M.KANNABIRAN,CHENNAI vs. ITO, CHENNAI

आदेश /O R D E R

PER N.R.S. GANESAN, JUDICIAL MEMBER:

This appeal of the assessee is directed against the order of

the Commissioner of Income Tax (Appeals) – 14, Chennai, dated

05.08.2015 and pertains to assessment year 2009-10.

2 I.T.A. No.1863/Mds/15

submitted that the assessee, a retired employee of Supreme Court

of India, filed his return of income on 07.02.2011 for the assessment

year 2009-10. The Assessing Officer reopened the assessment by

issuing notice under Section 148 of the Income-tax Act, 1961 (in

short 'the Act') on the presumption that the assessee has not filed

any return of income. Referring to page 1 of the paper-book, the

Ld.counsel submitted that this is an acknowledgement for the return

uploaded by the assessee electronically on 07.02.2011. Therefore,

it is not correct to say that the assessee has not filed any return of

income for the assessment year 2009-10. Referring to the reasons

recorded by the Assessing Officer for reopening assessment, the

Ld.counsel submitted that the reason for reopening the assessment

was furnished only on 22.04.2015 after completion of assessment.

Therefore, the entire assessment proceeding is not valid. The

Ld.counsel placed his reliance on the judgment of Bombay High

Court in CIT v. Videsh Sanchar Nigam Ltd. (2012) 340 ITR 66 and

submitted that the Bombay High Court found that when the reasons

recorded for reopening of assessment were not furnished to the

assessee till the completion of assessment, then the reassessment

3 I.T.A. No.1863/Mds/15

proceeding cannot be upheld. In view of this judgment of the

Bombay High Court, the reopening of the assessment is not valid.

submitted that this is a copy of the reasons recorded by the

Assessing Officer for reopening of the assessment. According to

the Ld. counsel, the Assessing Officer found that the assessee has paid `2,24,800/- for purchasing a plot of 1603 sq.ft. and

`30,22,400/- for purchasing plot of 1841 sq.ft., to Tamil Nadu

Housing Board. The above said payments were made during the

financial year 2007-08 and 2009-10. The Assessing Officer

admitted that the assessee filed the return of income for the

assessment year 2009-10 on 07.02.2011 admitting a total income of `1,46,000/-. According to the Ld. counsel, when the amounts were

paid during the financial year 2007-08 and 2009-10, it is for the

Assessing Officer to reopen the assessments for the financial year

2007-08 and 2009-10 relevant to assessment year 2008-09 and

2010-11. On the basis of the payments said to be made for the

financial years 2007-08 and 2009-10, the assessment relating to

financial year 2008-09 relevant to assessment year 2009-10 cannot

4 I.T.A. No.1863/Mds/15

be reopened. Therefore, the entire reassessment proceeding is

invalid.

unexplained investment in the land. According to the Ld. counsel,

Tamil Nadu Housing Board allotted a plot to the assessee at Nolambur, Chennai on 18.06.2008 for `30,86,645/-. The assessee

explained the source for making investment during the financial year

2008-09 relevant to assessment year 2009-10, as follows:-

(a) Loan from Shri Sunilkumar ` 8,00,000/- (b) Loan from Shri Kandasamy ` 7,50,000/- (c) Loan from Shri K. Sreenivasan ` 2,50,000/- (d) Loan from Shri Surya ` 4,00,000/- (e) Loan from Shri Narayanan ` 3,00,000/- (f) From sale of jewellery ` 5,02,070/-

Out of this, the Assessing Officer herself admitted the loan of `8,00,000/- from Shri Sunilkumar. However, she did not accept the

loan from others and sale of jewellery to the extent of `22,86,645/-.

that Shri Kandasamy is none other than father-in-law of the

assessee. The said Shri Kandasamy confirmed the grant of loan

5 I.T.A. No.1863/Mds/15

before the Assessing Officer to the extent of `7,50,000/-. A copy of

the confirmation letter given by Shri Kandasamy is available at Annexure 2 of the paper-book. According to the Ld. counsel, Shri

Kandasamy is a retired teacher from Government school. Besides his pension, he is also having agricultural income. Shri Kandasamy is also earning income from painting. Shri Kandasamy’s son,

daughter and daughter-in-law are Government employees. However, the Assessing Officer rejected the claim of the assessee on the ground that Shri Kandasamy has withdrawn `5,89,000/- out

of his total retirement benefits of `6,11,689/-. Therefore, nothing is

left out. The Assessing Officer also found that Shri Kandasamy had no capacity to give `7,50,000/- to the assessee. Accordingly, the

Assessing Officer made an addition of `7,50,000/-. The Ld.counsel

submitted that Shri Kandasamy retired from service in the year 2004. The last drawn salary before his retirement was `8,000/-.

After the retirement, he was cultivating the land and doing painting work also. The Assessing Officer disbelieved the claim of the assessee with regard to agricultural income on the ground that the

Shri Kandasamy gifted the land to his daughter. According to the Ld. counsel, even after gift of land to his daughter, Shri Kandasamy continued to cultivate the land and earned agricultural income.

6 I.T.A. No.1863/Mds/15

According to the Ld. counsel, Shri Kandasamy, being a retired teacher, his savings were available for making loan of `7,50,000/- to

his son-in-law, the present assessee. The CIT(Appeals), without

appreciating the contention of the assessee, confirmed the addition

made by the Assessing Officer. According to the Ld. counsel, the

CIT(Appeals) ought to have appreciated the material available on

record, including the confirmation letter filed by Shri Kandasamy.

According to the Ld. counsel, at the best, the addition could be

made only in the hands of Shri Kandasamy and not in the hands of

the present assessee.

Seenivasan, the Ld.counsel for the assessee submitted that Shri

Seenivasan is none other than father-in-law of Shri M. Manohar,

younger brother of the assessee. Shri Seenivasan is running a

grocery store. During examination, Shri Seenivasan admitted that he gave a loan of `2.5 lakhs to Shri Kannabiran, the present

assessee, from the sale proceeds of his wife’s jewellery. Shri

Seenivasan has also filed a confirmation letter before the Assessing

Officer. When the payee confirms the payment of loan, according to

7 I.T.A. No.1863/Mds/15

the Ld. counsel, the CIT(Appeals) is not justified in confirming the

addition made by the Assessing Officer.

Shri Narayanan, the Ld.counsel for the assessee submitted that the assessee received a sum of `4,00,000/- from Shri Surya and also

received a loan of `3,00,000/- from Shri Narayanan. The Assessing

Officer made addition in respect of the loan received from Shri

Surya and Shri Narayanan on the ground that the letters sent to

them were returned unserved by the postal authorities with

endorsement “No such person”. Referring to copy of the Inspector’s

report, which is available at page 48 of the paper-book, the

Ld.counsel submitted that on 02.01.2015, the Inspector found that

the door was locked. However, when he visited the premises again

on 13.01.2015, he did not visit Flat No.B-6. The Inspector did not

investigate whether Shri Tamilselvan is the actual owner of the

property or not. According to the Ld. counsel, due to harassment by

the Department, Shri Surya and Shri Narayanan refused to give

confirmation letters. According to the Ld. counsel, the fact is that

the assessee has received the money from Shri Surya and Shri

Narayanan and the Assessing Officer has not taken any further

8 I.T.A. No.1863/Mds/15

steps after the letter return by the postal authorities. Therefore,

there is no justification for making any addition.

assessee sold jewellery to M/s Sujatha Jewellery, 33, Big Street,

Kumbakonam. The purchase bills were filed before the lower

authorities and copies of the same are available at pages 35 to 47

of the paper-book. The Assessing Officer claimed that one Shri

Inder Chand Chethia, proprietor of M/s Sujatha Jewellery, was

examined and told that no jewellery was purchased from the

assessee. When M/s Sujatha Jewellery filed receipt of purchase of

Jewellery and Shri Inder Chand Chethia clarified that he could not

recollect from whom the jewellery was purchased, there is no

justification for making any addition. The fact that M/s Sujatha

Jewellery issued purchase bills for purchasing jewellery is not in

dispute. It is not the case of the Revenue that the copies of the

purchase bills filed before the lower authorities are not the one

issued by M/s Sujatha Jewellery. The fact remains that the

purchase of jewellery from the assessee is evidenced by way of

9 I.T.A. No.1863/Mds/15

purchase bills filed. Therefore, the Assessing Officer cannot ignore

purchase bills issued by M/s Sujatha Jewellery.

According to the Ld. counsel, the assessee was employed as Junior

Attendant in Supreme Court of India for the last 29 years. Out of his

salary income, according to the Ld. counsel, the assessee saved `84,575/-, which was used for making investment in the landed

property. The Ld.counsel further submitted that the material

available on record clearly suggests that the persons who lent

money to the assessee had sufficient source of income. The

CIT(Appeals) without appreciating the material available on record,

simply confirmed the additions made by the Assessing Officer.

Therefore, the order passed by the CIT(Appeals) confirming the

order of the Assessing Officer is to be quashed.

Representative, submitted that admittedly, the assessee is a retired

employee of Supreme Court of India. Referring to the letter of the

Assessing Officer dated 22.04.2015, whereby the reasons for

reopening of assessment were given to the assessee, the Ld. D.R.

10 I.T.A. No.1863/Mds/15

submitted that the assessee himself asked for reasons vide his

letter dated 17.04.2015. It was admittedly furnished on 22.04.2015.

The assessment order was in fact completed on 31.03.2015.

Therefore, there is no negligence on the part of the Assessing

Officer in furnishing the reasons recorded for reopening of

assessment. On a query from the Bench, when the Assessing

Officer found that the assessee has paid the amounts during the

financial year 2007-08 and 2009-10 relevant to the assessment year

2008-09 and 2010-11, how the Assessing Officer reopened the

assessment for assessment year 2009-10? The Ld. D.R. could not

give any explanation. Referring to the observation made by the

Assessing Officer with regard to filing of return of income, the Ld.

D.R. submitted that the assessee filed the return of income

electronically, therefore, it was not within the knowledge of the

Assessing Officer. On a query from the Bench, when the

Department requests the citizens of this country to file the return

electronically, can the Assessing Officer say that the return was not

within her knowledge? The Ld. D.R. submitted that he has to verify

the details from the Assessing Officer. According to the Ld. D.R.,

the assessee has not disclosed the investment made by him in the

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return filed, therefore, the Assessing Officer has rightly reopened

the assessment by issuing notice under Section 148 of the Act.

that the Assessing Officer received information from Addl. Director

of Income Tax (Investigation), Kochi. Accordingly, certain enquiries

were conducted by the Deputy Director of Income Tax

(Investigation) regarding allotment of land by Tamil Nadu Housing

Board at Alapakkam and Nolambur to the assessee. According to

the Ld. D.R., the assessee applied for allotment of plots at

Nolambur and Alapakkam from Tamil Nadu Housing Board. During

the financial year 2007-08, the assessee was allotted a plot at Alapakam for a sum of `2.25 lakhs. On 18.06.2008, the assessee

was allotted another plot at Nolambur by Tamil Nadu Housing Board for a sum of `30,86,645/-. The assessee accepted the allotment

and paid a sum of `30,86,645/-. The assessee claimed that the

source for making investment was the fund borrowed from five

persons and sale of jewellery. In fact, the loan from Shri Sunil

Kumar was accepted by the Assessing Officer. However, in respect

of loans from Shri Kandasamy, Shri Seenivasan, Shri Surya and

Shri Narayanan were not accepted by the Assessing Officer.

12 I.T.A. No.1863/Mds/15

According to the Ld. D.R., Shri Kandasamy is a retired school

teacher and he has no sufficient funds for making savings to the extent of `7,50,000/-. Even though Shri Kandasamy confirmed the

loan given to the assessee to the extent of `7,50,000/-, the

Assessing Officer, on investigation, found that the said Shri

Kandasamy has no capacity to lend the money. Therefore, the

Assessing Officer rejected the claim of the assessee in respect of

the loan said to be received from Shri Kandasamy. Referring to the

loan said to be received from Shri Seenivasan, the Ld. D.R. pointed

out that the said Shri Seenivasan is the father-in-law of Shri M.

Manohar, the younger brother of the assessee. Shri Seenivasan

was having a small grocery shop. It was submitted before the

Assessing Officer that he has not advanced any loan.

Shri Narayanan, the Ld. D.R. pointed out that the assessee claimed before the Assessing Officer that he has taken loan of `4,00,000/-

from Shri Surya and a sum of `3,00,000/- from Shri Narayanan.

The Ld. D.R. further pointed out that the letter issued by the

Assessing Officer was returned with postal endorsement “No such

person/address”. Coming to the sale of jewellery, the Ld. D.R.

13 I.T.A. No.1863/Mds/15

pointed out that the assessee could not satisfy the Assessing Officer that he received `5,02,070/- towards sale proceeds of gold

jewellery. In the absence of any satisfactory reason, the Assessing

Officer has rightly rejected the claim of the assessee. The Ld. D.R. further submitted that in the absence of any evidence, the Assessing Officer has made an addition of ` 84,575/- which was

claimed as saving from salary. Accordingly, the Ld. D.R. submitted that the CIT(Appeals) has rightly confirmed the unexplained investment made by the assessee to the extent of `22,86,645/-.

the landed property. The assessee explained before the Assessing

Officer that the source for purchasing the landed property from Tamil Nadu Housing Board is the loan borrowed from various persons including the sale of gold jewellery belonging to the assessee and saving from salary to the extent of ` 84,575/-. In fact,

the assessee explained before the Assessing Officer that the Tamil

Nadu Housing Board allotted a plot of land to the assessee at

14 I.T.A. No.1863/Mds/15

Nolambur for a total sum of `30,86,645/-. The source for making

the payment to Tamil Nadu Housing Board is as follows:-

` 8,00,000/- (1) Loan from Shri Sunilkumar (2) Loan from Shri Kandasamy ` 7,50,000/- (3) Loan from Shri K. Seenivasan ` 2,50,000/- (4) Loan from Shri Surya ` 4,00,000/- (5) Loan from Shri Narayanan ` 3,00,000/- (6) Sale of gold jewellery ` 5,02,070/-

Admittedly, the Assessing Officer accepted the loan of `8,00,000/-

said to be received from Shri Sunilkumar. However, the Assessing

Officer rejected the claim of the assessee in respect of other loans and sale of jewellery to the extent of `22,86,645/-. The

CIT(Appeals) confirmed the addition made by the Assessing Officer.

explained by the assessee. The assessee submitted before the Assessing Officer that he received a sum of `7,50,000/- from his

father-in-law Shri Kandasamy. In fact, Shri Kandasamy appeared

before the Assessing Officer and confirmed the loan. The

Assessing Officer however rejected the claim of the assessee on

the ground that he has no source of income to advance `7,50,000/-

to the assessee. Referring to the written submission and the

annexures, which are available at paper-book, the Ld.counsel for

15 I.T.A. No.1863/Mds/15

the assessee pointed out that Shri Kandasamy is a retired teacher

drawing pension and he is also having agricultural land and

agricultural income. The Assessing Officer, after referring to the

explanation of the assessee, observed that Shri Kandasamy neither had means nor credible source to advance a sum of `7,50,000/- to

the assessee. The fact remains that Shri Kandasamy is a retired

teacher and is drawing pension regularly. He is also cultivating the

land and receiving agricultural income. From the orders of the lower

authorities it is seen that the assessee was holding 3.05 acres of

Nanjai lands and 32 cents of Punjai lands. The Assessing Officer

disbelieved the claim of agricultural income on the ground that the

assessee has gifted all the Nanjai lands to his daughter Smt.

Manjula in June, 2007. However, the said Shri Kandasamy claimd

before the Assessing Officer that even after gifting the lands to his

daughter, he was enjoying the agricultural income. The Assessing

Officer, mainly placing reliance on the statement made by Shri

Kandasamy that he is not in the habit of saving, observed that after

completion of marriage of his son and daughter, Shri Kandasamy

left with no cash balance. It is an admitted fact that the assessee has withdrawn a sum of `5,00,000/- on 10.06.2008. The Assessing

Officer disbelieved the claim of the assessee on the ground that the

16 I.T.A. No.1863/Mds/15

payment was said to be made in April, 2008. Therefore, the money

withdrawn on 10.06.2008 could not have been used for advancing

the same to the assessee. The fact remains that the assessee is a

retired Head Master of a school and he is receiving pension. The

assessee is also cultivating Nanjai lands to the extent of 3.02 acres.

The said Shri Kandasamy is residing in a village. His requirement

for daily maintenance is very low. This Tribunal is of the considered

opinion that even though the land was gifted to the daughter of Shri

Kandasamy, the fact that continuance of cultivating the land and

enjoying agricultural income cannot be doubted. The said Shri Kandasamy is having bank balance and withdrew `5,00,000/- on

10.06.2008. The observation made by the Assessing Officer at

para 2.4.5 of her order shows that there was a fixed deposit and

after maturity, the same was credited in the bank account.

Therefore, it cannot be said that the said Shri Kandasamy has no

habbit of saving.

totally ignored by the Assessing Officer while considering the cash

credit claimed by the assessee. During the financial year 2008-09

relevant to the assessment year under consideration, the agriculture

17 I.T.A. No.1863/Mds/15

coolie was `250/- per day for working for five hours. If a husband

and wife go for agriculture work in any of the family, they can earn minimum of `500/- per day. An average income of a family, which

goes for daily work is `15,000/- per month. The Assessing Officer

also needs to take into consideration that Government of Tamil Nadu is providing free rice to the extent 25 KGs to a family. After

taking into consideration that a reasonable family could save more than `400/- per day, that means the reasonable family having no

regular employment could save `12,000/- per month. The people in

the State, more particularly, in the agriculture sector are illiterate

and they do not have bank account. Therefore, the people use to save the money by keeping the cash in their respective house. When this is the economic situation prevailed in the country, an

educated person like Shri Kandasamy who is receiving pension apart from retirement benefits as a Head Master and is also cultivating land to the extent of 3.02 acres. Even if he estimates agricultural income to the extent of `1 lakh per acre, the average income would be `3 lakhs per annum. Apart from this, Shri

Kandasamy is also receiving pension. This Tribunal is of the considered opinion that when Shri Kandasamy is having so much of

resources or source for earning income, the Assessing Officer is not

18 I.T.A. No.1863/Mds/15

justified in rejecting the claim of Shri Kandasamy for advancing a sum of `7,50,000/- to the assessee who is none other than the son-

in-law of Shri Kandasamy. In view of this factual situation, this

Tribunal is unable to uphold the orders of the lower authorities.

father-in-law of the assessee’s brother Shri M. Manohar. The said Shri Seenivasan confirmed the loan of `2,50,000/- in writing. The

source for making the loan was the sale proceeds of gold jewellery

belonging to Shri Seenivasan.

131 of the Act. The said Shri Seenivasan claimed before the Assessing Officer that he was running a provision store for the last four years. He also claimed before the Assessing Officer that he was earning `10,000/- per month. In response to Question No.12,

the said Shri Seenivasan claimed before the Assessing Officer

during examination under Section 131 of the Act, that he advanced a sum of `2,50,000/- to the assessee, who is none other than the

brother of his son-in-law, from the sale proceeds of gold jewellery

19 I.T.A. No.1863/Mds/15

belonging to his wife. In response to Question No.23, the said Shri

Seenivasan clarified that on the suggestion / recommendation made by his son-in-law, he advanced a sum of `2,50,000/- to the

assessee. Lastly, in response to Question No.30, the said Shri

Seenivasan answered that he has not given any money to the

assessee. A bare reading of the statement said to be recorded from

Shri Seenivasan clearly shows that he advanced a sum of `2,50,000/- from the sale proceeds of the gold jewellery belonging

to his wife. When he was examined persistently, in response to

Question No.30, he explained that he has not given any money to

the assessee. This statement recorded by the Assessing Officer

wherein the said Shri Seenivasan denied the fact of advancing loan

does not inspire confidence. When Shri Seenivasan clearly

explained that he advanced money on the suggestion made by his

son son-in-law Shri Manoharan, to the assessee, from the sale

proceeds of gold jewellery belonging to his wife, it is not known

where the sale proceeds of gold jewellery has gone if the money

was not advanced to the assessee. Hence, the answer given by

Shri Seenivasan to Question No.30 before the Assessing Officer

does not inspire confidence. Therefore, the Assessing Officer

cannot place reliance only on the answer given by Shri Seenivasan

20 I.T.A. No.1863/Mds/15

to Question No.30, ignoring all other answers given by Shri

Seenivasan. This Tribunal is of the considered opinion that the

statement recorded from Shri Seenivasan clearly suggests that he advanced a sum of `2,50,000/- and the source for making such

advance was the sale proceeds of gold jewellery belonging to his

wife. In those circumstances, this Tribunal is of the considered

opinion that the Assessing Officer is not justified in rejecting the

source of loan said to be received by the assessee from Shri

Seenivasan.

and Shri Narayanan, the assessee claimed before the lower authorities that he received `4,00,000/- from Shri Surya and

`3,00,000/- from Shri Narayanan. The Assessing Officer placed

reliance on the Inspector’s report to show that the above said two

persons were not residing in the address given by the assessee. A

copy of the report said to have been filed by the Income-tax

Inspector before the Assessing Officer is available at page 48 of the

paper-book. The Assessing Officer also claimed that the notice

sent by her was returned with endorsement “no such person”. The

fact that the letter was returned with an endorsement “No such

21 I.T.A. No.1863/Mds/15

address/ person” and the Inspector’s report that no such person

lived in the address given by the assessee was not brought to the

notice of the assessee at any point of time during the assessment

proceedings. When the postal authorities returned the letter issued

by the Assessing Officer, this Tribunal is of the considered opinion

that the matter should have been brought to the notice of the

assessee and the assessee should have been given an opportunity

to collect the new address of Shri Surya and Shri Narayanan so that

the Assessing Officer can contact the creditors at new address.

The Assessing Officer has not taken any such step after return of

the letter by the postal authorities. An identical issue came before

the Apex Court in CIT v. Orissa Corporation P. Ltd. (1986) (159 ITR

78). The Apex Court after considering an identical situation, found

that since the Assessing Officer has not taken any further step to

find out the address of the creditor by bringing the same to the

notice of the assessee, found that there cannot be any addition. In

view of the judgment of the Apex Court in Orissa Corporation P. Ltd.

(supra), this Tribunal is unable to uphold the observation of the

Assessing Officer with regard to the creditors Shri Surya and Shri

Narayanan.

22 I.T.A. No.1863/Mds/15

Officer that the gold jewellery was sold to M/s Sujatha Jewellery at

Kumbakonam. The assessee has also shown copies of the bills of

M/s Sujatha Jewellery. It appears one Shri Inder Chand Chethia

claimed before the Assessing Officer that he is the proprietor of M/s

Sujatha Jewellery and he has not purchased any jewellery as

claimed. The assessee has produced a copy of the receipt issued

by M/s Sujatha Jewellery. The assessee has also filed a copy of

the statement recorded from Shri Inder Chand Chathia. Shri Inder

Chand Chethia clarified before the Assessing Officer that the

purchase bill for gold jewellery was prepared by his accountant Shri

Ramakrishnan. On the basis this statement, the said Shri

Ramakrishnan was also examined and copy of the statement

recorded from him is available at paper-book. Shri Ramakrishnan in

response to Question No.7, explained before the Assessing Officer

that Bill No.301 to Bill No.313 are with regard to purchase of gold

jewellery from Shri M. Kannabiran. The assessee has also filed

copies of the bills issued by M/s Sujatha Jewellery. When M/s

Sujatha Jewellery purchased the gold jewellery from the assessee

and issued purchase bills, it cannot be said that Shri Inder Chand

23 I.T.A. No.1863/Mds/15

Chethia denied the purchase of jewellery from the assessee. The

purchase bills produced by the assessee clearly show that the

assessee sold the gold jewellery to M/s Sujatha Jewellery.

Therefore, this Tribunal is of the considered opinion that there is no

reason to doubt the purchase bills issued by M/s Sujatha Jewellery.

Similarly, the assessee employed in Supreme Court around 29

years, therefore, this Tribunal is of the considered opinion that he might have saved ` 84,575/- from his salary income.

opinion that there is no justification in making addition of `22,86,645/-. Accordingly, the orders of the lower authorities are

set aside and the entire addition of `22,86,645/- is deleted. Since

the addition made by the Assessing Officer is deleted on merit, it

may not be necessary for this Tribunal to go into the alternative

grounds raised by the assessee with regard to year of payment as

mentioned by the Assessing Officer in the notice issued under

Section 147 of the Act and also legality of reopening of assessment

under Section 147 of the Act.

24 I.T.A. No.1863/Mds/15

Order pronounced on 20th November, 2015 at Chennai.

sd/- sd/- (ए. मोहन अलंकामणी) (एन.आर.एस. गणेशन) (A. Mohan Alankamony) (N.R.S. Ganesan) लेखा सद�य/Accountant Member �या�यक सद�य/Judicial Member

चे�नई/Chennai, �दनांक/Dated, the 20th November, 2015.

Kri. आदेश क� ��त�ल�प अ�े�षत/Copy to: 1. अपीलाथ�/Appellant 2. ��यथ�/Respondent 3. आयकर आयु�त (अपील)/CIT(A)-14, Chennai 4. आयकर आयु�त/Pr.CIT-10, Chennai 5. �वभागीय ��त�न�ध/DR 6. गाड� फाईल/GF.