PALLADAM KRISHNASAMY GANESHWAR,TIRUPUR vs. DCIT, CC-3, COIMBATORE

4. The CIT (Appeals) - 20, Chennai failed to appreciate that having assessed the appellant in terms of Section 153A of the Act based on the incriminating materials seized during the search in the premises of Mr. O. Arumugasamy and others in contra distinction to the search in the premises of the appellant here in, where in no incriminating materials were seized for the purpose of making the disputed addition(s) in the search assessment order(s), the consequential search assessment order pass should be reckoned as bad in law.

5. The CIT (Appeals) - 20, Chennai failed to appreciate that having used the disputed search materials seized in the premises at Mr. O. Arumugasamy and others for making the disputed addition and further having not seized any incriminating material in support of the disputed addition in the hands of the searched person, the assessment completed by making additions not arising from the search conducted in the hands of the appellant should be reckoned as nullity in law.

6. The CIT (Appeals) - 20, Chennai failed to appreciate the law declared by the Supreme Court in the case reported in 454 ITR 212 on the scope of jurisdiction on the scope of jurisdiction under Section 153A of the Act in proper perceptive and as a consequence ought to have appreciated that the search assessment order under consideration was invalid, passed without jurisdiction and not sustainable both on facts and in law.

7. The CIT (Appeals) - 20, Chennai failed to appreciate that the finding rendered with respect to framing of assessment under Section 153A of the Act in the absence of incriminating material in contrary to judicial precedents, there by vitiating the passing of the appellate order,

8. The CIT (Appeals) - 20, Chennai erred in sustaining the addition of Rs. 6,00,00,000/- being the sum alleged to have been given as loan to Mr. O. Arumugasamy and others as unexplained investment in terms of Section 69 of the Act in the computation of taxable total income without assigning proper reasons and justification.

9. The CIT (Appeals) - 20, Chennai erred in sustaining the addition of Rs.49,00,000/- being the sum alleged to have been earned as unaccounted interest income for the loan given to Mr. O. Arumugasamy and others as income of the appellant in terms of Section 56 of the Act in the computation of taxable total income without assigning proper reasons and justification.

10. The CIT (Appeals) - 20, Chennai failed to appreciate that the additions made merely based on the 'dairy statement' seized during search in the premises of Mr. 0. Arumugasamy and others was wholly unjustified and ought to have appreciated that the subsequent affidavit filed was rejected on superfluous reasons, there by vitiating the action of First Appellate Authority in confirming the addition made. 11. The CIT (Appeals) - 20, Chennai failed to appreciate that the rejection of the affidavits and the explanation provided by the appellant on the ground that other parties had not appeared before the Assessing Officer in response to the summon issued by them was wrong, erroneous, incorrect, invalid, unjustified and not sustainable both on facts and in law. 12. The CIT (Appeals) - 20, Chennai failed to appreciate that appellant had discharged the onus cast upon in explaining the transaction under consideration by way of affidavits from the person whose statements were relied on and ought to have further appreciated that the action of the First Appellate Authority in not conducting any further enquiry while passing the order impugned is unsustainable in law. 13. The CIT (Appeals) - 20, Chennai failed to appreciate that having not unearthed any material indicating the actual transfer of the money relating to the presumed transaction by the appellant with the other individual(s)/ entities, the addition made as part of the computation of taxable total income invoking the provisions of section 69 of the Act was wrong, erroneous, unjustified, incorrect, invalid and not sustainable both on facts and in law. 14. The CIT (Appeals) - 20, Chennai failed to appreciate that the misreading of the sworn statements of the other parties would negate the presumption of unaccounted loan transactions and ought to have appreciated that the process of translating their presumption for substantiating the addition made in the computation of taxable total income was not conducted in accordance with the settled principles of law thereby grossly violating the principles of natural justice. 15. The CIT (Appeals) - 20, Chennai failed to appreciate that having not examined the nature of transactions reflected in the invalid loose sheets, the additions made should be reckoned as bad in law in view of the presumption of disputed loan transactions. 16. The CIT (Appeals) - 20, Chennai failed to appreciate that reasons provided in the affidavit for explaining the transactions under consideration was not understood in proper perceptive while rejecting the same on mere suspicion and surmises, 17. The CIT (Appeals) - 20, Chennai failed to appreciate that the findings rendered in relation there to in the impugned order was wrong, erroneous, incorrect, invalid, unjustified and not sustainable both on facts and in law. 18. The CIT (Appeals) - 20, Chennai failed to appreciate that the entire recomputation forming part of the assessment order was wrong, erroneous, incorrect, invalid, unjustified and not sustainable both on facts and in law.

As is evident, the sole subject matter of appeal is additions made by lower authorities consequent to search proceedings in the case of the assessee. The assessee has challenged the assumption of jurisdiction on legal grounds and also assailed the quantum additions on merits.

The details of the same along with ledger extracts have been extracted on Page No.28 onwards in the assessment order. The material as seized from other group indicated that there was a loan received entry of Rs.20 Crores from PK Ganeshwar Tirupur Tip Top and interest payment at the rate of 3% per month for the said loan. 3.6 In assessee’s premises, there was a sale agreement between Shri R. Eswaran (shareholder of Tirupur Tip Top Chit funds) and Sh. Senthil Kumar (son of Shri O. Arumugasamy) and director of M/s Kasthuri Mills Pvt. Ltd. 3.7 Considering all the above facts, Ld. AO concluded that there exists a nexus between Shri O. Arumugasamy, assessee, M/s SG wind farms Pvt. Ltd. and R. Eswaran of Tirupur Tip Top Chit funds. Hence, in the seized material of Shri O. Arumugasamy, notings were mentioned as Tirupur Tip Top C/o PK Ganeshwar, Further, cash loan of Rs.20 Crores entered in the seized material of Shri O. Arumugasamy as ‘PK Ganeshwar C/o TPR Tip Top’ was also repaid by Shri O. Arumugasamy during demonetization as part of Rs.36 Crores that was totally repaid to Shri PK Ganeshwar. As per document seized during search on that group, outstanding quantum of loan lent by the assessee and his concerns was Rs.71.88 Crores. Out of the same, the undisclosed portion was Rs.42.34 Crores whereas the balance was Rs.29.54 Crores which was the disclosed portion as per the books of assessee still outstanding from Shri O. Arumugasamy and his related concerns. 3.8 In relation to undisclosed portion, Rs.36 Crores was allegedly received by the assessee in cash from Shri O. Arumugasamy on two occasions i.e., Rs.16 Crores on 03-12-2016 and Rs.20 Crores on 27-11- 2016 as per material seized from search of Shri O. Arumugasamy group and confirmed in sworn statement recorded therein. 3.9 The details of return of income as filed by the assessee u/s 139(1) as well as filed u/s 153A was tabulated by Ld. AO as under: - A.Y. Date of Original Original Return of Date of Agri Addl. notice return of return of income as return of income income issued income as income per 153A income disclosed u/s.153A per 139(1) date filed filed u/s.153A 06.02.2020 2011-12 -(110177310) 30.09.2011 -(110177310) 18.08.2020 765400 Nil 06.02.2020 2012-13 375100 29.09.2012 10605100 18.08.2020 825700 10230000 2013-14 06.02.2020 23354770 29.09.2013 51315770 18.08.2020 102560 27961000 2014-15 06.02.2020 43979575 29.11.2014 43979575 18.08.2020 877000 Nil 2015-16 06.02.2020 54702600 02.10.2015 54702600 18.08.2020 303500 Nil 2016-17 06.02.2020 8329460 10.10.2016 8875360 18.08.2020 314600 545900 2017-18 06.02.2020 14322420 07.11.2017 14322420 18.08.2020 412600 Nil 2018-19 06.02.2020 28136770 27.09.2018 28136770 18.08.2020 463050 Nil 2019-20 143(2) 2364868 19.08.2020 NA NA NA NA 3.10 During the course of assessment proceedings, the assessee furnished various replies and filed financial statements etc. in support of its return of income. Upon perusal, it was noted by Ld. AO that no interest income was admitted by the assessee as received from Shri O. Arumugasamy group whereas material found during the search on that group indicated that the assessee had advanced loan of Rs.5 Crores during 16-12-2013 which was also available in the books of the assessee. Though the transactions were undertaken by the assessee, the assessee failed to disclose the interest income against the same. Such interest allegedly received by the assessee group was quantified at Rs.108.70 Lacs as under: - Amount in Rs. Interest Period Duration Interest paid In the hands of rate on 06.03.2014 P.K.Ganeshwar 10,00,00,000/-Rs. 5 crores 3% 16.12.2014 2 months 78,00,000 39,00,000 given by M/s.Shri Ganesha to 18 days Textiles and Rs.5 crores by 06.03.2014 M/s.SG Windfarms P.Ltd. 3,00,00,000/- given by M/s. SG 3% 30.12.2014 2 months Windfarms P.Ltd. to 16 days 19,80,000 0 06.03.2014 2,00,00,000/- Undisclosed cash 3% 21.01.2014 1 month 8,60,000 8,60,000 loan given by Shri to & 13 days P.K.Ganeshwar 06.03.2014 1,00,00,000/- Undisclosed cash 3% 12.02.2014 23 days 2,30,000 2,30,000 loan given by Shri to P.K.Ganeshwar 06.03.2014 1,08,70,000 49,90,000/- Total Accordingly, Ld. AO proceeded to add the proportionate interest of Rs.49.90 Lacs in the hands of the assessee. 3.11 The assessee opposed the same on the ground that all these loans were advanced through banking channels and repayment also happened through banking channels only. All the transactions were duly disclosed in the books of accounts. The assessee also filed loan confirmation from each of the entities for respective years. The assessee denied having entered into any other transactions with Shri O. Arumugasamy and others. The assessee also submitted that the group was unable to repay the outstanding loans and interest due to heavy losses incurred by that group in their business. The assessee refuted the allegation of Ld. AO on the ground that loose sheets recovered during search on third-party could not be considered as conclusive evidence in the absence of corroboration thereof. No addition could be made on the basis of presumption and surmises. 3.12 However, going by the material found during the search in the case of Shri O. Arumugasamy group as well as statements recorded therein, Ld. AO rejected the submissions of the assessee and added interest income of Rs.49.90 Lacs in the hands of the assessee as ‘income from other sources’ u/s 56. The interest income of Rs.58.80 Lacs pertaining to M/s SG Wind farms Pvt. Ltd. was added on protective basis.

3.13 The Ld. AO also made addition of alleged undisclosed investment for Rs.600 Lacs. The same is also based on material seized during search on Shri O. Arumugasamy group. As per the seized material, the assessee advanced cash loan of Rs.200 Lacs, Rs.100 Lacs and Rs.300 Lacs on 21-01-2014, 12-02-2014 and 06-03-2014 which was not entered in the assessees’ books of accounts. Though the assessee denied the same, the Ld. AO made addition in the hands of the assessee on similar lines. Finally, the assessment was framed on 18-06-2021 assessing returned income of Rs.439.79 Lacs at Rs.1148.49 Lacs. 3.14 In AYs 2015-16 & 2016-17, Ld. AO made similar addition of undisclosed investment and undisclosed interest income. In AY 2017-18, Ld. AO made addition of undisclosed interest income. 3.15 The assessee assailed impugned additions, in all the years, on legal grounds as well as on merits. On legal grounds, reliance was placed on the decision of Hon’ble Supreme Court in the case of Pr. CIT vs. Abhisar Buildwell (P.) Ltd. (149 Taxmann.com 399) for the argument that in the absence of any incriminating material as found during search on assessee, no addition could be made for unabated assessment year. The assessee also submitted that notice issued u/s 153A was not legally sustainable and consequential assessment was to be reckoned as nullity in law. On the given facts, Ld. AO ought to have issued notice u/s 153C by reckoning the assessee as “other person” by following separate procedure as laid down in the statute including the recording of satisfaction by both the AO of the searched person (Shri O Arumugasamy) and the AO of the assessee. The failure to do so would be fatal to assessment. The assessee also assailed impugned addition on merits, inter-alia, on the ground that the details in loose sheets were rough details having no evidentiary value and without any corroborative evidences. It was also submitted that the assessee had advanced loan to that group through banking channels only which was duly recorded in the books of accounts well before the date of search. During search proceedings, the assessee furnished copy of the affidavits of all these persons confirming that no cash transaction was entered into by the assessee. Further, Ld. AO did not bring on record any document / corroborative evidence establishing the movement of cash / alleged advancement of cash loan by the assessee during relevant assessment years. However, Ld. CIT(A) rejected the legal grounds and also confirmed the quantum addition on merits except for deletion of protective addition. Aggrieved, the assessee is in further appeal by us. Our findings and Adjudication 4. We find that identical legal issue has been decided by us in the case of group entity M/s SG Wind Farm Pvt. Ltd. (ITA Nos.1227/Chny/2024 & ors. for AYs 2014-15 to 2017-18) as under: - 5. Upon perusal of factual matrix as enumerated in preceding paragraphs, the undisputed position that emerges is that the impugned addition of undisclosed interest income is based on incriminating material found during an earlier separate / independent search conducted by the department on Shri O. Arumugasamy group on 09-11-2017. No incriminating material, in this regard, has been found during the search conducted on assessee group on 06-03-2019. From tabulation in para 3.9, it could be seen that the assessee had filed return of income for this year on 29-09- 2014 which stood attained finality since the date of issuance of notice u/s 143(2) had already expired on 30-09-2015. In other words, the regular assessment proceedings had attained finality and this year was a case of unabated assessment year. In response to notice u/s 153A, the assessee offered same income. Quite clearly, the impugned addition of undisclosed interest income is not based on any incriminating material found during search on the assessee group but the same are based on incriminating material found in another search which has already happened much earlier before the date of search on the assessee.

6. It is the case on behalf of the Revenue that once upon the search under section 132 or requisition under section 132A, the assessment has to be done under section 153A of the Act, 1961 and the AO thereafter has the jurisdiction to pass assessment orders and to assess the 'total income' taking into consideration other material, though no incriminating material is found during the search even in respect of completed/unabated assessments.

7. At the outset, it is required to be noted that as such various High Courts, namely, Delhi High Court, Gujarat High Court, Bombay High Court, Karnataka High Court, Orissa High Court, Calcutta High Court, Rajasthan High Court and the Kerala High Court have taken the view that no addition can be made in respect of completed/unabated assessments in absence of any incriminating material. The lead judgment is by the Delhi High Court in the case of Kabul Chawla (supra), which has been subsequently followed and approved by the other High Courts, referred to hereinabove. One another lead judgment on the issue is the decision of the Gujarat High Court in the case of Saumya Construction (supra), which has been followed by the Gujarat High Court in the subsequent decisions, referred to hereinabove. Only the Allahabad High Court in the case of Pr. CIT v. Mehndipur Balaji 2022 SCC Online All 444/[2023] 147 taxmann.com 201/ [2022] 447 ITR 517 has taken a contrary view. 7.1 In the case of Kabul Chawla (supra), the Delhi High Court, while considering the very issue and on interpretation of section 153A of the Act, 1961, has summarised the legal position as under: Summary of the legal position 38. On a conspectus of section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under section 132 of the Act, notice under section 153A(1) will have to be mandatorily issued to the person searched requiring him to file returns for six AYs immediately preceding the previous year relevant to the AY in which the search takes place. ii. Assessments and reassessments pending on the date of the search shall abate. The total income for such AYs will have to be computed by the AOs as a fresh exercise. iii. The AO will exercise normal assessment powers in respect of the six years previous to the relevant AY in which the search takes place. The AO has the power to assess and reassess the 'total income' of the aforementioned six years in separate assessment orders for each of the six years. In other words, there will be only one assessment order in respect of each of the six AYs "in which both the disclosed and the undisclosed income would be brought to tax".

iv. Although Section 153 A does not say that additions should be strictly made on the basis of evidence found in the course of the search, or other post-search material or information available with the AO which can be related to the evidence found, it does not mean that the assessment can be arbitrary or made without any relevance or nexus with the seized material. Obviously an assessment has to be made under this Section only on the basis of seized material. v. In absence of any incriminating material, the completed assessment can be reiterated and the abated assessment or reassessment can be made. The word 'assess' in Section 153A is relatable to abated proceedings (i.e., those pending on the date of search) and the word 'reassess' to completed assessment proceedings. vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under section 153A merges into one. Only one assessment shall be made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record of the AO. vii. Completed assessments can be interfered with by the AO while making the assessment under section 153A only on the basis of some incriminating material unearthed during the course of search or requisition of documents or undisclosed income or property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment. 7.2 Thereafter in the case of Saumya Construction (supra), the Gujarat High Court, while referring the decision of the Delhi High Court in the case of Kabul Chawla (supra) and after considering the entire scheme of block assessment under section 153A of the Act, 1961, had held that in case of completed assessment/unabated assessment, in absence of any incriminating material, no additional can be made by the AO and the AO has no jurisdiction to re- open the completed assessment. In paragraphs 15 & 16, it is held as under: "15.On a plain reading of section 153A of the Act, it is evident that the trigger point for exercise of powers thereunder is a search under section 132 or a requisition under section 132A of the Act. Once a search or requisition is made, a mandate is cast upon the Assessing Officer to issue notice under section 153A of the Act to the person requiring him to furnish the return of income in respect of each assessment year falling within six assessment years immediately preceding the' assessment year relevant to the previous year in which such search is conducted or requisition is made and assess or reassess the same. Since the assessment under section 153A of the Act is linked with search and requisition under sections 132 and 132A of the Act, it is evident that the object of the section is to bring to tax the undisclosed income which is found during the course of or pursuant to the search or requisition. However, instead of the earlier regime of block assessment whereby; it was only the undisclosed income of the block period that was assessed, section 153A of the Act seeks to assess the total income for the assessment year, which is clear from the first proviso thereto which provides that the Assessing Officer shall assess or reassess the total income in respect of each assessment year, falling within such six assessment years. The second proviso makes the intention of the Legislature clear as the same provides that assessment or reassessment, if any, relating to the six assessment years referred to in the sub-section pending on the date of initiation of search under section 132 or requisition under section 132A, as the case may be, shall abate. Sub-section (2) of section 153A of the Act provides that if any proceeding or any order of assessment or reassessment made under sub-section (1) is annulled in appeal or any other legal provision, then the assessment or reassessment relating to any assessment year which had abated under the second proviso would stand revived. The proviso thereto says, that such revival shall cease to have effect if such order of annulment is set aside. Thus, any proceeding of assessment or reassessment falling within the, six assessment years prior to the search or requisition stands abated and the total income of the assessee is required to be determined under section 153A, of the Act. Similarly, sub-section (2) provides for revival of any assessment or reassessment which stood abated, if any proceeding or any order of assessment or reassessment made under section 153A of, the Act is annulled in appeal or any other proceeding.

8. For the reasons stated hereinbelow, we are in complete agreement with the view taken by the Delhi High Court in the case of Kabul Chawla (supra) and the Gujarat High Court in the case of Saumya Construction (supra), taking the view that no addition can be made in respect of completed assessment in absence of any incriminating material.

9. While considering the issue involved, one has to consider the object and purpose of insertion of Section 153A in the Act, 1961 and when there shall be a block assessment under section 153A of the Act, 1961. 9.1 That prior to insertion of Section 153A in the statute, the relevant provision for block assessment was under section 158BA of the Act, 1961. The erstwhile scheme of block assessment under section 158BA envisaged assessment of 'undisclosed income' for two reasons, firstly that there were two parallel assessments envisaged under the erstwhile regime, i.e., (i) block assessment under section 158BA to assess the 'undisclosed income' and (ii) regular assessment in accordance with the provisions of the Act to make assessment qua income other than undisclosed income. Secondly, that the 'undisclosed income' was chargeable to tax at a special rate of 60% under section 113 whereas income other than 'undisclosed income' was required to be assessed under regular assessment procedure and was taxable at normal rate. Therefore, section 153A came to be inserted and brought on the statute. Under Section 153A regime, the intention of the legislation was to do away with the scheme of two parallel assessments and tax the 'undisclosed' income too at the normal rate of tax as against any special rate. Thus, after introduction of Section 153A and in case of search, there shall be block assessment for six years. Search assessments/block assessments under section 153A are triggered by conducting of a valid search under section 132 of the Act, 1961. The very purpose of search, which is a prerequisite/trigger for invoking the provisions of sections 153A/153C is detection of undisclosed income by undertaking extraordinary power of search and seizure, i.e., the income which cannot be detected in ordinary course of regular assessment. Thus, the foundation for making search assessments under sections 153A/153C can be said to be the existence of incriminating material showing undisclosed income detected as a result of search.

11. As per the provisions of Section 153A, in case of a search under section 132 or requisition under section 132A, the AO gets the jurisdiction to assess or reassess the 'total income' in respect of each assessment year falling within six assessment years. However, it is required to be noted that as per the second proviso to Section 153A, the assessment or re-assessment, if any, relating to any assessment year falling within the period of six assessment years pending on the date of initiation of the search under section 132 or making of requisition under section 132A, as the case may be, shall abate. As per sub-section (2) of Section 153A, if any proceeding initiated or any order of assessment or reassessment made under sub- section (1) has been annulled in appeal or any other legal proceeding, then, notwithstanding anything contained in sub-section (1) or section 153, the assessment or reassessment relating to any assessment year which has abated under the second proviso to sub-section (1), shall stand revived with effect from the date of receipt of the order of such annulment by the Commissioner. Therefore, the intention of the legislation seems to be that in case of search only the pending assessment/reassessment proceedings shall abate and the AO would assume the jurisdiction to assess or reassess the 'total income' for the entire six years period/block assessment period. The intention does not seem to be to re-open the completed/unabated assessments, unless any incriminating material is found with respect to concerned assessment year falling within last six years preceding the search. Therefore, on true interpretation of Section 153A of the Act, 1961, in case of a search under section 132 or requisition under section 132A and during the search any incriminating material is found, even in case of unabated/completed assessment, the AO would have the jurisdiction to assess or reassess the 'total income' taking into consideration the incriminating material collected during the search and other material which would include income declared in the returns, if any, furnished by the assessee as well as the undisclosed income. However, in case during the search no incriminating material is found, in case of completed/unabated assessment, the only remedy available to the Revenue would be to initiate the reassessment proceedings under sections 147/48 of the Act, subject to fulfilment of the conditions mentioned in sections 147/148, as in such a situation, the Revenue cannot be left with no remedy. Therefore, even in case of block assessment under section 153A and in case of unabated/completed assessment and in case no incriminating material is found during the search, the power of the Revenue to have the reassessment under sections 147/148 of the Act has to be saved, otherwise the Revenue would be left without remedy.

1. 1. Delay condoned.

2. We do not find any merit in this petition. The special leave petition is, accordingly, dismissed.

3. Pending application stands disposed of.

10. The facts of the present case would establish that impugned addition of interest income has been made on the basis of incriminating material found during the course of search on a third-party as well as statement recorded therein. In such a case, the proceedings have to be initiated u/s 153C and not u/s 153A which has not been done by Ld. AO. To initiate proceedings u/s 153C, it is mandatory requirement of law that satisfaction should have been recorded by Ld. AO of the searched person as well as the AO of the other person before proceedings u/s 153C. The recording of satisfaction is sine qua non to assume jurisdiction u/s 153C. Without recording of this satisfaction, no addition could have been made in the hands of the assessee. In the present case, no such satisfaction has been shown to us and in fact, the assessment has been framed u/s 153A which could not be sustained in law considering the mandatory provisions of Sec.153C.

12. Therefore, considering the aforesaid settled position of law, we would hold that the assessment, for all the years, would be bad-in-law and therefore, the impugned addition could not be sustained on this score only. We order so. In other words, the impugned addition of alleged undisclosed interest income stands deleted. The return of income as filed by the assessee stand restored.

We find that similar fact exists in the present appeals before us. Therefore, taking the same view, we would hold that in the absence of any incriminating material found during the course of search of assessee and all these years being unabated assessment years, the impugned additions as sustained in the impugned order, for all the years, is unsustainable in law. We delete the impugned additions as made by Ld. AO in all the years. The Ld. AO is directed to re-compute the income of the assessee for all the years.

5. All the appeals stand allowed in terms of our above order. Order pronounced on 19th November, 2024 Sd/- Sd/- (MANU KUMAR GIRI) (MANOJ KUMAR AGGARWAL) �ाियक सद3 / JUDICIAL MEMBER लेखा सद3 / ACCOUNTANT MEMBER चे3ई Chennai; िदनांक Dated : 19-11-2024 DS आदेशकीTितिलिपअ/ेिषत/Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. � थ�/Respondent 3. आयकरआयु</CIT Coimbatore 4. िवभागीय�ितिनिध/DR 5. गाडAफाईल/GF