TULSI GRAMODYOG SEWA SAMITI,LUCKNOW vs. THE CIT (EXEMPTIONS), LUCKNOW, LUCKNOW
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Income Tax Appellate Tribunal, LUCKNOW BENCH “A”, LUCKNOW
Before: SHRI ANADEE NATH MISSHRA & SHRI SUBHASH MALGURIA
PER SUBHASH MALGURIA, J.M.:
These are appeals preferred by the assessee Trust against the action of the Ld. Commissioner of Income Tax (Exemptions), Lucknow dated 04.11.2022, wherein he was pleased to reject the applications filed by the assessee for registration u/s 80G(vi) of the Income Tax Act, 1961 (hereinafter “the Act”) as well as u/s 12AA(3) of the Act. These appeals were heard together and are disposed off by this common order for the sake of convenience.
The grounds of appeal of the assessee for ITA. No.217/LKW/2022 are as under: -
“01. Because the CIT(Exemption) has erred on facts and in law in withdrawing the approval granted to the society under section 80G(5) of the Income-tax Act, 1961, the order passed is contrary to the
ITA No.217 & 224/LKW/2022 Page 2 of 12 provisions of law, based on incorrect facts, without consideration of submissions and against the principles of natural justice, be quashed. 02. Because the CIT(Exemption) has failed to appreciate that the objects of the said assessee society, are all charitable in nature and the activities carried on by it are in accordance with its objects, the twin conditions i.e. the “objects being charitable” and “activities being in accordance with the objects”, not being in dispute, the CIT (Exemption) has erred in withdrawing the approval’ granted u/s.80G(5) of the Act, such order being contrary to the provisions of law be set-aside. 03. Because the CIT (Exemption) has erred in law in Passing the order on grounds/issues falling beyond the instructions of the order of Hon’ble ITAT dated 07.12.2018 which is outside the scope and powers of CIT(E), the order should have been confined to the issues as per the ITAT Order, as such, the order passed by CIT(E) withdrawing the approval u/s.80G is bad in law. 04. Because on a proper consideration of facts and circumstances of the case, the evidences as filed by the assessee society, none of them has been found to be false or untrue, the CIT (Exemption) was not justified in withdrawing the approval as granted to the assessee society. 05. Because in any case and in all circumstances of the case, the conditions as laid down for grant of approval under section 80G having all been fulfilled and there being no violation of the same, the withdrawal of approval as granted under section 80G(5) to the assessee society and as withdrawn be restored.” 3. The grounds of appeal of the assessee for ITA. No.224/LKW/2022 are as under: -
“01. Because the CIT(Exemption) has erred on facts and in law in cancelling the registration granted to the society by applying the provisions of section 12AA(3) of the Income-tax Act, 1961, the order passed is contrary to the provisions of law, based on incorrect facts, without consideration of submissions and against the principles of natural justice, be quashed. 02. Because the CIT(Exemption) has failed to appreciate that the objects of the said assessee society are purely charitable and the activities carried on by it are in accordance with its objects, the twin conditions i.e. the “objects being charitable” and “activities being in accordance with the objects”, not being in dispute, the CIT (Exemption) has travelled beyond the provisions of the Act by questioning the source of income, which is not relevant for the purpose of registration and is a subject matter for determination of income by the Assessing Officer as per section 11 and 13, the order passed by the CIT (Exemption) cancelling registration is bad in law and be quashed. 03. Because the CIT (Exemption) has erred in law in passing the order cancelling the registration on grounds/issues not arising out of the earlier order of Hon’ble ITAT, which being beyond the scope and powers of CIT(E), the impugned order should have been confined to the
ITA No.217 & 224/LKW/2022 Page 3 of 12 issue as directed by the ITAT, in its order dated 07.12.2018 thus the order passed by CIT(E) is bad in law and be set aside. 04. Because ona proper appraisal of the facts and circumstances of the case and on a proper reading of the statements of Parasmal Daga as recorded and the cross examination thereof, it would be found that Parasmal Daga is not related to the assessee society in any manner whatsoever, and no-where in the statement he has accepted any transaction having taken place through him regarding the assessee society, reliance on his statements being out of context, based on pure suspicion and surmises, the order passed by CIT (Exemption) is totally unwarranted, unjustified, bad in law and be quashed. 05. Because the CIT (Exemption) has failed to bring on record any material or communication from the donors denying the donation made by them both in respect of the amount and its nature, in absence of any such denial directly by the donor, the CIT (Exemption) has acted merely on suspicion, conjectures and surmises and has arbitrarily held that the donations received by the assessee society are not genuine, such finding being contrary to the facts of the case, against the provisions of law, the order passed cancelling the registration is bad in law, be quashed. 06. Because on a proper consideration of facts and circumstances of the case, the evidences as filed by the assessee society, none of them has been found to be false or untrue, the CIT (Exemption) was not justified in cancelling the registration as granted to the assessee society. 07. Because in any case and in all circumstances of the case, the conditions as laid down for grant of registration under section 12AA having all been fulfilled and there being no violation of the same, the registration as sought for and as granted under section 12AA to the assessee society and as cancelled on a wrong premise, be withdrawn and the registration as granted earlier be restored. 08. Because without prejudice to the aforesaid grounds of appeal there is nothing on record, not even in the statement recorded at the time of survey; and also, not even the reports of the DCIT(Inv.), Kolkata, suggesting that the donations received by the assessee society from the said donors is bogus, or non-genuine, the cancellation of registration granted u/s.12AA is totally misplaced, unwarranted, unjustified and thereby be restored.” 4. None was present on behalf of the assessee when the appeal was called out for hearing nor was any adjournment application received. However, looking into the facts of the case, we deem it appropriate to hear the appeal on merits ex-parte qua the assessee. 5. The ld. CIT (D.R.), on the other hand, has contended that the objections raised by the ld. CIT (E) in the impugned
ITA No.217 & 224/LKW/2022 Page 4 of 12 order do not stand rebutted. It has been contended that since the books of account and vouchers and land ownership documents were not made available for verification and also the applicant has failed to produce any material to prove the activities of the assessee/trust, the ld. CIT (E) has correctly rejected the application for registration.
The Ld. CIT(E) passed this order with observation that the material submitted by the assessee are not enough to arrive at a satisfaction about of objects of the trust and the genuineness of the trust and its activities, which are essential conditions before granting of registration. Ld. CIT(E) further observed that assessee has failed to furnish the required information despite giving opportunities. He further observed that in order to grant registration u/s 12AA(3) as well as 80G(5) of the Act, only when the Commissioner is satisfied about the objects of the Trust and the genuineness of its activities. Both these requirements are cumulative and not alternative. Further he observed that the onus is on the assessee to produce all relevant documents/information so as to enable the Commissioner to arrive at the requisite satisfaction about the objects of the trust and the genuineness of its activities. Further, he observed that it is not possible to ascertain the nature of objects for which the trust has been created and whether the same are charitable u/s. 2(15) or not and also its genuineness. Accordingly, he rejected registration 12AA(3) by passing this order by holding as under: -
“1. Ms Tulsi Gramodyog Sewa Samiti, the assessee, challenged the orders dated 29.04.2022 and 04.05.2022 passed by the Commissioner of Income Tax(Exemption), Lucknow, wherein registration granted to assessee u/s 12AA of the I.T. Act, and approval for acceptance of donation u/s 80G of the I.T. Act, were cancelled, respectively. 2. Hon'ble High Court Lucknow Bench vide judgment letter dated 18.05.2022 issued a direction to the Commissioner of Income
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Tax(Exemption), Kolkata to give opportunity to the petitioner, to cross examine Shri Paras Mal Daga on 14.06.2022. The relevant portion of the order is being reproduced as under: ‘Further, we direct that the Commissioner of Income Tax (Exemption), Kolkata shall give opportunity to the petitioner to cross 6xamine Shri Paras Mal Daga. To avoid any ambiguity, we provide that the matter shall be fixed before the Commissioner of Income Tax (Exemption), Kolkata on 14.06.2022 on which date the petitioner shall be Permitted to cross examine Shri Paras Mal Daga. For the said purpose notice will be required to be served upon the petitioner by the Commissioner Of Income Tax (Exemption), shall take requisite steps to ensure the presence of Shri Paras Mal Daga on the said date So that the petitioner may be given the opportunity to cross examine him. On being cross examined if any proceedings are to be drawn further, the same shall also be drawn and thereafter the final order may be passed by the competent authority within next four weeks thereafter.” 3. In compliance with the order of Hon’ble High Court, Lucknow Bench dated 18.05.2022, the Commissioner of Income Tax (Exemption), Kolkata was briefed with the facts of the case vide a letter dated 31.05.2022. Further, the trustee of the trust i.e. M/s Tulsi Gramodyog Sewa Samiti was requested to comply with the order of Hon'ble High Court dated 18.05.2022. 4. The Commissioner of Income Tax(Exemption), Kolkata vide his letter dated 15.06.2022 intimated that i in compliance to order 18.05.2022 of Hon'ble High Court, Lvicknow in ‘Writ Tax No. 96 of 2022, a summon u/s 131 of the I.T. Act, 1961 was issued to Shri Paras Mal Daga to ensure his presence on 14.06.2022 so that the petitioner may get an opportunity to cross examine Shri Paras Mal Daga. 5. Shri Paras Mal Saga appeared before the Commissioner of Income Tax (Exemption), Kolkata’ on 14.06. 2022 and his statement on oath was recorded. Furthers Shri ‘Pradeep Agatwal, President of M/s Tulsi Gramodyog Sewa Samiti, also appeared the said date to cross-examine Shri Paras Mal Daga in the presence of Commissioner of Income Tax(Exemption), Kolkata. 6. A show cause notice dated 28.06.2022 was issued to the assessee trust endorsing the copies of statement of Shri Paras Mal Daga recorded on 11.08.2015 & 25.04.2022 and cross examined by Shri Pradeep Agarwal, Director of M/s Tulsi Gramodyog. The facts of the statements of Shri Paras Mal Daga are the same as recorded on 11.08.2015 & 25.04.2022. It is clear that Shri Paras Mall Daga is the person who made the arrangements for accommodation entries and derived the income from brokerage in the statement he reiterated the modus operandi for arranging bogus donation by M/s Matravani Institute of Experimental Research and Education. The cross examination by the Shri Pradeep Agarwal has been done and in response to question no 16 Shri Paras Mal Daga has reiterated and reaffirmed his earlier statement recorded on 11.08.2015 & 28.04.2022. 7. The assessee vide its letter dated 04.07.2022 requested for certified copies of the statement of Sh Paras Mal Daga dated 14.06.2022 recorded on oath. The desired certified copies were already sent but on request of the petitioner same were provided again to the petitioner. However, Sh Pradeep Agarwal vide his letter dated 06.07.2022 sought adjournment for one month.
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Petitioner's adjournment request was considered & adjournment was granted for 08.08.2022 which was communicated vide letter dated 07.07.2022. 8. In its response petitioner has stated that: - “kindly refer above subjected notices thanks for providing date of hearing/compliance of Notice your kind self has provided date of 09.08.2022. It is brought to notice that myself on dated 12.07.2022 my wife on dated 09.07.2022 and my mother on dated 06.07.2022 reflecting positive Covid report. Report of same enclose herewith for your kind consideration. Due to positive Covid report my family has remain in Covid quarantine and being senior citizen feeling not well yet. | am the only person look after my old mother and self. It is worth to mention that as the no activity of Ms. Tulsi Gramodyog Sewa Samiti is in existence at presents hence no staff available. Due to above circumstances could not collect records in response to submitting the explanation against notices serve by your kind self. Hence your good Self is requested to provide a further one month time extension for reply/explanation to be submitted before your good-self.” Again on 09.08.2022 an adjournment application dated 08.08.2022 was received on ITBA portal with request to adjourn the date for one month. Considering the application, date of hearing/compliance has been refixed on 24.08.2022, vide this office letter dated 10.08.2022. On 22.08.2022 reply has been received vide letter dated 20.08.2022. Reply of the assessee has been duly considered. In the reply filed by the assesse, it is stated that registration u/s 12A & 80G was cancelled only on the basis of Statement of Sri Paras Mall Daga, and he has never confirmed to manage the bogus donation. However, from the statement of Sh Paras Mal Daga, following points are clear: (i). In his statement Sh Paras Mal Daga has reiterated and reaffirmed his earlier statement dated 11.8.2015 & 28.04.2022. (ii). From the content the statement, it is clear that Shri Paras Mal Daga is the person who made the arrangements for accommodation entries and derived the income from brokerage. The modus operandi for arranging bogus donations through M/s. Matravani Institute of Experimental Research and Education has been explained by Shri Paras Mal Daga in his statement recorded on 14.06.2022, 11.08.2015 & 28.04.2022. (iii). Further in answer to Query no 4 Shri Paras Mal Daga has made following statement: “Matravani Institute of Experimental Research and Education did not have any work of its own.... they use to work for bogus donations only” This statement truly explains the actual reason of existence of M/s Matravani Institute of Experimental Research and Education and the nature of receipts of Rs. 1,36,00,250/- received as donations from this entity by Tulsi Gramodyog.
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To substantiate the aforesaid fact it is reiterated that a survey operation was conducted on Matravani Institute of Experimental Research and Education and its ally Mr. Suman Verma. Mr. Suman Verma admitted that he has facilitated bogus donations to various entities in lieu of commission through various NGOs. Further, the documents impounded from the premises of Mr. Suman Verma contains the name of M/s Tulsi Gramodyog Sewa Samiti. (iv). It would be pertinent to mention that in query number 11, Sh Pradeep Agrawal tried to cross question Sh Paras Mal Daga and even tried to threaten him to reconsider his statement but despite all this Mr Daga has reaffirmed his original statement. (v). Furthermore, the statement of Sh Paras Mal Daga recorded on oath reaffirms the fact that the donations received by M/s Tulsi Gramodyog are bogus and the activities of the trust are non-genuine and non- charitable in nature. It is further stated that from various incriminating documents found during Survey operation conducted on M/s Matrivani Institute of Experimental Research & Education and assesse M/s Tulsi gramodyog Sewa Samiti, and also from the conclusion drawn in the assessment order it is clear that assessee has obtained donations which are not genuine and the activity carried out by the assessee are not charitable in nature, and accordingly after considering the submissions of the assessee along with the enclosures, registration granted u/s 12AA to the assessee is liable to be cancelled. 10. Full facts of the case as narrated in cancellation of registration order dated 29.04.2022 and 04.05.2022 are as under: - 10.1 A report was received from the Commissioner of Income-tax (Exemption), Kolkata vide letter F.No. CIT(E)/Kol/Bogus Donation/201516/3116 dated 28.10.2015. In the report it was mentioned that bogus donations were received in lieu of cash by the “Tulsi Gramodyog Sewa Samiti Lucknow’ from M/s Haerbicure Health care of Kolkata in AY 201112. It has further been reported that Tulsi Gramodyog Sewa Samiti has received donation of Rs 30 Lakh from M/s Govind Ram Goel Charitable Trust in AY 2013-14 and donation of Rs. 68 Lakh from M/s Matrivani Institute of Experimental Research & Education in AY 2014-15 by paying in cash. 10.2. On the basis of above information and material available on records as well as after providing the opportunities to the assessee, the registration granted u/s 12AA of the Income Tax Act 1961, to the above named assessee society was cancelled by the then Commissioner of Income-tax (Exemption), Lucknow vide order dated 10.12.2015 w.e.f ) 01.04.2012, on the basis of facts and circumstances of the case after following statutory formalities; The cancelation order dated 10.12.2015 is reproduced from page no. 12 to 14 in the impugned order of the Ld. CIT(E). And page no. 15 to 38 is also reproduced in the impugned order of the Ld. CIT(E) 10.13. However, assessee failed to furnish any cogent evidence or corroborative document in support of his claim despite numerous opportunities given. On examination of facts and circumstances of the case, it becomes amply clear that the activities of the assessee are not genuine and also not charitable in nature. Reasons are detailed as under: -
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On perusal of available records, it is seen that during the assessment proceedings for AY 2014-15 the assessee trust's alleged donations of Rs. 1,45,47,255/- were examined. During the assessment proceedings assessee was asked to furnish details of donors with name, complete address, ID proof and confirmation and also required to furnish books of account with supporting bills and vouchers. However, assessee trust failed to furnish anything in support of its claim and stated that “we have shifted our account office from Aliganj to Vikasnagar and during this process some documents were misplaced. Therefore we are not in position to submit the required documents”. As the donation received by the assessee trust was found to be non- genuine addition was made by the AO which has further been confirmed by the CIT (Appeal). These facts reveal that the activities of assessee trust are non. genuine. 1.Assessment proceedings for A.Y. 2015-16 were completed on 15.12.2017 and an addition of Rs.2,32,41,602/- was made considering it as income from undisclosed sources. During this year assessment' proceedings assessee was again asked to furnish details of donors with name, complete addresses ID proof and confirmation and also required to furnish account with supporting bills and vouchers. This time also assessee trust failed to furnish anything in support of its claim. These facts prove that Trust is not having any charitable activities, and also the activities are non- genuine. It is emphasized that the additions made on account 9 undisclosed income which has remained unexplained have also been confirmed by the Appellate authority, ie. CIT(Appeal). 4.To verify the veracity of the claim regarding bogus donations survey operation u/s 133A of the 1|.T. Act, was conducted 25.01.2018 on M/s Tulsi Gramodyog Sewa Samiti, Aliganj, Lucknow in which the assessee was found to be actively engaged in received bogus donations. 1.Assessment pertaining to A.Y. 2018-19 & 2019-20 have been completed on 04.03.2021 by ACIT(Central)-2, Lucknow consequent to the survey action upon the Trust. 1. During the assessment proceedings for AY 2019-20, several notices have been issued which remained non-complied. Notices Reply 06/01/2021, 08/01/2021 Non-complied. 27/01/2021 28/01/2021 Non-complied. 19/02/2021 Non-complied. Non-complied. Non-complied.
1.During the course of assessment proceedings for A.Y. 2018-19, it was noticed that assessee trust received credits in its bank accounts amounting to Rs. 1,00,34,998/-. As no explanation was offered by the assessee, total credits amounting to Rs. 1,00,34,998/- were added u/s 68 of the J.T. Act, as unexplained income.
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All the facts enumerated above prove that the assessee Trust never complied in true sprit with the requirements of the notices issued as well as show cause issued either in the earlier proceedings of the assessment pertaining to various years or cancellation of the registration or during the course of this proceedings in compliance with the order of Hon’ble ITAT Lucknow bench and Hon'ble High Court. 3. ln compliance with the principle of natural justice the assessee was provided with an opportunity of personal hearing during the course of this proceeding on 23.03.2022. However, assessee chose to furnish a response through dak on 21.03.2022. The submissions have been duly considered and it is found that instead of providing reply regarding the question raised for establishing the genuineness of the activities, the assessee has always filed evasive reply and preferred only to quote the order of Hon'ble ITAT/Hon’'ble High Court for providing cross- examination of the statement of Shri, Paras Mal Daga. 4.When as per his request a Commission was issued under section 131 of the Income Tax Act, 1961 and the assessee was given an opportunity to cross examine Shri Paras Mal Daga in compliance with the directions of the Honble ITAT, assessee failed to avail of the opportunity without furnishing any cogent reason. All these facts prove that the Assessee is, adopting dilatory tactics and filing evasive replies to the‘ queries: as he has got nothing substantial in support of his claim. 5. Furthermore, after deliberate non-compliance to the opportunity of cross examination of Shri Paras Mal Daga on 25.04.2022, assessee filed a reply vide email dated 26.04.2022 raising irrelevant issues. The fact is that sufficient and.-adequate. opportunity of cross examination as well as opportunity of being heard has been provided to the assessee during the course of the proceedings and the Assessee has deliberately not complied with any of the y opportunities given. Hence, Assessee Trust has failed to establish the genuineness of the donation received to the tune of Rs.1,45,47,255/- during the A.Y. 2014-15 and Rs. 2,32,41,602/- during the A.Y. 2015-16. It is a fact on record that the addition made by the Assessing Officer of Rs.1,45,47,255/- & Rs. 2,32,41,602/- on account of bogus donation has been upheld by the Appellant authority. 6. It is noted that the assessee has received cheques amounting ' Rs. 1,34,00,000/- during F.Y. 2013-14 from M/s Matrivani Institute of Experimental Research and Education as per copy of Indus Bank statement. The assessee has denied that any amount bash for obtaining donation by cheque. On the contrary, Shri Paras Mal Daga in his statement taken on oath & signed by him on 25/04/2022 has reaffirmed his earlier statement dated 11/08/2015, Q-8 of the said statement is reported as below: - Q.8 Previously, your statement was recorded u/s 131 of the I.T Act, 1967 on 11.08.2015 at the office of DDIT (investigation), Unit-4(1), Kolkata at room 5/7A, 5th Floor, Aayakar Bhawan Annexure Chowringhee Square, Kolkata-700069. What do you have to say on this regarding Question No. 9 to 14 which is being reproduced as under: Ans. Sir I confirm that the above statement has been given by me on Oath u/s 131 of the 11 Act, 1967 on 11.08.2015 at the office of DDIT (Investigation), Unit- 4(1), Kolkata at room no. 5/7A, 5! Floor, Aayakar Bhawan Annexe, P-13, Chowringhee Square, Kolkata 700069.
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Regarding Question No. 9, there are some change in my directorship during the course of time, viz. presently I am not a director in Shri Chaturbhuj Real Estates Private Limited and Bhansri Abasan Private Limited. In the remaining matters, I will stick to what I have already stated. The statement of Shri Paras Mal Daga proves that the trustees of M/s Matrivani Institute of Experimental Research & Education have given bogus donations in lieu of cash to the assessee trust. It has been clearly indicated in the statement and report sent by the Ld. CIT (E), Kolkata that the assessee has paid cash of Rs. 1,34,00,00.00/- in addition to commission to manage this donation of Rs. 1,34,00,000.00/- by cheque from M/s Matrivani Institute of Experimental Research & Education. The claim of the assessee that no cash was paid to M/s Matrivani Institute of Experimental Research & Education in lieu of donation by cheque is not acceptable as he has failed to corroborate his claim with the cogent evidences despite numerous opportunities being given to him from time to time. The assessee is having its business of producing handicraft item and is apparently running its business on commercial lines. Apparently the assessee is generating huge amount of cash by suppressing its sales or by inflating its expenditure. This cash so generated has been used to obtain or manage the donation from M/s Matrivani Institute of Experimental Research & Education by way of cheque after paying commission to M/s Matrivani Institute of Experimental Research @ Education. It is further relevant to note that during assessment proceedings in AY. 2018-19 and 2019-20 also the assessee has failed to establish the genuineness of the donations-taken during the aforesaid years. 11. The intention of the legislature to grant. registration u/s 12AA and 80G, is to give the benefit u/s 14 for, encouraging medical relief to the poor and needy persons, promoting education among masses and support to the poor section of the society.” But time and again these provisions have been misused for personal need and benefit of trustees/members of the trusts and societies. Survey u/s. 133A conducted in the case of assessee elaborates the nature and volume of transactions in the alleged. The registration granted u/s 12AA can be cancelled u/s 12AA(3) of the Income Tax Act, if the activity of the society are found to be non genuine or the activities are not being carried out in accordance with the objects of the trust/institution. In this case it is not and cannot be the objective of the assessee society to receive donation from another trust/society by paying amount in cash. In this case trust has taken case by either suppressing its sales or inflating its expenditure, and same has been used to obtain donation from M/s Matrivani Institute of Experimental Research & Education after paying commission. Thus the activities of the society are not carried out in accordance with object of the society: Moreover, the activities of the assessee society are non- genuine and non-charitable in nature. 12. Considering the above stated facts and, on the basis of material available on record and relying on the statement of Sri Paras Mal Daga, and also various incriminating documents found during survey operation conducted on assessee and M/s Matrivani Institute of Experimental Research & Education, on the basis of which assessment were made by the AO as discussed supra, I find that assessee has
ITA No.217 & 224/LKW/2022 Page 11 of 12 obtained donations which are not genuine and the activity carried out by the assessee are ‘not charitable in nature, and accordingly after considering the submissions of the assessee along with the enclosures, registration granted u/s 12AA to the assessee is liable to be cancelled. In view of the above mentioned facts, registration granted to the assessee is hereby cancelled w.e.f 01.04.2012.” 6. Neither side has brought any material for our consideration to persuade us to take a view different from view taken by the Ld.CIT(E), therefore, the impugned order of Ld. CIT(A) is upheld and the assessee’s appeal is dismissed. However, the assessee will be at liberty to approach this Tribunal, in accordance with law, for restoration of the appeal for disposal on merits, if the assessee advances reasonable cause for non-appearance when the appeal was called out for hearing on 20/08/2024.
In the result, the appeals of the assessee stands dismissed.
Order pronounced in the open Court on 22/08/2024.
Sd/- Sd/- [ANADEE NATH MISSHRA] [SUBHASH MALGURIA] ACCOUNTANT MEMBER JUDICIAL MEMBER
DATED: 22/08/2024 Vijay Pal Singh, (Sr. PS)
ITA No.217 & 224/LKW/2022 Page 12 of 12 Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. DR By order
Assistant Registrar //True Copy//
