Loading judgment…
No AI summary yet for this case.
Income Tax Appellate Tribunal, E BENCH, MUMBAI
IN THE INCOME TAX APPELLATE TRIBUNAL "E" BENCH, MUMBAI SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER The Deputy Commissioner of Income- Tax – 15(3)(1), Mumbai, Room No. 460, 4th Floor, Aayakar Bhavan, Maharishi Karve Road, Mumbai - 400020 ……………… Appellant Vs M/s Tata Projects Ltd., Transocean House, Floor 02 to 04, Hiranandani Business Park, Powai, Mumbai - 400076 [PAN: AAACT4119L] …………… Respondent
CO No. 02/MUM/2022 (Arising out of ITA No. 1165/MUM/2021) (ASSESSMENT YEAR: 2013-14) M/s Tata Projects Ltd., Transocean House, Floor 02 to 04, Hiranandani Business Park, Powai, Mumbai - 400076 [PAN: AAACT4119L] ……………… Appellant Vs The Deputy Commissioner of Income- Tax – 15(3)(1), Mumbai, Room No. 460, 4th Floor, Aayakar Bhavan, Maharishi Karve Road, Mumbai - 400020 ……………… Respondent Appearances For the Department : Shri Om Prakash Singh For the Assessee : Shri Shri Rajan Vora Shri Nikhil Tiwari
ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14
Date of conclusion of hearing : 20.04.2022 Date of pronouncement of order : 19.07.2022
O R D E R Per Rahul Chaudhary, Judicial Member: 1. The present appeal filed by the Revenue and Cross-Objection filed by the Assessee arise from the order of Commissioner of Income Tax (Appeals)-24, Mumbai [hereinafter referred to as „the CIT(A)‟], passed on 21.02.2020 for the Assessment Year 2013-14, which in turn arose from the Assessment Order, dated 28.12.2018, passed under Section 143(3) read with Section 263 of the Income Tax Act, 1961 [hereinafter referred to as „the Act‟].
The Revenue has raised three grounds of appeals all directed against the order of CIT(A) deleting the disallowance of INR 3,78,15,218/- made by the Assessing Officer under Section 43B of the Act. The Ground raised by the Revenue are as under:
“1. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the disallowance made by the AO u/s 43B on account of Sales Tax/Works Contracts tax amounting to Rs. 3,78,15,218/- which was outstanding on the date of filing of return.
Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the disallowance made by the AO u/s 43B even though the judgment of the Hon‟ble SC in the case of Chowringhee Sales Bureau Pvt. Ltd. Vs. CIT (57 ITR 552) is squarely applicable to the case of the assessee.
ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14 3. The appellant prays that the order of CIT(A) on the above ground be set-aside and that of the assessing officer be restored.”
In the Cross-Objection, the Assessee has supported the order passed by the CIT(A) on the following grounds:
“1. Erred in challenging the order of the Hon‟ble Commissioner of Income-tax (Appeals) with regards to unpaid Sales Tax/Works Contract Tax of Rs. 3,78,15,218/- on the ground that the same should be disallowed under section 43B of the Act without appreciating the fact that the same is not routed through Profit & Loss Account and thus not liable for disallowance under section 43B of the Act.
Erred in challenging the order of the Hon‟ble Commissioner of Income-tax (Appeals) without appreciating the fact that Hon‟ble Commissioner of Income-tax (Appeals) has rightly concluded that decision of the Hon‟ble Supreme Court in the case of Chowringhee Sales Bureau Private Limited vs CIT (57 ITR 552) is not applicable to the facts of the case, since in the present case even if said unpaid sales-tax/work contract is treated as trading liability there is corresponding and equivalent input tax credit available and hence no addition can be made to the total income of the Appellant.” Thus, all the grounds raised in the appeal and the Cross- Objection pertain to disallowance of INR 3,78,15,218/- made under Section 43B of the Act.
The Brief facts of the case are that the Assessee filed its return of income on 28.11.2013 which was revised on 25.03.2015. Assessment was framed on the Assessee under Section 143(3) of the Act vide Assessment Order, dated 24.02.2016. The aforesaid
ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14 assessment was set aside by the Ld. Principal Commissioner of Income Tax -2, Mumbai (hereinafter referred to as „the PCIT‟) in exercise of powers under Section 263 of the Act as the PCIT, on perusal of tax audit report of the Assessee, was of the view that the auditor had reported an amount of INR 19,98,01,069/- relating to Sales Tax/Work Contract Tax incurred during the relevant previous year was outstanding as on the date of preparation of tax audit report and the aforesaid amount had not been disallowed by the Assessee while computing total income in the return of income for the Assessment Year 2013-14. 5. In the set aside proceedings Assessment Order was passed on 28.12.2018 under Section 143(3) read with Section 263 of the Act after making, inter alia addition of INR 3,78,15,218/- under Section 43B of the Act holding the same to be the liability incurred during the relevant previous year in respect of Sales Tax/Work Contract Tax but not paid till the date of filing of return of income .
Being aggrieved, the Assessee preferred appeal before CIT(A). The CIT(A) deleted the disallowance of INR 3,78,15,218 under Section 43B of the Act accepting the contention of the Assessee that provision of Section 43B of the Act are not applicable as the aforesaid Sales Tax/Work Contract Tax liability was not routed through Profit & Loss account and therefore no deduction was claimed by the Assessee. The CIT(A), however, rejected the contention of the Assessee that since there was huge input credit available as on the date of filing the return of income there was, in effect, no outstanding liability and/or that the outstanding liability should be deemed to have been set off against the available input credit. The relevant extract of the order of CIT(A) read as under.
ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14
“5.24 However, facts of assessee's case somewhat different from the facts outlined in case Chowringhee sales bureau (supra). This is because the assessee was entitled to certain credit on input tax paid for purchase of intermediate goods. Therefore, it was eligible to set the input tax credit from the amount collected from its customers before determination of the amount that it was required to actually pay to the sales tax Department. Such a stand vindicated by judgment of the Calcutta High Court in the case of National Standard Duncan Ltd (260 ITR 97). Nor does the Assessing officer have objection to such a stand. In his assessment order he has fairly accepted the stand of the assessee and allowed the amounts so set off to be so deducted. The dispute with regard to the amount that could not set prior to the due date filing of return. The assessee argues that the same is also liable be considered to be deemed setoff since it had sufficient balance of input tax credit which could be used for such set off and it states that such a view is supported by the aforesaid judgment of the Calcutta High Court in National Standard Duncan Ltd (supra). A closer reading of the said judgment reveals that does not support such an assumption by the assessee, because it only deals with a situation whether the amount that is actually set off which will be deemed to be a payment of the same to Central Government account or not. It does not deal with reserves available with the assessee but not actually set off till the date of filing return. Be that as may, that would still not make the assessee liable to pay the Sales tax/Contract tax of Rs 3,78,15,218/- outstanding as on the due date of filing of income tax return by exclusion method because the assessee had a reserve in excess of that which could use to set off this liability. In the circumstances, it cannot be said that the assessee had appropriated any part of Government revenues and that these constituted a trading receipt in its hands because by the same logic the Assessee had already 5
ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14 made payments of such revenues in excess of such collections, when it purchased the intermediate products. Therefore no case for addition is made out against the assessee on this count also. As already discussed earlier, the various courts, including the jurisdictional High Court in the case of CIT vs Calibre Personnel Services have held that unless the Tax, duty or cess are claimed as deduction in the profit and loss account, no disallowance under section 43B can be made. Hence the invoking of explanation (2) to section 43B does not help the AO because section 43B is itself not applicable in a situation where the deduction is not claimed in the profit and loss account. In the circumstances, the addition of Rs 3,78,15,218/- is held to be unsustainable it is accordingly deleted.” (Emphasis Supplied) 7. Being aggrieved, the Revenue has filed the present appeal whereas the Assessee has supported the order passed by the CIT(A) by filing the Cross-Objection.
The Learned Authorised Representative for the Assessee appearing before us made two-fold arguments. Firstly, he submitted that the Assessee had huge input tax credit available for set-off as on the date of filing income tax return and by virtue thereof, the Assessee did not have any outstanding liability as on the date of filing return of income. In this regard, he relied upon the certificate, dated 19.09.2018, issued by Chartered Accountant placed at 56 and 57 of the paper-book. The Learned Authorised Representative for the Appellant submitted that adjustment/set off, by legal fiction, is deemed to be actual payment of tax liability. Therefore, existence of sufficient input tax credit for setting off the outstanding Sales Tax/Works Contract Tax liability as on the date of filing of income tax return should be treated as payment in terms of Section 43B of the Act. Secondly, without prejudice to the ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14 aforesaid, the Learned Authorised Representative for the assessee submitted that the amount of Sales Tax/Works Contract Tax liability was not routed through the Profit & Loss Account by the Assessee. Since, no deduction has been claimed by the Assessee in respect of the Sales Tax/Works Contract Tax liability, the question of disallowance under Section 43B of the Act does not arise. To support this contention, the Learned Authorised Representative for the Assessee relied upon the reasons for insertion of section 43B of the Act as explained in the memorandum of Finance Bill 1983, judgment of Hon‟ble Delhi High Court in the case of CIT Vs. Noble and Hewitt (I) (P.) Ltd. [2008] 305 ITR 324,, and the judgments of the Hon‟ble Bombay High Court in the case of CIT vs Calibre Personnel Services Pvt. Ltd. (ITA No. 158 of 2013, dated 02.02.2015) and CIT Vs Knight Frank India Pvt. Ltd. (143 ITR 32).
Per Contra, the Learned Departmental Representative relied upon Paragraph 4.3 the Assessment Order the relevant extract of which reads as under:
“4.3. On perusal of tax audit report in Form 3CD under Annexure 10, the auditor…………………….. On perusal of details filed by the assessee company it is, noticed that the company does not substantiate the amount of Rs 3,78,15,218 shown as outstanding liability under section 43B with respect to sales tax/ work contract tax liability outstanding on the date of filing the Return of Income. The explanation (2) to sec. 43B provides that "for the purpose of clause (a), as in force at all material times, 'any sum payable' means a sum for which the assessee incurred liability in the previous year though such sum might not have been payable within that year under the relevant law. This explanation envisages the situation where the ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14 assessee has incurred a liability but the same was not payable within that year, as contended by the assessee. The assessee has contended that as the related income of this service tax shown as liability was not received, hence the service tax was not payable to the Govt. This contention is nullified by this explanation which clearly provides that even though the same was not payable under the relevant law but as the assessee has incurred the liability the same will be covered by the provisions of sec. 43B of the IT Act The assessee‟s case is clearly covered by this explanation, hence provisions of sec 43B are invoked and a sum of Rs.3,78,15,218/- being the service tax/work contract liability 10t paid on or before the due date of filing of return of income u/s 139(1) of the IT Act is disallowed and added to the total income of the assessee. Penalty proceedings initiated u/s 271(1) of the IT Act separately for furnishing inaccurate particulars of income leading to concealment of income.
Further the assessee company without prejudice argued that the company has not claimed service tax/work contract tax in the P&L account and therefore these are not claimed as expenses and accordingly the provisions of section 43B are not applicable in the assessee case. The argument made by the assessee company is not correct in view of the decision of Hon'ble Supreme Court in the case of Chowrangee sales bureau that sales tax is part of the turnover of the assessee Even if accounts are made on exclusion method, sales tax will be treated as part of turnover and even if sales tax is not debited in the P&L account, it is deemed to have been claimed in exclusion method. Considering this, even if appellant has not included service tax as part of revenue and not claimed these taxes in P&L account, these are deemed to be included in revenue and deemed to have been claimed in P&L account. Accordingly, if statutory liability is not paid till the due date
ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14 of filing return of income, the provisions of section 43B is clearly applicable. Accordingly the disallowance made by the undersigned in the above paragraph under sect 43B is confirmed.” (Emphasis Supplied)
The Learned Departmental Representative further submitted that the Assessee has not made payment to discharge the outstanding Sales Tax/Works Contract Tax liability before the due date of filing the return of income either by way of payment or by set off and therefore, the Assessing Officer was justified in making disallowance under Section 43B of the Act. This has also been confirmed by the CIT(A) in paragraph 5.2.4 of the order impugned. He further submitted that the Assessing Officer has correctly noted that even if accounts are made by following the exclusion method, the outstanding liability towards Sales Tax/Works Contract Tax shall be treated as part of the turnover even if the same is not debited to the Profit & Loss Account. It would be deemed that the aforesaid tax liability has been included in the turnover and deduction in respect of the same has been claimed by the Assessee. Since the Assessee has not paid the aforesaid statutory liability till the date of filing return of income, the provisions of Section 43B of the Act would be attracted.
We have given thoughtful consideration to the rival submissions, have perused the material on record and considered the judicial precedents cited before us.
Cross Objection No.2
We would first take up Cross Objection No. 2 raised by the Assessee. We note that in paragraph 1.17 of letter, dated
ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14 05.12.2019, filed before CIT(A) it was contended on behalf of the Assessee that as against the outstanding liability of INR 3,78,15,218/- as on the date of filing the return of income, the Assessee had available input tax credit of INR 32,88,84,619/- which would be utilised for discharging the aforesaid liability, and therefore, the question of making disallowance under Section 43B of the Act did not arise. At page 149 of the paper-book, the Assessee had placed on record a certificate, dated 30.09.2019, issued by a Chartered Accountant stating that the Sales Tax/Works Contract Tax liability outstanding as on the date of filing of the income tax return was set off against input tax credit available. During the course of hearing, in response to a query from the Bench, the learned Authorised Representative for the Appellant clarified that the aforesaid set-off was made after the filing of the return of income. From the aforesaid, it is clear that the Assessee had outstanding Sales Tax/Works Contract Tax liability of INR 3,78,15,218/- as on the date of filing return of income which was neither paid nor set off against available input tax credit. The contention advanced on behalf of the Assessee is that since there was huge input tax credit available as on the date of filing return of income, the outstanding Sales Tax/Works Contract Tax liability can be deemed to have been set off against such available input tax credit and therefore, the question of making disallowance under Section 43B of the Act does not arise. We do not find any merit in the aforesaid contention and are of the view that the authorities below were justified in rejecting the contention of the Assessee. In paragraph 5.2.4 of the order, the CIT(A) has rightly observed that the judgments relied upon by the Assessee do not support the contention that mere availability of unutilized tax credit would be deemed to be payment even in absence of actual
ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14 set off of the outstanding liability with the available tax credit. In our considered view, the provisions of section 43B would not be attracted in case there is actual payment or actual set off (which would be deemed to be payment). Mere availability of unutilized tax credit cannot be deemed to be payment and/or lead to a conclusion that there existed no outstanding Sales Tax/Works Contract tax liability as on the date of filing return of income. Accordingly, Cross Objection No.2 raised by the Assessee is dismissed.
Ground No. 1 & 2 of Appeal along with Cross Objection No. 1
Now we would take up Ground No. 1 & 2 of the Department appeal along with Cross objection No. 1 raised by the Assessee. Relying upon the reasons for insertion of Section 43B as explained in the Memorandum of Finance Act 1983, the Learned Authorised Representative for Assessee submitted that the provisions of Section 43B of the Act are triggered only when deduction is claimed by the taxpayer. Since in the present case the Sales Tax/Works Contract Tax liability was not routed through the Profit & Loss Account, the Assessee had not claimed deduction for the same and therefore, the question of disallowance by invoking provisions of Section 43B of the Act did not arise. Whereas, the stand of the Revenue is that even if the Assessee has, following the exclusion method, not included Sales Tax/Works Contract Tax liability in the gross turnover and had not debited the same to the Profit & Loss Account, the Assessee would be deemed to have (a) included the Sales Tax/Works Contract Tax in the gross turnover and (b) claimed deduction for the same. Accordingly, the contention of the Assessee that no deduction has been claimed by the Assessee is not correct. Further, since the Assessee has not 11
ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14 made payment towards the outstanding Sales Tax/Works Contract Tax liability, the Assessing Officer was justified in making disallowance of INR 3,78,15,218/- under Section 43B of the Act.
We note that the Learned Authorised Representative for the Assessee has relied upon judgments of the Hon‟ble High Courts to support his contentions. In the case of Noble and Hewitt (I) (P.) Ltd (supra), the Hon‟ble Delhi High Court had held as under:
“6. In our opinion, since the assessee did not debit the amount to the Profit and Loss Account as an expenditure nor did the assessee claim any deduction in respect of the amount and considering that the assessee is following Mercantile system of accounting, the question of disallowing the deduction not claim would not arise.”
The above decision of the Hon‟ble Delhi High Court turned on the fact that the assessee, in that case, had not claimed any deduction in respect of the amount. The Hon‟ble Bombay High Court, in the case of CIT Vs. M/s Calibre Personnel Services Private Limited: [Income Tax Appeal No. 158 & 160 of 2013, dated 02.02.2015], concurring with the aforesaid judgment of the Hon‟ble Delhi High Court concluded that the provisions of Section 43B of the Act are not attracted in absence of an assessee claiming any deduction. The relevant observations of the Hon‟ble Bombay High Court are as under:
“4. The respondent-assessee filed its return of income…………. The respondent-assessee pointed out that the amount of service tax payable is not taken to the profit and loss account and but credited directly to the Service Tax Payable under the head Current Liabilities in the Balance Sheet. This was as per the guidelines issued
ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14 by Institute of Chartered Accountants of India. Further it was also pointed out that in the absence of Respondent claiming any deduction on account of the unpaid service tax to arrive at its income the question of application of section 43B would not arise. The assessing officer did not accepted contention and added service tax payable of ₹ 1.34 crores to the income of the Respondent “ Thus, the key finding on which the above decisions were concluded in the favour of the Assessee was that no deduction was claimed by the assessee.
We are in agreement with the Ld. Authorised Representative for the Assessee that there can be no disallowance under Section 43B of the Act in absence of any deduction having been claimed by the Assessee in the first place as has been held by the Hon‟ble High Courts. However, the issue that arises for consideration, in the facts and circumstances of the present case, is whether the Assessee has claimed any deduction in respect of Sales Tax/Work Contract Tax liability. According to the Assessing Officer the answer is in affirmative as per paragraph 4.3 of the Assessment Order (relevant extract reproduced in paragraph 9 above). Whereas, the submissions of the Ld. Authorised Representative for the Appellant is that the Sales Tax/Work Contract Tax liability has not been routed through Profit & Loss account as the Assessee had followed exclusion method meaning thereby the Sales Tax/Work Contract Tax liability was not included in the sales, purchases, and inventories (opening, closing & Work-in-progress) to arrive at profits of the business. According to us, after the introduction of Section 145A of the Act, the Assessee did not have an option to follow exclusion method and was mandated to follow inclusion method. It is for this reason that the Tax Auditor is required to and ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14 has in the case of the Assessee reported in Clause 12(b) of the tax audit report in Form 3CD about the deviation from the provisions of Section 145A of the Act as under:
“There are no deviations from the method of valuation prescribed under Section 45A of the Income Tax Act, 1961 other than the following:
(i) Sales are recognized net of sales tax/service tax (ii) Purchases and Inventories are recognized for net of Central Value added tax.
The effect of the above deviations, computed in the manner prescribed by the Guidance note on Tax audit under Section 44AB of the Income Tax Act, 1961, issued by the Institute of Chartered Accountants of India, would have no impact on the profit before taxation. Please refer Annexure 2A attached. Annexure 2A Clause 12(b) of Form 3CD
Statement showing details of deviations from the method of valuation prescribed under section 145A and the effect thereof on the Profit or Loss Impact on Profit and Loss SNo. Particulars Increase in Decrease in Profit Profit 1 Increase in cost of - 52,117,546 opening stock of raw materials, work in process etc. on inclusion of excise duty on which MODVAT/ CENVAT credit is available/availed. 2 Increase in purchase - 313,135,446 cost of raw material on inclusion of excise duty on which MODVAT/ 14
ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14 CENVAT/ VAT credit is available/availed 3 Increase in closing 38,901,136 - stock of raw material, Work in process etc., on inclusion of excise duty & VAT 4 Accounting of MODVAT/ 326,351,856 - CENVAT/ VAT credit availed and utilized on raw material consumed 5 Increase in sale of 58,749,475 - finished goods on inclusion of sales tax, excise duty etc. 6 Sales tax & excise duty - paid on sale of finished 58,749,475 goods as a result of its inclusion in sales. Total 424,002,467 424,002,467
Net effect on Statement of Profit and Loss NIL
Note: MODVAT/CENVAT on closing stocks has been ascertained by applying the percentage of Modvat/Cenvat availed during the year 2012-13 to purchases made during 2012-13.”
From the above, it is clear that the increase in profits on account of inclusion of taxes/duties in closing stock and sales has been set off against the decrease in profits arising on account of increase of cost of opening stock, work-in–progress and purchase material. Thus, in effect, deduction has been claimed by the Assessee in respect of the tax liability incurred during the relevant previous year even though the same has not been routed through the Profit & Loss Account. We note that as per the statement showing details of variation from the method of valuation prescribed under Section 145A of the Act and the effect thereof on the profits of the ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14 Assessee prepared by the tax auditor, there is no effect on the profits from business. However, as per the provisions of Section 29 of the Act income under the head „profits and gains of business‟ would have to be computed as per the provisions of Section 30 to 43D of the Act. A co-joint reading of Sections 145A and Section 43B of the Act would show that as per Section 145A of the Act the business profits are firstly required to be mandatorily computed by following the 'Inclusive method', by loading the amount of tax or duty etc. on purchase, sale and inventories and thereafter, if some part of tax or duty is unpaid, that should be added back in the computation of income as per Section 43B of the Act to arrive at income chargeable under the head „profits and gains of business‟. Accordingly, we hold that the provisions of Section 43B of the Act would be attracted in the facts of the present case even though the Assessee has not routed the Sales Tax/Works Contract Tax liability through Profit & Loss Account. In view of the aforesaid, we set aside the order passed by the CIT(A) on this issue, and direct the Assessing Officer to disallow under Section 43B of the Act the quantum of the outstanding Sales Tax/Works Contract Tax liability of INR 3,78,15,218/- to the extent the same is included in the statement showing details of deviations from the method of valuation prescribed under section 145A of the Act by the tax auditor as per Clause 12(b) of tax audit report in Form 3CD. Accordingly, Ground No. 1 and 2 raised by the Revenue in appeal are allowed whereas Cross Objection No.1 of the Assessee is dismissed.
In result, appeal filed by the Revenue (ITA No. 1165/Mum/2021) is allowed and the cross objection filed by the Assessee (Co No. 02/Mum/2022) is dismissed.
ITA. No. 1165/Mum/2021 & CO No.02/Mum/2022 Assessment Year: 2013-14
Order pronounced on 19.07.2022. (Shamim Yahya) Judicial Member
म ुंबई Mumbai; दिन ुंक Dated : 19.07.2022 Alindra, PS
आदेश की प्रतितिति अग्रेतिि/Copy of the Order forwarded to : 1. अपील र्थी / The Appellant 2. प्रत्यर्थी / The Respondent. 3. आयकर आय क्त(अपील) / The CIT(A)- 4. आयकर आय क्त / CIT 5. दिभ गीय प्रदिदनदि, आयकर अपीलीय अदिकरण, म ुंबई / DR, ITAT, Mumbai 6. ग र्ड फ ईल / Guard file.
आिेश न स र/ BY ORDER, सत्य दपि प्रदि //// उप/सह यक पुंजीक र /(Dy./Asstt.