DCIT, NEW DELHI vs. SMT. SHALINI GOYAL, DELHI

IN THE INCOME TAX APPELLATE TRIBUNAL ELHI BENCH “G”, NEW DELHI

BEFORE SHRI H.S. SIDHU, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER

I.T.A. Nos. 398 & 399/DEL/2014 A.Yrs. : 2009-10 & 2010-11 DCIT, CENTRAL CIRCLE-5, VS. SMT. SHALINI GOYAL, DELHI 44, ENGINEERS ENCLAVE, ROOM NO. 361, 3RD FLOOR, PITAMPURA, ARA CENTRE, E-2 DELHI – 110 034 JHANDEWALAN EXTENSION, (PAN:AAEPG8998B) NEW DELHI (APPELLANT) (RESPONDENT) AND I.T.A. Nos.465 & 466/DEL/2014 A.Yrs. : 2009-10 & 2010-11 SMT. SHALINI GOYAL, VS. DCIT, CENTRAL CIRCLE-5, 44, ENGINEERS ENCLAVE, DELHI ROOM NO. 361, 3RD FLOOR, PITAMPURA, DELHI – 110 034 ARA CENTRE, E-2 (PAN:AAEPG8998B) JHANDEWALAN EXTENSION, NEW DELHI (APPELLANT) (RESPONDENT)

Department by : Sh. S.S. Rana, CIT(DR) Assessee by : None

ORDER PER H.S. SIDHU : JM

These are the Cross Appeals filed by the Revenue and the Assessee

emanating from the Orders of the Ld. CIT(A)-XXXI, New Delhi relevant to

assessment years 2009-10 & 2010-11. Since the issues involved in these

appeals are common and identical, hence, these appeals were heard

together and are being disposed by this common order for the sake of

convenience.

10) read as under:-

CIT(A) has erred in law in deleting the addition of Rs.

58,79,021/- on account of unexplained cash credit.

CIT(A) has erred in law in deleting the addition of Rs.

2,20,121/- on account of unexplained investment in

jewellery.

grounds of appeal before or during the course of

hearing of the appeal.

11) read as under:-

CIT(A) has erred in law in deleting the addition of

Rs. 1,28,89,000/- on account of unexplained cash

credit.

grounds of appeal before or during the course of

hearing of the appeal.

10) read as under:-

addition of Rs. 18,00,000/- on account of unexplained

credit ignoring the fact that the appellant has submitted

all the documents related such as PAN card, bank

statement etc. to the alleged unexplained credit during

the appellate proceedings. Thus, order of the Ld. CIT(A)

passed merely on surmises and conjectures should be

reversed and addition confirmed by him should be

deleted.

adhoc addition of Rs. 1,50,000/- on account of

unexplained investment in jewellery, without any basis,

arbitrarily and ignoring the fact that the appellant has

submitted during the proceedings that there was no

fresh investment in jewellery and difference in the value

of jewellery due to increase in price only. Thus, order of 3

the Ld. CIT(A) passed merely on surmises and

conjectures should be reversed and adhoc addition

confirmed by him should be deleted.

delete or amend all or any ground of appeal either

before or at the time of hearing.

11) read as under:-

addition of Rs. 43,34,185/- on account of unexplained

investment in jewellery, without any basis, arbitrarily

and ignoring the fact that during the proceedings the

appellant has submitted complete details of owners of

the jewellery found in the locker at the time of search

and their wealth tax returns. Thus, order of the Ld.

CIT(A) passed merely on surmises and conjectures

should be reversed and addition confirmed by him

should be deleted.

delete or amend all or any ground of appeal either

before or at the time of hearing.

REVENUE’S APPEAL - ITA NO. 398/DEL/2014 (AY 2009-10)

centralized consequent upon an action under section 132 of the Income

Tax Act, 1961 on 7.1.2010 in Gee Ispat Group of Cases. A notice under

section 153A of the I.T. Act was issued on 08.11.2010. The return

declaring income of Rs. 4,02,650/- was filed by the assessee on

21.10.2009. Thereafter, a questionnaire issued under section 142(1) on

18.7.2011 alongwith notice under section 143(2) of the Income Tax Act,.

1961. In response thereto, the A.R. of the assessee attended the

assessment proceedings in compliance to notices under section 142(1) &

143(2) of the Income Tax Act, 1961 and furnished information called for

from time to time alongwith necessary documents. After examining the all

the documents the AO completed the assessment u/s. 143(3)/153A

making the following additions/ disallowances.

i) Addition of Rs. 76,79,021/- on account of unexplained cash

credits u/s. 68 of the I.T. Act, 1961.

ii) Addition of Rs. 1,68,000/- on account of house hold

expenses.

iii) Addition of Rs. 3,70,121/- on account of unexplained

investment in jewellery.

preferred an appeal before the Ld. CIT(A), who vide impugned Order

dated 01.11.2013 has partly allowed the appeal of the asseseee.

Assessee are in appeals before the Tribunal.

of appeal raised in the Revenue’s appeal and requested that appeals of

the Revenue may be allowed by cancelling the order of the Ld. CIT(A). To

support his case, he filed the copy of the Written Submission, the

contents of the written submission are reproduced hereunder:-

“Sub: Written Submission in the above case- reg.

In the above case, it is humbly submitted that the following

decisions may kindly be considered:

(Delhi) where Hon'ble Delhi High Court held that where

assessee-company had shown in books unsecured loans of Rs.

2.68 crores and Rs. 2.45 crores from its two directors and it

was explained that money belonged to its own entity and was

routed through directors and Tribunal found that directors

who advanced loan were admittedly not at all men of means

for advancing such huge amount of loan amounting to about

Rs. 5 crores and secondly that assessee even for taking such

huge amount of loan did not want to pay any interest for

which creditors also agreed, Tribunal had rightly, arrived at a

finding of fact, on analysis of all relevant material on record,

that genuineness of transaction had not been established and

assessee-had failed to independently prove same application

money, amount so received was liable to be taxed under

section 68.

(Delhi) where Hon'ble Delhi High Court held that addition

made u/s 68 on account of unsecured loans was justified,

where initial onus of proving the creditworthiness of the

lenders was not discharged by the assessee.

where Hon'ble Supreme Court dismissed SLP against Madras

High Court's ruling that where assessee had not discharged

burden as regards source from which investment had been

made, investment in property was an unexplained investment

and same was rightly added to income of assessee.

CIT Vs R. Mallika [20131 36 taxmann.com 231

(Madras)/[2013] 219 Taxman 244 (Madras)

where Hon'ble Madras High Court held that where assessee

had purchased a property for Rs. 22 lakhs and she had not

discharged burden as regards source from which investment 7

had been made, investment in property was an unexplained

investment and same was rightly added to income of

assessee.

(Allahabad)

Where Hon'ble Allahabad High Court held that tribunal was

justified in holding that amount of loan received by assessee

was unexplained income u/s 68 in as much as identity,

genuineness, creditworthiness of the transaction is not

proved.

taxmann.com 292, 214 Taxman 429, 350 ITR 407, 256 CTR

34)

where Hon'ble Delhi High Court held that where assessee

failed to prove identity and capacity of subscriber companies

to pay share application money, amount so received was

liable to be taxed under section 68.

where Hon'ble Delhi High Court held that if AO doubts the

documents produced by assessee, the onus shifts on assessee

to further substantiate the facts or produce the share

applicant in proceeding.”

Registered AD post, in spite of the same, assessee, nor her authorized

representative appeared to prosecute the matter in dispute, nor filed any

application for adjournment. Keeping in view the facts and

circumstances of the present case and the issue involved in the present

Appeal, we are of the view that no useful purpose would be served to

issue notice again and again to the assessee, therefore, we are deciding

the present appeals exparte qua assessee, after hearing the Ld. DR and

perusing the records.

laws relied upon by Ld. DR. After going through the case laws cited by the

Ld. DR, we are of the view that the same are on the distinguished facts

and circumstances of the case and hence, are not applicable in the

present case. However, we find that Ld. First Appellate Authority has

elaborately discussed the issues in dispute by considering the

submissions of the Ld. Counsel of the assessee and adjudicated the

issues in dispute from page no. 7 to 10 of the impugned order. The

relevant finding of the Ld. CIT(A) is reproduced as under:-

“4.10.1 The AO has picked up 10 credit entries from the

bank account and mentions in the order that no details

about these entries have been filed to explain these

transactions. He recalls that vide questionnaire dated

18.07.2011 the assessee was required to explain the

credit transactions appearing in the bank A/c and since

no details have been filed, he proceeded to hold the

same as unaccounted income of he assessee and added

it to the total income. The relevant para of the

assessment order is reproduced below:

From the details of bank account of the assessee, it is

seen that the assessee raised unsecured loan from

some person/entities during the relevant previous years

out of which certain accounts were squared up. Net

amount of found received is detailed as under:

14-05-2008 2000000/-

31-05-2005 100000/-

06-06-2008 300000/-

10-06-2008 1834021/-

12-06-2008 220000/-

05-09-2008 1500000/-

10-10-2008 200000/-

10-11-2008 1100000/-

29-01-20013 100000/-

25-02-2009 325000/-

Total 7679021/-

No details are filed by the assessee to explain these

credit Transactions, In the course of assessment

proceedings, vide questionnaire dated 18-07-2011, the

assessee was asked to explain the credits transactions

appearing in the bank accounts, No details have been

filed to substantiate the transactions of credits

appearing in the bank account. The assessee in this way

has failed to justify the amount of Rs.7679021/-credited

to her bank account It is pertinent to mention that the

fund raised have been put to use by the assessee in

making investment for purchases of property. In the

course of assessment proceedings, no address of any

person/entity has been provided so as to verify the

genuineness of the entities/persons. Identity of these

person is not proved by the assessee by furnishing any

documentary evidence. No documents are produced to

substantiate and transactions made with this entities.

Therefore amount of Rs. 7679021/- credited to the bank

account of the assessee, is considered being

unexplained funds belonging to the assessee introduced

in her bank account. No account details of this entity

are filed in this office in the course of assessment

proceedings nor has any person been produced to

justify the transactions and to explain the genuineness

of the transactions and source of funds.

Creditworthiness of these entities/ person has also not

been proved by furnishing documents in respect of

financial status of these person/ entities. Therefore,

source of funds credited in the bank account of the

assessee is held as unexplained and unsubstantiated

being unexplained cash credits in the bank account of

the assessee.

4.10.2 The AR has submitted that most of the entries

listed by the AO in his order are in respect of

transactions with her husband which have been duly

reflected in the books of accounts as well as in his bank

accounts. A chart has been given by the AR at Page 25

of the paper book giving the name of the person with

whom transaction has been entered into. From the

same it is seen that 7 out of 10 transactions are in

respect of funds transferred from bank account of her

husband Mr. Sawar Mal Goyal, 2 entries relate to

amounts received from Mr. Rajesh Gautam and one

entry relates to transaction with Ms. Sonia Bassi. The

husband of the appellant (Mr. Sawar Mal Goyal) is also 12

assessed to tax by the same AO. The Canara Bank

account copy of Mr. Sawar Mal Goyal filed at Page 11 to

17 of paper book duly contains the entries for having

transferred funds to the assessee's bank account

maintained in the same branch (Wazirpur) of Canra

Bank. At page 9 of the paper book, the appellant has

also filed the confirmation from her husband which

contains all the 7 entries mentioned by the, AO. Hence,

I do not find any merit in holding these amounts as

unexplained., The questionnaire of 18.07.2012 is a

general questionnaire touching upon several points. As

such there is no query asking the appellant to explain

and substantiate each and every entry in the bank

statement. As regards amount received from Mr. Rajesh

Gautam, the confirmation is available at Page 26 of the

paper book. The AR has 'also placed the PAN card copy

of Ms. Sonia Bassi along with her bank account

statement at Pages 27 & 28. However, there is no

description of transaction or confirmations from Ms.

Sonia Bassi. In view of this it has to be held that the

appellant has discharged her onus in respect of amounts

received from her husband and Mr. Rajesh Gautam.

However, in respect of Ms. Sonia Bassi no confirmation

has been filed. Therefore it cannot be said that the

appellant has discharged her preliminary onus on this

entry. Considering all the factors, I confirm the addition

of Rs.18 lacs supposed to be relating to Ms. Sonia Bassi

as unexplained since no confirmation has been filed

either at the assessment stage or at the appeal stage.

The balance addition made under this head is hereby

deleted. ……

…..4.12 Unexplained investment in jewellery

4.12.1 The AO has made an addition of Rs.

3,70,121/- as unexplained investment in jewellery. He

has observed that there is a rise in the value of

jewellery by Rs. 3.70 lacs in the return of wealth filed

for the present assessment year as compared to the

return filed for A.Y. 2008-09. The AO has noted that the

assessee has not submitted ,any details showing the

source of funds used in acquiring the extra jewellery.

Therefore, he has brought to tax Rs. 3,17,121/- as

unexplained income in the hands of the assessee

representing unexplained investment in jewellery. The

AR has submitted that the difference in the total

jewellery declared in the Wealth Tax Return of A.Y.

2008-09 & 2009-10 was due to increase in the value of

jewellery and as such there was no purchase of

jewellery during the year. He therefore submitted that

there is no case of holding that any undisclosed

investment has been made in the jewellery.

4.12.2 I have considered the submissions of the

AR. Nothing of substance have been submitted during

the appeal proceedings to show that the difference in

the value of amount of jewellery shown in the Wealth

Tax Return of A.Y. 2008-09 and 2009-10 was on

account of difference in the valuation of the jewellery.

No valuation report has been submitted nor any list has

been. submitted showing item wise increase in the value

ofjewellery. In view of this I do not find any demerits in

the action of the AO.

The addition therefore is deserves to be retained. It is

however, noted that even in the absence of

documentary evidences it cannot be completely denied

that-there could be increase in the value of the

jewellery held by the appellant due to appreciation in

the price of gold. The standard gold rate was Rs.

12,280/- for 10 gms of 24 carat gold as on 31.03.2008

which, had increased to Rs. 15,105/- for 10 gms of24

carat gold. Thus there is increase in the price of gold

during the financial year 2009-10 by about Rs. 2,825/-

which comes to 23% on the price prevailing as on

01.04.2008. However, the appellant has shown increase

in the total value of jewellery by almost 42%

(Rs.3,70,121 / Rs. 89,40,67 x 100) which definitely is

on the higher side. Further, the appellant has failed to

submit any documents in this regard. The AO also does

not seems to have taken up assessment of Wealth Tax

of the appellant. In this background, I am of the view

that ends of justice would be met if the addition is

restricted to Rs. 1,50,000/- and the balance is deleted.

AO is directed to restrict the addition on this issue to Rs.

1,50,000/- only.”

that most of the entries listed by the AO in his assessment order are in

respect of transactions with assessee’s husband which have been duly

reflected in the books of accounts as well as in his bank accounts. We

note that 7 out of 10 transactions are in respect of funds transferred from

bank account of assessee’s husband Mr. Sawar Mal Goyal, 2 entries relate

to amounts received from Mr. Rajesh Gautam and one entry relates to

transaction with Ms. Sonia Bassi. The husband of the assessee (Mr. Sawar

Mal Goyal) is also assessed to tax by the same AO. The Canara Bank

account of Mr. Sawar Mal Goyal contains the entries for having

transferred funds to the assessee's bank account maintained in the same

branch (Wazirpur) of Canra Bank. The confirmation from assessee’s 16

husband which contains all the 7 entries mentioned by the, AO. As

regards amount received from Mr. Rajesh Gautam, the confirmation is on

record. There is no description of transaction or confirmations from Ms.

Sonia Bassi. In view of this it was rightly held by the Ld. CIT(A) that the

assessee has discharged her onus in respect of amounts received from

her husband and Mr. Rajesh Gautam. However, in respect of Ms. Sonia

Bassi no confirmation has been filed. Therefore it cannot be said that the

assessee has discharged her preliminary onus on this entry. Considering

all the factors, we are of the considered view that Ld. CIT(A)’s action in

confirming the addition of Rs.18 lacs was relating to Ms. Sonia Bassi as

unexplained since no confirmation has been filed either at the assessment

stage or at the appeal stage. The balance addition made under this head

was rightly deleted, which does not need any interference on our part,

hence, we uphold the action of the Ld. CIT(A) on the addition in dispute

and dismiss the ground no. 1 raised by the Revenue.

13.1 With regard to addition on account of unexplained investment in

jewellery is concerned, we find that the AO has made an addition of

Rs. 3,70,121/- as unexplained investment in jewellery. It was observed

that there is a rise in the value of jewellery by Rs. 3.70 lacs in the return

of wealth filed for the present assessment year as compared to the return

filed for A.Y. 2008-09. The AO has noted that the assessee has not

submitted any details showing the source of funds used in acquiring the

extra jewellery. Therefore, he has brought to tax Rs. 3,17,121/- as

unexplained income in the hands of the assessee representing 17

unexplained investment in jewellery. We note that before the Ld. CIT(A)

the AR has submitted that the difference in the total jewellery declared in

the Wealth Tax Return of A.Y. 2008-09 & 2009-10 was due to increase in

the value of jewellery and as such there was no purchase of jewellery

during the year. He therefore submitted that there is no case of holding

that any undisclosed investment has been made in the jewellery. We

further note that nothing of substance have been submitted during the

appeal proceedings to show that the difference in the value of amount of

jewellery shown in the Wealth Tax Return of A.Y. 2008-09 and 2009-10

was on account of difference in the valuation of the jewellery. Also no

valuation report has been submitted nor any list has been submitted

showing item wise increase in the value of jewellery. However, it was

noted that even in the absence of documentary evidences it cannot be

completely denied that there could be increase in the value of the

jewellery held by the assessee due to appreciation in the price of gold.

The standard gold rate was Rs. 12,280/- for 10 gms of 24 carat gold as

on 31.03.2008 which, had increased to Rs. 15,105/- for 10 gms of24

carat gold. Thus there is increase in the price of gold during the financial

year 2009-10 by about Rs. 2,825/- which comes to 23% on the price

prevailing as on 01.04.2008. However, the assessee has shown increase

in the total value of jewellery by almost 42% (Rs.3,70,121 ÷

Rs. 89,40,67 x 100) which definitely is on the higher side. Further, the

assessee has failed to submit any documents in this regard. The AO also

does not seems to have taken up assessment of Wealth Tax of the

appellant. In this background, Ld. CIT(A) has rightly held that the addition

is restricted to Rs. 1,50,000/- and the balance is deleted and directly the

AO to restrict the addition on this issue to Rs. 1,50,000/- only, which

which does not need any interference on our part, hence, we uphold the

action of the Ld. CIT(A) on the addition in dispute and accordingly, the

dismiss the ground no. 2 raised by the Revenue. In the result, the Appeal

of the Revenue stands dismissed.

REVENUE’S APPEAL - ITA NO. 399/DEL/2014 (AY 2010-11)

centralized consequent upon an action under section 132 of the Income

Tax Act, 1961 on 7.1.2010 in Gee Ispat Group of Cases. A notice under

section 142(1) was issued on 7.7.2011. The return declaring income of

Rs. 3,03,480/- was filed by the assessee on 31.3.2011. Thereafter, a

questionnaire issued under section 142(1) on 19.9.2011 alongwith notice

under section 143(2) of the Income Tax Act,. 1961. In response thereto,

the A.R. of the assessee attended the assessment proceedings in

compliance to notices under section 142(1) & 143(2) of the Income Tax

Act, 1961 and furnished information called for from time to time

alongwith necessary documents. After examining the all the documents

the AO completed the assessment u/s. 143(3)/153A making the following

additions/ disallowances.

i) Addition of Rs. 1,28,89,000/- on account of unexplained cash

credits u/s. 68 of the I.T. Act, 1961.

ii) Addition of Rs. 1,80,000/- on account of house hold

expenses.

iii) Addition of Rs. 43,34,185/- on account of unexplained

investment in jewellery.

preferred an appeal before the Ld. CIT(A), who vide impugned Order

dated 01.11.2013 has partly allowed the appeal of the asseseee.

Assessee are in appeals before the Tribunal.

of appeal raised in the Revenue’s appeal and requested that appeals of

the Revenue may be allowed by cancelling the order of the Ld. CIT(A). To

support his case, he reiterated the Written Submission as mentioned

above.

laws relied upon by Ld. DR. After going through the case laws cited by the

Ld. DR, we are of the view that the same are on the distinguished facts

and circumstances of the case and hence, are not applicable in the

present case. However, we find that Ld. First Appellate Authority has

elaborately discussed the issues in dispute by considering the

submissions of the Ld. Counsel of the assessee and adjudicated the

issues in dispute in the impugned order. The relevant findings of the Ld.

CIT(A) are reproduced as under:-

“4.10.1 While making the addition of Rs. 1,28,89,000/-,

the AO has noted as under:-

That the appellant did not file any details to explain the

credits appearing in bank accounts. Even though the

assessee was required to produce the lenders vide order

sheet entry dated 16/12/2011, no one was produced

before him.

No details have been furnished to substantiate the

credit transactions appearing in the bank account.

No address of the lenders have been provided.

Identity of the persons have not been proved by

furnishing the documentary evidences.

No documents have been furnished justifying the

advance against property.

4.10.2 In the absence of a remand report on the issue, I

have perused the assessment records. It is seen from

the assessment records that the appellant had furnished

confirmations, ITR copies and bank statement of the

lenders. Each confirmation contained the PAN of the

lender. These documents are part of the assessment 21

folder The AO has not taken any action on the same.

From the noting of the AO on the letter of the assessee

dated 16/12/2011 available in the assessment folder

(copy made as Annexure A to this order) it is observed

that the AO mentions as under in four lines:

Order sheet

16/12/2011

None was

Produced

4.10.3 The AR has submitted that the AO never asked

for any further details and this is also evident from the

noting of the AO as above. He has merely come to the

conclusion that no one was produced before him. The

AR submitted that all the evidences which were

available with the assessee in order to establish the

genuineness of the loans taken were furnished before

the AO which also contained the PAN. All the

transactions were very appearing in the bank accounts.

Since no further query was raised by the AO, the

appellant’s AR might not have submitted are details to

the AO. He further submitted that the all the details

have been submitted during the appeal proceedings

along with the additional evidences. The AO has not

given any report on the same. He therefore submitted

that it would be a miscarriage of justice if addition is

made inspite of providing complete details of the

lenders and their confirmations.

4.10.4 There is no way to rebut the claim of the AR that

the AO has not raised any further query after receiving

the confirmations etc. from the appellant's AR. There is

no record to show that he requested the appellant to

make any further submissions. The assessment order

does not give true picture of the proceedings as it is

incorrect to say that no details of the credit transactions

were filed when the assessment folder itself contains

confirmations, bank statements, ITR copies of the

lenders. During the appeal proceedings the

confirmations, bank statements, ITR copies submitted

by the AR have been forwarded to the AO with a

request to verify the same and submit his reort after

necessary inquiries. The required report has not been

submitted.

4.10.5 I find that the confirmations bear PAN of the

lenders. The transactions have been routed through

banking channels. In this background I do not find any

merit in sustaining the addition made uls 68. The AO is

required to proceed against the lenders if they were

found to be without adequate source justifying the

loans. During the assessment proceedings very. little

has been done by the AO to transfer the onus back to

the assessee if he was not satisfied with any matter.

There are no evidences to show that he wanted to

appellant to lead further evidences to satisfy any of his

doubts. In this background the addition of

Rs. 1,28,89,000/- made as unaccounted income of the

assessee cannot be sustained. The same is hereby

deleted.”

that the assessee did not file any details to explain the credits appearing

in bank accounts. Even though the assessee was required to produce the

lenders vide order sheet entry dated 16/12/2011, no one was produced

before him. No details have been furnished to substantiate the credit

transactions appearing in the bank account. No address of the lenders

have been provided. Identity of the persons have not been proved by

furnishing the documentary evidences. No documents have been

furnished justifying the advance against property. It was seen from the

assessment records that the assessee had furnished confirmations, ITR

copies and bank statement of the lenders. Each confirmation contained

the PAN of the lender. These documents are part of the assessment folder 24

The AO has not taken any action on the same. We find that find that the

confirmations bear PAN of the lenders. The transactions have been routed

through banking channels. In this background Ld. CIT(A) has rightly

observed that the AO is required to proceed against the lenders if they

were found to be without adequate source justifying the loans. During the

assessment proceedings very little has been done by the AO to transfer

the onus back to the assessee if he was not satisfied with any matter.

There are no evidences to show that he wanted to assessee to lead

further evidences to satisfy any of his doubts. In this background the Ld.

CIT(A) has rightly deleted the addition of Rs. 1,28,89,000/- made as

unaccounted income of the assessee, which does not need any

interference on our part, hence, we uphold the action of the Ld. CIT(A)

on the addition in dispute and dismiss the ground no. 1 raised by the

Revenue.

ASSESSEE’S APPEAL ITA NO. 465-466/DEL/2014 (AYRS. 2009-10 & 2010-11)

we have already dismissed the Revenue’s Appeals by upholding the

respective orders of the Ld. First Appellate Authority, hence, both the

Assessee’s Appeals have become infructuous and dismissed as such.

the Assessee stand dismissed in the aforesaid manner.

Order pronounced on 19/05/2017.

Sd/- Sd/-

[PRASHANT MAHARISHI] [H.S. SIDHU] ACCOUNTANT MEMBER JUDICIAL MEMBER

Date 19/05/2017

“SRBHATNAGAR”