CHANCHALBEN DAHYABHAI PATEL,DAMAN vs. INCOME TAX OFFICER, DAMAN

आदेश / O R D E R PER BIJAYANANDA PRUSETH, AM: These four appeals by the assessee emanate from separate orders

passed under section 250 of the Income-tax Act, 1961 (in short, ‘the Act’) by

the National Faceless Appeal Centre, Delhi/Commissioner of Income-tax

(Appeals) [in short, “NFAC/CIT(E)”] all dated 13.08.2024, for the Assessment

Years (AY) 2011-12, 2013-14, 2014-15 and 2015-16, which in turn arose out of

assessment orders passed by Assessing Officer (in short, ‘AO’) u/s 147 r.w.s.

144 r.w.s.144B of the Act on 26.12.2018, 25.03.2022 and 28.03.2022

respectively. In all the appeals, the facts are common and grounds of appeals

raised by the assessee are similar except variance of amounts. Hence, with the

consent of the parties, all the appeals were clubbed and heard together and

are decided by this consolidated order for sake of convenience and brevity.

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

ITA No.1035/SRT/2024 (AY 2011-12)

“1. I am a senior citizen widow lady, I am a tax compliant citizen. In the past I lost my husband (ex MP Daman) during unfortunate corona pandemic. Since then I was not in stable healthy/mental condition to follow up and comply the departmental notices. I have discontinued all business activities. Even now, I am struggling with my bad health. 2. In para-10 of the assessment order there is an addition of Rs.33,50,268. This is based on the estimated income of 2.8% on turnover of Rs.11,96,52,434. Whereas the profit and loss already submitted/declared and on record with the shows the profit of Rs.33,30,581.25 on turnover of Rs.10,93,44,350. These figures were arrived by considering all the entries in the bank statements ass discussed in the order. But Assessing Office hypothetically increased the turnover and profit percentage on estimated basis. 3. In para 11 of the assessment order thee is an addition of Rs.4,13,17,078. This is based on the analysis of other bank statements. These additions are against the facts of the case. All receipts are not income. There are certain transactions among the family member, which are not income. There is capital gain on certain transactions. Even cash deposits are from cash-in-hand or cash withdrawal occasionally. All cash deposits are not income. 4. In para 12 of the assessment order there is an addition of Rs.20,00,000 as unexplained investments. All fixed deposits are made and paid from the bank accounts itself. It is evident from the bank statements, where from fixed deposits are made.in the previous two paragraphs all the credit entries are added as income. Then fixed deposits creation is outflow from the inflow already added as income. This addition is the fit case of DOUBLE TXATION. Once as the credit entries in the bank and second as the fixed deposit creation outflow from the bank. 5. In para 13 of the assessment order there is an addition of Rs.3,00,000 as rental income. This, we already have offered as income. 6. In para 14 of the assessment order there is an addition of Rs.9,69,119 as unaccounted interest income. These receipts were already added as income and taxed in para 10 & 11 of the order. This is evident from the para 10 & 11 explanations. Where all bank credit entries were considered as income. These receipts were already considered as income at the time of making addition of credit entries. This is again the case of DOUBLE TAXATION. 7. In para 15 of the assessment order there is an addition of Rs.15,75,764. This income is already taxed in para 10 of the order. This is evident from the profit and loss account affixed & considered in the para 10 of the order. This

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

fig is clearly showing in the profit and loss account as income. This is again the case of DOUBLE TAXATION. 8. In para 16 of the assessment order thee is an addition of Rs.60,37,040 as profit from sale of shares. These receipts were already added as income and taxed in para 10 & 11 of the order. This is evident from the para 10 &11 explanations. Where all bank credit entries were considered as income. These receipts were already considered as income at the time of making addition of credit entries. This is the case of DOUBLE TAXATION. Once as receipts of amount and second as profit on sale of these receipts. When full receipts were added as income, then adding profit on sale is the case of double taxation. 9. In para 17 of the assessment order there is an addition of Rs.3,65,000 as interest income on KVP. The interest is calculated on estimated basis.”

ITA No.1036/SRT/2024 (AY 2013-14) “1. I am a senior citizen widow lady. I am a tax complaint citizen. In the past I lost my husband (ex MP Daman) during unfortunate corona pandemic. Since then I was not in stable healthy/mental condition to follow up and comply the departmental notices. I have discontinued all business activities. Even now, I am struggling with my bad health.

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

3.1 These deposits are added as the UNEXPLAINED INVESTMENTS under sec. 69 of the Income Tax Act, 1961. 3.2 As per sec 69 unexplained investments are investments made are not recorded in books of account. This is not the fact. All investments are well recorded and accounted for in the records. Time deposits referred as income in the order are continuing from the previous year as cumulative balances. These are not unexplained investments. These are well recorded investments in the form of time deposit continuing from previous year. 4. In para 6 of the assessment order for the A.Yr. 2013-14 an income from interest of Rs.23,72,006 was added under the head “income from other sources”. These interest incomes may be considered as income after sec 80T deductions. I already have offered this as income. In the computation shown these incomes are considered as taxable income. The TDS deducted on these interest income are not considered in the demand calculation. These may be allowed. This will accordingly reduce the demand for recovery. 5. In para 6 of the assessment order for the A.Yr. 2013-14 an income from business of Rs.46,82,588 was added. This is gross receipts. Total gross receipts cannot be the taxable income. Considering the generally acceptable norms 8% of the gross receipt i.e. Rs.3,74,607 is the taxable income. Thus business income of Rs.3,74,607 maybe considered as taxable income. This is considered in the computation of income. 6. In para 6 of the assessment order for the A.Yr. 2013-14 an addition of income under the head “unexplained money” of Rs.16,50,000 was made. These cash deposits were out of cash withdrawals on different dates during the year and balance cash-in-hand/chest. These are not taxable income for the current year. This may be deleted. 7. In the order rental income of Rs.6,00,000 is added as rental income. Whereas the facts is rental income of Rs.25000 P.M. amounting to Rs.3,00,000 is the correct i9ncome instead of Rs.6,00,000. It is evident from the 26AS. TDS of Rs.30,000 is deducted from the correct income of Rs.3,00,000/-. Correct rental income is Rs.2,10,000/- after deduction as shown in the computation. It may be corrected. 8. I further request for early hearing of my appeals so that I may get relief against the undue exorbitant tax dues.” ITA No.1037/Srt/2024 (A.Y. 2014-15) “1. I am a senior citizen widow lady. I am a tax compliant citizen. In the past I lost my husband (ex MP Daman) during unfortunate corona pandemic. Since then I was not in stable healthy/mental condition to follow up and comply the departmental notices. I already have discontinued all my business activities since long. Currently I am struggling with my bad health.

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

“lead” case. The CIT(A) has also relied on his appellate order for A.Y 2011-12

while disposing of appeals for other three AYs.

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

income for AY 2011-12. The appellant had sold immovable property and

deposited substantial cash in the bank accounts with HDFC Bank. Accordingly,

after recording reasons for escapement of income and after obtaining approval

from Competent Authority, notice u/s 148 was on 27.03.2018. However,

assessee did not file her return in response to the said notice. Thereafter, the

AO has issued five notices and show cause notice which are mentioned at

page-2 of the assessment order. There was no compliance to any of the

notices issued by the AO. Hence, AO has completed assessment proceedings

ex parte u/s 144 of the Act. Before passing the order, he issued another show

cause notice requiring assessee to explain as to why the sale consideration of

two properties amounting to Rs.4,23,07,500/- be not added as capital gains.

The assessee replied that due to some legal disputes and investigation, all lap

top/computer and related records were seized by the local authority. She

requested to allow further time to make the submission. However, no further

submission was made till finalization of the assessment order. The AO,

however, called for the information from the Sub-Registrar to find out cost and

year of the acquisition of the property at survey No.165/3 sold deriving the

year by assessee. He allowed cost of acquisition of Rs.17,10,000/- out of the

assessee’s share of Rs.62,70,000/- and added Rs.45,60,000/- as short-term

capital gain.

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

4.1 Similarly, the AO allowed index cost of acquisition in respect of the

property mentioned at para-5.2 of the assessment order and added

Rs.1,05,17,905/- as long-term capital gains. The consideration received from

the remaining properties were taxed as short-term capital gains after allowing

cost of acquisition. The addition of STCG was Rs.1,60,80,000/-, which is at

para-5.3 of the assessment order.

4.2 The AO has discussed about the survey u/s 133A of the Act conducted

by ADIT(Inv), Unit-2, Vapi wherein assessee had submitted her profit and loss

account showing net income of Rs.2,13,66,916/-. However, the assessee had

not filed any return of income. The AO issued show cause notice and

requested assessee to submit details and nature of income reported in the

profit and loss statement along with supporting evidences. The assessee filed a

reply asking for further adjournment which was not accepted by AO. The AO

thereafter reproduced statement of Shri Surendra Babubhai Patel, accountant

of the assessee, recorded u/s 131(1A) of the Act by the ADIT(Inv.) He had

replied that assessee was owner of a petrol pump from FYs 2009-10 to 2014-

the profit and loss account of C.D Petroleum for the year ended 31.03.2011,

the net profit was shown at Rs.30,30,591/-, which was added by AO as income

from the petrol pump. Further, from the other profit and loss account in the

name of Chandanaben D Patel-1, AO added other income of Rs.47,19,298/-.

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

The AO has not allowed expenses of Rs.31,42,213/- in absence of any

explanation by assessee to justify the expenses.

4.3 The AO also added Rs.6,81,005/-, being profit @ 3.25% on account of

difference of receipt of Rs.2,09,54,009/- on account of C.D. Petroleum-2

because out of total deposits of Rs.13,91,98,359/- only Rs.10,93,44,350/- was

shown as sales by the appellant. The AO has, however, excluded cash deposit

of Rs.89,00,000/- while working out profit on the above difference.

4.4 The AO found that assessee was maintaining seven bank accounts

which are mentioned at page-15 of the assessment order. He has added total

deposits of Rs.1,85,09,780/-, Rs.20,00,000/-, Rs.2,16,34,384/- and

Rs.18,00,000/- totalling to Rs.4,39,44,164/- in five bank accounts because the

assessee failed to explain these amounts during assessment proceedings by

submitting requisite details. The AO observed that the amounts do not pertain

to inter-bank transfers or sale proceeds of properties.

4.5 The AO has also discussed about various cash deposits of

Rs.2,05,00,000/- in four bank accounts at para-9 of the assessment order. After

listing the date and amount of deposits, he has trifurcated the deposits into

three periods i.e., 06.04.2010 to 08.05.2010, 21.06.2010 to 25.10.2010 and

19.03.2011 to 31.03.2011. During the above periods cash of Rs.1,08,00,000/-,

Rs.35,00,000/- and Rs.62,00,000/- were deposited by the assessee. The AO

found that the assessee sold three properties to M/s Wellknown Polyesters

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

Ltd. and M/s Alkem Laboratories Ltd. The AO has extracted copy of the

documents impounded from the premises of M/s Alkem Laboratories Ltd.

wherein cash payment of Rs.1,92,06,000/- was made by the said company. The

share of the assessee was Rs.55,40,937/-. Since this amount was closer to cash

deposit of Rs.62,00,000/-, AO added Rs.62,00,000/- as on-money received in

cash. Similarly, he added Rs.1,08,00,000/- as cash on-money on account of the

other properties sold on 29.04.2010 to M/s Wellknown Polyester Ltd. The AO

also added another sum of Rs.35,00,000/-, being the cash deposit in SBI during

21.06.2010 to 25.10.2010 because assessee failed to explain the nature and

source of such cash deposits. In the result, the AO added Rs.10,40,32,963/- to

the total income of assessee. The total income was determined at Rs.10,40,32,

960/-.

CIT(A) issues five notices between 24.12.2020 and 24.204.2023, in response to

which assessee filed written submission on 23.05.2023 and 31.05.2023. The

CIT(A) issued further notices on 10.01.2024, 08.04.2024 and 02.07.2024. He

has extracted the assessment order at pages 3 to 41 of the appellate order.

The submissions of the appellant are at pages 41 to 50 of the appellate order.

In the submission dated 23.05.2023, appellant submitted that she was not

keeping well after the death of her husband during the Covid-19. All the

business activities are either discontinued or mismanaged. She had a petrol

pump which was started by her husband. The other line of activity was sale

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

and purchase of lands. The AO has wrongly treated the profit on sale of lands

as income from capital gains instead of business income. In the subsequent

submission to the CIT(A), she again submitted that business profit had been

wrongly taxed under the head capital gain. The assessee had submitted the

profit and loss account in two parts, which had been wrongly treated as

separate profit and loss accounts by the AO. No business expenses were also

allowed by him. She also submitted that certain credits in bank accounts are

loans from family members and in any case, total credits cannot be taken as

sales. She further submitted that some income has been taxed twice. Other

credit entries include temporary advance from M/s Patel Builders and M/s

Patel Developers, which were wrongly added by AO. She also submitted that

loans were received from SBI against fixed deposits which has been incorrectly

added by the AO. It was also submitted that the cash deposits were out of the

cash withdrawals from the bank accounts. It was also submitted that the AO

himself is not sure about the cash deposits and he has used the word

“appears” many times in the order. Regarding the seized paper, in case of M/s

Alkem (supra), the paper was unsigned and name of the assessee was not

mentioned anywhere in the paper. Further, the transaction was done 11

months earlier from the date of survey on Alkem.

5.1 The above submissions were forwarded by the CIT(A) to the AO for

remand report because assessment order was passed u/s 144 of the Act. In the

remand report, the AO requested not to admit any additional evidence. In fact,

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

he submitted that no additional evidence had been submitted by the assessee,

as contended in her submission to the CIT(A). He referred to Rule-46A of the

Income-tax Rules, 1962 and contended that the assessee has not made out a

case of sufficient cause which prevented assessee from producing the

impugned evidences. Regarding the merit of additions, the AO has replied in a

tabular form which is at pages 55 to 57 of the appellate order. He submitted

that the assessee did not produce any relevant documents or evidences in

support of her claim due to which additions were made in the assessment

order.

5.2 After considering submissions of assessee and remand report, the

CIT(A) has given the decisions at pages 57 to 59 of the appellate order. He

observed that the assessee did not file any return of income nor any tax was

paid by the assessee. Only certain amount of TDS was made by the deductors,

credit of which was given by the AO. The assessee has also not maintained any

books of account and the accounts of the appellant are not audited despite the

sale amount running into crores of rupees. Even the interest income was not

offered for taxation. The assessee also did not file any reply to the AO and

even in course of appellate proceedings, two submissions were made without

any supporting evidences. The submissions are limited to controverting the

action of AO without giving any evidence or reasons as to why such actions are

incorrect. The CIT(A) further observed that the AO himself had tried to get

details from all possible sources and given credit wherever such details

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

warranted relief. The AO has also fairly reduced the credits which could be

explained by the assessee. Considering all these facts, the CIT(A) did not

interfere with the additions made by the AO and dismissed the appeal of

assessee.

before the Tribunal. The Ld. AR of the assessee has mainly relied on the

submissions made before the lower authorities. He submitted that the main

source of income of the assessee was from the petrol pump in the name and

style of M/s. C.D Petroleum. The assessee was also engaged in sale and

purchase of lands during the relevant year under consideration. The income

from trading of land was shown as business income in the profit and loss

account. Advance tax was also paid on such profit, which is reflected in 26AS of

the year. However, the AO has assessed the income from land dealing as short-

term capital gains or long-term capital gains depending on the period of

holding. The assessee had submitted before AO that she had two sources of

income i.e., petrol pump and trading in land. Her monthly income from petrol

pump was Rs.40,000/- to Rs.50,000/-. The profit on sale of land has also been

included in the profit and loss account reproduced by the AO in the

assessment order. Profit on sale of land of Rs.1,71,31,940/- was reflected in

the profit and loss account at page 11 of assessment order. Hence, the AO was

not correct in taxing the profit on sale of land as capital gain.

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

6.1 The Ld. AR also submitted that assessee had filed two written

submissions before the CIT(A) on 23.05.2023 and 31.05.2023. In the said

submissions, the assessee has contested various additions made by the AO.

The AO also did not allow the expenses against the income treated by him as

business income. Assessee also submitted that the AO has wrongly added all

the credits in the bank account which include amounts received from family

members as temporary advances and also loans received from various firms.

There are also transfer entries between different bank accounts whose

benefits were not given and the total credit of all banks have been considered

as income of assessee. The assessee had also withdrawn various amounts in

cash which were used for subsequent cash deposits in the banks, but AO has

made total additions of such deposits. Some credit entries are loans against

fixed deposits from SBI and such credits cannot be income of assessee. The Ld.

AR also submitted that a remand report was called for from the AO which was

submitted by him to the CITI(A) and it has been reproduced in pages 50 to 57

of the appellate order. The appellant was not given copy of the remand report

to offer her comments. The CIT(A) has simply relied on the findings of AO and

dismissed the appeal of assessee. He, therefore, requested that the appellate

order has been passed in the violation of the principles of natural justice.

authorities. He submitted that AO has passed a speaking order after granting

adequate opportunity of hearing to the assessee. He has allowed relief

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

wherever the circumstances so warranted. The assessee did not comply with

various notices issued by the AO. Despite non-compliance by the assessee, the

AO has obtained information from the registering authority and bankc and has

passed the order in a logical manner in accordance with law. Before CIT(A), the

appellant filed two written submissions which were duly forwarded to the AO

for remand report. The CIT(A) after receiving the remand report has

considered all facts on record and passed the appellate order confirming all

the additions because appellant did not support the claims in the written

submission with supporting evidences. Hence, the CIT(A) has rightly upheld

the additions made by the AO and dismissed the appeal.

record. The AO has passed an ex parte order u/s 144 r.w.s. 147 of the Act due

to non-compliance by the assessee to the notices issued by him. He has

collected various information from the Sub Registrar regarding the cost and

year of acquisition of properties sold by the assessee during the year. He has,

thereafter, computed the profit on sale of land as short-term capital gain or

long-term capital gain, depending on the period of holding. However, we find

that the assessee was regularly dealing in sale and purchase of land during the

year. The large number of instances of property dealing, as evident from the

record, makes it clear that the nature of income was business income. The

appellant has carried on the land dealing business in a regular, organised and

systematic manner. The definition of “business” in sub-section (13) of Section

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

2 of the Act is an inclusive one and not exhaustive. The word “business”

connotes some real, substantial and systematic or organized course of

activities or conduct with a set purpose, normally with the objective of making

profit. Whether or not a person carried on business in a particular commodity,

would depend upon the volume, frequency, continuity and regularity of

transactions of purchase and sale of such commodity and the transaction must

ordinarily be entered into with a profit motive. It is seen from the facts on

record that the land transactions entered into by the assessee has all the

ingredients of business. Further, the accountant of appellant had also stated

before the ADIT(Inv.), Unit-2, Vapi in the statement recorded u/s 131(1A) that

the assessee had business income from petrol pump and trading in land.

Hence, we find merit in the contentions raised by the Ld.AR of assessee that

profit on sale of lands should be taxed under the head “Profits and gains of

business or profession” u/s 28 of the Act.

8.1 We find that the appellant has raised grounds on all the additions made

by the AO. The Ld. AR submitted that the appellant is a senior citizen. Her

husband died during the Covid-19 period. She was not in a stable and healthy

mental condition to comply with the notices issued by the CIT(A). The Ld. AR

also submitted that the business has been discontinued and mismanaged. Due

to some legal disputes and investigation, all computer/laptops and related

records were seized by the local authorities. Hence, complete details could not

be furnished before the lower authorities. However, written submissions were

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

duly filed before the CIT(A) explaining the facts of the case and incorrect

additions made by the AO. However, the CIT(A) has upheld all additions made

by the AO.

8.2 We have again perused the records in view of the submissions of the Ld.

counsels. It is seen that the AO has passed an ex parte order u/s 144 r.w.s. 147

of the Act due to non-compliance by the assessee. Before CIT(A), the assessee

filed two written submissions wherein it was submitted that even the business

expenses were not allowed by the AO on the wrong presumption that assessee

was not doing any business. The fact of the matter was that assessee actually

carried on business of petrol pump and land dealing during the subject year.

Further, all credits were considered as income of assessee ignoring the fact

that temporary advances were received by assessee from family members and

other firms. The assessee had also received loans from SBI against fixed

deposits, which were also considered as unexplained income. Further, the

papers found M/s Alkem Laboratories Ltd. was unsigned and did not bear the

name of the assessee. These facts were explained to the CIT(A) by the assessee

vide two written submissions (supra), who rightly forwarded the submissions

to the AO for remand report. The AO, in the remand report, objected to the

admission of additional evidence and has also reiterated the same reasons

given in the assessment order to contend that additions were made because

assessee did not produce any relevant documents/evidences before him.

However, we find that the CIT(A) has not forwarded a copy of the remand

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel

report to the assessee to file her rejoinder. The impugned appeal has been

filed by the assessee and she was entitled to rebut the objections of AO in the

remand report. However, the appellant was not given any opportunity by the

CIT(A) to file rejoinder to the remand report. The CIT(A) passed the appellate

order without eliciting reply of assessee on the remand report of the AO.

Further, the assessee also could not furnish details because the records were

seized by the local authorities. Hence, objection to additional evidence by

revenue is not proper. Further, on a conjoin reading of section 250 and Rule

46A, we find that the restrictions placed on appellant to produce evidence do

not affect the power of CIT(A) u/s 250(4) of the Act to make further enquiry as

he thinks fit before disposing of an appeal. Considering all these facts and the

clear statutory provisions, we find that there is clear violation of the principles

of natural justice. Hence, in the interest of justice, we set aside the order of Ld.

CIT(A) and remit the matter back to the file of AO with a direction to pass a

speaking order in accordance with law after granting adequate and reasonable

opportunity of being heard to the assessee. The assessee is also directed to be

vigilant and to furnish all details and explanation as needed by AO by not

seeking adjournment without valid reason. With this direction, the grounds of

appeal raised by the assessee are treated as allowed for statistical purposes.

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel ITA Nos.1036-1038/SRT/2024 (AYs 2013-14, 2014-15 & 2015-16)

facts of the case as well as issues involved in these appeals are same as in

assessee’s own case for AY 2011-12. Hence, for the reasons given in detail in

appeal order for AY 2011-12, the additions made by AO were confirmed. We

have already set aside the order of CIT(A) for AY 2011-12 in ITA

No.1035/Srt/2024 (supra) and restored the matter back to the file of AO for

fresh adjudication in accordance with law. Following the reasons given therein,

the orders of CIT(A) are also set aside and restored to the file of AO for fresh

adjudication after granting adequate and reasonable opportunity to the

assessee.

Order pronounced in accordance with Rule 34 of ITAT Rules, 1963 on 09/06/2025 in the open court. Sd/- Sd/- (SIDDHARTHA NAUTIYAL) (BIJAYANANDA PRUSETH) �याियक सद�य/JUDICIAL MEMBER लेखा सद�य/ ACCOUNTANT MEMBER सूरत /Surat िदनांक/ Date: 09/06/2025 Dkp Outsourcing Sr.P.S*

ITA Nos.1035-1038/Srt/2024 (AYs 11-12,13-14 to 15-16 Chanchalben D Patel आदेश की प्रितिलिप अग्रेिषत/ Copy of the order forwarded to :  अपीलाथीर्/ The Appellant  प्र�यथीर्/ The Respondent आयकर आयुक्त/ CIT  आयकर आयुक्त (अपील)/ The CIT(A)  िवभागीय प्रितिनिध, आयकर अपीलीय आिधकरण, सूरत/ DR, ITAT, SURAT  गाडर् फाईल/ Guard File 

By order/आदेश से, सहायक पंजीकार आयकर अपीलीय अिधकरण, सूरत