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Income Tax Appellate Tribunal, A BENCH, AHMEDABAD
Before: DR. BRR KUMAR & SHRI SIDDHARTHA NAUTIYAL
(Assessment Year: 2018-19) Kapadia Marketing Inc., Vs. Income Tax Officer, Basement, Landmark Apartment, Ward-5(3)(1), Opp. Kamdhenu Complex, Ahmedabad Ambawadi, Ahmedabad-380015 [PAN No.AAFFK5994G] (Appellant) .. (Respondent) Appellant by : None Respondent by: Shri B.P. Srivastava, Sr. DR 28.11.2024 Date of Hearing Date of Pronouncement 17.01.2025 O R D E R
PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER:
This appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short “Ld. CIT(A)”), National Faceless Appeal Centre (in short “NFAC”), Delhi vide order dated 23.01.2023 passed for A.Y. 2018-19.
2. The assessee has taken the following grounds of appeal:-
“1. The learned CIT(A) has in confirming the disallowance of deduction of Rs. 1,05,00,000 under Section 35(1)(ii) being the donation of Rs. 70,00,000 given to Shri Arvindo Institute of Applied Scientific Research Trust on 28-03-2018 on the ground that CBDT by its letter dated 14-122018 stated that Section 25(1)(ii) approval wa granted only upto 31-03-2006 is as much as the said Institute has furnished the different certificates from CBDT from time to time granting approval under Section 35(1)(ii) upto 31-03-2019 and that the assessee is not aware that such certificates are false certificates, if any, and therefore the donation of Rs. 70,00,000 is given to Shri Arvindo Institute of Applied Scientific Research Trust on 28-03-2018 is as per approval by CBDT to 31-03-2019 and therefore it is allowable as deduction under Section 35(1)(ii).
Kapadia Marketing Inc. vs. ITO Asst.Year –2018-19 - 2– 2. The demand of Rs. 6,09,507 is wrongly charged the under Section 115BBE”
The brief facts of the case are that during the impugned assessment year, the assessee had claimed a sum of Rs. 1,05,00,000/- as deduction under Section 35(1)(ii) of the Act, being 150% of deduction made to specified scientific research institution. On perusal of the records, the Assessing Officer observed that the assessee had claimed to have donated a sum of Rs. 70,00,000/- to Shri Arvindo Institute of Applied Science and Research Institute Trust. The Assessing Officer observed that the said trust was found to have indulged in large scale scam of issuing bogus donation received for the purpose of claiming weighted deduction under Section 35(1)(ii) of the Act and many assessee’s had benefitted by claiming such bogus donation through this scam. The CBDT had issued advisory regarding this scam and directed the concerned officers for making necessary enquiries in such cases. On the basis of these facts, the Assessing Officer denied weighted deduction of Rs. 1,05,00,000/- claimed by the assessee, with the following observations:
“3.2 To verify the genuineness of claim, Notice u/s 142(1) dated 28.12.2020 assessee was asked to furnish latest copy of letter approval/notification of the association or institution (Shri Arvindo Institute of Applied Scientific Research Trust) to whom donation given, by the prescribed authority. 3.3 In response to aforesaid notice, assessee uploaded following documents in support of their contention. (a) Notification No. 1843 E dated 4.6.2003 which is valid from 1.4.2003 to 31.3.2006. (b) Letter No. CBDT/203/107/2011-12 dated 2.7.2012 which is claimed to be valid till 31.3.2015. (c) Letter No. CBDT/203/107/2000/12 dated 14.5.2012 which is claimed that validity for above exemption is forever unless until it is withdrawn.
Kapadia Marketing Inc. vs. ITO Asst.Year –2018-19 - 3– 3.4 Under Secretary ITA.II CBDT vide letter F. No. 225/351/2018-ITA (II) dated 14.12.2018, in para 3 has communicated as under: It emerges that the above trust was earlier approved under section 35(1)(ii) of the Act which expired on 31.3.2006. Thereafter, this entity being not recognized for the purpose of section 35(1)(ii) of the Act is not eligible to raise donations for undertaking scientific research however the trust has raised substantial donations over the last six years on the basis of a forged certificate while the donors have irregularly claimed weighted deduction u/s 35(1)(ii) of the Act on donations made to the Trust. 3.5 In view of specific findings of CBDT that M/s Shri Arvindo Institute of Applied Scientific Research Trust don't have recognition from CBDT after 1.4.2006, whereas assessee has paid Rs 70,00,000 to Shri Arvindo Institute of Applied Scientific Research Trust u/s 35(1)(ii) of the IT Act and claimed weighed deduction of Rs 1,75,00,000/- during FY 2017-18 relevant to AY 2018-19 on the basis of wrong facts and documents. In view of Under Secretary ITA.II CBDT vide letter F. No. 225/351/2018-ITA (II) dated 14.12.2018, It is clear that M/s Shri Arvindo Institute of Applied Scientific Research Trust don't have recognition to accept donation u/s 35(1)(ii). Accordingly, I disallow a sum of Rs 1,05,00,000 claimed as weighted deduction and same is added back to the income of the assessee.”
4. In appeal, the Ld. CIT(A) observed that Shri Arvindo Institute of Applied Science and Research Institute did not have requisite registration under Section 35(1)(ii) of the Act and hence, the claim of weighted deduction under Section 35(1)(ii) was prima facie inadmissible. Ld. CIT(A) also observed that from the advisory issued by the CBDT, it is an undeniable fact that the said trust Shri Arvindo Institute of Applied Science and Research Institute did not any valid registration or approval required under law to receive donation from the public and therefore, the donation claimed to have been made by the assessee is not eligible for claiming weighted deduction under Section 35(1)(ii) of the Act. Thirdly, Ld. CIT(A) observed that as per information in public domain, Shri Arvindo Institute of Applied Science and Research Institute was involved in the large scam running into hundreds of crores and the trustees of the aforesaid trust were certain individuals operating out of Ahmedabad. A complaint Kapadia Marketing Inc. vs. ITO Asst.Year –2018-19 - 4– had been filed with EOW of the Police Department and some of the key persons of this trust had also been arrested. Fourthly, Ld. CIT(A) was of the view that it was not possible to accept the claim of the assessee that it was unaware about the dubious nature of the trust and the donation was made under a bona fide belief that the said trust was genuine. Ld. CIT(A) observed that as per information available on record, registration granted to the said trust was only valid up till 2006 and all approvals / registrations of trusts are published in the Official Gazette notification of the Government of India. Therefore, any genuine donor with normal prudence would have verified the basic requirement of genuineness of valid registration before making such huge deduction of Rs. 70 lakhs to such trust. Additionally, Ld. CIT(A) noted that the assessee had reported a net taxable income of Rs. 63.40 lakhs after claiming deducting weighted deduction of Rs. 1.05 crrores (the correct taxable income of the assessee, therefore, should have been Rs. 1,69,30,739/- as against a sum of Rs. 64,30,739/- as actually declared by the assessee). Therefore, even from these facts, it is evident that there is lack of genuineness in the aforesaid transaction. Accordingly, Ld. CIT(A) upheld the action of the Assessing Officer in disallowing the claim of assessee, for weighted deduction under Section 35(1)(ii) of the Act.
5. The assessee is in appeal before us against the aforesaid order passed by Ld. CIT(A), dismissing the appeal of the assessee.
6. Before us, none appeared on behalf of the assessee. Further, we observe that on multiple occasions, the assessee has sought adjournment Kapadia Marketing Inc. vs. ITO Asst.Year –2018-19 - 5– and when the case up for hearing before us, neither any application for adjournment was filed, nor any one appeared on behalf of the assessee. Accordingly, we are proceeding to decide the case on merits.
7. On going through the facts of the record of the case, we are of the considered view that Ld. CIT(A) has correctly held that the assessee was not eligible for claiming of deduction under Section 35(1)(ii) of the Act.
In the case of Deviyani Dilip Patel vs. ITO in 9MDS) of 2016, which is directly on the issue of bogus donation scam of the same trust i.e., Shri Arvindo Institute of Applied Science and Research Insitute, the ITAT Chennai denied deduction under Section 35(1)(ii) of the Act with the following observations:
“6. The next issue arises for consideration is disallowance made by the Assessing Officer under Section 35(1)(ii) of the Act.
7. Shri S. Sridhar, the Ld.counsel for the assessee, submitted that the assessee has filed an application under Rule 27 of Income-Tax (Appellate Tribunal) Rules, 1963. The Ld.counsel submitted that the assessee claimed weighted deduction under Section 35(1)(ii) of the Act before the Assessing Officer in respect of the donation made to Shri Arvindo Institute of Applied Scientific Research Trust. According to the Ld. counsel, the assessee was misrepresented by the Trust saying that the approval granted for deduction under Section 35(1)(ii) of the Act was renewed. A forged gazette notification was also said to be obtained by the Trust. According to the Ld. counsel, the Assessing Officer subsequently found that the Trust was not approved by the Government of India as scientific and industrial organization under Section 35(1)(ii) of the Act. The Assessing Officer has also found that the said Trust was not doing any research activity in the field of medical science. The Ld.counsel further submitted that the Assessing Officer had not controverted that the Trust was not approved under Section 35(1)(ii) of the Act. However, the appellate authority found that genuineness of payment cannot be questioned on the basis of the statement recorded in the absence of any material evidence. Even, in case, the Trust to whom the donation was made was not an approved Trust, still according to the Ld. counsel, it has to be allowed under Section 37(1) of the Act as business loss. According to the Ld. counsel, the assessee is a science graduate and operating in the field of medical sciences / pharmaceuticals for the last 15 years in different capacities including research / consultant, etc.
Therefore, according to the Ld. counsel, the donation made by the assessee is related to his business activity, therefore, even though the Trust was not approved or renewed, it has to be allowed under Section 37(1) of the Act while computing the taxable income. Therefore, according to the Ld. counsel, the CIT(Appeals) has rightly allowed the claim of the assessee.
8. On the contrary, Shri Sridhar Dora, the Ld. D.R. submitted that the Assessing Officer disallowed the claim of the assessee on the ground that the recipient Trust is not doing any research activity. According to the Ld. D.R., the Assessing Officer has also found on enquiry that no such Trust was functioning in the address given by the assessee. Referring to the CBDT circular dated 14th December, 2018, the Ld. D.R. found that Shri Arvindo Institute of Applied Scientific Research Trust was approved till 31.03.2006. Thereafter the said Trust was not recognized for the purpose of Section 35(1)(ii) of the Act. According to the Ld. D.R., a forged gazette notification is also available at the paper-book filed by the assessee. This forged gazette notification, according to the Ld. D.R., was produced by the assessee. Whatever it may be, according to the Ld. D.R., for the purpose of deduction under Section 35(1)(ii) of the Act, both the assessee and Trust placed their reliance on the forged document, hence, the CIT(Appeals) ought not to have allowed the claim of the assessee.
We have considered the rival submissions on either side and perused the relevant material available on record. The CIT(Appeals) proceeded on the presumption that the CBDT approval was extended upto 31st March, 2019. In fact, the CBDT clarified by notification dated 14th December, 2018 that the approval was not extended beyond 31.03.2006. It is not known from where the CIT(Appeals) found that the CBDT’s approval was extended upto 31st March, 2019. It is also not the case of the assessee that Shri Arvindo Institute of Applied Scientific Research Trust was recognized beyond 31.03.2006. The assessee claims that on the basis of forged document, the Trust misrepresented, therefore, now making an alternative claim by making application under Rule 27 of Income-Tax (Appellate Tribunal) Rules, 1963.
We have carefully gone through the circular of the CBDT dated 14.12.2018. For the purpose of convenience, we are reproducing the same as follows:- Bogus donation racket for approved research association u/s 35(1)(ii) by Shri Arvindo Institute of Applied Scientific Research Trust-CBDT Advisory F.No. 225/351/2018-ITA (II) Government of India Ministry of Finance Department of Revenue Central Board of Direct Taxes **** Room N0. 245A, North Block New Delhi, the 14th December, 2018 To All Principal Chief Commissioners of Income Tax All Director Generals of Income Tax (Investigation)
Sir/Madam Subject: Information regarding bogus donation racket under section 35(1)(ii) of Income-tax Act, 1961-reg.- Kindly refer to the subject mentioned above.
In this connection, I am directed to state that Section 35(1)(ii) of the Income- tax Act,1961 (‘Act’) prescribes a weighted deduction @ 150% (175% before 01.04.2018) to a donor for any sum paid to an approved ‘research association having as its sole object the undertaking of scientific research or to a ‘university, college or other institution’ for carrying out scientific research. Very recently, Board has received several references from the field authorities for clarifying whether a Trust namely M/s Shri Arvindo Institute of Applied Scientific Research Trust (PAN:AAFTS7349D) (Hereinafter ‘the Trust’) having offices at Mumbai & Puducherry is an entity specified by the Central Government through a Notification for purposes of section 35(l)(ii} of the Act or not. Presently, the trust is assessed with CIT(Exemption), Mumbai.
3. In this regard, upon perusal of records, it emerges that the above Trust was earlier approved under section 35(1}(ii} of the Act which expired on 31.03.2006. Thereafter, this entity, being not recognized for purpose of section 35(1)(ii) of the Act, is not eligible to raise donations for undertaking scientific research however, the Trust has raised substantial donations over the last six years on the basis of a forged certificate while the donors have irregularly claimed weighted deduction u/s. 35(1)(ii) of the Act on donations made to the Trust.
In view of above, I am directed to state that the pending scrutiny assessment cases of donors who have claimed irregular weighted deduction u/s 35(1)(ii) should be handled in light of above facts. In case of donors whose cases are presently not under scrutiny, the Board desires that a list of donors who had provided funds to the Trust u/s 35(1}(ii) of the Act should be drawn by CIT (Exemption}, Mumbai for the period from A.Y 2012-13 to 2018-19 and circulated to the concerned field authorities expeditiously.
I am further directed to state that while handling investigations/ enquiries in these cases, the concerned Assessing Officer should examine the specific transactions related to the sum donated and cash trail should be clearly identified. Also, various provisions pertaining to enquiry and investigation under the Act should be effectively used and assessment orders should be passed under the monitoring of supervisory authorities.
This issues with approval of Member (IT&C), CBDT. Yours faithfully , (Rajarajeswari R.) Under Secretary (ITA.II) 11. In view of the above, it is obvious that Shri Arvindo Institute of Applied Scientific Research Trust was not recognized beyond 31.03.2006. Forged document has been filed before the authorities to misrepresent as if the said Trust was recognized beyond 31.03.2006. Moreover, it is also not the case of the assessee that the Kapadia Marketing Inc. vs. ITO Asst.Year –2018-19 - 8– recognition was extended beyond 31.03.2006. Therefore, the CIT(Appeals) is not justified in allowing the claim of the assessee under Section 35(1)(ii) of the Act. When the Trust was not renewed beyond 31.03.2006, it is not known what made the assessee to make donation.
The assessee now claims that he is a science graduate connected with pharmaceutical research and consultancy, therefore, it has to be allowed as business loss / expenditure under Section 37(1) of the Act. This Tribunal is of the considered opinion that the claim of the assessee cannot be allowed under Section 37(1) of the Act also. The payment was admittedly said to be made as donation for scientific research and not for any business expenditure. When the approval was not available on the date of payment and admittedly forged document has been produced before the authorities below to claim that Shri Arvindo Institute of Applied Scientific Research Trust was approved under Section 35(1)(ii) of the Act, this Tribunal is of the considered opinion that this kind of claim cannot be appreciated. Once the recognition was not granted and the claim was made on the basis of forged and false document, including one of gazette notification, this Tribunal is of the considered opinion that the CIT(Appeals) ought not to have allowed the claim of the assessee. Since it is not a business expenditure and the claim is one of donation, it cannot be allowed under Section 37(1) of the Act also. Therefore, this Tribunal is unable to uphold the order of the CIT(Appeals). Accordingly, the order of the CIT(Appeals) is set aside and that of the Assessing Officer is restored.
In the result, the appeal filed by the Revenue is allowed.”
9. In the case of C K Zipper Private Limited vs. ACIT in the ITAT Ahmedabad also disallowed the claim of weighted donation for A.Y. 2016-17 under Section 35(1)(ii) of the Act to Arvindo Institute of Applied Science and Research Institute on the ground that at the time of grant of registration, it did not have a valid registration. While passing the order the ITAT made the following observations:
“5. We have carefully considered the entire aspect of the matter and we find that it appears practically and factually the entity, namely, M/s. Shri Arvindo Institute of Applied Scientific Research Trust having PAN No. AAFTS7349D with whom the donation to the tune of Rs.20,00,000/- was made by the appellant and claimed weighted average deduction of Rs.15,00,000/- under Section 35(1)(ii) of the Act for A.Y. 2016- 17, though earlier was approved under Section 35(1)(ii) of the Act, the same was expired on 31.03.2006. Thus, the entity is not recognized for the purpose of Section 35(1)(ii) of the Act and neither eligible to raise donations for undertaking scientific research. In that view of the matter, the Ld. CIT(A) passed the following order:
“4.1 I have gone through the facts of the case, grounds of appeal and submissions made in this regard Briefly, the facts of the case are that the appellant M/s. C.K. Zipper Private Limited (PAN-AADCC7700M) filed its return of income for A.Y. 2016-17 an 16/08/2016 declaring total income of Rs.66,15,430/-. The return was processed us. 143(1) of 1. T. Act, 1961 on 02/10/2016. The case was selected for limited scrutiny and assessment was completed u/s. 143(3) of I.T. Act on 02/08/2018 determining income at Rs.66, 15,430/- Subsequently, it was found that the claim of the assessee towards deduction u/s 35(1)(ii) has been allowed on the basis of document given by an entity not authorized to issue the same. Apparently the documents were forged. Section 35(1)(ii) of the Income Tax Act, prescribes a weighted deduction @150% (175% before 01-04-2018) to a donor for any sum paid to an approved research association' having its sole object the undertaking of scientific research or to a university college or other institution for carrying out scientific research. This came to light when CBDT provided information Vide Letter F.No. 225/351/2018-ITA(II) dated 14-12-2018 issued to all field offices regarding bogus donation racket under section 35(1)(ii) of the I.T. Act, 1961. An entity namely M/s Shri Arvindo Institute of Applied Scientific Research Trust (PAN AAFTS7349D) was earlier approved under section 35(1)(ii) of the Act which expired on 31-03-2006. Thereafter, this entity, being not recognized for purpose of section 35(1)(ii) of the Act, is not eligible to raise donations for undertaking scientific research. However, the Trust has raised substantial donations over the last six years on the basis of a forged certificate. It was seen that one of the beneficiaries of such bogus donation is the assessee i.e. M/s. C.K. Zipper Private Limited (PAN- AADCC7700M). 4.2 Accordingly, the claim of the assessee to allow deduction u/s.35(1)(i) of Rs.35,00,000/- was not accepted and disallowed by AO as narrated under.
1. The expenditure of Rs.20,00,000/- is disallowed as unexplained expenditure u/s.69C of the I.T. Act and added back to the total income of the assessee. (Addition: Rs.20,00,000/-) 4.2 Accordingly, the claim of the assessee to allow deduction u/s 35(1)(ii) of Rs 35,00,000/- was not accepted and disallowed by AO as narrated under.
1. The expenditure of Rs. 20,00,000/- is disallowed as unexplained expenditure us BC of the LT Act and added back to the total income of the assessee. (Addition Rs.20,00,000/-)
2. The weighted deduction of Rs.15,00,000/- claimed on above expenditure is disallowed and added back to the total income of the assessee. (Addition Rs 25,00,000/-) 4.3 A show cause notice along with draft assessment order intimating the above additions was issued and served on the assessee on 27.08.2021 by the assessing officer. In response the assessee filed its reply on 31.08.2021 stating therein that it will provide bank statements relating to the above payment of Rs.20,00,000. The AO found the reply to be not satisfactory and made the additions discussed above.
44. The assessing officer had reasons to believe that the income had escaped assessment and he had recorded the same as follows- "On perusal of case records, it is observed that assessee M/s. C.K Zipper Private Limited (PAN-AADCC7700M) has claimed deduction amounting to Rs 35,00,000/- on account of donation made to the entity namely M/s Shri Arvindo Institute of Applied Scientific Research Trust(PAN AAFTS 73490) It is also observed that the said entity M/s. Shri Arvindo Institute of Applied Scientific Research Trust(PAN: AAFTS 7349D) do not have requisite recognition duly approved by CBDT. Thus in light of letter issued by CBDT, the deduction so claimed by assessee M/s C.K. Zipper Private Limited (PAN:AADCC7700M) is not allowable deduction." Satisfaction of this office: In view of the above facts, the provisions of clause(c) of explanation 2 to section 147 are applicable to facts of this case and the assessment year under consideration is deemed to be a case where income chargeable to tax escaped assessment. The office of undersigned is satisfied that in the case of assessee M/s C.K Zipper Private Limited (PAN AADCG7700M) income chargeable to fax has escaped assessment for A. Y. 2016-17. 4.5. It is observed that in this case, assessment u/s. 143(3) was made and the only requirement to initiate proceeding u/s 147 is reason to believe which has been recorded above. The provisions of clause(c) of Explanation (2) to section 147 are applicable to facts of this case and the assessment year under consideration is deemed to be a case where income chargeable to tax has escaped assessment. The present case is definitely a case of underassessment and excess relief. This case is within four years from the end of the assessment year under consideration. The necessary sanction to issue the notice u/s. 148 was obtained separately from Additional Commissioner of Income Tax as per the provisions of section 151 of the Act. Therefore there is no infirmity in the reopening of the case. Hence the ground against reopening of assessment is rejected. 4.6 The issue under question concerns donations. Any donation constitutes application of income and is normally not a deductible expenditure. It is only when certain donations are to be encouraged on the basis of the nature of activity or the goals of the entity undertaking certain specific tasks that government at times allows certain donations to such entities to be claimed as deductible expenditure. These donations remain deductible expenditure till the same have the sanction as per the statute. In the present case the appellant claims to have made the donation but in the absence of statutory approval it is not a deductible expenditure 4.7 However it is observed that the assessing officer has invoked the provisions of section that is unexplained expenditure. Though nowhere in the order it is mentioned or stated as to how the expenditure is unexplained or how the source of the same is unexplained. It is clear the donation is made to an entity not eligible for allowing deduction under the Income tax Act but it nowhere emerges from the assessment order that the donation is from unexplained sources. The AO in his show cause stated as under: “In connection with the assessment proceeding for the AY 2016-17, you have claimed deduction u/s 35(1) (ii) of the IT Act amounting to Rs 35,00,000 on account of donation made to the entity namely M/s Shri Arvindo Institute of Applied Scientific Research Trust (PAN AAFTS 73490) As intimated to you earlier, M/s. Shri Arvindo Institute of Applied Scientific Research Trust is not recognised for the purpose of section 35(1) (ii) of the Act after 31.03.2006 and therefore not eligible to raise donations for undertaking scientific research Hence notice u/s 148 was issued to you on 12.07. 2019 and thereafter notice u/s 143(2) was also issued and served on 27.09.2019 against which you had raised objection u/s 292(BB) Your objection has been countered and rebutted point wise vide letter dated: 10/01/2020 DIN & Letter No. ITBA/AST/F/17/2019-20/1023780691(1) through a speaking order. Therefore, your objection regarding the disallowance of claim of deduction is rejected and the sum of Rs. 35,00,000 is liable to be added back to your total income. You are requested to furnish any other evidence in support of your claim now except the documents provided eartier during the reassessment proceedings." 4.8 Thus the section 69C is wrongly invoked, But in any case the deduction claimed on the donation is correctly disallowed and the same is sustained.
5. In nutshell the appeal of the assessee appellant is partly allowed to the extent that section 69C is wrongly quoted by the AO in the assessment order. But disallowance of the deduction is rightly made.”
6. The Ld. CIT(A) upheld the order disallowing the claim made by the appellant. However, the expenditure was disallowed as unexplained expenditure under Section 69C of the Act. In this regard, the Ld. CIT(A) observed that the same expenditure is unexplained and how the source of the same is unexplained, has not been able to be specified by the Ld. AO while invoking Section 69C of the Act while rejecting the claim of the appellant. However, keeping in view the entire aspect of the matter, the claim made by the appellant on a wrong footing, particularly, when the donation made to the entity which is not eligible to raise donation under Section 35(1)(ii) of the Act, the Ld. CIT(A) upheld the order of disallowance of the claim made by the appellant by the Ld. AO which, in our considered opinion is just and proper. We, therefore, decline to interfere with the same. With the aforesaid observation, we dismiss the appeal preferred by the appellant as the same is found to be devoid of any merit.
In the result, the appeal preferred by the appellant is dismissed.”
10. In view of the above observations, we find no infirmity in the order of Ld. CIT(A), so as to call for any interference.
In the result, the appeal of the assessee is dismissed. This Order is pronounced in the Open Court on 17/01/2025 Sd/- Sd/- (DR. BRR KUMAR) (SIDDHARTHA NAUTIYAL) VICE PRESIDENT JUDICIAL MEMBER Ahmedabad; Dated 17/01/2025 TANMAY, Sr. PS TRUE COPY आदेश की �ितिलिप अ�ेिषत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant ��थ� / The Respondent. 2. 3. संबंिधत आयकर आयु� / Concerned CIT 4. आयकर आयु�(अपील) / The CIT(A)- िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad 5. 6. गाड� फाईल / Guard file. आदेशानुसार/ BY ORDER,