HITENDRAKUMAR SHAH,VADODARA vs. ITO WARD 4(1)(7) VADODARA, VADODARA

PER SANJAY KUMAR, JUDICIAL MEMBER:

- This appeal has been filed by the Assessee against the order dated 31.07.2026 passed by the Ld. office of the Commissioner of Income Tax, Appeal Addl./JCIT (A)-1 Nagpur (hereinafter referred to as ‘Ld. CIT (A)’ in short), under Section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’ in short) for Assessment Year 2020-21. ITA 2780/AHD/2026 (AY: 2020-21) - 2–

- 3– The remaining amount was declared as taxable income in the original Return of Income. The Assessee offered remainder of leave encashment amount received by him to tax in the return by claiming exemption only to the extent of RS. 3 lakhs u/s 10AA of the Act. The return of income was processed by CPC, Bengaluru, and an intimation under section 143(1) was issued on 10.12.2020, wherein no adjustment was made and no demand was raised neither any refund was issued. 3. 1. The Assessee filed an appeal u/s 250 of the Act before Ld. CIT(A) on 28.04.2026 against intimation u/s 143(1) of the Act after a delay of around 5 years claiming that after the pronouncement of judgment in the case of Harish Kumar vs. ITO, rendered in ITA No. 42/CHD/2025 dated 30.05.2025, he became aware that the compensation received by him is fully exempt under law. Consequently the Assessee filed the appeal claiming for the said ex-gratia payment as fully exempt in the said appeal. The Appellant also claimed the entire leave encashment amount received by him is fully exempt u/s 10AA of the Act as Notification No.31/2023 dated 24.05.2023 enhance the monetary ceiling of exemption of leave encashment payable to non-Government Employees to Rs.25 lakhs.

The Appellant respectfully submits the following additional written submissions pursuant to the hearing conducted on 08.10.2026, during which the Hon'ble Bench raised a query regarding the non-filing of revised returns of income and the possibility of seeking condonation under section 119(2)(b) of the Income-tax Act, 1961. The present submissions are being made to explain the legal position concerning the Appellant's claim for exemption under section 10(10B) in respect of compensation received under the BSNL Voluntary Retirement Scheme, 2019 (BSNL VRS-2019) and exemption of Leave Encashment under section 10(10AA) of Income Tax Act.

The Appellant received compensation pursuant to the BSNL VRS-2019 and Leave Encashment. At the time of filing the original return of income, the Appellant disclosed the relevant compensation and Leave Encashment and offered to tax, as recorded in the appellate order. Subsequently, upon becoming aware of the legal position and the decisions concerning the applicability of section 10(10B) to compensation received under BSNL VRS- 2019, the Appellant sought the benefit of exemption under the said provision before the appellate authority.

It is respectfully submitted that the present controversy does not arise from any undisclosed receipt, concealment of income or failure to disclose the transaction. The compensation was disclosed in the return, and the dispute concerns the correct legal characterisation and tax treatment of the disclosed receipt. The Appellant bona fide believed, at the time of filing the return, that the compensation was taxable except to the extent of exemption claimed under section 10(10C). The subsequent claim under section 10(10B) was made upon becoming aware of the legal position and the judicial decisions concerning similar compensation paid under BSNL VRS-2019. ITA 2780/AHD/2026 (AY: 2020-21) - 7– The Appellant accordingly submits that the claim deserves adjudication on its legal and factual merits. The mere fact that the claim was not made in the original return should not, by itself, prevent the Hon'ble Tribunal from examining whether the amount is chargeable to tax or qualifies for exemption under the applicable statutory provision.

Section 237 of the Income-tax Act, 1961 recognises the entitlement to a refund where the amount of tax paid by an assessee exceeds the amount with which the assessee is properly chargeable under the Act. The Appellant relies upon this provision to submit that the tax liability must ultimately be determined in accordance with the correct legal position and that an amount which is not chargeable to tax in law should not be subjected to tax merely because the assessee did not initially claim the applicable exemption.

The Appellant further relies upon CBDT Circular No. 14 (XL-35), dated 11.04.1955, which instructs the Income-tax Department to adopt a fair and helpful approach in dealing with taxpayers and not to take advantage of an assessee's ignorance of the law. The Circular emphasises that the Department should assist taxpayers in obtaining reliefs to which they are legally entitled, even where a taxpayer has not properly claimed such relief due to ignorance or omission.

It is respectfully submitted that the above Circular supports the Appellant's request for consideration of the claim in accordance with law. The Appellant does not contend that the Circular overrides the statutory conditions prescribed under section 10(10B) or the procedural requirements of the Act. Rather, the submission is that, where the relevant receipt is already disclosed and a claim for exemption is raised on the basis of a subsequent understanding of the applicable law and judicial decisions, the claim ought to be examined on its merits instead of being rejected solely on a technical ground.

The Hon'ble Supreme Court in Jute Corporation of India Ltd. v. Commissioner of Income-tax (1991) 187 ITR 688 (SC) recognised the powers - 8– of the appellate authority to entertain an additional ground where such consideration is necessary for determining the correct tax liability. The Court held, in substance, that the appellate authority has discretion to permit an additional ground and that such discretion must be exercised judicially in furtherance of the proper determination of the tax liability.

Similarly, in National Thermal Power Co. Ltd. v. Commissioner of Income-tax (1998) 229 ITR 383 (SC), the Hon'ble Supreme Court held that the Tribunal may consider a question of law arising from the facts available on record even if the question was not raised before the lower authorities, where consideration of that question is necessary to determine the correct tax liability. The principle laid down by the Hon'ble Supreme Court is that the Tribunal's appellate jurisdiction is not confined to the grounds originally raised where a relevant question of law arises from the material already on record.

The Hon'ble Bombay High Court in Commissioner of Income-tax v. Pruthvi Brokers & Shareholders Pvt. Ltd. (2012) 349 ITR 336 (Bom) also recognised that appellate authorities can entertain a legitimate claim which was not made in the return of income. The Court distinguished the restriction applicable to the Assessing Officer, as considered in Goetze (India) Ltd. v. Commissioner of Income-tax (2006) 284 ITR 323 (SC), from the powers of appellate authorities.

In Goetze (India) Ltd. (supra), the Hon'ble Supreme Court expressly clarified that its decision concerning the Assessing Officer's inability to entertain a fresh claim otherwise than through a revised return did not impinge upon the powers of the Income Tax Appellate Tribunal under section 254 of the Act. Accordingly, the said decision cannot be read as laying down an absolute prohibition against consideration of a legitimate additional legal claim by the appellate Tribunal.

In the present case, the Appellant's claim concerns the legal characterisation and exemption of compensation which was disclosed in the original return. The relevant transaction and receipt are not being introduced for the first time before the Tribunal. The Appellant therefore respectfully submits that the Hon'ble Tribunal may examine the applicability of section 10(10B) in the light of the facts on record and the governing judicial precedents, subject to verification of the statutory conditions.

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The Appellant respectfully places reliance upon Jayeshkumar Tulsidas Sutaria v. Income-tax Officer, ITA Nos. 2387 and 2388/Ahd/2025, Assessment Years 2020-21 and 2021-22, order dated 17.02.2026, passed by the Hon'ble Income Tax Appellate Tribunal, Ahmedabad SMC Bench.

In paragraph 4 of the said order, the Tribunal recorded the objection taken by the Ld. CIT(A), who had declined to entertain the claim for exemption under section 10(10B) on the ground that the claim had not been made in the original or revised return and that the assessee could have sought condonation from the jurisdictional Principal Commissioner of Income-tax under section 119(2)(b). The claim was consequently rejected at the appellate stage.

In paragraph 6, the Tribunal considered the assessee's explanation that the compensation received under BSNL VRS-2019 had initially been offered to tax because the assessee was unaware of the legal position and subsequently became aware of the decisions concerning the exemption under section 10(10B), including Harish Kumar v. ITO, ITA No. 42/CHD/2025, order dated 30.05.2025. The Tribunal considered the claim in the appellate proceedings notwithstanding the fact that the exemption had not been claimed in the original or revised return. In paragraph 7, the Tribunal allowed both appeals. The said decision is directly relevant because it concerns compensation under BSNL VRS-2019, the claim of exemption under section 10(10B), and the objection that the claim was not made in the original or revised return and should instead have been pursued through section 119(2)(b). The factual and legal similarity makes the decision particularly material to the present appeals.

The Appellant respectfully submits that the Hon'ble Tribunal may follow the above decision while considering the present claim.

The Appellant also relies upon the decision of the Hon'ble Income Tax Appellate Tribunal, Mumbai Bench, in Oracle Financial Services Software Limited, ITA Nos. 4795, 4796 and 3430/Mum/2019 and ITA Nos. 5378, 5376 and 3997/Mum/2019, particularly paragraphs 14 to 14.12 of the order.

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In paragraph 14, the Tribunal considered the Department's objection that a claim not made in the original or revised return could not be entertained at the appellate stage and that the assessee's only remedy was to seek condonation under section 119(2)(b). In paragraphs 14.1 and 14.2, the Tribunal discussed the scope of Goetze (India) Ltd. (supra), Jute Corporation of India Ltd. (supra), NTPC Ltd. (supra) and Pruthvi Brokers & Shareholders Pvt. Ltd. (supra), and recognised the distinction between the powers of the Assessing Officer and those of appellate authorities.

The Tribunal's reasoning, particularly in paragraphs 14.4 to 14.6, supports the proposition that the existence of a remedy under section 119(2)(b) does not, by itself, establish that the appellate jurisdiction under section 254 is unavailable in every case involving a claim not made in the return. The power under section 119(2)(b) enables the competent authority to consider condonation in cases of genuine hardship in accordance with the applicable statutory framework and CBDT instructions. The existence of that remedy must be considered alongside, and not automatically as a substitute for, the independent powers of appellate authorities recognised by judicial precedents

The Appellant acknowledges that Oracle Financial Services Software Limited arose in a different factual context and concerned a different substantive claim. It is relied upon only for the procedural principle concerning the jurisdiction of appellate authorities and the relationship between sections 119(2)(b) and 254. The substantive entitlement of the present Appellant must be determined separately under section 10(10B) on the facts and documents relevant to BSNL VRS-2019. The Appellant accordingly submits that the claim should not be rejected solely on the ground that an application under section 119(2)(b) was not filed, without first considering the scope of the Hon'ble Tribunal's appellate powers and the directly relevant decision in Jayeshkumar Tulsidas Sutaria (supra).

Without prejudice to the above procedural submissions, the Appellant submits that the substantive claim for exemption must be considered under section 10(10B) of the Income-tax Act, 1961. The said provision concerns compensation received by a workman under the Industrial Disputes Act, 1947, or under any other applicable law, rules, orders or notifications, subject to - 11– the statutory conditions and prescribed limits. The applicability of the provision depends upon the legal character of the payment, the governing scheme, the circumstances in which the payment was made, and compliance with the relevant statutory requirements.

The Appellant relies upon Harish Kumar v. Income-tax Officer, ITA No. 42/CHD/2025, order dated 30.05.2025, passed by the Hon'ble Income Tax Appellate Tribunal, Chandigarh Bench, which has been cited in the compilation of decisions concerning compensation paid under BSNL VRS- 2019. As reflected in the compilation, the Tribunal considered the nature of compensation under the scheme and its eligibility for exemption under section 10(10B), subject to satisfaction of the applicable conditions. The Appellant requests that the ratio of the said decision be considered in conjunction with the terms of the BSNL VRS-2019 scheme and the documents placed on record in the present appeals.

The Appellant also relies upon the decision in Shraddha Pralhad Arote & Others v. Income-tax Officer, ITA Nos. 262-301/PUN/2026, order dated 24.03.2026, passed by the Hon'ble Income Tax Appellate Tribunal, Pune Bench, as referred to in the compilation of decisions. The said decision is relied upon to the extent that it addresses the nature and treatment of compensation under the BSNL VRS-2019 scheme and the applicability of section 10(10B). The Appellant respectfully requests that the relevant reasoning of these decisions be examined against the facts and governing scheme applicable to the Appellant.

During the hearing, the Hon'ble Bench raised a query as to why the Appellant did not file a revised return or seek condonation under section 119(2)(b). In this regard, the Appellant respectfully submits that the time limit prescribed under section 139(5) had expired by the time the legal position concerning the claim was understood and the appellate proceedings were pursued. The Appellant does not dispute the statutory time limit for filing a revised return. The limited submission is that expiry of that time limit does not, by itself, answer the separate question whether a legitimate claim can be entertained by an appellate authority under its appellate jurisdiction

Section 119(2)(b) provides a mechanism for the competent authority to consider an application for condonation in cases of genuine hardship in - 12– accordance with the statutory framework and applicable CBDT instructions. However, as recognised in Jute Corporation of India Ltd. (supra), NTPC Ltd. (supra), Pruthvi Brokers & Shareholders Pvt. Ltd. (supra), and the relevant discussion in Oracle Financial Services Software Limited (supra), the powers of appellate authorities must be considered independently. The existence of an alternative statutory mechanism does not, without further examination, establish that the Tribunal lacks jurisdiction to adjudicate a legal claim arising from facts on record.

The Appellant respectfully submits that the present claim is not based upon a new or undisclosed transaction. The compensation was disclosed in the return, and the claim concerns the applicability of the exemption provision to that disclosed receipt. In these circumstances, the Appellant requests that the Hon'ble Tribunal exercise its appellate jurisdiction to determine the correct tax liability in accordance with law.

The Appellant respectfully submits that the decision of the Ahmedabad Bench in Jayeshkumar Tulsidas Sutaria (supra) is of particular significance because it dealt with the claim of exemption under section 10(10B) in relation to BSNL VRS-2019 and the objection concerning the absence of a claim in the original or revised return. The Appellant requests that the said decision be considered along with the decisions of the Hon'ble Supreme Court in Jute Corporation of India Ltd. (supra) and NTPC Ltd. (supra), and the decision of the Hon'ble Bombay High Court in Pruthvi Brokers & Shareholders Pvt. Ltd. (supra).

The Appellant is conscious that the entitlement to exemption under section 10(10B) depends upon the statutory conditions and the relevant facts of the case. The Appellant is not seeking exemption merely on the basis of a procedural argument. The request is that the claim be adjudicated on merits after considering the applicable scheme, supporting documents and the relevant judicial precedents, and that the procedural objection regarding non- filing of a revised return or an application under section 119(2)(b) not be treated as an automatic bar to appellate adjudication.

In view of the directly relevant decision of the Ahmedabad Bench and the principles laid down by the Hon'ble Supreme Court concerning the powers of appellate authorities, the Appellant respectfully submits - 13– that the issue should be decided in accordance with the applicable statutory provisions and binding judicial principles. The Appellant requests that the claim be considered on its merits rather than rejected solely on a technical ground, and that the decision be rendered after examining the legal position and the evidence relevant to the compensation received under BSNL VRS- 2019. 9. Consistency with Earlier Decisions of the Hon'blé Ahmedabad Bench and Alternative Prayer for Reference to a Special Bench under Section 255(3) of the Income-tax Act, 1961

The Appellant respectfully submits that the issue under consideration is covered by several favourable decisions of the Hon'ble Ahmedabad Bench of the Income Tax Appellate Tribunal, including Jayeshkumar Tulsidas Sutaria v. ITO, ITA Nos. 2387 and 2388/Ahd/2025, order dated 17.02.2026, concerning the claim of exemption under section 10(10B) of the Income-tax Act, 1961, in respect of compensation received under BSNL VRS-2019. The Appellant humbly requests that the aforesaid decisions and other relevant decisions relied upon in the paper book be followed in the interest of judicial consistency and certainty, particularly where the facts and legal issues are materially similar. Without prejudice, if the Hon'ble Bench is inclined to take a view contrary to the aforesaid decisions, the Appellant respectfully prays that the reasons for such departure may kindly be considered in the light of the principles of judicial discipline. Further, if the Hon'ble Bench finds that a genuine conflict between decisions of coordinate Benches or any other legally sufficient circumstance warrants such a course, the Appellant respectfully requests that the matter may be considered for reference to a Special Bench in accordance with section 255(3) of the Income-tax Act, 1961. This alternative request is made solely to ensure uniformity in the interpretation of the law and consistent adjudication of the issue, without prejudice to the Appellant's primary contention that the claim deserves to be decided in accordance with the favourable judicial precedents applicable to the facts of the present case.

The Appellant craves leave to make further submissions and produce such additional documents as may be considered necessary for the proper adjudication of the appeals.”

“2. The Assessee has taken the following effective grounds of appeal :-

That the CIT(A) has wrongly allowed exemption u/s 10(10B) on account of compensation under scheme approved by Central Government amounting to Rs. 5,00,000/- in place of Rs. 30,17,000/".

The appellant was employee of Department of Telecom Services. The Government of India in its Cabinet meeting dated 23.10.2019 approved the proposals of DOT for revival of BSNL and MTNL vide its Cabinet Note dated 22.10.2019. In its Circular Dated 04.11.2019 the BSNL envisaged a Scheme for effective implementation of VRS and invitged options from employees under the scheme for seeking voluntary retirement. Reliance is also placed by the appellant upon the decision of Hon'ble Madras High Court in the case of M/S Hindustan Photo Film Workers Welfare Centre WP No. 18566 of 2015 dated 17.03.2017. Facts of this case is identical to the case of HTML-TD. Both the entitles were closed in similar situation. Therefore, the provisions of section 10(10B) of the Act are clearly attracted in the case of the appellant. 3.10 Further, the decision dated 20.09.2023 of Jurisdictional Hon'ble'ble ITAT Chandigarh A" Bench was also perused wherein several appeals of employees of HTML-TD were taken up. The Hon'ble ITAT opined in para 48 that the matter had been examined by the Hon'ble Madras High Court and thereafter has attained finality in view of dismissal of the SLP by Hon'ble Supreme Court and also added that "such matters need not be litigated any further". 3.11 Respectfully following the decision of the Jurisdictional Hon'ble ITART and for the reasons mentioned above, the A.O. is directed to allow compensation received by the appellant at the time of VRS as exempt income u/s 10(10B) of the Act. Accordingly, Ground No.1 stands Allowed."

Though in strict terms, it may not be said that the amount received by the assessee was on account of commutation of pension, however, the fact on the file is that the aforesaid amount was given by the new employer who has taken over the company from the earlier employer and he had terminated the services of the employees on account of job retrenchment. The - 17– amount was paid as a Compensation for retrenchment of services taking into consideration the length of service, basic salary, the age and other factors. In our view, the said amount is a compensation paid by the employer while terminating the services of the employee on account of 1oss of job and further subsistence, thus, the said a mount was just a capital receipt in the hands of the assessee. In fact, no part of amount received by the assessee is taxable. We, therefore, allow the appeal of the assessee and delete the disallowance and consequent additions made by the Assessing officer in this respect. We further hold that the assessee is entitled to claim refund/adjustment of the tax paid in respect of the aforesaid compensation received, if so, claimed by the assessee. Following the above decision of the Tribunal in the identical facts and circumstances, this appeal of the appellant stands allowed with identical directions. "

“10. Ground No. 5 (raised by the Assessee as additional ground) relates to exemption claimed by the Assessee in respect of Leave Encashment under Section 10(10AA) of the Act. The Assessee has contended that the Assessee should be granted exemption under Section 10(10AA) of the Act as the Assessee continues to be governed by the CCS (Pension Rules), 1972. On perusal of the judgment of the Hon'ble Kerala High Court in the case of Sanchar Nigam Pensioners' Welfare Association Vs. Union of India (WP(C) No.16360 of 2023 we find that Hon'ble High Court has held that Department of Telcom (DoT) employees absorbed in BSNL, whose pension continues to be - 18– governed under Rule 37A of the CSS (Pension) Rules, constituted a special category and are required to be treated at par with Central Government employees for the purpose of exemption under Section 10(10AA) (i) of the Act. Accordingly, we direct the Assessing Officer to grant benefit of exemption under Section 10(10AA) of the Act to the Assessee after verifying that the Assessee was an employee of DoT absorbed by BSNL. The Assessee is directed to place before the Assessing Officer the relevant details/documents and revised computation of income claiming exemption under Section 10(10AA) of the Act of the Act for the same.

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(a) an order being an intimation under sub-section (1) of section 143, where the assessee objects to the making of adjustments, or any order of assessment under sub-section (3) of section 143 or section 144, where the assessee objects to the amount of income assessed, or to the amount of tax determined, or to the amount of loss computed, or to the status under which he is assessed; (b) an order of assessment, reassessment or recomputation under section 147; (c)an order being an intimation under sub-section (1) of section 200A; (d) an order under section 201; (e) an order being an intimation under sub-section (6A) of section 206C; (f) an order under sub-section (1) of section 206CB; (g) an order imposing a penalty under Chapter XXI; and (h) an order under section 154 or section 155 amending any of the orders mentioned in clauses (a) to (g):

Provided that no appeal shall be filed before the Joint Commissioner (Appeals) if an order referred to in this sub-section is passed by or with the prior approval of, an income-tax authority above the rank of Deputy Commissioner.” Emphasis supplied

“Assessment 143. [(1) Where a return has been made under section 139, or in response to a notice under sub-section (1) of section 142, such return shall be processed in the following manner, namely:—

(a) the total income or loss shall be computed after making the following adjustments, namely:— (i) any arithmetical error in the return;

- 21– (ii) an incorrect claim, if such incorrect claim is apparent from any information in the return; (iii) disallowance of loss claimed, if return of the previous year for which set off of loss is claimed was furnished beyond the due date specified under sub-section (1) of section 139; (iv) disallowance of expenditure indicated in the audit report but not taken into account in computing the total income in the return; (v) disallowance of deduction claimed under sections 10AA, 80-IA, 80-IAB, 80-IB, 80-IC, 80-ID or section 80-IE, if the return is furnished beyond the due date specified under sub-section (1) of section 139; or (vi) addition of income appearing in Form 26AS or Form 16A or Form 16 which has not been included in computing the total income in the return:

Provided that no such adjustments shall be made unless an intimation is given to the assessee of such adjustments either in writing or in electronic mode: Provided further that the response received from the assessee, if any, shall be considered before making any adjustment, and in a case where no response is received within thirty days of the issue of such intimation, such adjustments shall be made: Provided also that no adjustment shall be made under sub- clause (vi) in relation to a return furnished for the assessment year commencing on or after the 1st day of April, 2018;”

“40. The term 'order' would refer to the reflection of a conclusion in an adjudicatory process. Such would be the meaning to be assigned for the purpose of construing whether the order could be tested by an adjudicatory hierarchy of grievance redressal. Such creation of a grievance redressal process must be by a conscious legislative mandate. Where the scheme of Section 143(1) itself would indicate that an intimation is issued after a minimal inquiry, many a time based only on records before the Authority, - 22– there cannot be imputed the process of an adjudicatory exercise preceding such intimation.

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“… Section 246 of the Act makes provision as regards appeals to the AAC. The orders passed under various sections mentioned therein have been held to be appealable, but an order regarding interest passed under section 215 of the Act does not find mention in the said section. It cannot, therefore, be disputed that the Legislature in its wisdom did not make any provision for filing an appeal against the order passed under section 215(1) of the Act. There is a reason for this. As would be obvious from the provisions of sub-section (2) of section 215 of the Act, the Legislature in its wisdom, while enacting the said sub-section, gave a mandate that where as a result of an order under section 154 or section 155 or section 250 or section 254 or section 260 or section 262 or section 264, the amount on which the interest was payable under this section has been reduced, the interest shall be reduced accordingly and the excess interest paid, if any, shall be refunded. It would thus be seen that in view of this mandate of the Legislature, it would not be necessary for any assessee to file any appeal with a view to claim the relief regarding interest paid under sub-section (1) of section 215 of the Act. In all cases covered by sub-section (3) of section 215 of the Act and, of course, the first appeal to the - 24– AAC and second appeal to the Tribunal being covered by this sub-section, even if the appellate order does not mention the, re-payment of the excess interest to the assessee, the ITO is bound to return the excess interest to the assessee in view of the mandate given in sub-section (3) of section 215 of the Act. This mandate having been given by the Legislature, it became unnecessary to make any provision for appeal as regards the re-payment of interest in this regard. In this background, it would be seen that the AAC, instead of holding that the assessee will be entitled to the return of the interest in view of the provisions of sub-section (3) of section 215 of the Act, unnecessarily recorded a finding that the appeal was not competent. This finding misled the Tribunal and the Tribunal came to the conclusion that the appeal was maintainable, which in our view is not, as it is a well-established principle of law that the right of appeal is a creature of the statute. If there is no provision for appeal made in the statute, the said right cannot be availed of. As already pointed out, no appeal has been provided against an order passed under section 215(1), under section 246 of the Act...”

The order pronounced on 30.10.2026. (NARENDRA PRASAD SINHA) JUDICIAL MEMBER Ahmedabad; Dated 30.10.2026 DS, PS - 26–

आदेश की "ितिलिप अ"ेिषत / Copy of the Order forwarded to : 1. अपीलाथ"/ The Appellant