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Income Tax Appellate Tribunal, ‘B’ BENCH: CHENNAI
Before: SHRI MAHAVIR SINGH, HON’BLE & SHRI G. MANJUNATHA, HON’BLE
आदेश / O R D E R
PER G. MANJUNATHA, ACCOUNTANT MEMBER:
These three appeals filed by the assessee are directed against
separate, but identical orders of the Commissioner of Income Tax
(Appeals), Puducherry, dated 31.12.2018 & 04.02.2020 and pertains to
assessment years 2015-16, 2011-12 & 2012-13 respectively. Since, facts
are identical and issues are common, for the sake of convenience, these
appeals were heard together and are being disposed off, by this
consolidated order.
ITA No.369/Chny/2019 & ITA Nos.409 & 410/Chny/2020 :: 2 ::
The assessee has, more or less, raised common grounds of appeal
for both the assessment years. Therefore, for the sake of brevity, grounds
of appeal for the AY 2011-12, are re-produced as under:
The order u/s 143 r.w.s 147 of the income tax act is bad in law as the re assessment proceedings were initiated to reject the claim for deduction u/s.80P (2) (d) which is a debatable issue. 2. Learned CIT (A) has denied deduction u/s.80P in respect of interest earned form investments in co-operative banks as per the facts and circumstances of the case. 3. Learned CIT (A) has confirmed the addition made by the assessing officer of Rs.6,75,68,768/-being deduction claimed u/s.80P (2) (d) of the Income Tax Act. 3. The brief facts of the case are that the assessee is a Co-operative
Society engaged in manufacture of sugar and sale of sugar and by-
products, filed its return of income for the AY 2011-12 on 28.09.2011
declaring total income at Rs.4,93,34,048/-. The assessment has been
completed u/s.143(3) of the Act, on 28.11.2016 and determined total
income at Rs.10,68,91,391/-. The case has been, subsequently, re-opened
u/s.147 of the Act, for the reasons recorded, as per which, income
chargeable to tax has been escaped assessment on account of deduction
claimed u/s.80P(2)(d) of the Act, in respect of interest and dividend income
earned from Co-operative Banks amounting to Rs.6,75,68,767/-. The
assessment has been completed u/s.143(3) r.w.s.147 of the Act, dated
29.12.2018 and determined total income at Rs.17,44,60,158/- by making
disallowance of interest income u/s.80P(2)(d) of the Act, amounting to
Rs.6,75,68,767/- on the ground that the assessee is not entitled for
deduction u/s.80P(2)(d) of the Act, in respect of interest income received
from Co-operative Banks. The relevant findings of the AO are as under:
ITA No.369/Chny/2019 & ITA Nos.409 & 410/Chny/2020
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To summarize, the interest income earned by the co-operative society on the deposits placed with the Co-operative banks is not eligible for the deduction u/s. 80P(2)(d) in view of the following facts; Sec. 80P(2)(d) does not contain the word "Bank". Its scope is limited to only the "Co-operative societies". Further, the exemption and the deduction clauses of the Act, cannot be interpreted liberally.
The clear definition of the Co-operative societies u/s.2(19) of the Income Tax Act, 1961, does not include the word "Bank". Only exception is provided in respect of a regional rural bank to which provisions of the Regional Rural Bank Act, 1976 apply. The Co-operative Banks such as The Villupuram District Central Co-operative bank are neither "Co-operative society" nor a "Regional Rural Bank"
As per the Banking Regulation Act 1949, Section 56(c) (cciv) "primary agricultural credit society" means a co-operative society,-
(1) the primary object or principal which is to provide financial accommodation to its members for agricultural purposes or for purposes connected with agricultural activities (including marketing of crops) and
(2) The bye laws of which do not permit admission of any cooperative society as a member:
Provided that his sub-clause shall not apply to the admission of co-operative bank as member by reason of such co-operative bank subscribing to the share capital of such cooperative society out of funds provided by the State Government for the purpose.
The legislative intent is to distinguish the Co-operative banks from the Co-operative societies for the purpose of benefits u/s.80P of the IT Act.
The Co-operative Banks such as the Villupuram District Central Co-op. Bank Ltd., does not operate on the principle of mutuality with respect to the assessee.
As submitted by the assessee, the above referred interest income of Rs.6,75,68,767/- was derived from its investments in Co-operative Banks. It is pertinent to note here that vide Finance Act, 2006, deduction from income of Co-operative banks as per the provision of section 80P of the Act, has been withdrawn by way of insertion of section 80P(4) of the I. T. Act, 1961, w.e.f. 01.04.2007 differentiate a co-operative bank in comparison to co-operative society. The co-operative banks are functioning at par with the other commercial banks, which do not enjoy any tax benefit. Therefore, section 80P of the Income Tax Act, 1961, was amended by inserting a new sub section (4) so as to provide that the provisions of the said section shall not apply in relation to any cooperative bank other than a primary agricultural credit society or a primary co-operative agricultural and rural development bank.
In view of the above, it is clear that a co-operative bank is a commercial bank and does not fall under the purview of a "Co-operative Society" referred in section 80P(2)(d) of the Income Tax Act, 1961. In the present case, the assessee has earned interest income of Rs.6,75,68,767/- from such co-operative bank. In view of the above discussion, the deduction u/s. 80P(2)(d) of the Act, of Rs.6,75,68,767/- claimed by the assessee, is not allowed.
Being aggrieved by the assessment order, the assessee preferred an
appeal before the Ld.CIT(A). Before the Ld.CIT(A), the assessee contended
that interest and dividend income earned by Co-operative Society from any
other Co-operative Society is exempt from tax u/s.80P(2)(d) of the Act.
ITA No.369/Chny/2019 & ITA Nos.409 & 410/Chny/2020 :: 4 ::
The assessee had also argued that the Co-operative Society means a Co-
operative Society registered under the Co-operative Societies Act, 1912, or
under any other law for the time being in force in any state for the
registration of Co-operative Societies. The assessee is a Co-operative
Society registered under the Co-operative Societies Act, 1912, and thus, it
is entitled for deduction u/s.80P(2)(d) of the Act.
The Ld.CIT(A) after considering the relevant submissions of the
assessee and also by following the decision of the Hon’ble Karnataka High
Court in the case of Pr.CIT and Anr. V. Totgars Co-operative Sale Society,
reported in [2017] 392 ITR 74 (Karnataka), held that a Co-operative
Society is not entitled for deduction u/s.80P(2)(d) of the Act, in respect of
interest income earned from any other bank, including Co-operative Bank.
The relevant findings of the Ld.CIT(A) are as under:
3.3.1 The Hon'ble Karnataka High Court, as seen from the above order had extensively discussed the matter in depth. At para 14 of the order, the Hon'ble Court the held that the exclusion provided in section 80P(4) is enough to deny the claim of exemption u/s.80P(2)(d) of the Act. The Hon'ble Court dealt with decision of the Co-ordinate bench in the case of same assessee wherein it was earlier held that deduction u/s.80P was allowable from on the interest receipt from Co-operative Banks and had arrived at different judgment. It had also referred to a number of judgments of other Hon'ble High Courts. The Court was also of the view that decision of Hon'ble Apex Court in the case of Totgar Co-operative Sale Society Ltd vs. ITO (2010) 322 ITR 283 (SC) has binding precedent on the subject. I have not seen any subsequent judgment of any other High Court in which contrary view has been taken. I also have not seen decision of Hon'ble Jurisdictional Tribunal in favouring appellant on the subject. The case laws relied upon by the A/R are not applicable to the case of present assessee. The Hon'ble Apex Court, in the case of Commissioner of Customs (Import) vs. Dilip Kumar and Sons (Civil Appeal No 3327 of 2007, decided on 30.07.2018) had held that exemption provisions in tax laws are to be interpreted strictly. Section 80P(2)(d) provides for 100% exemption of interest and dividend receipts from other Co-operative societies. This section also has to be interpreted in the strictest of manners. Following the judgment of Hon'ble Karnataka High Court cited above, it is held that appellant's receipts from Villupuram Central District Cooperative Dank Bank is not eligible fur deduction u/s.80P(2)(d).
The Ld.AR for the assessee submitted that this issue is squarely
covered in favour of the assessee by the decision of the ITAT Chennai Bench
ITA No.369/Chny/2019 & ITA Nos.409 & 410/Chny/2020 :: 5 ::
in the case of M/s.Subramania Siva Co-operative Sugar Mills Ltd., in ITA
No.1378/Chny/2019 dated 20.02.2020, wherein, the Tribunal had
considered an identical issue and also by following the decision of the
jurisdictional High Court of Madras in the case of CIT v. Salem Agricultural
Producers’ Cooperative Marketing Society in TCA No.5/2015 dated
10.08.2016, held that the assessee is entitled for deduction u/s.80P(2)(d)
of the Act, in respect of interest income earned from deposits made with
other Co-operative Banks.
The Ld.DR, on the other hand, supporting the order of the Ld.CIT(A),
submitted that as per the provisions of Sec.80P(2)(d) of the Act, deduction
is available to a Co-operative Society in respect of interest or dividend from
its investment with any other Co-operative Society. In this case, the
assessee has earned interest income from its deposits made with a Co-
operative Bank and thus, the assessee is not entitled for deduction
u/s.80P(2)(d) of the Act. The AO and the Ld.CIT(A) have considered the
facts in right perspective of the law and denied deduction. Therefore, their
orders should be upheld.
We have heard both the parties, perused the materials available on
record and gone through orders of the authorities below. The provisions of
Sec.80P(2)(d) deals with interest or dividend income earned by Co-
operative Society from its investment with any other Co-operative Society.
As per the said Section, interest or dividend income earned by Co-operative
ITA No.369/Chny/2019 & ITA Nos.409 & 410/Chny/2020 :: 6 ::
Society from its deposits with any other Co-operative Society, then whole
amount of such interest income is deductible u/s.80P(2)(d) of the Act. The
provisions of Sec.2(19) of the Act, defines the Co-operative Society and as
per the said Section, Co-operative Society means a Co-operative Society
registered under the Co-operative Societies Act, 1912 or under any law for
the time being in force in any state for the registration of the Co-operative
Societies. In this case, there is no dispute with regard to the fact that the
assessee is registered under Co-operative Societies Act, 1912. It is also
not in dispute that the assessee has earned interest income from its
investments with Vilupuram Co-operative Bank. The AO denied deduction
u/s.80P(2)(d) of the Act, on the ground that the Co-operative Bank is not
a Co-operative Society. Otherwise, the AO never disputed the fact that the
assessee is a Co-operative Society and further, it has earned interest
income from other Co-operative Banks. Therefore, we are of the
considered view that once, it is not disputed that the assessee is a Co-
operative Society and also it has earned interest income from its
investments with other Co-operative Societies (Co-operative Bank), then,
deduction u/s.80P(2)(d) of the Act, cannot be denied, merely, for the
reason that the assessee has earned interest income from a Co-operative
Bank. In our considered view, although, the Co-operative Banks are not
entitled for deduction u/s.80P(4) of the Act, in respect of their income
derived from banking business, but there is no restriction for the assessee
to claim deduction u/s.80P(2)(d) of the Act, in respect of interest income
ITA No.369/Chny/2019 & ITA Nos.409 & 410/Chny/2020 :: 7 ::
earned from its investments with any other Co-operative Society (Co-
operative Bank) as long as the assessee is a Co-operative Society and
further, interest income earned by the assessee is from any other Co-
operative Society.
Further, this issue is squarely covered in favour of the assessee by
the decision of the ITAT Chennai Bench in the case of M/s.Subramania Siva
Co-operative Sugar Mills Ltd., in ITA No.1378/Chny/2019 dated
20.02.2020, wherein, the Tribunal had considered an identical issue and
also by following the decision of the jurisdictional High Court of Madras in
the case of CIT v. Salem Agricultural Producers’ Cooperative Marketing
Society in TCA No.5/2015 dated 10.08.2016, held that the assessee is
entitled for deduction u/s.80P(2)(d) of the Act, in respect of interest income
earned from deposits made with other Co-operative Banks. The relevant
findings of the Tribunal are as under:
We heard the rival submissions, gone through the relevant material and find merit in the submission of the Ld. AR. The fact remains that the assessee is a co-operative society. It has earned the impugned interest from Dharmapuri District Co-operative Bank Ltd., which is also a co-operative society engaged in banking business. The relevant portion of the order of the Jurisdictional High Court in the case of CIT vs Salem Agricultural Producers’ Cooperative Marketing Society in TCA No. 5/2015 dated 10.08.2016 is extracted as under: “6. Addressing the said issue, at paragraph No.8, in I.T.A.No.732/MDS/2014 dated 30/6/2014, the Tribunal has ordered as hereunder:- “The case of the assessee is that the income by way of interest and dividend earned by the assessee Society are from investments made in Salem District Central Co-operative Bank, which is also admittedly, a cooperative society and are allowable deduction. The Assessing Officer has held that the assessee has made only with Salem District Central Cooperative Bank and therefore, the income from investment with the Bank is not entitled for deduction under Section 80 P (2) (d) of the Act. On appeal, the Id.CIT (Appeals confirmed the order passed by the Id.CIT (Appeals). We find that in the case of CIT Vs. Kangra Co-operative Bank Ltd. [2009] 309 ITR 106 (HP), the Hon'ble Himachal Pradesh High Court has considered Section 80 P (2) (d) of the Act. The interest earned by the assessee co-operative bank on fixed deposits with Himachal Pradesh State Co-operative Bank in compliance with the provisions of Section 57 of the Himachal Pradesh Co-operative
ITA No.369/Chny/2019 & ITA Nos.409 & 410/Chny/2020
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Societies Act, 1968, the income derived from banking business is eligible for deduction under Section 80 P (2) (a) (i) of the Act. Exemption is also available under Section 80 P (2) (d) of the Act. In the present case, the assessee is an Agricultural Producers Co-operative Marketing Society Ltd., registered under Tamil Nadu Co-operative Societies Act and established for the benefit of the Agricultural producers and the interest or dividend earned by the assessee will be beneficial to the members alone. Therefore, keeping in view of the decision, in the case of CIT Vs. Kangra Co-operative Bank Ltd., (supra), we hold that the assessee is eligible for benefit under Section 80 P (2) (d) of the Act and also this being a beneficial section to the co-operative Societies.”
Let us consider the decision in KANGRA CO-OPERATIVE BANK LTD'S case referred to by the tribunal. The question of law framed therein is as follows:-
“Whether on the facts and circumstances of the case, the Income-tax Appellate Tribunal was right in law in holding that the interest income earned by the assessee on deposits made with H.P.State Co-operative Bank in the shape of F.D.Rs. is income derived from banking business and therefore, eligible for deduction under Section 80 P (2) (a) (i) of the Income Tax Act?”
After considering the decisions in CIT Vs. Karnataka State Co-operative Apex Bank reported in [2001] 251 ITR 194, CIT Vs. Ramanathapuram District Co-operative Central Bank Ltd reported in [2002] 255 ITR 423 (SC), a Division Bench of the Himachal Pradesh High Court, at paragraph Nos.10 and 11 held thus:-
“The Karnataka High Court in CIT Vs. Sri Ram Sahakari Bank Ltd., [2004] 266 ITR 632, held that the interest on investments and short-term fixed deposits in banks was entitled to be deducted under Section 80 P (2) (a) (i) of the Act. In fact, in CIT Vs. Nawanshahar Central Co-operative Bank Ltd., [2007] 289 ITR 6, the Apex Court has held that where under the provisions of the Co-operative Societies Act, the co-operative bank is statutorily required to place part of its funds in approved securities, the income attributable thereto is not taxable under Section 80 P (2) (a) (i) of the Income-tax Act, 1961.
In the present case, we have noted above that under Section 57, every co-operative Society including the assessee is required by law to keep a percentage of its profits in reserve funds. These reserve funds can only be invested or deposited in a certain manner. Applying the ration of the judgment in Nawanshahar Central Co-operative Bank Ltd's case [2007] 289 ITR 6, it is apparent that any interest on such investments is required to be deducted under Section 80 P (2) (a) (i) of the Act. At para 12 of the judgment, further reiterated that .... Furthermore, the investments have been made in the H.P.State Co-operative Bank which is also a cooperative Society and, therefore, even under Section 80 P (2) (d) of the Act, interest income from investments made in any co-operative Society would also be entitled for deduction.”
Though Mr.J.Narayanasamy, learned Senior Standing Counsel for Income Tax Department submitted that the Tribunal was not right in holding that the interest earned from the Salem Agricultural Producers Co-operative Marketing Society Ltd., for reduction under Section 80 P (2(a) (i) of the Income Tax Act, we are not inclined to accept the said contentions. For the reason that a District Central Co-operative Bank, is also a Society, in which event, the income by way of interest and dividend earned by the assessee/respondent Society from the investments made in Salem District Central Co-operative Bank, which is also a Co-operative Society is entitled for deduction under Section 80 P (2) (a) (i) of the Income Tax Act. Decision relied on by the assessee and considered by the Tribunal squarely applies to the facts on hand. Question of law, figuring as 4, is negatived as against the appellant.”
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From the above it is clear that the facts of this assessee is clearly falling within the four corners of the case decided by the Jurisdictional High Court, supra, and hence we allow the assessee’s appeal. The AO is directed to grant the deduction claimed by the assessee u/s. 80P(2), accordingly.
In this view of the matter and consistent with view taken by the
coordinate Bench, we are of the considered view that the assessee is
entitled for deduction u/s.80P(2)(d) of the Act, in respect of interest income
earned from its investments with Co-operative Banks and thus, we direct
the AO to delete the additions made towards disallowance of interest
income u/s.80P(2)(d) of the Act for the AYs 2011-12 & 2012-13.
ITA No.369/Chny/2019:
The grounds of appeal raised by the assessee for the AY 2015-16 are
as under:
The Learned CIT (A) has failed to note that the assessee is adopting the same method of valuation of closing stock and also failed to note that the sugar mill is covered under Government regulations and the accounts are also prepared as per government regulations as the sugar mill is a co-operative society under the control of the government as per the facts and circumstances of the case.
Learned CIT (A) has failed to note that the sale of power has to be considered for valuation of \ closing stock as the power is being generated out of Bagasse which is a by- product in the sugar industry as per the facts and circumstances of the case.
Learned CIT (A) has failed to note that interest on deposits has been considered for valuation of stock mainly on account of the reason that sugar mill is getting some loans and advances for payment to cane growers. As there will be delay in settling the sugar cane growers, instead of keeping the amount idle, the society earns some interest by depositing the same in short term deposits. Otherwise the interest burden of the society will be more and the society could have claimed the interest payment as expenses and the sugar mill is adopting the same method year after year.
Learned CIT (A) has failed to note that stock adjustment for opening and closing balances has also to be considered as the value of closing stock on the method adopted by the department for the A.Y.2014-15 is Rs.3172.56/- as per the facts and circumstances of the case.
Learned CIT (A) has failed to note that there is no revenue loss for the department on account of valuation of closing stock as one year's closing stock is the opening stock of next year and it will be automatically adjusted as per the facts and circumstances of the case.
Learned CIT (A) has failed to note Assessing officer has not mentioned anything about realizable in the assessment proceedings.
ITA No.369/Chny/2019 & ITA Nos.409 & 410/Chny/2020 :: 10 ::
Learned CIT (A) has denied deduction u/s.80P in respect of interest earned from investments in co-operative banks as per the facts and circumstances of the case. 8. Learned CIT (A) has confirmed the valuation of closing stock by the assessing officer. 9. Learned CIT (A) has confirmed the addition made by the assessing officer of Rs.2,78,91,526/-being deduction claimed u/s.80 P(2)(d) of the income tax Act.
The first issue that came up for our consideration from Ground Nos.1-
6 of the assessee’s appeal is under statement of closing stock amounting
to Rs.1,64,76,887/-. The AO has determined valuation of closing stock by
excluding ‘income from other sources’ being sale of scrap, interest on FD,
dividend and other income, by holding that those items of income are not
assessed as income from business or profession and thus, it cannot be part
of Revenue from operations to determine the value of closing stock. It was
the explanation of the assessee before the AO that it is following consistent
method of accounting for valuation of closing stock, which includes ‘income
from other sources’ being income from sale of scrap, interest on FD,
dividend and other income and thus, unless there is a change in facts, the
AO cannot change the method followed by the assessee to determine the
value of closing stock.
We have heard both the parties, perused the materials available on
record and gone through orders of the authorities below. We find that an
identical issue had been considered by the Tribunal in the assessee’s own
case for the AY 2011-12 in ITA No.1131/Mds/2015 dated 31.12.2015,
wherein, the Tribunal by considering various facts held that there is no error
ITA No.369/Chny/2019 & ITA Nos.409 & 410/Chny/2020 :: 11 ::
in the reasons given by the AO to determine the value of closing stock by
excluding ‘income from other sources’ being income from sale of scrap,
interest on FD, dividend and other income, etc., because, the above
components of income are not derived from the business of the assessee.
The relevant findings of the Tribunal are as under:
We have heard both the sides and perused the material on record. The ld. AR submitted that method of closing stock valuation of cost of production after deducting the income from the above components has been considered by the assessee for the past several years and the Department cannot disturb in the middle. In our opinion, the assessee has been following the system of accounting by deducting the income from power, scrap, interest on FD, dividend and others from the cost of production. First of all to arrive at the cost of value of closing stock, these components are not the income generated from the business activity carried on by the assessee. In other words, the income from the above components are not assessed under the head income from business and it is assessed as income from other sources. When it is assessed as income from other sources, it cannot be considered as component of cost of production for determining the value of closing stock. The ld. AR relied on the following judgments for the proposition that consistency to be followed in income-tax proceedings:
United Commercial Bank v. CIT (240 ITR 355)(SC)
CIT v. Woodward Governor India P. Ltd. (312 ITR 254)(SC)
Merck Ltd. v. DCIT (2 ITR (Trib)-OL 629 (Mumbai)
CIT v. Dhampur Sugar Mills Ltd. (360 ITR 82) (Allahabad) In our opinion, each assessment year is an independent assessment of unit and the wrong method of accounting followed by the assessee cannot be appropriated. In our opinion, the above components are not income from the business of the assessee, the same cannot be considered for the purpose of valuing the closing stock by deducting from cost of production.
In this view of the matter and consistent with view taken by the
coordinate Bench, we are of the considered view that there is no error in
the reasons given by the AO as well as the Ld.CIT(A) to sustain the
additions towards understatement of closing stock and thus, we are inclined
to uphold the findings of the Ld.CIT(A) and reject the ground taken by the
assessee.
ITA No.369/Chny/2019 & ITA Nos.409 & 410/Chny/2020 :: 12 ::
The next issue that came up for our consideration from Ground
Nos.7-9 of the assessee’s appeal is disallowance of deduction claimed
u/s.80P(2)(d) of the Act, in respect of interest income earned from its
investments with Co-operative Banks. The AO had disallowed the
deduction claimed u/s.80P(2)(d) of the Act, amounting to Rs.2,78,91,526/-
towards interest income earned from its deposits with M/s.Villupuram
District Central Co-operative Bank Ltd., on the ground that the assessee is
entitled for deduction u/s.80P(2)(d) of the Act, only in respect of interest
income from deposits with other Co-operative Societies, but not Co-
operative Banks.
We have heard both the parties, perused the materials available on
record and gone through orders of the authorities below. We find that an
identical issue had been considered by the Tribunal in the assessee’s own
case for the AYs 2011-12 & 2012-13 in ITA Nos.409 & 410/Chny/2020,
wherein, the Tribunal by following the decision of the Co-ordinate Bench,
in the case of M/s.Subramania Siva Co-operative Sugar Mills Ltd., in ITA
No.1378/Chny/2019 dated 20.02.2020, held that the assessee is entitled
for deduction u/s.80P(2)(d) of the Act, in respect of interest income earned
from deposits made with other Co-operative Banks. The facts are identical
for the year under consideration. The reasons given by us in Para Nos.8-
10 of this Order, in ITA Nos.409 & 410/Chny/2020 for the AYs 2011-12 &
2012-13, shall, mutatis mutandis, apply to this appeal, as well.
ITA No.369/Chny/2019 & ITA Nos.409 & 410/Chny/2020 :: 13 ::
Therefore, we for similar reasons direct the AO to delete additions made
u/s.80P(2)(d) of the Act, in respect of interest income from deposits with
Cp-operative Bank.
In this view of the matter and consistent with view taken by the
coordinate Bench, we are of the considered view that the assessee is
entitled for deduction u/s.80P(2)(d) of the Act, in respect of interest income
earned from its investments with Co-operative Banks and thus, we direct
the AO to delete additions towards disallowance of interest income
u/s.80P(2)(d) of the Act.
In the result, the appeals filed by the assessee in ITA
No.369/Chny2019 is partly allowed and ITA Nos.409 & 410/Chny/2020 are
allowed.
Order pronounced on the 25th day of April, 2022, in Chennai.
Sd/- Sd/- (महावीर िसंह) (जी. मंजूनाथा) (G. MANJUNATHA) (MAHAVIR SINGH) उपा�� /VICE PRESIDENT लेखा सद�य/ACCOUNTANT MEMBER
चे�ई/Chennai, �दनांक/Dated: 25th April, 2022. TLN आदेश क� �ितिलिप अ�ेिषत/Copy to: 1. अपीलाथ�/Appellant 4. आयकर आयु�/CIT 2. ��यथ�/Respondent 5. िवभागीय �ितिनिध/DR 3. आयकर आयु� (अपील)/CIT(A) 6. गाड� फाईल/GF