If the house property was vacant during the year under consideration then Annual Value is to be taken as Nil

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If the house property was vacant during the year under consideration then Annual Value is to be taken as Nil

Income Tax Appellate Tribunal – Ahmedabad

Neelam Sanjay Arya,, Ahmedabad vs Income Tax Officer, Ward-8(3), , … on 31 January, 2017

            IN THE INCOME TAX APPELLATE TRIBUNAL

           AHMEDABAD ” SMC ” BENCH – AHMEDABAD

     Before Shri S. S. Godara, JM & Shri Manish Borad, AM.

                           ITA No.3588/Ahd/2015

                             Asst. Year: 2011-12

   Mrs. Neelam Sanjay Arya,      Vs. ITO, Wd-8(3),

   200 ft. Ring Road, Nr. Sun        Ahmedabad

   City Bopal, Ahmedabad.

              Appellant                    Respondent

                         PAN ABZPA 1564B

           Appellant by        Shri Tushar Hemani, AR

           Respondent by       Shri P. S. Chaudhary, Sr.DR

                     Date of hearing: 17/01/2017

                 Date of pronouncement: 31/01/2017

                                ORDER

PER Manish Borad, Accountant Member.

This appeal of assessee for Asst. Year 2011-12 is directed against the order of ld. CIT(A) -IX, Ahmedabad, dated 05/10/2015 vide appeal No.CIT(A)-9/396/14-15 arising out of order u/s 143(3) of the IT Act, 1961 (in short the Act) framed on 28.02.2014 by ITO, Wd- 8(3), Ahmedabad. Assessee has raised following grounds of appeal :-

  1. The Id. CIT(A) has erred in law and on the facts of the case in confirming the action of Id. AO in making an addition of Rs.13,02,000 by determining Annual Value u/s. 23(l)(a) of the Act.

Asst. Year 2011-12

  1. The Id. CIT(A) has erred in not appreciating that since the house property was vacant during the year under consideration, the Annual Value is to be computed at nil u/s. 23(l)(c) of the Act.
  2. Both the lower authorities have passed the orders without properly appreciating the fact and that they further erred in grossly ignoring various submissions, explanations and information submitted by the appellant from time to time which ought to have been considered before passing the impugned order. This action of the lower authorities is in clear breach of law and Principles of Natural Justice and therefore deserves to be quashed.
  3. The Ld. CIT(A) has erred in law and in facts of the case in confirming action of Ld. AO in levying interest u/s 234A/B/C/D of the Act.
  4. The Ld. CTT(A) has erred in law and on the facts in confirming the action of ld. AO in initiating penalty u/s 271(l)(c) of the Act.
  5. Briefly stated facts as culled out from the records are that assessee is an individual having income from salary, loss from house property and business loss. Return of income declaring total income of Rs.2,72,680/- was filed electronically on 29.09.2011. The case was selected for scrutiny assessment and notice u/s 143(2) of the Act was issued on 31.07.2012 followed by notice u/s 142(1) of the Act and duly served. Necessary details were called for and the information along with audited financial statements were provided. During the course of assessment proceedings ld. Assessing Officer observed that assessee has shown loss under the head house property income at Rs.11,24,920/- and further observe that assessee had not shown any rent in respect of shop nos.27 to 42 of Amrapali-II, Ahmedabad but deduction was claimed u/s 24 of the Act for interest paid on these properties. In reply to the notice assessee submitted that the impugned properties/shops did not fetch any rental income during Asst. Year 2011-12 F.Y. 2010-11 but they were given on rent in F.Y. 2009-10 to ICICI Prudential Insurance Ltd. but the properties were vacated as the tenant closed their business activities due to economic recession. Assessee further referred to CBDT Circular No.14 of 2001 which was brought in to rationalize the provisions of the Act so as to provide simplified determination of annual value after allowing deduction in computing the ALV itself on account of vacancy of the property and unrealized rent. Therefore, if the property is self-occupied or lying vacant partially or wholly either in part of the year or whole of the year, has annual rent received or receivable for that part is nil, it would not have to suffer any tax due to computation u/s 23(1)(a) of the Act. Further in para 29(2) CBDT the Circular states “Where the property or any part of the property is let and was vacant during the whole or any part of the previous year and owing to such vacancy the actual rent received or receivable is less than the ALV the sum so received or receivable shall be the actual value.” However, reply of the assessee did not convince ld. Assessing Officer as he was of the view that provisions of section 23(1)(c)of the Act shall apply only if the property have been let out for some part during the year or has been lying vacant during part of the year but in the instant case the impugned property has not at all been let out during the year under consideration and, therefore, section 23(1)(a)of the Act is applicable and the ALV has to be computed as the sum for which the property might reasonably be expected to let from year to year. Accordingly ALV of 16 shops was calculated by applying monthly rent of Rs.1,50,000/- calculated Annual Lettable Value (ALV) at Rs.18,60,000/- and after providing standard deduction @ 30% at Asst. Year 2011-12 Rs.5,58,000/- the remaining amount of Rs.13,02,000/- was added to the income of the assessee. Apart from this a sum of Rs.6,761/- was offered as long term capital gain which was shown in the computation for which assessee agreed to pay tax. Accordingly, income was assessed at Rs.14,01,772/- and business loss allowed to be carried forward at Rs.9,13,177/-. Against the impugned addition of Rs.13,02,000/- assessee went in appeal before the first appellate authority but could not succeed as the impugned amount was sustained by ld. CIT(A) by observing as follows :-

2.2 ! have carefully considered the contention of the appellant as well as the reasoning given by the A.O. in his assessment order. I have also perused various case laws relied upon by the appellant as well as by the A.O. including the CBDT Circular No.14 of 2001. Hon’ble High Court of Andhra Pradesh in the case of Vivek Jain vs ACIT (2011) 14 Taxman 146 (A.P) has further elaborated upon section 23(1). It states as follows :-

“Section 23 of the Income-tax Act, 1961 – Income from house properly – Annual value – Assessment year 2002-03 – Whether under section 23(1)(c), period for which a let out property may remain vacant cannot exceed period for which property has been let out – Held, yes ~ Whether where property has not been let out at all during previous year under consideration, there is no question of any vacancy allowance being provided thereto under section 23(1 )(c) – Held, yes – Whether words in section 23(1 )(c) ‘where the property is let’ cannot be read as ‘where the property is intended to be let’ – Held, yes [In favour of revenue] Words and Phrases : ‘Where the property is let’ as occurring in section 23(1)(c) of the Income-tax Act, 1361.

FACTS For relevant assessment year, the assessee filed his return of income declaring certain income. During assessment proceedings, the Assessing Officer sought to include annual value in respect of a fiat In the computation of the assessee’s income from house property. The assessee contended that as per section 23(1 )(c), the annual value of the flat was nil and, hence, he was not liable to tax. The assessing authority held that section 23(1)(c) would apply only when the property v/as let out and since property in question was not let out during the accounting year, the question of allowing any deduction on account of vacancy v/ould not Asst. Year 2011-12 arise. On appeal, the Commissioner (Appeals) upheld the order of the Assessing Officer. On second appeal, the Tribunal concluded that in cases where the property had not been let out at all during the year under consideration, there was no question of any vacancy allowance as provided in section 23(1)(c) and, hence, the order of the Commissioner (Appeals) determining the annual let out value of the property was upheld.

On appeal to the High Court:

HELD While interpreting a statute, the Court may not only take into consideration the purpose for which it had been enacted, but also the mischief it seeks to suppress. It is evident that clause (c ) of section 23(1) has been inserted as a protection to the assessee in cases where, on account of vacancy, the rent received or receivable on a property which has been let out is less than the sum referred to in clause (a). Prior to its amendment, even in such cases it was the sum referred to in clause (a) which was to be taken as the annual value of the property. [Para 10] In order to attract section 23(1 )(c ), the following requirements must be fulfilled .(i) the property, or any part thereof, must be let; and (ii) it should have been vacant during the whole or any part of the previous year; (Hi) owing to such vacancy the actual rent received or receivable by the owner in respect thereof should be less than the sum referred to in clause (a ). It is only if these three conditions are satisfied, clause (c) of section 23(1)would apply in which event the amount received or receivable, in terms of clause (c) of section 23(1), shall be deemed to be the annual value of the property. Clause (c) does not apply to situations where the property has either not been let out at all during the previous year or, even if let out, was not vacant during the whole or any part of the previous year. Under the Explanation to section 23(1), for the purposes of clause

(b) or (c ), the amount actually received or receivable by the owner shall not include the .amount of rent which the owner cannot realize. Self-occupation by the owner of a house would require the annual value of such house, or part of the house, to be taken as nil under section 23{2)(a) and, where the house cannot actually be occupied by the owner on account of his employment, business or profession, as nil under section 23(2)(b), provided that in terms of section 23(3)(a), the house or part of the house had not actually been let during the whole or any part of the previous year. As a legal fiction is created, the word “actually”, as used in section 23(3)(c) does not find mention in section 23(1). [Para 11] The construction placed on section 23(1)(c ), by the assessee that if there is an intention to let out the property during the relevant year, coupled with efforts being made for letting it out, it must be held mat the property is let, would necessitate reading words into section 23(1 )(c ) which do not exist. The words “vshero the property is let” cannot be read as “where the property is intended to be let”. The provisions of a tax statute must be strictly construed. The words of a Asst. Year 2011-12 statute must be understood in their natural, ordinary or popular sense and construed according to their grammatical meaning. [Para 12] The contention, that as clause (c ) provides for an eventuality where a property can be vacant during the whole of the relevant previous year, both situations, i. e., “property is let” and “property is vacant for the vjhole of the relevant previous year” cannot co-exist, does not merit acceptance. Clause (c) encompasses cases where a property is let out for more than a year in which event alone would the question of it being vacant during the whole of the previous year arise. A property let out for two or more years can also be vacant for the whole of a previous year bringing it within the ambit of clause (c) of section 23(1). [Para 14] The contention, that if the owner had let out the property even for a day, it would acquire the status of “let out property” for the purpose of clause (c ) for the entire life of the property even without any intention to let it out in the relevant year, is also not tenable. The circumstances in which the annual let out value of a house property should be taken as nil is are specified in section 23(2). Under section 23(1 )(c), the period for which a let out property may remain vacant cannot exceed the period for which the property has been let out. If the property has been let out for a part of the previous year, it can be vacant only for th& part of the previous year for which the property was let out snd not beyond. For that part of the previous year during vjhich the property was not let out, but was vacant, clause (c) ‘would not apply and it is only clause (a) which would be applicable, subject of course to sub-sections (2) and (3) of section 23. Such a construction does not lead to any hardship, inconvenience, injustice, absurdity or anomaly and, therefore, the rule of ordinary and natural meaning being followed cannot be departed from. Benefit under section 23(1 )(c) cannot be extended to a case where the property was not let out at all. [Para 15] There is no merit in the submission that the words “property is let” are used in clause (c) to take out those properties which are held by the owner for self- occupation from the ambit of the said clause. Section 23(2)(a) takes out a self- occupied residential house, or a part thereof from the ambit of section 23(1). – Likewise, under section 23{2)(b), where a house cannot actually be occupied by- the owner on account of his carrying on employment, business or profession at any other place requiring him to reside at such other place in a building not belonging to him, the annual value of the property is also required to be treated as nil , thereby taking it out of the ambit of section 23(1), Section 23(3)(a) makes it clear that section 23(2)would not apply if the house or a part thereof is actually let during the whole or any part of the previous year. Thus, only such of the properties which are occupied by the owner for his residence, or which are kept vacant on account of the circumstances mentioned in clause (b) of section 23(2), fall outside the ambit of section 23(1), provided they are, as stipulated in section 23(3)(a ), not actually let during the whole or part of the previous year. Clause (c) was not inserted to take out from its ambit properties held by the owner for self- occupation inasmuch as section 23(2)(a ) provides for such an eventuality. It is only to mitigate the hardship faced by an assessee, and as clause (b ) does not Asst. Year 2011-12 deal with the contingency where the property is let and, because of vacancy, the actual rent received or receivable by the owner is less than the sum referred to in clause (a ), was clause (c) inserted. In cases v/here the property has not been let out at all during the previous year under consideration, there is no question of any vacancy allowance being provided thereto under section 23(1 )(c ). [Para 16] Accordingly, the order of the Tribunal is to be upheld. [Para 17]”

Relying upon the above stated judgment which has deliberated upon sec. 23(1 )(c) of the act and determination of annual letting value for a property which is vacant throughout the previous year, I hereby confirm the addition made by the A.O. and the ground of appeal is dismissed.

  1. Aggrieved, assessee is now in appeal before the Tribunal.
  2. Ld. Authorised Representative (AR) submitted that Assessee is engaged in the business of trading of Aluminium Panel Sheet. Assessee had shown loss from house property of Rs.11,24,920/-. Assessing Officer observed that apart from self-occupied property, assessee had not shown any rent income for Shop Property but had shown deduction of interest. Assessing Officer was of the opinion that the annual value of such property had to be considered u/s.23(1)(a) of the Act as assessee has not let any part of the property and Assessing Officer opined that primary condition for s.23(1)(c) of the Act is that the property should have been let out during part or whole year and had been lying vacant during part of or whole year. Assessing Officer held that as the assessee had not let it out at all, s.23(1)(a) of the Act is applicable and ALV has to be computed as sum for which property might reasonably be expected to let from year to year, (para 3.3) Assessing Officer took rent declared by the assessee in AY 2010-11 to calculate the ALV at Rs.13,02,000/- for 16 shops u/s.23(l)(a). Assessing Officer relied on Yatinder Kumar v ITO (2011) 133 ITD 237 (Pune Trib.) which pertains to s.17(3) of the Act and is irrelevant, (para 3.6 i)) AO relied upon Asst. Year 2011-12 Vivekjain v ACIT (2011) 14_Taxman 146(AP) dated 25/01/2011 to make the addition. Ld.CIT quoted Vivek Jain v ACIT (2011) 14 Taxman 146(AP) and confirmed the addition of the Assessing Officer. It is submitted that the assessee had recently for AY 2010-11 let the property to IC1CI Prudential Insurance Ltd. but due to economic slowdown, it was vacated. This shows the intention of the assessee to let the property and hence it would fall u/s.23(l)(c). For this reason, the ALV would be NIL. The assessee’s case is squarely covered by AC Sreeram v ACIT ITA No.l089/Bang/2010 dated 21/03/2012 which dealt with a case where there was intention to let out property, but it could not be let out due to a slowdown in the economy. It is submitted that for these reasons, the decision is squarely applicable to the assessee’s case. Following a catena of decisions, it was held in AC Sreeram (supra). A literal interpretation of the section cannot survive because it cannot be the intention of the legislature to differentiate between an owner who lets out property for 1 day and an owner who does not let it out at all. The interpretation of the lower authorities will lead to undesirable results: Even if the property was let out by a previous owner, it could be claimed as let out as the clause talks about the property and not the owner even though the current owner had no intention to let it out. Legislature would have used the words “actually let” as it did in s.23(3) of the Act if that was the intention in s.23(l)(c) of the Act. Relying on AC Sreeram (supra), it is submitted that intention to let is sufficient for the purposes of s.23(l)(c). The assessee’s case is also covered by ACIT v Prablta Sanghi [2012] 27 taxmann.com317 (Delhi) dated 18/09/2012 wherein it was held that s.23(l)(c) of the Act would apply where the assessee had earlier let Asst. Year 2011-12 out property but it was lying vacant in the relevant year. The facts are again squarely applicable to the assessee’s case. It is submitted that as these decisions are more recent in time than Vivek Jain (25/01/2011). they ought to be followed in the assessec’s case.
  3. Ld. AR further referred to the decision of the Co-ordinate Bench, Pune in the case of Vikas Keshav Garud vs. ITO (2016) 71 taxmann.com214 (Pune-Trib) and submitted that the issue in the appeal of assessee is squarely covered by the decision of the Co- ordinate Bench wherein it was held that if an assessee intended to let out property and took efforts in letting out the property but ultimately failed to let the same in terms of sec.23 (1)(c) of the Act from lettable value has to be nil being less than sum referred to in section 23(1)(a)of the Act.
  4. Ld. Departmental Representative (DR) vehemently argued and supported the orders of lower authorities.
  5. We have heard the rival contentions and perused the records placed before us and gone through the decision referred by the ld. AR. Solitary grievance in this appeal raised by assessee against the addition of Rs.13,02,000/- made by ld. Assessing Officer and confirmed by ld. CIT(A) made towards calculated N.P. Annual lettable value u/s 23(1)(a) of the Act, of all the properties which remained vacant throughout the year. From going through the orders the lower authorities and the contentions raised by assessee and ld. AR we find that the assessee is owner of 16 shops bearing No.27 to 42 situated Asst. Year 2011-12 at Amrapali -II, Complex, Ahmedabad which remained vacant through out the year and deduction of interest was claimed u/s 24 of the Act at Rs.10,90,296/-. As per the assessee the impugned property was fetching rental income in the preceding F.Y.2009-10 as it was let out to ICICI Prudential Insurance Ltd. but the property got vacated and in the relevant previous year i.e. 2011-12 necessary efforts were made to let out the impugned shops but was unable to do so due to recession in the economy. On the basis of these reasons assessee claimed that under the provisions of section 23(1)(c)of the Act, ALV is nil after claiming vacancy allowance. Whereas ld. Assessing Officer was of the confirmed view that section 23(1)(c)of the Act will apply only if the property is vacant for some part of the year meaning thereby that for a certain part of the year property has to be let out and then only the assessee can claim vacancy allowance. As the impugned property remained vacant throughout the year ld. Assessing Officer did not allow the vacancy allowance u/s 23(1)(c) of the Act and made addition of Rs.13,02,000/- by estimating annual rent of the impugned 16 shops at Rs.18,60,000/- after allowing standard deduction @ 30% at Rs.5,58,000/- calculated on lettable value u/s 23(1)(a) of the Act at Rs.13,02,000/-. We further observe that similar issue had come up before various judicial forums and one of the latest decision of Co- ordinate Bench, Pune in the case of Vikar Keshav Garud vs. ITO (supra) pronounced in March, 16, 2016 wherein similar issue came up and the facts of that case were that assessee owned a property which remained vacant throughout the year and assessee declared ALV of the property at Rs.NIL while filing the return of income. In the Asst. Year 2011-12 Course of assessment Assessing Officer adopted gross ALV at Rs.1,51,200/- and this addition was confirmed by ld. CIT(A). We find that the facts discussed in this decision of Co-ordinate Bench in the case of Vikas Keshav Garud (supra) are verbatim similar to those raised by the assessee in the present appeal before us. We find that the Co-ordinate Bench, Pune in the case of Vikash Keshav Garud (supra) has decided the issue in favour of assessee by observing as follows :-
  6. We have carefully considered the orders of the authorities below and material placed on record. We observe that the Assessing Officer has denied the application of section 23(1)(c)of the Act for determination of AI.V on the ground that clause (c) does not apply to a situation \\hcre the properly has either not been let out at all during the previous year or even it’ let out, \\as not vacant during the whole or any part of the previous year. As per the Assessing Officer words “where the properly is let” cannot be read as “where the property is intended lo be let”. For this proposition, the Assessing Officer has heavily relied upon the decision of the Hon’ble Andhra Pradesh High Court in the case of Vivek Jain (.supra). The Assessee ardently contested the action of the AO before CIT'(A) and claimed that in view ofS. 23(1 )(c). the annual letting value (ALV) ought lo have been determined at nil having regard to the fact the properly could not be let out and remained vacant for the whole \ear. In support of ibis proposition, decisions of the Tribunal in the case of Premsudha Exports (P) Ltd. vs. Asstt. CIT [2008] 110 ITD I58 |20U7| 17 SOT 293 (Mum.) and Shakiiniala Devi v. Dy. DIT [IT Appeal No. 1524/Bang/20I0. dated 20-12-2011] were relied upon before CIT(A). We notice from the order of the CIT(A) that the property was actually let out in the financial year 2006-07 to M/s. IUBI Home finance Ltd. at an actual rental value of Rs. I2.600/- per month i.e. Rs. I.5I.200/- per annum. During the year relevant lo assessment year 2009-10 in appeal, the assessee could not let out the property and thus remained vacant throughout the year. Therefore, the surrounding circumstances would suggest that the property was always available to be let out, however, could not be actually let out in reality. The intention lo let out the property is thus loud and clear in the circumstances which did not however fructify.
  7. The AI.V of properly remaining vacant for the whole year has to be computed with reference to section 23(1 )(c) of the Act. This sub-section deals with a situation where the property remains vacant for the whole \ear, Section 23( I )(c) of the Act as relevant in the context is set out for ready reference as under : —

Asst. Year 2011-12

“| Annual value how determined. •.       ,

  1. ( I ) for the purposes of section 22. the annual value of any property shall be deemed to be–

(c) where the properly or any part of the property is let and was vacant during the whole or an\ part of the previous sear and owing to such vacancy the actual rent received or receivable by the owner in respect thereof is less than the sum referred lo in clause (a). the amount so received or receivable :

Provided that the taxes levied by any local authority in ‘respect of the property shall be deducted (irrespective of the previous year in which the liability to pay such taxes was incurred by the owner according lo the method of accounting regularly employed by him) in determining the annual value of the property of that previous year in which such taxes arc actually paid by him. “[underline is ours]

  1. Section 23(1)(c)by its literal wording include a situation where a property which was vacant during the whole year by saying that “when a properly /.v lei and was vacant during the whole or part of the previous year actual rent received or receivable by the owner is less than .sum referred to in clause (a), the amount so received or receivable “. It goes without saying that a situation cannot coexist wherein the property is let during the previous year and is also simultaneously vacant for the whole year. The word ‘let1 and ‘vacant’ are mutually exclusive. To appreciate il further, the underlying principle of ibis provision has to be viewed with regard lo the intention together with efforts put by assessee in letting out the property, etc. and then gross annual value is required lo be determined. If the assessee intended to let the properly and took appropriate efforts in letting the property but ultimately failed lo let the same, the actual rent received from it will have to be considered as “Zero” being less than the sum referred in section 23(1 ){a) of the Act. The revenue has not brought anything on record in rebuttal to say that the properly has not remained vacant for the whole year or was self- occupied in some manner. As noted above, the fact that the assessee had on the previous occasion in the preceding year rented the properly remains untraversed. We are not inclined to agree with the interpretation suggested by the Revenue that property should be actually let out in relevant to previous year. This interpretation does not appear consistent with the phraseology mandated in Section 23(l)(c) which includes a situation where the property can remain vacant during the whole of the relevant previous year. Hence. both situations namely ‘properly is let’ and remained vacant for the whole year cannot coexist during the financial year. We also note from a reading of another provision i.e. sub-section (3) of section 23 of the Act. where the legislatures in their wisdom have used the word ‘house is actually let’. This also shows that the expression ‘properly is ‘let’ cannot mean actual letting out of the property because had it been so, there was no need to use the word ‘actually’ in sub-section (3) of section 23 of the Act. Applying the purposive Asst. Year 2011-12 interpretation, the expression ‘properly is let’ has to be read in contrast to ‘property is sell” occupied’ lo arrive at its true purport. We simultaneously note on facts that the property has been actually lei out in the financial year 2006-07 as noted above. It cannot be reckoned to be in the control of the assessee lo let out the properly throughout necessarily. The decision of Hon’ble Andhra Pradesh High Court in the ease of Vivek Jain (supra) relied upon by the revenue cannot be read in a manner that if the properly remains vacant throughout the year. section 23(1)(c) do not apply at all more so when the property was let out in proceeding or subsequent year. Therefore, in the totality of the circumstances and having regard to the provisions of the Act. we are of the view that the AI.V of the property at Dande Towers which remained vacant for the whole year has to be assigned ALV value in terms of section 23(1 )(c) of the Act. Accordingly, the order of the CIT(A) stands modified lo this extent. Ground No. 1 is thus partly allowed.
  2. Respectfully following the decision of the Co-ordinate Bench, Pune in the case of Vikas Keshav Garud (supra), we are of the view that assessee has rightly assigned “NIL” Annual Lettable Value of the impugned 16 shops which were ready to be let out during the year but remained vacant throughout the yearand the same was duly covered under the provisions of section 23(1)(c)of the Act. We accordingly set aside the order of ld. CIT(A), delete the impugned addition of Rs.13,02,000/-, and allow the appeal of assessee.
  3. In the result, appeal of the assessee is allowed.

Order pronounced in the open Court on 31st January, 2017 Sd/- sd/-

             (S. S. Godara)                          (Manish Borad)

            Judicial Member                        Accountant Member

Dated      31/01/2017

Mahata/-

Asst. Year 2011-12

Copy of the order forwarded to:

  1. The Appellant
  2. The Respondent
  3. The CIT concerned
  4. The CIT(A) concerned
  5. The DR, ITAT, Ahmedabad
  6. Guard File

BY ORDER

 

Asst. Registrar, ITAT, Ahmedabad

 

 

 

  1. Date of dictation: 30/01/2017
  2. Date on which the typed draft is placed before the

Dictating Member: 31/01/2017 other Member:

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