carry out. In this regard, we find support from judgement passed by Hon’ble Supreme Court in the case of M.R. Apparels (P.) Ltd. vs. Principal Commissioner of Income-tax [2025] 170 taxmann.com 712 (SC)[07-01-2025] wherein SLP was dismissed which was filed against the judgement of Hon’ble Delhi High Court in the case of M.R Apparels (P.) Ltd.

11 ITA No.48/PAN/2022 v. Pr. Chief CIT [2024] 168 taxmann.com 197 (Delhi) wherein Hon’ble Delhi High Court justified the proceedings u/s 263 of the IT Act by observing as under :- “The appellant has filed the present appeal under Section 260A of the Income Tax Act, 1961 (hereafter the Act) impugning an order dated 06.02.2024 (hereafter the impugned order) passed by the learned Income Tax Appellate Tribunal (hereafter the Tribunal), in ITA No. 198/DEL/2020, for the Assessment Year 2015-16. The appellant (assessee) had preferred the said appeal impugning an order dated 18.11.2019 passed by the learned Principal Commissioner of Income Tax (hereafter the CIT) under Section 263 of the Act holding that the Assessment Order dated 04.05.2017 passed by the learned Assessing Officer (hereafter the AO) under Section 143(3) of the Act in respect of the assessment year 2015-16, is erroneous, in so far as it is prejudicial to the interest of the Revenue. 2. The learned CIT concluded that the AO had not verified the necessary relevant facts relating to the taxability of sale of certain immovable property. 3. The controversy essentially, relates to the sale of immovable property during the relevant previous year (Financial Year 2014-15) for a sum of ^6,50,00,000/-. Admittedly, the sale deed in respect to the said immovable property was executed by the appellant on 17.03.2015 and the stamp duty of ? 32,50,000/- was also paid by the purchaser (M/s VTS IT Solutions). TDS at the rate of 1%, amounting to ^6,50,000/- was also deducted on the total sale consideration paid by the purchaser on 18.03.2015. Admittedly, a sum of ^5,05,00,000/- was received by the appellant. However, the appellant claims that he did not receive the balance amount of ^1,45,00,000/-, as the cheques for the said amount were dishonoured. According to the appellant, the transaction of sale and purchase of the immovable property remained inchoate. The appellant claims that notwithstanding that a conveyance deed was executed, the sale of the property in question was not consummated. The appellant did not reflect the sale of his immovable property, during the relevant Assessment Year and did not offer the capital gains to tax. 4. The learned CIT found that the AO did not examine the details regarding the dishonour of cheques. The learned CIT noted that the two cheques aggregating to ?1,45,00,000/- issued by the purchaser were postdated cheques as they were dated 15.09.2015 and 15.03.2016 respectively. The audit report furnished by the appellant is dated 04.09.2015. Therefore, the Auditors could not have commented upon

12 ITA No.48/PAN/2022 the dishonour of the cheques, as the report was prior to the dates of the cheques. 5. Pursuant to the order passed by the learned CIT, the AO passed an order dated 24.09.2021 under Section 144 read with Section 263 and 144 B of the Act. The learned AO assessed the appellant's income for the assessment year 2015-16 at ?1,86,11,320/- and raised a demand of ^44,19,500/-. In the meanwhile, on 10.01.2020, the appellant preferred an appeal before the Tribunal against the order dated 18.11.2019 passed by the learned CIT under Section 263 of the Act. 6. On 20.10.2021, the appellant also filed an appeal against the assessment order dated 24.09.2021 before the learned Commissioner of Income Tax (Appeals), which is pending. 7. The Tribunal rejected the appellant's appeal against the order dated 18.11.2023 passed by the CIT under Section 263 of the Act, in terms of the impugned order. 8. The learned Tribunal considered the appellant's contentions and found no fault with the CIT's order dated 18.11.2018. 9. The learned counsel for the appellant contends that all material and documents were available with the AO and he had made full enquiries. Therefore, the explanation no. 2 to Section 263 of the Act was not satisfied. 10. Section 263 of the Act is set out below: "Revision of orders prejudicial to revenue. (1) The Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer or the Transfer Pricing Officer, as the case may be, is erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including,— (i) an order enhancing or modifying the assessment or cancelling the assessment and directing a fresh assessment; or (ii) an order modifying the order under section 92CA; or (iii) an order cancelling the order under section 92CA and directing a fresh order under the said section. Explanation 1.—For the removal of doubts, it is hereby declared that, for the purposes of this sub-section, — (a) an order passed on or before or after the 1st day of June, 1988 by the Assessing Officer [or the Transfer Pricing Officer, as the case may be, shall include— (i) an order of assessment made by the Assistant Commissioner or Deputy Commissioner or the Income-tax Officer on the basis of the directions issued by the Joint Commissioner under section 144A; (ii) an order made by the Joint Commissioner in exercise of the powers or in the performance of the functions of an Assessing Officer [or the Transfer Pricing Officer, as the case may be,] conferred on, or assigned to, him

13 ITA No.48/PAN/2022 under the orders or directions issued by the Board or by the Principal Chief Commissioner or Chief Commissioner or Principal Director General or Director General or Principal Commissioner or Commissioner authorised by the Board in this behalf under section 120; (iii) an order under section 92CA by the Transfer Pricing Officer; (b) "record" shall include and shall be deemed always to have included all records relating to any proceeding under this Act available at the time of examination by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner; (c) where any order referred to in this sub-section and passed by the Assessing Officer 92[or the Transfer Pricing Officer, as the case may be,] had been the subject matter of any appeal filed on or before or after the 1st day of June, 1988, the powers of the* Principal Commissioner or Commissioner under this sub-section shall extend and shall be deemed always to have extended to such matters as had not been considered and decided in such appeal. Explanation 2. —For the purposes of this section, it is hereby declared that an order passed by the Assessing Officer or the Transfer Pricing Officer, as the case may be, shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made; (b) the order is passed allowing any relief without inquiring into the claim; (c) the order has not been made in accordance with any order, direction or instruction issued by the Board under section 119; or (d) the order has not been passed in accordance with any decision which is prejudicial to the assessee, rendered by the jurisdictional High Court or Supreme Court in the case of the assessee or any other person. Explanation 3.—For the purposes of this section, "Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA. (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section (2), an order in revision under this section may be passed at any time in the case of an order which has been passed in consequence of, or to give effect to, any finding or direction contained in an order of the Appellate Tribunal, National Tax Tribunal, the High Court or the Supreme Court. Explanation.—In computing the period of limitation for the purposes of sub-section (2), the time taken in giving an opportunity to the assessee to be reheard under the proviso to section 129 and any period during which any proceeding under this section is stayed by an order or injunction of any court shall be excluded." [Emphasis added] 11. We find no merit in the appellant's contention. Concededly, the audit report could not have commented upon the dishonour of cheques, as the report was issued prior to the date of the cheques aggregating ?

14 ITA No.48/PAN/2022 1,45,00,000/. The AO had accepted the said report. The assessment order does not indicate any enquiries in this regard. The learned CIT has rightly held that the Assessment Order was passed without making the necessary inquiries and verification. Thus, in terms of clause (a) of Explanation 2 to Section 263 of the Act, the assessment order is deemed to be erroneous in so far as it is prejudicial to the interests of the revenue. 12. We find that no question of law arises in the present case. 13. The appeal is, accordingly, dismissed. 14. Pending application is also dismissed.” 11. Respectfully following the above judgement passed in the case of M.R. Apparels (P.) Ltd. (supra), we are of the considered opinion that there is no error in the order passed by Ld. PCIT wherein he rightly held that the assessment order was passed without making the necessary inquiries and verification & therefore in terms of clause (a) of Explanation 2 to section 263 of the IT Act, the assessment order is deemed to be erroneous in so far as it is prejudicial to the interests of the Revenue. 12. Ground-wise adjudication is as follows : 12.1 With regard to ground no.1, we find that the order passed by Ld. PCIT is as per law & based on the facts of the case. 12.2 With regard to ground no.2, 3, 4 & 5, we find that Ld. PCIT has full jurisdiction & is also entitled u/s 263 of the IT Act to revise the impugned order dated 20-12-2019 passed u/s 143(3) of the IT

15 ITA No.48/PAN/2022 Act & we do not find any such error in the above order as pointed out by the assessee. 12.3 With regard to additional ground no.6, we find that Ld. PCIT has set-aside the assessment order for reassessment after proper enquiry on the grounds mentioned in the show cause notice therefore, we do not find any merit in this ground hence it is dismissed. 12.4. With regard to additional ground no.7 & 8 regarding DIN, the same were not pressed hence dismissed as such. 12.5 From the perusal of the order passed by Ld. PCIT & on the basis of material available before us, we do not find that Ld. PCIT has initiated revisionary proceedings either on the basis of audit objection or on the basis of proposal from the Assessing Officer. Accordingly, we do not find any force in this additional ground no.9 & therefore it is dismissed. 12.6 We have gone through the show cause notice issued by Ld. PCIT (which is also reproduced by Ld. PCIT in his order) & are of the considered opinion that the order was set aside for reassessment on the basis of grounds mentioned in the show cause notice only.

16 ITA No.48/PAN/2022 Accordingly, we do not find any merit in this additional ground no10 & therefore, the same is dismissed. 12.7 Additional ground no.11 is a general ground hence needs no adjudication. 13. In the result, the appeal filed by the assessee is dismissed. Order pronounced on this 28th day of October, 2026. Sd/- Sd/- (MANISH BORAD) (VINAY BHAMORE) ACCOUNTANT MEMBER JUDICIAL MEMBER Pune / Dated : 28th October, 2026. Sujeet/DOC Sujeet Kumar Digitally signed by Sujeet Kumar Sharma Sharma Date: 2026.10.29 10:42:58 +05'30' आदेश क� �ितिलिप अ�ेिषत / Copy of the Order forwarded to : अपीलाथ� / The Appellant. 1. ��यथ� / The Respondent. 2. 3. The Pr. CIT (Central), Bangalore. 4. DR, ITAT, Panaji. गाड� फ़ाइल / Guard File. 5. आदेशानुसार / BY ORDER, // True Copy // Assistant Registrar ITAT, Pune.