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TMI Blog2019 (12) TMI 1189X X X X Extracts X X X X X X X X Extracts X X X X ..... d four years. In the present case there was enough evidence and justification with the AO to reopen the assessment beyond period of four years. It has been widely held by the Courts that it is not necessary to prove beyond doubt that income has escaped assessment and it is sufficient that the AO has recorded his reasons and followed the due procedure of law for reopening of the assessment. In .view of factual matrix of the present case, I do not find any reason to interfere with the findings of the AO that this was a fit case for reopening of the assessment and accordingly the contentions and Grounds of the appellant are dismissed. Addition on account of share capital and share premium - In the factual matrix of the present case, where entries had been taken from paper companies and Credit worthiness of the Parties as well as the genuineness of the transaction had not been discharged by the appellant, there was no justification to accept the contentions of the AR Of the appellant that the additions were not justified. Accordingly, after careful consideration of the facts of the present case, there is no material or submissions provided by the AR of the appellant, which calls for an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... v.)- II, New Delhi that assessee company has obtained accommodation entries of amount totaling to ₹ 90, 00,000/- during the F.Y. 2005-06 relevant to A.Y. 2006-07 in the form of bogus share capital/premium/loan from Sh. Surender Kumar Jain Group (entry operator) where search/survey action ids 132/133.4 had been conducted on 14.09.2010. Therefore, I have reason to believe in terms of section 147 0/ the I.T. Act that income to the tune of ₹ 90,00, 000/- has escaped assessment. Issue notices u/s 148 of the I.T. Act for the A.Y. 2006-07. Dated: 22.03.2013 Sd/- (Gireeh Kumar Kohli) Asstt. Conunissioner of Income-tax Circle, Karnal." 2. In reply to this notice, assessee vide letter dated 03.04.2013stated that return filed on 29.11.2006 may be treated as return filed in response to notice u/s 148. Copy of reasons recorded for issue of notice u/s 148 was also supplied to the assessee as requested. Vide letter dated 21.01,2014, assessee objected to re-opening of assessment by way of issue of notice u/s 148 which was disposed off vide this office letter dated 07.03.2014 as reproduced below:- "No: ACIT/KNL/13-14/ Office Of the Asstt. Commissioner of Income ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r will not necessarily amount to disclosure within the meaning of the foregoing proviso." In your case, no further query in respect of share capital introduced during the year was raised during the assessment proceedings, neither any detail is placed on file. In the return, only amount of share premium is mentioned. Notice toys 148 has been issued on the basis of new tangible material received from the Departmental's sources, which is specific in nature and reliable in character. In the case of Pal Jain vs ITO [2004] 267 ITR 540 (P&H), Punjab & Haryana High Court following Phool Chand Bajrang Lal's [203 ITR 456 (SC)] has held that mere disclosure Of a transaction does not offer immunity from reassessment, where a transaction on further information is found to be not genuine and that the longer time limit of more than four years should have application in such cases. Ratio of judgment of apex Court in the case of Phool Chand Bajrang Lal's case is squarely applicable in your case. Relevant portion of the said judgment is reproduced below:- "From the plain phraseology of section 147, it appears that two conditions precedent which are required to be satisfied be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d reasons to believe that income chargeable to lax had escaped assessment on account of the omission of the assessee to make a full and true disclosure of the primary facts was relevant, reliable and specific. It was not at all vague or non-specific. From a combined review of the judgments of the apex Court, it follows that an ITO acquires jurisdiction to reopen assessment under section 147(a) read with section 148 only if on the basis of specific, reliable and relevant information coming to his possession subsequently, he has reasons, which he must record, to believe that by reason of omission or failure on the part of the assessee to make a true and full disclosure of all material facts necessary for his assessment during the concluded assessment proceedings, any part of his income, profit or gains chargeable to income-tax has escaped assessment. He may start reassessment proceedings either because some fresh facts come to light which were not previously disclosed or some information with regard to the facts previously disclosed comes into his possession which tends to expose the untruthfulness of those facts. In such situations, it is not a case of mere change of opinion or t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... se or justification. If the Assessing Officer has a cause or justification to think or to suppose that income has escaped assessment, he can be said to have a reason to believe that such income had escaped assessment. The words 'reason to believe' cannot mean that the 'Assessing Officer' should have finally ascertained the facts by legal evidence. They only mean that he forms a belief from the examination he makes and if he likes, from any information he receives. If he discovers or finds or satisfies himself that the taxable income has escaped assessment, it would amount to saying that he has reason to believe that such an income has escaped assessment. The justification fop his belief is not to be judged from the standards of proof required for coming to a final decision. A belief, though justified for the purpose of initiation of the proceedings under section 147, may ultimately stand altered after the hearing and while peaching the final conclusion on the basis Of the intervening enquiry, At the stage where he finds a cause or justification to believe that such an income has escaped assessment, the Assessing Officer is not required to base his belief on any fina ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on was liable to be dismissed. [Para 24]" Reliance is also placed on the judgments of apex Court delivered in the case Of Parashuram Pottery Works co. Ltd. vs. ITO [1977] 106 ITR 1 (SC) and Calcutta Discount co. Ltd. vs. ITO [1961] 41 ITR 191 (SC) that the words 'omission or failure to disclose fully and truly all material facts necessary for his assessment for that year' postulates a duty on the assessee to disclose fully and truly all material facts necessary for his assessment. 3. Further you have contended that the Assessing Officer initiated re-assessment proceedings upon a mere change of opinion, citing the judgment of Delhi High Court in the case of CIT vs. Kelvinator India Ltd. (2002) 256 ITR-1. In this regard, it is stated that details of share premium received during the year under consideration were not disclosed in the return. Further during the course of assessment proceedings, no such details were called for or placed on record. This issue was not discussed at all while framing original assessment u/s 143(3). Thus, question of change of opinion does not arise, since no opinion was formed earlier on this issue. As such, recourse to section 147 read w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he enclosure attached with this show cause notice. From the perusal of statement of Sh. Surendra Kumar Jain, he has owned up annexure A-1 to A-163, seized by Investigation Wing, Delhi that they have been obtained from his premises and they belong either to him or to She Virendra Kumar Jain. Of relevance to your case is pages 12, 18 and 22 of Annexure A-54 originally indexed by Investigation Wing, Delhi and passed to us. It contains hand written entry for companies who have subscribed to your share capital alongwith premium. It also provides detail of cheque number and date and amount and supposedly the name of commission agent, in this case, some Rishi Singhal. It contains detail of share Introducer Company and beneficiary company. The cheque number mentioned in this annexure match with cheque numbers as recorded in bank statement provided during reassessment proceedings. Various sheets which have-been obtained from computers of Sh Surendra Kumar Jain and Sh Virendra Kumar Jain and passed to this office by Investigation Wing, Delhi have been indexed by this office in the form of two annexures, i.e., B-l consists of bank communication letters of companies who have subscribed to yo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... earing- What is apparent may not be real and test of human probability has to be applied to understand if the apparent is real and if the transaction fails to withstand the test of human probabilities it has to be taken as ingenuine transactions. Further vide notice u/s 142(1) dated 07.03.2014, you asked to furnish the following information/ documents on 18.03.2014 were not furnished date: i) Produce complete books of account for the F. Y. 2005-06. ii) Complete detail of share premium received during the year and name & address Of the applicants. iii) Give details of current share holding pattern and details Of dividend paid, if any, from the date of incorporation of the company till date. iv) Detailed computation for arriving the basis of Share premium. v) If the alleged share applicants have parted with their share holding, then at what rate shares were transferred and to whom. Coupled with seized evidence obtained from Investigation Wing, Delhi and considerations which have been discussed in this show cause, you are hereby asked to- show cause why not Rs- 90 Lakhs be added to the returned income u/s 68 as cash credit in the A. Y. 2006-07 as the explanation of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... & memorandum and article of association of share holders d) Confirmation from shareholders. e) Copy of Audited statement of account of shareholders showing investments made and disclosed in their accounts. f) Form no. 2, i.e. Return of allotment of shares filed in ROC by assessee to show that shares were allotted. 03. The above details filed before Your Honor make crystal clear that all the transactions are through proper Banking Channel; shareholders are assessed to Income Tax and are existing. This fact is also proved from the record of Registrar of Company. CA Govt, of India Agency). All the above documents proved beyond doubt the identity of investors and genuineness of the investment and creditworthiness of shareholders. In view of above undisputed facts addition cannot be made on purely suspicious and assumption as law decided by Hon'ble Supreme Court of India in the case of "UMA CHARÆN SHAW BROTHERS v. C.I.T.. Reported in 37-ITR-271, held that "A suspicion however. strong cannot take place of evidences". Other authorities on the issue are 2009 - 30 - SOT - 44 (kol.) where in it was held that suspicion cannot replace evidential documents. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not been able to explain the source and receipt of money. According to the assessee, he had given the required information to explain the source and was not obligated to prove source of the money. It is the submission of the assessee that even in case there is some doubt about the source of money in giving into coffers of the share applicants which they invested with the assessee, it would not automatically follow that the said money belongs to the assessee and becomes unaccounted money. According to us, the assessee appears to be correct on this aspect. We feel that something more which was necessary and required to be done by the AO was not done. The MO failed to carry his suspicious to logical conclusion by further Investigation. After the registered letters sent to the investing company had been received back undelivered, the AO presumed that these companies did not exist at the given address. No doubt, if the companies are not existing i.e., they have only paper existence, one can draw the conclusion that the assessee had not been able to disclose the source of amount received and presumption under Section 68 of the Act for the purpose of addition of amount at the hands of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... give the Revenue the right to invoke Section 68. One must not lose sight of the fact that it is the Revenue which has all the power and wherewithal to trace any person. Moreover, it is settled law that the assessee need not to prove the "source of source". (Emphasis supplied) Para. 37 We are conscious of the malice of such kind of pernicious practice which is prevalent. In Divine Leasing and Finance Ltd (supra), this Court had eloquently highlighted the same in the following manner: "There cannot be two opinions on the aspect that the pernicious practice of conversion of unaccounted money through the masquerade or channel of investment in the share capital of a company must be firmly excoriated by the Revenue. Equally, where the preponderance of evidence indicates absence of culpability and complexity of the assessee it should not be harassed by the Revenue's insistence that it should prove the negative, In the case of a public issue, the company concerned cannot be expected to know every detail pertaining to the identity as well as financial worth of each of its subscribers. The company must, however, maintain and made available to the Assessing Officer f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rded or it is proved that it has "created" evidence, the Revenue is supposed to make thorough probe of the nature indicated above before it could nail the assessee and fasten the assessee with such a liability under Section 68 and 69 of the Act. Approved by Supreme Court of lndia in SLP No. CC. 15640/2012 dated 17.09.2012 c. The Hon'ble Punjab Haryana High Court of Delhi in the case of CIT vs: G. P. International Pvt. Ltd. Reported in 2010 - 325 -ITR - 25 (P & H) held that:- "Head Note" Income from undisclosed sources - company share application money - identity of contributors established -failure by some of them to respond to notice U/s 133. Not relevant amount not assessable and income of assessee - Income Tax Act, 1961. d. The Hon'ble High Court of Delhi in the case of CIT vs. Orbital Communication Pvt. Ltd. Reported in 2010 -327-ITR - 560 (Del) held that:- "Cash credits - share application money - substantial evidences produces by assessee to prove creditworthiness of creditor and geniuness of share application- failure to produce creditor not material - deletion of addition - no interference - Income Tax Act, 1961, s. 68 " ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat, the show cause notice is solely based on the report of Investigation wing of Income Tax Department, Delhi in the case of Sh. Surendra Kumar Jain. 7. At the outset it is most respectfully submitted that even for the sake of argument If it is assumed that the alleged report is correct, additions in the hands of assessee cannot be made. In the case in hand the alleged report of Investigation Wing do not belongs to the assessee. This is not the case that the certain documents belongs to the appellant were found and seized from the possession Sh. Surendra Kumar Jain. Hence it is ample clear that even in search operation of Mr. S. K. Jain no documents belongs to assessee was found and seized hence the Ld. Assessing Officer is not authorized to take the recourse of section 143 of the Income Tax Act, 1961. This is admitted facts no incriminating documents were found and seized either during the search operation on She Surendra Kumar Jain. Hence the Item of regular assessment not pending on the date of search cannot be disturbed, hence additions proposed by Ld. Assessing Officer is bad in law and same please be dropped. Authorities on this point are:- * S.S.P. Aviation Ltd. vs. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eeding with the assessment in respect of the above said five assessment years. c. To enable the assessee to raise the objections in a meaningful manner and to provide the assessee with a level playing ground, the assessee had requested for allowing inspection of the relevant records and to provide certified copy of the relevant documents on the basis of which the reasons are recorded. The assessee had requested for the below mentioned documents in the objection filed in response to notice under section 148:- (i) Copy of all Statements (including surrender statement) of Sh. Surender Kumar Jain in Investigation Wing. (ii) Final fate of block assessment in Central Circle. During the proceedings under section 148, Assessing Officer has not provided the copies of documents requested. In the show cause notice, your good self has provided copy of the statement recorded. But it seems that, the AO has not gone through the statement. In the statement, Sh. Surender Kumar Jain has never admitted that, the accommodation entries are provided to Assessee Company. We are not able to find the single instance of his admission in the statement. Further, we would like to mention that, the r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ITR 1 wherein they have held as under: "It is well known that a presumption can also be raised to the effect that in terms of clause (e) of section 114 of the Indian evidence act, 1872, judicial and official acts have been regularly performed. If it be held that an order which has been passed purportedly without application of mind would itself confer jurisdiction upon the assessing officer to reopen the proceedings without anything further, the same would amount to giving a premium to an authority exercising quasi-judicial function to take benefits of its own wrong. Hence, it is clear that section 147 of the Act does not postulate conferment of power upon the Assessing officer to initiate reassessment proceedings upon a mere change of option. " The disposal of objection filed is not as per the directions given in Supreme Court decision in the case of GKN Driveshaft (India) ltd. V. ITO (2003) 259 ITR 19. In the disposal letter, no proper documents are provided by the assessing officer and the reopening of assessment after expiry of 4 years period is bad in law and not sustainable and legal under the provisions of income tax act. Another serious allegation of Ld. A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ervices P. Ltd. Reported in 307 - ITR - 334 (Del) where in it has been held that:- "……….the additional burden on revenue. It must be shown that even if the assessee does not have means to make the Investment, the investment made by the applicant actually emanated from the coffers of the assessee, so as to enable it to be treated as undisclosed income of the assessee. This has not been done in so far as the present case is concerned. Reliance is also placed on the decision o Hon'ble Hi h Court o Delhi in the case of CIT vs. Real Time Marketing P. Ltd. Reported in 30 -ITR-35 (Del)". In view of above facts and legal position it is submitted that there is no material to allege that share capital represented the funds provided by Assessee Company. Moreover it is admitted fact that neither as a result of search and nor as a result Of investigation by investigation wing on Sh. Surender Kumar Jain group, any evidences was found to allege that the share capital and share premium received represent the undisclosed income Of the assessee company. whereas the evidences furnished during the assessment proceeding before Ld. Assessing Officer has filly substa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... had ever denied the contribution made by them towards share capital and share Premium. As in formed by shareholders, their Income Tax Assessment for the Assessment year 2005-06 is completed u/s 143(3) ofthe Income Tax Act, 1961 and investments made by them in assessee company are duly accepted by Income Tax Department as genuine. 4. From the above submissions, fact of the case as well numerous authorities cited here about it is un ambiguous crystal clear that the additions proposed by Ld. Assessing Officer is unjust, invalid and has no legs to stand in the eyes of judicial scrutiny. The additions proposed by Ld Assessing Officer are result of surmise and conjecture. In view of above submissions it is unambiguous crystal clear that by tendering numerous documentary evidences the identity, geniuness and creditworthiness of share applicant proved beyond doubt, Hence it is most respectfully submitted that share capital and share premium received by assessee please be accepted. Thanking you, For Ram Dev Rice Private Limited Counsel" 5. Reply of the assessee has been duly considered but not found sustainable. The evidence obtained from Investigation wing which were discus ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... been evasive to most of the queries raised in his statement, to the contents which he has handwritten, to the print outs which have been obtained from his computer, saying that he needs more time to explain. Instructions from his statements: To a reply to Q.No.7 on page 9 of statement, to a reference to annexure A-3, Sh. Virendra Jain says that it does not have any financial value, To a reply to Q.No.9 on page 12 of the statement to a reference to Annexure A-163, the contents of which belong to his computer, Sh. Virendra Jain says that he is not able to tell then. -Another reference to Annexure A:163 (contents derived from his computer by means of Q.No.10 on page 13, the reply is evaded. -via Q. No. 11 on page 13, on' reference to unsigned cheques of different companies and signed cheques of different companies which form part of Annexure A-122 and A-123 he is evasive. -via Q.No.12 on page 14 another reference to blank signed cheques, he is evasive. -via Q.No.13 when cheques books and pass book pertaining to different individual entities, companies totaling 198 in no. was asked from him he again remained evasive. -via Q.No.17 on page no.19 of the statement when ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tenable. No company will leave this kind of documents with their financial advisors. Furthermore, Sh. S.K. Jain and Sh. V.K. Jain were established entry operators. Documents related to concerns found from the premises of Sh. S.K. Jain and Sh. V.K. Jain do point towards their being controlled by S.R. Jain Group. Also adverse inference can be drawn from the fact that none of them attended hearing. 9. Assessee's contention that this is review, has already been dealt by means of disposal of objection to notice of 148. Assessee's contention with regard to re-assessment proceedings have comprehensively been dealt by means of disposal of objection. Assessee has already been provided copy of evidence, which formed the basis for re-assessment along with show cause notice dated 27.03.2014. The Department has already by means of cogent evidence pointed out towards ingenuineness of transaction by means of show cause notice. Assessee contention that notices sent to shareholders have been received back is not true. Summons were issued to the Directors of investor company with the object of enquiry about nature and source of share capital. Also, the idea was to give opportunity to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ory recognition to a principle which had been clearly adumbrated in judicial decisions." 11. The above discussed issue has also been supported by a recent judgement of Delhi High Court i.e. in the case of CIT vs. Independent Media (P) Ltd., 210 Taxmann 14 (Delhi) 2012, Hon'ble High Court held that if explanation addressed by the assessee with regard to identity and creditworthiness of subscriber companies and genuineness of transaction was not acceptable for valid reasons, AO could make addition under section 68 and for that purpose he would not be under any duty to further show or establish that monies emanated from goffers of assessee company, The Hon'ble High Court further observed that "we are unable to uphold the view of the Tribunal that it is incumbent upon the AO, on the facts and- circumstances of the case, to establish with the help of material on record that the share monies had come or emanated from the assessee's coffers. Section 68 of the IT Act casts no such burden on AO. This aspect has been considered more than 50 years back by Supreme Court in the case of A Govindarajulu Mudaliar vs. CIT [1958] 34 ITR 807 where previously the same argument was ad ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... accommodation entries of ₹ 90 Lacs relating to the A. Y. 2006-07 in the form of bogus share capital/premium/loan from Sh. Surrender Kumar Jain Group (entry operator) where search/survey operation have been conducted on 14.09.2010. b) The AO has also observed that copy of reasons recorded for issue of notice u/s 148 was also supplied to the assessee and the objections were disposed off. The AO has -also highlighted that the decision of Kelvjnator India Ltd. 256 ITR was not applicable since at the time of earlier assessment proceedings, no details have been placed on file and also in the present case, new tangible material had been received. The AO relied upon the decisions of Pal Jain 267 ITR (P & H) & Phool Chand Bajrang Lai (203 ITR) (SC) to argue that in this case there were valid reasons and justification for reopening of the assessment even beyond four years. From Pages 4 to 7 the AO has elaborately discussed the fresh information available with the AO, the due procedure followed for reopening of the assessment, as well as various judicial pronouncements on the basis of which on the facts of the present case, the reopening of the assessment was fully justified. c) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the part of the assessee to disclose fully and truly all material facts necessary for assessment. The AO has also relied upon various judicial pronouncements stated in the assessment order to highlight such omission or failure to disclosed fully and truly all material facts what clearly justified reopening of the assessment beyond four years. Though the AR of the appellant had argued that since there was no fresh material available with the AO to justify reopening of the assessment, the facts clearly indicate that specific details and evidences based upon survey/search action had been obtained and passed on to the AO with regard to amounts received from entry operators. It is therefore clear that such information passed on investigation and search/survey operation were not available with the AO at the time of original assessment u/s 143(3) of the LT. Act. In view of the present facts, and also keeping in view various judicial pronouncements of Rajat Import Ltd. 341 ITR Delhi (2012) and the decision of AGR Investments (2011) 333 ITR (Delhi) as well as the decision of Contel Medicare System (349 ITR) (DEL) (2012), it is clear that in the present case there was enough evidence ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t large no. of entities were being operated and managed by S.K. Jain Group to v provide bogus entries to different parties including the assessee. f) The AO has also referred to statements of Sh. Virender Kumar Jain and Sh. Surender Jain where during the course of the Statements both the persons have owned up various Incriminating documents s which were related to provide entries to different parties through shell companies operating from same addresses and not having, any genuine activity or income. In this regard, the AO has elaborately discussed from Para 6 to 10 of the assessment order, as to how there was specific material relating to the assessee company to establish that artificial paper companies with no genuine business activity had been used to provide accommodation entries to the assessee. g) The AO has relied upon various judicial pronouncements including CIT Vs. Independent Media Ltd. (201 Taxman)(Delhi)(2012) to argue that under similar facts Courts have held that considering the overall test of human probabilities as well as facts of the case, addition of ₹ 90 Lacs in the case of the assessee was fully justified. 4.2 A.R. Submissions :- The AR of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are capital/share premium from four parties as discussed in detail in the assessment order. The AO has made addition by observing that these four parties were actually only paper companies run by Sh. S. K. Jain Group on whom search and survey operations had been conducted by the Investigation wing. Incriminating documents relating to the appellant company had also been found and statements of Sh. Surender Jain & She Virender Jain had been recorded. The AO has elaborately discussed the specific documents as well as the nature of income and activity carried out by the four parties from whom the share capital/share premium had been received. It is clear that these four entities had characteristics of being only paper entities operating from a common address with negligible or no business activity but with large amount of shareholder funds and impressive Balance Sheets. b) In the present case, it is important to keep in mind that even though these four entities did not have any significant business activity or high returned income, nor there was any potential for earning huge profits in future, the appellant also paid large amount pf share premium for their shares. There was clearly ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ", for short). However, none was present from the assessee's side. In the absence of any representation from assessee's side, at the time of hearing before us, we heard the Ld. Sr. DR; who relied upon the order dated 31.03.2014 of the Assessing Officer and the aforesaid impugned order dated 17.11.2016 of the Ld. CIT(A). After perusal of the materials on record, including the order of the AO and the aforesaid impugned order dated 17.11.2016 of the Ld. CIT(A), we find that the Ld. CIT(A) has passed speaking order on merits. Relevant portion of the impugned order of the Ld. CIT(A) has already been reproduced in foregoing paragraph [C] of this order. We find that the Ld. CIT(A) has given detailed reasons for his decision on merits in the aforesaid impugned appellate order dated 17.11.2016 of Ld. CIT(A). During appellate proceedings in Income Tax Appellate Tribunal ("ITAT", for short) no material has been brought for our consideration to persuade us to take a view different from the view taken by the Ld. CIT(A) in the impugned order on merit. After hearing the Ld. Sr. DR and after perusal of materials on record, and further, in view of the foregoing discussion, we decline to interfere w ..... X X X X Extracts X X X X X X X X Extracts X X X X
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