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Facts
The assessee's appeals pertain to assessment years 2014-15 and 2016-17, challenging orders passed under Section 143(3) r.w.s. 153A. The core issue revolves around donations received by 'Shyam Salona Dhwaj Yatra Samiti' and their assessment in the hands of the assessee or an AOP.
Held
The Tribunal held that the CIT(A) was correct in directing that the income from the unregistered society should be assessed in the hands of the AOP (assessee and two others) and not the assessee in his individual capacity. The appeals are disposed of in terms of the CIT(A)'s directions, subject to proper assessment by the AO.
Key Issues
Whether income from an unregistered society is assessable in the hands of an individual or an AOP, and if the calculation of additions made by the AO is arithmetically correct.
Sections Cited
143(3), 153A, 139, 2(31)
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, JAIPUR BENCHES,”B” JAIPUR
Before: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM
ORDER PER: DR. S. SEETHALAKSHMI, J.M. Both these appeals have been filed by the assessee against two different orders of the ld. CIT(A)-4, Jaipur dated 22-01-2024 and 22-03- 2024 passed under section passed 143(3) r.w.s. 153A and 143(3) of the Income Tax Act, 1961 respectively. The grounds of appeal raised by the assessee in both the appeals are as under:-
& 1281/JPR/2024 SHRI KEDAR PRASAD VIJAY VS ACIT, CENTRAL CIRCLE, ALWAR – A.Y. 2014-15 ‘’1. The Ld. CIT(A) has erred on facts and in law in holding that amount of Rs.32,48,726/as per seized material and part thereof deposited in the bank account opened in the name of Shyam Salona Dhwaj Yatra Samiti, being the donation received from various persons which is operated by any two out of three individuals namely the assessee, Tulsi Ram Mittal and Dilip Kumar though not assessable in the hands of assessee in his individual capacity is to be deleted subject to assessment in the hands of AOP of these persons. Such direction of Ld. CIT(A) is perverse, illegal & bad in law, hence the same be expunged.
2. The Ld. CIT(A) has erred on facts and in law in rejecting the additional evidences filed by the assessee in support of existence of unregistered AOP in the name of Shyam Salona Dhwaj Yatra Samiti' by making various incorrect and irrelevant observations.
3. The Ld. CIT(A) has erred on facts and in law in holding that the expenditure incurred out of donation received by 'Shyam Salona Dhwaj Yatra Samiti' is not allowable as deduction in computing the total income by making various incorrect and irrelevant observations ignoring the concept of mutuality and basic principle of taxation.
4. That the learned Assessing Officer has erred in law as well as on the facts and circumstances of the case in wrongly computing the total receipts at Rupees 32,48,726.00, out of the seized material AS-2, whereas, the receipts are only Rupees 7,79,461.00 and expenses of Rupees 7,70,025.00 out of the same, thus there is an income of Rupees 9,436.00 only, out of the seized material AS- 2, as evidenced from statement/details of nottings and explanation and learned Commissioner of Income Tax-(Appeals)-IV, has erred in not giving any finding thereon.’’ A.Y. 2016-17 ‘’1. The Ld. CIT(A) has erred on facts and in law in holding that amount of Rs.22,95,239/- as per seized material and part thereof deposited in the bank account opened in the name of Shyam Salona Dhwaj Yatra Samiti, being the donation received from various persons which is operated by any two out of three individuals namely the assessee, Tulsi Ram Mittal and Dilip Kumar though not assessable in the hands of assessee in his & 1281/JPR/2024 SHRI KEDAR PRASAD VIJAY VS ACIT, CENTRAL CIRCLE, ALWAR individual capacity is to be deleted subject to assessment in the hands of AOP of these persons. Such direction of Ld. CIT(A) is perverse, illegal & bad in law, hence the same be expunged.
The Ld. CIT(A) has erred on facts and in law in rejecting the additional evidences filed by the assessee in support of existence of unregistered AOP in the name of 'Shyam Salona Dhwaj Yatra Samiti" by making various incorrect and irrelevant observations.
3. The Ld. CIT(A) has erred on facts and in law in holding that the expenditure incurred out of donation received by 'Shyam Salona Dhwaj Yatra Samiti is not allowable as deduction in computing the total income by making various incorrect and irrelevant observations ignoring the concept of mutuality and basic principle of taxation.
4. That the learned Assessing Officer has erred in law as well as on the facts and circumstances of the case in wrongly computing the total receipts at Rupees 22,95,239.00, out of the seized material AS-1 and AS- 3, whereas, the receipts are only Rupees 90,000.00 and expenses of Rupees 8,94,482.00, as evidenced from statement/details of nottings and explanation and learned Commissioner of Income Tax-(Appeals)-IV, has erred in not giving any finding thereon.
That the learned Assessing Officer has erred in law as well as on the facts and circumstances of the case in considering all the entries as appearing in seized material AS-I and AS-3 in the Assessment Year 2016- 17, whereas these entries relates to the financial year 2014-15 relevant to Assessment Year 2015-16, thus no cause of action arises vis-à-vis the entries appearing in AS-1 and AS-3 in the Assessment Year 2016-17 and the learned Commissioner of Income Tax-(Appeals)-IV, Jaipur, has erred in not giving any finding thereon.’’ 2.1 At the outset of hearing of the appeals of the assessee, the Bench noted that there are delay of 208 days and 139 days in filing the appeal (supra) by the assessee for which the assessee has filed two applications dated 13-10-2024 for condonation of delay narrating therein the same viewpoint/ reasoning which are as under:-
Application for condonation of delay in Filing of appeal in the case of KEDAR PARSAD VIJAY, 236, Scheme Number 1 Alwar Rajasthan PAN: AATPV5993J A.Y. 2014-2015 and 2016-17.
Respected Sir, It is humbly submitted that the appeal of the above assessee for the Assessment Year 2014-15 was decided by learned. Commissioner of Income Tax-(Appeals)- VI, Jaipur vide its order dated 22.01.2024 and while deciding the appeal, Hon'ble Commissioner of Income Tax-(Appeals)-VI, Jaipur, has given the following direction to the Assessing Officer on page number 60 in 1 and 2 para of the appellate order:- "in view of the above, the income as per the seized material, deposit in the bank account etc., of the unregistered society is assessable in the hands of the three individuals in the status of AOP (Sh. Kedar Prasad Vijay- appellant, Sh. Tulsi Ram Mittal, and Sh. Dilip Kumar)and not in the hands of the appellant in his individual capacity. The amount of income worked out in the hands of the appellant in this regard in the assessment order in the AY 2014-15 is Rupees 3248726.00 and in the AY 2016-17 is Rupees 2295239.00, which is cumulatively Rupees 5543965.00. Direction is hereby given for making the assessment in the hands of the AOP In view of the above discussions, the addition made in the hands of the appellant in his individual capacity is hereby directed to be deleted subject to assessment in the hands of the above referred AOP.’’ The Ld. AO for AY 2014-15 gave appeal effect vide order dt. 18.03.2024 holding that as directed by Ld. CIT(A) necessary relief against the impugned addition will be considered while completion of the relevant assessment of the referred AOP (Sh. Kedar Prasad Vijay- appellant, Sh. Tulsi Ram Mittal and Sh. Dilip Kumar), as per the direction of the appellate order. With the above referred finding, the assessee was under the bona fide belief that the addition in his hands is deleted.
& 1281/JPR/2024 SHRI KEDAR PRASAD VIJAY VS ACIT, CENTRAL CIRCLE, ALWAR Subsequently, the assessee moved an appeal effect application dated 22.08.2024 to the Assessing Officer for giving the appeal effect of the Commissioner of Income Tax-(Appeals)-IV, Jaipur's order dated 22.03.2024 for the Assessment Year 2016- 17. Thereafter the Ld. AO communicated the appeal effect order dated 09.04.2024 vide its intimation letter dated 28.08.2024. In this order the Ld. AO held that there was no submission regarding the AOP as directed by Ld. CIT(A) of 3 members, i.e. Sh. Kedar Prasad Vijay appellant, Sh. Tulsi Ram Mittal and Sh. Dilip Kumar. Accordingly following the direction of Ld. CIT(A) no relief is allowable at this stage in the case and thus sustained the addition made in the assessment order. When the assessee approached his counsel CA V.K. Datta with this order, he after consulting other professional colleagues advised the assessee on 01.10.2024 to file appeal against the order of Ld. CIT(A) for AY 2014-15 & 2016-17 with the application for condonation of delay. From the above it may be noted that the assessee was under the bona fide belief that Ld. CIT(A) has allowed relief to him but only when the appeal effect order for AY 2016-17 was communicated to him on 28.08.2024 he came to know that AO has taken different stand in AY 2016-17 as compared to that taken in AY 2014-15. This has resulted in delay in filing the appeal and therefore, in the interest of natural justice, equity and fair play, it is prayed that the appeal of assessee be admitted by condoning the delay in filing the appeal.’’ To this effect, the assessee has filed an affidavit deposing the above facts as to the delays made in filing the above mentioned appeals.
2.2. During the course of hearing, the ld. DR objected to assessee’s applications for condonation of such inordinate delays and prayed that Court may decide the issue as deemed fit and proper in the interest of justice.
2.3 We have heard both the parties and perused the materials available on record. The Bench noted that the reasons as advanced by assessee for condonation of delay in respect of the above mentioned appeals have sufficient reasons to & 1281/JPR/2024 SHRI KEDAR PRASAD VIJAY VS ACIT, CENTRAL CIRCLE, ALWAR condone the delay which has merit. Thus, we concur with the submission of the assessee and condone the delay so made in filing the appeals by the assessee in view of the decision of Hon’ble Supreme Court in the case of Collector, land Acquisition vs. Mst. Katiji and Others, 167 ITR 471 (SC) as the assessee was prevented by sufficient cause.
3.1 Apropos grounds of appeal of the assessee, brief facts of the case are that the assessee is employed as purchase manager of M/s Vijay Solvex Ltd. Alwar which is a Data Group Company. A search was conducted on a Data Group Alwar on 14- 10-2015. Accordingly search was also conducted at the residential premises of the assessee. The assessee has filed the return for AY 14-15 u/s 139 on 31.07.2014 at income of Rs.5,16,470/- and the same income is again declared in the return filed on 22.07.2016 in response to notice u/s 153A. It is noted from the assessment order that at the residence of assessee certain papers of ‘Shyam Salona Dhwaj Yatra Samiti’ was found at annexure AS 1. (page 1-12), AS 2. (page 1-10) and AS-
3. (Page 11-21 & 41-44). This was an unregistered society, main object of which was to conduct Dhwaj Yatra. For this purpose a bank account of the samiti was opened and on the bank account the photo 3 office bearer of the Samiti was imprinted. It was formerly registered on 22-1-18 with the registrar, Cooperative Department (Annexure 24-25) at 15/30, Dhobiyon Ki Gali, Siddhipura Alwar. It is claimed by & 1281/JPR/2024 SHRI KEDAR PRASAD VIJAY VS ACIT, CENTRAL CIRCLE, ALWAR assessee that in these annexures the donation given by various persons to the Samiti and the expenditure incurred on organizing Dhwaj Yatra is noted and therefore on the basis of these papers new addition can be made in his hand. Further it is noted that the AO, however, at page 7-8 of the order observed that (i) the samiti is not registered nor having any PAN (ii) the affidavit given by Mr. Dilip Kumar Gupta cannot justify the contention that transactions do not pertain to any individual but related to any hypothical entity (iii) in the bank passbook of samiti, the address of the individual is appearing and no official ID of Samiti is provided. (iv) bills / vouchers of expenses claimed to be incurred on Dhwaj Yatra is not furnished (v) the donation receipt furnished are self made, not subject to verification and therefore he held that amount deposited in the bank account is unaccounted receipt of the assessee and thus made addition of Rs.32,48,726/- on the basis of page 1-9 of annexure AS-2 and page 41 of annexure AS-3.
3.2 Before the CIT(A) assessee filed additional evidences by way of pictures taken during the course of conducting the Dhwaj Yatra, affidavit of 6 persons working as members of the samiti that document seized from the assessee belongs to the samiti as also the mistake in the amount added by the AO which is reproduced at page 46-49 of the appellate order. However the Ld. CIT(Appeal) after detailed discussion at page 52-59 of the appellate order rejected the additional & 1281/JPR/2024 SHRI KEDAR PRASAD VIJAY VS ACIT, CENTRAL CIRCLE, ALWAR evidences by observing that the registered society came into existence much later and therefore the samiti/AOP which is in existence during the year is completely distinct and separate and thus held that income as per seized material, deposits in the bank account etc. of the unregistered society is assessable in the hands of the 3 individuals in the status of AOP (Shri Kedar Prasad Vijay- Appellant, Shri Tulsi Ram Mittal and Shri Dilip Kumar) and not in the hands of the appellant in his individual capacity. Direction is given for making the assessment in the hands of AOP and thus addition made in the hands of the assessee is deleted subject to assessment in the hands of the AOP. For ready reference, the narration so made by the ld. CIT(A) at page 59 & 60 of his order is reproduced as under:- ‘’In view of the above discussion the additional evidence have been duly considered but the same are of no help to the appellant and are irrelevant. From the facts of the case it is clear that the registered society came into existence much later and was not in existence during the year for which the assessment has been made which is under appeal. Thus there is no legal dispute regarding the fact that the samiti/AOP which was in existence during the year under appeal is completely distinct and separate from the society which has come into existence in the year 2018. The activities of the registered society have not been examined neither by the learned assessing officer and nor such evidence have been placed on record in the appeal. Merely because the name of the registered society is same or similar to the name which was being used by the unregistered Association of person much earlier does not mean that the registered society and the unregistered Association of person are one and same person. Conversely the registered society apparently is an afterthought and colorable device to create some evidences and arguments as the registration was done after the assessment order was passed whereas the search and seizure action was carried out much earlier. Accordingly, the additional evidences are hereby rejected being irrelevant. In view of the above, the income as per the seized material, deposits in the bank accounts etc. of the unregistered society is assessable in the hands of & 1281/JPR/2024 SHRI KEDAR PRASAD VIJAY VS ACIT, CENTRAL CIRCLE, ALWAR the three individuals in the status of the AOP (Sh. Kedar Prasad Vijay - appellant, Sh. Tulsi Ram Mittal and Sh. Dilip Kumar) and not in the hands of the appellant in his individual capacity. The amount of income worked out in the hands of the appellant in this regard in the assessment orders in the AY 2014-15 is Rs. 32,48,726 and in AY 2016-17 is Rs. 22,95,239 which is cumulatively Rs. 55,43,965. Direction is hereby given for making the assessment in the hands of the AOP. In view of the above discussion, the addition made in the hands of the appellant in his individual capacity is hereby directed to be deleted subject to assessment in the hands of the above referred AOP Accordingly, this ground is statistically treated as allowed in above terms.’’ It is also noteworthy to mention that the ldCIT(A) has passed the similar type of order in the case of the assessee for the assessment year 2016-17 giving therein following narration.
‘’7.6 I have considered the facts of the case and written submissions of the appellant as against the observations / findings of the AO in the assessment order, the remand report and the rejoinder submitted by the appellant. The contentions / submissions of the appellant are being discussed and decided as under:- I have decided the similar issue in the case of the appellant for the assessment year 2014-15 in the ground of appeal number 2 where the additional evidence has been rejected being irrelevant and ground of appeal have been statistically treated as allowed with direction for making the assessment in the hands of the AOP. Material facts of the present appeal being pari material with the facts of the appeal in assessment year 2014-15 in the ground of appeal number 2 will apply mutatis mutandis to the present appeal for the assessment year 2016-17 and it is held accordingly.
& 1281/JPR/2024 SHRI KEDAR PRASAD VIJAY VS ACIT, CENTRAL CIRCLE, ALWAR In view of the above, the income as per the seized material, deposits in the bank accounts etc. of the unregistered society is assessable in the hands of the three individuals in the status of the AOP (Sh. Kedar Prasad Vijay -appellant, Sh. Tulsi Ram Mittal and Sh. Dilip Kumar) and not in the hands of the appellant in his individual capacity. The amount of income worked out in the hands of the appellant in this regard in the assessment orders in the AY 2014-15 is Rs. 32,48,726 and in AY 2016-17 is Rs. 22,95,239 which is cumulatively Rs. 55,43,965. Direction is hereby given for making the assessment in the hands of the AOP. In view of the above discussion, the addition made in the hands of the appellant in his individual capacity is hereby directed to be deleted subject to assessment in the hands of the above referred AOP. Accordingly, this ground is statistically treated as allowed in above terms.’’ 3.3 During the course of hearing, the ld. AR of the assessee submitted that the AO be directed to delete the addition made in the hands of the assessee for which the ld. AR of the assessee filed following written submission as to the appeals for the assessment year 2014-15 and 2016-17.
‘’Submission:- 1. The first issue which arises after the order of CIT(A) is whether having held that income as per the seized material and deposit in the bank account is assessable in the hands of 3 individuals in the status of AOP and not in the hands of the assessee in his individual capacity, is his further direction that addition is to be deleted from the hands of the assessee subject to assessment in the hands of the AOP is correct. The second issue which arises for consideration is whether the amount which is added by the AO is arithmetically correct.
& 1281/JPR/2024 SHRI KEDAR PRASAD VIJAY VS ACIT, CENTRAL CIRCLE, ALWAR 2. It is submitted that income is assessable in the hands of a person. A person is defined u/s 2(31) of the act to include an individual and AOP amongst others. The Income Tax Act nowhere provides that income is to be assessed in hands of one person if it is not assessed in the hands of other person. Though there is a concept of protective and substantive assessment but there is no concept that if income is not assessed in the hands of a person (here AOP) where it is assessable, then if it is not assessed in that hand, the addition made in the hand of other person (here individual) cannot be deleted. Hence the Ld. CIT(A) having held that the income as per the seized material and the deposit in the bank account etc. of the unregistered society is assessable in the status of AOP, his direction that addition in the hands of the individual is to be deleted subject to assessment in the hands of the AOP is illegal, bad in law and the same be expunged.
In respect of the second issue the assessee on the basis of the seized material and the bank statement of ‘Shyam Salona Dhwaj Yatra Samiti’ has explained that the total receipt and expenses as per the seized annexure vis-à-vis the deposit/ withdrawal in the bank account is as under:- AY Annexure Receipt Expenses Surplus Bank Bank Deposit Withdrawal 2014- AS-2 & Pg 41 7,79,461/- 7,77,025/- 2,436/- 4,37,000/- 3,86,000/- 15 of AS-3 2016- AS-1 & AS-3 5,60,100/- 8,49,075/- (2,88,975/- 2,92,600/- 6,35,100/- 17 ) The AO while making the addition has added both the receipt and expenses. Further amount carried forward from one paper to another paper has been added independently. Amount noted on the individual paper and the summarized total of these pages noted on a separate paper are both added. This has resulted into incorrect addition of Rs.32,48,726/- in AY 2014-15 and Rs.22,95,239/- in AY 2016-17. This factual mistake pointed out before CIT(A), though reproduced a para 3.5.1 at page 25 of the appellate order for AY 2014-15 and at para 3.5.2 page 43-44 of the appellate order for AY 2016-17 has not been adjudicated. The relevant working is placed at annexure 21 and 22 of the appeal papers. These mistakes are highlighted as under:- AY 2014-15 (AO Page 6) S. Annexure Amount Amount of Amount of Remarks No. added by AO receipt expenditure 1. AS-3/41 3,81,334/- - - It is total of bank balance & cash balance on 03.04.2014 2. AS-2/1 2,69,406/- 2,65,326/- - Totaling Mistake 3. AS-2/2 4,32,050/- - 4,10,730/- Totaling Mistake 4. AS-2/3 3,69,571/- 1,04,245/- - AO took total of Pg 2 & 3 5. AS-2/4 97,280/- 97,280/- - - 6. AS-2/5 93,117/- 93,117/- - - & 1281/JPR/2024 SHRI KEDAR PRASAD VIJAY VS ACIT, CENTRAL CIRCLE, ALWAR 7. AS-2/6 49,482/- 54,170/- - Amount less taken by AO 8. AS-2/7 9,17,435/- 1,61,102/- 1,42,195/- Amount taken by AO is total of receipt at page 2 to 7 and expense at page 7 9. AS-2/8 4,221/- 4,221/- - - 10. AS-2/9 6,34,830/- - 2,24,100/- Amount taken by AO is of total expenses that is Rs.4,10,730/- plus Rs.2,24,100/- Total 32,48,726/- 7,79,461/- 7,77,025/- AY 2016-17 (AO Page 3 & 4) S. Annexure Amount Amount of Amount of Remarks No. added by receipt expenditure AO 1. AS-1/2 90,000/- 90,000/- - - 2. AS-1/3 92,955/- - 92,995/- - 3. AS-1/4 3,635/- - - It is part of expenditure of Rs.92,995/- 4. AS-1/5 10,680/- - - It is part of expenditure of Rs.92,995/- 5. AS-1/6 20,000/- It is part of receipt of - - Rs.90,000/- 6. AS-1/7 12,640/- - - It is part of expenditure of Rs.92,995/- 7. AS-1/8 12,080/- - - It is part of expenditure of Rs.92,995/- 8. AS-1/9 50,000/- It is part of receipt of - - Rs.90,000/- 9. AS-1/10 33,700/- - - It is part of expenditure of Rs.92,995/- 10. AS-1/11 20,000/- - - It is part of receipt of Rs.90,000/- 11. AS-1/12 20,220/- It is part of expenditure of - - Rs.92,995/- 12. AS-3/11 25,937/- - - It is an expenditure which is part of page 14 & page 15 13. AS-3/13 & 56,403/- - 56,403/- - back of Pg 11 14. AS-3/14 58,627/- - - It is an expenditure which is part of page 15 15. AS-3/15 80,292/- - 80,292/- - & 1281/JPR/2024 SHRI KEDAR PRASAD VIJAY VS ACIT, CENTRAL CIRCLE, ALWAR 16. AS-3/16 6,18,585/- - 6,18,585/- On the back of this paper, there is an account receipt of Rs.6,18,200/- and expenditure of Rs.6,18,585/- 17. AS-3/17 1,85,340/- - - It is covered by page 16 above 18. AS-3/18 1,34,350/- - - It is covered by page 16 above 19. AS-3/19 1,66,495/- - - It is covered by page 16 above 20. AS-3/20 1,32,400/- - - It is covered by page 16 above 21. AS-3/42 4,70,100/- 4,70,100/- - - 22. AS-3/43 565/- - 565/- - 23. AS-3/44 235/- - 235/- - Total 22,95,239/- 5,60,100/- 8,49,075/- Thus the quantum of addition made by AO is otherwise incorrect.
It is further submitted that for the Dhwaj Yatra, group of persons have contributed the fund and that amount is utilized for incurring the expenditure. The contributors and the participators are same. Thus on the principle of mutuality, no addition can be made in the hands of the AOP as directed by Ld. CIT(A). In view of above, AO be directed to delete the addition made in the hands of assessee.’’ It may be noted that the ld. AR of the assessee has filed the following paper book concerning the issue in question. S.N. Particulars Page No. 1. Copy of Annexure AS-2 for A.Y. 14-15 1-10 2. Copy of Page 41 of Annexure AS03 11 3. Copy of Annexure AS-1 For AY 16-17 12-23 4. Copy of Annexure AS-3 for AY 16-17 24-42
On the other hand, the ld. DR supported the orders of the ld.CIT(A). 3.4 3.5 We have heard both the parties and perused the materials available on record. The Bench has taken into consideration the orders of the ld. CIT(A) wherein he has allowed the appeals for statistical purposes giving the direction as mentioned (supra). The Bench has also taken into consideration the written submissions of the assessee in relation to assessment year 2014-15 and 2016-17. The Bench noticed that all the information as submitted by the assessee are concerning to the case of the material seized from the residence of the assessee during the search. The Bench does not want to come into fuss as to the addition so made by the AO and restored by the ld. CIT(A) to the file of the AO holding that the addition made in the hands of the appellant in his individual capacity is hereby directed to be deleted subject to assessment in the hands of the above referred AOP. The Bench concurs with the view of the ld. CIT(A) subject to modification that addition made in the hands of the assessee be deleted and appropriate action as per law be taken in the case of AOP (Shri Kedar Prasad Vijay, Shri Tulsi Ram Mittal and Shri Dilip Kumar). While assessing the income of the AOP, the AO would also take into consideration the various mistakes in the amount as & 1281/JPR/2024 SHRI KEDAR PRASAD VIJAY VS ACIT, CENTRAL CIRCLE, ALWAR highlighted by the ld. AR of the assesee in the written synopsis reproduced supra. Thus both the appeals are disposed off as mentioned hereinabove. 4.0 In the result, both appeals of the assessee are disposed off as per direction given supra. Order pronounced in the open court on 09 /04/2025.
Sd/- Sd/- ¼jkBkSM+ deys'k t;UrHkkbZ ½ ¼MkWa-,l-lhrky{eh½ (RATHOD KAMLESH JAYANTBHAI) (Dr. S. Seethalakshmi) ys[kk lnL; @Accountant Member U;kf;dlnL;@Judicial Member Tk;iqj@Jaipur fnukad@Dated:- 09 /04/2025 *Mishra आदेश की प्रतिलिपिअग्रेf’ात@ब्वचल वf जीम वतकमत वितूंतकमक जवरू The Appellant- Shri Kedar Prasad Vijay, Alwar. 1. 2. izR;FkhZ@ The Respondent- ACIT, Central Circle, Alwar. 3. vk;djvk;qDr@ The ld CIT 4. विभागीय प्रतिनिधि] आयकरअपीलीय अधिकरण] जयपुर@क्त्ए प्ज्Aज्ए Jंपचनत 5. xkMZQkbZy@ Guard File (ITA No. 1280 & 1281/JPR/2024) vkns'kkuqlkj@ By order,
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