1

IN THE INCOME TAX APPELLATE TRIBUNAL

JODHPUR BENCH, JODHPUR

BEFORE SHRI HARI OM MARATHA, JUDICIAL MEMBERAND

SHRI N.K.SAINI, ACCOUNTANT MEMBER

ITA Nos. 127 & 128 /JU/2012

(u/s 12A)

M/s Nosegay Public School Vs. The CIT.

Management Committee, Bikaner

Sriganganagar

PAN No. AAATN8221E

(Appellant) (Respondent)

Appellant By : Shri Suresh Ohja

Respondent By : Shri G.R.Kokani

Date of hearing : 27.11.2012

Date of Pronouncement : 19.12.2012

ORDER

PER HARI OM MARATHA, J.M.

Both the appeals by the assessee Committee (Trust) is directed against

the order passed by ld CIT (Administration), Bikaner dated 14.6.2007 passed

u/s 12A(a) of the Income Tax Act, 1961 [hereinafter referred to as "the Act"

in short]. By this common order, we will dispose off both the appeals which

are inter-related.

2. Briefly stated, the facts of the case are that the appellant had filed

application for registration of a Charitable Trust / Institution u/s 12A(a) of

2

the Act in form No.10A. As per his application in Column No.4, date of

creation of the Insti tution has been mentioned as 9.11.1985. The assessee

received a notice of hearing in this case in which it is stated that since you

have applied for registration u/s 12A(a) on 30.3.2006, after expiry of one

year from the date of registration under the Rajasthan Society Registration

Act (RSRA), 1958 (on 9.11.1986), therefore, you are directed to attend this

office on 22.8.2006 at 11.00 AM and explain the reasons for the delay. The

assessee fi led condonation petition on 2.4.2007 stating therein that due to

lack of awareness of the law, we could not apply for registration of the

Society in time and when it came to our notice, we immediately applied for

the same. Through this letter, i t was prayed that the delay in fil ing the

application may be condoned. It was also suggested in the al ternative that in

case the delay is not condoned, registration may be granted from 1.4.2005 in

view of clause (ii) of proviso to section 12A(a) of the Act. The

Commissioner had inquired into the nature and objects of this Committee /

Insti tution and had found that its objectives are undisputedly charitable in

nature and, therefore, it deserves registrat ion u/s 12A(a) of the Act. Later

on, on 14.6.2007, the ld CIT registered the assessee u/s 12A(a) w.e.f

1.4.2005.

3. But despite fact that certificate of registration under the Act was

granted, the appellant is aggrieved on two grounds:-

(i) that the order passed by the Commissioner Bikaner on 14.6.2007

is not as per law and as such it is illegal because as per law the

Commissioner is bound to pass order accepting or rejecting

3

application for registration u/s 12A within six months from the date

of application fi led in his office; and

(ii) the assessee has mentioned the date of registrat ion of the Society

as 9.11.1985, the registration deemed to have been granted w.e.f

9.11.1985, as the Commissioner has not considered the condonation

petit ion at all. It was argued that without giving reasons for rejection

of condonation application and without mentioning anything in this

regard, the CIT cannot reject the application. The deemed rejection of

application will also not arise.

4. In this manner, the appellant has pleaded – one that the order in

question is not at al l a valid order in the eyes of law because it has been

passed beyond the permitted t ime and two deemed registration would be

from the date of its registration, when order was not passed within six

months of the receipt of application for registration by the Commissioner.

5. Before us, lengthy arguments were advanced by ld AR which was

controverted by ld. CIT – DR who supported the appellate order. Because

the issue before us is admixture of facts and law, we would like to extract

the entire submissions which was made by the assessee before CIT, in

verbatim, as under:-

“To

The Commissioner of Income-tax, Bikaner.

4

Reg. Nosegay Public School Management

Committee, Sriganganagar.

Assessment year:

Sub : For grant of 12 A OF I .T. ACT 1961

Dear Sir,

I want to draw your kind attention towards the fact that an

application for registration was submitted by the society on dated

30.3.2006. In this connection it is stated that in the application the

date of creation of the society was mentioned as 9.11.1985.

In this connection, it is stated that after application of

registration what I have been able to understand that one report

from the Assessing Officer/ Joint Commissioner was called for.

The order sheet dated 8.8.2006 is crystal clear, for your ready

reference the contents thereof are being reproduced herewith:

The predecessor of your good self issued one notice dated

9.8.2006 in respect of the fact that the registration application was

submitted after expiry of one year from the date of registration.

The assessee submitted replies vide letter dated 2.4.2007 stating full

facts and the reasons mentioned therein were on account of lack of

awareness, of the law. The relevant Paragraph is being reproduced

hereunder:

But due to lack of awareness of the law we could not apply

for the Registration of the Society in time and when it came

to our notice, we applied for the Registration.

From the perusal of the above you will observe that your predecessor was requested so as to condone the delay and to grant registration retrospectively.

Now, I want to draw your kind attention towards the provision of section

12AA of the Income-tax Act. The relevant provisions are being

reproduced hereunder:

(2) Every order granting or refusing registration under

clause (b) of sub section (1) shall be passed before the

expiry of six month from the end of the month in which

the application was received under clause(a) [or clause

(aa) of sub section(l)} of section 12A]

In this respect from the perusal of above you will observe that order has to be passed within six month from the date of submission of the application. In case of the assessee an application was submitted on 30.03.2006. The six month expired on 30.09.2006. In the meanwhile no order for refusal was passed by the Commissioner of

5

Income-tax, Bikaner. The word shall has been used. Therefore in case of the assessee the registration shall be deemed to have been granted in view of the above provisions.

It is. therefore, humbly prayed that necessary order for the period prior to 1.4.2005 may kindly be passed so that the assessee may be able to take legal benefit as provided in the act. Hope you will consider the request and pass the order for granting registration from the date of application.

I also want to draw your kind attention that the department himself

has accepted that the society is a Charitable Institution. The report of

the lower authorities is self explanatory in this regard.

Without prejudice to above it is stated that if the predecessor of your

good self was of the opinion that registration cannot be granted

retrospectively in that case speaking order should have been

passed. There is no order at all in respect of refusal of

registration under section 12AA /12A of the Income Tax Act, 1961.

Further without prejudice to above it will be worth mentioning here

that only on account of delay adverse view should not be drawn.

There is a direct judgment of Hon'ble Supreme Court reported in

167 ITR 471 in case of Collector, Land Acquisition vs. Mst. Katiji and

Others. The relevant paras of is being reproduced here under:

1. Ordinarily, a litigant does not stand to benefit by

lodging an appeal late.

2. Refusing to condone delay can result in a meritorious matter being thrown out at the very threshold and cause of justice being defeated. As against this, when delay is condoned, the highest that can happen is that a cause would be decided on merits after hearing the parties.

4. When substantial justice and technical considerations are pitted against each other, the cause of substantial justice deserves to be preferred, for the other side cannot claim to have vested right in injustice being done because of a non-deliberate delay.

5. There is no presumption that delay is occasioned deliberately, or on account of culpable negligence, or on account of mala fides. A litigant does not stand to benefit by resorting to delay. In fact, he runs serious risk.

6. It must be grasped that the judiciary is respected not on account of itspower to legalize injustice on technical grounds but because it is capable of removing injustice and is expected to do so.

6

The judgment of Supreme Court is very clear regarding the subject.

As far as the ignorance of law is concern I want to draw your kind attention towards the order of 1TA1 Jodhpur Bench, Jodhpur reported in 30 TW 158 the relevant portion is being reproduced as under:

In this case the Honb 'le Supreme Court has held that Court should adopt rational, common sense and pragmatic approach. And reliance can also he placed on the judgment of Apex Court in the case of Motilal Padampath Sugar Mill Company Limited Vs. State of Uttar Pradesh and others reported in (1997) 118 1TR 326. In this case it was held that "there is no presumption that every person knows the law. It is often said that every one is presumed-to know the law, but that is not correct statement. There is no such maxim known to the law."

From the perusal of the above you will observe that there was reasonable cause made known to the CIT Bikaner regarding delay. Though the matter became barred by limitation by that time but the reason was submitted to the Commissioner of Income-tax, Bikaner.

In above mentioned fact and circumstances you will observe that the order passed by your predecessor is a cyclostyled order in which the period seems to have beer, typed under some wrong impression.

I want to also draw your kind attention that the matter in respect of the period prior to 01.04.2005 remained undisposed off in the order. In the other word there is no order for the period prior to 01.4.2005. It is, therefore, prayed that order may kindly be passed, in view of section 12AA of the Income Tax Act, 1961, in case of disposal off application after expiry of six month.

It is therefore prayed that necessary order for the period prior to

01.04.2005 may kindly be passed for granting registration under

section 12A and 12AA of the Income Tax Act, 1961.

It is also prayed that a change of personal hearing may kingly be

allowed sot that the assessee may be able to come forward with

suitable submission and put his submission.

Hope you will consider the request.

Yours faithfully,

Sd/- For Nosegay Public School ;

Management Committee

dated 11.1.2012”

7

6. It was found that the appeal filed before the Tribunal is time barred.

This appeal was received in this office on 5.3.2012. This appeal is directed

against the order of ld. CIT dated 14.6.2007. The delay in fi ling this appeal

is 1660 days. A condonation petition has been filed which is duly supported

by an attested affidavit. The averments taken in this affidavit of the

Managing Trustee are being reproduced verbatim, to understand the ‘reasons’

for this delay.

“Affidavit

I Papinder Singh Sudan S/o Sh. Hakam Singh Sudan, Age 60 years,

resident of Chak 7-E Chhoti, Sri Ganganagar declare on oath as under:

That I am Managing Trustee of Nosegay Public School,

Sriganganagar and conversant with the affairs of the trust and also

competent to swear this Affidavit.

That Nosegay Public School Management Committee is a Society

created vide Memorandum of Association and was got registered vide

registration certificate dated 09.11.1985,

That an application under section 12 A of the Income-tax Act was

submitted vide application dated 30.03.2006 before the Commissioner of

Income-tax Bikaner.

That the Commissioner of Income-tax, Bikaner allowed the registration

to the Society Nosegay Public School Management Committee with effect from

01.04.2005.

Thai the Society applied for registration since its beginning i.e. from

date of creation.

That the Society now submitted an appeal before the Income-tax

Appellate Tribunal Jodhpur Bench, Jodhpur against the order of the

Commissioner of Income-tax, Bikaner dated 14.06.2007. The appeal is barred

by limitation.

That the appeal in question is delayed substantially on account

of ignorance of law and as per the advice of the tax consultant of the Society

at that time.

That now the present consultants of the Society advised that an appeal

should have been submitted. It has also been made known that no order can

8

be passed on an application U/s. 12 A of the Income-tax Act after period of

six months from the date of application.

That since the Members of Society were not aware about the Income-

tax Act and consequences thereof but the consultant advised that it makes

no difference if the registration to the Society has been granted with effect

from 1.4.2005 in place of dated 09.11.1985 whereas the Society was created

and running for fulfillment of aims and objects thereof after creation.

That the application under section 12 A of the Income-tax Act

submitted by the Society was decided by the Commissioner of Income-tax,

Bikaner vide order dated 14.06.2007 i.e. after expiry of 6 months from the date

of submitting of the application.

That an application in respect of condonation of delay was also

submitted before the Commissioner of Income-tax Bikaner vide application

dated 2.4.2007 prepared by the then consultant.

What has been stated above is true to the best of my knowledge

and nothing has been concealed. God may help me.

DEPONENT

Sd/-

(PAPINDER SINGH SUDAN)”

7. With the support of this affidavit and application for condonation of delay

it has been prayed that in the interest of substantial justice, this delay may

kindly be condoned. This request was repelled by ld. CIT – DR stating that this

delay is inordinate, therefore, it should not be condoned. After considering

rival stands, we have found that the reason for this delay is stated to be due to

wrong advice and ‘ignorance of law’ of the persons who are managing this

institution. We have gone through the decisions relied upon by the ld. AR in

respect of condonation of this delay. We have noticed that the Hon’ble Supreme

Court , as back as in the year 1987, had an occasion to decide such an issue in

the case of Collector, Land Acquisition Vs. Mst. Katiji and other [(1987) 167

ITR 471 (SC)]. The Hon'ble Supreme Court has titled their decision

overwhelmingly in the favour of the substantial justice when it is pitted against

the pedantic reasons. Subsequently, the Hon'ble Apex Court reiterated their

9

view while deciding the case of Vedabai alias Vijayanatabai Baburao Patil vs

Shantaram Baburao Patil and others [(2002)253 ITR 798 (SC) in which their

lordship have held as under:-

“In exercising discretion under section 5 of the Limitation Act, 1963, to

condone delay for sufficient cause in not preferring an appeal or other

application within the period prescribed, courts should adopt a pragmatic

approach. A distinction must be made between a case where the delay is

inordinate and a case where the delay is of a few days. Whereas in the

former consideration of prejudice to the other side will be a relevant factor

and calls for a more cautious approach, in the latter case no such

consideration may arise and such a case deserves a liberal approach. No

hard and fast rule can be laid down in this regard. The court has to exercise

its discretion on the facts of each case keeping in mind that in construing

the expression “sufficient cause” the principle of advancing substantial

justice is of prime importance. The expression “sufficient cause” should

receive a liberal construction.”

8. Similarly, Hon'ble Allahabad High Court has very succinctly dealt with

this issue threadbare while deciding the case of CIT & Anothers Vs. Ram Kishan

Gupta [(2007) 295 ITR 578 (All.). It has been held in this case as under:-

“In view of the aforesaid discussions, we are of the view that the sufficient cause

had been brought on record to condone the delay of five days. In the

circumstances, the impugned judgment and order dated July 26, 1999, is set

aside. The delay in filing the appeal before the Tribunal is condoned and the

Tribunal is directed to decide the appeal on the merits in accordance with law.

Since the appeal was filed in the year 1992, it would be appropriate that the

Tribunal expedites the hearing of the appeal and decide the same within a period

of three months from the date of production of certified copy of this order.

The appeal stands allowed as above, however in the facts of the case, there shall

be no order as to costs.”

10. The Hon'ble Apex Court has laid down a firm law vide which ‘ignorance of

law’ has been treated as a ‘sufficient cause’ and reasonable excuse for any default

committed under the law when the cause of substantial justice is under

consideration. The Hon'ble Apex Court while dealing with the case of Motilal

Padampat Sugar Mills Co Ltd Vs. State of Uttar Pradesh & others reported in

[(1997) 118 ITR page 326 (SC)], has held thus:-

10

“On the basis of an announcement in a newspaper that the State of U.P. had

decided to grant exemption from sales tax for a period of three years to all new

industrial units in the State, the appellant wrote a letter in October, l968, to the

Director of Industries of its intention to set up an industrial unit for the

manufacture of vanaspati, in reply to which the director confirmed that there will

be no sales tax on the finished product of the appellant's vanaspati factory from

the date it gets power connection for commencing production. Thereupon the

appellant approached financiers for financing the project and initiated

negotiations with manufacturers for the purchase of machinery for the factory.

In December, 1968, the Chief Secretary to Government and Adviser to the

Governor reiterated the assurance that the appellant would be entitled to the tax

holiday. On the appellant's request for confirmation, the Chief Secretary in a

reply dated December 22, 1968, confirmed that "the State Government will be

willing to consider your request for grant of exemption from U.P. sales tax for a

period of three years from the date of production", and the appellant to apply

formally to the Secretary in the Industries Department and in the meantime to

"go ahead with the arrangements for setting up of the factory". Since the

financial institutions were not satisfied with that reply, the appellant approached

the Chief Secretary again and the latter wrote a letter dated January 23, 1969, to

the effect that the appellant "will be entitled to exemption from U.P. sales tax for

a period of three years from the date of going into production", the exemption

being applicable to vanaspati sold in the State, and in view of this assurance the

appellant went ahead with the setting up of the vanaspati factory. Thereafter, the

State Government took a policy decision in January, 1970, that new vanaspati

units will be given only a graded partial concession during the first three years of

production and once again the State Government revised its policy in August,

1970, rescinding even the partial exemption. In the meantime, the appellant had

written a letter to the effect that it would be availing of the partial exemption. The

appellant thereupon filed a writ petition which it amended and in the amended

petition raised the plea that the Chief Secretary, acting on behalf of the State

Government, had given an unequivocal assurance that the appellant would be

entitled to exemption from payment of sales tax for a period of three years from

the date of commencement of production, intending or knowing that it would be

acted upon by the appellant, and the appellant, relying on that assurance,

established the factory by investing a large amount, and, therefore, the State

Government was bound to honour the assurance and exempt vanaspati

manufactured and sold by the appellant for a period of three years from July 2,

1970. The High Court rejected the plea. On appeal to the Supreme Court:

Held, reversing the decision of the High Court, that the facts necessary for

invoking the doctrine of promissory estoppel were clearly present and the

Government was bound to carry out the representation and exempt the appellant

from sales tax in respect of sales of vanaspati effected by it in Uttar Pradesh for a

period of three years from the date of commencement of production and was not

entitled to recover such sales tax from the appellant:

Held also, on the facts, that the fact that the appellant wrote a letter accepting the

concessional rate of sales tax did not amount to waiver.

11

It is elementary that waiver is a question of fact and it must be properly pleaded

and proved. No plea of waiver can be allowed to be raised unless it is pleaded and

the factual foundation for it is laid in the pleadings. Waiver means abandonment

of a right and it may be either express or implied from conduct, but its basic

requirement is that it must be "an intentional act with knowledge". There can be

no waiver unless the person who is said to have waived is fully informed as to his

right and with full knowledge of such right, he intentionally abandons it.

Where one party by his words or conduct makes to another a clear and

unequivocal promise which is intended to create legal relations or effect a legal

relationship to arise in the future, knowing or intending that it would be acted

upon by the other party to whom the promise is made and it is in fact so acted

upon by the other party, the promise would be binding on the party making it and

he would not be entitled to go back upon it, if it would be inequitable to allow him

to do so having regard to the dealings which have taken place between the parties,

and this would be so irrespective of whether there is any pre-existing relationship

between the parties or not.

It is not necessary, in order to attract the applicability of the doctrine of

promissory estoppel, that the promisee, acting in reliance on the promise, should

suffer any detriment. What is necessary is only that the promisee should have

altered his position: the alteration of position need not involve any detriment to

the promisee. The detriment in such a case is not some prejudice suffered by the

promisee by acting on the promise, but the prejudice which would be caused to

the promisee, if the promisor were allowed to go back on the promise.

Where the Government makes a promise knowing or intending that it would be

acted on by the promisee and, in fact, the promisee, acting in reliance on it, alters

his position, the Government would be held bound by the promise and the

promise would be enforceable against the Government at the instance of the

promise, notwithstanding that there is no consideration for the promise and the

promise is not recorded in the form of a formal contract as required by art. 299 of

the Constitution.

Since the doctrine of promissory estoppel is an equitable doctrine, it must yield

when equity so requires. If it can be shown by the Government that having regard

to the facts as they have subsequently transpired, it would be inequitable to hold

the Government to the promise made by it, the court would not raise an equity in

favour of the promisee and enforce the promise against the Government, because,

on the facts, equity would not require that the Government should be held bound

by the promise made by it. When the Government is able to show that in view of

the facts which have transpired since the making of the promise, public interest

would be prejudiced if the Government were required to carry out the promise,

the court would have to balance the public interest in the Government carrying

out a promise made to a citizen which has induced the citizen to act upon it and

alter his position and the public interest likely to suffer if the promise were

required to be carried out by the Government and determine which way the equity

lies. It would not be enough for the Government just to say that public interest

requires that the Government should not be compelled to carry out the promise or

that the public interest would suffer if the Government were required to honour

it. The Government cannot claim to be exempt from the liability to carry out the

12

promise on some indefinite and undisclosed ground of necessity or expediency;

nor can the Government claim to be the sole judge of its liability and repudiate it

on an ex parte appraisement of the circumstances. The Government will have to

disclose to the court what are the subsequent events on account of which the

Government claims to be exempt from the liability and it would be for the court to

decide whether those events are such as to render it inequitable to enforce the

liability against the Government. Mere claim of change of policy would not be

sufficient to exonerate the Government from the liability: the Government would

have to show what precisely is the changed policy and also its reason and

justification so that the court can judge for itself which way the public interest

lies and what the equity of the case demands. It is only if the court is satisfied, on

proper and adequate material placed by the Government, that overriding public

interest requires that the Government should not be held bound by the promise

but should be free to act unfettered by it, that the court would refuse to enforce

the promise against the Government. The court would insist on a highly rigorous

standard of proof in the discharge of the Government's burden in this regard.

But even where there is no such overriding public interest, it may still be

competent to the Government to resile from the promise on giving reasonable

notice, which need not be a formal notice, giving the promisee a reasonable

opportunity of resuming his position provided of course it is possible for the

promisee to restore status quo ante. If, however, the promisee cannot resume his

position, the promise would become final and irrevocable.

The doctrine of promissory estoppel cannot be applied in the teeth of an

obligation or liability imposed by law. Promissory estoppel cannot be invoked to

compel the Government or even a private party to do an act prohibited by law.

There can also be no promissory estoppel against the exercise of legislative

power. The legislature can never be precluded from exercising its legislative

function by resort to the doctrine of promissory estoppel.

Per curiam: (i) If the U.P. Sales Tax Act, 1948, did not contain a provision

enabling the Government to grant exemption it would not be possible to enforce

the representation against the Government, because the Government cannot be

compelled to act contrary to the statute, but since s. 4A of the U.P. Sales Tax Act,

1948, confers power on the Government to grant exemption from sales tax, the

Government can legitimately be held bound by its promise to exempt the appellant

from payment of sales tax. It is true that taxation is a sovereign or governmental

function, but no distinction can be made between the exercise of a sovereign or

governmental function and a trading or business activity of the Government, so

far as the doctrine of promissory estoppel is concerned.

(ii) There is no presumption that every person knows the law. It is often

said that every one is presumed to know the law, but that is not a correct

statement: there is no such maxim known to the law. ………

Decision of the Allahabad High Court reversed.

13

11. Therefore, taking the cumulative effect of these decisions, particularly

when appellant before us is a Charitable Institution, and the Commissioner as

well as the ITO have found the objects of the appellant ‘charitable in nature’ no

doubt has been raised in this regard, we are left with no option to condone this

delay in filing appeal before Tribunal. In such a insti tution the trustee or any

incharge has got no personal interest , but such institutions serve the public

cause of charity. Anybody so connected may have perfunctory interest and such

like long delays usually occur. There are raft of decisions which favour

condonation such delays, instead of defeating the cause of charity at the very

threshold. That is why the law has permitted such institution to exist and

flourish for public cause. We are aware that there may be some institutions

which may also work against the dictum of the law and avail personal benefits

of its trustees but such cases have to be segregated. In the light of the above

decisions, we are of the considered opinion that this appeal deserves to be

admitted after condoning the delay. Accordingly, we admit this appeal.

12. Coming to the merits of the case, we have found that the Commissioner

undeniably has passed the order u/s 12A(a) beyond six months of the receipt of

application in form 10A in its office on 30.3.2006. The impugned order was

passed on 14.6.2007, beyond six months as has been prescribed in Section 12A.

In such eventuali ties, the application for registrat ion is deemed to have been

allowed. We may rely on the decision of Hon'ble Special Bench of ITAT, Delhi

renedered in the case Bhagwad Swarup Shri Shri Devraha Baba Memorial Shri

Hari Parmarth Dham Trust Vs. CIT reported in [(2008) 299 ITR (AT) 161

(Delhi)(SB]. In the above order it has been held that if the order is passed by

CIT within 6 moths of receipt of application in form 10A, u/s 12A, it is deemed

14

that it stand allowed. The order passed by Commissioner refusing registration

was treated as a ‘nullity’ liable to be quashed. Thus, registrat ion was deemed to

be granted ‘as applied for by the assessee’. In this case also, similar situation

has occurred. The only difference is that the Commissioner has registered the

Insti tution but w.e.f. 1.4.2005, ignoring the date of registration given in the

Form No. 10A. The ratio of the above Tribunal order of the Special Bench the

application is ‘deemed allowed’ as applied for by the assessee. Since the

assessee had applied to get registration from the date of its inception, it is

wrong and i llegal to allow the same w.e.f. 1.4.2005 under this deeming

provision. This registration has to be treated to have been granted w.e.f. the

date of its inception i.e. 9.11.1985. Accordingly, we direct the Commissioner

to grant registration to the appellant w.e.f. 09.11.1985, which already deemed to

have been granted. In view of our above finding, the other appeal would be of

academic interest only.

12. In the result, both the appeal stands allow.

(Order Pronounced in the Open Court on 19.12.2012 )

Sd/- Sd/-

(N.K.SAINI) (HARI OM MARATHA)

JUDICIAL MEMBER ACCOUNTANT MEMER

Dated : 19t h

December, 2012

Rkk

Copy to:

1. The Appellant

2. The Respondent

3. The CIT

4. The CIT(A)

5. The DR

By Order

Assistant Registrar

ITAT, Jodhpur

15