DCIT, CHENNAI vs. M/S. GOLDEN SHELTERS PVT. LTD., CHENNAI

आदेश / O R D E R

Per A. Mohan Alankamony, AM:-

These appeals by the Revenue are directed against the

order passed by the learned Commissioner of Income Tax

(Appeals)-6, Chennai all dated 08.06.2016 in ITA No.

163/CIT(A)-6/2010-11, 284/CIT(A)-6/2014-15, 157/CIT(A)-

6/2009-10, 285/CIT(A)-6/2014-15, 198/CIT(A)-6/2013-14,

289/CIT(A)-6/2014-15 passed U/s.250(6) of the Act.

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company engaged in the activity of promoting projects, construction, investment and maintenance of flats, public residential complex, building choultries, dharmasalas, meditation

halls, old age homes, orphanages, yoga, spiritual classes etc. It was observed by the Ld.AO that the assessee company was receiving donations from various persons towards infrastructure

development, however failed to offer the same for taxation. Therefore the assessment for all the aforesaid assessment years were either taken up for scrutiny or reopened and reassessed.

3.1 The Revenue has raised various grounds in all its appeals in the case of the assessee; however the concise grounds are framed and stated herein below for adjudication.

3.2 ITA No.2341 of 2016, Assessment Year 2005-06:- The only issue raised in the appeal is that the Revenue is

aggrieved by the order of the Ld.CIT(A), who had followed the logic adopted in the order passed U/s.143(3) of the Act for the assessment year 2006-07 in the case of the assessee by

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granting relief of 25% of the addition made towards anonymous

donation received which was not offered for taxation.

3.3 ITA No. 2342 of 2016, Assessment Year 2006-07:-

The lone ground raised by the Revenue that, the Ld.CIT(A)

has erroneously quashed the order of the Ld.AO on the validity

of reassessment.

3.4 ITA No. 2343 of 2016, Assessment Year 2007-08:-

The only issue raised in the appeal by the Revenue is that

the Ld.CIT(A) has erroneously passed order U/s.250(6) r.w.s

143(3) of the Act, by following the logic adopted in the order passed U/s.143(3) of the Act for the assessment year 2006-07 in

the case of the assessee by granting relief of 25% of the addition

made towards anonymous donation received which was not

offered for taxation.

3.5 ITA No. 2344 of 2016, Assessment Year 2007-08:-

The lone ground raised by the Revenue that the Ld.CIT(A)

has erred in passing Order U/s.250(6) r.w.s 143(3) & 147 of

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the Act by quashing the order of the Ld.AO on validity of

reassessment.

3.6 ITA No. 2345 of 2016, Assessment Year 2010-11:-

The only issue raised by the Revenue is that the Ld.CIT(A), has erred in deleting the addition of Rs.2,57,70,000/- based on the findings of the Tribunal that the funds of the trusts were

advanced to the company for construction of meditation hall.

3.7 ITA No. 2346 of 2016, Assessment Year 2011-12:- The only issue raised by the Revenue is that the Ld.CIT(A),

has erred in deleting the addition of Rs.4,33,55,050/- based on the findings of the Tribunal that the funds of the trusts were advanced to the company for construction of meditation hall.

4.1 ITA No.2341 of 2016, Assessment Year 2005-06:

Granting relief of 25% of the addition made towards anonymous donation received which was not offered for taxation. During the course of reassessment it was observed by the Ld.AO that the assessee company had received large sum of

money from various persons and M/s. Anugraha Trust for

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construction of building. It was explained by the assessee that

the M/s. Anugraha Trust advanced large sum to the assessee

company and also canvased individuals who remitted donations

to the assessee company for construction of a meditation hall.

As regards the contribution received from M/s. Anugraha Trust

for Rs.5,30,00,000/- there was no dispute. However, the

assessee could not give the details of the individuals who had

made aggregate contribution of Rs.3,34,55,010/- as donation,

therefore the Ld.AO treated those contributions as unanimous

donations and added to the income of the assessee. On appeal,

the Ld.CIT(A) observed that the contributions were received by

the assessee both by cash as well as by cheque. It was further

generalized that approximately 25% of the contributions were

received by cheque and 75% were received by cash. Detailed

finding on that regard was made during the course of the

assessment proceedings for the assessment year 2006-07.

Based on the above findings, the Ld.CIT(A) directed the Ld.AO

to treat 25% of the donation as genuine and not anonymous

aggregating to Rs.83,63,750/- and thereby delete the addition to

that extent. Balance amount of anonymous donation of

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Rs.2,50,91,260 was confirmed. Aggrieved by the Order of the

Ld.CIY(A) the Revenue is on appeal before us.

4.2 The Ld. DR vehemently argued before us that the logic

applicable for the assessment year 2006-07 cannot be adopted for the relevant assessment year 2005-06 and therefore the order of the Ld.CIT(A) is erroneous and hence it was pleaded

that the same may be set aside. On the other side the Ld.AR argued in support of the order of the Ld.CIT(A) reiterating his findings that the entire donation received by the assessee for all the above assessment years were thread-bear analyzed by the

Ld.CIT(A) and found the mode of payment to be similar. Hence it was requested the order of the Ld.CIT(A) may be confirmed.

4.3 We have heard the rival submissions and carefully perused the materials available on record. From the facts of the case, it is apparent that the Ld.CIT(A) has verified the mode of payment

for all the assessment years and had overall come to a conclusion that approximately 25% of the payments were received by cheque. Therefore he held that the 25% of the

receipts cannot be treated as anonymous donations because the

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donees were easily identifiable / traceable and accordingly he

directed the Ld.AO to delete the addition to that extent. Since

the Ld.DR or the Revenue has not brought out any materials on

record to negate the findings of the Ld.CIT(A), we do not find it

necessary to interfere with the order of the Ld.CIT(A) on this

issue. Accordingly we hereby confirm the order of the Ld.CIT(A).

Hence the issue is decided against the Revenue.

5.1 ITA No.2342 of 2016, Assessment Year 2006-07:

Quashing the order of the Ld.AO on reopening: The appellant had filed its return of income for the relevant

assessment year on 29.11.2006. Thereafter the assessment

was completed U/s.143(3) of the Act vide order dated

30.12.2008. In the assessment, the Ld. AO had made addition

of 74.2% of the total donations received by holding it to be

anonymous donations. Accordingly the assessee paid taxes in

compliance with the assessment order. Subsequently the

assessment was once again reopened U/s.147 of the Act vide

notice issued U/s.148 of the Act dated 26.03.2013. The reasons

for reopening are reproduced herein below for reference:

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Page 3 “An information vide letter in F.No.DIT(E) No.Misc/Reopening/2012-13/481 dated 14.03.2013, has been received from Director of Income-tax (Exemptions), Chennai, about certain violations in the transactions between M/s. Anugraha Trust and the assessee company, M/s. Golden Shelters Pvt. Ltd. As per the information, the trust M/s. Anugraha Trust had actually acted as conduits to provide explanation to the sources of fund of Rs.17,03,84,556/- which has been directly credited to the Reserves & Surplus of the assessee company under the nomenclature, Infrastructure Development Fund. The “Infrastructure Development Fund” was treated as a capital receipt in the books of the company whereas in reality the amounts represent the unaccounted income of the assessee company, whereas in the hands of the trust, the above payment has been treated as contribution for Infrastructure Development Fund.

The fund transfer to the company during the course of scrutiny proceedings in the case of the Trust was initially shown as donation to the “Infrastructural Development Fund” but later termed as Investment. The fact remained that the funds of the trust actually belonged to the company. The buildings were also erected on the land belonging to the assessee and not that of the Trust.”

Thereafter the reassessment was completed vide order U/s.143(3) r.w.s.147 of the Act on 26.02.2014, wherein the balance 24.8% of the donations amounting to

Rs.4,39,59,216/- was added to the income of the assessee as anonymous donations. On appeal, the Ld.CIT(A) relying on the decision of the Hon’ble Apex court in the case CIT v.

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Kelvinator of India Limited reported in 320 ITR 561 quashed

the order of the Ld.AO on reopening. The relevant portion of the order of the Ld.CIT(A) is reproduced herein below for reference: 5.4 The matter is considered. My findings on the validity of the assessment proceedings are as under: i. The basic premise for reopening the proceedings has been the argument that the appellant company had "used" 1/5 Anugraha Trust as a conduit in channelising its own undisclosed money under the guise of “capital receipts" and questionable donations. The fact, as it emerges that during the impugned assessment year, the appellant company has not received any donation from M/s. Anugraha Trust Hence, the basic premise for reopening the proceedings commence on an erroneous presumption of facts. In the case of ITO vs Lalahmani Mewal Das reported [1976] 103lTR 437 (SC), the Hon'ble Supreme Court held that the reasons for the formation of ,the belief contemplated, by the Section 147 for the reopeningof the assessment must have rational connection or relevant bearing on the formation of belief. Rational connection postulates that there must bea direct nexus or live link between the material coming to the notice of the AO and the formation of his belief that income chargeable to tax has escaped assessment in that particular year. In the appellant’s case, as mentioned earlier since the AO has proceeded on an erroneous presumption of facts, there is no question of a ‘rational connection’ between the material and the belief as postulated by the Hon’ble Supreme Court. ii. In the original assessment, the Assessing Officer after appreciation of facts and circumstances of the case, deemed it appropriate to disallow approximately 74.2

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percent of the donation received, giving an allowance for the remaining 24.8 percent wherein the name, address, PAN and complete details were furnished. This was a conscious and a considered decision taken by the Assessing Officer in the original assessment order. In the reassessment proceedings, the AO has adder the balance 24.8 percent (allowed earlier) to the total income of the appellant on the grounds that investigations done in AY 2007-08 “confirms that the assessee engaged some people to purchase demand drafts out of assessee’s own funds and then receive the same as donation.” It is pertinent to note that no verification/investigation has been carried out by Assessing Officer to come to a finding that donations received in the impugned assessment year is appellant’s own funds. I am of the considered view that the Assessing Officer has not brought any new material on record to warrant a different view compared to the one taken in the original assessment proceedings. The action of the AO in the reassessment proceedings tantamounts’ to a fresh take on the same set of facts and circumstances. It is settled law by the Hon’ble Supreme Court of India in the case of CIT vs Kelvinator of India Limited reported in [2010] 320 ITR 561 (SC) that reassessment proceedings base on mere "change of opinion" is not good in law. In the appellants case not only the reasons for reopening are factually incorrect, but also a different opinion has been taken on the same set of facts and circumstances, without establishing the tangible material or evidence based on which a different view is taken.

5.5 In view of the facts, circumstances, and judicial precedence discussed above, I am of the considered view that the reassessment proceedings in the appellant’s case cannot be sustained. Accordingly, the reassessment proceedings are quashed. The appellants’ grounds on the validity of the reassessment proceedings are allowed.”

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5.2 Before us the Ld.DR argued in support of the order of the Ld.AO by reiterating the findings made by the Ld.AO. While as the Ld.AR relied on the order of the Ld.CIT(A) and

pleaded for upholding the same.

5.3 We have heard the rival submissions and carefully

perused the materials available on record. The Ld.CIT(A) while quashing the order of the Ld.AO on reopening has made the following findings: i. The appellant company has not received any donation

from M/s. Anugraha Trust, hence the basic premises for reopening the assessment was erroneous. ii. The issue with respect to anonymous donations was

cautiously and elaborately considered by the Ld.AO during the course of original assessment passed U/s.143(3) of the Act.

iii. No investigations were carried out by the Revenue to establish that the funds received by the assessee were its own undisclosed funds.

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iv. No fresh materials were brought out by the Revenue in

order to justify reopening of the assessment.

Before us also the Ld.DR has not brought out any

materials with cogent evidence to negate the findings of the Ld.CIT(A). Further it is apparent from the facts of the case that the issue of anonymous donations was already

considered by the Ld.AO during the course of original assessment. Thereafter no fresh materials have surfaced to prove the facts otherwise. In this situation, we do not find it necessary to interfere with the order of the Ld.CIT(A) who

has only judiciously followed the decision of the Hon’ble Apex Court while arriving at his decision. Thus this ground raised by the Revenue also fails.

6.1 ITA No.2343 of 2016, Assessment Year 2007-08:

Granting relief of 25% of the addition made towards anonymous donation received which was not offered for taxation. The Ld.AO vide his order passed U/s.143(3) of the Act treated the amount of Rs.11,56,96,492/- received by the

assessee company as anonymous donation. The assessee

13 ITA No.2341 to 2346/Mds/2016

company had explained that the donations were received from

various individuals and from M/s. Anugraha Trust for construction

of a meditation hall. However, the Ld.AO rejected the claim of

the assessee. On appeal, the Ld.CIT(A) after examining the

donation received by the assessee for the relevant assessment

year as well as the assessment year 2006-07 came to a

conclusion that approximately 24.8% of the donations were

received by cheque/draft by the assessee and therefore to that

extent viz., Rs.2,89,24,122/- granted relief to the assessee.

6.2 Before us the Ld.DR did not bring any materials on record

to negate the finding of the Ld.CIT(A). Further on the similar

issue apart from the assessment year 2006-07 for the

assessment year 2005-06 also the facts were identical and the

Ld.CIT(A) had granted relief to the assessee to the extent of 25%

of the donation received. Hence we do not have any reason to

interfere with the order of the Ld.CIT(A) for the relevant

assessment year 2007-08. Hence the ground raised by the

Revenue fails.

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7.1 ITA No.2344 of 2016, Assessment Year 2007-08:

Quashing the order of the Ld.AO on reopening: The appellant had filed its return of income for the relevant assessment year on 28.10.2007. Thereafter the assessment

was completed U/s.143(3) of the Act vide order dated 31.12.2009, wherein the Ld.AO made addition of Rs.11,56,96,490/- by holding it to be anonymous donation.

However, the donation given by M/s. Anugraha Trust for Rs.1,10,00,000/- and Shri P.Narayanan Rs.25,00,000/- is accepted to be genuine donations. Subsequently the Ld.AO reopened the assessment via notice U/s.147 r.w.s.148 of the Act

dated 26.03.2013. The reasons for reopening are reproduced herein below for reference: “Page 3: An information vide letter in F.No.DIT(E) No.Misc/Reopening/2012-13/481 dated 14.03.2013 has been received from the Director of Income Tax (Exemptions), Chennai, about certain violations in the transactions between M/s. Anugraha Trust and the assessee company, M/s. Golden Shelters Pvt. Ltd. As per the information, the trust M/s. Anugraha Trust had actually acted as conduit to provide explanation to the sources of fund of Rs.12,92,96,492/- which has been directly credited to the Reserves & Surplus of the assessee company under the nomenclature, Infrastructure Development Fund. The “Infrastructure Fund” was treated as Capital Receipt in the books of the company whereas in reality the amounts represent the unaccounted income of the assessee

15 ITA No.2341 to 2346/Mds/2016

company, whereas in the hands of the trust, the above payment has been treated as contribution for Infrastructure Development Fund.”

Thereafter the assessment was reframed wherein the Ld.AO added back the sum of Rs.1,10,00,000/- received from M/s. Anugraha Charitable Trust as unexplained credit in the hands of the appellant by treating the same as assessee’s own

unaccounted income routed through the individual donors and the trust. On appeal, the Ld.CIT(A) quashed the reopening proceedings by observing as under: “Para 6 : The matter is considered. My findings on the validity of the reassessment proceedings are as under:

i. The basic premise for reopening the proceedings appears to be the communication for DIT(Exemptions) that the trust, M/s. Anugraha Trust, was used as a “conduit” by the appellant in channelizing its own undisclosed money under the guise of “infrastructure development fund” through questionable donations. In the reassessment proceedings the Assessing Officer place sole reliance on this communication to add the impugned sum of Rs.1,10,00,000/- received from M/s. Anugraha Trust to the total income of the appellant. No evidence/enquiry, etc has been made by the Assessing Officer in order to verify/corroborate the communication received from the Directorate of Exemptions.

ii. The ld.Chennai Tribunal in its order in the case of M/s. Anugraha Trust in ITA No.2068, 2069, 2070 &

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2071/Mds/2014 has held that the funds of the Trust were advanced to M/s. Prajit Foundations Private Limited and the appellant company for the construction of meditation hall at Varadalapalam Mandal, Chitoor District, Andhra Pradesh. In view of this conclusion of the ld. Chennai Tribunal, being the highest fact finding body, the donations received from M/s. Anugraha Trust cannot be treated as unexplained credit of the appellant company.

iii. In any case, the issue of taxability of the impugned donations was examined by the Assessing Officer in the original assessment proceedings. The finding of the Assessing Officer on page-4 of the order under section 143(3) of the Act dated 31.12.2009 is reproduced as under: i. “The assessee also claimed that they have received Rs.1,10,00,000/- from M/s. Anugraha, a trust. The entire receipts are in cash. The assessee also filed a confirmation letter from Shri T. Narayanan, Commissioner of Income-tax (Appeals)-6, Chennai that he has paid donation of Rs.25,00,000/- for the purpose of construction of a building. In both these cases, the source of the donation and the intention of the done have been demonstrated by the assessee company. In view of this, an amount of Rs.11,56,96,492/- being the sum of donations over and above the two receipts supra, are chargeable to tax.”

iv. In the reassessment order, the Assessing Officer has admitted that the issue had been examined in the original assessment proceedings, and the same “was accepted in good faith.” I am unable to be persuaded by this argument. It is under section 143(1) that the details of income and expenditure furnished by the tax payers are accepted in good faith. Under the proceedings under

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section 143(3) of the Act, scrutiny and verification of the details filed are made, and necessary variations to the total income as per law are made by the AO. In the present case, the AO in the original assessment proceedings has given a clear finding that “the source and the intention of the done have been demonstrated by the assessee company.” Hence, this is not a case of acceptance out of ‘good faith’ as contended in the impugned reassessment order. On the contrary, this is a clear case of the impugned reassessment order. On the contrary, this is a clear case of arriving at a conclusion after proper verification of facts and due application of mind. It must not be mentioned here that the AO has not brought in any new facts relating to suppression of income by the appellant company. The entire details of the capital receipts were already available to the AO under the original proceedings. The reliance of the AO on the communication of the Directorate of Exemptions also becomes irrelevant in view of the clear finding of ld. Chennai Tribunal on the funds of M/s. Anugraha Trust.

v. I am therefore of the considered view that the present reassessment proceedings are nothing but a mere change of opinion on the same set of facts. The AO has reopened the assessment proceedings on account of supposed failure on the part of the appellantto fully and truly disclose the material facts that have led to the escapement of income from tax. The AO, in the reassessment order has not established which material fact had not been fully and truly disclosed. I am of the view that the reassessment proceedings are nothing but a re-appreciation of the same material on record. The Hon’ble Supreme Court in the case of CIT vs Kelvinator of India Limited reported in[2010] 320 ITR 561 held as under:

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“Prior to Direct Tax Laws (Amendment) Act, 1987, re- opening could be done under above two conditions and fulfillment of the said conditions alone conferred jurisdiction on the Assessing Officer to make a back assessment, but in section 147 of the Act [with effect from 1st April, 1989], they are given a go-by and only one condition has remained, viz., that where the Assessing Officer has reason to believe that income has escaped assessment, confers jurisdiction to re- open the assessment. Therefore, post-1st April, 1989, power to re-open is much wider. However, one needs to give a schematic interpretation to the words “reason to believe” failing which, we are afraid, Section 147 would give arbitrary powers to the Assessing Officer to re-open assessments on the basis of ‘mere change of opinion’, which cannot be per se reason to re-open. We must also keep in mind the conceptual difference between power to review and power to reassess. The Assessing Officer has no power to review’ he has the power to re-assess. The reassessment has to be based on fulfillment of certain pre-condition and if the concept of “change of opinion” is removed, as contended on behalf of the Department, then, in the garb of re-opening the assessment, review would take place. One must treat the concept of “change of opinion” as an in-built test to check abuse of power by the Assessing Officer. Hence after 1st April, 1989 Assessing Officer has power to re-open, provided there is “tangible material” to come to the conclusion that there is escapement of income from assessment. Reasons must have a live link with the formation of the belief. Under the Direct Tax Laws (Amendment) Act, 1987, Parliament not only deleted the words “reason to believe” but also inserted the word “opinion” in Section 147 of the Act. However, on receipt of representations from the companies against omission of the words “reason to believe”, Parliament re-introduced the said expression and deleted the word “opinion” on the ground that it would vest arbitrary powers in the Assessing Officer are therefore dismissed.”

The ratio of the above decision of Hon’ble Supreme Court is squarely applicable to the facts of the appellant’s case.

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Accordingly, I hold the reassessment proceedings to be invalid, as it is nothing but a change of opinion on an issue where the AO had given a clear finding in the original assessment order. Hence, the reassessment proceedings stands quashed.”

7.2 After hearing both sides, we find merit in the order of the Ld.CIT(A) because of the following reasons: i. The claim of the Revenue that the fund received by the

assessee company from M/s. Anugraha Charitable Trust is actually the assessee’s own funds is not proved with any cogent evidence.

ii. No enquiry or evidence was gathered on this regard by the Revenue to corroborate with the communication received from the Directorate of Exemptions.

iii. The Chennai bench of the Tribunal in the case of M/s. Anugraha Trust in ITA No.2068, 2069, 2070 & 2071/Mds/2014 has held the contribution made by

M/s. Anugraha Charitable Trust to be genuine. iv. In the original assessment proceedings U/s.143(3) of the Act, this issue of donation received from M/s. Anugraha Trust for Rs.1,10,00,000/- was considered by the Ld.AO

and no additions were made.

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From the above it is clear that the Ld.CIT(A) has rightly

followed the decision of the Hon’ble Apex Court in the case CIT v. Kelvinator India Limited reported in 320 ITR 561 and quashed the order of the Ld.AO on reopening because in the case of the

assessee the assessment was reopened based on change of opinion. Therefore, we do not find it necessary to interfere with the order of the Ld.CIT(A). Accordingly the Revenue fails on this

ground.

8.1 ITA No.2345 & 2346 of 2016, Assessment Years 2010- 11 & 2011-12: Deleting the addition of Rs.2,57,70,000/- and

Rs.4,33,55,050/- for the assessment years 2010-11 & 2011-12 respectively being the donation received from M/s. Anugraha Charitable Trust for construction of meditation hall, by holding the

genuineness, identity and creditworthiness of M/s. Anugraha Charitable Trust to be in order: During both these relevant assessment years, the

assessee company had received donations by way of cash from M/s. Anugraha Charitable Trust in order to construct a meditation hall. The Ld.A.O opined that the donation received by the

assessee company was the unexplained income of the assessee

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company and therefore made addition of the aforesaid amount

U/s. 68 of the Act. On appeal the Ld.CIT(A) relying in the

decision of the Chennai Bench of the Tribunal came to a

conclusion that the genuineness, identity and creditworthiness of

M/s. Anugraha Charitable Trust is in order and granted relief to

the assessee by observing as under:

Para 6 & 6.1 of the order of the CIT(A) for both the assessment

years

“6. The matter is considered. In support of its claim, the appellant has filed copy of consolidated order of ld. Chennai Tribunal in ITA No.2063, 2064, 2065, 2066 & 2067/Mds/2014 in the case of Nachipur Educational Trust, and ITA No.2068, 2069, 2070 & 2071/Mds/2014 and ITA No.2173/Mds/2012 in the case of M/s. Anugraha Trust. In its order, the ld. Chennai Tribunal has given a finding of fact in so far as source, genuineness and credit worthiness of the two trusts, M/s. Anugraha and M/s. Nachipur Educational Trust is concerned. The relevant portion of the finding of ld. Chennai Tribunal is reproduced as under:

“We have gone through the orders of the lower authorities and material available on record. The funds of the trusts were advanced to two companies namely, M/s. Prajit Foundation Pvt. Ltd., and M/s. Golden Shelters Pvt. Ltd., for construction of meditation hall at Varadapalam Mandal, Chitoor District, Andhra Pradesh”

6.1 In view of the fact that the genuineness, identity and credit worthiness of M/s. Anugraha Trust has been accepted by the ld. Chennai Tribunal, the addition made by the AO treating the receipt from the Trust as unexplained income of the appellant company cannot be sustained. Accordingly, I direct the AO to

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delete the addition of Rs.2,25,70,000/- (AY 2010-11) / Rs.4,33,55,050/- (AY 2011-12) on account of receipt from M/s. Anugraha trust. This ground, is therefore, allowed.”

Since the Ld.CIT(A) has arrived at his decision only based on the decision of the Chennai Bench of the Tribunal supra, we do not find it necessary to interfere with his order as we find it to be appropriate. Therefore this ground raised by the Revenue in both the appeals is held in favour of the assessee.

Order pronounced in the court on the 25th April, 2017.

Sd/- Sd/- (धु�वु� आर.एल रे�डी) (ए. मोहन अलंकामणी) ( Duvvuru RL Reddy ) ( A. Mohan Alankamony ) �या�यक सद�य /Judicial Member लेखा सद�य / Accountant Member

चे�नई/Chennai, �दनांक/Dated 25th April, 2017

JR आदेश क� ��त�ल�प अ�े�षत/Copy to: 1. अपीलाथ�/Appellant 2. ��यथ�/Respondent 3. आयकर आयु�त (अपील)/CIT(A) 4. आयकर आयु�त/CIT 5. �वभागीय ��त�न�ध/DR 6. गाड� फाईल/GF