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National Crime Investigation Bureau v. Commissioner Of Income Tax (Exemption), New Delhi .

Income Tax Appellate Tribunal
Feb 27, 2020
Judgment
Subsequent
References
CaseIQ
Case Information
CITATION CODES
citation codes
CASE NO.

ITA No. 4756 & 4757/Del/2018 Assessment Year: N.A.

Attorney(S)

None, ;

Shri Manoj Kumar, CIT-D.R.,

JUDGES

Bhavnesh Saini, J.M.

O.P. Kant, A.M.

ACTS

section 2(15) of the Income Tax Act, 1961

u/s 12AA & 80G of the Income Tax Act, 1961.

Indian Trust Act or the Income Tax Act,

u/s 12AA(a) of the Income Tax Act, 1961,

Reserve Bank of India & FCRA Act. (vii)

Use) Act, 1950,

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Smart Summary (Beta)

Structured Summary of the Opinion — ITA Nos. 4756 & 4757/Del/2018

Factual and Procedural Background

The appeals arise from a common order dated 27/04/2018 of the Learned Commissioner of Income Tax (Exemptions), New Delhi, which rejected the registration of the assessee trust under section 12AA and under section 80G of the Income Tax Act, 1961. The assessee filed applications in Form No.10A (for registration u/s 12AA) and Form No.10G (for registration u/s 80G) on 17/10/2017. The Ld. CIT(E) sought details of objects and activities, and after verification concluded that the trust's objects were not charitable and activities were not genuine, citing several inconsistencies and concerns. The CIT(E) rejected registration under 12AA and, as a consequence, also rejected the application under section 80G.

The assessee filed extensive grounds of appeal (lengthy grounds in both appeals) and supplied a paper book and an application for additional evidence. On the scheduled hearing date (22/01/2020) the assessee failed to appear and did not seek an adjournment; the Tribunal proceeded to hear the appeal ex parte. The Tribunal considered the trust deed, the applications, the paper book, submissions of the Revenue's representative and the material on record, and ultimately dismissed both appeals on 27/02/2020.

Legal Issues Presented

  1. Whether the objects and activities of the assessee trust qualify as "charitable purpose" and "general public utility" under the Income Tax Act (notably the inclusive definition in section 2(15)), so as to merit registration under section 12AA.
  2. Whether the trust's application for registration under section 80G should be allowed where registration under section 12AA was rejected.
  3. Whether the existence of the trust at the stated registered address and the genuineness of its activities and accounts were satisfactorily established.
  4. Whether alleged procedural irregularities (such as shifting registered office using supplementary deeds/resolutions) or accounting practices (cash expenses, omitted office rent, unspecified website costs) undermine the claim to registration.
  5. Whether the absence of FCRA registration/permission affects the trust's entitlement when the trust indicated an intention to receive foreign funds.

Arguments of the Parties

Appellant's Arguments (summary of grounds of appeal)

  • The existence of the trust at the given Delhi address is established (letters were delivered) and the procedure adopted to change registered office (supplementary trust deed & board resolution) should be valid in absence of a prescribed statutory amendment procedure.
  • The CIT(E) ignored and overlooked the trust's submissions and relied on assumptions or opinions; no particular instance of unlawful activity was pointed out by the CIT(E). The trust submitted proof of activities (photographs with government officials, appreciation letters, newspaper articles, bills & vouchers) which were not adequately considered.
  • The trust's activities (crime investigation assistance among other social activities such as blood donation, relief distribution, anti-corruption awareness) fall within the inclusive definition of "charitable purpose" under section 2(15) and amount to general public utility, and the trust is not operating commercially.
  • Accounts, income & expenditure and balance sheet were presented and the expenses (including website costs) were accounted for; many small payments were necessarily made in cash and that does not undermine genuineness of activities. The basic test for registration is genuineness of activities, not mode of payment.
  • Payments to Ms. Nirmala Kumari (Rs. 76,594) were claimed as financial assistance to a volunteer for out-of-pocket expenses; contention that she is director of another company does not invalidate the payment, and no opportunity of hearing was given to clarify this point.
  • Reference to FCRA provisions by the CIT(E) was improper since the trust did not receive foreign contributions and it was impractical for the trust to obtain FCRA permission for the nature of funding claimed.
  • The trust contended that all requirements of section 12AA are fulfilled and it should be considered eligible for registration under sections 12AA and 80G.

Revenue / Learned CIT(E)'s Findings (as recorded in the order)

  • The first object in the trust deed (clause 5(a)) expressly contemplates collecting donations from government and abroad and contains language and objectives that indicate the trust intends to perform crime investigation-type functions ("Anti Corruption Help govt. of India & State Govt., ... Crime & corruption Investigation Bureau ... take immediate actions against corruption and illegal works under Indian Penal Act"), which the CIT(E) held cannot be regarded as charitable in nature.
  • The trust appears to be running a crime investigating agency parallel to official state and central investigative agencies and has created an appearance (name, logo, designations such as Director General, Zonal Director) that may mislead the public into thinking it is a law-enforcing authority.
  • The trust's website and photographs show multiple plush offices across India (eight offices claimed). The balance sheet does not reflect the costs associated with the website, offices, events, rentals, furniture and fixtures; explanations were sought but no reply was furnished.
  • Many expenses were in cash and the bills and vouchers "don't inspire confidence"; overall the genuineness of accounts and activities was not established.
  • Payments shown as financial assistance to volunteers included an amount paid to Ms. Nirmala Kumari; internet inquiries showed she and the managing trustee are directors of a private company (NCIB News Network Pvt Ltd), undermining the claim that the payment was to a person with no source of livelihood.
  • The trust indicated intention to obtain funds from abroad but did not show FCRA permission; absence of such permission was noted as relevant.
  • On these bases the CIT(E) rejected registration under section 12AA and, since registration under section 12AA was refused, also rejected the application under section 80G.

Table of Precedents Cited

No precedents were cited in the provided opinion.

Court's Reasoning and Analysis

The Tribunal's analysis proceeded from the material on record: the trust deed (pages 3–24 of the paper book), the applications in Form 10A/10G, the additional submissions and the record of proceedings before the Ld. CIT(E). The Tribunal accepted the Ld. CIT(E)'s factual findings and reasoning for the following principal reasons (as expressly recorded):

  1. The text of the primary object (clause 5(a)) in the trust deed expresses activities that are investigatory and enforcement-oriented (references to crime investigation under the Indian Penal Code and to "Anti Corruption Help" and a Crime & Corruption Investigation Bureau). Such objects, the Tribunal agreed with the CIT(E), cannot be termed charitable within the meaning of section 2(15) and the inclusive definition of "charitable purpose". The Tribunal concluded that the object indicates an intention to set up an agency parallel to official investigative agencies.
  2. The trust's external presentation (name, logo that resembles police insignia, use of ranks/titles such as Director General, Zonal Director, etc.) could create a false impression among the public that it is a government law-enforcing authority; the potential for misuse of such appearance must be borne in mind when considering registration under section 12AA.
  3. The website and photographic material showed multiple well-appointed branch offices across India; the balance sheet and accounts did not disclose corresponding costs for website creation, offices, events, rentals, furniture and fixtures. The CIT(E) asked for explanations (including an opportunity to explain alleged omissions) and not having received satisfactory explanations or replies, the Tribunal found the accounts and the genuineness of activities unsubstantiated.
  4. Many expenses were found to be in cash and the accompanying vouchers and bills were described as not inspiring confidence by the CIT(E). The Tribunal accepted that finding as one factor undermining the credibility of the accounts.
  5. The payment described as financial assistance to volunteers (notably Rs.76,594 to Ms. Nirmala Kumari) was contradicted by internet evidence indicating that she and the managing trustee were directors of a private company, which called into question the assertion that the payments were to indigent volunteers; the Tribunal found this materially inconsistent with the trust's stated account.
  6. The trust stated an intention to obtain funds from abroad but had not shown FCRA permission; the absence of FCRA registration/permission was noted by the CIT(E) and taken into account by the Tribunal.
  7. The Tribunal also noted procedural posture: the assessee did not appear at the hearing despite being given opportunity and the appeal was therefore heard ex parte with regard to the assessee. The Tribunal therefore relied on the record and the CIT(E)'s findings to reach its conclusion.
  8. Weighing these findings together, the Tribunal concluded that the CIT(E)'s determination — that the objects and activities were not charitable and that the accounts and activities were not satisfactorily substantiated — was justified on the record before it.

Holding and Implications

Final Holding: The Tribunal upheld the rejection of the trust's applications: the appeals are dismissed and the orders of the Learned Commissioner of Income Tax (Exemptions) rejecting registration under section 12AA and rejecting registration under section 80G are affirmed.

Direct implications: As a direct consequence of this decision, the assessee trust remains unregistered under section 12AA and is denied registration under section 80G; therefore it will not be entitled to the tax registrations/exemptions that flow from such registrations and donors will not be entitled to 80G benefits in respect of donations to the trust.

Broader implications / precedent: The Tribunal's decision in this opinion rests on the facts and material on record (trust deed wording, website and photographic evidence, accounting inconsistencies, unexplained expenses, payments to persons shown to be company directors, absence of FCRA permission and the trust's failure to respond). The opinion does not state or establish any new principle of law beyond applying the statutory tests for charitable status under the Income Tax Act to the particular facts; the order therefore affirms the application of established administrative and evidentiary considerations when determining eligibility for registration under section 12AA and consequent 80G relief.

Order pronounced on 27th February, 2020. Bench: (Bhavnesh Saini) Judicial Member; (O.P. Kant) Accountant Member.

Show all summary ...

PER O.P. KANT, AM: These two appeals by the assessee are directed against a common order dated 27/04/2018 passed by the Learned Commissioner of Income Tax (Exemptions), New Delhi, rejecting the registration of the assessee trust under section 12AA of the Income Tax Act, 1961 (in short the Act) and 80G of the Act respectively. Appellant by -None- Respondent by Shri Manoj Kumar, CIT-D.R. Date of hearing 22.01.2020 Date of pronouncement 27.02.2020 ITA Nos.4756 & 4757/Del/2018

2. The assessee has raised very detailed and lengthy grounds of appeal. In ITA No. 4757/Del/2018 grounds are running in 10 Para of legal size pages, which have been further summarised in three pages. The summarised grounds are reproduced as under:

9. To summarize, the appellant hereby raises the following grounds of objection:

(i) That on the basis of facts & circumstances of the case, the erred in holding that the existence of trust in the state of Delhi is not established. As the existence of the trust at the address given in application is clearly established by the fact that all the letters sent by O/o CIT(E) are duly delivered at the given address. The O/o CIT(E) accepted the application after thorough scrutiny of documents submitted. Since, no procedure for amendment of trust, enumerated by the Indian Trust Act or the Income Tax Act, the procedure followed by trustees by way of execution of supplementary trust deed & board resolution should be treated as valid. The O/o CIT(E) Lucknow referred the said application to CIT(E), Delhi & no reply has been given by latter. The genuineness of the activities of the appellant trust cannot be regarded as doubtful merely because of any procedural lapses in shifting of its registered office.

(ii) That on the basis of facts & circumstances of the case, the CIT(E) has erred in completely ignoring & overlooking the submissions made by the Trust. Most of the grounds of rejection are mere Opinion or assumptions of Honble CIT(E) or in the form of allegations that the main purpose of the Trust is to establish itself as a shadow of crime investigation agency of Government, the activities undertaken by the trust are exclusively in the domain of enforcement ITA Nos.4756 & 4757/Del/2018 agencies or police, the name of the trust resemble to that of any legally authorized Govt. Agency, the trust may create an impression that it is a law enforcing Authority, the applicant is trying to create an impression in general public that they are working as Govt. Agency, the logo of appellant trust resembles with the logo of Police Authorities, the designations created by trust creates a false impression that the applicant is authorized by law to function as a law enforcing authority, the potential of misuse of registration u/s 12AA, even if the same is not actually misused is also to be borne in mind. However, nowhere in the order Hon'ble CIT(E) has stated any instances where the activities carried on by trust are found to be inappropriate, fraudulent & against any law applicable for the time being in force. The Hon'ble CIT(E) grossly ignored the proofs of activities submitted by appellant which are in the form of photographs with various Government officials, appreciation letters from senior Government officials including the offices of Chief Minister & Governor, newspaper articles, bills & vouchers, etc. With utmost respect we wish to state that the activities of the trust should not be declared as not genuine, merely on the basis of assumptions or opinion or suspicion where no contradictory evidence is available on records.

(iii) That on the basis of facts & circumstances of the case, the CIT(E) has erred in stating that the objects of crime investigation cannot be categorized as charitable act in the nature of General Public Utility. The intention of the trust is not to work on commercial basis which is proved from the fact that the trust has not received any consideration or reward from the Government but has actually received donation from a large number of persons from society who rely on the activities carried on by the trust. The trust's activities are ITA Nos.4756 & 4757/Del/2018 not only limited to crime investigation but also organizing blood donation camps, distribution of food & clothes, raising voice against corruption & crime, organizing peaceful protest & marches, spreading awareness about the rights & duties among the citizens & creating an environment for cooperation among police officials & public to reduce crime, reporting suspicious activities, etc. All these activities are in the nature of General Public Utility & for the gross benefit of society & each and every person living in it irrespective of their age, caste, religion, color & creed. The activities of the trust are in the nature of General Public Utility & qualify for registration u/s 12AA.

(iv) That on the basis of facts & circumstances of the case, the CIT(E) has erred in stating that the appellant trust has not given the true & full disclosure of the expenses incurred by it for carrying on its activities. The cost of website and other expenses incurred by trust are au y accounted for & Income & Expenditure Account & Balance Sheet are duly presented. The contention of Hon'ble CIT(E) that most of the expenses are made in cash & don't inspire confidence is not justifiable as the expenses so incurred in cash were not substantial but petty in nature & since the expenses were incurred on activities which are undertaken in different parts of the country, it is not possible for the appellant to have a bank account in each & every such state & also having regard to the amount paid, it was practically not possible to make payments by way of any mode other than cash. All the expenses which were actually incurred are accounted for & the trust has not accounted any such expense in respect of which no actual payment has been made. The basic condition of registration u/s 12AA is the genuineness of the activities & not the mode of expenses even when the proofs of actual occurrence of such activities are available on record. ITA Nos.4756 & 4757/Del/2018

(v) That on the basis of facts & circumstances of the case, the CIT(E) has erred in holding that the information given by trust in respect of payments made to Ms. Nirmala Kumari is invalid. The ground of rejection that Ms. Nirmala Kumari, a volunteer of trust to whom salary of Rs.76,594/- is paid by trust is a Director of some other company is not reasonable as nowhere in the order it is stated that the salary so paid was unreasonable or excess or there exists any material on record which contradicts the claim of the appellant trust that she works for the activities of the trust & has been paid for her out of pocket expenses only. Moreover, no opportunity of being heard was given by Hon'ble CIT(E) in respect of this ground of rejection to provide the necessary details & clarifications. Also, it is not clear as to how appointment of Ms. Nirmala Kumari as director of a company affects the genuineness of the activities of the trust.

(vi) That on the basis of facts & circumstances of the case, the CIT(E) has erred in referring to the provisions of FCRA Act as grounds of rejection. The fact that the appellant trust is not registered under FCRA does not holds any ground as it is impossible for appellant trust to get money in Foreign Currency in terms of the provisions laid down by the Reserve Bank of India & FCRA Act.

(vii) The appellant trust has carried on its activities genuinely for the benefit of the society & all the activities of the trust are within the scope of inclusive definition of "Charitable Purpose" as given in section 2(15) of the Income Tax Act, 1961 & since all the requirements of Section 12AA are fulfilled, the trust should be ITA Nos.4756 & 4757/Del/2018 considered as eligible for registration u/s 12AA & 80G of the Income Tax Act, 1961.

3. Similarly, lengthy and argumentative grounds have been raised in ITA No. 4756/Del/2018, which are running in four legal size pages. In the grounds, the assessee is mainly aggrieved with the rejection of grant of registration under section 80G of the Act.

4. At the outset we may like to mention that on the last date of hearing i.e. 19/11/2019, the case was adjourned to 22/01/2020 on the request of the Learned Counsel for the assessee. Despite notifying the date of the hearing, neither anyone attended before us on behalf of the assessee, nor any application for adjournment of the hearing was filed. In the facts and circumstances, we were of the opinion that the assessee is not interested in prosecuting its appeal and therefore, we heard the appeal ex-parte qua the assessee.

5. The facts in brief of the case are that the assessee trust filed applications on 17/10/2017 before the Learned Commissioner of Income Tax (Exemption) (in short the Ld. CIT(E)) in Form No. 10A and 10G seeking ITA Nos.4756 & 4757/Del/2018 registration under section 12AA and grant of registration under section 80G of the Act respectively. The Learned CIT(E) call for the details of the objects of the trust and the activities carried out by the trust. After verification of the objects and the activities, the Learned CIT(E) found that object of the trust are not charitable in nature and the activities are also found to be not genuine. The Learned CIT(E) has specifically referred to the first object of the trust as to collect offerings, gifts or donation of all kinds from Central Government, Semi government, all institutions, local bodies or industrial concern, Ltd or private locally within the Union of India or from abroad. The Learned CIT(E) has observed that the assessee has created a facade by way of its appearance to create an impression in the mind of the general public as if they are working as government agency. The Learned CIT(E) has observed various inconsistencies in the accounts maintained by the assessee trust. For example, not accounting of the rent and office expenses of various offices across the India and salary expenses to Ms. Nirmala Kumari etc. ITA Nos.4756 & 4757/Del/2018

6. Finally, the Learned CIT(E) rejected the registration under section 12AA and under section 80G of the Act observing as under:

8. As discussed in detail above, the proposed activities cannot be termed to be charitable in nature. Here it is also to be mentioned that the applicant intend to get funds from abroad but no FCRA permission has been shown. The existence of applicant on the given address is not substantiated to the satisfaction. The expenses are not found duly accounted for and the applicant failed to furnish explanation in this regard. Most of the expenses are made in cash and their Bills and Vouchers dont inspire confidence. The so called employee of the applicant is a director of M/s NCB, News Network Pvt Ltd, a Pvt Ltd Company along with the managing Trustee of the applicant, Mr. Suresh Kumar Shukla. Therefore, neither objects of the Trust nor are activities of the trust substantiated to be charitable in nature. Accordingly, the application filed by the applicant for grant of registration u/s 12A is rejected.

9. Since the applicant is not granted registration u/s 12AA(a) of the Income Tax Act, 1961, its application if Form No.10G seeking exemption u/s 80G is also hereby rejected as charitable activities are not established.

7. Before us, the assessee has filed a paper book containing pages 1 to 37, which consist of copy of applications in form No. 10A and 10G and other submissions filed before the Ld CIT(E ). The assessee has also filed an application for additional evidence having pages 1-12 consisting of a copy of the Emblems and Names (Prevention of Improper Use) Act, 1950, list of tax exempted institution registered under section 12A or 80G ITA Nos.4756 & 4757/Del/2018 or both as per Income-tax website, definition of Director General as per Oxford dictionary, Cambridge English dictionary and Wikipedia, and the screenshot from appellants website.

8. We have heard submission of the Learned DR and perused the material on record. We find from the pages 3 to 24 of the paper book, which is a copy of the trust deed of the assessee trust, that its objects have been bifurcated in the nature of the education, relief to poors, medical relief, and object of general public utility. The first object of the assessee appearing in clause 5(a) is reproduced as under: a. To collect offerings, gift or donations of all kinds, whether from Government, Central or Semi-Government, all institutions, local bodies or industrial concern, limited or private, locally within the Union of India or froma broad, which will form part of the funds, available to the Trust whether the bodies are located in the union of India or abroad and Anti Corruption Help govt. of India & State Govt., Electronic Media, Print Media & Social work card. Issue all Department Crime & corruption Investigation Bearou take immediately actions, against corruption, and illegal works under Indian Penal Act.

9. We are agreed with the finding of the Learned CIT(E) that above object cannot be called as charitable in nature. From other objects and activities, it appears that the assessee is running a crime investigating agency ITA Nos.4756 & 4757/Del/2018 parallel to the investigative agencies of the state and central government. The Learned CIT(E) has also pointed out following inconsistencies or discrepancies in the accounts and the activities of the assessee. The relevant finding of the Learned CIT(E) are reproduced as under:

4. Many of the objects including the above mentioned in the trust deed indicate that the main purpose of the Trust is to establish itself as a shadow or parallel of the crime investigation agencies by Govt and the Police of the country. These activities which are exclusively in the domain of enforcement agencies or police by virtue of powers conferred by the law or constitution of India are claimed to be carried out by the applicant where no legal authority is displayed. It is also noted that there is an uncanny resemblance of the name of the applicant to any legally authorized Govt Agency to investigate crime. To the minds of unsuspecting general public the name of the applicant may create an impression that it is a law enforcing Authority acting on behalf of the Govt. The applicant has tried its best on its part to create such a faade by way of its appearance so as to create an impression in the mind of general public a if they are working as Govt. Agency. This is apparent from the website www.ncib.in public as if they are working as Govt. Agency. This is apparent from the website www.ncib.in From the above website, it may be seen that the logo of the applicant has also clear resemblance with the logo of Police Authorities. The posts created by the a shown on the website is Director General, Asst. Director General, Zonal Director, State director etc. This also creates a false impression that the applicant is authorized by law to function as a Law Enforcing Authority. It is stated that the registration of a charitable institutions is not an idle formality, it is necessary to come to the conclusion on the basis of documents information etc whether the institution deserves registration u/s 12AA of the Act. The potential of misuse, even if the same is not actually misused is also be borne in mind while granting registration u/s 12A of the Act. Moreover, the above objects of the applicant cannot be categorized as charitable activity within the meaning of general public utility as defined in sectio cannot be camouflaged as charitable activity in the nature of general public utility.

5. The website of the applicant also shows that it has got 8 offices across the country. the name and place of its registered office and the office which it is presently claimed to be the registered office is not show in the website. The offices ITA Nos.4756 & 4757/Del/2018 n 2(15) of the Act. These types of activities pplicant as ITA Nos.4756 & 4757/Del/2018 are located at Delhi (some other address), Gujarat, Bihar, Ahmednagar, Bangalore, Rajasthan, Jharkhand & madhya Pradesh. From photographs of some of the offices shown in the website it is seen that these are well maintained plush offices with split air conditions and glass doors baring logo of the applicant. Further there are video gallery/ photographs of various events conducted by the applicant claiming to the police-public partnership program. On 20.04.2018, the AR of the applicant, Mr Ankit Gupta was shown the website of the NCIB. It was asked that the cost of website creation, which appears to be a costly website, does not appear in the balance sheet. Further there are several plush branch offices of the applicant located across the country. Their cost, cost of events, rentals, furniture and fixtures are not found shown in the balance sheet. The AR of the applicant was asked to explain the same by 24.04.2018. However, no reply has been received from the applicant till the date of passing of this order. As such the applicant has failed to justify the source of the expenses incurred by it in establishing the offices, conducting its activities and various events. Thus not only the genuineness of the accounts submitted by the applicant during the course of the proceedings but also the genuineness of the activities of the Trust remains un-established.

6. In a statement of financial assistance given to volunteer as salary filed by applicant during the course of proceedings, it is seen that the applicant has made payment of Rs.76,594/- to Ms. Nirmala Kuamri. In the footnote it is mentioned that the above amount is in the nature of financial assistance given to volunteers who belong to poor and needy family. All these persons have no source of living but as a result of atrocities which they or their family members had faced, they are self-motivated to work towards the upliftment and betterment of the society. The Trust gives them the financial assistance to cover their conveyance expenses, footing and other necessary expenses. However on inquiry from Internet, it is found that Mr Suresh Kumar Shukla and Ms Nirmala Kumari are Directors in a Pvt Ltd company namely NCIB News Network Pvt Ltd. As such ITA Nos.4756 & 4757/Del/2018 the statement made by the applicant that the payment is made to a volunteer as salary to persons who have no source of living is incorrect.

10. In view of the above facts and circumstances, we do not find any merit in the grounds raised by the assessee and accordingly we uphold the rejection of applications under section 12AA and 80G of the Act.

11. In the result, both appeals of the assessee are dismissed. Order pronounced in the open court on 27th February, 2020 Sd/- Sd/- (BHAVNESH SAINI) (O.P. KANT) JUDICIAL MEMBER ACCOUNTANT MEMBER Dated: 27th February, 2020 Priti/-(D.T.D.S.) Copy forwarded to:

1. Appellant

2. Respondent

3. CIT

4. CIT(A)

5. DR Asst. Registrar, ITAT, New Delhi ITA Nos.4756 & 4757/Del/2018 Sl. No. Particulars Date

1. Date of dictation (Order drafted through Dragon software): 26.02.2020

2. Date on which the draft of order is placed before the Dictating Member: 26.02.2020

3. Date on which the draft of order is placed before the other Member: 27.02.2020

4. Date on which the approved draft of order comes to the Sr. PS/PS: 27.02.2020

5. Date of which the fair order is placed before the Dictating Member for pronouncement: 27.02.2020

6. Date on which the final order received after having been singed/pronounced by the Members: 27.02.2020

7. Date on which the final order is uploaded on the website of ITAT: 27.02.2020

8. Date on which the file goes to the Bench Clerk 27.02.2020

9. Date on which files goes to the Head Clerk:

10. Date on which file goes to the Assistant Registrar for signature on the order:

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