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Income Tax Appellate Tribunal, PUNE BENCH “B”, PUNE
Before: SHRI ANIL CHATURVEDI, AM & SHRI PARTHA SARATHI CHAUDHURY, JM
आदेश / ORDER PER ANIL CHATURVEDI, AM :
This appeal filed by the assessee is emanating out of the order of Commissioner of Income Tax (A) – 2, Pune dated 25.10.2015 for the assessment year 2012-13.
The relevant facts as culled out from the material on record are as under :-
Assessee is a Co-operative Bank registered under the Maharashtra State Co-operative Societies Act and Banking Regulation Act with the R.B.I. Act. The assessee filed its return of income for A.Y.
2012-13 on 28.09.2012 declaring total income of Rs.4,30,43,859/-.
The case was selected for scrutiny and thereafter assessment was
framed u/s 143(3) of the Act vide order dated 12.02.2015 and the total
income was determined at Rs.5,29,79,140/-. Aggrieved by the order of
AO, assessee carried the matter before Ld.CIT(A), who vide order dated
25.10.2015 (in appeal No.PN/CIT(A)-2/DCIT Cir.5/PN/605/2014-15)
granted partial relief to the assessee. Aggrieved by the order of
Ld.CIT(A), assessee is now in appeal before us and has raised the
following grounds :
“1. The learned CIT(A)-2, Pune erred in law and on facts in upholding the disallowance of Rs.35,22,475/- (being 7.50% of the total income) u/s 36(1)(viia) of the ITA, 1961 made by learned DCIT, Circle 5, Pune (hereinafter referred to as the learned AO).
The learned CIT(A)-2 and the learned AO erred in law and on facts in holding that, provision of section 36(1)(viia) of the ITA, 1961 is applicable only if advances are made by rural branches of a Bank. Learned CIT(A)-2 ought to have appreciated the fact that there are two components of deduction u/s 36(1)(viia) of the ITA, 1961.”
Both the grounds being inter-connected are considered together.
During the course of assessment proceedings AO noticed that
assessee had claimed deduction of Rs.35,22,475/- u/s 36(1)(viia) of
the Act. AO noticed that assessee was not having any rural advances
and hence, the assessee was not eligible for deduction u/s 36(1)(viia) of
the Act. He after relying on the decision of Hon’ble Apex Court in the
case of Catholic Syrian Bank Ltd., Vs. CIT reported in 343 ITR 270
(SC) held that the claim of deduction u/s 36(1)(viia) of the Act cannot
be allowed to assessee and accordingly denied the claim. Aggrieved by
the order of AO, assessee carried the matter before Ld.CIT(A), who
upheld the order of AO.
Aggrieved by the order of Ld.CIT(A), assessee is now before us.
Before us, Ld.A.R. at the outset submitted that the issue is
covered in assessee’s favour by the decision of Tribunal in assessee’s
own case for A.Y. 2013-14 in ITA No.1600/PUN/2017 vide order dated
20.08.2019 as identical issue was decided by the ITAT in A.Y. 2013-
She pointed to the similarities on the ground raised in A.Y. 2013-
14 and the findings of the Tribunal on the issue. She submitted that
since the facts of the case in the year under consideration are identical
to that of A.Y. 2013-14, therefore following the order of Tribunal for
A.Y. 2013-14 in assessee’s own case, the claim of the assessee be
allowed.
Ld. D.R. on the other hand plaing reliance on the decision in the
case of Catholic Syrian Bank Ltd., Vs. CIT (supra) and CBDT Circular
No.464 dated 18.07.1986 submitted that AO was fully justified in
denying the claim of deduction.
Ld.A.R. in the rejoinder submitted that while deciding the issue
in A.Y. 2013-14, the Co-ordinate Bench of the Tribunal had followed
the decision of Tribunal in the case of Bhagini Nivedita Sahakari Bank
Ltd., Vs. DCIT reported in 100 taxmann.co 375 (Pune-Trib) wherein
the decision rendered by the Hon’ble Apex Court in the case of
Catholic Syrian Bank Ltd., (supra) and the CBDT Circular No.464
dated 18.07.1986 was also considered.
We have heard the rival submissions and perused the material
on record. The issue in the present case is with respect to denial of
claim of deduction u/s 36(1)(viia) of the Act. We find that identical
issue arose in assessee’s own case for A.Y. 2013-14 and the Co-
ordinate Bench of the Tribunal by following the decision of the
Tribunal in the case of Bhagini Nivedita Sahakari Bank Ltd., (supra)
had decided the issue in assessee’s favour by observing as under :
We find that similar issue of claim of deduction u/s. 36(1)(viia) of the Act in the absence of any rural branches, arose before the Tribunal in Bhagini Nivedita Sahakari Bank Ltd. Vs. Deputy Commissioner of Income Tax (supra) and relying on the decision of Hon’ble Kerala High Court in the case of The Kodungallur Town Co-Op. Bank Ltd. Vs. ACIT in ITA No. 37 of 2013 vide judgment dated 03.04.2014 and the amended provisions of the Act, the issue was considered and the assessee was held to be entitled to the aforesaid claim of deduction u/s. 36(1)(viia) of the Act. The findings of Tribunal are in para 14 to 27, which reads as under :
“14. We have heard the rival contentions and perused the record. The issue which arises in the present appeal is against claim of deduction under section 36(1)(viia) of the Act. Under the said section, deduction is allowable on account of provision for bad and doubtful debts. In other words, deduction could be claimed in respect of bad and doubtful debts subject to the terms and conditions which are provided in the Act itself. Explanation to section 36 of the Act defines the terms used in sub-clause (a) of clause (vii), wherein it was defined as non-scheduled banks, rural branches, co-operative banks and scheduled banks. The assessee before us is a co-operative bank. In the initial years, co- operative banks were entitled to the benefit of deduction under section 80P of the Act. However, the said deduction has been withdrawn by the Finance Act, 2007 w.e.f. 01.04.2007. Thereafter, the Legislature has extended the benefit of section 36(1)(viia) of the Act to co-operative banks also. Initially, only scheduled banks were entitled to the aforesaid deduction but w.e.f. 01.04.2007, the benefit has been extended to co-operative banks and they are entitled to claim the deduction on account of provision for bad and doubtful debts, subject to the condition that provision to that extent is made in the books of account. Sub- clause (a) refers to deduction of an amount not exceeding 7.5% of total income, before allowing any deduction under the Chapter VI- A and secondly, it also refers to a deduction of an amount not exceeding 10% of aggregate average advances made by rural branches of such banks, which have been computed in prescribed manner.
The CBDT vide Circular No.464, dated 18.07.1986 had clarified the position for bad and doubtful debts made by the banks that under the existing provisions inserted by Finance Act, 1979 provision for bad and doubtful debts made by scheduled or non-scheduled Indian bank was allowed as deduction within prescribed limits. The limit prescribed at the relevant time was 10% of total income or 2% of aggregate average advances made by the rural branches of such banks, whichever was higher. There was representation to the Government that foreign banks were not entitled to any such deduction and further it was also felt that existing ceiling at the relevant time, should be modified. Accordingly, by Amending Act, the deduction presently available under section 36(1)(vii) of the Act was split into two separate provisions. One of these limbs was the deduction to an amount not exceeding 2% of aggregate average advances made to by rural branches of the bank concerned; in this regard, it was clarified that foreign banks do not have rural branches, hence
this amendment would not be relevant in the case of foreign banks. The Circular further provided that the other provisions secure that a further deduction shall be allowed in respect of provision for bad and doubtful debts made by all banks, not just the banks incorporated in India, limited to 5% of total income. The Circular then concluded by saying that this will imply that all scheduled or non-scheduled banks having rural branches would be allowed the deduction upto 2 percent of the aggregate average advances made by such branches and a further deduction upto 5 percent of their total income in respect of provision for bad and doubtful debts. In other words, the Circular very clearly provided that two types of deductions have to be allowed to scheduled or nonscheduled banks i.e. in case they had rural branches, then deduction of 2% of aggregate average advances was to be allowed and in addition to that deduction upto 5% of their total income in respect of provision for bad and doubtful debts was to be allowed. The second part of deduction was also made available to foreign banks, which admittedly would never have rural branches in India. In such scenario, the intent of the Legislature was to provide deduction to the scheduled or non- scheduled banks; first on account of rural advances and second on account of total income other than the rural advances and two different types of deductions were provided. It may be clarified herein itself that the Circular which is dated 18.07.1986 was in respect of scheduled or non-scheduled banks and extending to the foreign banks but the Co-operative banks were not included at that relevant point for the aforesaid deduction. It was only w.e.f. 01.04.12007, amendment was made to section 36(1)(viia) of the Act in respect of any provision for bad and doubtful debts. It was provided that scheduled banks or non-scheduled banks, all Co-operative banks other than primary agricultural credit society or primary co-operative agricultural and rural development banks, deduction was allowable to the extent of an amount not exceeding 7.5% of total income computed before making any deduction under Chapter VI-A and an amount not exceeding 10% of aggregate average advances made by rural branches of such banks, computed in the prescribed manner. The scope of said section has thus been enlarged w.e.f. 01.04.2007 and deduction is available not only to the scheduled or non- scheduled banks but to the Co-operative banks also i.e. the assessee before us.
The issue which arises before us is in relation to co-operative banks which do not have any rural branches. The question which is to be addressed is whether in the absence of any rural branches, can the benefit of deduction be allowed under section 36(1)(viia) of the Act and that also to the extent of 7.5% of total income.
We find that this issue has been elaborately considered and addressed by the Hon’ble High Court of Kerala in The Kodungallur Town Co-Op. Bank Ltd. Vs. ACIT (supra) and it has been held as under:-
“9. Admittedly, appellants/assessees are cooperative banks. With introduction of Finance Act of 2007, coming into effect from 01.04.2007, one has to understand what was the position prior to 1.4.2007 and after 1.4.2007. During the relevant assessment year, admittedly the appellants/assessees were not entitled for any deduction provided under section 80P of the Act. Prior to 1.4.2007,
they were enjoying the benefits provided under section 80P. With the introduction of Finance Act 2007 with effect from 1.4.2007, they could claim deductions as provided under section 36(1) of the Act. We are concerned with subclause(a) of clause (viia) to section36(1). Prior to Finance Act of 2007, cooperative bank was not included in sub-clause (a) so far as provisions for bad and doubtful debts. With effect from 1.4.2007, cooperative bank was included under sub clause (a) of clause (viia) of section 36(1). It is further clarified that only such cooperative bank other than a primary agriculture credit society, etc., is included in sub clause (a) of clause (viia). The provision is a beneficial one. No doubt, plain reading of main section 36(1) (viia)(a) and Explanation under said section present certain difficulties, but situation is not without possibilities. The object and intention of the legislature is to be understood by harmonious construction of the provisions. The policy was to include cooperative banks as well, as they could not take shelter under section 80P of the Income Tax Act any more. By restricting the scope of the provisions, the very purpose of inclusion of cooperative bank would be lost. Sub clause (a) consists of two types of deduction. One refers to deduction of an amount not exceeding 7.5% of the total income (computed before making any deduction under this clause and chapter VIA). Section one refers to deduction of an amount not exceeding10% of the aggregate average advances made by rule branches of such bank while computing in the prescribed manner. So far as benefit of 7.5% of the total income, there is no condition that it should be in respect of any rural branch. All types of banks described under sub claque (a) of clause (viia) are entitled to seek deduction of an amount of exceeding 7.5% of the total income. Only condition is there should be a provision for bad and doubtful debts……..
10….
11….
…..So far as sub-clause (a) of clause (viia) to Section 36(1), two types of deductions are provided to non- scheduled bank, a scheduled bank and a co-operative bank other than a primary agricultural society, etc. It is to be noted that appellants/assessees are not primary agricultural credit co-operative society or other kind of bank so as to go out of the definition of co-operative bank under sub-clause (a) to clause (viia) of Section 36(1). No doubt, Explanation (ia) to Section 36(1)(viia) defines what is a rural branch. It is with reference to a place and certain number of population. It refers to branch of a scheduled bank or a nonscheduled bank. Apparently, we do not find the term co-operative bank. Section 5(cci) of Banking Regulation Act though has brought in definition of co- operative bank, virtually every bank which is not a scheduled bank would fall under the definition of non- scheduled bank. Reading of definition of non-schedule bank along with meaning of rural branch under Explanation to Section 36(1) of the Act, clearly indicate that co-operative bank also falls under the category of non- schedule bank for the purpose of this Section. Therefore,
reading of entire Section 36(1)(viia)(a) along with explanation would mean two kinds of deductions referred to in the section will be allowed to all those banks only if they satisfy the terms and conditions referred to in the provision.
Therefore, we are of the opinion, authorities below were justified in opining that benefit of deduction of 10% of the aggregate average advances is applicable to co- operative bank also provided their rural branches have advanced such amounts. Such rural branch means a branch as explained under Explanation (ia), as opined in the decision of Lord Krishna Bank’s case (supra).”
(underline provided by us for emphasis)
The Hon’ble High Court of Kerala thus, laid down the proposition that existing co-operative banks which do not enjoy the benefit of deduction provided under section 80P of the Act after 01.04.2007 but would be entitled to the benefit provided under section 36(1)(viia) of the Act, then the provisions have to be understood taking into consideration the amendment made by the Legislature. The Hon’ble High Court has clearly noted the fact that for availing the benefit of 7.5% of total income, there is no condition that it should be in respect of any rural branches. It has further observed that all types of banks described under sub-clause (a) of clause (viia) are entitled to seek deduction of an amount not exceeding 7.5% of total income and only condition is that there should be provision for bad and doubtful debts in the books of account. The second linked issue which was considered was whether co-operative bank in respect of having rural branches was entitled to have the benefit of second part of section 36(1)(viia)(a) of the Act. The Hon’ble High Court clearly held that reading the definition of non-scheduled bank along with meaning of rural branch under Explanation to section 36(1) of the Act clearly indicate that cooperative bank also falls under the category of non-scheduled bank for the purpose of said section. It further goes on to hold that reading the entire section along with Explanation would mean two kinds of deductions referred to in section would be allowed to all those banks only if they satisfy the terms and conditions referred to in the provision. Since the assessee bank in the said case did not have any rural branches, it was held that the benefit of deduction of 10% of aggregate average advances was not available to them. Hence, appeal of Revenue was decided in their favour i.e. on the second issue of deduction in respect of rural branches.
The Cochin Bench of Tribunal in a subsequent decision relating to assessment year 2010-11 in the case of Kodungallur Town Co-Op. Bank Ltd. Vs. ACIT (supra) again decided the aforesaid issue of claim of deduction under section 36(1)(vii) of the Act, especially in view of the ratio laid down by the Hon'ble Supreme Court in Catholic Syrian Bank Ltd. Vs. CIT (supra) relied upon by the Commissioner while invoking revisionary jurisdiction under section 263 of the Act. The Tribunal held that the Hon'ble Supreme Court had considered the issue whether the deduction was allowable to scheduled banks under section 36(1)(vii) of the Act in respect of bad debts written off and had held that the same shall be limited to the extent the said debts credit balance in the provision for bad and doubtful debts account made under clause (viia). It was further observed by the Tribunal that the assessments in the said case related to assessment year 2002-03 and prior years and the Apex Court had considered the law with reference to the fact situation; whereas the assessee before them was co-operative bank, which was included in the category of beneficiaries under clause (viia) by the
Finance Act, 2007 w.e.f. 01.04.2007. The Tribunal further goes on to hold that the deduction provided in the first part of clause (viia)(a) of 7.5% of total income, either to enjoyed by the assessee since inclusion of co-operative banks within ambit of clause (viia)(a) by the Finance Act, 2007 is unconcerned with the advances made by rural branches of banks. Further, referring to para 27 of the judgment of Apex Court, the Tribunal held as under:-
“7…..The deduction provided in the first part of clause (viia)(a) of 7.5% of the total income, hitherto enjoyed by the assessee since the inclusion of cooperative banks within the ambit of clause (viia)(a) by Finance Act, 2007, is unconcerned with advances made by the rural branches of the banks. A reading of paragraph 27 of the judgment of the Hon’ble Apex Court would show that while making the observation "indisputably, clause (viia)(a) applies only to rural advances”, the Hon’ble Apex Court was examining the issue if there would be double deduction of actual bad debts written off under clause (vii) and deduction in respect of rural advances provided under the second part of clause (viia). The Hon’ble Apex Court has not held that the first part of clause (viia) providing for deduction of 7.5% of the total income applies only to rural advances.”
(underline provided by us for emphasis)
Then, reference was made to the decision of jurisdictional High Court i.e. Hon’ble High Court of Kerala in The Kodungallur Town Co-Op. Bank Ltd. Vs. ACIT (supra), judgment dated 03.04.2014 and it was held that invoking of jurisdiction by the Commissioner was held to be not justified, relying on the ratio laid down by the Apex Court in Catholic Syrian Bank Ltd., which is dated 17.02.2012.
The Bangalore Bench of Tribunal in DCIT Vs. ING Vysya Bank Ltd. (2014) 149 ITD 611 (Bangalore) vide its order dated 25.10.2013 had held vide para 32 that the object of substitution of clause (viia) as explained in para 5 of CBDT Circular No.464, dated 18.07.1986 was to give separate deduction. The first was in respect of rural advances and second for provision for bad and doubtful debts in general.
Similar proposition has been laid down by the Hyderabad Bench of Tribunal in State Bank of Hyderabad Vs. DCIT (2015) 63 taxmann.com 322 (Hyderabad-Trib.), order dated 14.08.2015 and also by Visakhapatnam Bench of Tribunal in ACIT Vs. Chaitanya Godavari Grameena Bank (supra), judgment dated 04.05.2016).
The learned Authorized Representative for the assessee has pointed out before us that no other decision of any Hon’ble High Court, whether in favour or contrary, is available. The learned Departmental Representative for the Revenue has not pointed out any contrary decision or any decision of jurisdictional High Court on the issue. The position as settled by the Hon’ble High Court is that deduction under section 36(1)(viia) of the Act is available to non-scheduled bank i.e. co- operative bank @ 7.5% of total income or in case there are rural branches, then further deduction of 10% of aggregate average advances as per prescribed procedure.
The issue before us is similar to the issue before the Hon’ble High Court of Kerala and though the decision is by non-jurisdictional High Court but in the absence of any decision to the contrary by the jurisdictional High Court, the decision of High Court is binding upon the
Tribunal. In any case, no other decision of any High Court has been brought to our knowledge contradicting or favouring the view taken by the Hon’ble High Court of Kerala. In such circumstances, we are guided by the proposition laid down by the Hon’ble Bombay High Court in CIT Vs. Smt. Godavaridevi Saraf (supra), wherein it was held that until a contrary decision is given by any other Competent High Court, which is binding on Tribunal in the State of Bombay, it has to proceed on the footing with the law declared by the High Court, though of another State, is the final law of the land. In the facts before the Hon’ble Bombay High Court, the Tribunal had decided the issue relying on the ratio laid down by the Hon’ble High Court of Madras, which was not jurisdictional High Court. However, dismissing the appeal filed by Revenue, the Hon’ble Bombay High Court found favour with the view taken by Tribunal relying on the law declared by the Hon’ble High Court though of another State, which was final law of the land.
The Pune Bench of Tribunal in ACIT Vs. Aurangabad Holiday Resorts (P) Ltd. (supra) has referred to the aforesaid ratio laid down by the jurisdictional High Court in the case of CIT Vs. Smt. Godavaridevi Saraf (supra) and held as under:-
“11. Let us now take a look at the Hon'ble jurisdictional High Court's judgment in the case of Godavari Devi Saraf (supra). In this case, question before. Their Lordships was as follows:
“Whether, an the facts and circumstances of the case, and in view of decision in the case of A.M. Sali Maricar 90 ITR 116, the penalty imposed on the assessee under Section 140A(3) was legal?”
The specific question before. Their Lordships was whether the Tribunal, while sitting in Bombay, was justified in following the Madras High Court decision holding the relevant section as unconstitutional Hon'ble High Court concluded as follows:
“It should not be overlooked that Income Tax Act is an all India statute, and if a Tribunal in Madras has to proceed on the footing that Section 140A(3) was non existent, the order of penalty under that section cannot be imposed by any authority under the Act. Until a contrary decision is given by any other competent High Court, which is binding on the Tribunal in the State of Bombay (as it then was), it has to proceed on the footing that the law declared by the High Court, though of another State, is the final law of the land...an authority like Tribunal has to respect the law laid down by the High Court, though of a different State, so long as there is no contrary decision on that issue by any other High Court....”
The Tribunal had also referred to the decision of Hon’ble Bombay High Court in CIT Vs. Thana Electricity Supply Ltd. (1994) 206 ITR 727 (Bom), wherein the limited question was whether or not the decision of one of the High Court was binding on another High Court. The Tribunal in this regard observed as under:-
“10. In this light, and bearing in mind the fact that limited question before. Their Lordships was whether or not decision of one of the High Court's is binding on another High Court, it would appear to us that ratio decidendi in Thana Electricity Co. Ltd. (supra), is on the non binding nature of a High Court's judgment on another High Court. In any case, this Division Bench did not,
and as stated in this judgment itself, could not have differed with another Division Bench of the some strength in the case of Godavari Devi Saraf (supra). Therefore, it cannot be open to a subordinate Tribunal like us to disregard any of the judgments of the Hon'ble Bombay High Court, whether in the case of Thana Electricity Co. Ltd. (supra) or in the case of Godavari Devi Saraf. It is indeed our duty to loyally extend utmost respect and reverence to the Hon'ble High Court, and to read these two judgments by the Division Benches of equal strength of the Hon'ble jurisdiction High Court, i.e. in the case of Thana Electricity Co. Ltd. (supra) and Godavari Devi Saraf (supra), in a harmonious manner.”
Then, analyzing the two decisions of Hon’ble Bombay High Court, it was held that where two interpretations are possible; one in favour of assessee must be adopted, in turn, relying on the decision of the Hon'ble Supreme Court in CIT Vs. Vegetable Products Ltd. (supra). It was also noted that there were various other High Courts which were not in favour of view taken in CIT Vs. Smt. Godavaridevi Saraf (supra). The Tribunal decided the issue in turn, relying on the ratio laid down by the Hon’ble High Court of Gauhati in Smt. Bandana Gogoi Vs. CIT & Anr. (2007) 289 ITR 28 (Gau) in the absence of any other decision of any High Court in other State. In view of the above said position of law, we are departing from the view taken by Pune Bench of Tribunal in assessee’s own case relating to assessment year 2010-11, wherein the order is dated 29.05.2015 but decision of the Hon’ble High Court of Kerala on the issue is dated 03.04.2014 was neither relied upon nor brought to the knowledge of Tribunal and the issue was decided against assessee. The issue raised in the present appeal stands fully covered by the decision of the Hon’ble High Court of Kerala (supra) though not the jurisdictional High Court, but the only decision available on the said issue squarely binds the Tribunal and hence, applying the said ratio, we hold that the assessee is entitled to the claim of deduction under section 36(1)(viia) of the Act to the extent of 7.5% of total income. The assessee co-operative bank do not have any rural branches, hence is not entitled to the second part claim of 10% of advances made by rural branches. The deduction is allowable with a rider to satisfy the provisions of said section i.e. making a provision to that extent in the books of account. The first issue which is raised in the case of different co-operative banks stands decided in favour of assessee.”
The issue arising in the present appeal is identical to the issue before the Tribunal in Bhagini Nivedita Sahakari Bank Ltd. Vs. Deputy Commissioner of Income Tax (supra) and following the same parity of reasoning, we hold that the assessee is entitled to claim the aforesaid deduction u/s. 36(1)(viia) of the Act. Consequently, the grounds of appeal raised by assessee are thus, allowed.”
Before us, no material has been placed by Revenue to
demonstrate that the order of Tribunal in assessee’s own case for A.Y.
2013-14 (supra) has been set aside / stayed by higher Judicial
Forum. Revenue has also not pointed out any distinguishing feature
in the facts of the present case and in the case of assessee’s own case
in A.Y. 2013-14. We therefore, relying on the decision of the Tribunal
in assessee’s own case in A.Y. 2013-14 (supra) and for similar reasons
hold that assessee is entitled to claim the deduction u/s 36(1)(viia) of
the Act. Thus, the grounds of the assessee are allowed.
In the result, the appeal of assessee is allowed.
Order pronounced on 20th day of December, 2019.
Sd/- Sd/- (PARTHA SARATHI CHAUDHURY) (ANIL CHATURVEDI) �या�यक सद�य / JUDICIAL MEMBER लेखा सद�य / ACCOUNTANT MEMBER
पुणे Pune; �दनांक Dated : 20th December, 2019. Yamini
आदेश क� ��त�ल�प अ�े�षत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant 2. ��यथ� / The Respondent 3. CIT(A) – 2, Pune. . Pr.CIT-3, Pune. 4. 5. �वभागीय ��त�न�ध, आयकर अपील�य अ�धकरण, “बी” / DR, ITAT, “B” Pune; 6. गाड� फाईल / Guard file.
आदेशानुसार/ BY ORDER,स / / TRUE COPY / / व�र�ठ �नजी स�चव / Sr. Private Secretary आयकर अपील�य अ�धकरण ,पुणे / ITAT, Pune.