Commissioner of Income Tax v. Triumph International Finance (I) Ltd.

345 ITR 270High Court2012#933 most cited

What is Commissioner of Income Tax v. Triumph International Finance (I) Ltd. authority for?

Transactions involving the receipt or repayment of loans or deposits solely through journal entries, without actual cash movement, contravene Sections 269SS and 269T. However, penalties under Sections 271D or 271E for such contraventions are not imposable if the assessee demonstrates a reasonable cause under Section 273B, particularly when no cash has passed between parties.

114

judgments rely on this decision, according to BharatTax’s citation analysis of 367,735 Indian tax judgments — from 2015 to 2026.

Also referred to as

Commissioner of Income Tax v. Triumph International Finance · penalty under Section 271D · penalty under Section 271E · Section 269SS · Section 269T · journal entries · loans and deposits · reasonable cause · Section 273B · deletion of penalty

Also reported as

22 Taxmann.com 138208 Taxmann 299

Sections most often in play

Section 269SS Section 271D Section 143(3)Section 271E Section 273B Section 269T Section 10(26AAA)Section 68

Issues it is cited on

penalty under section 271e penalty under section 271d section 269t section 269s section 271e section 273 section 269ss section 271d section 269 deletion of penalty section 249(3)section 273b

Judgments citing Commissioner of Income Tax v. Triumph International Finance (I) Ltd.

DCIT Cen Cir 7(3), Mumbai vs. Lodha Building & Construction P.Ltd, Mumbai

In the result, all the appeals filed by the Revenue are dismissed and cross objections filed by the assessee are allowed

ITA 138/MUM/2017[2009-10]Status: DisposedITAT Mumbai31 Jan 2020AY 2009-10

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

…us are agreed that the Tribunal was correct in holding that receipt of any advance / loan by way of journal entries is in breach of Section 269SS of the Act as the decision of this Court in Commissioner of Income Tax Vs. Triumph International Finance (I) Ltd. 345 ITR 270 is binding upon it. However, the Revenue's grievance is with the impugned order dated 27th June, 2014 of the Tribunal further holding no penalty under Section 271D of the Act is imposable in view of Section 273B of the Act in the present facts. This is so as the Tribunal holds that the failure to comply with Section 269SS of the Act was on accoun…

DCIT Cen Cir 7(3), Mumbai vs. Lodha Building & Construction P.Ltd, Mumbai

In the result, all the appeals filed by the Revenue are dismissed and cross objections filed by the assessee are allowed

ITA 137/MUM/2017[2009-10]Status: DisposedITAT Mumbai31 Jan 2020AY 2009-10

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

…us are agreed that the Tribunal was correct in holding that receipt of any advance / loan by way of journal entries is in breach of Section 269SS of the Act as the decision of this Court in Commissioner of Income Tax Vs. Triumph International Finance (I) Ltd. 345 ITR 270 is binding upon it. However, the Revenue's grievance is with the impugned order dated 27th June, 2014 of the Tribunal further holding no penalty under Section 271D of the Act is imposable in view of Section 273B of the Act in the present facts. This is so as the Tribunal holds that the failure to comply with Section 269SS of the Act was on accoun…

DCIT Cen Cir 7(3), Mumbai vs. Lodha Building & Construction P.Ltd, Mumbai

In the result, all the appeals filed by the Revenue are dismissed and cross objections filed by the assessee are allowed

ITA 136/MUM/2017[2008-09]Status: DisposedITAT Mumbai31 Jan 2020AY 2008-09

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

…us are agreed that the Tribunal was correct in holding that receipt of any advance / loan by way of journal entries is in breach of Section 269SS of the Act as the decision of this Court in Commissioner of Income Tax Vs. Triumph International Finance (I) Ltd. 345 ITR 270 is binding upon it. However, the Revenue's grievance is with the impugned order dated 27th June, 2014 of the Tribunal further holding no penalty under Section 271D of the Act is imposable in view of Section 273B of the Act in the present facts. This is so as the Tribunal holds that the failure to comply with Section 269SS of the Act was on accoun…

DCIT Cen Cir 7(3), Mumbai vs. Lodha Builders P. Ltd, Mumbai

In the result, all the appeals filed by the Revenue are dismissed and cross objections filed by the assessee are allowed

ITA 6617/MUM/2016[2011-12]Status: DisposedITAT Mumbai31 Jan 2020AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

…us are agreed that the Tribunal was correct in holding that receipt of any advance / loan by way of journal entries is in breach of Section 269SS of the Act as the decision of this Court in Commissioner of Income Tax Vs. Triumph International Finance (I) Ltd. 345 ITR 270 is binding upon it. However, the Revenue's grievance is with the impugned order dated 27th June, 2014 of the Tribunal further holding no penalty under Section 271D of the Act is imposable in view of Section 273B of the Act in the present facts. This is so as the Tribunal holds that the failure to comply with Section 269SS of the Act was on accoun…

DCIT Cen Cir 7(3), Mumbai vs. Lodha Builders P. Ltd, Mumbai

In the result, all the appeals filed by the Revenue are dismissed and cross objections filed by the assessee are allowed

ITA 6616/MUM/2016[2011-12]Status: DisposedITAT Mumbai31 Jan 2020AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

…us are agreed that the Tribunal was correct in holding that receipt of any advance / loan by way of journal entries is in breach of Section 269SS of the Act as the decision of this Court in Commissioner of Income Tax Vs. Triumph International Finance (I) Ltd. 345 ITR 270 is binding upon it. However, the Revenue's grievance is with the impugned order dated 27th June, 2014 of the Tribunal further holding no penalty under Section 271D of the Act is imposable in view of Section 273B of the Act in the present facts. This is so as the Tribunal holds that the failure to comply with Section 269SS of the Act was on accoun…

DCIT Cen Cir 7(3), Mumbai vs. Lodha Builders P. Ltd, Mumbai

In the result, all the appeals filed by the Revenue are dismissed and cross objections filed by the assessee are allowed

ITA 6615/MUM/2016[2007-08]Status: DisposedITAT Mumbai31 Jan 2020AY 2007-08

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

…us are agreed that the Tribunal was correct in holding that receipt of any advance / loan by way of journal entries is in breach of Section 269SS of the Act as the decision of this Court in Commissioner of Income Tax Vs. Triumph International Finance (I) Ltd. 345 ITR 270 is binding upon it. However, the Revenue's grievance is with the impugned order dated 27th June, 2014 of the Tribunal further holding no penalty under Section 271D of the Act is imposable in view of Section 273B of the Act in the present facts. This is so as the Tribunal holds that the failure to comply with Section 269SS of the Act was on accoun…

DCIT Cen Cir 7(3), Mumbai vs. Lodha Builders P. Ltd, Mumbai

In the result, all the appeals filed by the Revenue are dismissed and cross objections filed by the assessee are allowed

ITA 6614/MUM/2016[2007-08]Status: DisposedITAT Mumbai31 Jan 2020AY 2007-08

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

…us are agreed that the Tribunal was correct in holding that receipt of any advance / loan by way of journal entries is in breach of Section 269SS of the Act as the decision of this Court in Commissioner of Income Tax Vs. Triumph International Finance (I) Ltd. 345 ITR 270 is binding upon it. However, the Revenue's grievance is with the impugned order dated 27th June, 2014 of the Tribunal further holding no penalty under Section 271D of the Act is imposable in view of Section 273B of the Act in the present facts. This is so as the Tribunal holds that the failure to comply with Section 269SS of the Act was on accoun…

DCIT Cen Cir 7(3), Mumbai vs. Lodha Properties Development P. Ltd, Mumbai

In the result, all the appeals filed by the Revenue are dismissed and cross objections filed by the assessee are allowed

ITA 6613/MUM/2016[2009-10]Status: DisposedITAT Mumbai31 Jan 2020AY 2009-10

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

…us are agreed that the Tribunal was correct in holding that receipt of any advance / loan by way of journal entries is in breach of Section 269SS of the Act as the decision of this Court in Commissioner of Income Tax Vs. Triumph International Finance (I) Ltd. 345 ITR 270 is binding upon it. However, the Revenue's grievance is with the impugned order dated 27th June, 2014 of the Tribunal further holding no penalty under Section 271D of the Act is imposable in view of Section 273B of the Act in the present facts. This is so as the Tribunal holds that the failure to comply with Section 269SS of the Act was on accoun…

DCIT Cen Cir 7(3), Mumbai vs. Simtoos P.Ltd, Mumbai

Appeals of the Revenue are dismissed

ITA 7123/MUM/2016[2011-12]Status: DisposedITAT Mumbai13 Sept 2019AY 2011-12

Bench: Shri Rajesh Kumar & Shri Amarjit Singhassessment Year: 2011-12

For Appellant: Shri Vijay Mehta, A.RFor Respondent: Shri Manoj Kumar Singh, D.R

Section 143(3)Section 269TSection 271ESection 273B

…ned AR of the assessee further submits that the journal entries were made prior to 12 June 2012 as the present appeal pertains to assessment year 2012-13, therefore, the ratio of decision in case title as CIT Vs Trump International (I) Ltd dated 12 June 2012 (345 ITR 270)/ [22 Taxmann.com 138(Bom)] is not applicable. The ACIT levied the penalty under section 271D on the observation that the assessee accepted loan/ deposits from sister concern through journal entries i.e. otherwise then account payee cheque/draft and thereby violated the provisions of section 269SS. The assessee has taken journal entries of Rs. 10…

Parvatabai Dada Kharate, Nashik vs. Assistant Commissioner of Income-Tax, Circle - 1, Nashik

In the result, the appeal of assessee is allowed

ITA 1603/PUN/2017[2011-12]Status: DisposedITAT Pune19 Aug 2019AY 2011-12

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

For Appellant: None (Written Submissions filed)For Respondent: Shri Sudhendu Das

Section 139(1)Section 271F

…sessee if he proves that there was reasonable cause for said failure. The expression “reasonable cause” used in Sec.273B of the Act is not defined under the Act. Hon’ble Bombay High Court in the case of CIT Vs. Triumph International Finance (I) Ltd. (2012) 345 ITR 270 has observed that the expression “reasonable cause” would have wider connotation that the expression “sufficient cause” and therefore the expression “reasonable cause” in Sec.273B of the Act for non-imposition of penalty would have to be construed liberally depending upon the facts of each case. 7. In the present case, it is assessee’s submis…

Mercedes - Benz India Pvt. Ltd., Pune vs. Deputy Commissioner of Income-Tax

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 1865/PUN/2013[1999-2000]Status: DisposedITAT Pune01 Aug 2019AY 1999-2000

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अऩीऱ सं./ Ita No. 1865/Pun/2013 यनधाारण वषा / Assessment Year : 1999-2000 Mercedes Benz India Private Limited. ( Formerly Known As Daimler Chrysler India Private Limited) E-3, Midc Chakan, Phase-Iii, Chakan Industrial Area, Kuruli & Nighoje, Tal : Khed, Pune-410 501. Pan : Aabcm 1789L .......अऩीऱाथी / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax, Circle-9, Pune. ……प्रत्यथी / Respondent

For Appellant: Shri Percy Pardiwala &For Respondent: Shri S. B. Prasad

…आयकर अऩीऱीय अधधकरण “ए” न्यायऩीठ ऩुणे में । IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, PUNE श्री डी. करुणाकरा राव,ऱेखा सदस्य, एवं श्री ववकास अवस्थी, न्याययक सदस्य के समक्ष BEFORE SHRI D. KARUNAKARA RAO, AM AND SHRI VIKAS AWASTHY, JM आयकर अऩीऱ सं./ ITA No. 1865/PUN/2013 यनधाारण वषा / Assessment Year : 1999-2000 Mercedes Benz India Private Limited. ( formerly known as Daimler Chrysler India Private Limited) E-3, MIDC Chakan, Phase-III, Chakan Industrial Area, Kuruli & Nighoje, Tal : Khed, Pune-410 501. PAN : AABCM 1789L .......अऩीऱाथी / Appellant बनाम / V/s. The Deputy Commissioner of Income Tax, Circle-9, Pun…

DCIT Cen Cir 7(3), Mumbai vs. Brightgold Construction P. Ltd, Mumbai

In the result, the appeal of Revenue is dismissed

ITA 2582/MUM/2017[2012-13]Status: DisposedITAT Mumbai24 Jul 2019AY 2012-13

Bench: Sri Mahavir Singh, Jm & Sri Nk Pradhan, Am Aayakr Apila Sam./ Ita No. 2582/Mum/2017 (Inaqa-Arna Baya- / Assessment Year 2012-13) The Dy. Commissioner Of M/S Brightgold Construction Income Tax, Central Circle- Pvt. Ltd. 7(3), 216, Shah & Nahar Vs. 6Th Room No. 655, Floor, Industrial Road, Off. Dr E. Aayakarbhavan, M.K. Road, Moses Road, Worli Mumbai- Mumbai-400 020 400 018 (Apilaaqai- / Appellant) .. (P`%Yaqaai- / Respondent) स्थायी लेखा सं./Pan No. Aabclr2913R

For Appellant: Shri G.L.V. Prasad, CIT DRFor Respondent: Shri Vijay Mehta, AR

Section 143(3)Section 269SSection 271DSection 273B

…mal course of business has been doubted in the regular assessment and there is a reasonable cause exist in the case of the assessee because in view of the decision of Hon’ble Bombay High Court in the case of CIT Vs Triumph International Finance (I) Ltd (2012) 345 ITR 270 (Bom.), the same was delivered only on 12.06.2012 and on that date Hon’ble Bombay High Court has clarified the position that the receiving of deposits or loans through journal entries would certainly be hit by the provisions of section 269SS and 269T of the Act. According to CIT(A), prior to the decision of Hon’ble Bombay High Court in the case o…

DCIT Cen Cir 7(3), Mumbai vs. Sahajanand Hi Tech Construction P.Ltd, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 127/MUM/2017[2008-09]Status: DisposedITAT Mumbai26 Jun 2019AY 2008-09

Bench: Shri G. S. Pannu, Vice- & Shri Pawan Singh

Section 143(3)Section 147Section 148Section 269SSection 271DSection 271E

…CIT levied penalty of Rs.49,05,000/- under section 271E and penalty of Rs. 27,02,533/- under section 271D. While levying penalty u/s. 271D/271E the ACIT relied upon the decision of Hon'ble Bombay High Court in the case of Trump International Finance (I) Ltd.(345 ITR 270) wherein it was held that transaction of loan/deposit by way of adjustment through book entry would result in contravention of provisions of section 269SS. 3. On appeal before CIT(A) both the penalties were deleted vide order dated 17.10.2016. The ld CIT(A) passed consolidated order in all appeals filed by the assessee. The ld. CIT(A)while del…

DCIT Cen Cir 7(3), Mumbai vs. Roselabs Finance Ltd, Mumbai

In the result, the appeals are dismissed

ITA 131/MUM/2017[2012-13]Status: DisposedITAT Mumbai23 Oct 2018AY 2012-13

Bench: Shri Saktijit Dey () & Shri N.K. Pradhan () Assessment Year: 2012-13 & Assessment Year: 2012-13 Dcit Cc-7(3), Room No. M/S Roselabs Finance Ltd. 655, 6Th Floor, Aayakar Vs. 216, Shah & Nahar Bhavan, M.K. Road, Industrial Road, Off. Dr. E. Mumbai-400020. Moses Road, Worli Mumbai-400018 Pan No. Aaacr9134M Appellant Respondent Revenue By : Mr. Sanjay Singh, Dr Assessee By : Mr. Vijay Mehta, Ar Date Of Hearing : 08/10/2018 Date Of Pronouncement: 23/10/2018

For Appellant: Mr. Vijay Mehta, ARFor Respondent: Mr. Sanjay Singh, DR

Section 269SSection 269TSection 271DSection 271E

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D” MUMBAI BEFORE SHRI SAKTIJIT DEY (JUDICIAL MEMBER) AND SHRI N.K. PRADHAN (ACCOUNTANT MEMBER) Assessment Year: 2012-13 & Assessment Year: 2012-13 DCIT CC-7(3), Room No. M/s Roselabs Finance Ltd. 655, 6th floor, Aayakar Vs. 216, Shah and Nahar Bhavan, M.K. Road, Industrial Road, Off. Dr. E. Mumbai-400020. Moses Road, Worli Mumbai-400018 PAN No. AAACR9134M Appellant Respondent Revenue by : Mr. Sanjay Singh, DR Assessee by : Mr. Vijay Mehta, AR Date of Hearing : 08/10/2018 Date of pronouncement: 23/10/2018 ORDER PER N.K. PRADHAN, AM The captioned appeals filed…

DCIT Cen Cir 7(3), Mumbai vs. Mahavir Premises P.Ltd, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 125/MUM/2017[2009-10]Status: DisposedITAT Mumbai23 Oct 2018AY 2009-10

Bench: Shri R.C.Sharma, Am & Shri Ram Lal Negi, Jm

Section 271DSection 271E

…of which have been placed on record. In deciding the dispute in favour of the assessee, the Hon'ble Tribunal had considered and applied the ratio laid down by the Hon'ble jurisdictional High Court in the case of CIT v. Triumph International Finance (I) Ltd. (345 ITR 270). 8. The aforesaid order of the Hon'ble Tribunal was approved by the Hon’ble jurisdictions! High Court in their judgment and order dated 06.02.2018 in the case of CIT v. Ajinath Hi-Tech Builders Pvt Ltd. and others, copies of which have also been placed on record. In this case, it was also held that prior to the judgment in CIT v. Triumph Interna…

DCIT Cen Cir 7(3), Mumbai vs. Hi Class Buildcon P.Ltd, Mumbai

In the result, all the appeals bearing ITA No

ITA 121/MUM/2017[2008-09]Status: DisposedITAT Mumbai26 Sept 2018AY 2008-09

Bench: Shri Sandeep Gosain, Jm & Shri N.K.Pradhan, Am

Section 143(3)Section 147Section 148Section 269SSection 269TSection 271DSection 271ESection 273

…t payee cheque or bank draft, there is violation of the provisions of Section 269SS/269T. 7.3.1. In this regard reliance is placed on the decision of the jurisdictional High Court in the case of CIT vs Triumph International Finance(l) Ltd dated June 12, 2012 (22 Taxmann.com 138 BOM) for A.Y, 2003-04 and the case of CIT vs M/s. Triumph International Finance(l) Ltd ITA No.5745 of 2010 dated 17.8.2012 for A.Y.2000-01. The decision for A.Y.2003-04 is with respect to contravention of provisions of section 269T, since there was a repayment of loan by making journal entries in the books of account and it was held by the…

Radhamadhav Realcon Pvt.Ltd, Pune vs. Joint Commissioner of Income-Tax, Range - 10, Pune

ITA 137/PUN/2018[2013-14]Status: DisposedITAT Pune25 Sept 2018AY 2013-14

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आय आयकर आय आय कर कर अपील कर अपील अपील संसंसंसं. / Ita No.137/Pun/2018 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Year : 2013-14 वष"

For Appellant: Shri Rakesh MohanFor Respondent: Shri B. Kishore (CIT)

Section 269TSection 271Section 271E

…ee. 4.2 Further, the Assessing Officer analyzed the provisions of section 269T of the Act and also the decisions cited by the assessee i.e. in the case of CIT Vs. Noida Toll Bridge Co. Ltd. 263 ITR 260 (Delhi), CIT Vs. Triumph International Finance (I) Ltd. 345 ITR 270 (Bom.) and Lodha Builders Pvt. Ltd. & Others Vs. ACIT in ITA No.476/M/2014 and held that the amount received by the assessee from VSK constitutes the loans or advances. Thus, the Assessing Officer held that repayment of loan by resorting to Journal entries, constitutes the contravention of provisions of section 269T of the Act. Accordingly, AO…

Sumangla Developers Private Limited, Mumbai vs. Addl.CIT Cen Cir 6, Mumbai

ITA 437/MUM/2018[2011-12]Status: DisposedITAT Mumbai12 Sept 2018AY 2011-12

Bench: Shri B.R. Baskaran (Am)& Shri Pawan Singh (Jm)

Section 143(3)Section 269SSection 271DSection 273B

…bilities through journal entries within the meaning of sec.273B of the Act. In this regard, the assessee placed reliance on the decision rendered by Hon’ble jurisdictional Bombay High Court in the case of CIT vs. Triumph International Finance (India) Limited (345 ITR 270), wherein it was held that settling of claims by making journal entries in the respective books is also one of the recognized modes of repaying loan/deposit. Though the Hon’ble Bombay High Court held that the same violates the provisions of sec.269T, yet it was held that the same constitutes reasonable cause within the meaning of sec.273B of the…

ITO 13(3)(3), Mumbai vs. Ved Investment & Trading Co.. P . Ltd, Mumbai

In the result, we set aside the order of the ld

ITA 5376/MUM/2016[2010-11]Status: DisposedITAT Mumbai21 Aug 2018AY 2010-11

Bench: Shri Shamim Yahya, Am & Shri Sandeep Gosain, Jm

For Appellant: Shri S. K. SaikiaFor Respondent: Shri Vijay Mehta

Section 147Section 148Section 69A

…In this factual background, the entries are misleading and they cannot be considered to be a proper recording of entry in the books. 16. We find that the Hon'ble jurisdictional High Court in the case of CIT vs. Triumph International Finance (I) Ltd. [2012] 345 ITR 270 (Bom) has held that squaring off entries by journal entries in the books of account has to be treated as making of loans/deposits by means other than account payee cheque and draft. Hence, this explanation by the assessee that this squaring off in the ledger account absolves the assessee of the liability of duly reflecting this sum of advance in…

Daimler Chrysler India Pvt. Ltd., Pune vs. Deputy Commissioner of Income-Tax, Pune

In the result, the cross objection of the assessee is dismissed

ITA 1381/PUN/2003[1998-99]Status: DisposedITAT Pune08 Aug 2018AY 1998-99

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita No.1381/Pun/2003 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Year : 1998-09 वष"

For Appellant: Shri Pramod AchuthanFor Respondent: Shri Rajeev Kumar, CIT

Section 143(3)Section 15ASection 35A

…पुणे "यायपीठ "यायपीठ "यायपीठ “ए” पुणे "यायपीठ पुणे म"म"म"म" आयकर आयकर अपीलीय आयकर आयकर अपीलीय अपीलीय अिधकरण अपीलीय अिधकरण अिधकरण, पुणे अिधकरण पुणे पुणे पुणे पुणे IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE "ी "ी डी "ी "ी डी. क"णाकरा क"णाकरा क"णाकरा राव क"णाकरा लेखा सद"य सद"य सद"य सद"य डी डी राव राव , लेखा राव लेखा लेखा एवं "ी "ी "ी िवकास "ी िवकास अव"थी अव"थी अव"थी, "याियक अव"थी "याियक "याियक सद"य "याियक सद"य सद"य केकेकेके सम" सद"य सम" सम" सम" एवं एवं एवं िवकास िवकास BEFORE SHRI D.KARUNAKARA RAO, AM AND SHRI VIKAS AWASTHY, JM आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / ITA No.1381/PUN/2003 अपील िन…