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Income Tax Appellate Tribunal, SURAT BENCH, SURAT
Before: SHRI PAWAN SINGH, JM & DR. A. L. SAINI, AM
IN THE INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI PAWAN SINGH, JM & DR. A. L. SAINI, AM आयकरअपीलसं./ITA Nos. 420 & 504 /SRT/2019 (�नधा�रणवष� / Assessment Year: (2007-08) (Virtual Court Hearing) Shri Gautam Chunilal Jain, Vs. The ITO, Ward-2(3)(7), Prop. of M/s Sai Star, 286, Laxmi Surat. Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. (Assessee) (Revenue) The ITO, Ward-2(3)(7), Vs. Shri Gautam Chunilal Jain, Surat. Prop. of M/s Sai Star, 286, Laxmi Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. �थायीलेखासं./जीआइआरसं./PAN/GIR No.: ABHPL0577D (Revenue) (Assessee) आयकरअपीलसं./ITA Nos. 215/SRT/2020 & 575/SRT/2019 (�नधा�रणवष� / Assessment Year: (2007-08) Shri Kushal R. Jain, The ITO, Ward-3(3)(3), Vs. Prop. M/s Kunal Gems, C/o. Surat. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. (Assessee) (Revenue) The ITO, Ward-3(3)(3), Vs. Shri Kushal R. Jain, Surat. Prop. M/s Kunal Gems, C/o. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. �थायीलेखासं./जीआइआरसं./PAN/GIR No.: ADVPJ6155B (Revenue) (Assessee) Assessee by Shri Himanshu Gandhi, CA Shri H. P. Meena, CIT(DR) Respondent by Date of Hearing 21/03/2022 Date of Pronouncement 29/03/2022 आदेश / O R D E R PER DR. A. L. SAINI, AM: Captioned cross appeals filed by the Assessees and Revenue, pertaining to Assessment Year (AY) 2007-08, are directed against the separate orders passed by the Learned Commissioner of Income Tax (Appeals)-1, Surat [in
ITA. 420 & 504, 575/SRT/2019 & 215/SRT/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain short “the ld. CIT(A)”] which in turn arise out of separate assessment orders passed by the Assessing Officer under section 143(3) r.w.s 147 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”).
Since, the issues involved in all the appeals are common, identical, therefore these appeals have been clubbed and heard together and a consolidated order is being passed for the sake of convenience and brevity. 3. Succinct facts are that during the assessment proceedings, Assessing Officer noted that assessee under consideration has been filling return of income as trader in rough and polished diamond and assessee had been filling return of income as trader only by mentioning the nature of business as the trader in ITR Form No.4. In view of the above facts, the assessee’s claim that he is a commission agent is not acceptable, it is only an attempt on the part of the assessee to avoid explanation for the bogus purchase. The assessee has debited in his books of accounts and consequently the tax liability which may arise as a result of disallowances of these purchases. In the assessee’s case, the department is in possession of the statement of Shri Rajendra Jain Group, Sanjay Jain and Dharmchand Jain Group who has admitted the nature of bogus transaction in his statement recorded under section 132(4) of the Income Tax Act, 1961. The Assessing Officer noted that Shri Gautam C. Jain, assessee made bogus purchases from Shri Rajendra Jain Group, Sanjay Group and Dharmchand Jain Group, amounting to Rs.42,22,03,472/-, therefore Assessing Officer disallowed all bogus purchases and made addition to the tune of Rs.42,22,03,472/-.
On appeal, the ld. CIT(A) in case of Gautam Lal Chunilal Jain restricted the addition to the extent of 5% of the impugned purchases at Rs.2,10,20,173/- (5% of Rs.42,04,03,472/-).
Aggrieved by the order of the ld. CIT(A), the Revenue as well as Assessee both are in appeal before us. The Revenue contended that addition made by the Assessing Officer at the rate of hundred percent of bogus purchase
ITA. 420 & 504, 575/SRT/2019 & 215/SRT/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain should be confirmed. However, the contention of the assessee in its cross-appeal is that no addition should be made on account of bogus purchases.
In case of Shri Kushal R. Jain, the Assessing Officer noted that assessee is one of the beneficiaries of entire non-genuine purchase transaction of Rs.59,90,66,263/-. During the course of search, statement of Shri Parveen Kr. Jain and Shri Uttam Hingar were recorded. In their statement, they had confessed to have entered into accommodation entry with the assessee through their group concerns namely M/s Avi Exports, M/s Vitrag Jewels and M/s Sun Diam. In the case of Shri Kushal R. Jain, the Assessing Officer made addition at the rate of 25% of bogus purchases of Rs.59,90,66,293/- which comes to Rs.14,97,66,573/-.
On appeal, ld. CIT(A), following the judgment of the Hon'ble jurisdictional High Court of Gujarat in the case of Mayank Diamond Pvt. Ltd. vs ITO, Tax Appeal No. 200 of 2003 dated 17.11.2014, restricted the addition to 5% of bogus purchases to the tune of Rs.2,99,53,314/- (5% of Rs.59,90,66,293/-).
Aggrieved by the order of the ld. CIT(A), the assessee was well as Revenue both are in appeal before us.
The contention of the Revenue is that addition made by the Assessing Officer must be sustained. However, contention of the assessee is that the addition restricted at the rate of 5% of bogus purchases should be entirely deleted.
We have heard both the parties and carefully gone through the submissions put forth on behalf of the assessee along with the documents furnished and the case laws relied upon, and perused the facts of the case including the findings of the ld. CIT(A) and other material brought on record. We note that in case of Rajendra Jain/Dharmchand Jain cases, the Co-ordinate Bench of Surat has sustained the addition at 6% of bogus purchases. Therefore,
ITA. 420 & 504, 575/SRT/2019 & 215/SRT/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain we note that these cross-appeals are squarely covered by the judgment of this Tribunal in the case of Pankaj K. Choudhary, in ITA No.1152/AHD/2017 for AY.2007-08 wherein the Tribunal held as follows: “12. We have heard the submission of ld.CIT-DR for the Revenue and the ld. Authorised Representative (AR) of the assessee. We have also gone through the various documentary evidences furnished by assessee. The ld. CIT-DR for the Revenue supported the order of AO. The ld. CIT-DR submits that Investigation Wing, Mumbai made a search on Bhanwarlal Jain Group. During the search and after search, the Investigation Wing made a thorough investigation and concluded that Bhanwarlal Jain Group and his associates including his sons were indulging in managing about 70 benami concerns. The benami concerns were engaged in providing accommodation entries. The assessee is one of the beneficiaries of such accommodation entries. In the transaction of accommodation entries, the documentary evidences are created in such a way, so that the bogus transaction is looks like genuine transaction. In bogus transaction, the fabricated evidences are always maintained perfectly. The assessee has obtained accommodation entry only to inflate the expenses and to reduce the ultimate profit. No stocks of diamonds were found at the time of search on Bhanwarlal Jain Group. The assessee has shown a very meagre gross profit (GP) @ 0.78% and not net profit (NP) at 0.02%. The ld. CIT(A) restricted the addition to the extent of 12.5% which is on the lower side. The ld. CIT-DR for the revenue prayed that disallowance made by the AO may be upheld or in alternative submitted that it may restricted at least @ 25%, keeping in view that the NP declared by the assessee is extremely on lower side. 13. On the validity of reopening, the ld.CIT-DR for the revenue submits that the AO received credible information about the accommodation entry provided by Bhanwarlal Jain Group. The assessee is one of the beneficiaries, who had availed accommodation entries from such hawala trader. At the time of recording reasons, the mere suspicious about the accommodation entry is sufficient as held by Hon'ble jurisdictional High Court in various cases. To support his submissions, the ld.CIT-DR relied upon the decision; Pushpak Bullion (P) Ltd Vs DCIT [2017] 85 taxmann.com 84(Gujarat High Court), Peass Industrial Engineers (P) Ltd Vs DCIT [2016] 73 taxmann.com 185 (Gujarat High Court), ITO Vs Purushttom Dass Bangur [1997} 90 Taxman 541 (SC) and Mayank Diamond Private Limited (2014) (11) TMI 812 (Gujarat High Court). AGR Investment Vs Additional Commissioner 197 Taxman 177 (Delhi) and Chuharmal Vs CIT [1998] 38 Taxman 190 (SC). 14. On the other hand, the ld.AR of the assessee submits that he has challenged the validity of reopening as well as restricting the addition to the extent of 12.50% of the alleged bogus purchases. The ld.AR of the assessee submits during the assessment, the AO has not made any independent investigation. The AO reopened the case of the assessee on the basis of third party information without making any preliminary investigation. The AO
ITA. 420 & 504, 575/SRT/2019 & 215/SRT/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain received vague information about providing accommodation entry by Bhanwarlal Jain Group. No specific information about the accommodation entry obtained by assessee was received by AO. There is no live link between the reasons recorded qua the assessee. Therefore, the re-opening is invalid and all subsequent action is liable to be set aside. 15. On account of additions of bogus purchases, the ld.AR submits that in the original assessment, the assessee filed its complete details of purchases to prove the genuineness of expenses. The AO accepted the same in the assessment order passed under section 143(3) on 10.03.2009. During re- assessment, the assessee again furnished complete details about the genuineness of purchases. The assessee filed confirmation purchases invoices, accounts of the parties, bank statement of assessee showing transaction to the banking channel. The AO has not made any comment on the documentary evidence furnished by assessee. The AO solely relied upon the statement of third party and the report of Investigation Wing. The report of wing and the statement of Bhanwarlal Jain were not provided to the assessee. The AO has not disputed the sales of assessee. No sale is possible in absence of purchase. The books of accounts were not rejected. The AO made the disallowance of entire purchases. The assessing officer not provided cross examination of the alleged hawala dealers. The disallowances sustained by the Ld. CIT(A) @ 12.5% of the impugned purchases, is on higher side and deserve to be deleted in total. The ld.AR of the assessee submits that entire purchases shown by assessee are genuine. In without prejudice and alternative submissions, the Ld. AR for the assessee submits that in alternative submission, the disallowance may be sustained on reasonable basis. To support his various submission, the ld.AR for the assessee is relied upon case laws: 1 M/s Andaman Timber industries VsCommissioner of Central Excise, CIVIL APPEAL NO. 4228 OF 2006 (Supreme Court) 2 CIT vs. Indrajit Singh Suri [2013] 33 taxmann.com 281 (Gujarat) 3 Albers Diamonds Pvt. Ltd. Vs ITO 1(1)(1), Surat I.T.A. No.776 &1180/AHD/2017 4 The PCIT-5 vs. M/s. Shodiman Investments Pvt. Ltd. TTANO. 1297 OF 2015 (Bombay High Court) 5 ShilpiJewellers Pvt. Ltd. vs. Union of India &Ors. WRIT PETITION NO. 3540 OF 2018 (Bombay High Court) 6 CIT in Vs. Mohmed Juned Dadani 355 ITR 172 (Gujarat) 7 Micro Inks Pvt. Ltd. Vs. ACIT [2017] 79 taxmann.com 153 (Gujarat) 8 Shakti Karnawat Vs. ITO - 2(3)(8), Surat ITA 1504/Ahd/2017 and 1381 /Ahd/2017 9 Asian Paints Ltd. Vs. DCIT, [2008] 296 ITR 90 (Bombay) 10 PCIT, Surat 1 Vs. Tejua Rohit kumar Kapadia [2018] 94 taxmann.com 325 (SC)
ITA. 420 & 504, 575/SRT/2019 & 215/SRT/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain 11 The PCIT-17 vs. M/s Mohommad Haji Adam & Co. ITA NO. 1004 OF 2016(Bombay High Court) 12 Pankaj Kanwarlal Jain HUF Vs. ITO 2(3)(8) Surat ITA.No.269/SRT/2017
In the rejoinder submissions the ld. CIT-DR for the revenue submits that that rigour of the rules of evidence contained in the Evidence Act is not applicable before the tax authorities. It was submitted that the ratio of various case laws relied by the ld. AR for the assessee is not applicable on the facts of the present cases. The ratio of decision of Hon’ble Gujarat High Court in Mayank Diamond Private Limited (supra) is directly applicable on the facts of the present case. 17. We have considered the submissions of the parties and have gone through the order of the lower authorities. We have also deliberated on each and every case laws relied by both the parties. We have also examined the financial statement of all the assessee(s) consisting of computation of income and audit report. We have also gone through the documentary evidences furnished in all cases. Ground No.1 in assessee’s appeal relates to the validity of reopening. The ld AR for the assessee vehemently argued that the AO reopened the case of the assessee on the basis of third party information, and without making any preliminary investigation, which was vague about the alleged accommodation entry by Bhanwarlal Jain Group. And that there was no specific information about the accommodation entry availed by the assessee. There is no live link between the reasons recorded qua the assessee. We find that the assessee has raised objection against the validity of the reopening before the AO. The objections of the assessee was duly disposed by AO in his order dated 09.02.2015. The assessee raised ground of appeal before ld CIT(A) while assailing the order of AO on reopening. The ld CIT(A) while considering the ground of appeal against the reopening held that the AO has received report from investigation wing Mumbai, which indicate that the assessee is beneficiary of the accommodation entry operators. The accommodation entry provider admitted before investigation wing that he has given such entry to various persons; based on such report the AO has reason to believe that the income of the assessee has escaped assessment and thus the action of AO in reopening is justified. 18. We find that the Hon’ble Jurisdictional High Court in Peass Industrial Engineers (P) Ltd Vs DCIT (supra) while considering the validity of similar notice of reopening, which was also issued on the basis of information of investigation wing that they have searched a person who is engaged in providing accommodation entries, held that where after scrutiny assessment the assessing officer received information from the investigation wing that well known entry operators of the country provided bogus entries to various beneficiaries, and assessee was one of such beneficiary, assessing officer was justified in re-opening assessment. Further similar view was taken by Hon’ble Jurisdictional High Court in Pushpak Bullion (P) Ltd Vs DCIT (supra). Therefore, respectfully following the order of Hon’ble High Court, we find that the assessing officer validly assumed the jurisdiction for making re-opening under section 147 on the basis of information of investigation wing Mumbai.
ITA. 420 & 504, 575/SRT/2019 & 215/SRT/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain So far as other submissions of the ld AR for the assessee that there is no live link of the reasons recorded, we find that the Hon’ble Jurisdictional High Court in Peass Industrial Engineers (P) Ltd clearly held that when assessing officer received information from the investigation wing that two well known entry operators of the country provided bogus entries to various beneficiaries, and assessee was one of such beneficiary, assessing officer was justified. Hence, the ground No. 1 in assessee’s appeal is dismissed. 19. Ground No. 2 in assessee’s appeal and the grounds of appeal raised by the revenue are interconnected, which relates to restricting the disallowance of bogus purchases to the extent of 12.5%. The AO made of 100% of purchases shown from the hawala dealers/ entry provider namely Bhanwarlal Jain. We find that the AO while making additions of 100%, of disputed purchases solely relied on the report of the investigation wing Mumbai. No independent investigation was carried by the AO. The AO has not disputed the sale of the assessee. The AO made no comment on the evidences furnished by the assessee. We further find that ld CIT(A), while considering the submissions of the assessee accepted the lapses on the part of the AO and noted that no sale is possible in absence of purchases. The Books of the assessee was not rejected by the AO. The ld CIT(A) on further examination of the facts and various legal submissions find that Ahmedabad Tribunal in Bholanath Poly Fab Private Limited (supra) held that in the such cases the addition of bogus purchases was sustained to the extent of 12%, on the observation that the assessee may have made purchases from elsewhere and obtained the bills from impugned supplier to inflate Gross Profit Rate. The ld CIT(A) by considering the overall facts, concluded that the 100% disallowance of purchase is not justified. We also find that the ld.CIT(A) also considered the decision of jurisdictional High Court in Mayank Diamonds Pvt. Ltd. (supra) and compared the fact of the present case with the facts in Mayank Diamonds Pvt Ltd (supra) and noted that assessee in that case was also engaged in the trading of polished diamonds. The ld CIT(A) noted that in that case the AO made disallowance of entire bogus purchase and on first appeal before CIT(A) the disallowances were maintained. However, the Tribunal gave partial relief to the assessee directing to sustain the addition @12% of such bogus purchases. And on further appeal, the Hon'ble High Court sustained Gross Profit Rate @ 5% being average rate of profit in industry. 20. Now adverting to the facts of the present case, the ld.CIT(A) held that in some other similar cases; though he had sustain 5% of Gross Profit Rate, considering the fact that where Gross Profit shown by those assessee’s are more than 5%. However, in the present case, the assessee has merely shown Gross Profit Rate only at 0.78% of turnover, accordingly, the ld. CIT(A) was of the view that disallowance of 12.5% of impugned purchases/bogus purchases would be reasonable to meet the end of justice. 21. We have seen that during the financial year under consideration the assessee has shown total turnover of Rs. 66,09,62,458/-. The assessee has shown Gross Profit @ .78% and net Profit @ .02% (page 11 of paper Book). The assessee while filing the return of income has declared taxable income of Rs.1,81,840/- only. We are conscious of the facts that dispute before us is only
ITA. 420 & 504, 575/SRT/2019 & 215/SRT/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain with regard of the disputed purchases of Rs, 4.34 Crore, which was shown to have purchased from the entity managed by Bhanwarlal Jain Group. During the search action on Bhanwarlal Jain no stock of goods/ material was found to the investigation party. Bhanwarlal Jain while filing return of income has offered commission income (entry provider). Before us, the ld CIT-DR for the revenue vehemently submitted that the ratio of decision of Hon’ble Gujarat High Court in Mayank Diamond Private Limited (supra) is directly applicable on the facts of the present case. We find that in Mayank Diamonds the Hon’ble High Court restricted the additions to 5% of GP. We have seen that in Mayank Diamonds P Ltd (supra), the assessee had declared GP @ 1.03% on turnover of Rs. 1.86 Crore. The disputed transaction in the said case was Rs. 1.68 Crore. However, in the present case the assessee has declared the GP @ 0.78%. It is settled law that under Income-tax, the tax authorities are not entitled to tax the entire transaction, but only the income component of the disputed transaction, to prevent the possibility of revenue leakage. Therefore, considering overall facts and circumstances of the present case, we are of the view that disallowances @ 6% of impugned purchases / disputed purchases would be sufficient to meet the possibility of revenue leakage. In the result the ground No. 2 of appeal raised by the assessee is partly allowed and the grounds of appeal raised by revenue are dismissed. 22. In the result the appeal of revenue is dismissed and the appeal of the assessee is partly allowed.” 11. Since the issue is squarely covered by the decision of the Co-ordinate Bench in the case of Pankaj K. Choudhary (supra) and there is no change in facts and law and Revenue is unable to produce any material to controvert the aforesaid findings of the Co-ordinate Bench (supra). We find no reason to interfere in the above said order of Co-ordinate Bench, therefore respectfully following the binding judgment of Co-ordinate Bench in the case of Pankaj K. Choudhary (supra), we dismiss the appeals of the assessees and we allow the appeals of the Revenue partly.
In the result, appeals filed by the assessees are dismissed whereas the appeals filed by the Revenue are partly allowed.
Before parting, we would like to deal with other arguments of the Learned Counsel for the assessee. Learned Counsel for the assessee submits that reopening of assessment is bad in law. However, Learned Departmental Representative (ld. DR) for the Revenue submits that first of all assessee has not raised this technical issue of reopening before the Assessing Officer. The ld. DR
ITA. 420 & 504, 575/SRT/2019 & 215/SRT/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain also argues that reasons recorded are as per the provisions of the Act. We have gone through the reasons recorded by the Assessing officer and noted that not only there existed, new information with the Assessing Officer from the creditable sources, but also that he has applied his mind and recorded the reasons. We note that Hon'ble Supreme Court in the case of Phul Chand Bajrang Lal and another vs. ITO 203 ITR 456, while considering the question of reassessment beyond the period of four years in the case of an assessee firm; had held that in case of acquiring fresh information specific in nature and reliable, relating to the concluded assessment, which went to falsify the statement made by the assessee at the time of original assessment and, therefore, he would be permitted under the law to draw fresh inference from such facts and material. The Court also went to an extent of saying that there are two distinct and different situations where the transaction itself on the basis of subsequent information is found to be bogus transaction and in such event, mere disclosure of the transaction cannot be said to be true and full disclosure and the Income-tax Officer would have jurisdiction to reopen the concluded assessment The Apex Court in the case of Phul Ghand Bajrang Lal (supra), observed as following: "...one has to look to the purpose and intent of the provisions. One of the purposes of Section 147 appears to be to ensure that a party cannot get away by willfully making a false or untrue statement at the time of original assessment and when that falsity comes to notice to turn around and say 'you accepted my lie, now your hands are tied and you can do nothing'. It would, be travesty of justice to allow the assessee that latitude."
The Hon'ble Gujarat High Court in the case of Dishman Pharmaceuticals and Chemicals Ltd. vs. DCIT (OSD), Ahmedabad (2012) 346 ITR 228 (Guj) has summed up the requirements of the law, in such circumstances and has held as following: "There is no set format in which such reasons must be recorded. It is not the language but the contents of such recorded reasons which assumes importance. In other words, a mere statement that the Assessing Officer had reason to believe that certain income has escaped assessment and such escapement of income was on account of non-filing of the return by the assessee or failure on his part to disclose fully and truly all material facts
ITA. 420 & 504, 575/SRT/2019 & 215/SRT/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain necessary for assessment would not be conclusive. Nor, absence of any such statement would be fatal, if on the basis of reasons recorded, it can be culled out that there were sufficient grounds for the Assessing Officer to hold such beliefs."
A three Judges bench of Hon'ble Gujarat High Court in the case of A.L.A. Firm v. CIT, 189 (1991) ITR 285, after an elaborate discussion of the subject opined that the jurisdiction of the Income Tax Officer to reassess income arises if he has in consequence of specific and relevant information coming into his possession subsequent to the previous concluded assessment, reason to believe, that income chargeable to tax and had escaped assessment. It was held that even if the information be such that it could have been obtained by the I.T.O. during the previous assessment proceedings by conducting an investigation or an enquiry but was not in fact so obtained, it would not affect the jurisdiction of the Income Tax Officer to initiate reassessment proceedings, if the twin conditions prescribed under Section 147 of the Act are satisfied.
In fact, in three recent judgments; the Hon'ble Gujarat High Court has upheld the reopening on similar facts. The case is squarely covered by these judgments which are: • Yogendrakumar Gupta vs. ITO 366 ITR 186 (Guj) • Peass Industrial Engineers (P) Ltd. 73 taxmann.com 185 (2016) • Order dated March 25, 2014 in the case of Lalita Ashwin Jain vs. ITO, Special Civil Application No. 1626 and 1627 of 2014. 17. As observed earlier not only there existed new information with the AO from the credible sources, but also he had applied his mind and recorded the conclusion that the purchases claimed were non-genuine and therefore bogus, (clearly meaning that what was disclosed was false and untruthful). The requirements of section 147 r.w.s. 148 have clearly been met; and the reopening is held justified and legal.
Based on these facts and circumstances, we dismiss the technical ground (reopening the assessment u/s 147) raised by the assessee.
ITA. 420 & 504, 575/SRT/2019 & 215/SRT/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain 19. In the result, appeals filed by the assessee in ITA Nos.215/SRT/2020, 420/SRT/2019 are dismissed and appeals filed by the Revenue in ITA Nos. 504/SRT/2019 and 575/SRT/2019 are partly allowed, to the extent indicated above.
Registry is directed to place one copy of this order in all appeals folder / case file(s).
Order is pronounced in the open court on 29/03/2022 by placing the result on the Notice Board as per Rule 34(5) of the Income Tax (Appellate Tribunal) Rule 1963.
Sd/- Sd/- (PAWAN SINGH) (Dr. A.L. SAINI) JUDICIAL MEMBER ACCOUNTANT MEMBER lwjr /Surat �दनांक/ Date: 29/03/2022 SAMANTA Copy of the Order forwarded to 1. The Assessee 2. The Respondent 3. The CIT(A) 4. CIT 5. DR/AR, ITAT, Surat 6. Guard File By Order // TRUE COPY // Assistant Registrar/Sr. PS/PS ITAT, Surat