THE DCIT CENTRAL-(1), INDORE vs. M/S AYUSH AJAY CONSTRUCTION PVT. LTD. , INDORE

PER Ms. MADHUMITA ROY - JM:

The bunch of appeals preferred by the Revenue and the Cross Objections are filed by the assessee are directed against the orders dated 27.11.2017 passed by the Ld. CIT(A)-II, Indore arising out of the assessment orders passed by the ACIT, Circle-5(1) Indore dated 30.12.2010 under Section 153C r.w.s. 153A/143(3) of the Income Tax Act, 1961(hereinafter referred to as “the Act”) for A.Ys. 2007-08 to 2009-10 respectively. In IT(SS)A No. 141/Ind/2019 the appeal preferred by the Revenue are directed against the order dated 26.04.2019 passed by the CIT(A)-3, Bhopal (M.P.) arising out of the assessment order passed by the DCIT (Central)-1, Indore dated 28.12.2016 under Section 143(3) r.w.s. 153A of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) for A.Y. 2014-15. In ITA No. 740/Ind/2019 the appeal preferred by the Revenue against the order dated 29.04.2019 passed by the CIT(A)-3, Bhopal (M.P.) arising out of the assessment penalty order passed by the ACIT (Central)-1, Indore dated 12.06.2017 under Section 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) for A.Y. 2014- 15.

IT(SS)A Nos.14to16/Ind/2018 & C.O. Nos. 19to21/Ind/2018 & IT(SS)A No. 141/Ind/2019 & ITA No. 740/Ind/2019 JCIT vs. Ayushajay Construction Pvt. Ltd. Asst. Years–2007-08 to 2009-10 & 2014-15 - 3 – 2. We have heard the respective parties, we have also perused the relevant materials available on record.

IT(SS)A Nos.14to16/Ind/2018 & C.O. Nos. 19to21/Ind/2018 & IT(SS)A No. 141/Ind/2019 & ITA No. 740/Ind/2019 JCIT vs. Ayushajay Construction Pvt. Ltd. Asst. Years–2007-08 to 2009-10 & 2014-15 - 4 –

certain ad-hoc disallowance of certain expenses. Relevant to mention that no reference of incriminating material has been made by the Assessing Officer is found while making the following addition:

A.Y. Date of Returned Date of Income Additional filing of income (in filing of declared in income Return u/s Rs.) Return in Return u/s offered, if 139(1) response to 153A (In Rs.) any (In Rs.) the notice u/s 153A 2009-10 30/09.2009 2,82,83,560/- 04/11/2015 2,82,83,560/- - 2010-11 29/09/2010 4,08,60,140/- 04/11/2015 4,08,60,140/- - 2011-12 30/09/2011 8,84,26,020/- 03/11/2015 8,84,26,020/- - 2012-13 30/09/2012 14,53,02,120/- 03/11/2015 14,53,02,120/- - 2013-14 29/09/2013 12,20,30,520/- 03/11/2015 12,20,30,520/- - 2014-15 30/09/2014 13,70,87,550/- 04/11/2015 13,70,87,550/- -

IT(SS)A Nos.14to16/Ind/2018 & C.O. Nos. 19to21/Ind/2018 & IT(SS)A No. 141/Ind/2019 & ITA No. 740/Ind/2019 JCIT vs. Ayushajay Construction Pvt. Ltd. Asst. Years–2007-08 to 2009-10 & 2014-15 - 5 – (iii) CIT V/s Kabul Chawla, (2016) 380 ITR 573 (Del.) (iv) CIT V/s Continental Ware Housing (2015) 374 ITR 645 (Mum.) (v) DCIT V/s Kalani Brothers (Indore) Pvt. Ltd. (2016) 27 TTJ 286 (Trib. Indore) (vi) Anant Steel Pvt. Ltd. V/s ACIT (2016) 28 ITJ 47 (Trib. Indore.)

“4.5 The appellant has also relied on the decision of Hon'ble ITAT Mumbai Bench in the case of ACIT vs Sar Yeash Co. (P) Ltd held as under:- “We observe that AO has made adhoc disallowance while completing assessment u/s 143(3) r.w.s. 153A of the Act which are not based on any, of the seized material found during the course of search. We are of the considered view that while making the assessment pursuant to search taken place and that too in a case where original return had already been accepted u/s 143(1) of the Act before the search had taken place, ad hoc addition made by the AO is not Justified, Similar question was also considered in the block assessment by Hon'ble Calcutta High Court in the case of Commissioner of Income Tax vs Ashim Krishna Mondal, 270 ITR 160 (Cal), wherein it was held no addition case be made in the block assessment based on estimate. In view of above facts that the, adhoc disallowance is not bases on any material found during the course of search the at the claim of the assessee is not genuine, we hold the order of Ld CIT (A) to delete the ad hoc disallowance made by AO does not call any interference. 4.6 The appellant has also relied on the decision of Hon'ble special Bench in the case of M/s All Cargo Global Logistics Limited vs DCIT as reported in 20 ITJ 045 where the bench has discussed the relevant provision of section 153A in light of the various decisions quoted before it. Hon'ble Bench in Paras 50, 51,53 & 58, observed, these paras read as under [ Refer Page Nos 82,83 & 89 of the ITJ):- "50. The provision contained in section 132 (1) empowers the officer to issue a warrant of search of the premises of a person where

IT(SS)A Nos.14to16/Ind/2018 & C.O. Nos. 19to21/Ind/2018 & IT(SS)A No. 141/Ind/2019 & ITA No. 740/Ind/2019 JCIT vs. Ayushajay Construction Pvt. Ltd. Asst. Years–2007-08 to 2009-10 & 2014-15 - 6 – anyone or more of conditions mentioned therein is or are satisfied, i.e. – a) summons or notice has been issued to produce books of account or other documents but such books of account or documents have not been produced, b) summons or notice has been or might be issued, he will not produce the books of account or other documents mentioned therein, or c) he is in possession of any: money or bullion etc. which represents wholly or partly the income or property which has not been and which would not be disclosed for the purpose of assessment, called as undisclosed income or property. We find that the provision in section 132 (1) does not use the word “incriminating document”. Clauses (a) and (b) of section 132(1) employ the words “books of account or other documents”. For harmonious interpretation of this provision with provision contained in section 153A, all the three conditions on satisfaction of which a warrant of search can be issued will have to be taken into account. 51. Having held so, an assessment or reassessment u/s 153A arises only when a search has been initiated and conducted. Therefore, such an assessment has a vital link with the initiation and conduct of the search. We have mentioned that a search can be authorised on satisfaction of one of the three conditions enumerated earlier. Therefore, while interpreting the provision contained in section 153A, all these conditions will have to be taken into account. With this, we proceed to literally interpret to provision in 153A as it exists and read it alongside the provision contained m section132(1). 53. The question now is - what is the scope of assessment or reassessment of total income u/s 153 A (1) (b) and the first proviso ? We are of the view that, for answering this question, guidance will have to be sought from section 132(1). If any books of account or other documents relevant to the assessment had not been produced in the course of original assessment and found in the course of search in our humble opinion, such books of account or other documents, have to be taken into account while making assessment or reassessment of

IT(SS)A Nos.14to16/Ind/2018 & C.O. Nos. 19to21/Ind/2018 & IT(SS)A No. 141/Ind/2019 & ITA No. 740/Ind/2019 JCIT vs. Ayushajay Construction Pvt. Ltd. Asst. Years–2007-08 to 2009-10 & 2014-15 - 7 – total income under the aforesaid provision. Similar position will obtain in a case where undisclosed income or undisclosed property has been found as a consequence of search. In other words, harmonious interpretation will produce the following results:- (a) Insofar as pending assessments are concerned, the jurisdiction to make original assessment and assessment u/s 153A merge into one and only one assessment for each assessment year shall be made separately on the basis of the findings of the search and any other material existing or brought on the record of the AO, (b) in respect of non-abated assessments, the assessment will be made on the basis of books of account or other documents not produced in the course of original assessment but found in the course of search, and undisclosed income or undisclosed property discovered in the course of search 58. Thus, question No. 1 before us is answered as under :(a) In assessments that are abated, the AO retains the original jurisdiction as well as jurisdiction conferred on him u/s 153Afor which assessments shall be made for each of the six assessment years separately; (b) In other cases, in addition to the income that has already been assessed, the assessment u/s 153A will be made on the basis of incriminating material, which in the context of relevant provisions means – (i) books of account, other documents, found in the course of search but not produced in the course of original assessment, and (ii) undisclosed income or property discovered in the course of search” 3.5.2] That in view of the above observation of the Hon'ble Special Bench of, ITAT in the case of M/s All Cargo Global Logistics Limited vs DCIT as reported in 20 ITJ 045. The case when proceeding was not pending as on the date of initiation of search falls in second proviso to section 153A(1) of the Income Tax Act, in clause (b) of Para 53 of the order of the Hon'ble ITAT special bench. In view of that para, the

IT(SS)A Nos.14to16/Ind/2018 & C.O. Nos. 19to21/Ind/2018 & IT(SS)A No. 141/Ind/2019 & ITA No. 740/Ind/2019 JCIT vs. Ayushajay Construction Pvt. Ltd. Asst. Years–2007-08 to 2009-10 & 2014-15 - 8 – assessment will be made on the basis of books of account or other documents not produced in the course of original assessment and that was the reason for execution of the search U/s 132 and these books of accounts were found and seized during the course of search. In that case, the assessing officer is empowered to examine these books of account for making addition to the income of the assessee. 3.5.3] That if during the course of search, any income or property which was discovered and not found as disclosed by the assessee. In that case, the assessing officer was empowered to make addition on the basis of that undisclosed income or property, which was detected during the course of search and not found recorded in the regular books of account of the assessee. 4.7 The facts of the case clearly indicate that the addition so made are not only on estimative /ad hoc basis but have been made without any incriminating documents. Thus, in view of the above judicial decisions and facts of the case, these grounds of appeal are accordingly allowed.”

IT(SS)A Nos.14to16/Ind/2018 & C.O. Nos. 19to21/Ind/2018 & IT(SS)A No. 141/Ind/2019 & ITA No. 740/Ind/2019 JCIT vs. Ayushajay Construction Pvt. Ltd. Asst. Years–2007-08 to 2009-10 & 2014-15 - 9 – facts and circumstances of the case, in our considered opinion, deletion of addition made by the Ld. A.O., without having any reference to the incriminating documents found during the course of search initiated under Section 153A of the Act keeping in view the ratio laid down by the different High Courts as mentioned hereinabove, is just and proper so as to warrant interference. Therefore, the appeals are filed by the Revenue is found to be devoid of any merit and thus, dismissed.

C.O. Nos. 19 to 21/Ind/2018 (A.Y. 2007-08 to 2009-10):- 8. Since these Revenue’s appeals have been dismissed, the Cross Objections become infructuous and hence dismissed as infructuous.

IT(SS)A No. 141/Ind/2019 (A.Y. 2014-15):- 9. The deletion of addition of Rs. 1,87,00,000/- is under challenged on account of suppressed Toll Receipts is the subject matter before us.

The above addition has been made on the basis of Page No. 110 & 113 of LPS-43 which relates to the A.Y. 2015-16 i.e. for the period of

IT(SS)A Nos.14to16/Ind/2018 & C.O. Nos. 19to21/Ind/2018 & IT(SS)A No. 141/Ind/2019 & ITA No. 740/Ind/2019 JCIT vs. Ayushajay Construction Pvt. Ltd. Asst. Years–2007-08 to 2009-10 & 2014-15 - 10 – 22.07.2014 to 22.08.2014 i.e. 27 days, while the period of assessment year in question is 2014-15 i.e. commencing from 01.04.2013 to 31.03.2014. In that view of the matter, this is an admitted position that no reference of any incriminating material pertaining to this assessment year under consideration found during the course of search has been made by the Ld. AO while making addition. Moreso, in respect of the additional income to the tune of Rs. 27,00,000/- already been surrendered by the assessee as it further appears from Question No. 32 to 34 raised to the assessee. Thus, the addition have been made merely on the basis of assumption and presumption neither there is any basis of calculating of any figure or suppressed Toll Receipt of Rs. 1,87,00,000/-. It is the contention of the assessee that before estimating the suppressed receipt the Ld. AO should have first rejected the appellant’s books of accounts. Moreso, there was no incriminating document seized during the search and seizure operation for the year under consideration. Section 153A should not be read in isolation of Section 132 of the Act only a valid search and seizure satisfying all the requirements of Section 132(1)(a)(b) and (c) could form the foundation of assumption of jurisdiction under Section 153A of the Act. The search operation under Section 132 of the Act could be initiated only against a person who is considered to be in possession of undisclosed income or property. The provision of Section 153 does not provide second or third indications to the Ld. AO so as to complete the normal scrutiny assessment. Existence of incriminating material, thus, a sine qua non of the assessment of jurisdiction under Section 153A of the Act and the same should also be

IT(SS)A Nos.14to16/Ind/2018 & C.O. Nos. 19to21/Ind/2018 & IT(SS)A No. 141/Ind/2019 & ITA No. 740/Ind/2019 JCIT vs. Ayushajay Construction Pvt. Ltd. Asst. Years–2007-08 to 2009-10 & 2014-15 - 11 – seen year to year basis revenue under the scheme of Section 153A for assessment year is also to be taken separately. It is an admitted position that disclosure for undisclosed income during search under Section 132 of the Act relating to those earlier assessment year does not lead to similar undisclosed income for these assessment year. The assessing officer does not have any evidence to produce to this party from 23.07.2014 to 17.08.2014 to be held that Toll Receipts has been suppressed by the appellant company subsequent to 17.08.2014. Thus, while making addition no incriminating material in respect of this particular period has been found to be referred by the Ld. A.O. Needless to mention that surrender of additional income was made on the basis of these loose papers rendering from 110 to 113 of LPS-43 only for A.Y. 2015-16. In fact, there is no incriminating material on the basis of which suppressed Toll Receipt have been added for earlier years. While considering the entire aspect of the matter the Ld. CIT(A) further observed and analyzed settled principle of law that in the search assessment no addition could be made on the basis of estimation / assumption / presumption. On this aspect he has further relied upon the judgment passed by the Coordinate Bench in the case of Monica Galaxy Pvt. Ltd. vs. ACIT, reported in (2018) 32 ITJ 637. The relevant observation whereof is as follows:

“We have considered the facts, rival submission and perused the material available on record. We have also gone through the orders of the lower authorities. We have also gone through the case laws cited by the Ld. Authorized Representative of the assessee. We find that on he basis of register market as BS-17-22 related with the period 01.04.2007 to 30.06.2007, which allegedly contained records of unaccounted

IT(SS)A Nos.14to16/Ind/2018 & C.O. Nos. 19to21/Ind/2018 & IT(SS)A No. 141/Ind/2019 & ITA No. 740/Ind/2019 JCIT vs. Ayushajay Construction Pvt. Ltd. Asst. Years–2007-08 to 2009-10 & 2014-15 - 12 – purchases and relying on the statements of the Director, the AO reached to the conclusion that the assessee suppressed its actual production and has unrecorded sales/purchases. We find that the sales were then estimated for all the years from 2002-03 to 2008-09 and cost of production was calculated for Assessment were duly field in time by the assessee. We find that no penalty or fine was ever levied to the assessee for non - maintenance of books or for not filling returns or for lapse of any other procedural requirement. We find that proper explanation was rendered at the time of assessment proceedings as well as before the Ld. CIT (A) for various observation made. We find that the estimation of sales based on the register seized is also not correct as all the assessment and other Assessment year to the Sales Tax Department and assessment for the Assessment year 2006-07 and 2007-08 were done under the sales Tax Act. We find that the Ld. Authorized Representative of the assessee ha s also reproduced the extract in his written submission and the same has been reproduced above also, which substantives that the entries from these record originate from the regular books of account. Copy of orders are placed in paper book at Vol. I page 15-18 the record pertained to the period from 01.04.2007 to 30.06.2007 i.e. Financial Year 2007-08 and has no nexus or relation or reference of any other year but the Financial year 2007-08 the anomalies or result of records pertaining to one year cannot be applied to other years either prospectively or retrospectively. As per the central Excise Act duty is levied on the manufacture or production of excusable goods similarly, Sales Tax is levied on "sales" and specifically covers and assesses sales of an entity. Since the assessee has clear assessment in these two Act. Which specifically assessee production and sales and the AO cannot draw inference under the Income-tax Act, basing on certain observation of the AO without any corroborative evidence. We also find that the sales have been estimated by increasing 10% of the estimated sales of the preceding year i.e 15% in case of Assessment Year 2003-04, Which is unreasonable. The increase of 10% / 15% on estimated sales, the net effect is increase of 56.36% in sales as compared to the sales shown in the trading account which is unrealistic and illogical. We also find that for the year 2008-09 also the sales were estimated based. Solely on the allegedly unrecorded purchase entries found in the raw material register of three months without any further finding or corroborative evidence, which is not justified. We have gone through the case Laws cited by the Ld. Authorized Representative of the assessee in the case of CIT v. Balchand Ajit Kumar,

IT(SS)A Nos.14to16/Ind/2018 & C.O. Nos. 19to21/Ind/2018 & IT(SS)A No. 141/Ind/2019 & ITA No. 740/Ind/2019 JCIT vs. Ayushajay Construction Pvt. Ltd. Asst. Years–2007-08 to 2009-10 & 2014-15 - 13 – (2007) 7 ITJ 324 (MP) and Man Mohan Sadani v. CIT, (2008) 11 ITJ 587 (MP) wherein the Hon’ble Jurisdictional High Court held as under:- Entire unrecorded sales cannot be treated as income – Net profit is to be applied,” We find that the above case laws cited by the Ld. Authorized Representative of the assessee are squarely applicable in the case of the assessee. We, therefore, delete the trading additions of Rs. 26,77,058/- and Rs 25,61,001/- in the Assessment Year 2006-07 and 2008-09 in view of our observation made above. Therefore, Grounds Taken in both the assessment years are allowed.”

He has further relied upon the judgment of Hon’ble Delhi High Court in the matter of PCIT vs. Meeta Gutgutiya, reported in (2017) 395 ITR 0526. The relevant observation whereof is as follows:

“15. On a plain reading of section It appears that a number of high court have concurred with the decision of this court in Kabul chawla (supra) beginning with the Gujarat high court in principal commissioner of Income Tax V. Saumya construction Pvt. Ltd (Supra). There, a search and seizure operation was carried out on 7th October, 2009 and an assessment came to be framed under section 143 (3) read with section 153A (b) in determining the total income of the Assessee of Rs. 14.5 crores against declared income of Rs. 3.44 cores, The ITAT deleted the additions on the ground that it was not based on any incriminating material found during the coerce of the search in respect of AYs under consideration i.e AY 2006-07 The Gujarat high court referred to the decision in Kabul chawla (supra) and one earlier decision of the Gujarat high court itself. It explained 153A of the Act, it is evident that the trigger point for exercise of powers there under 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 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 sections is to bring to tax the undisclosed income which is found during the coerce of or pursuant to the search or requisition However , instead of the artier regime of block assessment whereby, it was

IT(SS)A Nos.14to16/Ind/2018 & C.O. Nos. 19to21/Ind/2018 & IT(SS)A No. 141/Ind/2019 & ITA No. 740/Ind/2019 JCIT vs. Ayushajay Construction Pvt. Ltd. Asst. Years–2007-08 to 2009-10 & 2014-15 - 14 – only the undisclosed income of the Act seeks to assess the total income for the assessment year, which is clear from first proviso or which provisedes that the Asses sing year. The second proviso makes the intention of the legislature , if any, relating to the six assessment years referred to in the sub-section 132 or requisition under section 132A , as the case may be, shall abate if any proceeding or any order of made Unser section 132A as the case may be shall abate sub - section (2) of section 153A of the first Act provides that if any proceeding or any order of assessment or reassessment made provision then assessment or reassessment relating to any under sub-section (1) is assessment 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 there to of annulment is set aside. Thus, any six assessment year prior to the search or requisition stand abated and the total income of the assessee is requisition 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. 16. section 153A bears the heading "Assessment in case of search or requisition it is "well settled as held by the supreme court in a catena of decisions that the heading of the operative portion be regarded as a key to the interpretation of the operative portion of the section and if there is no ambiguity in the language or if it is plain and clear, then the heading used in the section strengthens that meaning. From the heading of section 153. The intention of the legislature is clear, Viz., to provide for assessment in case of search and requisition. When the very purpose of the provision is to make assessment in case of search or requisition, it goes without saying that the assessment has to have relation to the search or requisition, in other words, the assessment should connected with something round during the search requisition Viz. incrementing material which reveals undisclosed income. Thus , while in view of the mandate of sub-section (1) of section 153A of the Act, in every case where the is a search or requisition, the Assessment Officer is obliged to issue notice to such person to furnish returns if income for the six year preceding the assessment year relevant to the previous year In which the search is conducted or requisition is made any addition or disallowance can be made only on the basis of material collected during search or requisition in case incrementing material is found, as held by the Rajasthan high court in the case of Jai Steel (India) v. Asst. CIT (supra). The earlier assessment would have to be reiterated, in case where pending assessment have abated. The Assessing Officer can pass assessment order for each of the six years

IT(SS)A Nos.14to16/Ind/2018 & C.O. Nos. 19to21/Ind/2018 & IT(SS)A No. 141/Ind/2019 & ITA No. 740/Ind/2019 JCIT vs. Ayushajay Construction Pvt. Ltd. Asst. Years–2007-08 to 2009-10 & 2014-15 - 15 – determining the total income of the assessee which would include income declared in the returns, if any, unearthed during the search or requisition. In case where a pending reassessment under section 147 of the Act has abated, needless to state that the scope and ambit of the assessment would include any order which the Assessing Officer could have passed under section 147 of the Act as well as under section 153A of the Act.” 11. When there was no evidence found of this particular year the addition is not found to be sustainable in the hands of the appellant. The evidence if found the same should be restricted to the relevant assessment year and cannot be used for extrapolation of receipt for balance period. Neither any evidence is forthcoming for the Revenue so as to establish that the assessee followed the same practice, subsequently that is in the year under consideration. The evidence found in one year can be thus used in for another year to estimate the income. When no reference has been made to any incriminating material in respect of the year under consideration while making addition as per the ratio laid down in the judgment as also discussed hereinabove. The addition has been rightly found to be no sustainable and thus deleted by the Ld. CIT(A) and in our considered opinion is without any ambiguity so as to warrant interference. Thus, the appeal filed by the Revenue is found to be devoid of any merit and thus dismissed.

ITA No. 740/Ind/2019 (A.Y. 2014-15) 12. The quantum appeal preferred by the Revenue challenging the deletion of addition of Rs. 1,87,00,000/- since has already been dismissed in IT(SS)A No. 141/Ind/2019 for A.Y. 2014-15 the penalty proceedings lost

IT(SS)A Nos.14to16/Ind/2018 & C.O. Nos. 19to21/Ind/2018 & IT(SS)A No. 141/Ind/2019 & ITA No. 740/Ind/2019 JCIT vs. Ayushajay Construction Pvt. Ltd. Asst. Years–2007-08 to 2009-10 & 2014-15 - 16 –

its force and become infructuous. Thus, the appeal is found to be infructuous and hence dismissed as infructuous.

Order pronounced on 22/12/2022 by placing the result on the Notice Board as per Rule 34(4) of the Income Tax (Appellate Tribunal) Rule, 1963.

This Order pronounced in Open Court on /12/2022

Sd/- Sd/- Sd/- Sd/- (BHAGIRATH MAL BIYANI) (MADHUMITA ROY) ACCOUNTANT MEMBER JUDICIAL MEMBER Ahmedabad; Dated 22 /12/2022 TRUE COPY TANMAY, Sr. PS आदेश क� ��त�ल�प अ�े�षत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant 2. ��यथ� / The Respondent. 3. संबं�धत आयकर आयु�त / Concerned CIT 4. आयकर आयु�त(अपील) / The CIT(A)- 5. �वभागीय ��त�न�ध, आयकर अपील!य अ�धकरण, अहमदाबाद / DR, ITAT, Indore 6. गाड' फाईल / Guard file. आदेशानुसार/ BY ORDER, (Sr. Private Secretary) ITAT, Indore

IT(SS)A Nos.14to16/Ind/2018 & C.O. Nos. 19to21/Ind/2018 & IT(SS)A No. 141/Ind/2019 & ITA No. 740/Ind/2019 JCIT vs. Ayushajay Construction Pvt. Ltd. Asst. Years–2007-08 to 2009-10 & 2014-15 - 17 –