TRISHUL SHELTERS PVT LTD.,COIMBATORE vs. DCIT, COIMBATORE

आदेश /O R D E R

PER S. JAYARAMAN, ACCOUNTANT MEMBER:

The assessee filed this appeal against the order of the Commissioner of

Income Tax (Appeals)-1, Coimbatore for assessment year 2012-13.

:-2-: ITA No. 856/Mds/2017

property developers. For assessment year 2012-13, the assessee filed a

return declaring total income of Rs. 28,00,960/- on 26.09.2012. In this

return, it has shown the value of closing stock at Rs. 9,88,81,149/-. A survey

was conducted in the assessee’s premises on 16.10.2012, incriminating

materials were found which revealed that the assessee has incurred Rs.

11,48,99,378 towards the cost of construction of Akash Malli project as on

31.03.2012, however has shown its value in the return already filed with the

Revenue at Rs. 5,95,18,483/- only. In the sworn statement recorded at the

time of survey, the director of the assessee company admitted this fact.

Subsequently, the assessee filed a revised return on 19.10.2012 admitting an

income of Rs. 5,66,10,340/- and altered the value of closing stock as on

31.03.2013 which has cascading effect in the subsequent ays also. In

pursuance of the directions issued u/s. 144A dated 20.03.2015 by the Addl.

CIT, the AO made a reference u/s. 142A to the D.V.O dated 24.03.2015 to

obtain the value of the impugned building. As per section 142A, the valuation

officer shall send a copy of the report of the estimate within a period of 6

months from the end of the month in which a reference is made. Since, the

AO did not receive such report till 07.10.2015, the date of passing the

impugned assessment order, the AO completed the assessment based on

available material. While doing so, the AO held that the assessee has not

disclosed the sources for meeting the cost of construction to the extent of Rs.

:-3-: ITA No. 856/Mds/2017

5,38,09,380/- which remain outside books of account. Therefore, such

sources remain undisclosed. Admitting it as suppression in closing does not

arise, the impugned expenditure is hit by the provisions of section 69C and

hence directed the assessee to adopt the value of closing stock shown in the

original return before the survey at Rs. 9,88,81,491/- as against the value of

clock claimed at Rs. 15,26,90,871/- in the revised return after the survey.

Aggrieved, the assessee filed an appeal before the CIT(A). The CIT(A)

dismissed the appeal.

with following grounds:

“1. The order of the Honourable Commissioner of Income Tax (Appeals) is opposed to law and contrary to the facts of the case and against equity and principles of natural justice. 2. a) The Honourable Commissioner of Income Tax (Appeals) erred in concluding that section 69C would apply even for expenditure that culminates into an investment or asset. b) The Honourable Commissioner of Income tax (Appeals) failed to appreciate the legal distinction embedded in section 69, 69B & 69C of the Act. c) The Honourable Commissioner of Income Tax (Appeals) ought to have followed the decision of Honble Supreme Court in the case of V K J Builders and Contractors Pvt Ltd and directed the assessing officer to determine the value of opening stock in the subsequent financial year accordingly. 3. The Honourable Commissioner of Income Tax (Appeals) omitted to consider the legal ground relating to the validity of the assessment order. In view of the above grounds and such other additional grounds as may be adduced at the time of hearing with the leave of the Honourable Income Tax Appellate Tribunal, the appellant prays before the Honourable Income Tax Appellate Tribunal that;

:-4-: ITA No. 856/Mds/2017

a. The Order of the Honorable Commissioner of Income Tax (Appeals) upholding the action of the learned assessing officer be set aside, b. Directions be given to the learned Assessing Officer not to treat the expenditure as that covered u/s 69C and accordingly retain the opening stock of subsequent financial year unaltered, c. Alternatively, the impugned assessment order be annulment as time barred, and d. Such other consequential orders may be passed as the Honourable Income Tax Appellate Tribunal may deem fit to render justice.”

as under:

“The appellant craves the leave of the Hon'ble Appellate Authority to file the following additional grounds of appeal for the first time. The appellant submits that the failure to raise these grounds was due to inadvertence. The appellant further submits that this omission is not intentional and craves the leave of the Hon'ble Appellate Authority to admit these additional grounds. ADDITIONAL GROUNDS OF APPEAL Ground No.4 For that a direction to revise the value of opening stock of the subsequent year i.e., assessment year 2013-14 in the assessment completed for the assessment year 2012- 13, cannot be given. Ground No.5 For that the assessment completed u/s.143(3) is barred by limitation and not a valid assessment.”

them on merit.

provisions of section 69, 69B & sec. 69C, alternate submission etc., as

:-5-: ITA No. 856/Mds/2017

submitted before the CIT(A) . For convenience sake, the relevant portion is

extracted from the order of the CIT(A) as under:

“Submission with reference to difference between sec 69/69B and sec 69C: o The following table brings the difference between the sections 69/69B/69C: Particulars Sec 69 Sec 69B Sec 69C Nature of Investment Investment, bullion, Expenditure outflow jewellery, valuable article Conditions Investment not Investment etc., not - recorded in the fully recorded in the books. books.

Source of Source for the Source of investment not excess investment expenditure not explained to the not explained to the explained to the satisfaction of AO satisfaction of AO satisfaction of AO Outcome Such investment Such Excess Such expenditure may be deemed as investment may be may be deemed income deemed as income as income. Additional Such expenses condition cannot be claimed as deduction

o Its submitted that from the above table, it could be seen that the additional condition is not found in the case of investment, etc. It applies only to expenditure. This additional condition is because of insertion of proviso to sec 69C. o Its is submitted that order prior to insertion of the additional condition mentioned above, by the Finance Act, 1998, the expenditure in respect of which the source was not proved was also south to be claimed as revenue deduction u/s. 37 whereby the addition made u/s. 69C does not in effect survive at all. o In other words, where any business expenditure (say – like, rent, wages etc) was incurred outside books and the sources for the same was not satisfactorily explained, upon being found by the AO, the assessee used to claim the deduction of the same expenditure u/s. 37, etc after the expenditure gets taxation u/s. 69C. In effect, the addition made u/s. 69C gets neutralized by seeking deduction u/s. 37, etc. o This practice of seeking deduction was enclosed by the courts as well. To discourage the said practice the amendment was made in sec 69C by inserting a proviso whereby the expenditure could not be claimed as deduction so as to make the addition as NIL.

:-6-: ITA No. 856/Mds/2017

o The memorandum explaining the provisions of the Finance (nO.2) Act 1998 dealing with the insertion of the Explanation below sec 69C read as under (235 ITR ST 35): 29.1 Under the existing provision, where an expenditure incurred by the taxpayer in respect of which he either offers no explanation regarding the source of such expenditure or where explanation offered is found unsatisfactory, the expenditure is treated as “income” under section 69C. There is no corresponding provision for disallowance of such expenditure. 29.2 This used to enable the taxpayer charged to tax under section 69C to claim the expenditure as deduction under section 37 defeating the very objective of the section. 29.3 The Act has amended section 69C of the Income Tax Act according to which unexplained expenditure deemed as income cannot be allowed as deduction under any head of income. 29.4 This amendment will take effect from 1st day of April, 1999, and will, accordingly, apply in relation the assessment year 1999-2000 and subsequent years. o It is submitted that the proviso introduced in sec 69C was not corresponding introduced in the sec 69/69A/69B. o Therefore, it is submitted that the proviso would apply only in respect of the cases where there is expenditure without creating an investment or asset. o If the intention of the legislature is to apply the said proviso to sec 69/69B of the Act, the legislature might have very well introduced the similar proviso in those sections as well. o It is submitted that in the absence of the proviso in sec 69/69B, it is impermissible to borrow the principle in sec 69V to sec 69/69B also. o It needs mention here that any investment made or assets acquired would be only by incurring the expenditure. If one extends the theory that the expenditure incurred for creation of the asset would also by hit by the provisions of sec 69C, it would amount to indirectly introducing the proviso to sec 69/69B as well. o In view of the above, it is respectfully submitted that the proviso would apply to the expenditure incurred without creating any investment or asset and NOT to those outflow where the expenditure results in creation of the assets. o Therefore, it is also submitted that the expenditure incurred for creation of inventory, in the case of appellant, would not be hit by sec 69C of the Act. Submission with reference to double disallowance :

:-7-: ITA No. 856/Mds/2017

o As already submitted, the intention of the proviso is to deny the benefit of deduction in the case where the assessee seeks to neutralize the addition made u/s. 69C. o However, the learned Assessing Officer, in the instant case, holds that the amount incurred for creation of inventory would not be allowed to be counted for valuation of inventory at all. This would result in denying further deduction as well. o This fact could be seen from the following example: a) Mr. A purchases inventory for Rs. 100000/- b cash b) The said inventory was sold for Rs. 110000/- c) The provisions of sec 40A(3) was applied in respect of the purchase of Rs. 100000/- incurred in cash and the same was disallowed. In other words, he pays tax on this Rs. 100000/- d) While assessing the income on sale of such inventory for Rs. 110000/-. It would be proper to say that he had to pay tax on the income of Rs. 10000/- being profit on sale of the inventory. e) However, if the cost of purchase of Rs. 100000/- was denied deduction while computing the profit on sale, on the ground that the purchase was already disallowed and consequently treating the cost of inventory as NIL, the entire Rs. 110000/- would be taxable. f) This would result in Mr. A paying tax on Rs. 100000/- by invoking sec 40A(3) and also paying tax on Rs 110000/- on the entire sale price as deduction for purchase is denied. g) This would result in double taxation, which is not permissible in law o It is submitted that this principle can be seen from the other angle also as illustrated in the following lines: a) In the case of survey, the inventory was found to be more than – say Rs. 10 lacs – the amount recorded in the books of account. b) The assessee agrees for the excess inventory and pays the tax on Rs. 10 lacs. c) Subsequently, the inventory was sold for Rs. 11 lacs. d) The assessee pays the tax on Rs. 1 lacs. e) It may not be proper to say that the assessee had paid tax on the inventory of Rs. 10 lacs u/s. 69C and therefore, the said amount of Rs. 10 lacs could not be deductable from the sale price of Rs. 11 lacs. f) If such a view is accepted, the assessee would be compelled to pay tax on Rs. 10 lacs for the cost of inventory found during the survey and the

:-8-: ITA No. 856/Mds/2017

entire sale price of Rs. 11 lacs being sale price of such inventory where the cost of such inventory being denied deduction. g) Such a proposition is not permissible in law. o In view of the above, it is submitted that the provisions of section 69C would not apply to inventory. o In other words, applying the provisions of section 69C to inventory would result in double disallowance. o It is therefore submitted that the action of the learned Assessing Officer in applying the provisions of section 69C to inventory is not in accordance with law. Submission with reference to adjusting the opening stock of next year: o It is submitted that whenever, the value of the closing stock is increased in the assessment, by making addition, the value of the opening stock is to be correspondingly increased for ascertaining the correct profit of the subsequent year. o This view that the corresponding adjustment in the opening stock of the subsequent year required to be made compulsorily was endorsed by the Hon. Supreme Court in the case of M/s. V K J Builders and Contractors P Ltd – 318 ITR 204 (2009) o In the instant case, the appellant had increased the value of the closing stock in the revised return instead of the Assessing Officer estimating the value of the closing stock in the assessment. o Applying the same principle enunciated by the Hon. Supreme Court mentioned above, when the value of the closing stock is increased, the opening stock of the appellant in the following year is also to be increased correspondingly. o It is therefore, submitted that the action of the learned Assessing Officer directing the appellant to remove the incremental value in the opening stock of the appellant for the next year is not in accordance with law. Alternative submission: o It is submitted that the learned Assessing Officer on 24.03.2015 referred the building for valuation u/s. 142A to the DVO in terms of the direction made by the Additional CIT u/s. 144A. o As a result thereof, the time limit for completion of the assessment got extended from 31.03.2015 to 07.10.2015 o However, the DVO report was not made available to the learned Assessing Officer till the completion of the assessment u/s. 143(3), i.e., 07.10.2015. The report of the DVO was dated only on 14.10.2015.

:-9-: ITA No. 856/Mds/2017

o The purpose of extension of the time limit by making reference to DVO u/s. 142A is only to avail the benefit of ascertaining the cost of construction estimated by the DVO. o However, the assessment was completed on 07.10.2015 ( being the last date for completion of the assessment) without having the report of the DVO. o In other words, the order of assessment was passed on 07.10.2015 without the valuation report of DVO. o When the valuation report of DVO itself was not available at the time of framing the assessment, the extended time limit would not be available to the learned Assessing Officer. o In such a case, it is submitted that the order passed by the learned Assessing Officer is time barred and non-est in law.”

relevant portion of the order of the CIT(A) is extracted as under:

“5. I have considered the submission of the assessee and the assessment records. In this case, during the couser of survey, a statement was recorded from the Director of the company, Smt. RukminiKarthkeyan by confronting her with the impounded material and she had deposed that the actual amount for construction of AkashMalli project is Rs. 11,98,99,388/-. However, in the return it was shown as Rs. 5,53,80IA,895/- and actual amount suppressed is Rs 5,38,09,380/-. The assessee company has admitted the suppressed amount in the revised return filed on 19.10.2012 subsequent to the survey. Therefore, it is clear that the assessee company has made expenditure outside the books of account and the sources for the expenditure remains unexplained during the course of the assessment and even during the course of appellate proceedings. The sources for meeting the expenses is definitely from the assessee company’s undisclosed source and it was treated by the Assessing Officer u/s. 69C of the Act and accordingly it was not allowed to be added to the closing stock adopted before the survey. 6. The appellant’s contention that the provisions of section 69C would apply only in respect of cases where the expenditure is without creating an investment or asset is not acceptable as section 69C does not categorically state so. When the section clearly states that the unexplained expenditure is deemed to be income of the assessee and shall not be allowed as deduction under any head of income, it cannot be taken as only for expenditure without creating an investment or asset.

:-10-: ITA No. 856/Mds/2017

The assessee is directed to adopt the closing stock of Rs. 9,88,81,491/- as on 31.03.2012 and revise the value of opening stock adopted in the return of income for the assessment year 2013-14 as Rs. 9,88,81,491/- instead of Rs. 15,26,90,871/-.”

The assessee is a flat promoter and property developer. It had actually

incurred Rs. 11,48,99,378/- towards the cost of construction of Akash Malli

Project as on 31.03.2012 but in its books it has shown this expenditure

:-11-: ITA No. 856/Mds/2017

under the head closing stock at Rs. 5,95,18,483/- only. The assessee has

admitted at the time of survey that it has suppressed the value of closing

stock by Rs. 5,38,09,380/-. After the survey, it filed a revised return

admitting the suppressed value at Rs. 5,38,09,380/- as an income. However,

the assessee could not explain the nature and sources of the impugned

expenditure incurred towards suppression of the value of closing stock at Rs.

5,38,09,380/-. Hence, the AO invoked section 69C and refused to allow the

altered value of closing stock shown after the survey at Rs. 15,26,90,871/-

and directed the assessee to adopt the value of closing stock at Rs.

9,88,81,491/- as was shown in the original return, filed before the survey as

the assessee has not explained the sources for the impugned cost of

construction. The CIT(A) has confirmed the action of the AO. Now , let us

examine the provisions of section 69C. The relevant portion of the provision

is extracted as under:

“69C. Unexplained expenditure, etc.

Where in any financial year an assessee has incurred any expenditure and he offers no explanation about the source of such expenditure or part thereof, or the explanation, if any, offered by him is not, in the opinion of the Assessing Officer, satisfactory, the amount covered by such expenditure or part thereof, as the case may be, may be deemed to be the income of the assessee for such financial year:

Provided that, notwithstanding anything contained in any other provision of this Act, such unexplained expenditure which is deemed to be the income of the assessee shall not be allowed as a deduction under any head of income.”

Thus, the issue is whether the impugned cost of construction is an

expenditure or not. As pointed out above, since the assessee is a flat

:-12-: ITA No. 856/Mds/2017

promoter, the impugned cost of construction represented various

expenditures incurred towards the Akash Malli project. On sale of such flats

etc., the receipts would be credited to the P&L a/c. The difference between

the credits and debits only would be offered as income at the year end.

Hence, the impugned construction cost is nothing but an expenditure , the

nature and sources of which the assessee has not explained . Hence , the

AO has deemed it to be income of the assessee u/s. 69C. The proviso to sec

69C makes it clear that notwithstanding anything contained in any other

provision in this Act, such unexplained expenditure which is deemed to be the

income of the assessee shall not be allowed as a deduction under any head of

income. Thus, we do not find any infirmity in the action of the AO and the

action of the CIT(A) in upholding such action. Similar issue came before this

tribunal in the case of Income Tax Officer vs Smt. Sundari Chimand as

reported in 124 ITD 460 . The relevant portion is extracted as under :

“ The facts of the case are that the assessee is a dealer in textiles, readymade garments and dress materials. There was a survey in the premises of the assessee under section 133A of the Act on November 6, 2002. During the course of survey some discrepancies were found in the stock with regard to the valuation. Due to discrepancy, the assessee offered an additional income of Rs. 1.15 crores representing the value of such undisclosed stock. The assessee agreed to offer the said sum of Rs. 1.15 crores in two assessment years, i.e., Rs. 55 lakhs for the assessment year 2002-03 under the head "Income from other sources" and balance of Rs. 60 lakhs as "business income" in the assessment year 2003-04. Thereafter, the assessee filed a revised return for the assessment year 2002-03 offering the said additional income of Rs. 55 lakhs under the head "Income from other sources". This was done by crediting the profit and loss account with the purchases of Rs. 55 lakhs and the corresponding debit for the same reflected under "advance for purchase of an asset" in the balance-sheet as on March 31, 2002. The assessee vide her letter dated December 31, 2002, filed with the return for the assessment year 2002-03 stated that the said sum of Rs. 55 lakhs pending in the advance for purchases would be accounted for as purchases in the subsequent financial year relevant to the assessment year 2003-04. The assessment for the assessment year 2002-03 was completed under section 143(3) of the Income-tax Act on March 12, 2003, accepting

:-13-: ITA No. 856/Mds/2017

and assessing the additional income of Rs. 55 lakhs offered as stated above. The assessee had filed a return of income for the assessment year 2003-04 declaring total income of Rs. 59,74,279 which included the business income of Rs. 59,28,279. In the profit and loss account filed with the return, the assessee had increased the purchases by Rs. 55 lakhs as already stated above and the closing stock as on March 31, 2003, by Rs. 1.15 crores. The Assessing Officer, however, did not accept the accounting treatment given to the additional income offered during the survey and added a further sum of Rs. 1.15 crores to the returned income vide the impugned order dated February 24, 2006, under section 143(3) of the Act. Aggrieved, the assessee preferred an appeal before the Commissioner of Income-tax (Appeals) who deleted the addition of Rs. 1.15 crores. Against this order of the Commissioner of Income-tax (Appeals), the Revenue has filed the present appeal before the Tribunal. ……………………………………………………………………………………

……………………………………………………………………………………..

We have heard both the sides and perused the records available with us. In the present case, there was unexplained investment in the form of stock-in- trade detected by the income-tax authorities by survey under section 133A of the Act on November 6, 2002, to the tune of Rs. 1.15 crores. The assessee, admittedly offered this income as unexplained income of Rs. 55 lakhs for the assessment year 2002-03 and Rs. 60 lakhs for the assessment year 2003-04. Now, the assessee wanted to claim the same as purchases at Rs. 1.15 crores for the assessment year 2003-04 and take advantage of expenditure and reduce the income of the assessee. This is not permitted under the provisions of section 69C of the Act. Section 69C reads as follows:

"69C. Where in any financial year an assessee has incurred any expenditure and he offers no explanation about the source of such expenditureor part thereof, or the explanation, if any, offered by him is not, in the opinion of the Assessing Officer, satisfactory, the amount covered by such expenditure or part thereof, as the case may be, may be deemed to be the income of the assessee for such financial year: Provided that, notwithstanding anything contained in any other provision of this Act, such unexplained expenditure which is deemed to be the income of the assessee shall not be allowed as a deduction under any head of income."

This proviso was inserted by the Finance (No.2) Act, 1998, with effect from April 1, 1999, thereby it prohibits any deduction towards unexplained expenditure which is offered as deemed income under section 69C of the Act. Under section 4 of the Act, the income is to be charged in accordance with the provisions of the Act in respect of the total income of the previous year of every person. As provided by section 5, the total income of any previous year of a person would, inter alia, include all income from whatever source derived which is received or is deemed to be received by such person, subject to the provisions of the Act. It will be seen from section 69C of the Act that where in any financial year the assessee incurs the expenditure thereof and the assessee fails to offer satisfactory explanation to the Assessing Officer, the amount covered by such expenditure may be treated as deemed income of the assessee for such financial year. The scheme of section 69C of the Act, would show that in cases where the nature and source of investments made by the assessee or the nature and source of acquisition of any asset owned by the assessee or the source of

:-14-: ITA No. 856/Mds/2017

expenditure incurred by the assessee are not explained at all, or not satisfactorily explained, then, the value of such investments and money or the value of articles not recorded in the books of account or the unexplained expendituremay be deemed to be the income of the assessee. It follows that the moment a satisfactory explanation is given about such nature and source by the assessee, then the source would stand disclosed and will, therefore, be known and the income would be treated under the appropriate head of income for assessment as per the provisions of the Act. However, these provisions apply because no source is disclosed at all on the basis of which the income can be classified under one of the heads of income under section 14 of the Act. It would not be possible to classify such deemed income under any of these heads including income from "other sources" which have to be sources known or explained. When the income cannot be so classified under anyone of the heads of income under section 14, it follows that the question of giving any deductions under the provisions which correspond to such heads of income will not arise. If it is possible to peg the income under anyone of those heads by virtue of a satisfactory explanation being given, then these provisions of sections 69, 69A, 69B and 69C will not apply, in which event, the provisions regarding deductions, etc., applicable to the relevant head of income under which such income falls will automatically be attracted. The opening words of section 14 "save as otherwise provided by this Act" clearly leave scope for "deemed income" of the nature covered under the scheme of sections 69, 69A, 69B and 69C being treated separately, because such deemed income is not income from salary, house property, profits and gains of business or profession, or capital gains, nor is it income from "other sources" because the provisions of sections 69, 69A, 69B and 69C treat unexplained investments, unexplained money, bullion, etc., and unexplained expenditure as deemed income where the nature and source of investment, acquisition or expenditure, as the case may be, have not been explained or satisfactorily explained. Therefore, in these cases, the source not being known, such deemed income will not fall even under the head "Income from other sources". Therefore, the corresponding deductions which are applicable to the incomes under any of these various heads, will not be attracted in the case of deemed incomes which are covered under the provisions of sections 69, 69A, 69B and 69C of the Act in view of the scheme of those provisions. It is therefore, clear that when the investment was not recorded in the books of account and the assessee failed to offer satisfactory explanation about the nature and source of such investment, or such investment was not recorded in the books of account nor the nature and source of its acquisition explained, there could arise no question of treating the value of such investments, which was deemed to be the income of the assessee, as deductible purchases in the financial year, such deemed income did not fall under the head "Profits and gains of business or profession." In our opinion, the Commissioner of Income-tax (Appeals) was not justified in holding that the value of such unexplained stock was liable to be included as purchases in the final account of the assessee as explained source of purchases and the assessee was not entitled to claim that the value of stock should be allowed as deduction from his income. Accordingly, we reverse the order of the Commissioner of Income-tax (Appeals) on this issue and restore that of the Assessing Officer. In the result, the appeal of the Revenue is allowed “.

Thus, the above order also fortifies our stand taken , supra.

:-15-: ITA No. 856/Mds/2017

barred by limitation, we find that the AO has made a reference u/s. 142A to

the DVO on 24.03.2015. Clause v to Explanation 1 of section 153 has

provided that for the purposes of computing the period of limitation for

assessment , the period commencing from the date on which the Assessing

Officer makes a reference to the Valuation Officer under sub-section (1) of

section 142A and ending with the date on which the report of the Valuation

Officer is received by the Assessing Officer shall be excluded. The AO noticed

that as per sub-section (6) of section 142 A, the Valuation Officer shall send a

copy of the report of the estimate made under sub-section (4) or sub-section

(5), as the case may be, to the Assessing Officer and the assessee, within a

period of six months from the end of the month in which a reference is made

under sub-section (1). Such period was over as on 30.9.2015. However , the

AO has not received any report from the VO till 07.10.2015 . Hence, based

on the available material , the AO completed the assessment well within the

period permitted u/s 153 and hence we do not find any infirmity in the order

of the CIT(A) when he dismissed the corresponding appeal grounds of the

assessee. Corresponding grounds fail.

:-16-: ITA No. 856/Mds/2017

Order pronounced on Monday, the 05th day of February, 2018 at Chennai.

Sd/- Sd/- (एन.आर.एस. गणेशन) (एस जयरामन) (N.R.S. GANESAN) (S. JAYARAMAN) !या�यक सद"य/Judicial Member लेखा सद"य/Accountant Member

चे�नई/Chennai, 1दनांक/Dated: 05th February, 2018 JPV आदेश क' *�त2ल3प अ4े3षत/Copy to: 1. अपीलाथ&/Appellant 2. *+यथ&/Respondent 3. आयकर आयु5त (अपील)/CIT(A) 4. आयकर आयु5त/CIT 5. 3वभागीय *�त�न�ध/DR 6. गाड7 फाईल/GF