CIT v. Lokpal Film Exchange (Cinema)

304 ITR 172High Court2008#5345 most cited

What is CIT v. Lokpal Film Exchange (Cinema) authority for?

A penalty under sections 271D and 271E cannot be imposed if the assessee acted bona fide and had a reasonable explanation, such as believing inter se transactions between partners and the firm were not governed by sections 269SS/269T, which constitutes a reasonable cause under section 273B.

22

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2024.

Also referred to as

CIT v. Lokpal Film Exchange (Cinema) · penalty under section 271D · penalty under section 271E · section 269SS · section 269T · reasonable cause · section 273B · bona fide belief · inter se transactions partners firm

Sections most often in play

Section 271DSection 271E

Issues it is cited on

penalty under section 271dsection 269ssection 273section 269tsection 269sssection 273bsection 271dsection 269section 26reasonable causesection 271section 27

Judgments citing CIT v. Lokpal Film Exchange (Cinema)

INCOMETAX OFFICER, KOZHIKODE vs. THE VENGERI SERVICE CO-OPERATIVE BANK LTD, KOZHIKODE

Appeals are hereby partly allowed

ITA 730/COCH/2023[2016-17]Status: DisposedITAT Cochin25 Sept 2024AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: ------- None -------For Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 269SSection 271D

…under section 271D and 271E of the Act: - "In our opinion, belief on the part of the assessee in view of the past history of the case that deposit/repayment by its members in cash is bonafide belief. In the case of CIT vs. Lokpal Film Exchange (Cinema) (2008) 304 ITR 172, the Hon'ble High Court held that the assessee had acted bonafidely and its plea that inter se transaction between the partners and the firm were not governed by the provision of section 269SS/269T, was a reasonable explanation and no penalty could be imposed. In view of the above, we are of the opinion that considering the bonafide and genuine t…

INCOME TAX OFFICER,WARD 1,KALPETTA, KALPETTA vs. MULLANKOLLY SERVICE CO OPERATIVE BANK LTD, MULLANKOLLY

Appeals are hereby partly allowed

ITA 729/COCH/2023[2015-16]Status: DisposedITAT Cochin25 Sept 2024AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Adithya Unnikrishnan, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 269SSection 271D

…under section 271D and 271E of the Act: - "In our opinion, belief on the part of the assessee in view of the past history of the case that deposit/repayment by its members in cash is bonafide belief. In the case of CIT vs. Lokpal Film Exchange (Cinema) (2008) 304 ITR 172, the Hon'ble High Court held that the assessee had acted bonafidely and its plea that inter se transaction between the partners and the firm were not governed by the provision of section 269SS/269T, was a reasonable explanation and no penalty could be imposed. In view of the above, we are of the opinion that considering the bonafide and genuine t…

INCOME TAX OFFICER,WARD 1,KLAPETTA, KALPETTA vs. MULLANKOLLY SERVICE CO OPERATIVE BANK LTD, MULLANKOLLY

Appeals are hereby partly allowed

ITA 728/COCH/2023[2015-16]Status: DisposedITAT Cochin25 Sept 2024AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Adithya Unnikrishnan, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 269SSection 271D

…under section 271D and 271E of the Act: - "In our opinion, belief on the part of the assessee in view of the past history of the case that deposit/repayment by its members in cash is bonafide belief. In the case of CIT vs. Lokpal Film Exchange (Cinema) (2008) 304 ITR 172, the Hon'ble High Court held that the assessee had acted bonafidely and its plea that inter se transaction between the partners and the firm were not governed by the provision of section 269SS/269T, was a reasonable explanation and no penalty could be imposed. In view of the above, we are of the opinion that considering the bonafide and genuine t…

INCOMETAX OFFICER, KOZHIKODE vs. THE VENGERI SERVICE COOPERATIVE BANK LTD, KOZHIKODE

Appeals are hereby partly allowed

ITA 727/COCH/2023[2016-17]Status: DisposedITAT Cochin25 Sept 2024AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: ------- None -------For Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 269SSection 271D

…under section 271D and 271E of the Act: - "In our opinion, belief on the part of the assessee in view of the past history of the case that deposit/repayment by its members in cash is bonafide belief. In the case of CIT vs. Lokpal Film Exchange (Cinema) (2008) 304 ITR 172, the Hon'ble High Court held that the assessee had acted bonafidely and its plea that inter se transaction between the partners and the firm were not governed by the provision of section 269SS/269T, was a reasonable explanation and no penalty could be imposed. In view of the above, we are of the opinion that considering the bonafide and genuine t…

KANHIAYA LAL SAIN,JAIPUR vs. JCIT RANGE-7 JAIPUR, JAIPUR

In the result, the Appeals of the appellant stands allowed with no orders as to costs

ITA 1022/JPR/2024[2010-11]Status: DisposedITAT Jaipur25 Sept 2024AY 2010-11

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 271Section 271DSection 271E

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, ‘’SMC” JAIPUR Jh lanhi xkslkbZ] U;kf;d lnL; ds le{k BEFORE: Hon’ble SHRI SANDEEP GOSAIN, JUDICIAL MEMBER vk;dj vihy la-@ITA No. 1022 &1023/JP/2024 fu/kZkj.k o"kZ@Assessment Year : 2010-11 Shri Kanhiya Lal Sain cuke The JCIT Vs. 7, Purana Ramgarh Mode Range-7 Anand Colony,Jaipur Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: BCYPS 6300 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@Assessee by : Shri Shrawan Kumar Gupta, Adv. jktLo dh vksj ls@Revenue by: Mrs. Monisha Choudhary, Addl. CIT-DR lquokb…

MAQTRO PICTURES,ERNAKULAM vs. ITO , NON CORPORATE WARD 2(4), KOCHI

In the result, the assessee’s appeal is partly allowed

ITA 999/COCH/2022[2017-18]Status: DisposedITAT Cochin25 Sept 2023AY 2017-18

Bench: Shri Sanjay Arora, Am &Shri Manomohan Das, Jm

For Appellant: Sri.P.M.Veeramani, CAFor Respondent: Smt.J.M.Jamuna Devi, Sr.DR
Section 250(6)Section 269SSection 269TSection 271DSection 68

…ssee is in second appeal. Maqtro Pictures v. ITO 3. The assessee’s only explanation before us, as indeed at the earlier stages, relying upon on the decision in CIT v. Muthoot Financiers [2015] 371 ITR 408 (Del) and CIT v. Lokhpat Film Exchange (Cinema) [2008] 304 ITR 172 (Raj), besides others by the Tribunal, was that a partnership firm is not a juristic person, much less independent and apart from its’ partners, being only a compendious name for the partners constituting it for the time being. Credits in their accounts cannot, therefore, be regarded as a loan or deposit, so as to contravene s.269SS. In fact, the…

SRI. PADMANABHA MANGALORE CHOWTA,MANGALORE vs. JOINT COMMISSIONER OF INCOME-TAX, RANGE-1, MANGALORE

In the result, the appeal of the assessee is allowed

ITA 1147/BANG/2022[2017-18]Status: DisposedITAT Bangalore07 Mar 2023AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2017 – 18

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri Gudimella VP Pavan Kumar, D.R
Section 269SSection 271Section 271DSection 273BSection 275

…ciate that the appellant bonafidely believed that such acceptance of cash was not in violation of law, which bonafide beliefs is also accepted by the decisions of the Hon'ble Rajasthan High Court in the case of CIT V. LOKPAT FILM EXCHANGE [CINEMA] reported in 304 ITR 172 [Raj] and also the decision of the Hon'ble ITAT, Ahmadabad Bench, in the case of ITO V. UNIVERSAL ASSOCIATES reported in TIOL-498/ITAT-AHM and consequently, the penalty levied u/s.271D of the Act, for the alleged violation u/s.269SS of the Act, requires to be cancelled having regard to the ratio of the decision of the Hon'ble Supreme Court in the…

THE MAMURPUR CO-OPERATIVE THRIFT AND CREDIT SOCIETY LTD.,NEW DELHI vs. ADDL. CIT, RANGE- 38, NEW DELHI

In the result, both the appeals filed by the assessee are allowed

ITA 1371/DEL/2019[2014-15]Status: DisposedITAT Delhi10 Sept 2020AY 2014-15

Bench: Shri H.S. Sidhu & Shri O.P. Kant

Section 143(2)Section 143(3)Section 269SSection 269TSection 271DSection 271ESection 27ISection 80P

…as not controverted the factual finding of the Learned Counsel of the assessee that in subsequent years also no penalty has been initiated/levied in the case of the assessee under section 271D/271E. In the case of CIT Vs Lokhpal Film Exchange (Cinema) (2008), 304 ITR 172, the Hon’ble High Court held that the assessee had acted bonafidely and its plea that inter se transaction between the partners and the firm were not governed by the provision of section 269SS/269T, was a reasonable explanation and no penalty could be imposed. In view of the above, we are of the opinion that considering the bonafide and genuine t…

THE MAMURPUR CO-OPERATIVE THRIFT AND CREDIT SOCIETY LTD.,NEW DELHI vs. ADDL. CIT, RANGE- 38, NEW DELHI

In the result, both the appeals filed by the assessee are allowed

ITA 1370/DEL/2019[2014-15]Status: DisposedITAT Delhi10 Sept 2020AY 2014-15

Bench: Shri H.S. Sidhu & Shri O.P. Kant

Section 143(2)Section 143(3)Section 269SSection 269TSection 271DSection 271ESection 27ISection 80P

…as not controverted the factual finding of the Learned Counsel of the assessee that in subsequent years also no penalty has been initiated/levied in the case of the assessee under section 271D/271E. In the case of CIT Vs Lokhpal Film Exchange (Cinema) (2008), 304 ITR 172, the Hon’ble High Court held that the assessee had acted bonafidely and its plea that inter se transaction between the partners and the firm were not governed by the provision of section 269SS/269T, was a reasonable explanation and no penalty could be imposed. In view of the above, we are of the opinion that considering the bonafide and genuine t…

SURENDRA ENGINERING CORPORATION,MUMBAI vs. JCIT 17(3), MUMBAI

In the result, appeal stands allowed

ITA 2386/MUM/2017[2012-13]Status: DisposedITAT Mumbai05 Dec 2019AY 2012-13

Bench: Shri Pramod Kumar & Shri Saktijit Dey

For Appellant: Shri Sanjay R. ParikhFor Respondent: Shri V. Vinod Kumar
Section 143(3)Section 2(23)Section 269SSection 271D

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI PRAMOD KUMAR, VICE PRESIDENT, AND SHRI SAKTIJIT DEY, JUDICIAL MEMBER ITA no.2386/Mum./2017 (Assessment Year : 2012–13) Surendra Engineering Corporation 1, Jaitirath Mansion 6A, Barrack Road ……………. Appellant Mumbai 400 020 PAN – AAAFS2803B v/s Jt. Commissioner of Income Tax ……………. Respondent Circle–17(3), Mumbai Assessee by : Shri Sanjay R. Parikh Revenue by : Shri V. Vinod Kumar Date of Hearing – 12.09.2019 Date of Order – 05.12.2019 O R D E R PER SAKTIJIT DEY, J.M. The captioned appeal has been filed by the assessee challenging the order d…

M/S. SHREE SAI ENTERPRISES,BHUBANESWAR vs. ADDL. CIT, RANGE-4, BHUBANESWAR

In the result, appeal of the assessee is allowed

ITA 290/CTK/2018[2014-15]Status: DisposedITAT Cuttack23 Aug 2019AY 2014-15

Bench: Shri Chandra Mohan Gargassessment Year: 2014-2015

For Appellant: Shri N.R.BiswalFor Respondent: Shri Subhendu Dutta, DR
Section 156Section 269SSection 271D

…at there is no separate legal entity for the partnership firm and the partner is entitled to use the funds of the firm. 11. We further note that even the Rajasthan High Court in the case of Commissioner of Income Tax Vs. Lokhpat Film Exchange (Cinema), (2008) 304 ITR 172 (Raj), relying upon the decision of the Supreme Court in R.M.Chidambaram Pillai (supra), dealing with identical facts, wherein, the firm during the relevant Assessment Year, received deposits from its partners. The Assessing Officer, considering it be a intra-party transactions of deposit, otherwise, than by way of a cheque or by bank draft, cons…

ACIT, NEW DELHI vs. SH. SATVINDER SINGH WADHAWAN, NEW DELHI

In the result, the Revenue’s appeal No

ITA 3081/DEL/2013[2008-09]Status: DisposedITAT Delhi21 Jun 2019AY 2008-09

Bench: Sh. H.S. Sidhu & Shri B.R.R. Kumar

Section 143(3)Section 269SSection 269TSection 271Section 271DSection 271E

…d as loans or deposits. Amount paid by firm to partners or vice versa- is payment to self and does not pa/take the character of loan or deposits in general law. Provisions of section 269SS are not applicable to such facts (CIT v. Lokhpat Film (Cinema) (2008) 304 ITR 172 (Raj.) 6.2 Deposit assessed as income, No penalty can be imposed u/s 271D in such case: it was held by Jodhpur tribunal in Bajrang Textiles v. Additional CIT [2009] (JD.) 190 that where the A.O having treated the impugned amount of deposit as income, he is precluded from treating the same amount as deposit or loan for the purpose of section S'…

ACIT, NEW DELHI vs. SH. SATVINDER SINGH WASHAWAN, NEW DELHI

In the result, the Revenue’s appeal No

ITA 3082/DEL/2013[2008-09]Status: DisposedITAT Delhi21 Jun 2019AY 2008-09

Bench: Sh. H.S. Sidhu & Shri B.R.R. Kumar

Section 143(3)Section 269SSection 269TSection 271Section 271DSection 271E

…d as loans or deposits. Amount paid by firm to partners or vice versa- is payment to self and does not pa/take the character of loan or deposits in general law. Provisions of section 269SS are not applicable to such facts (CIT v. Lokhpat Film (Cinema) (2008) 304 ITR 172 (Raj.) 6.2 Deposit assessed as income, No penalty can be imposed u/s 271D in such case: it was held by Jodhpur tribunal in Bajrang Textiles v. Additional CIT [2009] (JD.) 190 that where the A.O having treated the impugned amount of deposit as income, he is precluded from treating the same amount as deposit or loan for the purpose of section S'…

SMT ANITA HATI,KOLKATA vs. JCIT, RG-1, KOLKATA, HOOGHLY

In the result, the appeal of the assessee is allowed

ITA 921/KOL/2015[2009-2010]Status: DisposedITAT Kolkata20 Sept 2017AY 2009-2010
Section 269SSection 269TSection 271E

…in general law henceforth provisions of section 269SS & 269T are not applicable in such a case. 3. Smt. Anita Hati paid back the amount to fulfil the business requirement of the firm in which she is a partner. 4. In CIT vs Lokhpat firm exchange (Cinema) 2008, 304 ITR 172 (Raj) where the partnership firm had accepted cash deposits from its partners in the genuine bonafide belief that it was not different from them. Tribunal deleted penalty following CIT vs R.M. Chidambaram Pittars (1977) 106 ITR 292 (SC) holding that there cannot be a contract of service between firm and one of its partner applied if for purpose o…

SMT PARINITA HATI CHOWDHURY,KOLKATA vs. JCIT, RG-1, HOOGHLY, HOOGHLY

In the result, the appeal of the assessee is treated as allowed

ITA 920/KOL/2015[2009-2010]Status: DisposedITAT Kolkata20 Sept 2017AY 2009-2010

Bench: Shri P.M. Jagtap, Am & Shri S.S. Viswanethra Ravi, Jm] I.T.A. No. 920/Kol/2015 Assessment Year: 2009-10 Smt. Parinita Hati Chowdhury.............................……………………………………………Appellant C/O. V.N. Purohit & Co. Chartered Accountants, Diamond Chambers Unit Iii, 4Th Floor, Suit No. 4G 4, Chowringhee Lane Kolkata - 700016 [Pan : Adlpr2179P] J.C.I.T., Range-1………………………………………………................................................Respondent Aayakar Bhawan, Khadinamore G.T. Road, P.O. Chinsurah Hooghly - 712101 Appearances By: Shri V.N. Purohit, Fca Appearing On Behalf Of The Assessee. Shri Kalyan Nath, Addl. Cit Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : September 11, 2017 Date Of Pronouncing The Order : September 20, 2017 Order Per P.M. Jagtap, Am This Appeal Filed By The Assessee Is Directed Against The Order Of Ld. Cit (Appeals) – 6, Kolkata Dated 10.03.2015 Whereby He Confirmed The Penalty Of Rs. 53,000/- Imposed By The Ao Under Section 271E Of The Income Tax Act, 1961. 2. The Assessee In The Present Case Is An Individual Who Is Partner In The Partnership Firm Of M/S. S. Hati. As Noticed By The Ao During The Course Of Assessment Proceedings Of The Said Firm For A.Y. 2009-10, Loan Of Rs. 53,000/- Taken By The Assessee From The Said Firm Was Repaid In Cash. Since There Was A Violation Of Section 269T Of The Act

Section 269SSection 269TSection 271E

…w henceforth provisions of section 269SS & 269T are not applicable in such a case. 3. Smt. Parinita Hati Chowdhury paid back the amount to fulfil the business requirement of the firm in which she is a partner. 4. In CIT vs Lokhpat firm exchange (Cinema) 2008, 304 ITR 172 (Raj) where the partnership firm had accepted cash deposits from its partners in the genuine bonafide belief that it was not different from them. Tribunal deleted penalty following CIT vs R.M. Chidambaram Pittars (1977) 106 ITR 292 (SC) holding that there cannot be a contract of service between firm and one of its partner applied if for purpose o…

D. K. ENTERPRISE,HOOGHLY vs. JCIT, RG-1, BWN, BURDWAN

In the result, both the appeals of revenue are dismissed and that of assessee is allowed

ITA 849/KOL/2014[2010-2011]Status: DisposedITAT Kolkata14 Jul 2017AY 2010-2011

Bench: "ी ऐ. ट". वक", "यायीक सद"य एवं/And "ी एम. बालगनेश, लेखा सद"य) [Before Shri A. T. Varkey, Jm & Shri M. Balaganesh, Am]

Section 269SSection 271D

…assessment records by the Ld. CIT(A). The Ld. CIT(A) relying on the decision of the Coordinate Bench of this Tribunal in ITA No.1916/Kol/2004 and taking note of the decision of the Hon’ble Rajasthan High Court in CIT Vs. Lokhpat Film Exchange (cinema) (2008) 304 ITR 172 (Raj) and the Hon’ble Supreme Court’s decision in CIT Vs. R. M. Chidambaram Pillai 1977 CTR (SC) 71, (1977) 106 ITR 292 (SC) was pleased to delete the addition on the ground that payment of the amount by a partner to a firm is the payment to self and does not partake the character of loan or deposit in general law, therefore, according to the Ld.…

ITO, WD-1(3), BURDWAN, BURDWAN vs. M/S D. K. ENTERPRISE, BURDWAN

In the result, both the appeals of revenue are dismissed and that of assessee is allowed

ITA 1347/KOL/2014[2010-2011]Status: DisposedITAT Kolkata14 Jul 2017AY 2010-2011

Bench: "ी ऐ. ट". वक", "यायीक सद"य एवं/And "ी एम. बालगनेश, लेखा सद"य) [Before Shri A. T. Varkey, Jm & Shri M. Balaganesh, Am]

Section 269SSection 271D

…assessment records by the Ld. CIT(A). The Ld. CIT(A) relying on the decision of the Coordinate Bench of this Tribunal in ITA No.1916/Kol/2004 and taking note of the decision of the Hon’ble Rajasthan High Court in CIT Vs. Lokhpat Film Exchange (cinema) (2008) 304 ITR 172 (Raj) and the Hon’ble Supreme Court’s decision in CIT Vs. R. M. Chidambaram Pillai 1977 CTR (SC) 71, (1977) 106 ITR 292 (SC) was pleased to delete the addition on the ground that payment of the amount by a partner to a firm is the payment to self and does not partake the character of loan or deposit in general law, therefore, according to the Ld.…

ITO, WD-1(3), BURDWAN, BURDWAN vs. M/S D. K. ENTERPRISE, BURDWAN

In the result, both the appeals of revenue are dismissed and that of assessee is allowed

ITA 1346/KOL/2014[2010-2011]Status: DisposedITAT Kolkata14 Jul 2017AY 2010-2011

Bench: "ी ऐ. ट". वक", "यायीक सद"य एवं/And "ी एम. बालगनेश, लेखा सद"य) [Before Shri A. T. Varkey, Jm & Shri M. Balaganesh, Am]

Section 269SSection 271D

…assessment records by the Ld. CIT(A). The Ld. CIT(A) relying on the decision of the Coordinate Bench of this Tribunal in ITA No.1916/Kol/2004 and taking note of the decision of the Hon’ble Rajasthan High Court in CIT Vs. Lokhpat Film Exchange (cinema) (2008) 304 ITR 172 (Raj) and the Hon’ble Supreme Court’s decision in CIT Vs. R. M. Chidambaram Pillai 1977 CTR (SC) 71, (1977) 106 ITR 292 (SC) was pleased to delete the addition on the ground that payment of the amount by a partner to a firm is the payment to self and does not partake the character of loan or deposit in general law, therefore, according to the Ld.…

ITO, WARD-3(1),ASANSOL, ASANSOL vs. M/S RANJIT JEWELLERS, ASANSOL

In the result, the appeal of the revenue is dismissed

ITA 2425/KOL/2013[2008-09]Status: DisposedITAT Kolkata14 Dec 2016AY 2008-09
Section 143(3)Section 269SSection 269TSection 271DSection 271E

…s. Ranjit Jewellers . 2 the loan in cash and accordingly, imposed a penalty of Rs.12,31,400/- U/Sec. 271E of the Act 9. The CIT-A by relying on the decision of Hon’ble High Court of Rajasthan in the case of ITO Vs. Lokhpat Film Exchange (Cinema) reported in 304 ITR 172 (Raj) and on a decision of Kolkata Tribunal in ITA No.1916/Kol/2004 held that the firm and partners are not separate and cancelled the penalty imposed by the AO. 10. Before us the ld.DR submits that the Assessee himself admitted that he repaid the loan amounts to the said firm C.M.Roy & Sons in the assessment proceedings and changed his version…

ITO, NEW DELHI vs. SMT. KAVITA BEHAL, NEW DELHI

In the result, both the appeals of the Revenue stand dismissed

ITA 6529/DEL/2013[2009-10]Status: DisposedITAT Delhi16 Nov 2015AY 2009-10

Bench: Shri H.S. Sidhu

For Appellant: Sh. Sanjeev Saxena & Sh. Devinder KFor Respondent: Ms. Garima Jain, Sr. DR
Section 271DSection 271E

…ITA NOS. 6528 & 6529/Del/2013 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “SMC-2”, NEW DELHI BEFORE SHRI H.S. SIDHU, JUDICIAL MEMBER I.T.A. Nos. 6528 & 6529/DEL/2013 A.YR. : 2009-10 Smt. Kavita Behal, ITO, Ward-5(2), 49, Lajpat Nagar-III Room No. 234-B, CR Building, VS. Ring Road, IP Estate, New Delhi New Delhi (PANAAEPB271P) (APPELLANT) (APPELLANT) (RESPONDENT) (RESPONDENT) (APPELLANT) (APPELLANT) (RESPONDENT) (RESPONDENT) Department by : Ms. Garima Jain, Sr. DR Assessee by : Sh. Sanjeev Saxena & Sh. Devinder K. Jain, Cas Date of Hearing : Date of Hearing : 05 Date of Hearing : Date of Hearing : 05 0…

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